Energy Conservation Program for Consumer Products: Test Procedures for Furnaces/Boilers, Vented Home Heating Equipment, and Pool Heaters

SUMMARY: On Monday, August 23, 1993, the Department of Energy (DOE or

Department) published a proposed rule amending furnace and boiler,

vented home heating equipment, and pool heater test procedures (58 FR

44538). Among the various proposed technical changes and revisions,

that notice proposed a revision to the existing Energy Factor and

proposed a new energy efficiency descriptor, Annual Efficiency. A

multiplication factor (F-factor), which represented the ratio of the

energy consumed at the power plant to generate the auxiliary electric

energy delivered to the fossil-fueled appliance to the useful heat

equivalent of that electrical energy delivered at the appliance, was

applied to the auxiliary energy in the calculation of the proposed

Energy Factor and Annual Efficiency. Today's notice announces a

reopening of the comment period to seek comment on an alternative

definition of the F-factor based on the ratio of the national average

cost of the auxiliary electrical energy to the national average cost of

the fossil fuel energy on a common unit energy basis. DOE is soliciting

comments, data, and information respecting this alternative energy cost

factor.

DATES: Written comments in response to this document must be received

by February 21, 1995.

ADDRESSES: Written comments and statements shall be submitted to: U.S.

Department of Energy, Office of Energy Efficiency and Renewable Energy,

``Test Procedures for Furnaces/Boilers, Vented Home Heating Equipment,

and Pool Heaters,'' (Docket No. EE-RM-93-501), Mail Stop EE-43, Room

5E-066, Forrestal Building, 1000 Independence Avenue, SW., Washington,

DC 20585, (202) 586-7574.

Copies of the transcript of the public hearing and the comments

received may be read and/or photocopied at the DOE Freedom of

Information Reading Room, U.S. Department of Energy, Forrestal

Building, Room 1E-190, 1000 Independence Avenue, SW., Washington, DC

20585, (202) 586-6020, between the hours of 9 a.m. and 4 p.m., Monday

through Friday, except Federal holidays.

The Department proposed to incorporate by reference in the Final

Rule the following standards:

1. American National Standards Institute/American Society of

Heating, Refrigerating, and Air-Conditioning Engineers Standard 103-

1993.

2. American National Standards Institute Standard Z21.56-1990.

Copies of these standards may be viewed at the Department of Energy

Freedom of Information Reading Room at the address stated above. Copy

of the American National Standards Institute/American Society of

Heating, Refrigerating, and Air-Conditioning Engineers Standards 103,

may be obtained from the American Society of Heating, Refrigerating,

and Air-Conditioning Engineers, 1791 Tullie Circle, Atlanta, Georgia

30329. A copy of the American National Standard Institute Standard

Z21.56 may be obtained from American National Standards Institute, 11

West 42nd Street, New York, New York 10036.

FOR FURTHER INFORMATION CONTACT:

Cyrus H. Nasseri, U.S. Department of Energy, Office of Energy

Efficiency and Renewable Energy, Mail Station, EE-431, 1000

Independence Avenue, SW., Washington, DC 20585, (202) 586-9138, FAX

(202) 586-4617.

Eugene Margolis, Esq., U.S. Department of Energy, Office of General

Counsel, Mail Station, GC-72, 1000 Independence Avenue, SW.,

Washington, DC 20585, (202) 586-9507.

SUPPLEMENTARY INFORMATION:

I. Introduction

II. Discussion of Comments

III. Discussion of Issues for Further Comment

I. Introduction

On August 23, 1993, DOE published in the Federal Register a Notice

of Proposed Rulemaking and public hearing for furnaces/boilers, vented

home heating equipment, and pool heaters (hereafter referred to as the

1993 Proposed Rule) to amend the furnace, vented home heating equipment

and pool heater test procedures (58 FR 44538). A public hearing was

held in Washington, DC on January 5, 1994. Among the various proposed

technical changes and revisions, a revision to the existing Energy

Factor and a new energy efficiency descriptor, named Annual Efficiency,

were proposed. An intent of these proposed descriptors was to account

for the electrical consumption of a furnace in its efficiency rating.

To accomplish this, a multiplication factor (F-factor), which

represented the ratio of the energy consumed at the power plant to

generate the auxiliary electric energy consumed by the fossil fueled

appliance to that auxiliary electrical energy, was applied to the

auxiliary energy in the calculation of the proposed Energy Factor and

Annual Efficiency.

The current DOE test procedure includes for information the

computation of the annual fossil fuel and auxiliary electrical energy

consumptions of fossil-fueled furnaces and boilers and an Energy Factor

which includes both the fossil fuel and the auxiliary electrical energy

consumption of the appliances. The Energy Factor is defined as the

ratio of the annual output of energy delivered to the heated space by

fossil-fueled appliances to the total annual energy input to the

appliances including auxiliary electrical energy.

