Re: Heaters or Furnaces, air or hydronic, electric thermal energy storage, residential or commercial, and Ceramic Thermal Energy Storage Bricks

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1 Re:, air or hydronic, electric thermal energy storage, residential or commercial, and Ceramic Thermal Energy Storage Bricks CCSB Contact: Nathan D. Ripke Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BOILERS, FURNACES, STOVES AND RELATED ARTICLES GROUP: subject to item , house heating, hot air, see Note, item 26282, in boxes, crates or wrapped packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 6 or greater NOTE Also applies on burners, sprayers, vaporizers or air conditioning apparatus when forming an integral part of the furnace which they accompany. CHINA GROUP: subject to item Chinaware, Earthenware, Porcelainware or Stoneware, NOI, released to value not exceeding $90.00 per 100 pounds, see Note, item 47514, in boxes, crates, drums or Package Chinaware, Earthenware, Porcelainware or Stoneware, NOI, not released to value of $90.00 per 100 pounds, in boxes, crates, drums or Package NOTE Not Involved. MACHINERY GROUP: subject to item Air Heaters, other than portable, with blowers or fans, with or without accompanying hardware or accessories, in packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 6 but less than Sub 3 10 or greater Machinery or Machines, NOI, or Machinery or Machine Parts, NOI: Sub 1 In boxes, crates or Packages 107, 1082 or 2107, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 8 but less than Sub 4 15 or greater Sub 5 On skids or in packages other than boxes, crates or Packages 107, 1082 or 2107, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 8 but less than Sub 8 15 or greater National Motor Freight Traffic Association, Inc. Subject 12, Page 1 of 5

2 Proposed Classification Provisions Item Description Class BOILERS, FURNACES, STOVES AND RELATED ARTICLES GROUP: subject to item , house heating, hot air, etc... No Change NOTE No Change. BRICK GROUP: subject to item A-NEW Brick, thermal energy storage, ceramic, in packages CHINA GROUP: subject to item Chinaware, Earthenware, Porcelainware or Stoneware, NOI, etc... No Change Chinaware, Earthenware, Porcelainware or Stoneware, NOI, etc... No Change NOTE No Change. MACHINERY GROUP: subject to item Air Heaters, other than portable, with blowers or fans, with or without accompanying hardware or accessories, etc... No Change, air or hydronic, electric thermal energy storage, residential or commercial, with blowers or fans and thermostat, with or without complement of ceramic thermal energy storage bricks, see Note, item C-NEW, in packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 7 but less than Sub 3 15 or greater C-NEW NOTE Applies only on air or hydronic heaters or furnaces for permanent installation that collect and store heat by means of ceramic thermal energy storage bricks Machinery or Machines, NOI, or Machinery or Machine Parts, NOI, etc... No Change Analysis Research Project 1279 and Background of Proposal Docket , Subject 4 (May 2016) was a proposal submitted by Steffes Corporation to establish new provisions for their electric thermal energy storage systems and the necessary bricks for those units. Based on the information of record, that proposal was disapproved, and Research Project 1279 was initiated to review the transportation characteristics of the involved products. Electric thermal energy storage systems represented as residential air heaters are currently classified in item , whereas the involved residential furnaces that use forced-air to distribute heat are classified in item 26280, and the involved residential and commercial hydronic furnaces are classified in item The involved ceramic thermal energy storage bricks shipped without a heater or furnace are currently classified in item or item Subject 12, Page 2 of National Motor Freight Traffic Association, Inc.

3 About Electric Thermal Storage Systems Electric Thermal Storage (ETS) systems convert low cost, off-peak electricity to heat and store it inside ceramic bricks. A thermostat monitors the room s air temperature and regulates heat delivery through blowers or fans on an as-needed basis. This technology can be used in various models of heaters or furnaces including: residential air heaters, residential forced air furnaces, and residential or commercial hydronic furnaces. Examples of the ETS systems are shown below. Shipments of Electric Thermal Storage Systems LTL shipments are tendered to the carrier in a variety of configurations. For example, one or more air heaters may be shipped on a lift truck skid or pallet, with or without bricks; one furnace may be shipped in sections on multiple pallets, with or without (a) complementary pallet(s) of bricks; or the bricks may shipped alone without a heater or furnace National Motor Freight Traffic Association, Inc. Subject 12, Page 3 of 5

4 Transportation Characteristics Information of record includes 119 density figures submitted by a shipper and carriers that represent the various models of the involved products and the different configurations in which they are tendered for shipment. Densities range from 3.19 to pcf, with an average density of pcf. When the data is evaluated based on the proposed provisions the following ranges and averages are calculated. Proposed Group Range Average Description Item A-NEW Brick Less than but less than or greater Handling and Stowability The involved heaters or furnaces are shipped inside two fiberboard sleeves with a complement of fiberboard edge protectors. The smaller units are completely enclosed in fiberboard, while the midsection of the larger units are left exposed (page 3, lower right photo). All heaters or furnaces are wrapped in plastic film, strapped to a lift truck skid or pallet. The bricks are strapped to a lift truck skid or pallet, utilize fiberboard edge protectors and are wrapped in plastic film. There have been no reports of negative handling or stowing considerations. Liability One shipper reported that the value of their heaters or furnaces ranges from $4.16 to $6.35 per pound, with an average value of $5.33 per pound. Shipments of brick range in value from $0.16 to $0.34 per pound, with an average value of $0.28 per pound. The same shipper reported a claims ratio of 2% based on 120 annual shipments. One carrier reported zero claims on the involved products. The remaining liability elements do not significantly impact the evaluation of these products. Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classifications for commodities that are a source or potential source of interpretation disputes so as to eliminate or avoid those disputes. As mentioned in the analysis, electric thermal energy storage systems are not specifically named in the Classification and are currently classified in one of three separate items depending on the products representation and primary function. Ceramic thermal energy storage bricks are also unnamed, and are currently classified in one of two general items for chinaware, earthenware, porcelainware or stoneware. CCSB policy also calls for classification provisions to reflect a commodity s known transportation characteristics. Information of record indicates that the involved products range in density from 3.19 to pcf, with an average density of pcf. CCSB policy further states that when commodities or commodity groups exhibit a wide density range not accurately reflected by a single overall average density, density-based classes may be Subject 12, Page 4 of National Motor Freight Traffic Association, Inc.

5 established. The table below illustrates the data of record when it has been divided by the proposed items and the proposed density groupings. Proposed Item Description Group Average CCSB Minimum Average Guideline Class Based on CCSB Guidelines A-NEW Brick Less than but less than or greater This proposal would establish specific provisions for ceramic thermal energy storage bricks, at class 50, based on an average density of pcf. It would also establish specific provisions for electric thermal energy storage systems predicated on density breaks at 7 and 15 pcf1. Furthermore, a new Note would be added and referenced to clarify that those provisions only apply on air or hydronic heaters or furnaces for permanent installation that collect and store heat by means of ceramic thermal energy storage bricks. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and guidelines. 1 The density provisions would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 12, Page 5 of 5