Rulemaking Process Overview 

Kickoff Workshop (Today) 

Test procedure Preparation 

Workshop on NOPRs, October 1998 

* Publication of NOPRs, March 1999 

Public Comment and Hearing, May 1999 

Extra Workshop if Necessary, TBD 

Final Rules, January 2000 

 EE-RM-98-101 COMMENT 02DD

Rulemaking Process Overview 

• Kickoff Workshop (Today) 

• Test procedure Preparation 

• Workshop on NOPRs, October 1998 

• Publication ofNOPRs, March 1999 

• Public Comment and Hearing, May 1999 

• Extra Workshop if Necessary, TBD 

• Final Rules, January 2000 
COMMERCIAL EQUIPMENT 

Qtr 1,1998 / Qtr 2.1998 I Qtr 3,1998 1 Qtr4.1998 1 Qtr 1.1999 I Qtr 2,1999 1 Qtr 3,1999 I Qtr 4,1999 1 Qtr 1.2 . ID Task Name Jan I Feb I Mar I Apr I May I Jun / Jul 1 Aug ] Sep I Oct 1 Nov I DeC 1 Jan I Feb I Mar I Apr 1 May I Jun I Jul I Aug I Sep I Oct I Nov 1 Dec I Jan I Feb' 

v 2 Protocol and Mln. Energy Stds. 4 

3 Opt~ons 

- 

and ARematives -JNIST 

4 Rule Language 

Optlons 

P 

and 

P 

ABematlves 

' 

 EE-RM-98-101 COMMENT 02DD

-

'I 

COMMERCIAL EQUIPMENT 

Qtr 1, 1998 I Qtr 2, 1998 I Qtr 3, 1998 I Qtr 4, 1998 Qtr 1, 1999 I Qtr 2, 1999 I Qtr 3, 1999 1 Qtr 4, 1999 ·1 Qtr 1, 2 

10 Task Name Jan I Feb I Mar I Apr I May I Jun I Jul I Aug I Sep I Oct I NovJ Dec Jan JFeb] Mar] Apr May Jun L Jut j Aug Sep I Oct I Nov I Dec I Jan I Feb 

1 Test Procedure Preparation 

2 Protocol and Min. Energy Stds. 

3 Options and Attematives 1NIST' 

4 Rule Language ''r-------' NIST 

5 Sampling 

6 

7 

~ ____ t-______ O~p_ti_o_nS __ an_d_A_tt_e_m_a_t_N_es ________ {-------JNIS~ 

Rule Language L 

8 

9 

; 

10 

11 

12 I 

13 Workshops 

14 Options and Alternatives 

15 

16 

1----+----------------- Draft Announcement PDOE/' CS l 

Announcement Concurrence I b DOEI 

17 

18 

Logistical Arrangements r---n,DOE Iocs 

Workshop Session -4/1' 

19 TranSCript, DOE Response an : 0 DOE/OCS 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

NOPR Language 

Draft Announcement 

Announcement Concurrence 

Logistical Arrangements 

Workshop Session 

Transcript, DOE Response an 

Final NOPR (optional) 

Draft Announcement 

Announcement Concurrence 

Logistical Arrangements 

Workshop Session 

Transcript, DOE Response an 

Public Comment 

Regulatory Hearing 

Transcript and Comments Mgmt. 

35 Rule Preparation 

36 NOPR 

31 Initial Draft 

38 Preamble 

39 Rule 

40 DOE Concurrence 

41 OCS 

----_·_----------1 Policy/Legal 

1---

42 

43 EE·' 

44 Publication of NOPR 

45 Final Rule 

46 Revision 

47 DOE Concurrence 

48 OCS 

49 Policy/Legal 

50 EE·' 

51 Publication of Final Rule 

• 

DOE/OCS 

I 

; 

. 

. 

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NIST I . 

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.1/5 
Requirements For 

Commercial Products 

Energy Policy Act of 1992 (EPACT) 

- Standards 

- Test Procedures 

- Labeling 

Covered Products 

- Furnaces and Boilers 

- Water Heaters 

- Air Conditioners and Heat Pumps 

Other DOE Requirements 

- Certification & Compliance Testing 

- Enforcement Testing 

Standards Effective January 1, 1994 

 EE-RM-98-101 COMMENT 02DD

Requirements For 

Commercial Products 

Energy Policy Act of 1992 (EP ACT) 

- Standards 

- Test Procedures 

- Labeling 

• Covered Products 

- Furnaces and Boilers 

- Water Heaters 

- Air Conditioners and Heat Pumps 

• Other DOE Requirements 

- Certification & Compliance Testing 

- Enforcement Testing 

Standards Effective January 1, 1994 
Commercial Water Heaters 

Clarification of Coverage 

- Interpretation of Table 1 1.1 in ASHRAE 90.1 

- Packaged Boiler or Water Heater? 

Standby Loss Testing 

- Determination of Requirements 

Unfired Storage Tanks 

- Test Procedure for Determining Heat Loss 

 EE-RM-98-101 COMMENT 02DD

Commercial Water Heaters 

• Clarification of Coverage 

- Interpretation of Table 11.1 in ASHRAE 90.1 

- Packaged oiler or Water Heater? 

• Standby Loss Testing 

- Determination of Requirements 

• Unfired Storage Tanks 

- Test Procedure for Determining Heat Loss 
Commercial Water Heater Issues 

* Clarification of Coverage 

- Interpretation of Table 1 1.1 of ASHRAE 90.1 - 1989, Addendum b 

- Commercial Water Heater or Packaged Boiler? 

Standby Loss Testing 

- Determination of SL requirements 

Unfired Storage Tanks 

- Test procedure for determining heat loss 

 EE-RM-98-101 COMMENT 02DD

Commercial Water Heater Issues 

• Clarification of Coverage 

- Interpretation of Table II.lof ASHRAE 90.1-1989, Addendum b 

- Commercial Water Heater or Packaged Boiler? 

• Standby Loss Testing 

- Determination of SL requirements 

• Unfired Storage Tanks 

- Test procedure for determining heat loss 
Clarification of Coverage 

General Issues 

Would it be beneficial to develop a table similar to 7.2.2 of 

ASHRAE Standard 90.1R? 

- Address only EPAct-covered products 

- Clarify lower limits of coverage 

- Stand on its own 

Should references in Table 1 1.1 to ANSI 22 1.10.3- 1990 be 

updated to the 1993 version of the standard? 

- Thermal efficiency and standby loss test procedures unchanged 

from 1990 version 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

General Issues 

• Would it be beneficial to develop a table similar to 7.2.2 of 

ASHRAE Standard 90.1R? 

- Address only EP Act-covered products 

- Clarify lower limits of coverage 

- Stand on its own 

• Should references in Table 11.1 to ANSI Z21.10.3-1990 be 

updated to the 1993 version of the standard? 

- Thermal efficiency and standby loss test procedures unchanged 

from 1990 version 
Clarification of Coverage 

Electric S torarre Water Heaters 

an input-to-wlume ratio less than 1.17 k W/galfon. 

Should Table 1 1.1 be clarified to indicate that electric water heaters 

covered under the category of "Other Water Heating Equipment" have 

an input-to-volume ratio < 4,000 B tulhlgal as defined by EPAct? 

ANSIZ21.10.3-1993 

- Scope: Input > 75 kBtu/h (22 kW) 

- Any reason why the SL test procedure should not apply to Electric Storage 

Water Heaters with inputs between 12kW and 22kW? 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

Electric Storage Water Heaters 

Equipment Type Input Rating Input-to-Volume Sub-category or Periormance 

Ratio Rating Condition Required 

Electric Storage < 4,000 Btu/h/gal rtr --- >12kW Water Heaters (1.17 kW/gal) SL 0.3 + 27/V 

* Test procedure can be applied to all electric storage water heaters with Input ratings greater than 12kW and 

an input-to-\Qlume ratio less than 1.17 kW/galion. 

