[Federal Register Volume 83, Number 220 (Wednesday, November 14, 2018)]
[Proposed Rules]
[Pages 56746-56750]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-24697]
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DEPARTMENT OF ENERGY
10 CFR Part 430
Energy Conservation Program: Test Procedures for Consumer Warm
Air Furnaces, Notice of Petition for Rulemaking
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for rulemaking; request for comment.
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SUMMARY: On October 12, 2018, the Department of Energy (DOE) received a
petition from the Air-Conditioning, Heating, and Refrigeration
Institute (AHRI) asking DOE to initiate notice-and-comment rulemaking
to develop a new, unified test procedure for residential furnaces which
would replace the three currently required performance metrics (i.e.,
annual fuel utilization efficiency (AFUE), fan efficiency ratio (FER),
and standby mode/off mode energy consumption (PW,SB and
PW,OFF)) with a single new metric (AFUE2). As the petition
acknowledges, a combined metric would necessitate a translation of the
existing energy conservation standards applicable to residential
furnaces using an appropriate crosswalk. Through this announcement, DOE
seeks comment on the petition, as well as any data or information that
could be used in DOE's determination whether to proceed with the
petition.
DATES: Written comments and information are requested on or before
January 14, 2019.
ADDRESSES: Interested persons are encouraged to submit comments,
identified by ``Test Procedure for Consumer Warm Air Furnaces
Petition,'' by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov. Follow the
instructions for submitting comments.
Email: [email protected]. Include Docket No. EERE-
2018-BT-PET-0017 in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. If possible,
please submit all items on a compact disc (CD), in which case it is not
necessary to include printed copies.
Hand Delivery/Courier: Appliance and Equipment Standards Program,
U.S. Department of Energy, Building Technologies Office, 950 L'Enfant
Plaza SW, Suite 600, Washington, DC 20024. Telephone: (202) 287-1445.
If possible, please submit all items on a CD, in which case it is not
necessary to include printed copies.
Docket: For access to the docket to read background documents, or
comments received, go to the Federal eRulemaking Portal at: http://www.regulations.gov/docket?D=EERE-2018-BT-PET-0017.
FOR FURTHER INFORMATION CONTACT: Mr. Eric Stas, U.S. Department of
Energy, Office of the General Counsel, 1000 Independence Avenue SW,
Washington, DC 20585. Telephone: (202) 586-9507. Email:
[email protected].
SUPPLEMENTARY INFORMATION: The Administrative Procedure Act (APA), 5
U.S.C. 551 et seq., provides among other things, that ``[e]ach agency
shall give an interested person the right to petition for the issuance,
amendment, or repeal of a rule.'' (5 U.S.C. 553(e)) DOE received a
petition from AHRI, as described in this notice and set forth verbatim
below,\1\ requesting that DOE
[[Page 56747]]
develop a new test procedure for residential furnaces with a combined
metric (annual fuel utilization efficiency 2 (AFUE2)), which would
encompass the three existing metrics currently required (i.e., AFUE,
FER, and PW,SB/PW,OFF). In promulgating this
petition for public comment, DOE is seeking views on whether it should
grant the petition and undertake a rulemaking to consider the proposal
contained in the petition. By seeking comment on whether to grant this
petition, DOE takes no position at this time regarding the merits of
the suggested rulemaking or the assertions in AHRI's petition.
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\1\ Attachments and data submitted by AHRI with its petition for
rulemaking are available in the docket at http://www.regulations.gov/docket?D=EERE-2018-BT-PET-0017.
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In its petition, AHRI requests that DOE undertake notice-and-
comment rulemaking to develop a new test procedure for residential warm
air furnaces that would consolidate all aspects of the regulation of
such furnaces using a single metric (AFUE2) and yield a unified
timeline for rulemaking and compliance. Currently, residential furnaces
are subject to separate requirements for heating (AFUE), air
circulation (FER), and standby mode and off mode energy consumptions
(power in watts for standby mode and off mode (PW,SB and
PW,OFF)). The petitioner asserts that its recommended single
metric would reduce regulatory burden on manufacturers by streamlining
test requirements and aligning regulatory review schedules, thereby
promoting design flexibility and product innovation. The petitioner
further asserts that consumers would also benefit by having a single,
combined metric for product comparison purposes and by receiving some
portion of anticipated cost savings, all of which could be achieved
without sacrificing energy savings. As the petition acknowledges, a
combined metric would necessitate a translation of the existing energy
conservation standards applicable to residential furnaces using an
appropriate crosswalk.
