Compliance Testing Procedures: Correction Factor for Room Air Conditioners, 72739-72741 [2010-29773]
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Federal Register / Vol. 75, No. 227 / Friday, November 26, 2010 / Proposed Rules
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[FR Doc. 2010–29738 Filed 11–24–10; 8:45 am]
BILLING CODE 7590–01–P
DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE–2008–BT–TP–0010]
Compliance Testing Procedures:
Correction Factor for Room Air
Conditioners
Office of the General Counsel,
Department of Energy (DOE).
ACTION: Petition for rulemaking; request
for comment.
AGENCY:
On November 15, 2010, the
Department of Energy received a
petition for rulemaking from the
Association of Home Appliance
Manufacturers (AHAM). The petition,
requests the initiation of a rulemaking
regarding compliance testing procedures
for room air conditioners. The petition
seeks temporary enforcement
forbearance, or in the alternative, a
temporary industry-wide waiver or
guidance, to allow use of a data
correction factor in compliance testing
procedures for room air conditioners.
Public comment is requested on
whether DOE should grant the petition
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SUMMARY:
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and proceed with a rulemaking
procedure on this matter.
DATES: Comments must be postmarked
no later than December 27, 2010.
ADDRESSES: Any comments submitted
must reference ‘‘Petition for Rulemaking:
Correction Factor for Room Air
Conditioners.’’ Comments may be
submitted using any of the following
methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail: AHAM2-2008-TP0010@ee.doe.gov. Include ‘‘Petition for
Rulemaking’’ in the subject line of the
message.
• Postal Mail: Subid Wagley, U.S.
Department of Energy, Office of Energy
Efficiency and Renewable Energy,
Building Technologies Program, EE–2J,
1000 Independence Avenue, SW.,
Washington, DC 20585–0121. Please
submit one signed original paper copy.
• Hand Delivery/Courier: Subid
Wagley, U.S. Department of Energy,
Office of Energy Efficiency and
Renewable Energy, Building
Technologies Program, EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121. Please
submit one signed original paper copy.
FOR FURTHER INFORMATION CONTACT:
Subid Wagley, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies Program, EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121, (202) 287–
1414, e-mail: subid.wagley@ee.doe.gov.
Betsy Kohl, U.S. Department of Energy,
Office of General Counsel, Mail Stop
GC–71, 1000 Independence Avenue,
SW., Washington, DC 20585–0121, (202)
586–7796, e-mail:
elizabeth.kohl@hq.doe.gov.
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)). Pursuant to
this provision of the APA, AHAM
petitioned the Department of Energy for
the issuance of a new rule, as set forth
below. In publishing this petition for
public comment, the Department of
Energy 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, the Department of Energy takes
no position at this time regarding the
merits of the suggested rulemaking.
The proposed rulemaking sought by
AHAM would allow manufacturers of
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72739
room air conditioners to use a correction
factor that is not currently included in
the regulations governing DOE’s
compliance testing procedures. The
petition seeks temporary enforcement
forbearance, or a temporary industrywide waiver or guidance, to allow use
of this methodology. The Department of
Energy seeks public comment on
whether DOE should grant the petition
and proceed with a rulemaking
procedure on this issue.
Issued in Washington, DC, on November
18, 2010.
Scott Blake Harris,
General Counsel.
Set forth below is the full text of the
Association of Home Appliance
Manufacturers’ petition:
Before the U.S. Department of Energy
November 15, 2010
Petition for Rulemaking
Petition of the Association of the Home
Appliance Manufacturers for
Temporary Enforcement Forbearance, a
Temporary Industry-Wide Waiver Or
Guidance To Allow Use of DOE—
Proposed Correction Factor for Room
Air Conditioner Testing
Pursuant to 5 U.S.C. 553(e), the
Association of Home Appliance
Manufacturers (AHAM) files this
petition.
AHAM represents manufacturers of
major, portable and floor care home
appliances, and suppliers to the
industry. AHAM’s more than 150
members employ tens of thousands of
people in the U.S. and produce more
than 95% of the household appliances
shipped for sale within the U.S. The
factory shipment value of these
products is more than $30 billion
annually. The home appliance industry,
through its products and innovation, is
essential to U.S. consumer lifestyle,
health, safety and convenience. Through
its technology, employees and
productivity, the industry contributes
significantly to U.S. jobs and economic
security. Home appliances also are a
success story in terms of energy
efficiency and environmental
protection. New appliances often
represent the most effective choice a
consumer can make to reduce home
energy use and costs. AHAM, relevant
to this petition, represents the
manufacturers of the vast majority of
room air conditioners.
