Docket Number: EER

HeatingProducts‐2011‐TP

Test Procedure NOPR for Residential and Certain Commercial W
2

Introduction

Description of Issues Addressed in This NOPR 4

2 Regulatory History3 Rulemaking Overview

1 Introduction

5 Closing Remarks
3

Agenda

9:00 – 9:45 Welcome, Introductions, and Opening Rema

9:45 – 10:00 Regulatory History and Rulemaking Overview

10:00 – 11:00 Scope11:00 – 11:15 Break11:15 – 11:45 Test Setup

11:45 – 12:30 Test Conditions

12:30 – 1:30 Lunch1:30 – 2:30 Draw Patterns

2:30 – 2:45 Break2:45 – 3:15 Rated Values for Storage Volume and FHR

3:15 – 3:30 Annual Energy Consumption

3:30 – 3:45 Conversion of Existing Ratings

3:45 – 4:00 Closing Remarks
4

Welcome and Introduction• Introductions• Role of the Facilitator

• Ground Rules

– Listen as an ally

– Focus on issues

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– One person speaks at a time (raise hand to be recognized; state y

the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

• Agenda Review

• Opening Remarks

Title Slide, Boiler Photo Source: http://www.easco.com/mobile-temporary-boilers-rentals.html 
5

Listening Via the Webcast• The U.S. Department of Energy (DOE) is broadcasting this meet

over the internet.

• DOE is providing the webcast to accommodate interested parti

unable to attend the public meeting in person.

• The web broadcast allows interested parties to listen in, view t

and submit questions and comments.

• All interested parties are encouraged to submit written comme

the public meeting but before the close of the public comment 

January 21, 2014.
6

Purpose of the Public Meeting• Present the procedural and analytical approaches to evaluate t

procedure amendments for residential and certain commercia

heaters

• Invite comment on the test procedure notice of proposed rulem

(NOPR)

• Discuss next steps in the rulemaking.

• Encourage participants to submit data, information, summary s

and written comments, including additional issues for discussio
7

Request for CommentThe deadline for submitting comments is January 21, 2014.

While DOE invites comment on all aspects of the material prese

this document, several specific issues on which DOE seeks com

set out in comment boxes like this one. DOE uses these comme

to highlight issues and to ask specific questions on the approac

to amend the test procedures.
8

Regulatory History

Description of Issues Addressed in This NOPRClosing Remarks

452 Regulatory History3 Rulemaking Overview

1 Introduction
9

Regulatory History

• The Energy Policy and Conservation Act (EPCA) of

1975 (Public Law 94‐163), as amended

– Established the Energy Conservation Program for

Consumer Products other than Automobiles, which

includes residential water heaters.

– Established the Energy Conservation Program for

Certain Industrial Equipment, which includes

commercial water heaters.

– Directs DOE to establish test procedures in conjunction

with energy conservation standards.
10

Regulatory History

• The Energy Independence and Security Act of 2007 (EISA 20

(Public Law 110‐140)

• Directed DOE to develop, if necessary, a test procedure amendmen

and incorporate standby mode and off mode energy consumption in

procedures for covered residential products (42 U.S.C. 6295(gg)(2))

• Amended EPCA to require the Secretary to periodically review all te

for possible amendment. (42 U.S.C. 6293 (b); 42 U.S.C. 6314(a)(1)(A

• The American Energy Manufacturing and Technical Correcti

(AEMTCA) (Public Law 112‐210)

• Amended EPCA to require that DOE publish a final rule establishing 

efficiency descriptor and accompanying test methods for covered rewater heaters and commercial water heating equipment.
11

Regulatory History• On May 11, 1998, DOE published a final rule in the Federal Reg

establishing the current test procedures for residential water h

25996. The test procedures for residential water heaters are lo

Appendix E to Subpart B of 10 CFR 430.

• On May 16, 2012, DOE published in the Federal Register a final 

establishing the current test procedures for commercial water 

28928. The test procedures for commercial water heaters are l

CFR 431.106.

• On October 12, 2011, DOE published a request for information 

need to amend the test procedures for residential water heate

63211.