DOE proposed in the 1993 Proposed Rule the definition of Energy

Factor as defined in ANSI/ASHRAE Standard 103-1988, with the provision

that non-weatherized warm air furnaces are located indoors and all

combustion and ventilation air is admitted through grills and ducts

from the outdoors and does not communicate with air in the conditioned

space [Isolated Combustion Systems (ICS)]. In addition, for those

appliances such as mobile home furnaces and vented home heating

equipment that are primarily installed indoors, DOE proposed a new

descriptor, Annual Efficiency. The new annual efficiency descriptor was

identical in form to the Energy Factor but for non-weatherized

furnaces. For boilers and for weatherized warm air furnaces, Annual

Efficiency and Energy Factor would be identical.

For fossil-fueled furnaces and boilers, the proposal defined

``Energy Factor'' as a term that gives credit for the electrical energy

recovered as usable heat, such as from a blower motor that is in the

circulating air stream. In addition, an F-factor, representing the

ratio of the energy consumed at the power plant to generate the

auxiliary electric energy delivered to the fossil-fueled appliance to

that auxiliary electrical energy, was applied to the auxiliary energy

in the calculation of the proposed Energy Factor and Annual Efficiency.

A typical value of 3.0 for the F-factor is presented as one used in

California.

II. Discussion of Comments

This notice addresses comments received on the proposed Energy

Factor and Annual Efficiency descriptors and, [[Page 4349]] in

particular, the multiplication factor F, which was applied to the

auxiliary electrical consumption. This factor was defined in the 1993

Proposed Rule as the ratio of the energy consumed at the power plant to

generate the auxiliary electric energy delivered to the fossil-fuelled

appliance to the useful heat equivalent of that electrical energy

delivered at the appliance.

Many comments were received on the proposed formulation of energy

descriptors to capture electrical consumption of furnaces/boilers,

vented home heating equipment, and pool heaters. In general, the

comments received were supportive of the goals of the proposed

amendments.

Twenty-one commenters offered comments on the energy efficiency

descriptor issues emphasizing the F-factor. Midwest Gas of the Midwest

Power Systems Inc. of Iowa supported fully the energy factor descriptor

and the annual efficiency descriptor (Midwest Gas, No. 1, at 2).

Columbia Gas Distribution Companies of Columbus, Ohio, Oklahoma Natural

Gas Co., Texas Gas Transmission Corp., City Gas Company of Florida,

Southern California Gas Co., Southern Union Gas of Texas, Lone Star Gas

Co., and Texas and Brooklyn Union Gas of N.Y., all expressed support

for the concept of the energy factor and the annual efficiency

descriptors; however, they suggested that the source- based F-factor

should be applied to all covered appliances, regardless of their

primary energy source. They considered it unfair to apply the F-factor

to fossil-fueled furnaces and boilers but not to all-electric

appliances (Columbia Gas, No. 3, at 1; Oklahoma Natural Gas, No. 4, at

1; Texas Gas, No. 5, at 3; City Gas, No. 6, at 1; Southern California

Gas, No. 24, at 1; Southern Union Gas, No. 26, at 1; Lone Star, No. 11,

at 2; and Brooklyn Union, No. 19, at 1).

American Gas Association (AGA) and Hydronics Institute (HI) stated

that they have long supported a full-cycle approach to energy decisions

but are disappointed in that the proposed energy descriptors apply the

F-factor only to the auxiliary electric energy in fossil-fueled

furnaces and boilers and not to all-electric equipment. AGA considered

the proposed approach illogical and biased and stated that it could

result in a consumer purchasing electric furnaces because of their

lower purchase price without fully considering operating cost. AGA

recommended the inclusion of source energy for electric furnaces (AGA,

Testimony, at 54, and No. 13, at 2; and HI, Testimony, at 75, and No.

16, at 2). Minnegasco, and Public Service Electric and Gas Co. (PSE&G)

expressed the same concerns as the American Gas Association on the F-

factor (Minnegasco, No. 18, at 3; and PSE&G, Testimony, at 102, and No.

9, at 3). The PSE&G further stated that if DOE adopts a source-to-site

based F-factor, the factor should be regionally and seasonally applied

because of regional and seasonal differences in electricity generation

and demand side management programs. The PSE&G further suggested that

the energy descriptor be defined to include air emissions and solid

waste produced (PSE&G, Testimony, at 102, and No. 9, at 3).