Test Procedure 

ANSI* 

Z21 .10.3-1993 

• Should Table 11.1 be clarified to indicate that electric water heaters 

covered under the category of "Other Water Heating Equipment" have 

an input-to-volume ratio < 4,000 Btulh/gal as defined by EPAct? 

• ANSI Z21.10.3-1993 

Scope: Input> 75 kBtulh (22 kW) 

Any reason why the SL test procedure should not apply to Electric Storage 

Water Heaters with inputs between 12kW and 22kW? 
Clarification of Coverage 

Electric Instantaneous Water Heaters 

Electric Instantaneous 

Water Heaters 

Should Table 1 1.1 be clarified to directly address the category of 

electric instantaneous water heaters with the EPAct requirement for 

standby loss for instantaneous water heaters? 

- 12 kW lower limit on Input Rating 

- Input-to-Volume Ratio 2 4,000 Btu/h/gal 

ANSIZ21.10.3-1993 

- Scope: Input > 22 kW (75 kBtu/h) 

- Any reason why the test procedure should not apply to Electric 

Instantaneous Water Heaters with inputs between 

12 kW (41 kBtu/h) and 22 kW? 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

Electric Instantaneous Water Heaters 

Equipment Type Input Rating Input-to-Volume Sub-category or Performance 

Test Procedure Ratio Rating Condition Required 

V<10gal flT 800/0* 

Electric Instantaneous ~ 4,000 Btuth/gal SL --- ANSI 

>12kW Water Heaters (1.17 kW/gal) 1lT 77%* Z21.10.3 .. 1993 

V ~ 10 gal SL 2.3 + 67/V 

• Should Table 11.1 b~e clarified to directly address the category of 

electric instantaneous water heaters with the EP Act requirement for 

standby loss for instantaneous water heaters? 

12 kW lower limit on Input Rating 

- Input-to-Volume Ratio > 4,000 Btu/hlgal 

• ANSI Z21.10.3-1993 

Scope: Input> 22 kW (75 kBtulh) 

Any reason why the test procedure should not apply to Electric 

Instantaneous Water Heaters with inputs between 

12 kW (41 kBtulh) and 22 kW? 
Clarification of Coverage 

Gas-fired S torarre Water Heaters 

Gas-fired Storage 

Water Heaters 

I 

Should Table 1 1.1 be clarified to indicate that the ANSI test procedure 

should be applied to gas storage water heaters with 

- input ratings > 75,000 Btuh and 

- input-to-volume ratios < 4,000 Btu/h/gal? 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

Gas-fired Storage Water Heaters 

Equipment Type Input Rating Input-to-Volume Sub-category or Performance 

Ratio Rating Condition Required 

> 75,000 Btuth and llT 78% 

Gas-fired Storage ~ 155,000 Btu/h SL 1.3 + 1141V 

Water Heaters < 4,000 Btuth/gal 

> 155,000 Btuth llT 78% 

SL 1.3 + 951V 

Test Procedure 

ANSI 

Z21.10.3-1993 

• Should Table 11.1 be clarified to indicate that the ANSI test procedure 

should be applied to gas storage water heaters with 

input ratings> 75,000 Btu/h and 

- input-to-volume ratios < 4,000 Btuth/gal? 
Clarification of Coverage 

Gas-fired Instantaneous Water Heaters 

Gas Instantaneous 

Water Heaters 

Should Table 11.1 be clarified to indicate that gas-fired instantaneous 

water heaters with input ratings > 200,000 B tulh are EPAct-covered 

products? 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

Gas-fired Instantaneous Water Heaters 

Equipment Type Input Rating Input-to-Volume Sub-category or Performance 

Test Procedure Ratio Rating Condition Required 

V < 10 gal rtr 80% 

Gas Instantaneous SL --- ANSI 

> 200,000 Btu/h ~ 4,000 Btu/h/gal Water Heaters rtr 77% Z21.10.3-1993 V~10gal 

SL 2.3 + 67/V 

• Should Table 11.lbe clarified to indicate that gas-fired instantaneous 

water heaters with input ratings> 200,000 Btulh are EPAct-covered 

products? 
Clarification of Coverage 

Oil-fired Instantaneous Water Heaters 

V< 10 gal T 80% 

Oil Instantaneous SL --- 

> 21 0,000 Btufh 2 4,000 Btufhfgal ANSI 

Water Heaters T 77% 221.10.3-1993 

V 2 10 gat SL 2.3+67/V - 

Should Table 1 1.1 be clarified to indicate that oil-fired instantaneous 

water heaters with input ratings > 2 10,000 B tu/h are EPAct-covered 

products? 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

Oil-fired Instantaneous Water Heaters 

Equipment Type Input Rati ng Input-to-Volume Sub-category or Performance 

Test Procedure Ratio Rating Condition Required 

V < 10 gal 'flT 80% 

Oil Instantaneous SL --- ANSI 

Water Heaters > 210,000 Btu/h ~ 4,000 Btu/h/gal 121.10.3-1993 

V ~ 10 gal 'flT 77% 

SL 2.3 + 67/V 

• Should Table 11.1 be clarified to indicate that oil-fired instantaneous 

water heaters with input ratings> 210,000 Btulh are EPAct-covered 

products? 
Clarification of Coverage 

Commercial Water Heater or Packaged Boiler? 

To what extent is equipment that heats water used for purposes that are 

different from those anticipated at the time of manufacture? 

For example: 

products that are designed to provide space heating are used to provide 

service water heating 

How can EPAct efficiency requirements and test procedures be applied 

to these products? 

Should similar efficiency requirements and test procedures be 

applicable to EPAct-covered products used, or that can be used, to 

provide service water heating regardless of design intent? 

Which test procedure, if any, should be used to test boilers as 

commercial water heaters? 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage 

Commercial Water Heater or PackaQ:ed Boiler? 

'-" 

• To what extent is equipment that heats water used for purposes that are 

different from those anticipated at the time of manufacture? 

For example: 

products that are designed to provide space heating are used to provide 

service water heating 

• How can EP Act efficiency requirements and test procedures be applied 

to these products? 

• Should similar efficiency requirements and test procedures be 

applicable to EPAct-covered products used, or that can be used, to 

provide service water heating regardless of design intent? 

• Which test procedure, if any, should be used to test boilers as 

commercial water heaters? 
Standby Loss Testing 

Not required for storage water heaters, instantaneous water 

heaters or unfired hot water storage tanks having 

- storage capacities greater than 140 gallons, 

- tank surface insulated to R- 12.5, and 

- no standing pilot light 

Tank Surface Insulation 

- Should the R-value be considered and effective R-value? 

- What calculation method should be used to determine the 

"effective" R-value in order to verify whether an item is exempt 

from testing for standby loss? 

 EE-RM-98-101 COMMENT 02DD

Standby Loss Testing 

• Not required for storage water heaters, instantaneous water 

heaters or unfired hot water storage tanks having 

- storage capacities greater than 140 gallons, 

- tank surface insulated to R-12.5, and 

- no standing pilot light 

• Tank. Surface Insulation 

- Should the R-value be considered and effective R-value? 

- What calculation method should be used to determine the 

"effective" R-value in order to verify whether an item is exempt 

from testing for standby loss? 
Unfired Storage Tanks 

Maximum HL Requirement 

- 6.5 Btuh per square foot of tank surface area 

- Applies to unfired storage tanks 

V I 140 gallons 

* V > 140 gallons and insulated to < R-12.5 

Test Procedure 

- What test procedures are available for use in determining HL per 

square foot of tank surface area? 

- If procedures exist, then which should DOE require? 

- Is a new procedure required? 

 EE-RM-98-101 COMMENT 02DD

Unfired Storage Tanks 

• Maximum HL Requirement 

- 6.5 Btulh per square foot of tank surface area 

- Applies to unfired storage tanks 

• V < 140 gallons 

• V > 140 gallons and insulated to < R -12.5 

• Test Procedure 

- What test procedures are available for use in determining HL per 

square foot of tank surface area? 

- If procedures exist, then which should DOE require? 