DOE welcomes comments and views of interested parties on any aspect
of the petition for rulemaking.
In conjunction with its petition, AHRI requested that DOE not
enforce the reporting, certification and compliance obligations related
to the furnace fan energy conservation standards (for which compliance
is required on July 3, 2019) pending consideration of this petition for
rulemaking.\2\ In response to AHRI's request, DOE is issuing an
enforcement policy regarding enforcement of the furnace fan standards.
Further details will be provided on the DOE website.\3\
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\2\ AHRI's request is available in the docket at http://www.regulations.gov/docket?D=EERE-2018-BT-PET-0017.
\3\ See http://www.energy.gov/gc/enforcement/.
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Submission of Comments
DOE invites all interested parties to submit in writing by January
14, 2019 comments and information regarding this petition.
Submitting comments via http://www.regulations.gov. The http://www.regulations.gov webpage will require you to provide your name and
contact information prior to submitting comments. Your contact
information will be viewable to DOE Building Technologies staff only.
Your contact information will not be publicly viewable except for your
first and last names, organization name (if any), and submitter
representative name (if any). If your comment is not processed properly
because of technical difficulties, DOE will use this information to
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However, your contact information will be publicly viewable if you
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Any information that you do not want to be publicly viewable should not
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Do not submit to http://www.regulations.gov information for which
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DOE processes submissions made through http://www.regulations.gov
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Include contact information in your cover letter each time you
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confidential'' with the information believed to be confidential
deleted. Submit these documents via email or on a CD, if feasible. DOE
will make its own determination about the confidential status of the
information and treat it according to its determination.
[[Page 56748]]
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
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disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
DOE considers public participation to be a very important part of
its process for considering rulemaking petitions. DOE actively
encourages the participation and interaction of the public during the
comment period. Interactions with and between members of the public
provide a balanced discussion of the issues and assist DOE in
determining how to proceed with a petition. Anyone who wishes to be
added to DOE mailing list to receive future notices and information
about this petition should contact Appliance and Equipment Standards
Program staff at (202) 287-1445 or via email at
[email protected].
Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this notice of
petition for rulemaking.
Signed in Washington, DC, on November 2, 2018.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
Before the
UNITED STATES DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
Energy Conservation Program:
Test Procedures for Consumer Warm Air Furnaces
PETITION FOR A RULEMAKING
The Air-Conditioning, Heating, and Refrigeration Institute
(AHRI) submits this Petition for a Rulemaking to formally request
that the Department of Energy (DOE or the Department) promulgate a
new test procedure for residential furnaces pursuant to its
authority under the Energy Policy and Conservation Act (EPCA), 42
U.S.C. Sec. 6293. Currently, three separate Federal test procedures
measure three different performance characteristics of consumer
warm-air furnaces: fuel efficiency (AFUE), air-movement efficiency
(FER), and stand-by/off-mode energy consumption. AHRI petitions DOE
to establish a new test procedure that will designate a single
efficiency metric for the entire product and replace the existing
test procedures for all three performance characteristics. A whole-
product test procedure and single performance metric will reduce
regulatory burden and increase opportunity for innovation.