Edison Electric Institute supported adoption of the proposed energy

descriptors Energy Factor and Annual Efficiency, but without the F-

factor (equivalent to setting F=1). Edison Electric Institute believed

that site energy rather than source energy should be used in the

calculation for Energy Factor and Annual Efficiency because (1) the

appliance standard is to benefit the consumer who makes his or her

decisions on energy usage based on site energy and has no control over

the electrical power plant; (2) there is no technical justification for

using source rather than site energy; (3) an unnecessary precedent

would be created for other appliance standards that are currently

defined using site energy; (4) given that electricity can be generated

from renewable energy (wind, solar, hydro), the F-factor could distort

the actual amount of energy needed for electricity generation and could

have the tendency to favor fossil-fueled equipment over electric

equipment; and (5) given that electricity is generated using different

fuels and at different rates of conversion from heat to electricity,

including nuclear and hydroelectric, a single F-factor would be

misleading (Edison, No. 20, at 2).

Lennox Industries supported the inclusion of electrical energy in

the proposed energy descriptors but objected that limiting the

application of the F-factor on electric energy usage only to fossil-

fueled furnaces and boilers would penalize this type of product and

confuse the consumer (Lennox, Testimony, at 85).

Inter-City Products stated that (1) applying the F-factor to

auxiliary electric energy consumption in gas-fired furnaces, but not to

the electric energy consumption in electric furnaces, puts the gas-

fired equipment at an unjustified disadvantage in comparison to

electric furnaces and heat pumps, which could cause significant load

shifting from gas to electric, (2) gas and electrical consumption

cannot be separated for cost comparison in a single energy descriptor

that combines two different forms of energy but not cost in the

calculation because their operating cost will be different, and (3)

there is no basis for the proposed value of 3.37 for the F-factor.

Therefore, Inter-City stated that it would not support the proposed

energy descriptors until these issues were resolved (Inter-City, No. 7,

at 3).

GAMA objected to the proposed energy descriptors' immediate

implementation in their present form, for reasons similar to those

mentioned by Inter-City, supra. GAMA also suggested the possibility of

developing two separate energy descriptors for fossil fuel and electric

energy consumption. Carrier Corp. and Consolidated Industries both

stated their support of GAMA (GAMA, Testimony, at 18, and No. 8, at 5;

Carrier, No. 12, at 1; and Consolidated, No. 22, at 1). York

International objected to the proposed energy descriptors and would

support the descriptors only if the F-factor was not applied. York also

considered F-factor's use inconsistent by not applying it to all-

electric units (York, No. 10, at 1).

California Energy Commission supported the proposed energy

descriptors with the F-factor (California, No. 25, at 3). The National

Resources Defense Council (NRDC) strongly supported the proposed energy

descriptors and the concept of applying a multiplication factor to

auxiliary electrical energy consumed to reflect the cost of energy to

the consumers. The NRDC suggested that other than the source-based F-

factor, factors based on consumer cost or emission impacts (air

pollution impacts or climate pollution impacts) could also be used to

develop the F-factor. But NRDC suggested that a factor based on average

consumer costs (the ratio of unit energy cost to consumers of

electrical energy and fossil fuel) would be a more accurate and useful

approach, as it is more reflective of the costs the consumer is

incurring. The NRDC suggested that in order to avoid the necessity of

changing the cost ratio due to fluctuations or changes in the gas to

electric costs every year, a single value for the factor should be

chosen and maintained for the next ten years or longer unless the

factor changes drastically (NRDC, Testimony, at 68 and No. 15, at 2).

III. Discussion of Issues for Further Comment

The main reason for the Department's 1993 proposal to establish the

energy factor and the annual efficiency descriptor was to take into

account the consumption of the auxiliary electric [[Page 4350]] energy

in the operation of fossil-fueled furnaces and boilers. The AFUE

descriptor for fossil-fueled units, as defined, deals with only the

primary energy consumption (gas or oil) of an appliance, and therefore

does not give the consumer a complete account of the overall energy and

cost performance of the appliance. A survey of the yearly auxiliary

electrical energy consumption and gas consumption of gas-fired

furnaces, as published in the October 1993 GAMA Efficiency

Certification Directory, showed that the auxiliary electrical energy

consumption varies from approximately 2.0 to 6.5 percent of the gas

consumption. Even though this energy consumption ratio is small, it is

significant in cost to the consumer because electricity costs

approximately four times more than gas. On the basis of AFUE alone, a

consumer would not be able to compare the overall efficiency of two (or

more) different models of fossil-fueled furnaces or boilers of

comparable output capacity but with blower motors of different

efficiencies and, hence, different costs. The proposed Energy Factor or

Annual Efficiency will give the consumer the necessary descriptor for a

more informed purchasing decision.

