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 UNITED STATES OF AMERICA 

 DEPARTMENT OF ENERGY 

PUBLIC MEETING 

 

ON 

 

TEST PROCEDURES FOR FURNACES AND BOILER MEETING 

(INCORPORATED BY REFERENCE IEC) 

 U.S. Department of Energy 

 1000 Independence Avenue, SW 

 Washington, DC 20585 

 Room 1E44 

 

 Monday 

 October 3, 2011 

 

Chair: 

Mohammed Khan 

Facilitator: 

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Joanna Mauer 

Appliance Standards Awareness Project (ASAP) 

529 14th St. NW, Suite 500 

Washington, DC 20045 

Frank Stanonik 

Chief Technical Advisor 

Air conditioning, Heating, and Refrigeration Institute 

2111 Wilson Boulevard 

Suite 500 

Arlington, VA 22201 

John Michael Talbottt 

Consultant 

NIST/DOE 

William Healy, Ph.D. 

NIST 

100 Bureau Drive, Stop 8632 

Gaithersburg, MD 20899 

Participants from DOE:

Mohammed Khan 

Building Technologies 

Ari Altman, 

General Counsel’s office 

 

Presenters:

Mohammed Khan 

DOE 

John Talbott 

Consultant NIST/DOE
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AGENDA

 ITEM PAGE 

 

Welcome, Doug Brookman 4 

Opening Remarks, Mr. Khan 4 

Introductions 6 

Agenda Review, Doug Brookman 7 

Rulemaking Overview, Mr. Khan 8 

 

Regulatory History, Mr. Khan 10 

Proposed Amendments, Mr. Talbott 14 

Additional Remarks 19 

Closing Remarks 22 
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Good morning everybody and 

3 welcome. This is the test procedures for 

4 residential furnaces and boilers, with incorporation 

5 of second edition of I.E.C. 62301 standard, 

6 addressing energy use in standby mode and off mode, 

7 a Notice of Proposed Rulemaking, public meeting. 

8 Today is October 3, 2011, here in the Forestall 

9 Building in Washington, D.C. My name is Doug 

10 Brookman. I’m the facilitator for today from Public 

11 Solutions in Baltimore. We’re going to start off 

12 this morning with welcoming remarks from Mohammed 

13 Khan. 

14 Welcoming Remarks 

15 MR. KHAN: Thank you, Doug. Good morning. 

16 Mohammed Khan, Department of Energy. First, I’d 

17 like to express appreciation for everyone’s 

18 participation here today. As all of you know that 

19 might be familiar with the public meetings that the 

20 Department of Energy puts on, I always emphasize the 

21 importance of the comments and the participation for 

22 the stakeholders and how that’s invaluable to us in 

23 the development of our standards as well as the test 
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1 procedurals that we do. 

2 This particular Rulemaking, which is for 

3 the test procedures for furnaces and boilers, may be 

4 -- I don’t know if everyone knows or not, but we’ve 

5 been working on for a while now, and I’m happy to 

6 see that we’re at the final stages of it. You may 

7 or may not know that this particular Rulemaking took 

8 on a couple of different phases or different 

9 approaches. We initially proposed a rule which did 

10 not include any kind of integration to the AFUE 

11 metric, and then later decided to propose an 

12 integrated AFUE. 

13 And then, based on the comments that were 

14 received from the stakeholders, we were able to 

15 determine that that was not really the best thing to 

16 do. 

17 So we’re here today to wrap this up, and 

18 what we’ve done is this time propose the second 

19 edition of the applicable industry standard, the IEC 

20 62301, and we’re very confident that this is the 

21 best thing to do. In fact, with support from 

22 another rule on a separate set of products being 

23 pool heaters, water heaters, and direct heating 

24 equipment, there were comments from industry that 

25 the second edition IEC was actually suitable and 
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1 offered better improvement. 

2 So with that, again, I thank you and turn 

3 it back to Doug. 

