TECHNICAL SUPPORT DOCUMENT (TSD): ENERGY EFFICIENCY

PROGRAM FOR COMMERCIAL AND INDUSTRIAL EQUIPMENT:

EFFICIENCY STANDARDS FOR COMMERCIAL HEATING, AIR-.

CONDITIONING, AND WATER HEATING EQUIPMENT

Including:

Packaged Terminal Air-Conditioners and Packaged Terminal Heat Pumps

Small Commercial Packaged Boilers

Three-Phase Air-Conditioners and Heat Pumps <65,000 Btu/h

Single-Package Vertical Air Conditioners and Single-Package Vertical Heat Pumps

<65,000 Btu/h

March 2, 2006

U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

Appliances and Commercial Equipment Standards

Washington, DC 20585

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
This Document was prepared for the Department of Energy

by staff members of

Navigant Consulting, Inc.

and

Pacific Northwest National Laboratory

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TABLE OF CONTENTS

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Table of Contents

List of Figures .

List of Tables

Nomenclature

111

V

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viii

Chapter 1. Introduction 1

1.1 OVERVIEW

1.2 STRUCTURE OF THE DOCUMENT

1

3

Chapter 2. Packaged Terminal Air-Conditioners And Packaged Terminal Heat

Pumps

2.1 BACKGROUND 4

2.2 ENERGY SAVINGS 6

2.2.1 Revised Cooling Mode Energy Savings Analysis Summary 7

2.2.2 Heating Mode Energy Savings Analysis Summary 9

2.2.3 Revised Potential Energy Savings for PTACs and PTHPs Summary 9

2.3 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS 10

Chapter 3. Commercial Boilers 13

3.1 BACKGROUND 13

3.2 ENERGY SAVINGS 14

3.3 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS 15

3.3.1 Small Commercial Boilers (>300 and < 2,500 kBtu/h) 15

4.3.1.1 I=B=R Commercial Boiler Ratings Directory Analysis 15

Chapter 4. Three-Phase Air-Conditioners and Heat Pumps <65,000 Btu/h 21

4.1 BACKGROUND 21

4.1 ENERGY SAVINGS 23

4.2 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS 24

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Chapter 5. Single-Package Vertical Air Condioners and Heat Pumps

<65,000 Btu/h .................................................................................................................... 25

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5.1 BACKGROUND

5.2 ENERGY SAVINGS

5.2.1 SPVU Shipments

5.2.2 Equipment Size Analyzed

5.2.3 Time Frame

5.2.4 Product Life

5.2.5 Efficiency Levels Analyzed

5.2.6 Unit Energy Savings

5.2.7 Calculation of Energy Consumption by Standard Level

5.3 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS

5.3.1 SPVU Test Procedures and Standards

5.3.1.1 Statutory Criteria for Amended Test Procedures

5.3.1.2 Evaluation

5.3.1.3 Statutory Criteria for Amended Standards

5.3.1.4 Evaluation

5.3.1.5 Analysis of SPVAC Efficiencies - Cooling

5.3.1.6 Analysis of SPVHP Efficiencies - Cooling

25

26

26

27

27

27

27

28

29

30

30

31

32

33

33

34

35

References 37

Appendices 40

Appendix A. PTAC and PTHP Energy Savings Analyses 41

Appendix A-l Revised Cooling Mode Energy Savings Analysis 41

Appendix A-2 Heating Mode Energy Savings Analysis 48

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LIST OF FIGURES

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Figure 1. Comparison of Energy Efficiency Standards for PTACs and PTHPs -

Cooling Mode 5

Figure 2. Comparison of Energy Efficiency Standards for PTHPs - Heating

Mode 5

Figure 3: Current Efficiency Levels for PTACs

Figure 4: Current Efficiency Levels for PTHPs

11

12

Figure 5: SPVAC <65,000 Btu/h Market Data by EER Level 34

Figure 6: SPVHP <65,000 Btu/h Market Data by EER level 35

Figure 7: SPVHP <65,000 Btu/h Market Data by HSPF Level 36

Figure A - 1: HSPF versus COP47o F for Unitary Heat Pumps <65,000 Btu/h 49

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LIST OF TABLES

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Table 1. Comparison of Energy Efficiency Standards for PTACs and PTHPs

Table 2. Comparison of Cooling Energy Efficiency Levels for PTACs and

PTHPs

Table 3. Potential Energy Savings for PTACs and PTHPs Based on the Standard

90.1-1999 Replacement Efficiency Level as a Baseline*

Table 4. Differences in Assumptions for PTAC and PTHP Cooling-Mode Energy

Savings

Table 5. Updated Potential Energy Savings for PTACs and PTHPs

Table 6. Comparison of Energy Efficiency Standards for Commercial Boilers

Table 7. Potential Energy Savings for Small Commercial Boilers

Table 8. 2005 I=B=R Commercial Boiler Efficiency Summarya

Table 9. 2005 I=B=R Commercial Boiler Minimally Complying Efficiency

Summarya

.4

.6

.7

.8

.9

14

15

18

19

Table 10. Comparison of Energy Efficiency Standards for Three-Phase ACs 22

Table 11. Potential Energy Savings for Three-Phase ACs 23

Table 12. Product Shipments 26

Table 13. Annual Energy Consumption Estimates for SPVU, Cooling + Fan 29

Table 14. National Energy Consumption Estimate (Cooling and Supply Fan),

2010to2037 30

Table 15. Existing and Proposed Efficiency Standard Levels 34

Table 16. Distribution of COP for SPVHP Products with 6.6 HSPF 36

Table A - 1: Market Maximum Efficiency Levels for PTACs and PTHPs 41

Table A - 2: Reported Shipments of PTACs and PTHPs 42

Table A - 3: Shipments for PTACs and PTHPs by Capacity 42

Table A - 4: PTAC and PTHP Regional Market Ranks by Equipment Type 43

Table A - 5: Estimated PTAC and PTHP Shipments 44

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Table A - 6: Shipments by Building Category ................................................................. 44

Table A - 7: Cooling Energy Savings Scenarios Analyzed for 42"x16" PTACs

and PTHPs ......................................................................................................... 45

Table A - 8: Summary of Potential Energy Savings for Large (New Construction)

PTACs and PTHPs - Cooling Mode ................................................................. 46

Table A - 9: Summary of Potential Energy Savings for Small (Replacement)

PTHPs - Cooling Mode ..................................................................................... 47

Table A - 10: COP and HSPF Estimates for PTHP Products .......................................... 50

Table A - 11: Heating Energy Savings Scenarios Analyzed for 42"x 16" PTHPs ........... 51

Table A - 12: Summary of Potential Energy Savings for Large (New

Construction) PTACs - Heating Mode .............................................................. 52

Table A - 13: Summary of Potential Energy Savings for Small (Replacement)

PTHPs - Heating Mode ..................................................................................... 53

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NOMENCLATURE

Acronyms and Abbreviations

AC air conditioner

ANSI American National Standards Institute

ARI Air-Conditioning and Refrigeration Institute

ASHRAE American Society of Heating, Refrigerating and Air-Conditioning

Engineers

CEE Center for Energy and Environment

COP coefficient of performance

DOE U.S. Department of Energy

EER energy efficiency ratio

EPACT Energy Policy Act

EPCA Energy Policy and Conservation Act

FLEOH full-load equivalent operating hours

GAMA Gas Appliance Manufacturers Association

HI Hydronics Institute Division of GAMA

hp horsepower

HP heat pump

HSPF heating seasonal performance factor

HVAC heating, ventilating and air conditioning

I=B=R Institute of Boilers and Radiation Manufacturers

IESNA Illuminating Engineering Society of North America

LCC life-cycle cost

NA not applicable

NC not calculated

n.d. no date

Max NPV maximum net present value

PTAC packaged terminal air conditioner

PTHP packaged terminal heat pump

SEER seasonal energy efficiency ratio

SPVAC single-package vertical air conditioner

SPVHP single-package vertical heat pump

SPVU single package vertical unit

TSD technical support document

Symbols

AE differential between combustion efficiency and thermal efficiency

combustion efficiency

ET thermal efficiency

arithmetic mean

standard deviation

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Units

Btu British Thermal Unit

h hour

kWh kilowatt-hour

kBtu kilo Btu (1O Btu)

quad quadrillion Btu (1015 Btu)

sf square feet

TBtu tera Btu (1012 Btu)

W watt

yr year

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CHAPTER 1. INTRODUCTION

1.1 OVERVIEW

On October 29, 1999, American Society of Heating, Refrigerating and AirConditioning Engineers (ASHRAE)'s Board of Directors approved American National

Standards Institute (ANSI)! ASHRAE!Illuminating Engineering Society of North

America (IESNA) Standard 90.1-1999, which addressed efficiency levels for 34

categories of commercial heating, ventilating and air-conditioning (HVAC) and water

heating equipment covered by the Energy Policy and Conservation Act (EPCA).'° The

new Standard 90.1 (Standard 90.1-1999) revised the efficiency levels of the existing

Standard 90.1-1989 for certain equipment. For the remaining equipment, ASHRAE left

the preexisting levels in place, after considering revision of the levels for some equipment

and deferring consideration of others.

Following the publication of Standard 90.1-1999, the U.S Department of Energy

(the Department or DOE) performed a screening analysis that covered 24 of the

categories of equipment to help decide what action it would take with respect to the new

efficiency levels. For each of these types of equipment, the screening analysis examined

a range of efficiency levels that included the levels specified in EPCA and Standard 90.1-

1999, as well as the levels associated with the lowest life-cycle cost (LCC). The analysis

is summarized in the report "Screening Analysis for EPACT-Covered Commercial

HVAC and Water-Heating Equipment" (screening analysis) and estimates the annual

national energy consumption and the potential for energy savings that would result if the

Energy Policy Act (EPACT)-covered products were to meet these efficiency levels.25

The analysis also estimates additional energy-savings potential for the EPACT-covered

products if they were to exceed the efficiency levels prescribed in Standard 90.1-1999.

The baselines for the comparison were the corresponding levels specified in Standard

90.1-1999 and EPCA.

Following completion of the screening analysis, the Department published a

notice that described the screening analysis and announced its public availability. For

each equipment category for which ASHRAE adopted or considered a revised standard

level, the notice stated whether the Department was inclined to immediately adopt the

standard level in Standard 90.1-1999, or to undertake a more thorough analysis to

determine if a more stringent level was warranted. For the equipment categories that

ASHRAE did not address in revising Standard 90.1 - namely, three-phase air

conditioners (ACs) and heat pumps (HPs) with capacities less than 65,000 Btu per hour -

DOE stated that it had tentatively decided to take no action until ASHRAE had amended

Standard 90.1's efficiency levels for these types of equipment. Finally, the notice

published on May 15, 2000, announced a public meeting and invited written comment on

the screening analysis and DOE's planned actions. 65 FR 30929 (May 15, 2000).

The Department adopted the efficiency levels in Standard 90.1-1999 as Federal

standards to replace existing EPCA levels for 18 equipment categories of commercial air

conditioners, heat pumps, furnaces, water heaters, and hot water storage tanks following

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the public meeting on July 11, 2000. For electric water heaters, DOE rejected the

Standard 90.1-1999 level, leaving the EPCA level in place. 66 FR 3335, 3336-37, 3349-

52 (January 12, 2001) (the "January 2001 final rule").

For 11 other categories of commercial equipment, the Department stated it would

evaluate whether to adopt more stringent standards than those contained in Standard

90.1-1999. 66 FR 3336-38, 3349-52. The Department selected these categories of

equipment for further evaluation because the screening analysis indicated at least a

reasonable possibility of finding "clear and convincing evidence" that more stringent

standards "would be technologically feasible and economically justified and would result

in significant additional conservation of energy." 66 FR 3349. These are the criteria

EPCA prescribes for the adoption of standards more stringent than those in Standard

90.1. (42 U.S.C. 631 3(a)(6)(A)) The Department stated that it could discontinue its

evaluation of any of these types of equipment, however, and adopt the Standard 90.1-

1999 efficiency level, whenever it concluded that these criteria are not likely to be

satisfied. 66 FR 3348. However, DOE had previously indicated that it would take such

action only after seeking public comment. 65 FR 30932.