A second reason for having the proposed energy descriptors is to

allow for the consideration of design options involving changes in

auxiliary electric energy consumption in the Department's analysis

supporting the energy efficiency standard rulemaking.

The definition of the F-factor in the 1993 proposed rule was

intended to: (1) provide consumers with rating information which

reflects annual operating cost, including electrical energy, so they

can make informed choices when comparing several models or makes of

fossil-fueled appliances; and (2) encourage manufacturers to make the

most overall energy efficient appliance, the efficiency of which can be

shown to the consumers with a meaningful energy descriptor. After

reviewing the objections presented by commenters with regard to the

proposed F-factor, the Department invites comment on an alternative

formulation of the F-factor based on the ratio of costs. In particular,

DOE invites comment on the NRDC suggestion that basing a multiplication

factor on energy costs of electricity and fossil fuel to consumers

rather than on source energy ratio would be a more meaningful criterion

in reflecting the overall energy efficiency of fossil-fueled

appliances. This ratio may also give consumers a clearer grasp of the

cost of operating their appliances.

The F-factor value of 3.37 in the 1993 proposed rule was based on

historical values of power-plant-to-site energy ratios. More recent

calculations, based on future projections in the ``Annual Energy

Outlook 1994'' (Energy Information Administration, DOE, DOE/EIA-

0383(94), January, 1994, Table A2), showed that a value of F=3.2 would

be appropriate for the years 2000 through 2010. Average national

electricity-to-fuel price (as opposed to energy) ratios also were

calculated for the same years, using the ``Annual Energy Outlook 1994''

(Tables A3 and A4). These price ratios were obtained by first

calculating a weighted-averaged fuel price (for natural gas, LPG, and

oil), then taking the ratio of average national electricity price to

the weighted average fuel price. The weighted average price for the

three fuels was calculated by weighting each fuel price by its yearly

national residential space heating consumption (in quads per year).

These calculations showed that the projected electricity-to-fuel price

ratio will vary from 3.46 in the year 2000 to 3.30 in the year 2010,

and that the trend for this ratio will be toward less variation over

time. Therefore, while some variation will exist in the price ratio

over time (as cautioned by the NRDC in its testimony), the Department

seeks comment on whether a nationwide price ratio of 3.36 will be valid

for the next 10 to 20 years (determined by extrapolating for the year

2002 and price ratio remaining unchanged during that period). The

actual ratio of electricity-to-fuel price will not be the same across

the U.S., but the use of a multiple-valued F-factor, as suggested by

the Edison Electric Institute, would cause complications for

manufacturers that sell the same appliance in different parts of the

country. Using a single value is similar to the adoption of a national

average outdoor temperature and a national average heating degree-days

in the calculation for the heating seasonal efficiency and AFUE in the

current test procedure.

The Department is seeking comment on the equations for the proposed

Energy Factor and the Annual Efficiency for furnaces and boilers that

use fossil fuel as the primary source of energy, and a much smaller

quantity of electrical energy for the auxiliary equipment (2.0 percent

to 6.5 percent of the yearly gas consumption for gas furnaces; less

than 1.0 percent for boilers). The F-factor should be applied to all

types of source energy and to all types of space-heating equipment. As

previously stated, the inclusion of the F-factor in the proposed

equations for these energy descriptors is to calculate the total cost

of the fossil fuel energy and the auxiliary electrical energy consumed

by the appliance. In this way, the consumers would have a more complete

energy descriptor than the AFUE to compare the total cost of operating

the appliance in their homes. This would also discourage the possible

practice of running the air circulation blower longer during burner

ignition and shut-off in order to obtain a slightly higher AFUE value,

while actually consuming more electrical energy and thus, more overall

energy. The Department believes the best information available to

consumers to make an informed decision when purchasing a fossil-fueled

appliance is an efficiency descriptor that will reflect the total cost

of operating the appliance. The proposed energy descriptors do reflect

that total cost to the consumer.

Based on the discussion above, DOE is seeking comment today on

redefining the F-factor in the August 23, 1993, proposed rule as the

ratio of national average price of electricity to the national average

price of fossil fuel, on a common unit energy basis. In particular, DOE

invites comment on use of value of 3.36 for the F-factor.

The Department solicits comment and information on the application

of the proposed consumer energy cost factor to the auxiliary electrical

energy consumption as a multiplication factor in the calculation of the

proposed Energy Factor and the Annual Efficiency for fossil fuel

heating appliances.

Issued in Washington, DC, on January 11, 1995.

Christine A. Ervin,

Assistant Secretary, Energy Efficiency and Renewable Energy.

[FR Doc. 95-1433 Filed 1-19-95; 8:45 am]

BILLING CODE 6450-01-P