• On January 11, 2013, DOE published a request for information 

requesting input on the various issues pertaining to water heat

in AEMTCA. 78 FR 2340.
12

Rulemaking Overview

Description of issues Addressed in this NOPR Closing Remarks

452 Regulatory History3 Rulemaking Overview

1 Introduction
13

• DOE published the residential and commercial water hea

procedure NOPR on November 4, 2013. 78 FR 66202.

• DOE is holding the NOPR public meeting today, Decembe

• DOE will accept comments on the NOPR from interested 

– Oral comments from today’s meeting will be recorded and 

– Interested parties can submit written comments until Janu

2014.

– DOE reviews and considers all comments.

• DOE expects to issue a final rule in early 2014.Steps in the Rulemaking Process

RFI NOPR Final Rule
14

Description of Issues Addressed in this NOPR

Description of Issues Addressed in This NOPRClosing Remarks

452 Regulatory History3 Rulemaking Overview

1 Introduction
15

Summary of Proposed Method of Test

• Proposes to modify the preparation of water heaters for t

• Modifies the water delivery temperature to better reflect 

as seen in typical installations in the field

• Proposes the use of multiple draw patterns for testing wa

during a 24 hour simulated use test, with a particular wat

being tested using a draw pattern appropriate for its deliv

• Proposes updates to the draw pattern to be more reflecti

field usage based on recent data

• Proposes to include requirements for rating storage volum

hour rating

• Modifies the calculation of annual energy consumption
16

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
17

Scope of Test Method

• The scope of coverage for the existing DOE residential WH 

narrower than the scope of DOE’s authority to cover wateunder EPCA.

– For example, water heaters with storage volumes at or above 2 ga

than 20 gallons are not covered in the test method but are within 

authority under EPCA.

• The proposed test method would modify the scope to elim

coverage gaps for residential WH and match the DOE test 

coverage to the authority under EPCA.

• The proposed changes would not expand the scope of the 

of current energy conservation standards.
18

Scope of Test Method

• AEMTCA amended EPCA to require DOE to develop a unifo

efficiency descriptor that:

– Includes all covered residential and commercial water heaters

– Applies “to the maximum extent practicable, to all water heating t

use as of the date of enactment of this paragraph and to future wa

technologies.” (42 U.S.C. 6295(e)(5)(C) and (H))

• AEMTCA allows for exclusions for equipment that:

– Does not have a residential use– Is effectively rated using the thermal efficiency and standby loss d

– Can be clearly described in the final rule (42 U.S.C. 6295(e)(5)(F))

• DOE proposes to exclude from the uniform descriptor the follow

equipment:

– Unfired Storage Tanks

– Add‐on Commercial Heat Pump Water Heaters

– Hot Water Supply Boilers

– Commercial Water Heaters not meeting the proposed definition o

commercial water heater”
19

Scope of Test Method – “Light Commercial” De

• DOE proposes to add a definition of “light commercial wat

to 10 CFR 431.102 for equipment that meets the following 

– For models requiring electricity, uses single‐phase external 

• Three‐phase power supply is not typically available in residenc

unit that does not use single‐phase power (i.e., uses 3‐phase p

not be intended for residential applications

– Is not capable of delivering hot water at temperatures of 18

• Temperatures of 180 0F and above are not typically required i

and are more likely to be used in commercial settings

– Does not bear a Code Symbol Stamp signifying compliance w

requirements of the ASME Boiler and Pressure Vessel Code

• The ASME code symbol stamp is typically found on commercia

• “Light commercial” water heaters would be tested using t

descriptor.
20

Scope of Test Method – Gas‐fired

• Existing test method coverage for residential gas‐fired wat

– Covers gas storage and gas instantaneous

– Has several coverage gaps

• For storage: between 2 and 20 gallons; over 100 gallons

• For instantaneous: below 50,000 Btu/h input rating

• Proposed test method for gas‐fired water heaters under u

descriptor:

– Eliminates coverage gaps in existing residential TP

– Covers both residential and “light commercial”