For three-phase central air conditioners and central air-conditioning heat pumps

less than 65,000 Btu/h (three-phase ACs), DOE took no action because ASHRAE had not

addressed these products, but encouraged ASHRAE to amend its efficiency levels for this

equipment in conjunction with the then-pending DOE standards rulemaking for similar,

single-phase residential products, and stated that DOE would act once ASHRAE had

adopted such amendments.

The Department initially considered single-package vertical air conditioners

(SPVACs) and single-package vertical heat pumps (SPVHPs) in the November 24, 1999,

residential central air conditioner (CAC) notice of proposed rulemaking (NOPR). In the

October 5, 2000, NOPR for residential CACs, DOE determined that single-package

vertical units (SPVUs) were commercial products not subject to residential efficiency

standards. Subsequently, DOE included these products as part of their evaluation of

commercial unitary air-conditioning and heat pump equipment (CUAC and HP)

rulemaking and the HVAC equipment under the ASHRAE products rulemaking

dependent upon capacity. On August 8, 2005, EPACT 2005 (Pub. L. 109-58) was signed

into law, which contains energy conservation standards for small (>65,000 Btu/h to

<135,000 Btulh), large (>135,000 Btulh to <240,000 Btu/h), and very large (>240,000 to

<760,000) commercial package air conditioners and heat pumps. The signing of EPACT

2005 required the classification of SPVUs into two distinct capacity categories: those

products <65,000 Btu/h and those products >65,000 Btu/h to <760,000 Btu/h. The

Department will continue its evaluation of products <65,000 Btu/h, which are included in

this TSD.

The four products-packaged terminal air-conditioners and heat pumps (PTACs

and PTHPs), small commercial packaged boilers, three-phase ACs and HPs <65,000

Btu/h, and SPVUs <65,000 Btu/h-are the subjects of this technical support document

(TSD). The TSD reviews the calculated potential national energy savings contained in

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the screening analysis, summarizes new data obtained and new analyses performed after

the screening analysis, and provides information supporting DOE's current action

regarding each of the five covered products.

1.2 STRUCTURE OF THE DOCUMENT

The TSD consists of six chapters. Chapter 1 includes an introduction describing

DOE's authority to take action on EPACT-covered products for which ASHRAE amends

efficiency levels prescribed in Standard 90.1-1989, background information summarizing

the history of DOE action to date, and the purpose of this TSD. The subsequent chapters

give an overview of the history of each product category, describe the individual products

and product classes being evaluated, summarize the potential national energy savings,

and describe the issues involved with and information relative to DOE's current action.

Chapter 1 Introduction

Chapter 2 Packaged Terminal Air Conditioners and Packaged Terminal Heat Pumps

Chapter 3 Small Commercial Packaged Boilers

Chapter 4 Three-Phase Air-Conditioners and Heat Pumps <65,000 Btu/h

Chapter 5 Single-Package Vertical Air Conditioners and Heat Pumps <65,000 Btu/h

Appendices Appendix A: PTAC and PTHP Energy Savings Analyses

Appendix A-i - Revised Cooling Mode Energy Savings Analysis

Appendix A-2 - Heating Mode Energy Savings Analysis

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CHAPTER 2. PACKAGED TERMINAL AIR-CONDITIONERS AND

PACKAGED TERMINAL HEAT PUMPS

2.1 BACKGROUND

PTACs and PTHPs are self-contained air-conditioning units that provide cooling,

and in some cases heating, and are installed inside a sleeve placed in an exterior wall

opening in commercial buildings. They are primarily used to provide space conditioning

for commercial facilities such as hotels, motels, hospitals, nursing homes, apartments,

dormitories, schools, and offices.

EPCA Section 340 (10)(A) defines a PTAC as "a wall sleeve and a separate

unencased combination of heating and cooling assemblies specified by the builder and

intended for mounting through the wall. It includes a prime source of refrigeration,

separable outdoor louvers, forced ventilation, and heating availability by builder's choice

of hot water, steam, or electricity." (42USC63 1 l(l0)(A))

Likewise, EPCA Section 340 (l0)(B) defines a PTHP as "a packaged terminal air

conditioner that utilizes reverse cycle refrigeration as its prime heat source and should

have supplementary heat source available to builders with the choice of hot water, steam,

or electric resistant heat." Energy efficiency standards are set forth in EPCA for PTACs

and PTHPs in Section 342 (a)(3). (42USC63 13(a)(3)) The efficiency requirements in the

statute correspond to the levels in Standard 90.1 as in effect on October 24, 1992, and are

given as formulas for energy efficiency ratio (EER) for cooling and coefficient of

performance (COP) for heating based on the capacity of the product (see Table 1, Figure

1, and Figure 2).

Table 1. Comparison of Energy Efficiency Standards for PTACs and PTHPs

Efficiency_(EERICOP)

Category

______________

Standard 90.1-1999 EPCA New Construction Replacement

________________

PTAC -

_______________

10.0 -(0.16 x 12.5 -(0.213 x 10.9- (0.213 x

Cooling Mode Cap/1000)* EER Cap/l000)* EER Cap/1000)* EER

PTHP - 10.0 -(0.16 x 12.3 -(0.213 x 10.8 -(0.213 x

Cooling Mode Cap/l000)* EER Cap/l000)* BER Cap/1000)* EER

PTHP - 1.3 + (0.16 x 3.2- (0.026 x 2.9- (0.026 x

Heating Mode EER)** COP Cap/1000))*COP Cap/1000)* COP

Sources: EPCA and Standard 90.1-1999.

* Cap means the rated cooling capacity of the product in Btu/h. If the unit's capacity is less than 7,000

Btulh, 7,000 Btulh is used in the calculation. If the unit's capacity is greater than 15,000 Btu/h, 15,000

Btulh is used in the calculation.

** EER is the minimum cooling EER.

t According to Standard 90.1-1999 Table 6.2.1D, Footnote b, replacement efficiencies apply only to units

(1) factory labeled as follows: "Manufactured for Replacement Applications Only; Not to be Installed in

New Construction Projects"; and (2) with existing sleeves less than 16 in. high and less than 42 in. wide.

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11.0

10.0

LU

9.0

8.0

7.0

0 2000 4000 6000 8000 10000 12000 14000 16000 18000 20000

Capacity (Btulh)

-1--- PIAC and PTHP Cooling Mode EPCA Level [1 0.0-(0. 16*Cap/l 000)]

-o-- PIAC Cooling Mode ASHRAE 90.1-1999 New Construction Level [1 2.5-(0.21 3*CapIl 000)]

--- PIAC Cooling Mode ASHRAE 90.1-1999 Replacement Level [1 0.9-(0.21 3*CapIl 000)1

-h--- PTHP Cooling Mode ASHRAE 90.1-1999 New Construction Level [12.3(0.213*Cap/1000)]

-o--- PTHP Cooling Mode ASHRAE 90.1-1999 Replacement Level [1 0.8-(0.21 3*Capfl 000)]

Figure 1. Comparison of Energy Efficiency Standards for PTACs and PTHPs -

Cooling Mode

3.2

3.0

0

o 2.8

0

2.6

2.4

0 2000 4000 6000 8000 10000 12000 14000 16000 18000 20000

Capacity (Btu/h)

-0--- PTHP Heating Mode EPCA Level [1 .3+(0. 1 6*EER)]

-o--- PTHP Heating Mode ASHRAE 90.1-1999 New Construction Level [3.2(0.026*Cap/1 000)]

-x--- PTHP Heating Mode ASHRAE9O.1-1999 Replacement Level [2.9(0.026*Cap/1000)]

Figure 2. Comparison of Energy Efficiency Standards for PTHPs - Heating Mode

ASHRAE's Board of Directors gave final approval to certain revisions to

Standard 90.1-1989 on October 29, 1999. For PTACs and PTHPs, ASHRAE increased

the efficiency standards and divided the standards for each category into separate levels

for new construction and replacement installations (see Table 1). In addition to the

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differences in installation, the distinctions between new construction and replacement

products are in their labeling and sleeve size. To qualify for the efficiency levels

applicable to replacement products, PTACs and PTHPs must have a sleeve size less than

16 inches high and less than 42 inches wide, and be labeled as being for replacement

applications only.

The PTAC and PTHP energy efficiency levels for EPCA, new construction

Standard 90.1-1999 and maximum net present value (Max NPV) (from the screening

analysis) are summarized for four PTAC and PTHP capacity categories in Table 2 below.

Table 2. Comparison of Cooling Energy Efficiency Levels for PTACs and PTHPs

Efficiency (EER) _____________

Category

_____________

EPCA

______________

Standard

90.14999* Max NPV*

_____________________________ ______________

PTAC<7kBtu/h 8.9 9.4 9.4

PTAC7-lOkBtu/h 8.6 9.0 10.6

PTAC 10-13 kBtu/h 8.1 8.3 10.2

PTAC>l3kBtu/h 7.8 7.9 9.5

PTHP <7 kBtu/h 8.9 9.3 9.3

PTHP7-lOkBtu/h 8.6 8.9 10.6

PTHP 10-13 kBtu/h 8.1 8.2 9.7

PTHP>l3kBtu/h 7.8 7.8 9.3

Sources: Screening Analysis (DOE 2000).

* At new construction levels only.

2.2 ENERGY SAVINGS

This section examines the national potential energy savings estimated in the

screening analysis, describes the new analysis that updates the cooling mode energy

savings estimates of the screening analysis, and summarizes the new heating mode

energy savings analysis.

The purpose of the screening analysis was to examine the efficiency levels

specified in EPCA and Standard 90.1-1999 for the EPACT-covered products, as well as

more efficient levels, including those associated with the most energy efficient products

available on the market. The energy savings estimates contained in the screening

analysis include savings for PTACs and PTHPs operating in the cooling mode only. The

potential energy savings estimates for PTACs and PTHPs operating in the cooling mode

in the screening analysis are summarized in Table 31

Energy savings for PTHPs operating in the heating mode were not calculated in the Screening Analysis.

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Table 3. Potential Energy Savings for PTACs and PTHPs Based on the Standard

90.1-1999 Replacement Efficiency Level as a Baseline*

Potential Energy Savings (guads)

Category Standard 90.1-1999

Relative to EPCA

Max NPV Relative to

________________________ Standard 90.1-1999

PTACs - Cooling Mode 0.068 0.3 12

PTHPs -Cooling Mode 0.039 0.249

PTHPs -Heating Mode NC NC

TOTAL 0.107 0.561

Source: Screening Analysis (DOE 2000, Table 3.12).2

* Assumes Standard 90.1-1999 standards for Replacement apply to 100% of the units.

Table 3 shows the results of the energy savings calculations as presented in Table

3.12 of the screening analysis. The Department subsequently used these values in

developing the summary chart of potential energy savings in the January 12, 2001, final

rule. 66 FR 3336. Table 3 shows the potential energy savings of 0.561 quads for

developing a standard at the Max NPV level, which is higher than that of Standard 90.1-

1999. The potential energy savings for the Standard 90.1-1999 replacement efficiency

levels relative to the EPCA efficiency levels are 0.107 quads as shown in Table 3. These

savings are a result of assuming 100 percent of the packaged terminal products increasing

in efficiency from the EPCA baseline levels to the Standard 90.1-1999 replacement

efficiency levels only.

2.2.1 Revised Cooling Mode Energy Savings Analysis Summary

This section describes the revised analysis that updates the cooling mode energy

savings estimates for PTACs and PTHPs in the screening analysis. The methodology and

assumptions used for the revised cooling mode energy savings analysis are presented in

Appendix Al. In Standard 90.1-1999, the replacement efficiency level only applies to

products with sleeve sizes less than 16 inches in height and 42 inches in width. The

original screening analysis lumps the PTAC and PTHP units together without regard to

product dimensions. The assumptions made in the revised analysis are listed in Table 4

and described below.

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Table 4. Differences in Assumptions for PTAC and PTHP Cooling-Mode Energy

Savings

Category Screening Analysis Revised Cooling Mode

Energy_Savings_Analysis

_____________

Methodology

_________________________

Savings are calculated • Savings are calculated using one

under two different scenario -market weighted

scenarios -using Standard shipments used to calculate

90.1-1999 new construction savings for both Standard 90.1-

efficiency levels and 1999 efficiency levels.

replacement efficiency

levels. *

Shipments • All shipments grouped • 85% of shipments estimated to

together regardless of be larger products, and 15%

product size. smaller products.