- Is a new procedure required? 
Clarification of Coverage - Summary Table 

Water Heaters 

< 4,000 Btulhlgal Water Heaters 

Water Heaters 

Water Heaters 

Oil Instantaneous 

Water Heaters 

Unfired Hot Water 

* ANSI test procedure assumes qT of immersed electric heating elements to be 98%. 

* Water heaters and unfired storage tanks with storage capacities greater than 140 gal, tank surface area insulated to R-12.5, 

and no standing pilot light are not required to meet SL or HL. requirements. 

 EE-RM-98-101 COMMENT 02DD

Clarification of Coverage - Summary Table 

Equipment Type Input Rating Input-to-Volume Sub-category or Performance Test Procedure Ratio Rating Condition Required ,. 

Electric Storage >12 kW < 4,000 Btuth/gal flT --- ANSI 

Waler Heaters (1.17 kW/gal) SL 0.3+ 27N Z21.10.3-1993 

> 75,000 Btu/h and flT 78% 

Gas Storage ::; 155,000 Btu/h SL 1.3 + 114N ANSI 

Water Heaters < 4,000 Bluth/gal 

78% Z21.10.3-1993 > 155,000 Btulh flT 

SL 1.3 + 95N 

> 105,000 Btu/h and flT 78% 

Oil Storage s 155,000 Btuth SL 1.3 + 114N ANSI 

Water Heaters < 4,000 Btu/htgal 

78% Z21.10.3-1993 > 155,000 Btu/h flT 

SL 1.3 + 95N 

V < 10 gal flT 80%· 

Electric Instantaneous ?: 4,000 Bluth/gal SL --- ANSI 

> 12 kW 

Water Heaters (1.17 kW/gal) flT 77%' Z21.10.3-1993 

V?: 10 gal SL 2.3 + 67N 

V<10gal flT 80% 

Gas Instantaneous SL --- ANSI 

Water Heaters > 200,000 Btu/h ?: 4,000 Bluth/gal Z21.10.3-1993 

V?:10gal flT 77% 

SL 2.3 + 67N 

V < 10 gal flT 80% 

Oil Instantaneous SL -- ANSI 

Water Heaters > 210,000 Btu/h ?: 4,000 Bluth/gal Z21.10.3-1993 

V?: 10 gal 1lT 77% 

SL 2.3 + 67N 

Unfired Hot Water 

V S 140 gal 

HL ::; 6.5 Btulh/ff No lesl procedure Storage Tanks V> 140 gal and 

Rell < 12.5 

ANSI lest procedure assumes TjT of immersed electric heating elements to be 98%. 

Water heaters and unfired storage tanks with storage capacities greater than 140 gal, tank surface area tnsulated to R-12.5, 

and no standing pilot light are not required to meet SL or HL requirements. 
ASHRAE 90.1 b- 1992, Table 1 1.1 

gy Conservation Act (NAECA) of 1987. 

nd gas storage water heaters with rated volumes 220 gallons and gas instantaneous water heaters with 

rature difference. 

 EE-RM-98-101 COMMENT 02DD

ASHRAE 90.1b-1992, Table 11.1 

Input to Test Energy Thermal 

Standby Loss VT Ratio Efficiency 

Category Type Fuel Input Rating VT

h 

(Btuh/gal)h Method" Factor9 

Et% (oMhr)h 

NAECA aU ~Iectric ~ 12kW jail pOE Test ~O.93-0.00132V 

Covered storage gas ~75,OOO Btuh aile Procedure 1 0 ~O.62·0.0019V 

Water instantaneous gas ~OO,OOO BtuhC aU PFR, O.62-0.0019V 

Heatin~ storage oil f';105,000 Btuh jail Part 4302 0.59-0.0019V 

Equipt nstantaneous oil f:;210,OOO Btuh all ~0.59-0.0019V 

pool heater gas/ai/ a/l all ~NS' 221.56 ~7B 

198966 

IOther storage electric all all ~NSI ~0.30+27NT 

lWater ~21.10.3 

Heatin,p storagel gas/oil ~155,000 Btuh Iall I< 4,000 199065,9 ~78 ~1.3+114NT 

!equipt instantaneous > 155,000 Btuh jail < 4,000 i:': 7B ~1.3+95NT I< 10 ~ 4,000 ~80 -- ~10 ~ 4,000 277 b;Z.3+67NT 

Unfired jail ~6.5 Btuhlft" 

Storage 

tranks Note f 

~For detailed references see Section 14. 

"Consistent with National Appliance Energy Conservation Act (NAECA) of 1987. 

rDOE Test Procedures apply to electric and gas storage water heaters with rated volumes ~20 gallons and gas instantaneous water heaters with 

input ratings of 50,000 to 200,000 Btuh. 

~AII except those water heaters covered by NAECA. 

f\Nhen testing an electric storage water heater for standby loss using the test procedures of Section 2.9 of Z21.10.3-199065, the electrical supply 

~oltage shall be maintained within ±1 % of the center of the voltage range specified on the water heater nameplate. Also, when needed for 

!calculations, the thermal efficiency (EI) shall be 98%. 

!when testing an oil water heater using the test procedures of Section 2.8 and 2.9 of 221.10.3-199065, the following modifications will be made: 

A vertical length of flue pipe shall be connected to the flue gas outlet of sufficient height to establish the minimum draft specified in the 

manufacturer's installation instructions. All measurements of oil consumption will be taken by instruments with an accuracy of ±1% or 

better. 

The burner rate shall be adjusted to achieve an hourly Btu input rate within ±2% of the manufacturer's specified input rate with the CO2 

reading as specified by the manufacturer with smoke no greater than 1 and the fuel pump pressure within ±1 % of the manufacturer's 

specification. 

Heat loss of tank surface area (Btu/ft2) based on BO°F water-air temperature difference. 

~V is rated storage volume in gallons as specified by the manufacturer. 

tvT is the storage volume in gal/ons as measured during the test to determine standby loss. Vr may differ from V, but it is within tolerances allowed 

by the applicable 221 and UL standards. Accordingly, for the purpose of estimating the standby loss requirement using the rated volume shown on 

he rating plate, VT should be concerned as no less than O.95V for gas and oil water heaters and no less than 0.90V for electric water heaters. 
Commercial Boilers 

and Furnaces 

Definition of "Packaged Boiler" 

Thermal vs. Combustion Efficiency 

- Jacket Losses 

Uniformity of Test Conditions 

- Setup 

- Procedures 

Provisions for Unusual Design Features 

 EE-RM-98-101 COMMENT 02DD

Commercial Boilers 

and Furnaces 

• Definition of "Packaged Boiler" 

• Thermal vs. Combustion Efficiency 

- Jacket Losses 

• Uniformity of Test Conditions 

- Setup 

- Procedures 

• Provisions for Unusual Design Features 
Test Standards for Commercial 

Space Heating Equipment 

Four test standards referenced in ASHRAE 

90.1 -1 989 for packaged boilers 

- ANSI 221.13-1993a for gas-fired boilers 

- H 1 Standard - 1989 for oil and gas-fired boilers 

- UL 726- 1995 for oil-fired boilers 

- ASME PTC 4.1 for steam generating boilers (oil and gas) 

Two test standards referenced in ASHRAE 

90.1-1989 for warm air furnaces 

- ANSI 221.47 -1993 for Gas-fired furnaces 

- UL 727-1994 for oil-fired furnaces 

 EE-RM-98-101 COMMENT 02DD

Test Standards for Commercial 

Space Heating Equipment 

• Four test standards referenced in ASHRAE 

90.1-1989 for packaged boilers 

- ANSI Z21. 13-1993a for gas-fired boilers 

- H I Standard -1989 for oil and gas-fired boilers 

- UL 726-1995 for oil-fired boilers 

- ASME PTe 4.1 for steam generating boilers (oil and gas) 

• Two test standards referenced in ASHRAE 

90.1-1989 for warm air furnaces 

- ANSI Z21.47 -1993 for Gas-fired furnaces 

- UL 727-1994 for oil-fired furnaces 
Issues In Commercial Boilers 

And Furnaces 

Definition of "Packaged Boiler", Upper Limit 

on Boiler size 

Thermal vs. Combustion Efficiency; Jacket 

Loss 

Uniformity of Test Conditions, Setup, and 

Procedures 

Provisions for Less-Common Features (Low 

temperature Applications, Condensing, 

Modulating, Modular, etc.) 