4 MR. BROOKMAN: Okay. Let’s do 

5 introductions around the room. Say your name, and 

6 organizational affiliation. I think it’s on. No? 

7 Is that better? Let’s start with introductions. 

8 Please. 

9 Introductions 

10 MR. STANONIK: Frank Stanonik, Air 

11 Conditioning, Heating and Refrigeration Institute. 

12 MS. MAUER: Joanna Mauer, Appliance 

13 Standards Awareness Project. 

14 DR. HEALY: Bill Healy from NIST. 

15 MR. TALBOTT: John Talbott, consultant for 

16 NIST. 

17 MR. ALTMAN: Ari Altman with the General 

18 Counsel’s office at DOE. 

19 MR. KHAN: Again, Mohammed Khan, 

20 Department of Energy, Building Technologies Office. 

21 MR. BROOKMAN: Okay. So thanks to all of 

22 you. Thanks for being here on time so we can get an 

23 early start on this. 

24 

25 Agenda Review
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1 MR. BROOKMAN: I think all of you received 

2 a packet of information as you came into the room 

3 today, and you can see that the agenda is listed on 

4 page two. We anticipate this will be a fairly short 

5 meeting today. 

6 We’re going to start off immediately 

7 following this agenda review with a rulemaking 

8 review by Mohammed. There’s an opportunity after 

9 that for all of you to have brief opening remarks if 

10 that’s applicable. We will, following that, talk 

11 about the rulemaking steps and history, and then a 

12 presentation from John Talbott on proposed 

13 amendments. Yet another opportunity for discussion, 

14 and description of key interests from interested 

15 parties, and then closing and next steps. We 

16 anticipate we’ll be done, probably before noon 

17 today. So that’s the general plan. 

18 So I’d ask for your consideration. You’ve 

19 all attended these meetings previously. Please 

20 speak one at a time. Please say your name for the 

21 record each time you speak. I’m going to be cuing 

22 individuals by name as best I can. We also 

23 appreciate those individuals who make follow on 

24 comments, that’s also useful for the Department. 

25 Please keep the focus here. Turn your 
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1 cell phones on silent mode. Limit sidebar 

2 conversations. And I know everyone will be concise 

3 and focused as the day goes on here today. 

4 So, questions or comments before we 

5 actually launch into the content? Then to Mohammed 

6 Khan. 

7 Rulemaking Overview 

8 MR. KHAN: Good morning everyone. Welcome 

9 and thank you for participating in the Department’s 

10 follow-up meeting on test procedures for residential 

11 furnaces and boilers. My name again, is Mohammed 

12 Khan and the Department of Energy’s project manager 

13 for this rulemaking activity. 

14 I’ll be providing an overview of the 

15 rulemaking, and John Talbott, who is a consultant to 

16 the Department of Energy will present details on the 

17 Department’s analyses and interpretation of the 

18 applicable industry standard. 

19 Today’s meeting serves multiple purposes, 

20 mainly, and as always, our goal is to have a two-way 

21 discussion. The Department wants to convey its key 

22 points and concepts associated with this rulemaking 

23 activity, and carefully listen to your thoughts and 

24 potential concerns. The Department believes that 

25 today’s opportunity for information exchange is very 
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1 essential. 

2 So first, the Department wants to present 

3 its proposal for test procedure amendments and seek 

4 your comments. Second, this is a forum for all 

5 interested parties to hear and discuss the issues 

6 raised by both the Department and by all others. 

7 And lastly, we’ll describe the next steps in 

8 Rulemaking, including how to submit comments and 

9 relevant data. 

10 This slide lists the steps that the 

11 Department has already taken as well as those that 

12 the Department will be performing in order to 

13 finalize the test procedure rulemaking. 

14  On October 20, 2010, DOE published, in the 

15 Federal Register, it’s test procedure final 

16 rule, then, 

17  On September 13, 2011, DOE published a NOPR, 

18 which proposed amendments to this 2010 final 

19 rule. 

20  Today we’re here to discuss the proposed test 

21 procedure provisions and the bases for them. 

