1 | Building Technologies Programeere.energy.govPublic Service of Colorado Ponnequin Wind FarmEnergy Conservation Standards forAppliances and Commercial EquipmentEnergy Conservation ProgramNOPR Public Meeting for Alternative EfficiencyDetermination Methods (AEDMs)June 5, 2012Building Technology ProgramEnergy Efficiency and Renewable EnergyDepartment of Energy2 | Building Technologies Programeere.energy.gov• 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 recognized, statename for the record)– Set cell phones to silent/vibrate• Housekeeping ItemsWelcome and Introduction3 | Building Technologies Programeere.energy.govAgenda9:00 – 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 pmWelcome, Introductions, Agenda Review, andOpening StatementsRulemaking OverviewDefinitions and Scope of CoverageBreakSubstantiation RequirementsLunchDOE ValidationBreakNext Steps and Closing Remarks4 | Building Technologies Programeere.energy.gov• Present DOE’s proposal for applying AlternativeEfficiency Determination Methods (AEDMs) to certainequipment covered under its regulatory program.• Provide a forum for public discussion of rulemakingissues.• Encourage interested parties to submit data, information,and written comments.• Inform interested parties and facilitate the rulemakingprocess.Purpose of the Public Meeting5 | Building Technologies Programeere.energy.govOpening StatementsAt this time, DOE welcomes opening remarks on the NOPR forAlternative Efficiency Determination Methods.6 | Building Technologies Programeere.energy.govPublic Meeting Agenda1Overview and Background234Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation7 | Building Technologies Programeere.energy.gov• AEDMs are:– Computer modeling or mathematical tools that predict theperformance of non-tested basic models.• Use of AEDMs:– Allows manufacturers to rate and certify basic models by usingthe simulated energy use or efficiency results derived from anAEDM.– May reduce manufacturer testing burden by reducing the amountof testing required for developing certified ratings.What are AEDMs?8 | Building Technologies Programeere.energy.gov• DOE’s current regulations permit the use of AEDMs for:– Commercial heating, ventilation and air-conditioning (HVAC)equipment– Commercial water heating (WH) equipment– Distribution transformers– Electric motors• Manufacturers of residential central air conditioners(CACs) and central heat pumps (CHPs) may use anAlternate Rating Method (ARM) to rate their non-testedcombinations.Background9 | Building Technologies Programeere.energy.gov• DOE believes other similar products could be ratedthrough the use of AEDMs or ARMs.• DOE also seeks to implement procedural changes to itsrequirements for AEDMs and ARMs.• DOE sought comment on these topics and other issuesin a Request for Information (RFI), which was publishedin theFederal Registeron April 18, 2011.• The NOPR being discussed today proposes specificrevisions to DOE’s regulations for AEDMs and ARMs asa result of comments received in response to the RFI.Request for Information10 | Building Technologies Programeere.energy.govPublic Meeting Agenda1Introduction and Overview234Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation11 | Building Technologies Programeere.energy.govDOE proposes to combine its AEDM and ARMrequirements under the term “AEDM.”– The provisions DOE proposes to adopt are more similar to thecurrent provisions for AEDMs.– AEDMs are used by a wider range of industries.– AEDMs and ARMs are conceptually identical.– DOE proposed product-specific requirements, where necessary.Naming Convention12 | Building Technologies Programeere.energy.gov• DOE is not proposing to add a pre-approval process forAEDMs and is proposing to drop the current preapproval requirement for CACs and CHPs.– Pre-approval would place additional burden on manufacturersand DOE.– The proposed substantiation process requires a manufacturer totest several basic models to validate accuracy of the AEDM.• While DOE does not plan to review AEDMs prior to theiruse, DOE may request the records underlying an AEDMat any time.Pre-Approval by DOE13 | Building Technologies Programeere.energy.govRequest for CommentIssue 1:DOE requests comment on its proposal not to add apre-approval process for AEDMs and its proposal to no longerrequire pre-approval for use of an alternative rating method forCACs and CHPs.14 | Building Technologies Programeere.energy.gov• DOE proposes to expand the use of AEDMs to othertypes 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 systems• DOE proposes to continue the use of AEDMs for:– Commercial HVAC and WH equipment, distribution transformers,and electric motors– CACs and CHPsApplicability of an AEDMIssue 2:DOE requests comment on the proposed scope ofapplicability of AEDMs.15 | Building Technologies Programeere.energy.gov• DOE believes that:– AEDMs may be developed that can accurately simulate theperformance of basic models across various product classes.