 EE-RM-98-101 COMMENT 02DD

Issues In Commercial Boilers 

And Furnaces 

• Definition of "Packaged Boiler", Upper Limit 

on Boiler size 

• Thermal vs. Combustion Efficiency; Jacket 

Loss 

• Uniformity of Test Conditions, Setup, and 

Procedures 

• Provisions for Less-Common Features (Low 

temperature Applications, Condensing, 

Modulating, Modular, etc.) 
Issue: Definition of Packaged 

Boiler and Size Limit 

Definition for Packaged Boiler: 

- EPACT: Boilers that is shipped complete with heating 

equipment, mechanical draft equipment, and automatic 

controls; usually shipped in one or more sections. 

- HI Std. 1989: A boiler-burner unit factory assembled and 

wired. 

- ANSI Z21.13: No definition. 

- UL 726- 1995: Defines a "Boiler Assembly" as "...factory-built 

and shall include all essential components necessary for its 

normal function as intended, and may be shipped as two or 

more major subassemblies". 

- ASME PTC 4.1: No definition. 

* Question and Request for Comments: 

- Is the EPACT definition clear enough? 

- What types of boilers are not packaged boilers? 

- Are custom designed, field-assembled boilers excluded? 

 EE-RM-98-101 COMMENT 02DD

Issue: Definition of Packaged 

Boiler and Size Limit 

• Definition for Packaged Boiler: 

- EPACT: Boilers that is shipped complete with heating 

equipment, mechanical draft equipment, and automatic 

controls; usually shipped in one or more sections. 

- HI Std. 1989: A boiler-burner unit factory assembled and 

wired. 

- ANSI Z21. 13: No definition. 

- UL 726-1995: Defines a "Boiler Assembly" as " ... factory-built 

and shall include all essential components necessary for its 

normal function as intended, and may be shipped as two or 

more major subassemblies". 

- ASME PTC 4. 1: No definition. 

• Question and Request for Comments: 

- Is the EPACT definition clear enough? 

- What types of boilers are not packaged boilers? 

- Are custom designed, field-assembled boilers excluded? 
Issue: Definition of Packaged 

Boiler and Size Limit (cont.) 

Upper Limit on Size of Packaged Boiler: 

- EPACT: Does not specify an upper limit. 

- HI: No size limit. However, Hl's I=B=R rating directory listed 

boilers with gross output up to 13,500,000 Btulh. 

- UL 726-1995: No size limit. 

- ANSlZ21.13-1993a: Limits coverage for gas-fired boilers to 

input of less than 12,500,000 Btulh. 

- ASME PTC 4.1: No size limit. 

Questions and Request for Comments: 

- Is there a practical size limit for a packaged boiler ? 

- Should there be a size limit ? And if yes, at what input ? 

>> Gas-fired: As specified by ANSI 221.13 ? 

,> Oil-fired: Same as gas-fired, or different value ? 

- Should the test procedure be limited to space heating boilers? 

 EE-RM-98-101 COMMENT 02DD

Issue: Definition of Packaged 

Boiler and Size Limit (cont.) 

• Upper Limit on Size of Packaged Boiler: 

- EPACT: Does not specify an upper limit. 

- HI: No size limit. However, HI's I=B=R rating directory listed 

boilers with gross output up to 13,500,000 Btu/h. 

- UL 726-1995: No size limit. 

- ANSI Z21. 13-1993a: Limits coverage for gas-fired boilers to 

input of less than 12,500,000 Btu/h. 

- ASME PTC 4. 1: No size limit. 

• Questions and Request fo.r Comments: 

- Is there a practical size limit for a packaged boiler? 

- Should there be a size limit? And if yes, at what input? 

» Gas-fired: As specified by ANSI Z21.13 ? 

» Oil~fired: Same .as gas-fired, or different value? 

- Should the test procedure be limited to space heating boilers? 
Issue: Thermal vs Combustion 

Efficiency; Jacket Loss 

General Definition for Efficiencies: 

- Thermal Efficiency: Ther. Effy. = (Output / Input), in %. 

- Combustion Efficiency: Comb. Effy. = (1 00 - %Flue Loss). 

- Usually: Ther. Effy. = Comb. Effy. - Jacket Loss. 

Specified Efficiency Terms by EPACT: 

- Boilers: Combustion efficiency. 

- Furnaces: Thermal efficiency. 

Effy. Term by Referenced Standards - Boilers: 

- HI: Both Thermal (called Overall Effy.) and Comb. Effy. 

- ANSI 227.13-1993a: Comb. Effy. for indoor boilers. Thermal 

Effy. for outdoor boilers. 

- UL 726-1995: Comb. Effy. (implied) but no calculation 

procedure for flue loss. 

- ASME PTC 4.1: Both outputlinput and heat loss methods. 

 EE-RM-98-101 COMMENT 02DD

Issue: Thermal vs Combustion 

Efficiency; Jacket Loss 

• General Definition for Efficiencies: 

- Thermal Efficiency: Ther. Effy. = (Output / Input), in 0/0. 

- Combustion Efficiency: Comb. Effy. = (100 - %Flue Loss). 

- Usually: Ther.Effy. = Comb. Effy. - Jacket Loss. 

• Specified Efficiency Terms by EPACT: 

- Boilers: Combustion efficiency. 

- Furnaces: Thermal efficiency. 

• Effy. Term by Referenced Standards - Boilers: 

- HI: Both Thermal (called Overall Effy.) and Comb. Effy. 

- ANSI Z21.13-1993a: Comb. Effy. for indoor boilers. Thermal 

Effy. for outdoor boilers. 

- UL 726-1995: Comb. Effy. (implied) but no calculation 

procedure for flue loss. 

- ASME PTe 4.1: Both output/input and heat loss methods. 
Issue: Thermal vs Combustion 

Efficiency; Jacket Loss (cont.) 

Effy. Term by Referenced Standards - 

Furnaces: 

- ANSI 221.47-1993: Defines a thermal efficiency equal to a 

calculated combustion efficiency. Provides a test method for 

jacket loss, but not used in Effy. calculation. 

- UL 727-1994: Comb. Effy. (implied). No calculation proc. for 

flue loss. 

Jacket Loss: 

- ASME PTC 4.1: Provides graph for jacket loss estimate and 

test method for actual measurement. 

- ANSI 221.47: Provides test method for jacket loss. 

 EE-RM-98-101 COMMENT 02DD

Issue: Thermal vs Combustion 

Efficiency; Jacket Loss (cont.) 

• Effy. Term by Referenced StandardsFurnaces: 

- ANSI Z21.47-1993: Defines a thermal efficiency equal to a 

calculated combustion efficiency. Provides a test method for 

jacket loss, but not used in Effy. calculation. 

- UL 727-1994: Comb. Effy. (implied). No calculation proc. for 

flue loss. 

• Jacket Loss: 

- ASME PTe 4.1: Provides graph for jacket loss estimate and 

test method for actual measurement. 

- ANSIZ21.47: Provides test method for jacket loss. 
Issue: Thermal vs Combustion 

Efficiency; Jacket Loss (cont.) 

Questions and Request for Comments: 

- Should a thermal efficiency as required by EPACT be 

calculated for warm air furnaces by substracting the jacket 

loss from the combustion efficiency? 

- If so, should jacket loss be excluded for indoor installation? 

- Or should combustion efficiency be considered as the thermal 

efficiency as prescribed in ANSl 221.47-1993? 

- Should parasitic electric energy be included in efficiency 

calculation for boilers as prescribed in ASME PTC 4.1? 

- If jacket loss is needed, should a method be selected from 

ANSl 221.47 or ASME PTC 4.1 ? 