22 Comments. Comments are key in 

23 facilitating any DOE standards or test procedure 

24 rulemaking. The Department carefully reviews and 
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1 considers all comments. DOE will review the 

2 transcript of today’s public meeting and any 

comments received by November 28th 3 , which is the 

4 close of the comment period. 

5 Once all comments or relevant data are 

6 considered, DOE will then develop its final rule 

7 and publish it in the Federal Register as soon as 

8 possible. 

9 At this juncture, we want to allow anybody 

10 who wishes to do so to present any opening remarks. 

11 I don’t think we had any requests to do so, but let 

12 me just ask again. 

13 MR. BROOKMAN: Yes, let’s do that. Any 

14 summary remarks here at the outset? None? I see 

15 none as I glance around the table. So we’ll 

16 proceed. 

17 Regulatory History 

18 MR. KHAN: Okay. Thank you. Let me talk 

19 briefly about the pertinent regulatory history and 

20 what’s driving this effort. Test procedures for 

21 residential furnaces and boilers are codified at 

22 10CFR Part 430, subpart B, Appendix N. These test 

23 procedures include measures for AFUE, energy use 

24 descriptors, operating costs, and as of recent, 

25 provisions for determining standby mode and off mode 
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1 electrical energy consumption. 

2 Regarding the applicable energy 

3 conservation standard, DOE is promulgating new 

4 standards in its direct final rule, which was 

5 published on June 27, 2011. The DFR establishes 

6 minimum requirements for AFUE, as well as 

7 requirements for standby mode and off mode 

8 electrical power consumption. 

9 This slide explains why DOE is required to 

10 consider standards for standby and off mode energy 

11 consumption, and which industry standards must also 

12 be considered. The Energy Independence Security Act 

13 of 2007 directs DOE to incorporate standby mode and 

14 off mode energy consumption into its test 

15 procedures. 

16 EISA 2007 also requires DOE to integrate 

17 standby and off mode into the applicable efficiency 

18 descriptor unless the Secretary determines that the 

19 current test procedure already fully accounts for 

20 standby and off mode energy consumption, or if it is 

21 not technically feasible to do so. Lastly, EISA 

22 says DOE must consider the current versions of the 

23 International Electrotechnical Commission Standard 

24 62301, entitled “Household Electrical Appliance: 

25 Measurement of standby power” and 62087, titled, 
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1 “Methods of Measurement for the Power Consumption of 

2 Audio, Video, and Related Equipment.” 

3 For this rulemaking covering residential 

4 furnaces and boilers, DOE believes 62301 is 

5 applicable only. 

6 (Pause because of computer problem.) 

7 MR. BROOKMAN: For those of you listening 

8 in, we’re having a little bit of technical 

9 difficulty that we’re trying to sort through. We’ll 

10 be back in motion here shortly. 

11 MR. KHAN: Okay. I apologize for that 

12 technical difficulty. Now, back in October 2010, 

13 DOE satisfied the EISA 2007 requirements relevant to 

14 residential furnaces and boilers, by publishing the 

15 final rule, amending test procedures for furnaces 

16 and boilers. In that rule it was determined that 

17 the AFUE metric already accounts for standby mode 

18 and off mode consumption of fossil fuel, but 

19 measures of electrical standby and off mode energy 

20 consumption were, in fact, needed. 

21 To fully satisfy the EISA requirement, 

22 DOE’s test procedure utilized the IEC standard 62301 

23 with some necessary clarifications. A key 

24 clarification was that the existing test procedure 

25 specifications for ambient temperature and voltage 
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1 shall apply in lieu of those specified in the IEC 

2 standard. 

3 The final and also very important point on 

4 this slide is that the test procedures reference the 

5 first edition of the IEC standard, which was the 

6 current version at that time. 

7 So not long after DOE published the 

8 October final rule for furnaces and boilers, the IEC 

9 finalized its second version of the 62301 standard. 