• 100% of shipments used in • Shipment estimates based on

both calculation scenarios, average of 1999-2000 shipments

o Shipment fraction for from ARI and Census data.

smaller products not

provided by ARI and

unknown. ______________________________

Cooling Load Space cooling load not • Space cooling load based on

analyzed separately from estimated cooling load for

other packaged unitary lodging building category.

______________

equipment. ______________________________

Analysis Period 2004-2030 2008-203 0, assumes DOE

for Developing completing a rulemaking by

a Higher 2004 with an effective date of

Standard __________________________

2008.

* As shown in the Screening Analysis (DOE 2000, Appendix D).'

The Department has re-evaluated the energy savings estimates in the screening

analysis for PTAC and PTHP products operating in the cooling mode based on new

market information (see Table 4 for a list of new assumptions). The revised cooling

mode energy savings analysis estimates the size of the market for larger sized packaged

terminal products to be 85 percent of current U.S. shipments and 15 percent for smaller

size packaged terminal products based on average shipment data from 1999 to 2001 from

ART and Census information. Also, the shipments were allocated among the two

Standard 90.1-1999 efficiency levels - larger products were assigned the Standard 90.1-

1999 new construction efficiency level and smaller products were assigned the Standard

90.1-1999 replacement efficiency level. Furthermore, the cooling load estimates in the

updated analysis reflect cooling loads for lodging facilities only because the majority of

PTAC and PTHP installations are in lodging (i.e., apartments, hotels, motels, and assisted

living residences). In addition, DOE updated the effective dates for adopting standards

higher than the Standard 90.1-1999 based on the earliest possible timeframes for

conducting a rulemaking and making standards effective.

03/02/06

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
2.2.2 Heating Mode Energy Savings Analysis Summary

The Department also conducted an analysis to examine the additional energy

savings potential from improvements in the heating efficiency of PTHPs, since this was

not included in the screening analysis. DOE estimates that PTHPs represent

approximately 45 percent of the total market for packaged terminal equipment. Also, the

heating mode energy savings analysis assumes that 85 percent of the PTHP market is in

the larger product size category, while 15 percent of the PTHP market is in the smaller

category, similar to the assumptions made for PTACs. The methodology and

assumptions used for the heating mode energy savings analysis are presented in

Appendix A-2.

2.2.3 Revised Potential Energy Savings for PTACs and PTHPs Summary

Table 5 demonstrates the revised potential energy savings for PTACs and PTHPs

for both cooling and heating mode relative to EPCA and Standard 90.1-1999. Table 5

also shows the potential energy savings when adopting the market maximum efficiency

levels for packaged terminal products relative to the Standard 90.1-1999 efficiency

levels.

Table 5. Updated Potential Energy Savings for PTACs and PTHPs

Potential Energy Savings (guads)

Standard 90.1-1999 Market Maximum

Relative to EPCA Relative to Standard 90.1-1999

Category -_______________ _______________ _______________ New _______________ New

Construction Replacement Construction Replacement

(Large PTHPs) (Small PTHPs) (Large PTHPs) (Small PTHPs)

____________ ______________

PTAC &

______________

PTHP 0.450* 0.012* 0.048** 0.055t Cooling

Mode

_______________ _______________

PTHP

_______________ _______________

Heating 0.037* 0 0.031** 0.006t

Mode

_____________ _____________

TOTAL

_____________ _____________

0.499 0.139

* Assumes having an effective date for the adopted ASHRAE standard in 2005 with energy savings

calculated to 2030.

** Values represent adopting the market maximum efficiency level in 2008 relative to adopting the

Standard 90.1-1999 New Construction efficiency levels in 2005.

l Values represent adopting the market maximum efficiency level in 2008 relative to adopting the

Standard 90.1-1999 Replacement efficiency level in 2005.

The adoption of Standard 90.1-1999 efficiency levels for products with sleeve

sizes greater than or equal to 1 6"x42" is estimated to provide potential energy savings of

0.499 quads of energy relative to the EPCA standard levels in cooling mode. The

Department estimates that the adoption of Standard 90.1-1999 replacement efficiency

levels for smaller sleeve-size packaged terminal products will save an additional 0.0 12

03/02/06

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
quads of energy for cooling operation. The revised cooling mode energy savings analysis

also shows that adopting the market maximum efficiency levels for packaged terminal

products compared to the Standard 90.1 efficiency levels gives an additional potential

energy savings of 0.048 quads for the larger sleeve size products and an additional 0.055

quads for the smaller sleeve size products (assuming that market maximum for these

products would bring them up to the efficiency required by Standard 90.1-1999 for the

16" x 42" or larger products by 2008).

The heating mode energy savings analysis shows that adoption of Standard 90.1-

1999 efficiency levels for products with sleeve sizes greater than or equal to 1 6"x42" is

estimated to provide savings benefits of 0.03 7 quads of energy relative to the EPCA

standard levels. Adoption of Standard 90.1-1999 efficiency levels for smaller packaged

terminal products is expected to save zero quads of energy, since the heating COP

efficiency levels for these smaller sleeve size PTHP products are identical to the current

EPCA requirements. Since there is no change in efficiency levels, this analysis assumes

that there are zero heating energy savings from adoption of the Standard 90.1-1999

heating efficiencies for these products. DOE assumed that, independent of adoption of

standards, the heating efficiency for the fraction of the market that is represented by the

small size PTHPs would meet the Standard 90.1-1999 efficiency levels by 2008.

In summary, the potential cooling-mode energy savings in seeking a standard

above Standard 90.1-1999 is estimated in the Screening Analysis to be 0.561 quads. The

revised energy savings analysis calculated the revised cooling mode potential energy

savings analysis to be 0.462 quads when compared to EPCA. The revised potential

cooling-mode energy savings in seeking a standard above Standard 90.1-1999 is

estimated to be 0.103 quads. Furthermore, the total potential energy savings (heating

mode and cooling mode) in adopting a standard above the Standard 90.1-1999 efficiency

levels is estimated to be 0.139 quads.

2.3 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS

One of the factors that DOE considers in developing priorities and establishing

schedules for conducting rulemakings is "evidence of energy efficiency gains in the

market absent new or revised standards." Evidence of such gain exists for PTACs and

PTHPs. An examination of the January 2003 ARI Directory for PTACs and PTHPs

reveals that 52 percent of the listed PTACs are at or above the Standard 90.1-1999 new

construction efficiency level and 98 percent of the listed PTACs are at or above the

Standard 90.1-1999 replacement efficiency level (see Figure 3)4 Furthermore, 72

percent of the listed PTHPs are at or above the Standard 90.1-1999 new construction

efficiency level and 99 percent of the listed PTHPs are at or above the Standard 90.1-

1999 replacement efficiency level (see Figure 4)5 Although the data do not represent

information on actual shipments of PTACs and PTHPs, they do suggest that

manufacturers have already been manufacturing the equipment at these higher efficiency

levels without a requirement to do so.

03/02/06

10

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
This information suggests that some of the potential energy savings estimated in

the previous section may be achieved in the absence of standards that exceed the levels in

Standard 90.1-99, because a substantial part of the PTAC and PTHP market has already

moved to higher efficiency levels.

----------

13

12

11

uJ 10 uJ

9

8

7

• EPCA Required EER

ASHRAE New EER

ASHRAERepIacementEER

- 52% of the listed PTAC5 are at or above

.4

• 4444•

the ASHRAE new construction level.

•

44 4

4

e , , - 98% of the listed PTACs are at or above the

,,•

44

4

,

.4

4

44 4

4+ +

4. 4.

----4,----- -------4 -

-

----- --- 4-

4

44. 4

_ 4

,

__ ,,, 4

•

_

CS 4* 4

- - - .-.

•

•

44 - - - - - - - - - - -

-.-. 4 4 •4 +4

-S. 4.

5 7 9 11 13 15 17 19 21

Source: January 2003 ARI PTAC Directory (ARt 2003a). Cooling Capacity [kBtu/h]

Figure 3: Current Efficiency Levels for PTACs

03/02/06

11

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
13

-------- 12 --

________ 11

w 10 ----------------- ---------------------

w

9

8

7

• EER

.4

EPCA Required EER

ASHRAE NEW EER

Ge

C,

- ASHRAE Replacement EER -----------------*------------

- 72% of the listed PTHPs are at or above

•

Ge 44.4

the ASHRAE new construction level.

4

,• , - 99% of the listed PTHPs are at or above the

ASHEreplacewentJeveI.

444.

• 4

4

.4 - -,--

•

Ge

---

- •- •-• - - --

•

- 400 4

------S

0G

•

• •__ •

44, ,,t =__==_S_____

•55• 0 •+4

5 7 9 11 13 15 17 19 21

Cooling Capacity [kBtu/h]

Source: January 2003 ARI PTHP Directory (ARI 2003b).

Figure 4: Current Efficiency Levels for PTHPs

03/02/06

12

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
CHAPTER 3. COMMERCIAL BOILERS

3.1 BACKGROUND

Commercial boilers (also called commercial packaged boilers) are used to provide

heating for commercial facilities by heating water and distributing the water in the form

of steam or hot water. Commercial boilers are differentiated from residential boilers by

their gross output capacity - residential boilers have a capacity of up to 300 kBtu/h while

commercial boilers have capacities of 300 kBtu/h or larger. Commercial boilers can be

classified into several categories, including oil-fired or gas-fired boilers, steam or hotwater boilers, and small (300 kBtu/h to 2,500 kBtu/h) or large (>2,500 kBtu/h)

commercial boilers.

EPCA provides efficiency standards for commercial packaged boilers. EPCA

Section 340 (1 1)(B) defines a packaged boiler as "a boiler that is shipped complete with

heating equipment, mechanical draft equipment, and automatic controls; usually shipped

in one or more sections." (42USC63 11(11 )(B)) The efficiency of a commercial boiler

can be expressed in one of two ways - combustion efficiency (Ec) or thermal efficiency

(ET). Ec (sometimes referred to as "fuel efficiency") is a measure of a the ability to

extract heat from the fuel and is defined as 100 percent minus flue losses (or stack

losses).15 Ec measures the heat loss through the boiler's stack and takes into

consideration incomplete fuel combustion. Flue losses include dry flue gas, incomlete

combustion, and uncondensed water vapor formed by the combustion of hydrogen. Ec

ranges from 75 percent to 86 percent for most non-condensing mechanically fired

boilers.9

In contrast, ET (sometimes referred to as "overall efficiency", "boiler efficiency"

or "fuel-to-steam efficiency") is a measure of a boiler's ability to provide useful heat and

is defined as the ratio of energy output to energy input. E can be calculated from a

boiler rating by dividing the gross output value (total heat transferred to water or stream)

by the gross input value (higher heating value of fuel consumed).'8 In contrast to E2 ET

accounts for radiation losses and convection losses through the boiler's shell (i.e., jacket

losses or case losses) and heat exchanger efficiency. ET is a more accurate metric for

describing the performance of boilers from an energy efficiency point of view because it

takes into account the useful output of either steam or hot water that is produced by the

boiler. ET is mathematically related to E with the equation Ec = ET -jacket loss.

However, the amount of heat loss through a boiler's shell (i.e., jacket loss) varies

depending on the boiler's design and construction.

Minimum efficiency levels for commercial boilers in EPCA are 80 percent

combustion efficiency (Ec) for gas-fired commercial boilers (42USC6313(a)(4)(C)) and

83 percent Ec for oil-fired commercial boilers (42USC63 13(a)(4)(D)) (see Table 6).

Minimum efficiency levels in Standard 90.1-1989 were the same as the EPCA efficiency

levels. During the development of Standard 90.1-1999, ASHRAE changed the efficiency

2 Combustion efficiency levels as specified in EPCA.

03/02/06

13

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
metric from Ec to ET for small commercial boilers. For large commercial boilers,

ASHRAE maintained the combustion efficiency metric.