AHRI Petitions DOE to Conduct a Notice-and-Comment Rulemaking to Adopt
the AFUE2 Test Procedure and Metric for Residential Furnaces
AHRI is the trade association representing air conditioning,
heating, commercial refrigeration, and ventilation equipment
manufacturers. AHRI advocates for the HVACR industry, administers a
third-party certification program that verifies the performance of
HVACR equipment, and publishes global industry standards. Many of
AHRI's 315 members design, develop, and manufacture residential
furnaces. Any AHRI member that manufactures a furnace for sale in
the United States or Canada is eligible to participate in AHRI's
Furnace Product Section. The Furnace Engineering Committee is a
subcommittee of the Furnace Product Section and is comprised of
furnace product engineers with decades of experience. Over a year
ago, the Furnace Engineering Committee identified challenges with
the existing residential furnace Federal test procedures and has
dedicated its time and resources to developing a more functional and
facile test procedure. The goal of the new test procedure is to
combine the three existing furnace test procedures into a single
test using a single metric: AFUE2.\4\
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\4\ During previous discussions with DOE about unrelated
performance metric changes, DOE staff indicated that the name of a
metric is mandated by statute, and therefore any metric change must
retain the codified nomenclature. If upon further review, DOE
determines that the nomenclature, like the test procedure, is
mutable, then AHRI encourages DOE to adopt a fitting identifier for
the metric. AHRI is not bound to ``AFUE2.''
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I. Description of the Test Method and Metric
The AFUE2 test procedure is based upon the methods established
by the ASHRAE 103-2017 AFUE test procedure; \5\ the Federal FER test
procedure (10 CFR Sec. 430 Appx AA); and the Federal stand-by loss/
off-mode test procedure (10 CFR Sec. 430 Appx N). The AFUE2 metric
accounts for furnace fuel, fan power, and stand-by and off-mode
power consumption. The measured value represents the sum of usable
heat and fan benefit, divided by the total fuel and electricity
consumed. A draft of the test procedure is attached.\6\ For the
benefit of the Department and the public, a description of the
notable features of the test procedure and metric are provided
below.
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\5\ AFUE2 fuel efficiency measures are based primarily on ASHRAE
103-2017. DOE has codified ASHRAE 103-1993 in 10 CFR Sec. 430 Appx
N. The relevant portions of the ASHRAE 103-2017 that are referenced
in the AFUE2 test procedure are similar to the equivalent provisions
in ASHRAE 103-1993/10 CFR 430 Appendix N. Other provisions, related
to cyclic testing, are only applicable to products with draft hoods
and draft diverter technologies.
\6\ Exhibit 1 AFUE2 Draft Test Procedure.
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The first step in the process is to measure the fuel
consumption. The furnace is set up and measurements are taken in
accordance with the most current industry test standard, ASHRAE 103-
2017.\7\ The AFUE2 test procedure differs most significantly from
the ASHRAE 103-2017 test procedure by including only steady-state
testing and excluding cyclic testing for fuel and oil furnace models
currently available in the U.S. market.\8\ Cyclic testing is time
consuming and requires the execution of complex calculations, and
the value of the cyclic testing is limited at best. AHRI's data
indicates that for the vast majority of modern products, the steady-
state efficiency accurately represents the AFUE efficiency, and
cyclic testing and calculations are unnecessary. Based on an
analysis of over 100 models, only a handful demonstrated greater
than a 1% difference between measured AFUE and steady-state
efficiencies (less jacket loss).\9\ The average difference between
actual AFUE and steady-state efficiencies is close to zero. The
elimination of cyclic testing for currently compliant products is
warranted and reduces testing burden without sacrificing accuracy.
Notably, to close any loopholes that might permit technology
backsliding, the test procedure specifies that products that
incorporate draft hoods and draft diverter technologies must
complete the cyclic testing procedures published in ASHRAE 103-2017.
AHRI is not aware of any furnaces on the market today that
incorporate these technologies.
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\7\ Per Note 2, DOE regulations currently refer to the ASHRAE
103-1993, but the test set-up is the same with some clarifications.
\8\ These are models with power burners as defined by the DOE
test procedures.
\9\ Exhibit 2: Calculations reflecting steady-state efficiency
and measured AFUE efficiency.
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After the fuel consumption is measured, the next step in the
procedure is to turn off the equipment and measure the electrical
consumption of the furnace when not in heating mode. The procedure
for measuring and calculating stand-by and off-mode energy use is
identical to the Federal method.
Finally, the ventilation energy consumption is measured. The
AFUE2 test method for measuring and calculating ventilation energy
consumption is based on the FER test procedure, with some
significant changes. First, the AFUE2 test procedure describes set-
up and settings for the ventilation test in greater detail than the
FER test procedure. For example, the AFUE2 test procedure
specifically identifies the location of the external static pressure
taps. These set-up descriptions are intended to reduce test-to-test
variability.