10 Because of the timing of the standard, DOE believed 

11 that the second edition was relevant and that a full 

12 review of it was necessary. After performing a full 

13 review, DOE concluded the second edition 62301 

14 offers a number of improvements and consequently, 

15 DOE is proposing to incorporate the current IEC 

16 standard 62301 in its entirety into the list of 

17 incorporated references found at 10CFR43.3, while 

18 identifying the applicable provisions of 62301 for 

19 DOE’s test procedures for residential furnaces and 

20 boilers. 

21 If there aren't any questions at this 

22 time, I’d like to turn it over to John Talbott. 

23 MR. BROOKMAN: Questions? 

24 

25 Proposed Amendments 
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1 MR. TALBOTT: Okay. This is John Talbott, 

2 consultant for NIST and we conducted a review of the 

3 new second edition IEC standard, and the following 

4 is the key points of the review. 

5 The two key areas where the improvement 

6 was determined was in the accuracy provisions and in 

7 the specification of stability. And I’ll discuss 

8 those in detail. 

9 On the accuracy, there is just a more 

10 comprehensive specification requiring accuracy. DOE 

11 believes that that revision provides a more 

12 realistic accuracy provision for a range of 

13 electricity that might be encountered in furnaces 

14 and boilers, thereby making the test method 

15 appropriate for a variety of situations that a 

16 furnace and boiler equipment could present. The new 

17 specification is more in line with the commercially 

18 available equipment that we surveyed, and it seems 

19 that the first edition really, sometimes the 

20 specification was not available in commercial 

21 equipment, and those issues were discussed with the 

22 process of the IEC in various drafts and comments to 

23 the drafts. And it was more or less universally 

24 agreed that an improvement in the accuracy provision 

25 was needed. 
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1 They actually used a specification that 

2 uses the maximum current ratio, and then specifies 

3 that the accuracy needed for these measurements of 

4 ten watts, would be 95 percent -- two percent at the 

5 95 percent level, and then for lower than a tenth of 

6 a watt. It specifies a more stricter absolute 

7 uncertainty of 0.02 watts at 95 percent of 

8 confidence. And this aligns itself with how the 

9 instrumentation that’s out there specifies accuracy. 

10 On the other issue of stability, and here 

11 again, there are more possibilities of an unstable 

12 situation with these low wattages. We did not find 

13 that in some of the testing that NIST has done, but 

14 nonetheless, we can’t rule out that it is not an 

15 issue for furnaces and boilers. And on the 

16 stability issue, they have described a much better 

17 way of determining stability. And in the testing 

18 that NIST has done, they were very much informed by 

19 the appendices of the IEC’s standard, in that it 

20 walks people through how to determine the stability. 

21 And we have reviewed some of the 

22 literature that comes with the instrumentation 

23 that’s available, and it speaks directly to the IEC 

24 standard 62301. And many of them just provide 

25 software to report out the variables that you need 
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1 to determine its stability. And so the user is 

2 given a choice if that stability test is met, they 

3 can just read it directly off the meter. 

4 And we feel that the Department is 

5 challenged from two areas here. They have to 

6 determine is there nothing in here that’s going to 

7 result in an unreasonable burden, or an additional 

8 burden? And we’re finding that there’s possibly 

9 some additional test time would be needed to 

10 determine this stability, but it’s not -- once it’s 

11 determined, a reasonable lab technician can 

12 accomplish it and proceed. 

13 So, in summary, the changes incorporated 

14 by the second edition would allow for less 

15 burdensome methods because it’s more clearly 

16 defined. The instrumentation literature speaks to 

17 the IEC standard, and the commercial, the available 

18 instruments are nothing special. They’re on the 

19 order of a couple thousand dollars if you wanted to 

20 start from scratch, and maybe three thousand dollars 

21 would get you to a unit that includes the software 

22 to directly address the IEC standard provisions. 