In developing Standard 90.1-1999, ASHRAE chose a 5 percent differential

between Ec and E-r (AE) for hot water boilers that met an 80 percent combustion

efficiency. Therefore, for small commercial boilers (^300 and ^2,500 kBtu/h in

capacity), ASHRAE, based on input and data provided by GAMA, adopted a 75 percent

ET level for small gas-fired boilers which was believed to be consistent with the EPACT

92 minimum standard (80 percent Ec - 5 percent AE = 75 percent ET) and a 78 percent ET

level for small oil-fired boilers (83 percent E - 5 percent AE = 78 percent ET) as part of

Standard 90.1-1999. Oil-fired boilers were not explicitly analyzed as part of the

ASHRAE process, but instead were assumed to have both thermal and combustion

efficiencies three percentage points higher than that finally established for gas-fired

boilers.

Table 6. Comparison of Energy Efficiency Standards for Commercial Boilers

Efficiency

Category EPCA Standard 90.1-1999

Small Gas-Fired (300-2,500

kBtu/h)

80.0% Ec

_________________

75.0% E

________________

Small Oil-Fired (300-2,500

kBtu/h)

83.0% Ec

_________________

78.0% E

________________

Sources: EPCA and Standard 90.1-1999.

3.2 ENERGY SAVINGS

The screening analysis shows the estimated potential national energy savings for

gas-fired commercial boilers with respect to the EPCA efficiency baseline. The

Department did not analyze energy savings for oil-fired commercial boilers in the

screening analysis. For small commercial hot water boilers, ASHRAE changed the

minimum efficiency in Standard 90.1-1999 from the 80 percent Ec (as specified in

EPCA) to 75 percent ET. For gas-fired products, ASHRAE implied that this 5 percent

point differential was characteristic of the efficiency ratings difference for products with

an 80 percent Ec rating, and the screening analysis therefore stated there was no energy

savings in adopting Standard 90.1-1999 levels. However, there is an estimated 0.064

quads of potential energy savings reported in the Screening Analysis for adopting

Standard 90.1-1999 over the EPCA levels for small gas-fired commercial steam boilers

(see Table 7). This is because the GAMA data for gas-fired steam boilers suggested that,

for baseline products (80 percent Ec), a 72 percent ET was more representative of their

thermal efficiency. Thus this 8 percent point differential was used in describing the

baseline thermal efficiency for the three categories of small steam boiler products (400,

800, and 1,500 kBtu/h capacities). These products are then shown as going from a 72

percent E1 value in EPCA to a 75 percent ET value in Standard 90.ll99925, even though

the EPCA baseline efficiency specified is 80 percent Ec for these boilers. The

Department also calculated energy savings for adopting various efficiency levels above

03/02/06

14

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
the Standard 90.1-1999 levels in the screening analysis. Energy savings resulting from

adopting the Max NPV efficiency levels relative to the Standard 90.1-1999 levels are

summarized in Table 7.

Table 7. Potential Energy Savings for Small Commercial Boilers

EPCA Standard 90.1-1999 Max NPV

_______ Relative to EPCA Relative to 90.1-1999

Category

E ET

Energy Energy

(%) (%) Savings (/) Savings

____________________ _______ _______

(guads) (guads)

Small Gas-Fired

_______

Boilers 80.0 75.0 0.064 78.7 0.200

(300-2,500 kBtu/h)

_______ _______ _______________

Small Oil-Fired

_______ _______________

Boilers 83.0 81.0 NC - NC

(300-2,500 kBtu/h)

_______ _______ ______________ _______ ______________

Sources: EPCA and Screening Analysis (DOE 2000).

* Combustion efficiency.

The screening analysis estimates that the Max NPV efficiency levels (i.e., the

efficiency levels for the lowest life-cycle cost) occur at an average of 78.7 percent E1 for

all small gas-fired commercial boilers. The corresponding estimated energy savings for

the Max NPV efficiency levels relative to Standard 90.1-1999 is 0.200 quads for small

gas-fired boilers (see Table 7).

3.3 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS

3.3.1 Small Commercial Boilers (300 and < 2,500 kBtu/h)

A significant issue regarding small commercial boilers is whether ASHRAE

lowered the standard in changing from an 80 percent Ec level specified in EPCA to a 75

percent ET level specified by Standard 90.1-1999 for small gas-fired boilers, and an 83

percent Ec level specified by EPCA to a 78 percent Er level specified by Standard 90.1-

1999 for small oil-fired boilers. The Department's understanding is that the 5 percent

differential between the two efficiency metrics corresponds to the largest difference

between combustion and thermal efficiency levels for any boiler ratings reported in the

Institute of Boilers and Radiation Manufacturers (I=B=R) directory and complied with

the existing 80 percent Ec efficiency level specified by EPCA. Moreover, the differential

was not based on a direct correlation between Ec and ET. However, the Department's

analysis of the 2005 I=B=R directory for commercial boilers shows that the average

differential between Ec and ET for commercial boilers listed (gas and oil-fired boilers of

all capacities) is 2.28 percent (see Table 8).21 The following section describes the

analysis of the 2005 I=B=R ratings directory and quantifies the differential between E

and ET based on available data.

4.3.1.1 I=B=R Commercial Boiler Ratings Directory Analysis

03/02/06

15

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
The I=BR ratings directory is produced by the Hydronics Institute (HI) Division

of the Gas Appliance Manufacturers Association (GAMA) and includes boilers,

baseboard radiation, and finned tube radiation products. The Department chose the

I=B=R ratings directory for the analysis because the directory is the best available source

for ETratings3 across the boiler industry. For this analysis, DOE used only the

commercial boiler section of the directory (i.e., boilers with capacities of 300 kBtu/h or

larger). The 2005 I=BR ratings directory lists 1715 commercial boiler models from 25

manufacturers. However, the directory has certain features and

peculiarities/inconsistencies which limited the number of boilers that could be examined

in the analysis.

First, some of the boilers are designated with a "#" symbol before the model

series name indicating that these boilers are tested for Ec under test procedures specified

in the ANSI Z2 1.13 test method.7 The remaining boilers (those without a "#" symbol

before the model series name) are tested for both Ec and ET under test procedures

specified in the HI test method.19 The Department is unaware of any rationale that would

cause commercial boiler manufacturers to use the HI test method over the ANSI Z21 .13

test method. ET values are calculated by dividing the gross output value by the nameplate

input rating4 for only those boilers tested under the HI test procedure (boilers without the

"#" symbol before the model series name). ET values cannot be calculated for boilers

tested under ANSI Z2 1.13 because of the difference in the method of testing. Therefore,

this analysis excluded the boiler models certified under ANSI Z2 1.13. The remaining

boilers represent 62.6 percent of the boilers in the directory and include 1075 commercial

boilers.

Second, some of the boiler ratings in the directory show ET ^ Bc, which is

physically impossible. ET is always less than Bc because ET includes the effects of jacket

losses and Ec does not. These anomalous ratings are likely due to HI's de-rating

procedures, manufacturers' interpolation of results.27 Any significant variation is

instrument calibration and test procedures leads to erroneous readings. Specifically, the

HI test procedure allows boiler manufacturers to de-rate boilers by 3 percent for boilers

using dual fuel burners (HI 1989). Also, manufacturers may interpolate ratings for model

series without actually testing the entire model line (Bixby 1999 as cited in Ware 2000).27

Manufacturers are also allowed to "self-select" boilers they certify to HI which could

result in misleading results.27 In addition, HI's testing program is a "witnessed" boiler

test at a manufacturer's facility, rather than at a certified testing facility exclusively used

for HI boiler testing (Demaria 1999 as cited in Ware 2000). This can result in variation

in instrument calibration and variation in testing. Finally, calibration of testing

instruments may differ among the manufacturer test facilities even within the

requirements of the HI test standard (HI 1989 as cited in Ware 2000). All of these factors

potentially contribute to errors in the boiler ratings. For these reasons, this analysis

E1 values are calculated by dividing the listed gross output values by the gross input values.

For oil-fired boilers, a heating value of 140,000 Btu/gallon is used for boilers using light oil and 150,000

Btulgallon is used for boilers using heavy oil.

03/02/06

16

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
excluded boiler models where ET ^ Ec. The remaining boilers represent 59.4 percent of

the boilers in the directory and include 1019 commercial boilers.

Table 8 shows a summary of the commercial boilers examined in the 2005 I=B=R

ratings directory. The table shows that, for all of the small commercial boilers evaluated

(gas and oil-fired), the average Er is 80.9 percent and the average difference between

combustion and thermal efficiency (AE) is 2.6 percent. For small gas-fired boilers, the

average ET is 79.7 percent and the average AE is 2.6 percent. For small oil-fired boilers,

the average E-r is 82.3 percent and the average AE is 2.61 percent. Furthermore, Table 14

shows that among the small gas-fired commercial boilers that have Ec between 80

percent and 81 percent, the average ET is 76.7 percent and the average AE is 3.6 percent.

Among the small oil-fired commercial boilers that have Ec between 83 percent and 84

percent, the average ET is 81.0 percent and the average AE is 2.5 percent. Finally, the

2005 I=B=R directory shows 105 minimally complying small gas-fired boilers (i.e., gasfired boilers with E = 80.0 percent) and only one minimally complying small oil-fired

boiler (i.e., oil-fired boilers with Bc = 83.0 percent) in Table 14. For small gas-fired

boilers that minimally comply (Ec=80.0 percent), the average ET is 76.8 percent and the

average AE is 3.16 percent. Among the small, oil-fired boilers that minimally comply

(Ec83.0 percent), the ET is 82.1 percent and the average AE is 0.9 percent.

Because some boilers have been excluded from the sample examined, few copper

or stainless steel boilers of any size or fuel type are represented. Table 8 also shows the

maximum, minimum, and standard deviation for the sample examined to show the range

and variance in efficiencies.

Since the boilers examined represent only 59 percent of the boilers listed in the

2005 I=B=R ratings directory, it's important to determine whether the 59 percent

examined are representative of the entire listing. To verify this, DOE performed a

variance test on the E ratings for the boilers with ET ratings as demonstrated by Ware.27

The Department computed the mean (jt) and standard deviations (ci) for different

commercial boilers categories. The results indicate that the dispersion among E values

is somewhat tighter than a normal distribution and are also consistent with Ware.

03/02/06

17

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Table 8. 2005 I=B=R Commercial Boiler Efficiency Summarya

Gas Oil ALL BOILERS (Gas and Oil)

E E1 AE E ETb E E ET Categ ry (%) (%) (%) (%) (%) (%) (%)

Average (j.t) Boilers of All Sizes 81.83 79.55 2.28 84.59 82.32 2.27 83.14 80.86 2.28

Maximum 97.10 96.40 5.10 93.30 92.90 6.90 97.10 96.40 6.90

Minimum 80.00 75.40 0.10 81.20 75.60 0.10 80.00 75.40 0.10

Standard Deviation () 2.51 3.01 1.30 1.19 1.78 1.29 2.43 2.86 1.30

Count(n) 537 537 537 482 482 482 1019 1019 1019

Average (j.t) 300 kBtu/h & <2,500 kBtu/h 82.30 79.68 2.62 84.86 82.26 2.61 83.48 80.87 2.62

Maximum 97.10 96.40 5.10 93.30 92.90 6.90 97.10 96.40 6.90

Minimum 80.00 75.40 0.10 81.20 75.60 0.10 80.00 75.40 0.10

Standard Deviation (cs) 3.20 3.79 1.36 1.34 1.93 1.31 2.83 3.33 1.34

Count(n) 288 288 288 246 246 246 534 534 534

Average (.t) Aluminum 85.90 85.00 0.90 93.30 92.90 0.40 89.60 88.95 0.65

Average (ji) Cast Iron 81.46 79.16 2.30 84.59 82.34 2.25 82.93 80.66 2.28

Average (ji) Copper 84.00 80.92 3.08 - - - 84.00 80.92 3.08

Average (R) Steel 90.08 88.46 1.62 84.33 81.62 2.71 86.58 84.29 2.29

Average (R) Stainless Steel 95.10 93.40 1.70 - - - 95.10 93.40 1.70

a. Model series starting with a '#" symbol in the I=B=R Ratings Directory are not included. Boiler models with ET^EC are not included.

b. For light oil models, a nominal heating value of 140,000 Btu per gallon is used.

