MEMORANDUM

To: Heating Products Docket Number: EE-2006-STD-0129 From: Mohammed Khan, Building Technol ogies, U.S. Department of Energy Date: July 15, 2008

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This memo provides a summary of a meeting held on Monday, July 14, 2008 between the U.S. Department of Energy sta ff and representatives of the Air-Conditioning, Heating and Refrigeration Inst itute (AHRI) and some of its members. The meeting was held at DOE, Office of Building Technologi es, at 650 L’Enfant Plaza. The meeting

commenced at 2 PM and concluded at 3:30P M. The attendees included the following:

Representing DOE : Mohammed Khan, Building Technologies Ronald Lewis, Building Technologies Michael McCabe, Building Technologies Eric Stas, General Counsel Francine Pinto, General Counsel Michael Kido, General Counsel Mark Friedrichs (via teleconference), Of fice of Policy and International Affairs

Representing AHRI : Frank Stanonik Joseph Mattingly

Manufacturers : Joe Boros, Rheem Manufacturing William Hoover, A.O. Smith Manufacturing Ryan Ritsema, Bradford White Manufacturing

Attendees via teleconference : Alex Lekov, Lawrence Berkeley National Laboratory (LBNL) Lisa Thompson, LBNL Jim McMahon, LBNL Ashley Armstrong, Navigant Consulting, Inc. (NCI) Matt O’Hare, NCI

The purpose of the meeting was to provide AHRI and its members, at their request, opportunity to discuss their con cerns regarding the following topic areas:

• The energy factor (EF) for storage-type water heaters (specifi cally, gas-fired and electric) and its relationshi p to storage tank volume;

• Coverage for currently unregulated stor age-type water heaters with a storage volume between 2 and 20 gallons; and

• Establishing a separate product cla ss for “Ultra Low NOx” water heaters required in Southern California.

1The first concern AHRI and the thr ee manufacturers discussed was the relationship between the EF of storage-type water heaters, ma inly gas-fired and electric, and storage volume of the ta nk. Specifically, AHRI expr essed concerns that the promulgation of amended energy conservation standards for storage water heaters would amount to simply the raising or “shifting” of the EF lines. AHRI and its members stated the existing relationship between EF and th e storage volume of the tank is linear. However, low-volume water heaters (i.e., those below 30 gallons) using traditional technologies are essentially at their maximu m efficiency and they believe it would be extremely challenging to further increase the EF of these smaller units. Manufacturers also indicated that the gap between the Federal energy conservation standards and higher efficiencies is very small for low volume water heaters, which also makes testing extremely difficult. AHRI suggested the DOE consider changing how it characterizes the relationship between energy factor and storag e volume of gas-fired storage-type and electric storage-type water heaters. AHR I mentioned one option could be to use nonlinear approach (e.g., quadratic equation) or to use two equations defi ning different parts of the standards line or a constant slope a nd boundary approach (i.e., a straight line once the maximum EF using conventional technologies is reached). DOE staff indicated that industry data, which supports AHRI’s suggestion, would be useful in its consideration of the issue. AHRI said it would provide wr itten comments subsequent to the ANOPR publication and any possible data it was ab le to gather from manufacturers.

The second issue AHRI and the three manu facturers wanted to discuss was the coverage of storage-type wate r heaters rated greater than or equal to 2 gallons and less than 20 gallons. AHRI said it believes there is a need to regulate these types of water heaters because they use a significant amount of energy. It indicated that while many of

the units are not used in the residential sector, total annual shipments are about 300,000. AHRI members present indicated that a signi ficant issue is the heat loss through the fittings attached to the 2-20 gallon units, whic h in comparison to the larger storage water heaters, is disproportionally high. ASHRAE SPC 118.2 is in a pro cess of updating the test procedure and may address testing requi rements for these products but the ASHRAE process is not likely to be completed befo re this rulemaking is published. DOE staff pointed out there is currently no test procedur e in place to gauge the performance of these products and that the most recent effort ( 1998) failed to establis h a consensus for an applicable test procedure. AHRI said that perhaps a standby loss test procedure would suffice, and that the standby loss test proce dure from the current water heater test procedure may be applicable. AHRI also said it would submit comments in response to the ANOPR regarding this issue.

The final issue discussed concerned wa ter heaters incorporating a new technology for controlling NOx emissions in water heaters distributed to Southern California. AHRI indicated that manufacturers, in response to new Southern California emissions requirements (SCAQMD), have developed a technology that achie ves “Ultra Low NOx”

emission standards. AHRI believes this new burner technology that is used to control NOx emission also negatively affects the ener gy efficiency of the water heater. AHRI

23 indicated the technology when used for natura l draft water heaters is currently limited to 40 kBtu/h burner capacity. AHRI suggested the DOE consider establishing a separate product class for these products. DOE staff said that there are certain statutory requirements it follows in establishing re gulated product classes and encouraged AHRI

submit its comments in context of the stat utory requirements. AHRI said it would provide its comments in response to the ANOPR.