23 Although the furnaces and boilers 

24 rulemaking included a lot of discussion that these 

25 procedures are a little bit overkill for the 
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1 furnace-boiler industry, we’ve addressed most of 

2 those issues in the final rule. In particular, we 

3 allow for the existing test procedure specification 

4 of voltage and ambient air temperature to be used in 

5 lieu of the IEC standard, which was a burden if you 

6 had to use separate room air measurements and 

7 separate voltage measurements. So that’s all 

8 unified and so you’re left with the new version of 

9 the IEC standard with those two exceptions made. 

10 We have received supporting comment to the 

11 second edition in our various rulemakings, in 

12 particular, the heating products. The comments were 

13 very supportive and encouraged DOE to go to the 

14 second edition. 

15 So if there’s any further comments on the 

16 technical aspects, I think that’s it. 

17 MR. STANONIK: Frank Stanonik, AHRI. Just 

18 a couple questions, more for my education, I think. 

19 So this specification of the instrument uncertainty, 

20 two percent of the 95 percent confidence level for 

21 power values greater than one watt. Is this a 

22 normal parameter of instrumentation of this sort? 

23 In other words, if you go out and buy it, is the 

24 company going to say, oh, yeah, this particular 

25 instrument is this accurate? Or I think of a scale 
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1 might have an accuracy of, you know, plus or minus 

2 two pounds or something. Is this comparable? 

3 MR. TALBOTT: Yeah, I will let Bill Healy 

4 of NIST get into that level of detail. 

5 DR. HEALY: Bill Healy from NIST. Yes, we 

6 believe that it’s something that manufacturers 

7 should be able to supply. It’s a very standard -- 

8 so it would be something that’s associated with the 

9 instrument manufacturers should supply. 

10 MR. STANONIK: Okay. So to follow up. 

11 Frank Stanonik. So this is really, again, this is a 

12 parameter in terms of the quality of the instrument 

13 you need, but the actual measurement, what is being 

14 proposed now is, let’s say I’m rating a new model, 

15 and so I would run -- let’s say I ran three tests to 

16 measure the AFUE and in the course of those three 

17 samples I would also measure this three times and 

18 run the same statistical analysis. That’s the idea, 

19 right? For my standby/off mode. 

20 MR. TALBOTT: Yes, the standby/off mode 

21 measurement of wattage would be a measure of energy 

22 consumption subject to the sampling provisions that 

23 would be identical to the AFUE. And so this 95 

24 percent here, that’s specified here, is part of the 

25 instrument’s specification. So your documentation 
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1 on the instrument would provide that information. 

2 The sampling provisions also use the phrase 95 

3 percent confident, but that’ a different -- that’s 

4 relating to the sample size of the disclosure, of 

5 the representation. 

6 MR. STANONIK: Okay. Then, just want to 

7 confirm from what you looked at, roughly a meter 

8 that is capable of doing this, you’re talking about 

9 two or three thousand dollars? 

10 MR. TALBOTT: Yes. 

11 MR. BROOKMAN: Additional comments? Or 

12 questions related to this presentation? Okay. I 

13 see nothing additional. 

14 Additional Remarks 

15 As reflected in the agenda, there is an 

16 opportunity here, following the presentation for any 

17 additional remarks. Any other issues that anybody 

18 wishes to raise? Frank. 

19 MR. STANONIK: Frank Stanonik, AHRI. The 

20 reason for my questions, and we haven’t had a lot of 

21 comments up to date, up to this point on this 

22 particular rulemaking, but I did actually get a 

23 comment last week expressing some concern about the 

24 need for this, quote/unquote, “specialized 

25 instrument” that might cost $3000 or whatever, to 
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1 measure energy consumptions that are going to be -- 

2 potentially they’re going to be in the tens of 

3 watts. But anyhow, that’s only one comment, and if 

4 it turns out we have more members that it’s a 

5 concern, we’ll let you know. But I guess I’ll bring 

6 it to your attention now. 

