The Air-Conditioning, Heating, and Refrigeration Institute (ACHRI) trade group is not happy with the approach the U.S. Department of Energy (DOE) is taking to initiatives aimed at updating efficiency standards and testing procedures for commercial boilers.
Upgrading testing and energy efficiency standards are deeply related but separate undertakings. The issue is that the DOE is doing both at once. In March, the DOE released a notice of proposed rulemaking (NPRM) on new commercial boilers. A month earlier, it issued an NPRM on test procedures for the same equipment.
Having both procedures ongoing at the same time, according to the ACHRI, makes little sense technically and contradicts statutes mandating that testing procedures be set before energy efficiency is addressed. ACHRI sent a letter to the DOE earlier this week asking for suspension of the efficiency standards rulemaking.
ACHRI Chief Technical Advisor Frank Stanonik described a chicken and egg situation. “In the case of a DOE rulemaking, manufacturers cannot determine what they would need to do to comply with the new standard if they don’t know what test will be required to determine the new rating(s). This is serious – when a new standard goes into effect, manufacturers cannot make products that do not meet the standard. But if they do not know how compliance will be measured, they cannot determine what the effect of the standard will be.”
The timelines for the new standards and for the changes in testing regimen are tight and overlapping. A public hearing on the standards rulemaking is slated for April 21. The comment period ends on May 23. A public meeting on the testing rulemaking was held on Monday. The comment period ends on May 31.
It seems like a case of too much to do in too short a period. The law mandates that testing procedures must be review every seven years, Joanna Mauer, the Technical Advocacy Manager of the Appliance Standards Awareness Project, told Energy Manager Today. The last review was done in 2009. The DOE also is overdue in proposing new efficiency standards, she said.
Priorities – and the calendar – appear to be clashing. “Ideally, test procedures would be finalized early in the process, but unfortunately that is not always possible, in part because test procedure issues are often raised during the standards rulemakings,” she wrote. ”However, it certainly seems reasonable for manufacturers to have adequate time to evaluate the new test procedures in order to determine the impact of potential standard levels, and it is not uncommon for DOE to grant extensions of the comment periods in order to allow more time for stakeholders to review documents.”
Between the two rulemakings, the world of boilers clearly be significant.
The NPRM on test procedures proposes, among other things, an optional field test for commercial packaged boilers with fuel intakes of more than 5 million Btu/h; a conversion method to calculate thermal efficiency based on combustion efficiency for steam packaged boilers with fuel intakes of more than 5 million Btu/h; modification to inlet and outlet water temperatures during testing of hot water boilers; establishment of limits on ambient humidity during testing; changes to setup and instrumentation during testing and standardization of terminology and provisions for “fuel intake rate.”
The NPRM on efficiency standards is part of a legal requirement for that the DOE revisit efficiency standards every six years. The NPRM proposes increasing the efficiency requirement for new boilers from 80 percent to 85 percent. The DOE had been considering raising the efficiency to 90 percent, Mauer told Energy Manager Today last month. It is possible that the more modest figure was proposed because 90 percent efficiency would likely have entailed the use of a condensing boiler, which would have raised manufacturers’ costs significantly.