– Substantiation requirements should demonstrate that the AEDMcan accurately simulate performance for applicable productclasses.• DOE proposes to require, as part of the substantiationprocess, testing of at least one basic model from eachDOE product class to which the AEDM is to be applied.Use Across Product Classes16 | Building Technologies Programeere.energy.govRequest for CommentIssue 3:DOE requests comment on its proposal to require atleast one basic model from each product class be tested tosubstantiate the AEDM.DOE is particularly interested in whether additional clarificationis needed for manufacturers of certain covered products todetermine all the applicable product classes that would need tobe tested to substantiate the AEDM.DOE requests feedback on how manufacturers currentlydevelop simulation tools to ensure they are applicable across awide range of product classes.17 | Building Technologies Programeere.energy.govPublic Meeting Agenda1Introduction and Overview234Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation18 | Building Technologies Programeere.energy.gov• Proposed individual tolerances between the test resultsof a basic model and AEDM output for that basic model:– 5%: CRE, WICF refrigeration systems, BVMs, ACIMs,distribution transformers, commercial HVAC and WH equipment,and CACs and CHPs.– 10%: Electric motors and small electric motors• Proposed overall tolerance for the average of all tests:– 3% for all equipmentAEDM Tolerances19 | Building Technologies Programeere.energy.govRequest for CommentIssue 4:DOE seeks product specific comments and supportingdata on these proposed overall and individual tolerance levelsby product type.Specifically, DOE seeks data showing that the variability seen inthe manufacturing processes, test instrumentation, and testingprocedures are such that a different tolerance should beconsidered.20 | Building Technologies Programeere.energy.govSelecting Units for SubstantiationProposed Requirement Applicable ProductsTest a minimum of five basic models including at least onebasic model from each product class to which the AEDM willbe applied.AllTest 25 units (five units of five different basic models)DistributionTransformersTest the smallest and largest capacity basic models from theproduct class with the highest sales volume.CAC and CHP,Commercial HVACand WH, ACIM, WICFrefrigeration systems,CRE and BVMsTest the basic model with the highest sales volume theprevious year, or the basic model which is expected to havethe highest sales volume for newly introduced basic models.AllTest data used for substantiation must meet applicableFederal energy conservation standards and applicable DOEtesting procedures in place at the time the basic model isdistributed in commerce.All21 | Building Technologies Programeere.energy.govRequest for CommentIssue 5:DOE seeks comment on the proposed criteria forselecting basic models and the number of basic models that amanufacturer should be required to test for substantiation aswell as the necessity of differences in testing requirements fordistribution transformers.22 | Building Technologies Programeere.energy.gov• Current DOE regulations:– Manufacturers of commercial HVAC and water heaters mustundergo two rounds of testingto substantiate the AEDM.• NOPR:– DOE is proposing new provisions that will require manufacturersto perform additional testing and re-substantiation if changesoccur that may impact the validity of the AEDM.– Manufacturers have the discretionto choose the extent to whichthey want to conduct additional testing beyond the requirementsof this proposal.– DOE is therefore proposing to eliminate the second round oftesting for commercial HVAC and water heaters.Number of Testing Rounds23 | Building Technologies Programeere.energy.govPublic Meeting Agenda1Introduction and Overview234Definitions and Scope of CoverageSubstantiation RequirementsDOE Validation24 | Building Technologies Programeere.energy.gov• AEDM validation:– Ensures the accuracy of product ratings based on AEDMs– Could be unnecessary and burdensome if too frequent• NOPR proposals:– DOE does not to specify a particular validation frequencyrequirement– DOE reserves the right to request the documentation supportingthe AEDM and to test a basic model at any point.