This petition requests temporary
enforcement forbearance, or in the
alternative, a temporary industry-wide
waiver or guidance, to allow use of a
data correction factor for room air
conditioners that DOE currently
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26NOP1
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72740
Federal Register / Vol. 75, No. 227 / Friday, November 26, 2010 / Proposed Rules
acknowledges produces more accurate
results and which has been proposed
(by DOE) for adoption. This relief would
be automatically superseded by the
effective date of the new DOE test
procedure.
We do not believe that our request
requires formal notice and comment but
we are prepared to supply additional
information for any public record or
procedure. Similar to the vocation of the
microwave oven test procedure, there is
longstanding, sufficient public record
evidence justifying this requested
action. See, 75 FR 42579, 42581 (July
22, 2010).
Initially, we note that this issue stems
from an endemic problem within the
DOE test procedures which DOE and
other stakeholders are beginning to
address: The DOE test procedures are
outmoded and often rely on older
versions of industry practices or
consensus body testing standards which
have been superseded by standards
which are more accurate, uniform,
repeatable and reflective of actual use.
Indeed, DOE has endorsed and
proposed using the new ANSI/ASHRAE
test procedure discussed below.
In this case, DOE currently is
applying in its compliance testing
program an outmoded test methodology,
which is less accurate and for that
reason alone may produce test results
inappropriately indicating that a room
air conditioner has technically incorrect
ratings, does not qualify for Energy Star,
or fails to meet the minimum
performance standards. As discussed
below, the issue relates to the current
DOE recommended test procedure’s
failure to correct for deviation from
standard barometric pressure. It is
unreasonable and unfair to penalize
companies during this evolving
transitional period between an archaic
procedure and a new, modern
methodology that is more accurate. With
these facts in mind, DOE compliance
enforcement forbearance, or an
industry-wide waiver or guidance,
allowing the correction factor for room
air conditioners is entirely warranted.
The issue relates to 10 CFR Part 430,
Subpart B, Appendix F, promulgated in
1977. For purposes of the DOE
minimum efficiency program, industry
has since 1983 recognized the benefits
of adjusting capacity ratings to reflect a
correction factor in Section 6.1.3 of
ASHRAE Standard 16–1983 (RA 99).
Since 1983, AHAM’s room air
conditioner certification program has
used this correction factor. The
correction factor is based on the test
room condition deviation from the
standard barometric pressure of 29.92
inches of mercury. The correction factor
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normalizes test capacity results to
standard test room conditions and
thereby produces more accurate and
comparable test results, as
acknowledged by DOE. More
specifically, the use of the correction
factor when barometric pressure is >1
in. Hg below standard rating point
allows capacity performance
modification.
We understand that DOE or a test
laboratory under contract with DOE has
recently rejected use of the correction
factor at the present time for purposes
of certifying compliance to the DOE
efficiency standard, on the ground that
the correction factor is not contained in
the DOE test procedure as it currently is
written.
DOE has already acknowledged that
its current test procedure is inaccurate
due to lack of the correction factor and
that the correction factor ought to be
adopted. It has so indicated in its recent
Supplemental Notice of Proposed
Rulemaking (SNOPR) to amend the test
procedure. See 75 FR 37594, 37635
(June 29, 2010). DOE states:
‘‘Section 6.1.3 of ANSI/ASHRAE Standard
16–1983 (RA 99) also introduces a correction
factor based on the test room condition’s
deviation from the standard barometric
pressure of 29.92 inches (in.) in mercury (Hg)
(101 kilopascal (kPa)). Section 6.1.3 of ANSI/
ASHRAE Standard 16–1983 (RA 99) states
that the cooling capacity may be increased
0.8 percent for each in. Hg below 29.92 in.
Hg (0.24 percent for each kPa below 101 kPa).
This change would not impact the measured
efficiency of units tested at standard testing
conditions. The capacity correction factor
provides manufacturers with more flexibility
in the test room conditions while
normalizing results to standard conditions.