For heavy oil models, a nominal heating value of 150,000 Btu per gallon is used.

10/05/05

18

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Table 9. 2005 I=B=R Commercial Boiler Minimally Complying Efficiency Summarya

_____________________________________ - G as Oi l

Categ

ET for AE for ET for AE for ETb for AE for

________

E1b for

________

AE for

80E<81 8OEc<8I E080.0 E080.0 83Ec<84 83^Ec<84 Ec83.0 E83.0

_________________________ (%) (%) (%) (%) (%) (%) (%) (%)

Average (ii) Boilers of All Sizes 77.42 2.79 77.52 2.48 81.27 2.33 82.10 0.90

Maximum 79.90 5.10 78.20 4.60 83.50 4.50 82.10 0.90

Minimum 75.40 0.90 75.40 1.80 79.20 0.10 82.10 0.90

Standard Deviation (a) 1.34 1.34 0.93 0.93 1.15 1.23 0.00 0.00

Count(n) 156 156 105 105 196 196 1 1

Average (ii) ^300 kBtu/h & <2,500 kBtu/h 76.67 3.56 76.84 3.16 81.04 2.54 82.10 0.90

Maximum 79.90 5.10 78.20 4.60 83.50 4.50 82.10 0.90

Minimum 75.40 0.90 75.40 1.80 79.20 0.10 82.10 0.90

Standard Deviation (a) 1.33 1.35 1.05 1.05 1.13 1.18 0.00 0.00

Count(n) 78 78 47 47 72 72 1 1

a. Model series starting with a "#' symbol in the FBR Ratings Directory are not included. Boiler models with E1^Ec are not included.

b. For light oil models, a nominal heating value of 140,000 Btu per gallon is used.

For heavy oil models, a nominal heating value of 150,000 Btu per gallon is used.

10/05/05

19

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
As a result of the analyses based upon the GAMA directory data, it is evident that

the average difference between Ec and ET is on the order of approximately two to three

percent as shown in Table 8 and Table 9, depending on the type of boiler. These values

are lower than the five percent AE ASHRAE used in translating E efficiency levels in

EPCA into ET efficiency levels in Standard 90.1-1999 for small commercial boilers.

In addition, the above analysis indicates that the 0.200 quads of potential energy

savings estimated in the screening analysis for adopting the Max NPV efficiency levels

over the Standard 90.1-1999 efficiency levels for small gas-fired commercial boilers

should be reduced. The Department calculated the 0.200 quads of potential energy

savings as the difference in energy consumption between boilers with efficiencies at the

Max NPV level of 78.7 percent ET and the Standard 90.1-1999 efficiency level of 75

percent E1 (see Table 7). However, as shown above, the average ET for small gas-fired

commercial boilers is 79.7 percent in the 2005 I=B=R directory, which is greater than the

Max NPV level estimated in the screening analysis. Therefore, if the average ET values

from the analysis above are used as the baseline in the calculation, there would be no

potential energy savings because the average ET values are already higher than the Max

NPV efficiency levels.

10/05/05

20

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
CHAPTER 4. THREE-PHASE AIR-CONDITIONERS AND HEAT PUMPS

<65,000 BTU/H

4.1 BACKGROUND

Three-phase central air-conditioners and central air-conditioning heat pumps

(three-phase ACs) less than 65,000 Btu/h in cooling capacity are used in commercial

applications and are physically the same as residential central air-conditioning units of

the same sizes, except for certain electrical components (e.g., the compressor and fan

motors, safety cutoffs). Residential central air-conditioning units have single-phase

electrical components while the commercial versions have three-phase electrical

components. The product classes being considered are air-cooled three-phase ACs less

than 65,000 Btu/h that are either single-package or split-system.

Three-phase ACs and HPs fall within the small commercial package airconditioning and heating equipment category, which is defined in EPCA as "air-cooled,

water-cooled, evaporatively-cooled, or water source (not including ground water source)

electrically operated, unitary central air conditioners and central air-conditioning heat

pumps for commercial application which are rated below 135,000 Btu per hour (cooling

capacity)." (42USC63 11(8)) Energy efficiency levels for single-package three-phase

ACs less than 65,000 Btu/h were set forth in EPCA at a seasonal energy efficiency rating

(SEER) level of 9.7 for cooling and a heating seasonal performance factor (HSPF) level

of 6.6 for heating (see Table 10). (42USC6313(a)(l)(B and E)) Energy efficiency levels

for split system three-phase ACs less than 65,000 Btu/h were 10.0 SEER for cooling and

6.8 HSPF for heating. (42USC63 13(a)(1)(A and D)) These efficiency levels are the

same as those in Standard 90.1-1989. During the development of Standard 90.1-1999,

ASHRAE explicitly chose not to revise standards for air-cooled three-phase ACs less

than 65,000 Btu/h. This decision was based on the close relationship the design of these

products has to residential, single-phase air-cooled air-conditioners and heat pumps less

than 65,000 Btu/h, whose efficiency is regulated under Section 325 of EPCA.

Subsequently, in the January 12, 2001, final rule (66 FR 3336), DOE stated that it would

take no action on three-phase ACs since ASHRAE took no action. As a result, the EPCA

energy efficiency levels for the three-phase ACs of 9.7 SEER for single-package units

and 10 SEER for split systems remained in place. DOE completed its standards

rulemaking to develop and set new efficiency standards for these single-phase products,

and published a final rule in the Federal Register on May 23, 2002. 67 FR 36368. This

rule sets efficiency standards for residential, single-phase air-cooled air conditioners and

heat pumps at a SEER rating of 12.0 for both single-package and split-system heat

pumps.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Table 10. Comparison of Energy Efficiency Standards for Three-Phase ACs

Efficiency (SEER)

_______________

EPCA Standard 90.1- Addendum ito

Category 1999 Standard 90.1-2001 ________

Cooling

________

Heating Cooling Heating Cooling Heating

(SEER) (HSPF) (SEER) (HSPF) (SEER) (HSPF)

____________

3-Phase Single- 9.7 NA 9.7 NA 12.0 NA

Package AC

_______ _______ _______ _______ __________ __________

3-Phase Single- 9.7 6.6 9.7 6.6 12.0 7.4

Package HP

_______ __________ __________

3-Phase Split-

_______

10.0

_______

NA

_______

10.0 NA 12.0 NA

System AC

______ _______ _______ _______ _________ _________

3-Phase Split- 10.0 6.8 10.0 6.8 12.0 7.4

System HP

_______ _______ _______ _______ __________ __________

Sources: EPCA, Standard 90.1-1999, and Standard 90.1-200i Addendumi.

On January 22, 2001, the Department published a Final Rule setting a 13 SEER

and 7.7 HSPF standard for residential central air conditioners and heat pumps. The AirConditioning and Refrigeration Institute (ART) requested a judicial review of this rule by

the US Court of Appeals for the 4th Circuit in Richmond, Virginia. Subsequently, DOE

issued the May 23, 2002 rule, withdrawing the 13 SEER rule and enacting a 12 SEER

and 7.4 HSPF standard. ARI supported this 12 SEER Rule.

In June of 2002, ART proposed an addendum to the ASHRAE 90.1 committee

during ASHRAE's annual summer meeting. The proposed addendum would adopt a 12

SEER rating for the three-phase commercial air-conditioning products and become

effective in 2006 so as to be in effect in the building standard at the same time it becomes

effective for similar single-phase residential products. In January of 2003 during

ASHRAE ' s annual winter meeting, ASHRAE' s technical committee voted on ARI' s

proposed addendum. The outcome of the voting was to accept the addendum to increase

the energy efficiency of small three-phase air-conditioning units to match the 12 SEER

efficiency adopted by DOE for single-phase residential air-conditioning units.

Addendum ito Standard 90.1-2001 was approved by the ASHRAE Standards Committee

on June 28, 2003, by the ASHRAE Board of Directors on July 3, 2003, and by the

American National Standards Institute (ANSI) on August 6, 2003.

Opponents of the 12 SEER rule, namely the Natural Resources Defense Council,

challenged the rule in a New York court on procedural grounds. On January 13, 2004,

the US Court of Appeals for the Circuit in New York ruled that DOE, in enacting the

12 SEER standard, "failed to effect a valid amendment of the original standard (13

SEER) effective date, and as a consequence was thereafter prohibited from amending

these standards downward." ART withdrew its separate appeal of DOE's prior 13 SEER

standard on January 17, 2004. On August 17, 2004, DOE published a technical

amendment in the Federal Register to officially adopt the 13 SEER standard.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
4.1 ENERGY SAVINGS

In the screening analysis, DOE estimated the national energy savings for various

energy efficiency levels compared to the 10 SEER efficiency level in EPCA. It estimated

savings for 11, 12, 13, and the max-tech 15 SEER. Since Standard 90.1-1999 analysis

did not address three-phase air-conditioning units, the efficiency levels for these products

remained at the EPCA 10 SEER level. The result is no energy savings in adopting

Standard 90.1-1999 levels. However, with the Addendum ito Standard 90.1-1999, which

raises the efficiency levels for three-phase ACs to a 12 SEER level, the national energy

savings are estimated to be 2.174 quadrillion Btu (quads) as shown in Table 11.

Table 11. Potential Energy Savings for Three-Phase ACs

90.1-1999 Level 1 Level 2 Level 3 Level 4 EPCA Relative to Relative to Relative to Relative to Relative to 1992

_____

EPCA EPCA EPCA EPCA EPCA

Category

.E

rID Cl)

3-ph,

Single- 9.7 9.7 0 11.0 0.871 12.0 1.413 13.0 1.871 15.0 2.604 Package

AC

_____ ____ ____ ____ ____ ____

3-ph,

Single- 9.7 9.7 0 11.0 0.113 12.0 0.184 13.0 0.243 15.0 0.338 Package

HP

_____ ____ ____ ___ ____ ____

3-pt',

____

Split- 10.0 10.0 0 11.0 0.279 12.0 0.511 13.0 0.707 15.0 1.021 System

AC

_____ ____ ____ ____ ____ ____

3-pLi,

____

Split- 10.0 10.0 0 11.0 0.036 12.0 0.066 13.0 0.092 15.0 0.133 System

HP

_____ ____

Total - -

____

0.0 -

____

1.299

___

- 2.174 -

____

2.913

____

4.096

Source: Screening Analysis (DOE 2000).2

The screening analysis also estimated that the Max NPV from energy savings

(i.e., the lowest life-cycle cost) in the various efficiency levels analyzed occurs with a

SEER level of 12.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
4.2 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS

EPCA states that DOE must adopt amendments to ASHRAE Standard 90.1 unless

it shows through clear and convincing evidence that a more stringent standard, that is

technologically feasible and economically justified, would produce significant additional

energy savings. EPCA bars DOE from adopting any standard that would increase the

maximum allowable energy use or decrease the minimum required efficiency for a

product. Therefore, DOE can either adopt the addendum to Standard 90.1-1999,

increasing the energy efficiency level for three-phase air-conditioning units from a 10

SEER level established by EPCA to a 12 SEER level, or seek a higher energy efficiency

level. The screening analysis estimated that adopting a 12 SEER efficiency level would

achieve an energy savings of 2.174 quads. In addition, the 12 SEER efficiency level

corresponds with energy savings that are estimated to yield the Max NPV (i.e., lowest

life-cycle cost). On the other hand, if DOE were to seek a higher efficiency level, the

estimated net present value would be lower. For example, if a 13 SEER efficiency level

were adopted, energy savings are estimated to amount to only 0.739 quads relative to a

12 SEER level, and the life-cycle cost is estimated to be greater. The screening analysis

estimated that the 12 SEER efficiency level for three-phase air-conditioning units has the

lowest life-cycle cost.