- If jacket loss is needed for outdoor units, should laboratory 

results be adjusted to (average?) outdoor conditions? 

 EE-RM-98-101 COMMENT 02DD

Issue: Thermal vs Combustion 

Efficiency; Jacket Loss (cont.) 

• Questions and Request for Comments: 

- Should a thermal efficiency as required by EPACT be 

calculated for warm air furnaces by substracting the jacket 

loss from the combustion efficiency? 

- If so, should jacket loss be excluded for indoor installation? 

- Or should combustion efficiency be considered as the thermal 

efficiency as prescribed in ANSI Z21.47-1993? 

- Should parasitic electric energy be included in efficiency 

calculation for boilers as prescribed in ASME PTC 4.1? 

- If jacket loss is needed, should a method be selected from 

ANSI Z21.47 or ASME PTC 4.1? 

- If jacket loss is needed for outdoor units, should laboratory 

results be adjusted to (average?) outdoor conditions? 
Issue: Uniformity of Test 

Conditions, Setup, Procedures 

For boilers, differences in test methods in 

ASHRAE 90.1 referenced standards exist 

among the four standards for gas boilers and 

the three standards for oil boilers. 

* For furnaces, some minor differences in test 

methods exist between the two standards for 

gas and oil furnaces. 

 EE-RM-98-101 COMMENT 02DD

Issue: Uniformity of Test 

Conditions, Setup, Procedures 

• For boilers, differences in test methods in 

ASHRAE 90.1 referenced standards exist 

among the four standards for gas boilers and 

the three standards for oil boilers. 

• For furnaces, some minor differences in test 

methods exist between the two standards for 

gas and oil furnaces. 
Issue: Uniformity of Test 

Conditions, . . .. (cont.) 

For Boilers 

ITEM ANSI 221.13 HI Std-1989 UL 726-95 ASME TC4.1 

----------- (Gas Fuel) --------- (Gas or Oil) ------- (Oil Fuel) ----------- (Gas or Oil) ------- 

Scope Steam & hot water 

Test Fuel Sp. by manufacturer 

Input +/- 2% rated 

Length of Not specified 

S.S.Test 

In Water 80F +/- I0 F 

Out Water 180 F +/- 2 F 

Del T (Rise) 100 F 

Flue Gas T. Av. 9 traverse 

Vert.Flue L. 5 ft.14 ft.(>400kB/h) 

Hori.Flue L. 2 ft.(if <400kB/h) 

Vent Insul. Uninsulated 

Steam & hot water 

#2 or 4,5,6 fuel oil 

100- 105 % rated 

30 min. 

Not specified 

200 F +/- 2 F 

120 F to 165 F 

9 t.c. grid 

2 ft if hori. outlet 

2 ft if Vert.outlet 

R7 Insulation 

Steam & hot water 

Non-residue fuel oil 

+/- 2% rated 

45 min. 

Not specified 

Not less than 200 F 

Not specified 

Av . 9 traverse 

5 ft./3 ft. (direc t vent) 

---- 

Uninsulated 

Steam only 

Sp. by manufacturer 

Rated 

2 runs each at 4 hr 

Not specified 

---- 

---- 

Av. traverse 

Not specified 

Not specified 

Not specified 

 EE-RM-98-101 COMMENT 02DD

ITEM 

Issue: Uniformity of Test 

Conditions, .... (cont.) 

For Boilers 

ANSI Z21.13 HI Std-1989 UL 726-95 ASME TC4.1 

___________ (Gas Fuel) _________ (Gas or Oil) _______ (Oil Fuel) ___________ (Gas or Oil) ______ _ 

Scope Steam & hot water 

Test Fuel Sp. by manufacturer 

Input +/- 2% rated 

Length of N at specified 

S.S.Test 

In Water 80F +/-10 F 

Out Water 180 F +/- 2 F 

Del T (Rise) 100 F 

Flue Gas T. A v. 9 traverse 

Vert.Flue L. 5 ft.l4 ft.(>400kB/h) 

Hori.Flue L. 2 ft.(if <400kB/h) 

Vent Insul. U ninsulated 

Steam & hot water 

#2 or 4,5,6 fuel oil 

100-105% rated 

30 min. 

N at specified 

200 F +/- 2 F 

120 F to 165 F 

9 t.c. grid 

2 ft if hori. outlet 

2 ft if Vert.outlet 

R 7 Insulation 

Steam & hot water 

N on-residue fuel oil 

+/- 2% rated 

45 min. 

N at specified 

N at less than 200 F 

Not specified 

Av . 9 traverse 

5 ft.l3ft.(direct vent) 

U ninsulated 

Steam only 

Sp. by manufacturer 

Rated 

2 runs each at 4 hr 

Not specified 

Av. traverse 

N at specified 

N at specified 

N at specified 
Issue: Uniformity of Test 

Conditions, .... (cont.) 

For Furnaces 

TTEM ANSI 221.47 UL 727- 1994 

(Gas Fuel) (Oil Fuel) 

Test Fuel Sp. by manufacturer Sp. by manufacturer 

Input Rated +I- 2% Rated +I- 2% 

Length of Test 30 min. 45 min. 

Flue Gas T Av. 9 traverse Single t.c. at center 

Vert.Flue L. 5ft. 6 in. No less than 2 ft. 

Flue Insul. Uninsulated Uninsulated 

 EE-RM-98-101 COMMENT 02DD

Issue: Uniformity of Test 

Conditions, .... (cont.) 

For Furnaces 

ITEM ANSIZ21.47 UL 727-1994 

(Gas Fuel) (Oil Fuel) 

Test Fuel Sp_ by manufacturer Sp. by manufacturer 

Input Rated+/- 2% Rated+/- 2% 

Length of Test 30 min. 45 min. 

Flue Gas T A v. 9 traverse Single t.c. at center 

Vert.Flue L. 5ft. 6 in. No less than 2 ft. 

Flue Insul. Uninsulated Uninsulated 
Issue: Uniformity of Test 

Conditions, .... (cont.) 

Questions and Request for Comments: 

DOE needs a uniform test method that would 

produce a single efficiency value for a unit when 

tested by a DOE test procedure. 

- Should DOE test procedure be based on one single (for each 

type of fuel) referenced standard, or a compromise set of 

parameters of the referenced standards (for each type fuel)? 

- If a single set of test parameters is chosen, what should be 

the criteria, and the values? 

- UL 727 (for oil furnaces) does not provide a flue loss 

calculation. Should Hl's procedure (for oil boilers) be adopted 

for oil furnaces? 

- Should 9-junction thermocouple grid be an option for flue gas 

measurement? 

- Should insulation of flue pipe to flue temp. measuring plane 

be required as specified in HI Std.-1989 for boilers? 

 EE-RM-98-101 COMMENT 02DD

Issue: Uniformity of Test 

Conditions, .... (cont.) 

• Questions and Request for Comments: 

DOE needs a uniform test method that would 

produce a single efficiency value for a unit when 

tested by a DOE test procedure. 

- Should DOE test procedure be based on one single (for each 

type of fuel) referenced standard, or a compromise set of 

parameters of the referenced standards (for each type fuel)? 

- If a single set of test parameters is chosen, what should be 

the criteria, and the values? 

- UL 727 (for oil furnaces) does not provide a flue loss 

calculation. Should HI's procedure (for oil boilers) be adopted 

for oil furnaces? 

- Should 9-junction thermocouple grid be an option for flue gas 

measurement? 

- Should insulation of flue pipe to flue temp. measuring plane 

be required as specified in HI Std.-1989 for boilers? 
Issue: Provision for LessCommon Features 

The referenced test standards do not specify or 

provide test procedures for some less-common 

but existing design features such as: 

Hot water boilers for low temp. applications. 

- Low temperature applications (such as for radiant floor 

heating, etc.) only. 

- Both low and high temperature applications. 

Gas-f ired condensing boilers and furnaces. 

- No condensate collection and measurement procedure. 

* Modulating boilers and furnaces. 

