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Standards Update – 2nd Quarter 2013

Created 7/23/2013 by David Cohan
Updated 7/24/2013 by Greg Stiles
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Standards Update – 2nd Quarter 2013

Federal Level

After a packed first quarter of standards activity, the pace in the second quarter slackened somewhat. Several rulemaking comment periods closed last quarter, with NEEA weighing in on virtually all of them. Only a few things were added to the existing list of ongoing rulemakings, and very few have been concluded, with a growing list of Proposed and Final Rules being sequestered at the Office of Information and Regulatory Affairs (OIRA) at OMB for undetermined amounts of time (the longest so far is about 20 months).

Some highlights of DOE actions in the second quarter, with details in the active rulemaking section following this list:

  1. Issued a Request for Information (RFI) for commercial furnace standards. This is the first phase of what will become a standards rulemaking later in the year. NEEA won’t likely weigh in on this one, as it is pretty much for natural gas-fired equipment only.
  2. Issued a Final Rule for residential furnace and boiler test procedures. This was mostly a procedure tune-up process, without substantive changes.
  3. Issued a Proposed Rule (NOPR) for residential refrigerator and refrigerator-freezer test procedures. This is the long-awaited procedure for testing icemaker energy use and incorporating the results into the annual energy use for these products, plus a few clean-up items left over from the last Final Rule in 2010. These new rules should go into effect in 2014 with new efficiency standards for these products. Expect a Final Rule before the end of the year. The current standards assume 84 kWh per year for icemaking, in addition to what’s currently on the Energy Guide label. When the new standards go into effect, the Energy Guide label will include the annual energy use for icemaking, as determined using the new procedure. The result may be quite close to the assumed 84 kWh, which was derived from manufacturer data and largely confirmed by NEEA’s field data.
  4. Published a Final Rule on April 9th for distribution transformers, at last! Improvements for medium voltage liquid-immersed products posted only a slight gain (on the order of 4%), while the gains for medium voltage dry-type products improved much more substantially (on the order of 30%).
  5. Published a Proposed Rule on large electric motor test procedures. The proposal mostly consists of changes associated with testing some motor types (such as partial motors) that are newly proposed for coverage in the standards rulemaking. It is a good proposal, in general, and should fairly easily win the approval of most stakeholders. On to the standards!
  6. Published a Supplemental Notice of Proposed Rule on April 2nd for the furnace fan test procedure. This is a good thing, because the original proposal was pretty far off the mark. This next proposal is better, but still needs more work. Regional RBSA data could be key to resolving a few of the remaining issues.
  7. Published a Notice of Determination for Residential Portable Air Conditioners. DOE has concluded that these products use a significant amount of energy, and that there may be significant energy savings potential. Expect the beginning of a rulemaking process, for both a test procedure and standards, soon.

The list of active rulemakings has grown even longer since last quarter. Here are some details about the status and importance of the individual rulemakings:

  • Automatic Commercial Icemaker Standards (still behind schedule, waiting on a Proposed Rule, which is reportedly hung up at OMB – the Office of Management & Budget)
  • Commercial A/C & HP system standards (This process began last quarter with a request for information. The recently published ASHRAE standards will be examined as a starting point for some equipment classes. More stringent standards may be cost-effective for some classes.)
  • Residential Air Conditioning and Heat Pump Systems Test Procedure (still behind schedule, still waiting on a Final Rule)
  • Battery Charger Efficiency Standards (Ongoing, and still substantially behind schedule. DOE took comments and data through an RFI that closed this last quarter, taking a new look at their analysis to see if the levels of efficiency now in effect in CA are in fact cost-effective, and to learn if any other jurisdictions have adopted the CA standards. They did; see the state standards discussion further on).
  • Ceiling Fans & Ceiling Fan Light Kits (DOE is still chewing on the information they got this last quarter in response to the publication of their rulemaking Framework document. In the meantime, a few members of Congress seem to be upset by the notion of new regulations for these products. With the political class involved, there’s no telling how this will come out in the end.)
  • Residential Clothes Dryer Test Procedures (DOE is now considering the data and information they got in response to their Proposed Rules, and we’re expecting a Final Rule late third quarter or early fourth quarter. We need this one in order to seriously consider clothes dryer initiatives and incentive programs.)
  • Large Electric Motor Efficiency Standards, 1-200 hp (Ongoing, with the joint stakeholders having formally petitioned DOE to publish their proposal as the core of a Direct Final Rule by the end of the year. No word yet on a NOPR, which is now substantially overdue. The savings from this one could be very large. The Test Procedure Proposed Rule was a good one, in general, and will help keep the standards process moving along.)
  • · Fan, Blower and Fume Hood Standards (These products have never been regulated before, so the Framework document published on February 1st is important. It will establish the product classes that will be regulated and the metrics to be used for ratings, among other things. Comments on the framework document in association with other energy advocates were submitted on May 28th. A two day meeting with AMCA (Air Movement and Control Association) ,DOE and energy advocates to discuss a negotiated rulemaking was held in Chicago in mid-June. The outcome of the meeting is still indeterminate.
  • Residential Furnace Fan Test Procedure and Efficiency Standards (Ongoing. Perhaps due to the need for a Supplemental NOPR for the test procedure, the Preliminary Analysis for the standards rulemaking has not yet been published. The Final Rule for the Test Procedure is now more likely in the third or fourth quarter.)
  • General Service Fluorescent Lamps (GSFLs) and Incandescent Reflector Lamps (IRLs) (Ongoing. At issue in this rulemaking will also be the continuation, or not, of the 2-year waivers from the July 2012 standards for many 700 series GSFL lamps.)
  • High Intensity Discharge Lamp Test Procedure and Efficiency Standards DOE held a public meeting at the end of February to discuss interim technical support document (ITSD) for high-intensity discharge lamps. NEEA attended the meeting and provided comments on the ITSD for HID lamps on May 17.
  • Efficiency Standards for Certain Incandescent Reflector Lamps (ER, BR & small diameter) (Still significantly overdue on a Proposed Rule for the Standards, which is still hung up, with so many others, at OIRA.)
  • Metal Halide Fixture Efficiency Standards (Still significantly overdue on a Proposed Rule.)
  • Packaged Terminal Air Conditioning & Heat Pump Standards (Ongoing.)
  • Commercial and Industrial Pump Standards (Following stakeholder negotiations, DOE opened a rulemaking for these products with a Framework document published on February 1st. The classes of products being regulated may be limited, but there still may be significant savings potential.) Meetings were held with Hydraulics Institute prior to submission of framework comments by NEEA on May 2.
  • · Energy Efficiency Descriptor for Small, Large and Very Large Commercial Package Air Conditioning and Heating Equipment. DOE issued a RFI on the consideration of replacing the energy descriptor of EER to IEER. NEEA provided comments
  • Commercial Refrigeration Equipment Efficiency Standards (Still significantly overdue on a Proposed Rule; was to have been completed by the end of the year, but wasn’t. This is one of the most important rulemakings tied up at OIRA, with significant regionals savings at stake.)
  • Commercial Clothes Washer Efficiency Standards (This one is still scheduled for a Preliminary Analysis publication in the third quarter.)
  • Set-top Box Test Procedures (Ongoing, with nothing new to add this quarter. In the meantime, the California Energy Commission has begun their own rulemaking on these products, and will likely complete the process before DOE. See the State standards update below.)
  • Television Test Procedures and Efficiency Standards (Still significantly overdue on a Test Procedure Final Rule and Framework document for Efficiency Standards. We still hope to see a Test Procedure Final Rule by the end of the third quarter, in time for manufacturers to test their 2014 models using the new procedure.)
  • Vending Machine Standards (Just starting a new rulemaking process. Noteworthy is the fact that the three main vending machine manufacturers, making products for the two largest soft drink bottlers (Coke & Pepsi), have significantly shifted to CO2 refrigerant (R-744) for their newest vending machines. This will be a major topic of discussion in the rulemaking, and may have implications outside the vending machine industry.
  • Walk-in Cooler & Freezer Efficiency Standards (Still significantly overdue on a Proposed Rule. This one was confirmed as being sequestered at OIRA with a number of other proposals and rules. There is significant savings potential in this one.)
  • Standby & Off-Mode Test Procedures for Residential Water Heaters ( still significantly overdue on a Final Rule. Parts of a new on-mode Test Procedure are nearly ready for a public review process at ASHRAE and AHAM, with a refinement of test procedures and instrumentation very close to final at the ASHRAE SP 118.2 Committee. They are also likely to propose new test procedure draw patterns, probably identical to or patterned on those that AHAM has already delivered to DOE as part of their test procedure proposals. The next step is for DOE to consider these proposals, and then examine the other test procedure specifications, such as setpoint, ambient temperature and inlet water temperature, and then publish a Final Rule.)
  • DOE proposed a negotiated rulemaking on Certification of Commercial Equipment including Refrigeration Equipment. Air Handler and Water Heater. NEEA submitted an application to be in the work group and was accepted as one of 22 members of the 37 that applied. During May and June NEEA has participating in the work group to determine Alternative Efficiency Determination Methods requirements for this equipment. The accuracy of the efficiency rating of non-tested equipment has a large impact on energy use.
  • Residential & Commercial Water Heater Uniform Efficiency Metrics (Ongoing, with no updates this quarter.)
  • Residential Water Heater Standards Waiver Process (In 2012, a group of utility stakeholders petitioned DOE for a waiver process to exempt certain large electric resistance storage water heaters from the new standards that are to take effect on January 1st, 2015, claiming that the waiver is needed for their demand management and energy thermal storage programs. DOE published a proposed a Proposed Rule for such a process on February 26th. Since that time, NRECA has gone to Congress to ask for a bill rider – probably on the Shaheen-Portman energy bill – to exempt large electric storage water heaters that are “grid-enabled” from the 2015 standards, substituting new standards that are a slight increase in efficiency from current tanks. NEEA is coordinating its comments with the NPCC and BPA, and working with General Electric – a heat pump water heater initiative ally – and some other efficiency stakeholders to limit the damage from what could become a rather large loophole in the standards. There are substantial regional energy savings at stake here. DOE’s waiver process continues in parallel with the political maneuvering, with analyses in progress. We’re still expecting a Supplemental NOPR within a few months and another round of comments.)