The AFUE2 test procedure also clarifies the hierarchy of speed
taps settings for the
[[Page 56749]]
various modes of ventilation testing. The FER procedure directs
manufacturers to test using the ``maximum airflow settings,'' but
this description is ambiguous and can lead to absurd results
depending on its interpretation. The AFUE2 test procedure specifies
that the airflow be set according to the installation and operations
manual, and the test procedure prescribes which airflow setting
should be selected if there is overlap between operating modes. If
the manual identifies the maximum airflow during the heating mode,
and the second highest airflow during cooling mode, then the speed
taps should be set accordingly: first heating, then cooling. If the
heating and cooling mode airflows are the same, then the cooling
mode speed tap is set first, which reflects how the furnace would
operate in the field.
Finally, manufacturers have been challenged with the
repeatability of the FER test. Testing has demonstrated more than a
5% difference among tests on the same unit. The poor repeatability
of the FER measurements is resolved in AFUE2 due to the relatively
small proportion of the electrical consumption. The AFUE fuel
efficiency test is well established and repeatable, so overall AFUE2
will be much more repeatable than FER.
II. The AFUE2 Metric Prevents Double Regulation
AFUE2 efficiency is the sum of the fan benefit and usable heat,
divided by electric and fuel consumption, all weighted by operating
hours. The calculations for AFUE2 and FER are based on different
operating hours. The hours differ in two meaningful ways: (1) The
cooling hours are derived directly from AHRI Standard 210/240, which
is incorporated by reference into the Federal standard for central
air conditioners; and (2) package equipment is ascribed zero fan
operating hours in the cooling mode. The AFUE2 test procedure relies
on cooling mode operating hours from AHRI Standard 210/240 based on
the simple logic that air conditioners conduct the cooling during
furnace-ventilation cooling mode and air conditioner operating hours
are already defined in AHRI 210/240. Harmonizing the two standards
is preferable and logical, and assigning different operating hours
in two different regulations for what is essentially the same
product is arbitrary. Packaged equipment is assigned zero operating
hours because the ventilation electricity consumption is already
directly regulated by DOE's air conditioning standard. DOE is
strictly prohibited from regulating the same product twice. Two
separate regulations (SEER and FER) imposed on the same component of
a single type of equipment is contrary to DOE's statutory authority.
Eliminating operating hours for packaged equipment permits the
furnace to be measured by AFUE2 without double-regulating the
ventilation energy use.
Aside from the above distinctions, most of the methods and
measurements from the currently applicable test procedures and
metrics are reflected in the AFUE2 test procedure and metric. The
ultimate goal of combining the AFUE, FER, and stand-by/off-mode test
procedures is to streamline the testing requirements, align
regulatory review schedules, and reduce regulatory burden.
III. Establishing the AFUE2 as the Federal Test Procedure and Metric Is
in the Public Interest
A. A Combined Test Procedure and Metric Reduces Burden
The AFUE2 test procedure and metric will decrease the regulatory
burden. At least six different regulations apply to consumer furnace
efficiency: (1) AFUE test procedure (2) AFUE energy conservation
standard (3) FER test procedure (4) FER energy conservation standard
(5) stand-by loss/off-mode test procedure (6) stand-by loss/off-mode
energy conservation standard. Each of these regulations is subject
to mandatory review--every six years for energy conservation
standards and every seven years for test procedures. Each of the six
applicable regulations follows a different schedule, which places
the equipment manufacturers, distributors, contractors and DOE in a
constant state of change and adjustment. The AFUE test procedure was
most recently finalized in 2016. DOE is required to review it again
by 2023. The FER test procedure was finalized in 2014; it will be
reviewed by 2021. The stand-by loss test procedure was finalized in
2013; it will be reviewed by 2020. Stand-by and off-mode test
procedures were amended in 2012 and are due for review in 2019.