*
*
*
*
*
In sum, DOE has reviewed the most recent
revisions of the referenced test standards.
ANSI/AHAM RAC–1–R2008 and ANSI/
ASHRAE Standard 16–1983 (RA 99), and has
determined that incorporation by reference of
these versions provide more accurate and
repeatable measurements of capacity while
providing greater flexibility to manufacturers
in selecting equipment and facilities, and
does not add any significant testing burden.
Furthermore, these revisions would not
impact the measurement of EER for this
equipment. DOE also believes that
manufacturers may already be using these
updated standards in their testing. Therefore,
DOE is proposing in today’s SNOPR to
amend the DOE test procedure to reference
the relevant sections of ANSI/AHAM RAC–
1–R2008 and ANSI/ASHRAE Standard 16–
1983 (RA 99).’’
Under these circumstances, and for
the interim before final test procedure
rulemaking, it is unfair and
unreasonable to penalize firms by
judging their product against an
inaccurate methodology rather than
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Sfmt 4702
using the correction factor, which DOE
correctly asserts is more accurate and
which DOE endorses and plans to
adopt.
Such action by DOE is entirely
warranted. In the case of microwave
ovens, DOE unilaterally revoked an
outmoded test procedure through a
direct final rule and without prior
notice. 75 FR 42579 (July 22, 2010)
Here, test procedure revocation is not,
requested, practical nor prudent because
test standards, labels, Energy Star and
incentive programs are in place. This
petition does not request that DOE
circumvent or repeal the test procedure,
but rather that it immediately act to
improve testing before administrative
processes are completed.
If the current test procedure is applied
to comparable room air conditioners in
test rooms under different barometric
pressures, it will produce materially
inaccurate capacity results. DOE
acknowledges the inaccuracy of the
existing test procedure—by stressing
that the correction factor in ASHRAE
16–1983 (RA 99) produces more
accurate and repeatable test results by
normalizing results to standard
conditions. 75 FR at 37635. DOE states
that Section 6.1.3 of ASHRAE 16–1983
(RA 99) has ‘‘a correction factor based on
the test room condition’s deviation from
the standard barometric pressure of
29.92 inches (in.) of mercury (Hg) (101
kilopascal (kPa)) * * * The capacity
correction factor provides
manufacturers with more flexibility in
the test room conditions while
normalizing results to standard
conditions.’’ Id. (emphasis added).
DOE concluded that the correction
factor ‘‘provide[s] more accurate and
repeatable measurements of capacity
while providing greater flexibility to
manufacturers in selecting equipment
and facilities, and does not add any
significant testing burden.’’ Id.
(emphasis added). DOE goes on to state
that it ‘‘also believes that manufacturers
may already be using these updated
standards in their testing.’’ Id. (emphasis
added).
Recognizing the commercial reality
and the demands of fairness, DOE and
industry should be working on this
issue collaboratively. DOE has proposed
that its test procedure be amended to
incorporate the correction factor.
Unfortunately, unless DOE provides
relief in the interim by procedure
revision or waiver, industry will suffer
from a test procedure that DOE
acknowledges is inaccurate and that is
harmful with no benefit to the public.
Accordingly, with this petition,
AHAM requests temporary enforcement
forbearance, or in the alternative, a
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Federal Register / Vol. 75, No. 227 / Friday, November 26, 2010 / Proposed Rules
temporary industry-wide waiver or
guidance, to allow use of the data
correction factor for room air
conditioners. This relief would be
automatically superseded by the
effective date of the new DOE test
procedure.
AHAM looks forward to meeting with
DOE at the earliest opportunity to
discuss this important matter.
[FR Doc. 2010–29773 Filed 11–24–10; 8:45 am]
BILLING CODE 6450–01–P
FEDERAL RESERVE SYSTEM
12 CFR Part 225
[Regulation Y; Docket No. R–1397]
RIN AD 7100–58
Conformance Period for Entities
Engaged in Prohibited Proprietary
Trading or Private Equity Fund or
Hedge Fund Activities
Board of Governors of the
Federal Reserve System (‘‘Board’’).
ACTION: Proposed rule; request for
public comment.
AGENCY:
• Mail: Jennifer J. Johnson, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue, NW., Washington,
DC 20551.
