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Pu

Energy Conservation Standards for Appliances and Commercial Equipment

Energy Conservation ProgramNOPR Public Meeting for Alternative Efficiency Determination Methods (AEDMs)

June 5, 2012

Building Technology PEnergy Efficiency and Department of Energy
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• Introductions• Role of the Facilitator• Ground Rules (norms)

– Listen as an ally– Use short, succinct statements (keep to the point)– Hold sidebar conversations outside the room– Focus on issues, not personalities– One person speak at a time (raise hand to be recogniz

name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introduction
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Agenda

9:00 – 9:30 am9:30 – 9:45 am9:45 – 10:45 am10:45 – 11:00 am11:00 – 12:30 pm12:30 – 1:30 pm1:30 – 2:45 pm2:45 – 3:00 pm3:00 – 4:00 pm

Welcome, Introductions, Agenda Review, and Opening StatementsRulemaking OverviewDefinitions and Scope of CoverageBreakSubstantiation RequirementsLunchDOE ValidationBreakNext Steps and Closing Remarks
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• Present DOE’s proposal for applying Alternative 

Efficiency Determination Methods (AEDMs) to cequipment covered under its regulatory program

• Provide a forum for public discussion of rulemak

issues.

• Encourage interested parties to submit data, info

and written comments.

• Inform interested parties and facilitate the rulem

process.

Purpose of the Public Meeting
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Opening Statements

At this time, DOE welcomes opening remarks on the NOAlternative Efficiency Determination Methods.
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Public Meeting Agenda

1 Overview and Background2

3

4

Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation
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• AEDMs are:

– Computer modeling or mathematical tools that predict 

performance of non-tested basic models.

• Use of AEDMs:

– Allows manufacturers to rate and certify basic models 

the simulated energy use or efficiency results derived AEDM.

– May reduce manufacturer testing burden by reducing t

of testing required for developing certified ratings.

What are AEDMs?
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• DOE’s current regulations permit the use of AED

– Commercial heating, ventilation and air-conditioning (H

equipment

– Commercial water heating (WH) equipment – Distribution transformers– Electric motors

• Manufacturers of residential central air condition

(CACs) and central heat pumps (CHPs) may usAlternate Rating Method (ARM) to rate their noncombinations.

Background
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• DOE believes other similar products could be ra

through the use of AEDMs or ARMs.

• DOE also seeks to implement procedural chang

requirements for AEDMs and ARMs.

• DOE sought comment on these topics and othe

in a Request for Information (RFI), which was puin the Federal Register on April 18, 2011. 

• The NOPR being discussed today proposes spe

revisions to DOE’s regulations for AEDMs and Aa result of comments received in response to the 

Request for Information
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Public Meeting Agenda

1 Introduction and Overview2

3

4

Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation
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DOE proposes to combine its AEDM and ARM requirements under the term “AEDM.”

– The provisions DOE proposes to adopt are more simil

current provisions for AEDMs.

– AEDMs are used by a wider range of industries.– AEDMs and ARMs are conceptually identical.– DOE proposed product-specific requirements, where n

Naming Convention
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• DOE is not proposing to add a pre-approval proc

AEDMs and is proposing to drop the current preapproval requirement for CACs and CHPs.

– Pre-approval would place additional burden on manufa

and DOE.

– The proposed substantiation process requires a manu

test several basic models to validate accuracy of the A

• While DOE does not plan to review AEDMs prio

use, DOE may request the records underlying aat any time.

Pre-Approval by DOE
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Request for Comment

Issue 1: DOE requests comment on its proposal not to adpre-approval process for AEDMs and its proposal to no lorequire pre-approval for use of an alternative rating methoCACs and CHPs.
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• DOE proposes to expand the use of AEDMs to o

types of commercial equipment: 

– Commercial refrigeration equipment (CRE)– Automatic commercial ice makers (ACIMs)– Small electric motors– Refrigerated beverage vending machines (BVMs)– Walk-in cooler and freezer (WICF) refrigeration system

• DOE proposes to continue the use of AEDMs fo

– Commercial HVAC and WH equipment, distribution tra

and electric motors

– CACs and CHPs

Applicability of an AEDM

Issue 2: DOE requests comment on the proposed scopapplicability of AEDMs.
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• DOE believes that:

– AEDMs may be developed that can accurately simulat

performance of basic models across various product c

– Substantiation requirements should demonstrate that t

can accurately simulate performance for applicable prclasses.

• DOE proposes to require, as part of the substan

process, testing of at least one basic model from DOE product class to which the AEDM is to be a

Use Across Product Classes
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Request for Comment

Issue 3: DOE requests comment on its proposal to requleast one basic model from each product class be tested substantiate the AEDM. DOE is particularly interested in whether additional clarifis needed for manufacturers of certain covered products determine all the applicable product classes that would nbe tested to substantiate the AEDM. DOE requests feedback on how manufacturers currently develop simulation tools to ensure they are applicable acwide range of product classes. 
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Public Meeting Agenda

1 Introduction and Overview2

3

4

Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation
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• Proposed individual tolerances between the test 

of a basic model and AEDM output for that basic 

– 5%: CRE, WICF refrigeration systems, BVMs, ACIMs, 

distribution transformers, commercial HVAC and WH eand CACs and CHPs. 

– 10%: Electric motors and small electric motors

• Proposed overall tolerance for the average of al

– 3% for all equipment

AEDM Tolerances
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Request for Comment

Issue 4: DOE seeks product specific comments and suppdata on these proposed overall and individual tolerance leby product type.Specifically, DOE seeks data showing that the variability sthe manufacturing processes, test instrumentation, and teprocedures are such that a different tolerance should be considered. 
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Selecting Units for Substantiation

Proposed Requirement Applic

Test a minimum of five basic models including at least one basic model from each product class to which the AEDM will be applied.

