December 4, 2013

Docket Number: EERE-2013-BT-TP-0004

DirectHeatingPoolHeaters2013TP0004@ee.doe.gov

Test Procedure NOPR for Direct Heating Equipment and Pool Heaters

u.s. DEPARTMENT OF 

ENERGY Energy Efficiency & 

Renewable Energy 
2

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 your name for 

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 
3

Public Meeting Agenda

Description of Issues Addressed in This 

NOPR 4

2 Regulatory History

3 Rulemaking Overview

1 Introduction

5 Closing Remarks
4

Listening Via the Webcast

• The U.S. Department of Energy (DOE) is broadcasting this meeting live 

over the internet. 

• DOE is providing the webcast to accommodate interested parties that are 

unable to attend the public meeting in person.

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

and submit questions and comments.

• All interested parties are encouraged to submit written comments after 

the public meeting but before the close of the public comment period on 

January 7, 2014.
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Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate test 

procedure amendments for Direct Heating Equipment and Pool Heaters

• Invite comment on the test procedure notice of proposed rulemaking 

(NOPR)

• Discuss next steps in the rulemaking.

• Encourage participants to submit data, information, summary statements, 

and written comments, including additional issues for discussion.
6

Request for Comment

The deadline for submitting comments is January 7, 2014. 

While DOE invites comment on all aspects of the material presented in 

this document, several specific issues on which DOE seeks comment are 

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

to highlight issues and to ask specific questions on the approaches taken 

to amend the test procedures.
7

Public Meeting Agenda

Description of Issues Addressed in This 

NOPR

Closing Remarks

4

5

2 Regulatory History

3 Rulemaking Overview

1 Introduction
8

Regulatory History

• The Energy Policy and Conservation Act (EPCA) of 1975 

(Public Law 94-163)

– Established the Energy Conservation Program for 

consumer products other than automobiles, which 

includes direct heating equipment and pool heaters

– Directs DOE to establish test procedures in conjunction 

with energy conservation standards.

– Subsequent amendments to EPCA require the Secretary 

to review periodically all test procedures for possible 

amendment. (42 U.S.C. 6293 (b))

• The Energy Independence and Security Act of 2007 

(EISA 2007) (Public Law 110-140) 

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

amendment to measure and incorporate standby mode 

and off mode energy consumption into all test 

procedures (42 U.S.C. 6295(gg)(2))
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Regulatory History

• On May 12, 1997, DOE published a final rule in the Federal Register

establishing the current test procedures for direct heating equipment (DHE) 

and pool heaters. 62 FR 26140.

• The current test procedure for vented home heating equipment is found in 

Appendix O to Subpart B of 10 CFR Part 430 and applies to DHE.

• The current test procedure for pool heaters is found in Appendix P to 

Subpart B of 10 CFR Part 430.

• On December 17, 2012, DOE published in the Federal Register a final rule 

establishing a method for measuring the electrical energy use of DHE and 

pool heaters in standby mode and off mode. 75 FR 74559.

• On October 12, 2011, DOE published a request for information (RFI) on the 

need to amend the test procedures for DHE and pool heaters. 76 FR 63211.
10

Public Meeting Agenda

Description of issues Addressed in this 

NOPR 

Closing Remarks

4

5

2 Regulatory History

3 Rulemaking Overview

1 Introduction
11

• DOE published the direct heating equipment and pool heaters 

test procedure NOPR on October 24, 2013. 78 FR 63410.

• DOE is holding the NOPR public meeting today, December 4, 

2013.

• DOE will accept comments on the NOPR from interested 

parties.

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

– Interested parties can submit written comments until January 7, 2014.

– DOE reviews and considers all comments.

• DOE expects to issue a final rule in early 2014.

Steps in the Rulemaking Process

NOPR Final Rule 
12

Public Meeting Agenda

Description of Issues Addressed in This 

NOPR

Closing Remarks

4

5

2 Regulatory History

3 Rulemaking Overview

1 Introduction
13

Summary of Proposed Updates: Direct Heating Equipment

• Adds provisions for testing vented home heating equipment 

that utilizes condensing technologies;

• Replaces outdated references to industry standards with 

references to six current industry test standards that do not 

substantively modify test set-up or conditions;

• Reduces the test burden for floor furnaces by allowing a default 

assigned value for jacket loss in lieu of testing; and

• Includes clarifications and corrections.
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Provisions for Condensing Technologies

• Method to determine the efficiency of vented heaters that 

utilize condensing technologies

– Proposes using provisions similar to those found in DOE’s furnace and boiler test 

procedures.