– Manufacturers must retain documentation containing:• description of the AEDM• supporting substantiation test data• AEDM itselfFrequency of DOE Validation25 | Building Technologies Programeere.energy.gov• DOE may conduct assessment testing to evaluatecompliance with conservation standards pursuant to10 CFR 429.104• The test results obtained from the testing of one unit willbe compared to:– Federal conservation standard• Verify the unit complies with applicable conservation standard– Manufacturer’s certified rating developed by AEDM• Ensure that tolerances required by 10 CFR 429.70(c) are metAssessment Testing26 | Building Technologies Programeere.energy.gov• If DOE determines that the model fails to meet itscertified rating:– Manufacturers must re-substantiate their AEDM within 30 daysusing the test data obtained through DOE testing and re-rate andre-certify as necessary.– If DOE test data include new results for basic models that do notmeet the substantiation criteria, the manufacturer must makeadditional modifications to the AEDM.• DOE has tentatively decided not to require new testingfor basic models outside of the affected product class aspart of the re-substantiation process, in order to alleviatemanufacturer burden.Potential Outcomes of Assessment TestingResults – Failure to meet certified ratings27 | Building Technologies Programeere.energy.govRequest for CommentIssue 6:DOE requests comment on the appropriate course ofaction and necessary time to complete re-substantiation and rerating steps when a basic model tested by DOE fails to meet itscertified rating generated using an AEDM.28 | Building Technologies Programeere.energy.govPossible noncompliance with conservation standard:– Initiate an investigation pursuant to 10 CFR 429.106; and/or– Undertake enforcement testing pursuant to 10 CFR 429.110Enforcement testing results in a noncompliancedetermination:– All other models within that basic model are deemed noncompliant.– If the basic model used for AEDM substantiation is found noncompliant, 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 other basicmodels rated with the AEDM pending additional investigation.– DOE will not require re-testing of basic models not found to benoncompliant.Potential Outcomes of Assessment TestingResults – Non-compliance with Standards29 | Building Technologies Programeere.energy.govDOE proposes to disallow the use of an AEDM following:– multiple instances of non-complianceand/or– if there is evidence that the mis-rating was willfulPotential Outcomes of Assessment TestingResults – Non-compliance with StandardsIssue 7:DOE requests comment on the proposal that DOEdisallow the use of an AEDM if there is evidence that the misrating is willful and/or thereare multiple instances of noncompliance.30 | Building Technologies Programeere.energy.gov• DOE is proposing that manufacturers must resubstantiate their AEDMs when:– There is a change either to theapplicable standards or DOE testprocedure.– A model used to substantiate the AEDM is discontinued orbecomes obsolete.• When a manufacturer re-substantiates an AEDM, datamust be obtained from physical tests of current models.Re-substantiation of an AEDMIssue 8:DOE requests comment on the necessity of requiringre-substantiation when there isa change in standards or testprocedure and requiring that AEDMs be substantiated withactive models.31 | Building Technologies Programeere.energy.govClosing StatementsAt this time, DOE welcomes closing remarks on the NOPR forAlternative Efficiency Determination Methods.32 | Building Technologies Programeere.energy.govIn all correspondence, include all of the following:– Alternative Efficiency Determination Method Notice of Proposed Rulemaking– Docket Number EERE-2011-BT-TP-0024– Regulatory Identification Number (RIN) 1904-AC46Email: AED/ARM-2011-TP-0024@ee.doe.govComment period closes July 2, 2012DOE Seeks Comments on its ProposalPostal Mail:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW.Mailstop EE-2JWashington, DC 20585Courier:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, SW., 6thFloorWashington, DC 20024Telephone: 202-586-294533 | Building Technologies Programeere.energy.govRelevant 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/certification_enforcement.html•Contact Ashley Armstrong, Project Manager, from the ApplianceStandards Program for additional information:–Ashley.Armstrong@ee.doe.gov–202-586-6590•Contact John Cymbalsky, Supervisor, from the Appliance StandardsProgram for additional information:–John.Cymbalsky@ee.doe.gov–202-287-1692