– Does not include upper or lower storage volume limit

– Does not include upper or lower input rating limits
21

Scope of Test Method – Gas‐fired

• Existing Coverage

0

50

100150200

0 20 40 60 80 100 

Input Capacity, kBtu/hr

Rated Volume, gallons

Residential Gas Storage

Residential Gas Instantaneuos
22

Scope of Test Method – Gas‐fired

• Proposed Coverage

0

50

100150200250

0 20 40 60 80 100 

Input Capacity, kBtu/hr

Rated Volume, gallons

Residential Storage

Residential Instantaneuos

Pro

Co

Proposed

New

Coverage

Proposed New

Proposed possible "Light

Commercial" New Coverage(if certain criteria met)
23

Scope of Test Method – Electric

• Existing test method coverage for residential electric wate

– Covers electric storage

– Contains several coverage gaps

• For storage: between 2 and 20 gallons; over 120 gallons

• Electric instantaneous definition currently “reserved”

• Proposed test method for electric water heaters under un

descriptor:

– Eliminates coverage gaps in existing residential TP

• Defines and clarifies test method for electric instantaneous wa

– Covers both residential and “light commercial”

– Does not include upper or lower storage volume limit

– Does not include upper input rating limit
24

Scope of Test Method – Electric

• Existing Coverage

05

10152025303540

0 20 40 60 80 100 

Input Capacity, kW

Rated Volume, gallons

Residential Electric Storage
25

Scope of Test Method – Electric

• Proposed Coverage

05

10152025303540

0 20 40 60 80 100 

Input Capacity, kW

Rated Volume, gallons

Residential Electric Storage

Electric Instantaneous Proposed New Coverage

Proposed possible "Light Commercial"

New Coverage (if certain criteria met)
26

Scope of Test Method – Oil‐fired

• Existing test method coverage for residential oil‐fired wate

– Covers oil‐fired storage

– Contains several coverage gaps

• For storage: over 50 gallons

• Oil‐fired instantaneous

• Proposed test method for oil‐fired water heaters under un

descriptor:

– Eliminates coverage gaps

– Covers both residential and “light commercial”

– Does not include upper or lower storage volume limit

– Does not include upper input rating limit
27

Scope of Test Method – Oil‐fired

• Existing Coverage

0

50

100150200250

0 20 40 60 80 100 

Input Capacity, kBtu/h

Rated Volume, gallons

Residential Oil‐fired Storage
28

Scope of Test Method – Oil‐fired

• Proposed Coverage

0

50

100150200250

0 20 40 60 80 100 

Input Capacity, kBtu/h

Rated Volume, gallons

Residential Oil‐fired Storage Proposed New Coverage

Proposed possible "Light

Commercial " New Coverage(if certain criteria met)
29

Scope Summary

• Proposes to expand the scope of coverage so that the test meth

applicable to all products that meet the EPCA definition of resid

heater

– Includes water heaters with storage volumes between 2 and 20 ga

– Removes minimum limit on firing rate of instantaneous gas water 

– Removes the limitations on maximum storage volumes that are cu

residential test procedure for storage water heaters

– Amends test procedure to include applicable provisions for electri

instantaneous water heaters

• Covers certain commercial water heaters

– Only excludes categories of water heaters that do not have a resid

– Adds a definition of “light commercial water heater” to 10 CFR 43

equipment that meets the following conditions:

• For models requiring electricity, uses single‐phase external power sup

• Is not capable of delivering hot water at temperatures of 180 0F or ab

• Does not bear a Code Symbol Stamp signifying compliance with the re

the ASME Boiler and Pressure Vessel Code
30

Item 1: Is the proposed definition of “light commercial water heat

appropriate, and is it appropriate to test commercial water heater

definition under the uniform descriptor, while testing all other com

water heaters using thermal efficiency and standby loss?