All public comments are available
from the Board’s Web site at https://
www.federalreserve.gov/generalinfo/
foia/ProposedRegs.cfm as submitted,
unless modified for technical reasons.
Accordingly, your comments will not be
edited to remove any identifying or
contact information. Public comments
may also be viewed electronically or in
paper form in Room MP–500 of the
Board’s Martin Building (20th and C
Streets, NW) between 9 a.m. and 5 p.m.
on weekdays.
FOR FURTHER INFORMATION CONTACT:
Brian P. Knestout, Senior Attorney,
(202) 452–2249, Jeremy R. Newell,
Senior Attorney, (202) 452–3239,
Christopher M. Paridon, Senior
Attorney, (202) 452–3274, or Kieran J.
Fallon, Associate General Counsel, (202)
452–5270, Legal Division; David K.
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and Regulation, Board of Governors of
the Federal Reserve System, 20th Street
and Constitution Avenue, NW.,
Washington, DC 20551. Users of
Telecommunication Device for Deaf
(TDD) only, call (202) 263–4869.
SUPPLEMENTARY INFORMATION:
The Board is requesting
comment on a proposed rule that would
implement the conformance period
during which banking entities and
nonbank financial companies
supervised by the Board must bring
their activities and investments into
compliance with the prohibitions and
restrictions on proprietary trading and
relationships with hedge funds and
private equity funds imposed by section
619 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act
(‘‘Dodd-Frank Act’’). Section 619 is
commonly referred to as the ‘‘Volcker
Rule.’’
I. Background
The Dodd-Frank Act was enacted on
July 21, 2010.1 Section 619 of the DoddFrank Act adds a new section 13 to the
Bank Holding Company Act of 1956
(‘‘BHC Act’’) (to be codified at 12 U.S.C.
1851) that generally prohibits banking
entities 2 from engaging in proprietary
trading or from investing in, sponsoring,
or having certain relationships with a
hedge fund or private equity fund.3 The
new section 13 of the BHC Act also
Comments: Comments should be
received on or before January 10, 2011.
ADDRESSES: You may submit comments,
identified by Docket No. R–1397 and
RIN No. AD 7100–58, by any of the
following methods:
• Agency Web Site: https://
www.federalreserve.gov. Follow the
instructions for submitting comments at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
regs.comments@federalreserve.gov.
Include Docket Number R–1397 and
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• Fax: (202) 452–3819 or (202) 452–
3102.
1 Dodd-Frank Wall Street Reform and Consumer
Protection Act, Public Law No. 111–203, 124 Stat.
1376 (2010).
2 The term ‘‘banking entity’’ is defined in section
13(h)(1) of the BHC Act, as amended by section 619
of the Dodd-Frank Act. See 12 U.S.C. 1851(h)(1).
The term means any insured depository institution
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3 The Volcker Rule defines the terms ‘‘hedge fund’’
and ‘‘private equity fund’’ as an issuer that would
be an investment company, as defined under the
Investment Company Act of 1940 (15 U.S.C. 80a–
1 et seq.), but for section 3(c)(1) or 3(c)(7) of that
Act, or any such similar funds as the appropriate
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Futures Trading Commission (‘‘CFTC’’) may, by
rule, determine should be treated as a hedge fund
or private equity fund. See 12 U.S.C. 1851(h)(2).
SUMMARY:
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72741
provides for nonbank financial
companies supervised by the Board that
engage in such activities or have such
investments to be subject to additional
capital requirements, quantitative
limits, or other restrictions.4 These
prohibitions and other provisions of
section 619 are commonly known, and
referred to herein, as the ‘‘Volcker Rule.’’