Energy conservation standards for stand-by and FER were published in
2013 and 2014, respectively, while the AFUE standard has been under
review since 2011. Industry expects that energy conservation
standards will be reviewed again in 2019 and 2020. The Department is
perennially reviewing and amending furnace regulations, while
manufacturers pour time and resources into public comments, testing,
redesign, and ever-shifting compliance requirements. The total
reduction in regulatory burden resulting from implementation of
AFUE2 will save manufacturers more than $250 million over thirty
years.\10\
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\10\ Exhibit 3, ``Estimated Benefits of AFUE2''
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If DOE adopts the AFUE2 test procedure that assesses all three
performance characteristics simultaneously, then the Department
would only have to conduct a test procedure rulemaking process once
every seven years. Similarly, combining the performance measurements
into a single metric will obviate the need for three separate energy
conservation standards, and DOE will only have to review energy
conservation standards once every six years.
Resource savings to the Department are relevant, but pale in
comparison to the significant savings afforded manufacturers, and
consequently consumers, if DOE were to combine the test metric and
eliminate four of six rulemaking review cycles. Multiple discordant
regulatory requirements generate unnecessary costs. For example,
manufacturers must run an FER test, and a separate AFUE test, and
stand-by loss testing. The incremental costs of the equipment, the
set-up, mounting on the test stand, the laboratory time, and
technician costs can be drastically reduced by conducting one test
instead of three. The alignment of review cycles and redesign cycles
further reduces repetitive testing required for design development
and safety certifications. The AFUE2 test procedure mimics many of
the existing test methods, but the merging of the instances of
active testing cuts superfluous costs.\11\
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\11\ Id.
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Every time DOE makes an amendment to any of the applicable
regulations, manufacturers must redesign equipment, make capital
investments to update manufacturing facilities, republish all
marketing literature, and educate distributors, contractors, and
consumers about the change. Merging six rulemaking cycles into two
dramatically reduces the compliance burden associated with
regulatory changes because changes will occur two-thirds less
frequently. Manufacturers can pass on significant savings to
consumers by making all required changes to their furnaces within a
single design-cycle rather than spending resources on unnecessary
tooling, design, testing, production introduction, training and
other related costs.\12\ Less frequent regulatory changes offer
greater certainty to manufacturers, which promotes investment in
innovation and product improvements.
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\12\ Id.
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Crucially, reduced costs for manufacturers and consumers does
not translate to lost energy savings. Fewer regulatory review cycles
does not mean regulatory roll-back or less oversight. AHRI is
confident that DOE will take no less interest in the
representativeness and effectiveness of the applicable test
procedure as a result of this change. And each energy conservation
standard review remains targeted at achieving the ``maximum energy
savings'' that are economically justified. Ultimately, DOE will be
able to look at the furnace as a whole and make necessary
adjustments to testing and energy conservation during a single
rulemaking review instead of executing its mandate piecemeal.
B. The AFUE2 Test Procedure and Metric Will Increase Innovation
As discussed above, the AFUE2 test metric combines three
performance characteristics into a single measure. The current
approach fragments furnace efficiency into three separate minimum
requirements: stand-by/off mode, ventilation, and fuel efficiency.
The practice of setting minimums for discrete characteristics of a
single product is overly prescriptive; this approach drives product
development in only one direction. Component level regulation
restricts design choices between manufacturers. AFUE2 gives
manufacturers more design flexibility on how they achieve overall
energy savings. The AFUE2 test method and metric requires
manufacturers to account for all three performance characteristics,
but it promotes innovation by allowing for internal efficiency
trade-offs at the product level. Product designers must be given
license to develop better ways to save fuel and electricity while
improving the quality and performance of the equipment. A combined
metric saves energy
[[Page 56750]]
without prescribing multiple engineering requirements.
C. The Combined Metric Is Easier for Consumers To Use and
Understand
AFUE2 is easier for consumers to understand. It is difficult for
the average consumer to distinguish between the fuel efficiency of a
furnace, the electric efficiency of the furnace fans and the watts
saved or lost during stand-by or off-mode. The average consumer
considers three separate measures for a single product unnecessarily
complex and unhelpful. A single metric will serve as an easy basis
of comparison between all fuel furnace types. A simple label can
concisely represent the single efficiency metric and provide
approximate costs of operation, which is a chief concern of
consumers.