Packaged modular boilers. 

* Both steam and hot water applications. 

 EE-RM-98-101 COMMENT 02DD

Issue: Provision for LessCommon Features 

The referenced test standards do not specify or 

provide test procedures for some less-co~mon 

but existing design features such as: 

• Hot water boilers for low temp. applications. 

- Low temperature applications (such as for radiant floor 

heating, etc.) only_ 

- Both low and high temperature applications. 

• Gas-fired condensing boilers and furnaces. 

- No condensate collection and measurement procedure. 

• Modulating boilers and furnaces. 

• Packaged modular boilers. 

• Both steam and hot water applications. 
Issue: Provision for LessCommon Features (cont.) 

a Questions and Request for Comments: 

- Should both low and high temperature test conditions be 

specified for hot water boilers? What should be the low 

temperature test settings (inlet and outlet water temp.)? 

- Should condensate measurement be specified for condensing 

boilers and furnaces? Considerladopt the one in ASHRAE 

1 03-1 993? 

- Should DOE specify the two rating conditions (at the 

maximum and minimum input rates) for modulating boilers 

and furnaces as specified in ASHRAE 90.1 -1 989? 

- Should only a single boiler be tested in a modular package? 

- Should a steam and hot water boiler be tested on steam only? 

 EE-RM-98-101 COMMENT 02DD

Issue: Provision for LessCommon Features (cont.) 

• Questions and Request for Comments: 

- Should both low and high temperature test conditions be 

specified for hot water boilers? What should be the low 

temperature test settings (inlet and outlet water temp.)? 

- Should condensate measurement be specified for condensing 

boilers and furnaces? Consider/adopt the one in ASH RAE 

103-1993? 

- Should DOE specify the two rating conditions (at the 

maximum and minimum input rates) for modulating boilers 

and furnaces as specified in ASHRAE 90.1-1989? 

- Should only a single boiler be tested in a modular package? 

- Should a steam and hot water boiler be tested on steam only? 
Commercial Air Conditioners 

and Heat Pumps 

Minimum External Static Pressure 

- Relationship of Current ART Standard to Field 

bxperience 

- Possibility of Error Due to Any Discrepancy 

 EE-RM-98-101 COMMENT 02DD

Commercial Air Conditioners 

and Heat Pumps 

• Minimum External Static Pressure 

- Relationship of Current ARI Standard to Field 

Experience 

- Possibility of Error Due to Any Discrepancy 
COMMERCIAL AIR CONDITIONERS 

AND HEAT PUMPS 

Issue - The adequacy of the external static pressure specified 

by the current test procedures 

ARI standards 21 0/240 and ARI 3401360 specify a minimum external 

resistance during testing. 

Critics observe that the specified resistance is lower than that typically 

encountered in a field installation. 

Problem: Efficiency rating may be overstated. 

 EE-RM-98-101 COMMENT 02DD

~,. ·1 --------------------------------------------~ 

COMMERCIAL AIR CONDITIONERS 

AND HEAT PUMPS 

Issue - The adequacy of the external static pressure specified 

by the current test procedures 

ARI standards 210/240 and ARI 340/360 specify a minimum external 

resistance during testing. 

Critics observe that the specified resistance is lower than that typically 

encountered in a field installation. 

Problem: Efficiency rating may be overstated. 

Li()E W"rb!wp, i\pril P und I:", 199X 

Pil.'!! A. J)1'manski Ie!. \30]) 'J7S-':>'1)n 
Minimum External Pressure 

Standard Capacity Ratings Minimum Extend Resistance 

(Thousands of Btu/h) Bw (Inches of Water) [Pa] 

Vp thru 28 fup thnx 8.21 0.10 t24.91 

29 thru 42 [8.5 thm 12.41 0.15 [37.4] 

43 thn~ 70 [12.6 thru 20.51 0.20 149.81 

71 thru 105 E20.8 thm 30.83 0.25 C62.33 

106 thru 134 [31.1 thru 39.31 0.30 [74.73 

Cooling capacity for units with cooling function: High Temperature Heating Capacity for heatingonly units (See 5.1 -3.3). 

 EE-RM-98-101 COMMENT 02DD

~,c·==.rl·-----------------------------------------------~ 

Issue - The adequacy of the external static pressure specified 

by the current test procedures (cont.) 

Minimum External Pressure 

Standard Capacity Ratin~s Minimum External Resistance 

(Thousands of Btu/h) fkWl (Inches of Water) [Pal 

Up tbru 28 [Up thru 8.2] 0.10 [24.9] 

29 thru 42 [8.5 thru 12.4] 0.15 [37.4] 

43 tbru 70 [12.6 thru 20.5] 0.20 {49.8] 

71 thru 105 [20.8 thru 30.8] 0.25 (62.3] 

106 thru 134 [31.1 tbru 39.31 0.30 [74.7] 

Cooling capacity for units with cooling function: High Temperature Heatir(g Capacity for heatmgonly units (See 5.1 .3.3). 
i 

Minimum External Pressure 

Minim urn 

'Standard Capacity Ratings External 

Resistance 

(mh) -- CkwJ (Inches of Water) FPa3 

135 thru 210 39.6 th 61.6 0.35 87.2 

211 tfuv 280 61 "7 thru 82.1 0.40 99.6 

281 thru 350 I 82.2 thru 102.6 0-45 112.1 

351 thru 400 102.7 thru 117.2 0.55 137.0 

401 thru 500 117.3 th 146.6 0-65 161.9 

501 and over 146.7 and over 0.75 186.8 

* Cooling Capacity for units with cooling function: High Temperature Heating Capacity 

for heating-only units (see 5.1.3.2) 

i 

-Nlsr 

Issue - The adequacy of the external static pressure specified 

by the current test procedures (cont.) 

 EE-RM-98-101 COMMENT 02DD

Issue - The adequacy of the external static pressure specified 

by the current test procedures (cont.) 

" ~ 

Minimum External Pressure 

Minimum 

·Standard Capacity Ratings External 

Resistance 

(MBh) [leW] (Inches of Water) [kPa] 

135 thru 210 39.6 thru 61.6 0.35 87.2 

211 thru 280 61.7 thru 82.1 0.40 99.6 

281 thru 350 82.2 thru 102.6 0.45 112.1 

351 thru 400 102.7 thru 117.2 0.55 137.0 

401 thru .500 117.3 thru 146.6 0.65 161.9 

501 and over 146.7 and over 0.75 186.8 

.. Cooling Capacity for units with cooling function; High Temperature Heating Capacity 

for heating-only units (see 5.1.3.2) 
Issue - The adequacy of the external static pressure specified 

by the current test procedures (cont.) 

Questions: 

Is the specified external static pressure too low? 

If yes, is this a problem that should be corrected? 

If yes, how should it be corrected? 

 EE-RM-98-101 COMMENT 02DD

Issue - The adequacy of the external static pressure specified 

by the current test procedures (cent.) 

Questions: 

• Is the specified external static pressure too low? 

• If yes, is this a problem that should be corrected? 