Specifically, the Volcker Rule
prohibits banking entities from engaging
in proprietary trading (as defined by the
Volcker Rule) or from acquiring or
retaining any ownership interest in, or
sponsoring, a hedge fund or private
equity fund.5 The Volcker Rule,
however, also expressly provides certain
exceptions from these prohibitions,
including, among others, exceptions
that allow a banking entity, subject to
certain terms, conditions, and
restrictions, to: (i) Trade in obligations
of the United States or any agency
thereof, obligations issued by the
Government National Mortgage
Association, the Federal Home Loan
Mortgage Corporation, a Federal Home
Loan Bank, the Federal Agricultural
Mortgage Corporation, or a Farm Credit
System institution chartered under and
subject to the provisions of the Farm
Credit Act of 1971 (12 U.S.C. 2001 et
seq.), and obligations of any State or of
any political subdivision thereof; 6 (ii)
purchase and sell securities and other
instruments in connection with
underwriting or market-making related
activities, to the extent that any such
activities are designed not to exceed the
reasonable near term demands of
clients, customers, or counterparties; 7
(iii) engage in risk-mitigating hedging
activities in connection with and related
to individual or aggregated positions,
contracts, or other holdings that are
designed to reduce the specific risks to
the banking entity in connection with
and related to such positions, contracts,
or other holdings; 8 and (iv) purchase,
sell, acquire, or dispose of securities and
other instruments on behalf of
customers.9 Additionally, the Volcker
Rule permits the appropriate agency or
agencies, by rule, to grant other
exceptions from the prohibitions on
proprietary trading and investing in, or
4 See 12 U.S.C. 1851(a)(2) and (f)(4). A ‘‘nonbank
financial company supervised by the Board’’ is a
nonbank financial company or other company that
has been designated by the Financial Stability
Oversight Council (‘‘FSOC’’) under section 113 of
the Dodd-Frank Act as requiring supervision and
regulation by the Board on a consolidated basis
because of the danger such company may pose to
the financial stability of the United States.
5 12 U.S.C. 1851(a)(1)(A) and (B).
6 Id. at § 1851(d)(1)(A).
7 Id. at § 1851(d)(1)(B).
8 Id. at § 1851(d)(1)(C).
9 Id. at § 1851(d)(1)(D).
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Agencies
[Federal Register Volume 75, Number 227 (Friday, November 26, 2010)]
[Proposed Rules]
[Pages 72739-72741]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-29773]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2008-BT-TP-0010]
Compliance Testing Procedures: Correction Factor for Room Air
Conditioners
AGENCY: Office of the General Counsel, Department of Energy (DOE).
ACTION: Petition for rulemaking; request for comment.
-----------------------------------------------------------------------
SUMMARY: On November 15, 2010, the Department of Energy received a
petition for rulemaking from the Association of Home Appliance
Manufacturers (AHAM). The petition, requests the initiation of a
rulemaking regarding compliance testing procedures for room air
conditioners. The petition seeks temporary enforcement forbearance, or
in the alternative, a temporary industry-wide waiver or guidance, to
allow use of a data correction factor in compliance testing procedures
for room air conditioners. Public comment is requested on whether DOE
should grant the petition and proceed with a rulemaking procedure on
this matter.
DATES: Comments must be postmarked no later than December 27, 2010.
ADDRESSES: Any comments submitted must reference ``Petition for
Rulemaking: Correction Factor for Room Air Conditioners.'' Comments may
be submitted using any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: AHAM2-2008-TP-0010@ee.doe.gov. Include ``Petition
for Rulemaking'' in the subject line of the message.
Postal Mail: Subid Wagley, U.S. Department of Energy,
Office of Energy Efficiency and Renewable Energy, Building Technologies
Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-
0121. Please submit one signed original paper copy.
Hand Delivery/Courier: Subid Wagley, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington,
DC 20585-0121. Please submit one signed original paper copy.
FOR FURTHER INFORMATION CONTACT: Subid Wagley, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington,
DC 20585-0121, (202) 287-1414, e-mail: subid.wagley@ee.doe.gov. Betsy
Kohl, U.S. Department of Energy, Office of General Counsel, Mail Stop
GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-0121, (202)
586-7796, e-mail: elizabeth.kohl@hq.doe.gov.
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)). Pursuant to this
provision of the APA, AHAM petitioned the Department of Energy for the
issuance of a new rule, as set forth below. In publishing this petition
for public comment, the Department of Energy 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, the Department of Energy takes no
position at this time regarding the merits of the suggested rulemaking.
The proposed rulemaking sought by AHAM would allow manufacturers of
room air conditioners to use a correction factor that is not currently
included in the regulations governing DOE's compliance testing
procedures. The petition seeks temporary enforcement forbearance, or a
temporary industry-wide waiver or guidance, to allow use of this
methodology. The Department of Energy seeks public comment on whether
DOE should grant the petition and proceed with a rulemaking procedure
on this issue.