Test 25 units (five units of five different basic models) D

Tra

Test the smallest and largest capacity basic models from the product class with the highest sales volume.

CA

Comm

and W

refrige

CRE 

Test the basic model with the highest sales volume the previous year, or the basic model which is expected to have the highest sales volume for newly introduced basic models.Test data used for substantiation must meet applicable Federal energy conservation standards and applicable DOE testing procedures in place at the time the basic model isdistributed in commerce.
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Request for Comment

Issue 5: DOE seeks comment on the proposed criteria foselecting basic models and the number of basic models tmanufacturer should be required to test for substantiation well as the necessity of differences in testing requirementdistribution transformers. 
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• Current DOE regulations:

– Manufacturers of commercial HVAC and water heaters 

undergo two rounds of testing to substantiate the AED

• NOPR:

– DOE is proposing new provisions that will require man

to perform additional testing and re-substantiation if choccur that may impact the validity of the AEDM.

– Manufacturers have the discretion to choose the exten

they want to conduct additional testing beyond the reqof this proposal.

– DOE is therefore proposing to eliminate the second ro

testing for commercial HVAC and water heaters. 

Number of Testing Rounds
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Public Meeting Agenda

1 Introduction and Overview2

3

4

Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation
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• AEDM validation:

– Ensures the accuracy of product ratings based on AED– Could be unnecessary and burdensome if too frequen

• NOPR proposals:

– DOE does not to specify a particular validation frequen

requirement

– DOE reserves the right to request the documentation s

the AEDM and to test a basic model at any point.

– Manufacturers must retain documentation containing:

• description of the AEDM• supporting substantiation test data• AEDM itself

Frequency of DOE Validation
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• DOE may conduct assessment testing to evalua

compliance with conservation standards pursua10 CFR 429.104 

• The test results obtained from the testing of one 

be compared to:

– Federal conservation standard

• Verify the unit complies with applicable conservation sta

– Manufacturer’s certified rating developed by AEDM

• Ensure that tolerances required by 10 CFR 429.70(c) ar

Assessment Testing
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• If DOE determines that the model fails to meet it

certified rating:

– Manufacturers must re-substantiate their AEDM within 

using the test data obtained through DOE testing and re-certify as necessary.

– If DOE test data include new results for basic models t

meet the substantiation criteria, the manufacturer musadditional modifications to the AEDM.

• DOE has tentatively decided not to require new 

for basic models outside of the affected product part of the re-substantiation process, in order to manufacturer burden.

Potential Outcomes of Assessment Testing Results – Failure to meet certified ratings
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Request for Comment

Issue 6: DOE requests comment on the appropriate couraction and necessary time to complete re-substantiation arating steps when a basic model tested by DOE fails to mcertified rating generated using an AEDM.
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Possible noncompliance with conservation standar

– Initiate an investigation pursuant to 10 CFR 429.106; a– Undertake enforcement testing pursuant to 10 CFR 42

Enforcement testing results in a noncompliance determination:

– All other models within that basic model are deemed n

compliant.

– If the basic model used for AEDM substantiation is fou

compliant, manufacturer must:

• Re-substantiate AEDM within 30 days of notification• Re-rate and re-certify all basic models as necessary.

– DOE will withhold a finding of noncompliance for all ot

models rated with the AEDM pending additional invest

– DOE will not require re-testing of basic models not fou

noncompliant.

Potential Outcomes of Assessment Testing Results – Non-compliance with Standards
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DOE proposes to disallow the use of an AEDM foll

– multiple instances of non-compliance 

and/or

– if there is evidence that the mis-rating was willful

Potential Outcomes of Assessment Testing Results – Non-compliance with Standards

Issue 7: DOE requests comment on the proposal that DOdisallow the use of an AEDM if there is evidence that the rating is willful and/or there are multiple instances of noncompliance. 
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• DOE is proposing that manufacturers must resubstantiate their AEDMs when:

– There is a change either to the applicable standards o

procedure.

– A model used to substantiate the AEDM is discontinue

becomes obsolete.

• When a manufacturer re-substantiates an AEDM

must be obtained from physical tests of current 

Re-substantiation of an AEDM

Issue 8: DOE requests comment on the necessity of requre-substantiation when there is a change in standards or procedure and requiring that AEDMs be substantiated witactive models.
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Closing Statements

At this time, DOE welcomes closing remarks on the NOPAlternative Efficiency Determination Methods.
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In all correspondence, include all of the following:

– Alternative Efficiency Determination Method Notice of Propose– Docket Number EERE-2011-BT-TP-0024– Regulatory Identification Number (RIN) 1904-AC46

Email: AED/ARM-2011-TP-0024@ee.doe.gov

Comment period closes July 2, 2012

DOE Seeks Comments on its Proposal

Postal Mail: 

Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW.Mailstop EE-2JWashington, DC 20585

Courier: 

Ms. Brenda EdwardsU.S. Department of EnerBuilding Technologies Pro950 L’Enfant Plaza, SW., 

Washington, DC 20024 Telephone: 202-586-294
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Relevant Web Pages

• DOE Appliance Standards

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

• Certification, Compliance, and Enforcement Webpage

– http://www1.eere.energy.gov/buildings/appliance_standards/c

enforcement.html

• Contact Ashley Armstrong, Project Manager, from the Applia

Standards Program for additional information: 

– Ashley.Armstrong@ee.doe.gov– 202-586-6590

• Contact John Cymbalsky, Supervisor, from the Appliance Sta

Program for additional information: 

– John.Cymbalsky@ee.doe.gov– 202-287-1692