Currently, the Department has been made aware that during ASHRAE' s winter

meeting of 2005, ASHRAE has completed public review of a proposed addendum to

Standard 90.1 (Addendum f to Standard 90.1-2004) that would incorporate 13 SEER and

7.7 HSPF levels for three-phase ACs and HPs <65,000 Btu/h. Under ASHRAE's

process, if the ASHRAE Standards Committee and ASHRAE Board approve this

addendum during the 2006 ASHRAE winter meeting, it would then go to ANSI for

approval, and its official adoption and publication would likely occur in the spring of

2006.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
CHAPTER 5. SINGLE-PACKAGE VERTICAL AIR CONDIONERS AND HEAT

PUMPS <65,000 BTU/H

5.1 BACKGROUND

SPVUs are a type of air-cooled small or large commercial package airconditioning and heating equipment. They are factory assembled as a single-package

having their major components arranged vertically, and they use single- or three-phase

power. SPVUs are used primarily in schools, manufactured or modular buildings,

telecommunication shelters, and portable buildings, and are subject to different duty

cycles and operating hours than what is typically encountered in residential applications.

SPVUs can be classified into several categories, including wall-mounted vertical package

exterior units, cabinet units, wall-mounted vertical package interior units, large vertical

interior units, and stacked vertical closet units.

The Department considered SPVUs in the November 24, 1999, residential central

air-conditioners and heat pumps NOPR (64 FR 66306, Section W.C.6). In the October 5,

2000, NOPR for Residential CACs (65 FR 59590, Section V.J.l), DOE determined that

SPVUs were commercial products not subject to residential efficiency standards.

Subsequently, DOE included these products as part of their evaluation of commercial

HVAC equipment under the ASHRAE products rulemaking. On July 30, 2002,

ASHRAE adopted Addendum d to Standard 90.1-2001, which contains energy

conservation standards and test procedures for SPVUs.

In a July 25, 2003, letter from DOE to ARI, DOE rejected the standards and test

procedure (ARI 390-2001) in Addendum d and stated reasons for this decision. ART

replied to this letter on November 4, 2003, proposing changes and additions to ART 390

and Addendum d to address the Department's complaints. On March 16, 2004, the

Department responded to ARI's proposed changes and additions, accepting all of the

changes to ARI 390 and some of the changes to Addendum d, and stated other concerns

that must be addressed before DOE would adopt Addendum d. ART addressed the

Department's remaining concerns in a May 12, 2004, letter. On May 24, 2004, ARI

submitted to ASHRAE a "proposed change to ASHRAE standard under continuous

maintenance" that included the changes discussed between ART and DOE. ASHRAE

accepted the continuous-maintenance proposal, and largely incorporated its contents into

proposed Addendum b to Standard 90.1-2004. At this point, ASHRAE has completed its

public review process of Addendum b and is in the final stages of considering whether to

approve the addendum.

In Addendum b, ARI redefined both SPVACs and SPVHPs as encased air-cooled

small or large commercial package air-conditioning and heating equipment.

Additionally, it created SPVU categories corresponding to the equipment categories in

EPCA. As a result of revisions made to ART Standard 390, any standards and test

procedures ASHRAE prescribed for SPVU equipment would apply to equipment covered

by EPCA, and not overlap with EPCA definitions of PTACs and PTHPs.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Even though Addendum b contained recommended efficiency levels for SPVUs

>65,000 Btu/h, EPACT 2005 supercedes ASHRAE Addendum b for these products. The

signing of EPACT 2005 by the President divided SPVIJs into two categories: those

products <65,000 Btu/h and those products >65,000 Btu/h to <760,000 Btu/h. The

Department will continue its evaluation of products <65,000 Btulh, which are the subject

of this notice. However, the SPVUs >65,000 Btu/h to <760,000 Btu/h are covered under

the standards specified by EPACT 2005 and are not included in this TSD.

The energy descriptor used by ARI for SPVUs is EERICOP, which is a significant

change from the SEER/HSPF descriptor used to rate similarly designed residential threephase central air conditioners and heat pumps <65,000 Btu/h. The use of the EERICOP

descriptor may be more appropriate for SPVUs because the intended use is different than

that of residential central air conditioners. SPVUs, as mentioned above, are subject to

different duty cycles and operating hours than what is typically encountered in residential

applications.

5.2 ENERGY SAVINGS

The Department estimates the potential energy savings for going beyond

ASHRAE efficiency levels for SPVU products <65,000 Btu/h to be 0.137 quads of

primary energy. The methodology and data used to make the estimate are described

below.

5.2.1 SPVU Shipments

ARI does not currently track shipments of SPVU products separately from other

small package unitary products. At the request of DOE in 2003, ARI consulted with

manufacturers of SPVU products and provided shipment data to DOE under

confidentiality. Such an agreement was deemed necessary given the small number of

manufacturers of these products. ARI provided actual shipment data for the period from

1995 to 2001, and provided estimates of shipments from 2001 to 2005. For the purpose

of this rulemaking, DOE assumed ART's estimate of product shipments for 2005 to be

adequate for an initial energy savings estimate. The estimated product shipments are

shown in Table 12 below.

Table 12. Product Shipments

Product Category 2005 Shipments*

SPVAC <65,000 Btu/h, single-phase 31,976

SPVHP <65,000 Btu/h, single-phase 13,125

SPVAC < 65,000 Btu/h, three-phase 14,301

SPVHP <65,000 Btu/h, three-phase 6129

Total <65,000 Btu/h 65,531

* ARI Estimate

The Department estimated the growth rate in shipments for SPVU products based

on the data made available by ART to DOE for commercial unitary AC products 65,000

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Btu/h to 240,000 Btu/h for DOE's commercial unitary air conditioners and heat pumps

(CUAC) rulemaking. During the period from 2010 to 2037, the growth rate in the base

case for the CUAC products averaged 2.18 percent. DOE assumed the same average

growth rate for its analysis of SPVUs. DOE calculated savings from adopting efficiency

levels above ASHRAE's separate efficiency levels for both single-phase and three-phase

products.

5.2.2 Equipment Size Analyzed

According to ART data provided to the Department, the most common SPVU size

shipped in the <65,000 Btu/h size category is a nominal 3-ton capacity unit (36,000

Btu/h). Actual SPVU products range from nominal sizes of 3/4 tons (3,000 Btu/h) to 5

tons (60,000 Btu/h) in capacity. This analysis assumed that total shipped capacity can be

reasonably estimated by multiplying the most common size product (3 tons or 36,000

Btu/h) by the total shipments.

5.2.3 Time Frame

According to EPCA, the minimum time frame for DOE to promulgate a rule that

increases the efficiency for small or large package commercial air-conditioning

equipment (including SPVLJ products) above what is in Standard 90.1 is four years.

Hence, the earliest possible date for the Department to develop a minimum efficiency

standard above Standard 90.1-2004 Addendum b levels (assuming publication in 2005)

would be 2009. However, the Clean Air Act Amendments of 1990 require manufacturers

to phase out the use of hydrofluorocarbon (HFC) and hydrochlorofluorocarbon (HCFC)

refrigerants by January 1, 2010. Given manufacturer concerns with adoption of a new

refrigerant, a more practical effective date for the new standards would be 2010. Because

the minimum efficiency levels promulgated under ASHRAE are very close to the

minimum efficiency levels under EPCA for this analysis, DOE calculated only the energy

savings from going beyond ASHRAE level starting in 2010. It used a 28-year timeframe

from 2010 to 2037 as the basis for the energy savings analysis.

5.2.4 Product Life

The Department estimated the product lifetime for SPVUs to be 15 years based on

ASHRAE's estimate of the lifetime for CUAC products.

5.2.5 Efficiency Levels Analyzed

The base case efficiency levels for this analysis are assumed to be those in

Standard 90.1-2004 Addendum b. These levels are 9.0 EER for SPVACs and SPVHPs

<65,000 Btu/h, and 3.0 COP for SPVHP products <65,000 Btu.

The Department's estimate of maximum potential energy savings for SPVU

products <65,000 Btu/h is based on the assumption that all products could be designed to

reach the maximum efficiency levels currently available on the market. Product data

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
provided by ARI suggest that maximum efficiency levels are currently at 10.9 EER for

SPVHP products and 10.7 EER for SPVAC products <65,000 Btu/h. Given that there

seems to be no evidence that SPVAC products could not be designed to be as efficient as

SPVHP products, the maximum efficiency used in this analysis is 10.9 EER.

The Department did not analyze energy savings potential for heating. However,

the highest heating efficiency currently on the market for SPVHP products <65,000 Btu/h

is 3.4 COP. This level, however, corresponded to products with cooling efficiencies of

10.5 EER. The SPVHP products with cooling efficiencies of 10.9 EER have heating

efficiencies of 3.1 COP.

5.2.6 Unit Energy Savings

The Department developed an estimate of unit energy savings for SPVU products

based on an analysis of energy consumption for commercial unitary air conditioner

products used in education building applications. The energy and end-use load

characterization analysis for the Commercial Unitary Air Conditioners developed energy

consumption estimates for a sample of 1033 commercial buildings where 99 of those

buildings were education buildings. Because of high occupancy density, the cooling load

on an education building is largely a function of the heat gains from lights, occupants,

and ventilation air. Because similar levels of each would be expected in a portable

classroom-type application, DOE felt that the cooling energy consumption estimates from

this building set would be reasonably reflective of cooling load estimates for portable

classrooms. In addition, scheduled hours of use are expected to be similar.

Two primary sources of energy consumption exist in a package air conditioner;

the compressor/condenser energy consumption (including condenser fan) that operates to

provide cooling (or in the case of the heat pump, reverse cycle heating), and the supplyair blower. Because, in a commercial application, the supply blower generally runs

continually during occupied hours to provide for ventilation in the building, its energy

consumption during the course of the year can be large relative to the

compressor/condenser energy consumption.

The relative operating hours of fan and condenser in an SPVU product are

expected to be similar to that of a commercial unitary air conditioner used in the same

application. However, on a horsepower-per-ton-cooling-capacity basis, the fan in an

SPVU is small relative to the fan in a larger single-package rooftop air conditioner.

While the fan in the rooftop unit can be expected to provide for up to two inches or more

external static pressure, the maximum external static pressures listed for SPVU used in

mobile classrooms is typically no more that 0.5 inches. A supply fan for a 7.5-ton

rooftop air conditioner would use a 1- to 3-horsepower (hp) motor depending on product

design. A common product would use a 2-hp motor for low-to-moderate external static

pressures, with an option for a larger motor for higher external static pressure

applications. By contrast, a typical size supply fan motor on a standard efficiency 3-ton

SPVU is an one-third horsepower blower motor directly connected to two small blowers.

The Department estimated the fan power consumption for a baseline SPVU product

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
assuming an one-third horsepower blower and a 65 percent motor efficiency. This

corresponds to a power draw of 0.379 kilowatts (kW).

The fan power consumption estimate for an education building used in the CUAC

rulemaking for a baseline 8.9 EER 7.5-ton air conditioner with a gas heating section was

2.41 kW at an external static pressure of 1.25 inches. This corresponds to 0.32 12

kW/ton, or a 0.964 kW fan power consumption for a 3-ton product. Because this is well

over the expected power draw from an SPVU motor, DOE multiplied the expected supply

fan energy consumption from the CUAC analysis by the ratio of the expected SPVU

blower power draw (0.3 79 kW) to the supply fan power draw used in the CUAC analysis

(0.964 kW). This ratio is calculated to be 0.393.

After accounting for the change in fan energy consumption, DOE estimated the

resulting total energy consumption for SPVUs used in mobile classroom education

buildings in terms of annual kWhlton at each EER level analyzed in the Commercial

Unitary AC analysis (Table 18). Because the estimate of shipments corresponds to the

tonnage assuming a baseline (no new standard) scenario, the tonnage used to calculate the

kWh/ton ratio is the original tonnage estimate for all education buildings based on an

assumed baseline 9.0 EER product. In addition, DOE estimated energy consumption for

intermediate levels of 9.0 and 10.9 EER through interpolation of energy consumption

between actual levels simulated.

Table 13. Annual Energy Consumption Estimates for SPVU, Cooling + Fan

EER

________

Annual Energy Consumption for

Education Buildings, CUAC

Analysis (KWh/ton/yr)

Annual Energy Consumption for

Education Buildings, SPVU

Analysis (KWh/ton/yr)

8.5 2270 1537

8.9 2186 1470

9.0 2166 1454

9.5 2074 1379

10.0 1991 1313

10.1 1975 1301

10.5 1916 1254

10.8 1874 1222

10.9 1861 1211

11.0 1848 1201

11.5 1786 1152

11.8 1752 1126

12.0 1730 1109

5.2.7 Calculation of Energy Consumption by Standard Level

The Department based the calculation of national energy consumption for a

standard level on the annual energy consumption for all the products shipped in that year

for each year being studied. This is simply a multiplication of total shipments, assumed

average system size (tons), and the appropriate annual energy consumption (in kWhlton)

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
for that standard level. For this analysis, DOE calculated only cooling and supply fan

energy consumption.