State Level

After losing our Washington State efficiency standards bill to some rather dysfunctional politics, the same standards bill in Oregon passed through the legislature and was signed into law by Governor Kitzhaber in June. Standards for small battery charger systems and televisions go into effect on January 1st, 2014. Standards for high-wattage double-ended quartz halogen lamps go into effect on January 1st, 2016, and larger commercial/industrial battery chargers systems standards go into effect on January 1st, 2017. Savings estimates for televisions will be calculated after the new test procedure is published and we get a better estimate of what these products use in the field. NEEA’s RBSA data will be used to validate these new test results for the region.

In the meantime, the California Energy Commission (CEC) has initiated another round of standard-setting. The products being considered are the following:

  1. Air Filter Labeling
  2. Commercial Clothes Dryers
  3. Computers
  4. Dimming Ballasts
  5. Electronic Displays
  6. Faucets
  7. Game Consoles
  8. Quality LED Lamps
  9. Pools (pumps and filter systems)
  10. Spas
  11. Small Diameter Directional Lamps (such as MR16s)
  12. Set Top Boxes
  13. Small Network Equipment
  14. Toilets
  15. Urinals
  16. Water Meters

An Invitation to Participate (ITP) was issued last quarter, and preliminary information on these products was submitted. Standards proposals are being prepared and are due to the CEC by July 19th. Products that make it through this phase of the process should have new standards adopted late in 2014 or early 2015. The California investor-owned utilities are submitting extensive amounts of data and standards proposals at the end of the month. NEEA is closely monitoring the progress of the CEC process, and will submit data on selected products from our RBSA field metering project. If all goes well, we’ll bring these standards to Oregon and Washington in 2015.

Summary

As you can gather from the length of these reports lately, there is an enormous amount of standards activity going on right now. If you would like more detail on any of these rulemakings, don’t hesitate to contact us (for residential and consumer products, contact Charlie Stephens at 503 688-5457 or cstephens@neea.org, and for commercial and industrial products, contact Louis Starr at 503 688-5438 or lstarr@neea.org).

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Comments (1)
Greg Stiles on 07/24/13 on 09:33 AM (Pacific Time)
Wow! Lots of things happening. Thanks for the update David!

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