9 Sept 2016
Update on Recent Department of Energy Rulemaking Activities
The U.S. Department of Energy recently announced the following regulatory actions of potential interest to Hong Kong and mainland Chinese exporters of compact fluorescent lamps, cooking products, central air conditioners and heat pumps, and water heaters.
The DOE has amended the energy test procedures for medium base compact fluorescent lamps and adopted test procedures for new metrics (including colour rendering index, correlated colour temperature, power factor and start time) for all CFLs, including hybrid CFLs and CFLs with bases other than medium screw. The agency has also replaced references to ENERGY STAR testing requirements with references to the latest versions of the relevant industry standard test methods referenced by the ENERGY STAR testing requirements, with certain modifications. In addition, the DOE has adopted new test procedures to support the on-going energy conservation standards rulemaking for general service lamps, the recently revised final test procedure and energy conservation standards for ceiling fan light kits, and the labelling requirements specified by the Federal Trade Commission. The test procedures will also support the ENERGY STAR programme requirements for lamps and luminaires. While the effective date of this rule is 28 September, parties have until 27 February 2017 to make any representations based on testing in accordance with the new requirements.
The DOE is seeking input by 21 September on a proposal to amend its energy test procedure for all conventional electric cooking tops to incorporate by reference the relevant selections from European standard EN 60350–2:2013 - “Household electric cooking appliances Part 2: Hobs-Methods for measuring performance.” The agency has also revised its proposals for testing non-circular electric surface units, electric surface units with flexible concentric cooking zones and full-surface induction cooking tops based on EN 60350–2:2013. Moreover, the DOE is proposing to extend the test methods in EN 60350–2:2013 to measure the energy consumption of gas cooking tops by correlating test equipment diameter to burner input rate, including input rates that exceed 14,000 British thermal units per hour. The proposal would modify the calculations of conventional cooking top annual energy consumption and integrated annual energy consumption to account for the proposed water heating test method.
In addition, the DOE would incorporate by reference test structures from American National Standards Institute Z21.1–2016 - “Household cooking gas appliances” to standardise the installation conditions under which cooking tops are tested. The agency is also proposing minor technical clarifications to the gas heating value correction and other grammatical changes to the regulatory text in appendix I that do not alter the substance of the existing test methods.
With regard to conventional ovens, the proposal would repeal the regulatory provisions establishing the test procedure for these products under the Energy Policy and Conservation Act. The DOE has determined that the conventional oven test procedure may not accurately represent consumer use as it favours conventional ovens with low thermal mass and does not capture cooking performance-related benefits due to increased thermal mass of the oven cavity.
Central AC and Heat Pumps
The DOE is proposing to revise its energy test procedures for central air conditioners and heat pumps established under the EPCA. The agency published several proposals in a November 2015 supplemental notice of proposed rulemaking and finalised some of the proposed test procedure amendments in a June 2016 final rule. The DOE is now considering additional revisions to some of the amendments proposed in the past notices as well as certain additional amendments. Comments on these changes may be submitted by 23 September.
Specifically, the DOE is proposing two sets of amendments to the test procedure: (1) amendments to appendix M that would be required as the basis for making efficiency representations starting 180 days after publication of a final rule; and (2) amendments as part of a new appendix M1 that would be the basis for making efficiency representations as of the compliance date for any amended energy conservation standards. Broadly speaking, the proposed amendments address off-mode test procedures, clarifications on test set-up and fan delays, limits to gross indoor fin surface area for valid combinations, external static pressure conditions for testing, clarifications on represented values for central air conditioners and heat pumps that are distributed in commerce with multiple refrigerants, and the methodology for testing and calculating heating performance. The agency does not expect the proposed changes to appendix M to change measured efficiency but has determined that the proposed procedures in new appendix M1 would change measured efficiency.
The DOE is seeking comments, data and information by 29 September on a proposal to establish a mathematical conversion factor to translate the current energy conservation standards and the measured values determined under the energy factor, thermal efficiency and standby loss test procedures for consumer water heaters and certain commercial water heaters to those determined under the more recently adopted uniform energy factor test procedure. As required by the EPCA, the DOE initially presented proposals for establishing a mathematical conversion factor in a notice of proposed rulemaking dated 14 April 2015. Upon further analysis and review of the public comments received, the agency has issued a supplemental notice of proposed rulemaking that updates the proposed mathematical conversion factors based on new test data, proposes updates to the methodology for developing the conversions for certain covered water heaters based on feedback received from interested parties, and proposes a new approach for denominating the existing energy conservation standards in terms of the new uniform energy factor metric.