• If yes, how should it be corrected? 
Sampling, Certification 

and Enforcement 

Compliance 

- DOE Requirement 

- Test to DOE Test Procedure 

Sampling & Certification 

- Test 2 or More Units of Each Basic Model 

- Certi~ Energy Efficiency to DOE 

Enforcement 

- Applies to Standards & Representations 

- Present Requirements, Test 4 or More Units 

 EE-RM-98-101 COMMENT 02DD

• Compliance 

Sampling, Certification 

and Enforcement 

- DOE Requirement 

- Test to DOE Test Procedure 

• Sampling & Certification 

- Test 2 or More Units of Each Basic Model 

- Certify Energy Efficiency to DOE 

• Enforcement 

- Applies to Standards & Representations 

- Present Requirements, Test 4 or More Units 
Sampling, Certification 

and hnforcement 

Statistical Sampling 

- Sample Size & Selection, Test Location, 

Compliance, Adjustment Factors, Enforcement 

* Limited and Heterogeneous Populations 

- Large Capacity, Low Production and Site 

Assembled Units 

- Product Groupings and Representative Models 

 EE-RM-98-101 COMMENT 02DD

Sampling, Certification 

and Enforcement 

• Statistical Sampling 

- Sample Size & Selection, Test Location, 

Compliance, Adjustment Factors, Enforcement 

• Limited and Heterogeneous Populations 

- Large Capacity, Low Production and Site 

Assembled Units 

- Product Groupings and Representative Models 
Background 

Federal regulations require that certain 

coveredproducts must meet energy 

performance standards 

Each basic model of a covered product must 

be certified to DOE to be in compliance 

with the relevant minimum standards 

Compliance of a basic model is 

demonstrated by measurements using 

specified test procedures 

 EE-RM-98-101 COMMENT 02DD

Background 

• Federal regulations require that certain 

covered products must meet energy . 

performance standards 

• Each basic model of a covered product must 

be certified to DOE to be in compliance 

with the relevant minimum standards 

• Compliance of a basic model is 

demonstrated by measurements using 

specified test procedures 
Sampling 

Used to estimate characteristics of a large 

population by evaluating a small sample 

Utilizes statistically-based procedures 

Intended to limit testing expense and time 

strikes a balance between manufacturer's 

risk of false negative, and consumer's risk 

of false positive 

 EE-RM-98-101 COMMENT 02DD

Sampling 

• Used to estimate characteristics of a large 

population by evaluating a small sample 

• Utilizes statistically-based procedures 

• Intended to limit testing expense and time 

• strikes a balance between manufacturer's 

risk of false negative, and consumer's risk 

of false positive 
Compliance vs. Enforcement 

Compliance testing is used to certify that a 

basic model meets the minimum standards 

and serves as the basis for representations 

Enforcement testing is used to resolve 

disputed product performance claims 

Compliance Certification is required for all 

covered products 

Enforcement actions are conducted as 

needed 

 EE-RM-98-101 COMMENT 02DD

Compliance VS. Enforcement 

• Compliance testing is used to certify that a 

basic model meets the minimum standards 

and serves as the basis for representations 

• Enforcement testing is used to resolve 

disputed product performance claims 

• Compliance Certification is required for all 

covered products 

• Enforcement actions are conducted as 

needed 
Basic Model 

All units of a covered product which do not 

have any features or characteristics which 

significantly affect energy efficiency or 

energy usage 

Other characteristics can be different, such 

as color, finish, shape etc. 

 EE-RM-98-101 COMMENT 02DD

Basic Model 

• All units of a covered product which do not 

have any features or characteristics which 

significantly affect energy efficiency or 

energy usage 

• Other characteristics can be different, such 

as color, finish, shape etc. 
Population 

the entire production of a basic model of a 

covered product, i.e. all the 200 gallon gasfired water heaters made by manufacturer 

ABC 

there is no time constraint, but compliance 

is certified only once, prior to distribution of 

product 

product must remain in compliance in future 

 EE-RM-98-101 COMMENT 02DD

Population 

• the entire production of a basic model of a 

covered product, i.e. all the 200 gallon gasfired water heaters made by manufacturer 

ABC 

• there is no time constraint, but compliance 

is certified only once, prior to distribution of 

product 

• product must remain in compliance in future 
Sample 

a "random" selection of representative units 

from a basic model population 

used to conduct measurements to estimate 

performance of larger population 

each unit does not need to meet the 

standard; the value used to represent the 

performance of the population must meet 

the standard 

 EE-RM-98-101 COMMENT 02DD

Sample 

• a "random" selection of representative units 

from a basic model population 

• used to conduct measurements to estimate 

performance of larger population 

• each unit does not need to meet the 

standard; the value used to represent the 

performance of the population must meet 

the standard 
Covered Products, Populations 

and Basic Models 

 EE-RM-98-101 COMMENT 02DD

Covered Products, Populations 

and Basic Models 

I 

I 

I 

I 
Covered Products, Populations 

and Basic Models 

 EE-RM-98-101 COMMENT 02DD

Covered Products, Populations 

and Basic Models 

basic model B 

basic .... 

model A I 

I 

basic model C 
Typical Sampling Plans for 

Compliance 

use one-sided confidence limits (t-test) 

confidence interval (90, 95, 97.5%) varies 

with product 

incorporates adjustment factor (divisor) to 

account for measurement uncertainty and 

product variability 

bounded by sample mean, is. represented 

value cannot be more favorable than sample 

mean 

 EE-RM-98-101 COMMENT 02DD

Typical Sampling Plans for 

Compliance 

• use one-sided confidence limits (t-test) 

• confidence interval (90, 95, 97.5%) varies 

with product 

• incorporates adjustment factor (divisor) to 

account for measurement uncertainty and 

product variability 

• bounded by sample mean, i.e. represented 

value cannot be more favorable than sample 

mean 
Typical Sampling Plans for 

Compliance- cont. 

* minimum sample size is two units 

no upper limit on sample size 

excessive product or measurement 

var~ability degrades rating 

 EE-RM-98-101 COMMENT 02DD

Typical Sampling Plans for 

Compliance- cont. 

• minimum sample size is two units 

• no upper limit on sample size 

• excessive product or measurement 

variability degrades rating 
Sampling Plan for Enforcement 

* double sampling procedure with confidence 

limit of 97.5 

minimum sample size of 4 units 

maximum sample size of 20 units 

not bounded by the sample mean 

 EE-RM-98-101 COMMENT 02DD

Sampling Plan for Enforcement 

• double sampling procedure with confidence 

lilTIit of 97.5 

• minimum sample size of 4 units 

• maximum sample size of 20 units 

• not bounded by the sample mean 
Issues- statistical sampling 

selection of basic models 

appropriate sample sizes 

selection of sample units 

testing locations 

compliance determination 

adjustment factors 

compliance vs. enforcement 

enforcement of labeling accuracy 

 EE-RM-98-101 COMMENT 02DD

Issues- statistical sampling 

• selection of basic models 

• appropriate sample sizes 

• selection of sample units 

• testing locations 

• compliance determination 

• adjustment factors 

• compliance vs. enforcement 

• enforcement of labeling accuracy 
Limited and Heterogeneous 

Populations 

some products are produced in limited 

numbers, or have many design variations 

some products are very large or site-built 

these classes of products raise concerns 

about excessive testing burdens and expense 

 EE-RM-98-101 COMMENT 02DD

Limited and Heterogeneous 

Populations 

• some products are produced in limited 

numbers, or have many design variations. 

• some products are very large or site-built 

• these classes of products raise concerns 

about excessive testing burdens and expense 
Industry Programs 

several industry programs are in-place or in 

development for testing and rating covered 

products 

- ARI- air conditioners and heat pumps 

- GAMA- water heaters up to 500,00OBtu/h 

- HI- packaged boilers 

other equipment not currently included 

available to all manufacturers? 

 EE-RM-98-101 COMMENT 02DD

Industry Programs 

• several industry programs are in-place or in 

development for testing and rating covered 

products 

- ARI - air conditioners and heat pumps 

- GAMA- water heaters up to 500,OOOBtu/h 

- HI-packaged boilers 

• other equipment not currently included 

• available to all manufacturers? 
Water Heater Issue 

ANSI 221.10.3-1990 does not specify 

characteristics to determine basic model 

a ASHRAE Standard 1 1 8.1 - 1 993 contains 

provision for rating non-tested models 

 EE-RM-98-101 COMMENT 02DD

Water Heater Issue 

• ANSI Z21.1 0.3-1990 does not specify 

characteristics to determine basic model 

• ASHRAE Standard 118.1-1993 contains 

provision for rating non-tested models 
Issues- Limited Populations and 

Industrv Programs 

are special provisions needed for large, site 

assembled or low production units 

can products be: 

- grouped into a limited number of basic models 

- characterized by simulation or other analytical 

methods 

should ASHRAE 1 1 8.1 - 1993 be used 

how should industry programs be 

incorporated 

 EE-RM-98-101 COMMENT 02DD

Issues- Limited Populations and 

Industry Programs 

• are special provisions needed for large, site 

assembled or low production units 

• can products be: 

- grouped into a limited number of basic models 

- characterized by simulation or other analytical 

methods 

• should ASHRAE 118.1-1993 be used 

• how should industry programs be 

incorporated 
Equipment Labeling 

Legislative Requirements 

- '1 ‘ethnical Justification 

Label Characteristics 

- Location 

- Content 

Labeling Mixed Component Systems 

 EE-RM-98-101 COMMENT 02DD

Equipment Labeling 

• Legislative Requirements 

- Economic Justification 

- Technical Justification 

• Label Characteristics 

- Location 

- Content 

• Labeling Mixed Component Systems 
EQUIPMENT LABELING 

Introduction 

Labeling rule must be prescribed within 12 months of 

prescribing test procedures. The date for displaying the labels 

is 12 months from the rule prescription date. 