Scope Request for Comment
31

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
32

Water Heater Test Preparation• Proposes to require storage water heaters to be pre‐condit

the energy factor test by running the draw patterns on two

consecutive days, with measurements only taking place du

second 24‐hour period

– Aims to make the state of the water heater at the beginning 

hour test period similar to that at the end of the test period, 

minimizing the need to make large corrections to the energy

consumption values

– Ensures the water heater is at operational temperature at st

• Proposes to require a one hour idle period prior to comme

24‐hour simulated use test for instantaneous water heater

Item 5: What is the added burden, if any, in requiring a 24‐hour 

conditioning period for storage‐type water heaters compared to 

practice?
33

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
34

Test Conditions• Proposes to lower the set point temperature of resid

water heaters in the test procedure from 135 0F to 1

– Lowers the set point temperature to better represent conditions 

recent studies

• DOE 2010 Technical Support Document, Chapter 7: The average set

the field estimated as 124.2 0F.

• Proposes to set water heater temperature controls on sto

heaters to better yield delivered water at the nominal tem

– For water heaters with a single control:

• Following cutout, draw water from tank and monitor outlet water te

or 5 minutes. For water heaters with a rated volume < 20 gallons, usgpm; for water heater with a rated volume ≥ 20 gallons, use a flow ra

• Maximum outlet water temperature must be 125 0F ± 5 0F

– For water heaters with two or more thermostat controls – use exi

• Set uppermost thermostat so that temperature measured by the sen

corresponding heating element inside tank is 125 0F ± 5 0F

• Proceed with process until lowermost temperature control results in 

temperature of 125 0F ± 5 0F in water heater
35

Proposed Changes to Account for 125 °F Setpo• First Hour Rating Test

– Modifies criterion to terminate draws when outlet water b

cold

– Proposes to terminate draws when outlet water temperatu

below its maximum measured temperature during the dra

• Changes the criterion from the current 25 0F drop with the se

temperature at 135 0F

• Maintains the inherent assumption that the nominal minimu

temperature for hot water is 110 0F
36

Changes to Calculations• Maximum gpm Rating (Section 6.2.1)

• Simulated Use Test

– Modifies calculation procedures for Energy Factor to normalize st

temperature and delivered water temperature to 125 0F

Item 6: Is the proposed change to the nominal water delivery tem

125 0F appropriate, and if not, what data or information are availa

would justify a different water delivery temperature?

Item 7: Is the proposed method for setting the thermostat(s) of st

water heaters appropriate?

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 ൌ െ ൣ൫ത,2 െ ത,,2൯ െ ሺ125Ԭ െ 67.5Ԭሻ൧
37

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
38

Multiple Draw Patterns• Proposes a revised simulated‐use test that involves four 

draw patterns for water heaters of different capacities

– Classifies water heaters into the following usage categories: 1) Po

low, 3) medium, and 4) high.

– Bases classification on the rated first hour rating test for storage w

the rated maximum flow rate for instantaneous water heaters.

– Ranges are based on first‐hour rating data for existing models, req

the current plumbing code, and recommended cut‐offs proposed 

commenters to RFI

Usage Category First Hour Rating (gallons) Maximum Flo

(gallons/min.)

Point‐of‐Use FHR < 20 Max FR < 1.7

Low 20 ≤ FHR < 55 1.7 ≤ Max FR < 

Medium 55 ≤ FHR < 80 2.8 ≤ Max FR < 

High FHR ≥ 80 Max FR ≥ 4
39

Modified Draw Pattern• Proposes draw patterns having different daily draw volum

numbers of draws that capture the key ways in which hot 

in residences while yielding a test that is repeatable

– Implements draw patterns that involve draws with three di

rates, a variety of draw lengths, and a variety of spacing be

– Distributes draws to mimic timing of uses in a residence

– Specifies the following total volume of water drawn and nu

in 24 hour simulated test for each draw pattern:

Point‐of‐use: 10 gallons, 9 draws

Low: 38 gallons, 11 draws

Medium: 55 gallons, 12 draws

High: 84 gallons, 14 draws
40

Item 3: Is the proposed method of characterizing water heaters as 

low, medium, or high appropriate and sufficient?

Item 4: Are the draw patterns proposed for the different water he

categories appropriate?

Modified Draw Pattern
41

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
42

Rated Values• Due to impact on the EF efficiency requirements and ratin

proposes to establish requirements for rating the followin

– Rated Storage Volume– First Hour Rating

– Max GPM Rating

• New requirements for rated storage volume, first hour ra

max GPM rating would be placed in 10 CFR 429.