Issued in Washington, DC, on November 18, 2010.
Scott Blake Harris,
General Counsel.
Set forth below is the full text of the Association of Home
Appliance Manufacturers' petition:
Before the U.S. Department of Energy
November 15, 2010
Petition for Rulemaking
Petition of the Association of the Home Appliance Manufacturers for
Temporary Enforcement Forbearance, a Temporary Industry-Wide Waiver Or
Guidance To Allow Use of DOE--Proposed Correction Factor for Room Air
Conditioner Testing
Pursuant to 5 U.S.C. 553(e), the Association of Home Appliance
Manufacturers (AHAM) files this petition.
AHAM represents manufacturers of major, portable and floor care
home appliances, and suppliers to the industry. AHAM's more than 150
members employ tens of thousands of people in the U.S. and produce more
than 95% of the household appliances shipped for sale within the U.S.
The factory shipment value of these products is more than $30 billion
annually. The home appliance industry, through its products and
innovation, is essential to U.S. consumer lifestyle, health, safety and
convenience. Through its technology, employees and productivity, the
industry contributes significantly to U.S. jobs and economic security.
Home appliances also are a success story in terms of energy efficiency
and environmental protection. New appliances often represent the most
effective choice a consumer can make to reduce home energy use and
costs. AHAM, relevant to this petition, represents the manufacturers of
the vast majority of room air conditioners.
This petition requests temporary enforcement forbearance, or in the
alternative, a temporary industry-wide waiver or guidance, to allow use
of a data correction factor for room air conditioners that DOE
currently
[[Page 72740]]
acknowledges produces more accurate results and which has been proposed
(by DOE) for adoption. This relief would be automatically superseded by
the effective date of the new DOE test procedure.
We do not believe that our request requires formal notice and
comment but we are prepared to supply additional information for any
public record or procedure. Similar to the vocation of the microwave
oven test procedure, there is longstanding, sufficient public record
evidence justifying this requested action. See, 75 FR 42579, 42581
(July 22, 2010).
Initially, we note that this issue stems from an endemic problem
within the DOE test procedures which DOE and other stakeholders are
beginning to address: The DOE test procedures are outmoded and often
rely on older versions of industry practices or consensus body testing
standards which have been superseded by standards which are more
accurate, uniform, repeatable and reflective of actual use. Indeed, DOE
has endorsed and proposed using the new ANSI/ASHRAE test procedure
discussed below.
In this case, DOE currently is applying in its compliance testing
program an outmoded test methodology, which is less accurate and for
that reason alone may produce test results inappropriately indicating
that a room air conditioner has technically incorrect ratings, does not
qualify for Energy Star, or fails to meet the minimum performance
standards. As discussed below, the issue relates to the current DOE
recommended test procedure's failure to correct for deviation from
standard barometric pressure. It is unreasonable and unfair to penalize
companies during this evolving transitional period between an archaic
procedure and a new, modern methodology that is more accurate. With
these facts in mind, DOE compliance enforcement forbearance, or an
industry-wide waiver or guidance, allowing the correction factor for
room air conditioners is entirely warranted.
The issue relates to 10 CFR Part 430, Subpart B, Appendix F,
promulgated in 1977. For purposes of the DOE minimum efficiency
program, industry has since 1983 recognized the benefits of adjusting
capacity ratings to reflect a correction factor in Section 6.1.3 of
ASHRAE Standard 16-1983 (RA 99). Since 1983, AHAM's room air
conditioner certification program has used this correction factor. The
correction factor is based on the test room condition deviation from
the standard barometric pressure of 29.92 inches of mercury. The
correction factor normalizes test capacity results to standard test
room conditions and thereby produces more accurate and comparable test
results, as acknowledged by DOE. More specifically, the use of the
correction factor when barometric pressure is >1 in. Hg below standard
rating point allows capacity performance modification.
We understand that DOE or a test laboratory under contract with DOE
has recently rejected use of the correction factor at the present time
for purposes of certifying compliance to the DOE efficiency standard,
on the ground that the correction factor is not contained in the DOE
test procedure as it currently is written.