The AFUE2 test method and metric improves consumer utility of
the efficiency information. Furnace manufacturers question the
technical viability of the FER test procedure and metric. A separate
regulation for ventilation energy disproportionately emphasizes the
electrical consumption of a furnace, when the fuel consumption is
much more significant to consumers. A representative proportion of
energy use by both parts is described by AFUE2.
IV. Metric Changes Require a Crosswalk
AHRI requests that DOE adopt the AFUE2 test procedure pursuant
to a notice-and-comment rulemaking. The Department has statutory
authority to amend test procedures under 42 U.S.C. 6293(e) of EPCA.
The statute prescribes steps to establish a crosswalk from the
previous metric to the new metric. Specifically, EPCA states that
DOE ``shall determine, in the rulemaking carried out with respect to
prescribing such procedure, to what extent, if any, the proposed
test procedure would alter the measured energy efficiency . . . of a
covered product as determined under the existing test procedure.''
The transition from three independent metrics to one integrated
product metric will demonstrably ``alter the measured efficiency.''
As such, DOE ``shall amend the applicable energy conservation
standard during the rulemaking carried out with respect to such test
procedure. In determining the amended energy conservation standard,
the Secretary shall measure, pursuant to the amended test procedure,
the energy efficiency . . . of a representative sample of covered
products that minimally comply with the existing standard. The
average of such energy efficiency . . . determined under the amended
test procedure shall constitute the amended conservation standard
for the applicable covered products.''
AHRI has begun analyzing testing data to assist in the
development of the required crosswalk. A representative sample of
furnaces that are ``minimally compliant'' with energy conservation
minimums at each furnace product class will be tested, rated, and
averaged. This average will provide a degradation factor that can be
applied to all furnaces within that product class to ensure
equivalence across product lines with the current AFUE metric.
Uniquely, this particular crosswalk requires translation from three
performance characteristics to one product efficiency measure, and
each of those performance characteristic standards are currently
further divided into separate product classes. It will likely be
necessary to adjust the calculated baseline efficiencies to ensure
that the maximum permissible energy use of the furnace reflects
minimally compliant furnaces at each product class for each metric.
For example, minimally compliant non-weatherized natural gas
furnaces are currently rated with an AFUE of 80%. Based on
preliminary estimates, after the application of the degradation
factor, the baseline efficiencies for the AFUE2 rating is 77%.\13\
The FER and stand-by loss regulations also specify different product
classes for which the minimally compliant product will also have to
be measured and averaged. Using this data, the baseline minimum
efficiencies can be adjusted upward to ensure all current energy use
is appropriately captured. More testing is required to assign values
to this methodology.
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\13\ The 3% degradation factor is based on preliminary findings.
AHRI will provide more substantial testing to support a degradation
factor as more tests are conducted. The preliminary value will
likely change with more data.
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Crosswalks can create havoc in the market if not carefully
executed. AHRI urges DOE to work with stakeholders to ensure a
precise and simple transition from ``AFUE + FER + Stand-by/off-
mode'' to ``AFUE2.'' For clarity, AHRI recommends that the baseline
efficiency for translation is the AFUE minimum for each residential
furnace product class. Maintaining the established product class
structure for residential furnaces will have the least disruptive
impact on the market. As described above, these baseline
efficiencies can be adjusted to ensure that maximum energy use and
minimum efficiencies remain steady, but the decades-old definitions
and classifications remain constant for ease of market adoption.
V. AHRI Requests a Prompt Response
Finally, AHRI requests that DOE act promptly to initiate a
notice-and-comment rulemaking to adopt the proffered test procedure
and metric as soon as possible. The FER minimum efficiency standards
go into effect in July of 2019, and DOE will have to expedite the
release of a notice of proposed rulemaking to ensure that
manufacturers do not have to comply with one metric and test
procedure while preparing to comply with another. AHRI appreciates
the consideration that DOE will give this petition and thanks the
Department in advance for its attention to this petition.
Signed,
Caroline Davidson-Hood,
General Counsel.
Air-Conditioning, Heating, and Refrigeration Institute
2311 Wilson Boulevard, Suite 400
Arlington, Virginia 22201
[email protected]
(703) 600-0383
[FR Doc. 2018-24697 Filed 11-13-18; 8:45 am]
BILLING CODE 6450-01-P