To estimate accumulated energy savings over the life of the study period, DOE

calculated the total energy use for all the products shipped since the beginning of the

study period (and still in operation). Products that have exceeded their expected service

life of 15 years for any year of the study are removed from service during that year, and

thus have no energy consumption associated with them.

The resulting cooling and fan energy consumption estimates for all SPVAC and

SPVHP for the study period from 2010 to 2037 are shown in Table 14 in terms of total

kWh electric consumption and total primary energy consumption (quads).

Table 14. National Energy Consumption Estimate (Cooling and Supply Fan), 2010

to 2037

9.0 EER 10.9 EER

Product Category

__________________________

Electric

(gWh)

Primary

(Quads)

Electric

(gWh)

Primary

(Quads)

SPVAC <65,000 Btu/h, 1 phase 64,625 0.488 54,219 0.4 10

SPVHP <65,000 Btu/h, 1 phase 26,526 0.200 22,255 0.168

SPVAC <65,000 Btu/h, 3 phase 28,903 0.218 24,249 0.183

SPVHP <65,000 Btu/h, 3 phase 12,387 0.094 10,392 0.079

Total SPVU <65,000 Btu/h 132,441 1.001 111,116 0.840

Savings 21,325 0.161

National energy savings in going from 9.0 EER to a 10.9 EER product are

estimated to be 0.161 quads for cooling and fan energy consumption. At this time, DOE

has not made a separate detailed calculation for the potential energy savings for

improving the heating COP for SPVHP products.

The Department expects the additional potential energy savings for heat pumps

would be unlikely to increase the energy savings estimate shown above by more than 20

percent, due to the relatively small market volume for SPVHP equipment (31 percent of

total shipments of SPVUs) and smaller potential improvement in heating COP compared

with cooling EER.

5.3 ISSUES IMPACTING POTENTIAL ENERGY CONSERVATION

STANDARDS

5.3.1 SPVU Test Procedures and Standards

In 2002, ASHRAE published Addendum d to Standard 90.1-2001. The intent of

Addendum d was to establish SPVACs and SPVHPs or, collectively, SPVUs, as a new

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
product class of air-conditioning and heating equipment as well as to establish test

procedures and standards for these products. Under EPCA, the publication of the

addendum triggered a review at the DOE to determine if the amended Standard 90.1

could be adopted as a Federal standard. DOE's examination of Addendum d revealed

some deficiencies and other concerns with the test procedures (ART Standard 390-2001)

as well as with the minimum efficiency standards, which were inconsistent with current

Federal regulations.

In May of 2004, ART submitted a continuous-maintenance proposal to ASHRAE,

which corrected the deficiencies and addressed most of the remaining concerns identified

by DOE. This proposal was presented in the June 2004 ASHRAE annual meeting and

was cleared for public review. Tn November of 2004, ASHRAE announced a 45-day

public review period regarding the SPVU modifications contained in the ART proposal,

and a new addendum was issued (Addendum b to Standard 90.1-2004). Addendum b

included the following changes:

1. Test procedure references which apply to SPVACs and SPVHPs were changed

from ART 2 10/240 and ART 340/360 to ARI Standard 390-2003.

2. Definitions of SPVAC and SPVHP were added to Standard 90.1-2004.

3. Modifications to the efficiencies for SPVAC and SPVHP products were made as

follows:

a) SPVAC <65,000 Btu/h - EER was changed from 8.6 to 9.0

b) SPVHP <65,000 Btu/h - EER was changed from 8.6 to 9.0

c) COP was changed from 2.7 to 3.0.

4. The table was reformatted to reflect a different organization structure in Standard

90. 1-2004.

5.3.1.1 Statutory Criteria for Amended Test Procedures

According to EPCA, if an industry test procedure is amended, DOE must amend

the DOE test procedure to be consistent with the industry test procedure or determine by

rule that doing so does not meet the statutory criteria for Federal test procedures. (42

U.S.C. 6314 (a)(4)(b))

The statutory criteria for Federal test procedures require that a test procedure be

reasonably designed to produce test results which reflect energy efficiency, energy use,

and estimated operating costs of a type of industrial equipment (or class thereof) during a

representative average use cycle (as determined by the Secretary), and shall not be unduly

burdensome to conduct. (42 U.S.C. 6314 (a)(2)) In other words, the Department may not

adopt changes in an industry test procedure prescribed by ASHRAE Standard 90.1 if the

amended industry test procedure does not provide results that are accurate and repeatable,

and is unduly burdensome to conduct.

Therefore, the Department must determine whether the new test procedures in

ART 390-2003 for SPVUs meet the statutory requirements that they be reasonably

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
designed to assess the products and produce accurate results, and not be unduly

burdensome to conduct.

5.3.1.2 Evaluation

Under EPCA, the heating efficiency metric for commercial 3-phase heat pumps

<65,000 Btu/h is the HSPF. For commercial single-phase heat pumps <65,000 Btu/h,

EPCA does not prescribe a standard, and therefore does not have a heating efficiency

metric defined. For all heat pumps ?65,000 and <135,000 Btu/h, EPCA uses COP as the

heating efficiency metric.

Under Addendum b, the proposed heating efficiency metric for SPVHPs is COP.

Therefore, under the proposed changes in Addendum b, the heating efficiency metric is

being changed for three-phase SPVHPs <65,000 Btu/h.

The HSPF test procedure does not measure the "backup" electric resistance heat

needed under all conditions. Instead it calculates the electric resistance heat that would

be needed because:

(1) the heat pump capacity at those temperature cannot meet the estimated

building load through the reverse-cycle heating (based on steady-state operation

of the heat pump for outdoor air above 45 F or below 17 F);

(2) the heat pump capacity at those temperature cannot meet the estimated

building load through the reverse cycle heating (through use of the defrost cycle

operation of the heat pump); or

(3) the heat pump reverse cycle heating has been deliberately controlled to be off

based on a certain temperature switch (typically a low temperature controller).

In the case of(1), the amount of electric resistance heat is a function of the

heating capacity of the reverse-cycle unit. If the heating capacity of the unit as a function

of temperature is the same under COP or HSPF standard, the choice of either standard

won't affect the amount of backup resistance for this purpose. This may be the primary

source of electric resistance backup in these products.

In the case of (2) however, there is an issue regarding the defrost controller. The

defrost controller takes heat from the building to defrost the compressor, while at the

same time running the backup electric resistance elements to provide heat to the building.

Different strategies for defrost mechanisms and defrost control may result in varying

amounts of overall reverse-cycle heating capacity during periods with outdoor air

between 17 and 47 F, and thus different amounts of backup heat.

In the case of (3), there is a potential issue because a manufacturer could decide to

use electric resistance heat in place of the compression heat by deliberately forcing the

compressor off. Typically this might be done to prevent damage to the compressor at

some low temperature if, for instance, it was so cold outside as to prevent evaporation of

the refrigerant. However, in this instance there would not be any capacity either and 1)

10/05/05

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
above would apply. The HSPF test procedure takes this into account in calculating the

amount of backup heat. It is likely that, in most normal designs, there would be little

differential impact on system electric heat from this reason in the case of HSPF or COP

standards.

Electric heat may also be provided through a fourth option (provided for in the

DOE test procedure) which is the simultaneous use of reverse-cycle heating and electric

resistance heat, even when the reverse cycle heating can meet the load. This can be done

to raise the temperature of the heating air supply for comfort reasons. ASHRAE has

referred to this within 90.1-2001, and allows it as long as the equipment meets the HSPF

as required since the HSPF test procedure would include this use of resistance heat in the

HSPF rating. However, it is not clear where in the ARI 390 test procedure this would be

accounted for. The amount of electric resistance heat used for this may not be adequately

accounted for in a high-temperature COP test alone and presents a potential loophole.

The proposed COP metric alone cannot guarantee maintenance of the efficiency

provided by the HSPF rating, since it does not account for the electric resistance backup

that might occur in (2) or (3), or that might be accounted for in (4).

5.3.1.3 Statutory Criteria for Amended Standards

According to EPCA, the Department is required to further investigate any

standards that could represent a lowering of the existing efficiency levels. Moreover, the

Department decided to further investigate whether the amended standards represented a

lowering of the EPCA standards when the existing metric of HPSF was changed in

Addendum b to COP to measure the heating efficiency of the unit. EPCA specifically

states that any amended standard be rejected if it represents a lowering of the standard in

accordance with 42USC63 13 (a)(6)(B)(ii).

According to EPCA, certain provisions are established for amended test

procedures and energy conservation standards for consumer products. There are no

equivalent requirements for commercial equipment, such as SPVUs. However, there is

nothing preventing the methodology provided in EPCA from being applied to

commercial equipment. The provisions set forth for consumer products state that, if an

industry test procedure is amended such that the test procedure alters the measured

efficiency, DOE must amend the DOE standard according to requirements set forth in

EPCA. (42USC6293 (e)(2))

Therefore, to ensure that the Department is in full compliance with EPCA, the

Department examined the relationship between HSPF and heating COP analytically to

determine whether the proposed standard levels in Addendum b represent a reduction of

efficiency levels.

5.3.1.4 Evaluation

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
In order for the Department to determine whether the ARI standard levels

proposed in Addendum b were reductions to the existing EPCA standard levels, DOE

conducted a comparative analytical study between each of the efficiency metrics. Table

15 shows the efficiency standard levels in EPCA, Standard 90.1-1999, and the proposed

Addendum b.

Table 15. Existing and ProDosed Efficiency Standard Levels

____________

Capacity

(kBtu/h) EPCA

______________

Addendum d to

90.1-2001

Addendum b to

90.1-2004

SPVAC Single-Phase None None 9.0 EER

(Cooling) Three-Phase 9.7 SEER 8.9 EER 9.0 EER

SPVHP Single-Phase None None 9.0 EER

(Cooling) Three-Phase 9.7 SEER 8.9 EER 9.0 EER

SPVHP Single-Phase None None 3.0 COP

(Heating) Three-Phase 6.6 HSPF 2.7 COP 3.0 COP

5.3.1.5 Analysis of SP VAC Efficiencies - Cooling

Figure 5 shows a summary of the ARI market data for SPVAC cooling

efficiencies with the bars representing the total number of product models identified with

a given SEER and the vertical lines representing the range and numeric average of EERs

for those products.

25

U,20

4-.

C.)

2

0

0

4-.

C

0

0

I •

i :11 _____

11.0

10.5

10.0

0) 9.5 ,

C

9.0

8.5 W

w

8.0

7.5

7.0

9.7 10.0 10.1 10.2 10.5 10.6 11.0 11.1 12.0 12.5

SEER

OCountofftoducts - Max of FER -Mn of EER - Average of EER

Figure 5: SPVAC <65,000 Btu/h Market Data by EER Level

Of the 54 models ARI identified, only 2 were exactly at the current minimum

standard level of 9.7 SEER. These models are probably anomalous because both of these

models, with an EER of 8.5 in the ARI data, are from the same manufacturer and are of

the SPVU type that is designed as a through-the-wall PTAC replacement. One of these

models may actually be a heat pump, while the other is a true air conditioner. In both

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
cases, the manufacturer's product literature reviewed actually rated these products as an

8.7 EER, not an 8.5 EER.

Considering the rest of the market data, there were also 16 products with SEER of

10.0. These products have corresponding EERs ranging from 8.9 to 9.7, with an average

of 9.21. Using a differential approach, the difference between the market minimum 10

SEER and the EPCA minimum 9.7 SEER is 0.3 points. Applying the 0.3 point

differential to the 9.21 EER average gives an 8.91 EER.

Using a ratio approach (the ratio of the 9.7 SEER EPCA minimum to the 10.0

SEER market baseline), the efficiency would be established at 97 percent of the market

baseline in terms of SEER. By applying the 97 percent ratio to the average market

baseline in terms of EER (9.21 EER), 97 percent of that value would give an EER of

8.93. The use of a ratio is shown here because it becomes important in the translation

between heat pump heating COPs below.