7 MR. BROOKMAN: Okay. Thank you. 

8 MR. KHAN: Doug. 

9 MR. BROOKMAN: Mohammed, comment? 

10 MR. KHAN: Mohammed Khan, DOE. I 

11 appreciate those thoughts, Frank. I do believe that 

12 we also looked at the availability of such 

13 instrumentation and I’ll let Bill comment on it as 

14 well, but I think what we found was that that level 

15 of accuracy or ability within this instrumentation 

16 is pretty much commonplace, particularly at that 

17 price range, anyway. 

18 MR. BROOKMAN: Bill. 

19 DR. HEALY: Bill Healy from NIST. Just 

20 agree with Mohammed. Yes, I believe these are 

21 commercially available, readily available pieces of 

22 equipment. 

23 MR. STANONIK: Frank Stanonik, AHRI. A 

24 related question, and I apologize because I only pay 

25 attention to what I care about, I guess, but has a 
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1 similar proposal been put forth for the -- related 

2 to what I call the “white good” products, the 

3 dishwashers, clothes washers, products of that 

4 nature that also would have a measurement of 

5 standby/off mode? Because I know that AHAM was also 

6 concerned about the original test procedure. 

7 MR. KHAN: Mohammed Khan, DOE. It’s my 

8 understanding that the other products that are 

9 considered covered products that the Department must 

10 regulate are also going to be looking at the second 

11 edition of IEC, which has that same requirement, and 

12 I’m not sure of the status of those particular 

13 rulemakings or whether or not they’ve actually 

14 adopted them or referenced them as of yet, but my 

15 understanding, again, is that they are looking at 

16 the second edition. 

17 MR. BROOKMAN: So additional questions and 

18 comments? Or perhaps final and closing remarks? I 

19 see none additional. John Talbott, please. 

20 MR. TALBOTT: John Talbott. I have looked 

21 across some of the DOE other rules on the other 

22 products, and it’s -- the old -- some products have 

23 adopted parts of the IEC’s 62301 standard and some 

24 have adopted the entire standard, and so there are 

25 some differences across products, because there’s 
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1 some differences within those products that they 

2 choose not to go with some of the provisions. So 

3 there’s a mix in the DOE suite of products. And so 

4 for the time being, the first edition is called out 

5 in a reference, the list of references, and will 

6 remain there until the last product does not use it. 

7 Or maybe it’ll even stay then. So this is an 

8 additional reference added, the second edition. The 

9 first edition will remain, and then this rulemaking 

10 is about having it apply to Appendix N, furnaces and 

11 boilers, and taking Appendix N out of the first 

12 edition reference. 

13 So, a lot of products, and there’s a lot 

14 of differences, but generally they’re all going 

15 towards this second edition referencing. 

16 MR. BROOKMAN: Okay. So now we’re going 

17 to have closing remarks by Mohammed Khan. 

18 Closing Remarks 

19 MR. KHAN: Okay. Again, as I said at the 

20 outset of the meeting, your comments, thoughts, are 

21 very important and valuable to the Department of 

22 Energy in facilitating final rule development of our 

23 standards and test procedures. 

24 So this slide here just summarizes the 

25 ways and mechanisms for you to submit your comments 
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1 and any data that you might actually have that 

2 supports it as well. And then also, just to keep 

3 things clear and facilitate us handling the comments 

4 as they come in, please reference the information 

5 there regarding the docket, the RIN number, and of 

6 course the title, and as we said also, we’ll go 

7 through the transcript, consider all of your 

8 comments on the final rule and then process it and 

9 publish the final rule as soon as we can. 

10 And again, I thank you for your 

11 participation today. 

12 MR. BROOKMAN: Thanks to all of you. 

13 (Whereupon, at 9:44 a.m., the meeting in 

14 the above captioned matter was adjourned.) 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

 REPORTER'S CERTIFICATE
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 This is to certify that the attached proceedings 

before: 

U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

TEST PROCEDURES FOR FURNACES AND BOILER MEETING 

(INCORPORATED BY REFERENCE IEC) 

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law 

Judge or the Agency. 

 Further, I am neither counsel for or related to 

any party to the above proceedings. 

 

 

Wendy Greene 

 Official Reporter 

Dated: October 6, 2011