EPCA §344 (b): label must show the energy efficiency. DOE - - - 

may require estimated operating costs and energy use on label. 

EPCA §344(c) : DOE can prescribe additional requirements 

likely to assist purchasers in making purchasing decisions. 

EPCA §3 44 (el : provides additional labeling requirements and 

authority. 

EPCA 5344 (f): no labeling rules unless certain conditions are 

met. 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Introduction 

• Labeling rule must be prescribed within 12 months of 

prescribing test procedures. The date for displaying the labels 

is 12 months from the rule prescription date. 

• EPCA §344 (b): label must show the energy efficiency. DOE 

may require estimated operating costs and energy use on label. 

• EPCA §344(c): DOE can prescribe additional requirements 

likely to assist purchasers in making purchasing decisions. 

• EPCA §344 (e): provides additional labeling requirements and 

authority. 

• EPCA §344 (f): no labeling rules unless certain conditions are 

met. 
EQUIPMENT LABELING 

Comment Areas 

The justification for labeling under EPAct, 

Label location and contents, and 

Labeling of mixed component systems 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Comment Areas 

• The justification for labeling under EP Act, 

• Label location and contents, and 

• Labeling of mixed component systems 
EQUIPMENT LABELING 

Justification for Labeling 

EPCA §344(h): The Secretary shall not promulgate 

labeling rules for any class of industrial equipment unless 

the Secretary has determined that : 

- (1) such labeling is technologically and economically feasible; 

- (2) significant energy savings will likely result; and 

- (3) the labeling is likely to assist consumers in making purchasing 

decisions. 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Justification for Labeling 

• EPCA §344(h): The Secretary shall not promulgate 

labeling rules for any class of industrial equipment unless 

the Secretary has determined that : 

- (1) such labeling is technologically and economically feasible; 

- (2) significant energy savings will likely result; and 

- (3) the labeling is likely to assist consumers in making purchasing 

decisions. 
EQUIPMENT LABELING 

Justification for Labeling: Questions 

What may be the specific problems with individual classes 

of covered equipment affecting technical feasibility and 

economic justification for labeling? 

* What energy savings, if any, would result? 

* Would labels assist customers in making purchasing 

decisions for individual classes of covered equipment? 

What are the implications of purchases taking place 

without equipment being seen. 

What are other benefits to stakeholders? 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Justification for Labeling: Questions 

• What may be the specific problems with individual classes 

of covered equipment affecting technical feasibility and 

econoDlic justification for labeling? 

• What energy savings, if any, would result? 

• Would labels assist customers in making purchasing 

decisions for individual classes of covered equipment? 

What are the implications of purchases taking place 

without equipment being seen. 

• What are other benefits to stakeholders? 
EQUIPMENT LABELING 

Label Location and Contents 

EPCA 5344(e) : Labeling rules shall 

- (I) indicate the energy efficiency of the equipment on the 

permanent nameplate attached to such equipment or other nearby 

permanent marking; 

- (2) prominently display the energy efficiency of the equipment in 

new equipment catalogs used by the manufacturer to advertise the 

equipment; and 

- (3) include such other markings as the Secretary determines 

necessary, solely to facilitate enforcement of the standards 

established for such equipment under section 342. 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Label Location and Contents 

• EPCA §344(e): Labeling rules shall 

- (1) indicate the energy efficiency of the equipment on the 

permanent nameplate attached to such equipment or other nearby 

permanent marking; 

- (2) prominently display the energy efficiency of the equipment in 

new equipment catalogs used by the manufacturer to advertise the 

equipment; and 

- (3) include such other markings as the Secretary determines 

necessary, solely to facilitate enforcement of the standards 

established for such equipment under section 342. 
EQUIPMENT LABELING 

Label Location and Contents: Questions 

For which equipment classes can the current nameplates be 

modified to accommodate efficiency information? 

How could the energy efficiency data be prevented from 

getting overwhelmed by other nameplate information? 

* How could the data be displayed in a consistent manner? 

What would make a marking 'nearby' and 'permanent'? 

What would constitute the 'prominent' display of energy 

efficiency information in new equipment catalogs? 

* What other markings are necessary solely to facilitate the 

enforcement? Any additional data beyond efficiency? 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Label Location and Contents: Questions 

• F or which equipll1ent classes can the current nameplates be 

lllodified to accommodate efficiency information? 

• How could the energy efficiency data be prevented from 

getting overwhelmed by other nameplate information? 

• How could the data be displayed in a consistent manner? 

• What would make a marking 'nearby' and 'permanent'? 

What would constitute the 'prominent' display of energy 

efficiency information in new equipment catalogs? 

• What other markings are necessary solely to facilitate the 

enforcement? Any additional data beyond efficiency? 
EQUIPMENT LABELING 

Labeling of Mixed Components 

Some covered commercial equipment is comprised of 

separate components, often furnished by different 

manufacturers. 

For residential appliances, for split system condenserevaporator coil systems, the required labels contain energy 

efficiency ratings which are either 

- (1) the energy efficiency rating of the condenser-evaporator coil 

combination that is the particular manufacturer's most commonly 

sold combination for that condenser model; or 

- (2) the energy efficiency rating of the actual condenser-evaporator 

coil combination comprising the system to which the label is to be 

attached. 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Labeling of Mixed Components 

• Some covered commercial equipment is comprised of 

separate components, often furnished by different 

manufacturers. 

• F or residential appliances, for split system condenserevaporator coil systems, the required labels contain energy 

efficiency ratings which are either 

- (1) the energy efficiency rating of the condenser-evaporator coil 

combination that is the particular manufacturer's most commonly 

sold combination for that condenser model; or 

- (2) the energy efficiency rating of the actual condenser-evaporator 

coil combination comprising the system to which the label is to be 

attached. 
EQUIPMENT LABELNG 

Labeling of Mixed Components: Questions 

* Should component manufacturers or system integrators be 

responsible for developinglaffixing the labels? 

With mixed systems, there may be too many combinations 

to test all. Residential air conditioners use computer 

simulation, with only the highest sales combination tested. 

Under what circumstances, if any, should computer 

simulation results to be used to calculate system efficiency 

ratings to appear on labels? 

 EE-RM-98-101 COMMENT 02DD

EQUIPMENT LABELING 

Labeling of Mixed Components: Questions 

• Should component ll1anufacturers or systell1 integrators be 

responsible for developing/affixing the labels? 

• With mixed systems, there may be too tnany cOll1binations 

to test all. Residential air conditioners use computer 

simulation, with only the highest sales combination tested. 

Under what circumstances, if any, should computer 

simulation results to be used to calculate system efficiency 

ratings to appear on labels? 
Next Steps 

Written Comments Due May 13, 1998 

Workshop Transcript Available 

approximately April 30, 1998 

Next Workshop, mid-October, 1998 to 

Discuss Draft Language for the NOPRs 

 EE-RM-98-101 COMMENT 02DD

Next Steps 

• Written Comments Due May 13, 1998 

• Workshop Transcript Available 

approximately April 30, 1998 

• Next Workshop, mid-October, 1998 to 

Discuss Draft Language for the NOPRs