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Federal Register / Vol. 86, No. 44 / Tuesday, March 9, 2021 / Notices
systems operate at higher ESP than heatonly systems due to the installation of an evaporator coil as part of an air conditioning system, and typically require different blower speeds for heating operation and cooling operation.
ECR provided information on the operating conditions for two field installations of belt-driven, single-speed furnaces that are intended for heatingonly operation, showing field ESP
readings that are lower than the ESP
required by Appendix AA.
ECR requested that the specified models be tested under the current Appendix AA, with the following modifications: 1 In section 8.6.1, the ESP requirement is instead the factoryequipped ESP, increased by 0.08 w.c.
to accommodate the fact that furnaces are tested for Fan Energy Rating FER
without the air filter under Appendix AA; 2 sections 8.6.2, Constant circulation airflow-control setting measurements, and 8.6.3, Heating airflow-control setting measurements are not required; and 3 calculations in section 10.1, Fan Energy Rating FER, are modified to account for the absence of a separate constant circulation airflow-control setting and heating airflow-control setting.
On August 18, 2020, DOE published in the Federal Register a notice that announced its receipt of the petition for waiver, granted ECR an interim waiver, and requested public comments. 85 FR
50808 Notice of Petition for Waiver.
In the Notice of Petition for Waiver, DOE reviewed ECRs description of the issue and suggested alternative test method, as well as test data submitted by ECR. DOE also reviewed data and analyses collected and conducted in support of the final rule establishing the furnace fan test procedure. Field data previously analyzed by DOE for a notice of proposed rulemaking published in the Federal Register on May 15, 2012
indicated that 0.50 w.c. is representative of field conditions for heating-only furnaces. 77 FR 28674, 28686 May 15, 2012. Based on this review, DOEs Notice of Petition for Waiver modified the suggested alternate test procedure in ECRs petition for waiver to require that the basic models specified in the petition be initially tested at 0.500.55 w.c., rather than the 0.28 w.c. suggested by ECR which is the factory-equipped ESP of 0.20 w.c.
for the basic models for which a waiver has been requested, increased by 0.08
w.c. to account for the use of an air filter in the field. 85 FR 50808, 50811
August 18, 2020. However, given the difficulty that a number of the specified ECR basic models may have in operating at an ESP of 0.50 0.55 w.c., the
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alternate test procedure further specifies that if the unit under test shuts down prior to completion of the test, the ESP
range is incrementally reduced by 0.05
w.c., and the test is to be re-run. Id. This process is repeated until a range is reached at which the test can be conducted to its conclusion, with a minimum allowable ESP range of 0.30
0.35 w.c., which corresponds to the lowest ESP at which shut-off occurred in the ECR data. Id.
As DOE explained in the Notice of Petition for Waiver, the alternate test procedure for the interim waiver did not waive the requirements of section 8.6.3
of Appendix AA as requested by ECR
because, as DOE discussed in the furnace fans test procedure final rule published on January 3, 2014 January 2014 Final Rule , that section is not applicable to the basic models specified in the Interim Waiver Order i.e., models with only one airflow control setting.
Id., see also 79 FR 500, 514 Jan. 3, 2014. In the January 2014 Final Rule, DOE stated that for single-stage units, EMax, which is calculated in section 8.6.3 of Appendix AA, and EHeat, which is calculated in section 8.6.1.2, are equivalent because the maximum airflow-control setting and the heating airflow-control setting in which measurements are specified to be made are the same, and consequently, the same value is used for both variables in the FER equation. 79 FR 500, 514 Jan.
3, 2014. As such, there is no need to separately perform that calculation in section 8.6.3 of Appendix AA. In addition, section 10.1 of Appendix AA
states that for furnace fans for which the maximum airflow-control setting is a default heating airflow-control setting, QHeat the airflow in the heating airflowcontrol setting is equal to QMax the airflow in the maximum airflow-control setting. Based on the discussion in the January 2014 Final Rule and calculations in section 10.1, the test in section 8.6.3 of Appendix AA would not need to be performed, and, therefore, DOE found that a waiver was not required regarding sections 8.6.3 or 10.1
of Appendix AA. 85 FR 50808, 50811
August 18, 2020.
Regarding the testing in section 8.6.2
of Appendix AA, DOE noted that the testing required under that section is different than that required under section 8.6.1.2 and section 8.6.3 of Appendix AA, in that the burner would be firing only in testing performed under the latter section. Because the burner must be firing during the section 8.6.1.2 testing and must be off during the section 8.6.2 testing, it is possible that the resulting measurements would be different. As a result, in the Interim
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Waiver Order, DOE modified the suggested alternate test procedure to require that section 8.6.2 of Appendix AA be conducted, and results of the testing must be used in the calculation of FER. 85 FR 50808, 5081150812
August 18, 2020.
In the Notice of Petition for Waiver, DOE also solicited comments from interested parties on all aspects of the petition and the specified alternate test procedure. 85 FR 50808, 50808 August 18, 2020. DOE received one comment in response to the Notice of Petition for Waiver, which was from the California Investor-Owned Utilities CA IOUs .4
The CA IOUs raised a series of concerns with the Interim Waiver Order and the specified alternate test procedure, specifically the CA IOUs stated: 1 The Interim Waiver Order results in an unfair competitive advantage for ECR by allowing it to sell lower-cost furnaces as compared to other competitors; 2 the alternate test procedure is inconsistent with the requirements of 10 CFR
430.27a in that it effectively creates a new efficiency metric; and 3 based on manufacturer materials, its seems that most of the subject furnace fan basic models are intended for use with an air conditioner. CA IOUs, No. 5 at pp.
16
In support of its assertion that the alternate test procedure would provide ECR an unfair competitive advantage, the CA IOUs referenced the rulemaking for the January 2014 Final Rule in which DOE did not establish a heatingonly installation type for furnaces. CA
IOUs, No. 5 at p. 2. As explained in the April 2, 2013 supplemental notice of proposed rulemaking SNOPR for the furnace fans test procedure rulemaking, an industry stakeholder commented that it was not aware of any product on the market that would be categorized as a heating-only product, adding that this installation type could provide manufacturers with a means of gaming the test procedure by modifying its furnaces to eliminate factory-installed cooling capabilities, which would allow such furnaces to be tested at the lower ESP specified for heating-only units. 78
FR 19606, 19619 April 2, 2013.
Unaware of any products on the market that were heating-only and within the scope of the rulemaking, DOE agreed that heating-only installation types should be eliminated from consideration. Id. However, DOE would clarify that nothing in EPCA prohibits the manufacture of a furnace fan designed for heating-only installations.
4 The CA IOUs comment can be accessed at:
https www.regulations.gov/document?D=EERE2019-BT-WAV-0004-0005.

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