• DOE proposes to eliminate provisions that allow manufac

designate a single standard input rating for testing electriheaters that are identical except with different input ratin

DOE would require manufacturers test units at all input ra
43

Rated Values – Storage Volume

• DOE has had 63 water heaters tested at independent test la

– Rated storage volume was always higher than the measured storage 

samples that were tested

– ANSI and UL standards prescribe the allowable difference between m

rated storage volumes for water heaters

• Federal standards are directly proportional to rated storage 

– As rated storage volume increases, the efficiency requirement decre

• DOE proposes to require that any represented value of the 

volume must be calculated as the mean of the measured stvolumes, Vst, of all the units within the sample.

• For testing conducted by DOE, the certified rating will be co

only if the measurement is within five percent of the certifie

– If the certified rated storage volume is valid, that volume will be use

the required energy factor for the basic model.

– If the certified rated storage volume is invalid, the average measured 

used as the basis for the required energy factor for the basic model.
44

Rated Values – Storage Volume

• DOE tested 19 Electric Water Heaters.

– Rated storage volume ranged from 5.0% to 10.6% higher th

storage volume.

– On average rated storage volume was 9.4% higher than me

0.0%2.0%4.0%6.0%8.0%

10.0%12.0%14.0%16.0%18.0%

0 2 4 6 8 10 12 14 16 18 

Percent Difference b/t Measured and

Rated Volume

Unit Number
45

Rated Values – Storage Volume• DOE tested 44 gas and propane water heaters.

– Rated storage volume ranged from 1.5% to 15.6% higher th

storage volume.

– On average rated storage volume was 4.8% higher than me

0.0%2.0%4.0%6.0%8.0%

10.0%12.0%14.0%16.0%18.0%

0 5 10 15 20 25 30 35 40 

Percent Difference b/t Measured and

Rated Volume

Unit Number
46

Rated Values – FHR and Max GPM• Applicable draw pattern for 24‐hour simulated use test w

determined by either the FHR (storage) or Max GPM (inst

• DOE proposes that any represented value of FHR or Max 

be calculated as the mean of the measured FHR or Max Gof all the units within the sample

• For testing conducted by DOE, the certified rating will be 

valid only if the measurement is within five percent of the 

rating

– If the certified rating is valid, that rating will be used as the 

determining the draw pattern

– If the certified rating is invalid, the average measured ratin

the basis for determining the applicable draw pattern
47

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
48

Annual Energy Consumption• DOE proposes to revise calculation of annual energy cons

that it is based on the EF rating

• Bases calculation of the annual energy consumption on the 

rating rather than the daily energy consumption so that wa

models with the exact same EF rating have the same estim

energy consumption and yearly operating costs

• DOE proposes to add separate estimates of annual fossil 

consumption and annual electrical energy consumption i

the overall annual energy consumption

– Allows the user of the test procedure to estimate operation

water heaters that have dual fuel inputs
49

Calculation of Annual Energy Consumption• Annual Energy Consumption, Eannual

where: V: nominal volume of hot water drawn during applicab

: density of water at 125 0F

cp: specific heat of water at 91.5 0F

67: nominal temperature difference between inlet and 

Ef: energy factor

• Annual Electrical Energy Consumption, Eannual,e

Eannual,e = Eannual * (Qe/Q)/3412where: Qe: daily electrical energy consumption

Q: total energy used by water heater during 24 hour test

3412: conversion factor from Btu to kWh

• Annual Fossil Fuel Energy Consumption, Eannual,f

Eannual,f = Eannual – (Eannual,e x 3412)

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ૠ ૟࢖ࢉ ࣋ ࢂ

ࢌࡱ
50

Estimated Annual Operating Cost

• The estimated annual operating cost would be determined 

– For gas or oil estimated annual operating cost is the sum of:

• The product of the annual gas or oil energy consumption time

representative average unit cost of gas or oil, as appropriate, in 

Btu

• The product of the annual electric energy consumption times t

representative average unit cost of electricity in dollars per kilo

– For electric:

• The product of the annual energy consumption times the repr

average unit cost of electricity in dollars per kilowatt‐hour

Item 8: DOE seeks comment on the addition of terms to quantify d

energy consumption separately from fossil fuel energy consumptio

separate estimates of annual fossil fuel energy consumption and a

electrical energy consumption in addition to the overall annual en

consumption.
51

Description of Issues Addressed in this NOPR

Draw PatternsRated Values

D

E

B Test SetupC Test Conditions

A Scope of Coverage

F Annual Energy Consumption

G Conversion of Existing Ratings
52

Conversion of Existing Ratings• AEMTCA requires DOE to develop a mathematical conver

to translate from the existing metrics to the uniform desc

U.S.C. 6295(e)(5)(E))

• DOE will conduct a separate rulemaking to develop the m

conversion of existing efficiency ratings to ratings under tdescriptor

– Target completion end of 2014.

• Manufacturers can use conversion factor to rerate mode

existence prior to the effective date of the uniform descr

one year after publication or Dec. 31, 2015 (whichever is 

• Conversion factor must not affect the minimum efficienc

requirements for covered water heaters
53

Conversion of Existing Ratings• To date, DOE has performed testing on 20 water heaters:

– 10 Electric (8 storage, including 1 HP, and 2 instantaneous)– 8 Gas‐fired (5 storage and 3 instantaneous)

– 2 Oil‐fired storage

• FHR results – no trend

– FHR under proposal ranged from 13% lower to 30% higher than t

the current test. Average 2% increase under proposal.

• Max GPM results – increased

– All units tested had increase in max GPM ranging from 9% to 17% 

proposal. Average increase was 13%.

• EF results – generally decreased for low and medium patt

increase for high usage pattern

Item 2: Is information or data available regarding the translation o

first‐hour ratings to a first‐hour rating determined using the propo

point? What is the effect of such translation on the appropriate b

between different size categories?
54

Conversion of Existing Ratings – First Hour Rat• First hour rating results under proposed and current 

method shows no trend
55

Conversion of Existing Ratings – First Hour Rat• Grouped by draw pattern, slight increasing trend em

– Sample size too small and results too variable to draw defin

conclusions
56

Conversion of Existing Ratings – Max GPM Rat• Max GPM results under proposed test method incre

compared to current test method

0.000.200.400.600.801.001.201.40

012345

Maximum GPM rating under new test

procedure as percentage of rating under

current test

Maximum gpm rating under current test procedure

Natural gas Electric Line of equivalence
57

Conversion of Existing Ratings – Max GPM Rat• Increases occur for all sizes when grouped by draw p

0.000.200.400.600.801.001.201.40

0.0 1.0 2.0 3.0 4.0

Maximum GPM rating under new test

procedure as percentage of ating under

current test

Applicable draw profile under current test procedure

Natural gas Electric Line of equivalence

Pointof use Low usage Mediumusage High usa
58

Conversion of Existing Ratings – Energy Factor• Energy Factor shows little trend when results are gro

product type and current efficiency rating
59

Conversion of Existing Ratings – Energy Factor• Energy Factor generally decreases at draw patterns w

total volumes and increases for the high usage patte
60

Public Meeting Agenda

Description of Issues Addressed in This NOPRClosing Remarks

4

52 Regulatory History3 Rulemaking Overview

1 Introduction
61

Closing Remarks

Meeting participants are invited to provide clo

remarks or statements at this time.
62

How to Submit Written Comments

• In all correspondence, please refer to the residential and commercial 

rulemaking by:

 Test Procedures for Residential and Commercial Water Heaters Docket Number: EERE‐2011‐BT‐TP‐0042

 Regulatory Identification Number (RIN): 1904‐AC53

• Email: HeatingProducts‐2011‐TP‐0042@ee.doe.gov

Postal: Courier:Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Mailstop EE‐2J

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Offic950 L’Enfant Plaza, SW, 6th F

Washington, DC 20024Tel: (202) 586‐2945

Comment period closes: January 21, 2014 — 11:59 PM 

http://www1.eere.energy.gov/buildings