MEMORANDUM 

To: Heating Products Docket Number: EE-2006-STD-0129 

From: Mohammed Khan, Building Technologies, U.S. Department of Energy 

Date: July 15, 2008 

------------------------------------------------------------------------------------------------------------ 

 This memo provides a summary of a meeting held on Monday, July 14, 2008 

between the U.S. Department of Energy staff and representatives of the Air-Conditioning, 

Heating and Refrigeration Institute (AHRI) and some of its members. The meeting was 

held at DOE, Office of Building Technologies, at 650 L’Enfant Plaza. The meeting 

commenced at 2 PM and concluded at 3:30PM. 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), Office 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 concerns regarding the following topic areas: 

• The energy factor (EF) for storage-type water heaters (specifically, gas-fired and 

electric) and its relationship to storage tank volume; 

• Coverage for currently unregulated storage-type water heaters with a storage 

volume between 2 and 20 gallons; and 

• Establishing a separate product class for “Ultra Low NOx” water heaters 

required in Southern California. 

1

 EE-2006-STD-0129 COMMENT 28
 The first concern AHRI and the three manufacturers discussed was the 

relationship between the EF of storage-type water heaters, mainly gas-fired and electric, 

and storage volume of the tank. Specifically, AHRI expressed 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 the 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 maximum 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 storage volume of gas-fired storage-type and 

electric storage-type water heaters. AHRI mentioned one option could be to use nonlinear approach (e.g., quadratic equation) or to use two equations defining different parts 

of the standards line or a constant slope and 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 written comments subsequent to the ANOPR 

publication and any possible data it was able to gather from manufacturers. 

 The second issue AHRI and the three manufacturers wanted to discuss was the 

coverage of storage-type water 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 significant issue is the heat loss through the 

fittings attached to the 2-20 gallon units, which in comparison to the larger storage water 

heaters, is disproportionally high. ASHRAE SPC 118.2 is in a process of updating the 

test procedure and may address testing requirements for these products but the ASHRAE 

process is not likely to be completed before this rulemaking is published. DOE staff 

pointed out there is currently no test procedure in place to gauge the performance of these 

products and that the most recent effort (1998) failed to establish a consensus for an 

applicable test procedure. AHRI said that perhaps a standby loss test procedure would 

suffice, and that the standby loss test procedure 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 water 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 achieves “Ultra Low NOx” 

emission standards. AHRI believes this new burner technology that is used to control 

NOx emission also negatively affects the energy efficiency of the water heater. AHRI 

2

 EE-2006-STD-0129 COMMENT 28
3

indicated the technology when used for natural 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 regulated product classes and encouraged AHRI 

submit its comments in context of the statutory requirements. AHRI said it would 

provide its comments in response to the ANOPR. 

 EE-2006-STD-0129 COMMENT 28