– Would incorporate the method for testing condensing products from ASHRAE 

103-2007 “Method of Testing for Annual Fuel Utilization Efficiency of Residential 

Central Furnaces and Boilers” as stand-alone amendments to DOE’s vented 

heater test procedure.

• A separate test is conducted where condensate from the combustion 

process is directly collected and measured.

• For testing of condensing units that are not designed to collect and dispose 

of condensate in normal use, such means must be provided during testing.

• Using the measured condensate result, a reduction in the latent heat loss 

term (LL,A) is calculated to reflect the deserved efficiency increase. 

• The provisions would apply to all types of direct heating equipment. 
15

Updates of Industry Reference Standards

• Updates to referenced industry test standards

– Current test procedure references various industry standards that have 

been superseded and are no longer current. 

– DOE proposes to adopt six current industry standards. 

• In several cases, the proposed changes reflect the updating of specific 

provisions of the old standards to essentially identical provisions contained 

in the most current version of these standards. 

• In one case, the separate references for gas floor furnaces, gas wall furnaces, 

and gas room heaters are replaced with ANSI Z21.86-2008, which covers all 

three types of vented heaters. 

• ANSI/ASHRAE Standard 103-2007 is proposed for use in lieu of three older 

standards. 
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Jacket Loss and Clarifications & Corrections

• Jacket loss

− To reduce testing burden, NOPR proposes that an assigned default value 

of 1 percent for jacket loss be optionally used in lieu of jacket loss testing 

for floor furnaces. This value is identical to the allowance for furnaces 

and boilers. 

• Clarifications and corrections

− Proposes that an equation be added to section 4.2.4 to provide a means 

of calculating a weighted-average steady-state efficiency for manually 

controlled vented heaters. 

− Proposes that the tracer gas procedures in section 3.3 be modified to 

make it clear how to test units not employing a thermal stack damper. 

− Proposes to correct typographical errors in section 4.3.6 in an equation 

to compute part-load fuel utilization efficiency. 

 
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Issues on which DOE seeks comment: Direct Heating Equipment

Item 1: Are the proposed provisions for testing vented heaters that are capable 

of condensing operation appropriate and sufficient?

Item 2: Are the updates to the industry standards incorporated by reference 

into the direct heating equipment test procedure appropriate and sufficient?

 

Item 3: Is the assignment of a 1-percent default jacket loss in lieu of testing for 

vented floor furnaces appropriate? 

Item 4: What are the anticipated impacts of this proposed rule on small 

business manufacturers of direct heating equipment? 
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Summary of Proposed Updates: Pool Heaters

Proposed expansion to cover electric pool heaters

– Would include both electric heat pump pool heaters and electric 

resistance heaters

Proposed clarification for oil-fired pool heaters

– The proposed amendments clarify that the test procedure also applies to 

oil-fueled pool heaters. 

– No changes to test procedure are required for this clarification. 
19

Coverage of Electric Pool Heaters

• Proposed expansion of test procedure to cover electric pool 

heaters 

– Proposed amendments for heat pump type electric pool heaters would 

reference ANSI/ASHRAE Standard 1160-2009, “Performance Rating of 

Heat Pump Pool Heaters” and ANSI/ASHRAE Standard 146-2011, 

“Method of Testing and Rating Pool Heaters”

– Proposed amendments for electric resistance type pool heaters would 

reference ANSI/ASHRAE Standard 146 -2011, “Method of Testing and 

Rating Pool Heaters”

– Proposed amendments would include additional calculations to 

determine integrated thermal efficiency, expressed in terms of percent, 

for all types of pool heaters.

– DOE is proposing to include a method to determine the integrated 

thermal efficiency based on the COP value for heat pump pool heaters.
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Issues on which DOE seeks comment: Pool Heaters

Item 5: Are the proposed provisions for testing electric resistance and heat 

pump pool heaters appropriate and sufficient?

Item 6: What are the anticipated impacts of this proposed rule on small 

business manufacturers of pool heaters? 
21

Public Meeting Agenda

Description of Issues Addressed in This 

NOPR

Closing Remarks

4

5

2 Regulatory History

3 Rulemaking Overview

1 Introduction
22

Closing Remarks

Meeting participants are invited to provide closing 

remarks or statements at this time. 
23

How to Submit Written Comments

• In all correspondence, please refer to the commercial packaged boiler rulemaking 

by: 

− Test Procedures for Direct Heating Equipment and Pool Heaters

− Docket Number: EERE-2013-BT-TP-0004 

− Regulatory Identification Number (RIN): 1904-AC94

• Email: DirectHeatingPoolHeaters2013TP0004@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: (202) 586-2945

Comment period closes: January 7, 2014 — 11:59 PM EDT