DOE has already acknowledged that its current test procedure is
inaccurate due to lack of the correction factor and that the correction
factor ought to be adopted. It has so indicated in its recent
Supplemental Notice of Proposed Rulemaking (SNOPR) to amend the test
procedure. See 75 FR 37594, 37635 (June 29, 2010). DOE states:
``Section 6.1.3 of ANSI/ASHRAE Standard 16-1983 (RA 99) also
introduces a correction factor based on the test room condition's
deviation from the standard barometric pressure of 29.92 inches
(in.) in mercury (Hg) (101 kilopascal (kPa)). Section 6.1.3 of ANSI/
ASHRAE Standard 16-1983 (RA 99) states that the cooling capacity may
be increased 0.8 percent for each in. Hg below 29.92 in. Hg (0.24
percent for each kPa below 101 kPa). This change would not impact
the measured efficiency of units tested at standard testing
conditions. The capacity correction factor provides manufacturers
with more flexibility in the test room conditions while normalizing
results to standard conditions.
* * * * *
In sum, DOE has reviewed the most recent revisions of the
referenced test standards. ANSI/AHAM RAC-1-R2008 and ANSI/ASHRAE
Standard 16-1983 (RA 99), and has determined that incorporation by
reference of these versions provide more accurate and repeatable
measurements of capacity while providing greater flexibility to
manufacturers in selecting equipment and facilities, and does not
add any significant testing burden. Furthermore, these revisions
would not impact the measurement of EER for this equipment. DOE also
believes that manufacturers may already be using these updated
standards in their testing. Therefore, DOE is proposing in today's
SNOPR to amend the DOE test procedure to reference the relevant
sections of ANSI/AHAM RAC-1-R2008 and ANSI/ASHRAE Standard 16-1983
(RA 99).''
Under these circumstances, and for the interim before final test
procedure rulemaking, it is unfair and unreasonable to penalize firms
by judging their product against an inaccurate methodology rather than
using the correction factor, which DOE correctly asserts is more
accurate and which DOE endorses and plans to adopt.
Such action by DOE is entirely warranted. In the case of microwave
ovens, DOE unilaterally revoked an outmoded test procedure through a
direct final rule and without prior notice. 75 FR 42579 (July 22, 2010)
Here, test procedure revocation is not, requested, practical nor
prudent because test standards, labels, Energy Star and incentive
programs are in place. This petition does not request that DOE
circumvent or repeal the test procedure, but rather that it immediately
act to improve testing before administrative processes are completed.
If the current test procedure is applied to comparable room air
conditioners in test rooms under different barometric pressures, it
will produce materially inaccurate capacity results. DOE acknowledges
the inaccuracy of the existing test procedure--by stressing that the
correction factor in ASHRAE 16-1983 (RA 99) produces more accurate and
repeatable test results by normalizing results to standard conditions.
75 FR at 37635. DOE states that Section 6.1.3 of ASHRAE 16-1983 (RA 99)
has ``a correction factor based on the test room condition's deviation
from the standard barometric pressure of 29.92 inches (in.) of mercury
(Hg) (101 kilopascal (kPa)) * * * The capacity correction factor
provides manufacturers with more flexibility in the test room
conditions while normalizing results to standard conditions.'' Id.
(emphasis added).
DOE concluded that the correction factor ``provide[s] more accurate
and repeatable measurements of capacity while providing greater
flexibility to manufacturers in selecting equipment and facilities, and
does not add any significant testing burden.'' Id. (emphasis added).
DOE goes on to state that it ``also believes that manufacturers may
already be using these updated standards in their testing.'' Id.
(emphasis added).
Recognizing the commercial reality and the demands of fairness, DOE
and industry should be working on this issue collaboratively. DOE has
proposed that its test procedure be amended to incorporate the
correction factor. Unfortunately, unless DOE provides relief in the
interim by procedure revision or waiver, industry will suffer from a
test procedure that DOE acknowledges is inaccurate and that is harmful
with no benefit to the public.
Accordingly, with this petition, AHAM requests temporary
enforcement forbearance, or in the alternative, a
[[Page 72741]]
temporary industry-wide waiver or guidance, to allow use of the data
correction factor for room air conditioners. This relief would be
automatically superseded by the effective date of the new DOE test
procedure.
AHAM looks forward to meeting with DOE at the earliest opportunity
to discuss this important matter.
[FR Doc. 2010-29773 Filed 11-24-10; 8:45 am]
BILLING CODE 6450-01-P