5.3.1.6 Analysis of SF VHP Efficiencies - Cooling

The ARI market data for SPVHPs is shown graphically in Figure 6.

40

30

(.)

25

0

20

15

0

0 10

0

35

. .

-

5

10.0 10.1 10.2 10.5 10.6 10.7 11.0 11.5 12.0

SEER

B Count of Foducts -Max of EER-Miri of EER , Average of EEF

Figure 6: SPVHP <65,000 Btulh Market Data by EER level

11.0

10.5

10.0

9.5

9.0 I

w

0..)

8.0

7.5

7.0

Figure 6 indicates that there were no products at the current DOE minimum of 9.7

SEER. However, there were 14 models identified at a 10 SEER level. The range of

EERs for those products was from 8.6 to 9.7 with an average of 9.13. When applying the

differential approach (a 0.3 differential between the market minimum of 10 SEER and the

EPCA minimum of 9.7 SEER), subtracting a 0.3 point differential from the 9.13 EER

average gives 8.83 EER.

5.3.1.7 Analysis of SF VHF Efficiencies - Heating

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
The ARI market data for SPVHP <65,000 Btu/h products are shown graphically

in Figure 7.

... .........

30

25

U)

U

20

.

2

15

0

0

- - - .- -..

6.6 6.7 6.8 6.9 7.0 7.4 7.5 7.8

HSPF

COP.Average of COP

Figure 7: SPVHP <65,000 Btu/h Market Data by HSPF Level

4.0

3.8

3.6

3.4

3.2

0

3.0 0

0

2.8

2.6

2.4

2.2

2.0

Of the 63 products identified by ART, there are 26 models at the minimum HSPF

of 6.6 as established by EPCA. The minimum COP for those products was 2.7. The

average COP was 2.86 for that group, with a range from 2.7 COP to 3.0 COP. For

products with an HSPF of 6.6, the distribution of COP is shown in Table 21 below.

Table 16. Distribution of COP for SPVHP Products with 6.6 HSPF

COP Count of Products

2.7 5

2.8 6

2.9 10

3.0 5

Extending the range of low HSPF products considered to cover products with

HSPF values between 6.6 and 6.8, inclusive, adds only 6 more products (total 32), and

the average HSPF goes to 6.63, and the average COP goes to 2.87. Because the majority

of the market in this range is at the EPCA minimum value, it may not be appropriate to

use a larger range of HSPF values. However, even if the Department did so, because of

the scale of the values of HSPF compared with COP, it would be inappropriate to simply

use an average differential between the HSPF and COP metrics in calculating what would

be an appropriate market COP minimum. Using a ratio between the two metrics is

however appropriate. The ratio of the market average COP for this product range to the

market average HSPF is 0.4335. Applying this ratio to an HSPF of 6.6 gives a

corresponding COP of 2.861.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
REFERENCES

1. Air-Conditioning, Heating & Refrigeration News (ACH&R). June 10, 2002. PTA Cs

Are Not Just for Hotels and Motels.

2. Air-Conditioning and Refrigeration Institute (ARI). 2002a. April2002 ARIPTAC

Directory.

Air-Conditioning and Refrigeration Institute (ARI). 2002b. April 2002 API PTHP

Directory.

4. Air-Conditioning and Refrigeration Institute (ARI). 2003 a. January 2003 ARIPTAC

Directory.

5. Air-Conditioning and Refrigeration Institute (ARI). 2003b. January 2003 ARJPTHP

Directory.

6. Air-Conditioning and Refrigeration Institute (ARI). 2003c. ARI Database for Unitary

Products.

7. American National Standards Institute (ANSI). 1991. ANSI Z21.13-1991, Z21.13a1993, Gas-Fired Low Pressure Steam and Hot Water Boilers.

8. American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.

(ASHRAE). 1989. ASHRAE Standard 90.1-1989, Energy Efficient Design of

New Buildings Except Low-Rise Residential Buildings. Atlanta, Georgia.

9. American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.

(ASHRAE). 1996. 1996 ASHRAE Handbook - HVAC Systems and Equipment.

Atlanta, Georgia.

10. American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.

(ASHRAE). 1999. ASHRAE Standard 90.1-1999, Energy Efficient Design of

New Buildings Except Low-Rise Residential Buildings. Atlanta, Georgia.

11. American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.

(ASHRAE). 2001. ASHRAE Standard 90.1-2001, Energy Efficient Design of

New Buildings Except Low-Rise Residential Buildings. Atlanta, Georgia.

12. Buderus Hydronic Systems, Inc. (n.d.). G515 Series. Retrieved September 3, 2003,

from http ://www.buderus .net/products/detail.asp?id=9

13. Carrier Corporation. (n.d.). LodgingAC System Drawing. Retrieved September 3,

2003, from

http ://www.lodgingac.carrier.comldetails/ 1 ,,CLI 1DW 1 9ETI 1 054,00.html

10/05/05

37

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
14. Center for Energy and Environment (CEE). 1999. A Practical Guide to Commercial

Air-Conditioning Rebates for Municipal Utilities.

15. Cleaver Brooks. (n.d.). Efficiency Facts. Retrieved September 4, 2003, from

http://www.cleaver-brooks.comlEfficiencyl .html

16. Energy Policy Act of 1992 (EPACT). Public Law 102-486, 106 Stat 2776.

17. Energy Policy and Conservation Act (EPCA). 42 U.S.C. 62901, et seq.

18. Federal Energy Management Program (FEMP). 2000. How to Buy an EnergyEfficient Commercial Boiler.

19. Hydronics Institute (HI) Division of Gas Appliance Manufacturer Association

(GAMA). 1989. Testing and Rating Standard for Heating Boilers. June Edition.

Berkeley Heights, New Jersey.

20. Hydronics Institute (HI) Division of Gas Appliance Manufacturer Association

(GAMA). 2000. Method to Determine Efficiency of Commercial Space Heating

Boilers (BTS 2000). Berkeley Heights, New Jersey.

21. Institute of Boilers and Radiation Manufacturers (I=B=R). 2002. I=B=R Ratings for

Boilers, Baseboard Radiation and Finned Tube (Commercial) Radiation.

Berkeley Heights, New Jersey.

22. Institute of Boilers and Radiation Manufacturers (I=B=R). 2003. I=B=R Ratings for

Boilers, Baseboard Radiation and Finned Tube (Commercial) Radiation.

Berkeley Heights, New Jersey.

23. Klenck, T. (n.d.). How It Works: Water Heater. Retrieved September 2, 2003 from

http ://popularmechanics .com/home_improvement/how_it_works/i 997/9/water_he

aters/index2.phtml

24. U.S. Census Bureau. 2000. Current Industrial Reports Refrigeration and Heating

Equipment.

25. U.S. Department of Energy (DOE). 2000. Screening Analysis for EPA CT-Covered

Commercial HVA C and Water-Heating Equipment.

26. US. Department of Energy (DOE). 2002. The FY2003 Priority-Setting Summary

Report and Actions Proposed.

27. Ware, M. J. 2000, August. Establishing an Energy Efficiency Recommendation for

Commercial Boilers. Paper presented at the 2000 ACEEE Summer Study on

Energy Efficiency in Buildings - Efficiency and Sustainability, Asilomar, CA.

10/05/05

38

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
28. York. (n.d.). Split System Air Conditioners - Stellar® 2000 Series High Efficiency

(HDB). Retrieved September 3, 2001, from

http ://www.yorkupg.com/ProDetails.asp?id=3

39

10/05/05

EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
APPENDICES

..........................................

..............................

..............................................................................................

............................................................................

................................................................................................

.........................................

.........................

............................................

..............................................................................................

...........................................................................

............................................................................

.........................

.........................

Appendix A. PTAC and PTHP Energy Savings Analyses 41

Appendix A-i Revised Cooling Mode Energy Savings Analysis 41

A-1.1 Background 41

A-1.2 Equipment Efficiencies 41

A-1.3 Shipments 41

A-1.4 New Versus Replacement Equipment Market 44

A-1.5 Energy Savings Potential for Larger Sleeve Size PTACs and PTHPs .... 45

A-i .6 Energy Savings Potential for Small Sleeve Size PTHPs 46

Appendix A-2 Heating Mode Energy Savings Analysis 48

A-2.l Background 48

A-2.2 Heating Load Estimates 48

A-2.3 Equipment Efficiencies 49

A-2.4 Energy Savings Potential for Large Sleeve Size PTHPs 50

A-2.5 Energy Savings Potential for Small Sleeve Size PTHPs 52

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Appendix A. PTAC and PTHP Energy Savings Analyses

Appendix A-i Revised Cooling Mode Energy Savings Analysis

A-1.i Background

The purpose of this work is to evaluate the energy savings potential for PTAC and

PTHP products. A method of evaluating commercial heat pumps was designed for use in

performing the screening analysis. The current analysis assesses the energy savings

potential for these products based on an updated version of the screening analysis

methodology. This analysis is based on the assumption that product efficiency levels that

meet the current maximum efficiencies on the market represent the highest efficiency

levels that DOE could possibly require.

A-1.2 Equipment Efficiencies

Market maximum efficiency levels used in the analysis were determined using the

April 2002 directory of PTACs and PTHPs.2'3 Table A - 1 shows the highest efficiency

products listed in the ART directory. Product selections were made based on existing

products that can provide the efficiency levels indicated for the sizes analyzed, which are

predominantly industry standard size (42" x 16") products.

Table A - i: Market Maximum Efficiency Levels for PTACs and PTHPs

Capacity Si A l dEER

Range

(Btu/h)

ze na yze

(Btu/h)

______________

PTAC

______________

PTHP

______________

<7,000 6,000 11.8 12.1

7,000-10,000 8,500 12.0 11.5

10,000-13,000 11,500 11.0 11.0

>13,000 14,000 9.6 10.0

Sources: April 2002 ART PTAC Directory (ART 2002a).2

April 2002 ART PTHP Directory (ART 2002b).3

A-1.3 Shipments

A-i.3.i Shipments by Year

Historical data for PTAC and PTHP shipments are available from the Current

Industrial Reports published by the U.S. Census Bureau (Census) (Census 2000) and are

summarized for 1996 to 2000 in Table A - 2 below. However, analysis of the shipment

data from later years suggests some inconsistency between ART estimated shipments and

shipments provided by the Census Bureau. For example, the Current Industrial Report's

shipments for the year 2000 are less than 50% of the reported shipments from ART.

Estimated ART shipments for 2000 are 430,000 units and for 2001, 387,000 units.' In

addition, the Census estimated shipments for 1999 (347,338 units reported) are below the

468,000 unit estimate that ART provided to DOE in 1999 for the Screening Analysis.

Also, in 1994, ARI provided shipment estimates for 1993 equal to 127,000 PTAC units

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
and 99,000 PTHP units. These estimates were reported for units greater than 7,000 Btu/h

in capacity only. The Census estimates for 1993 were 79,433 PTAC units and 57,225

PTHP units. It appears that the Census shipment estimates consistently do not reflect the

ARI's estimate of product shipments. The reason for that has not been ascertained.

Average ARI shipment estimates for 1999-2001 have been used as the base shipments for

this study. An average 1% per year growth rate is assumed.

Based on the historical ratio of PTHP to PTAC products, in both Census and AR!

estimates it is believed that approximately 55% of products are PTACs and 45% are

PTHPs.

Table A -2: Reported Shipments of PTACs and PTHPs

Year

_______________________________

PTAC

(units)

PTHP

(units)

Total

(units)

2001 AR! 212,850 174,150 387,000

2000 ART (estimated) 236,500 193,500 430,000

2000 AR! 252,000 216,000 468,000

2000 (Census) 105,360 96,349 201,709

1999 (Census) 191,564 155,774 347,338

1998 (Census) 185,745 156,132 341,877

1997 (Census) 168,084 130,736 298,820

1996 (Census) 151,089 112,549 263,638

Average (1999-2001), ARI Estimate 233,783 194,550 428,333

Sources: Current Industrial Reports - Refrigeration and Heating Equipment (Census 2000).

A-1.3.2 Shipments by Capacity

Shipments by capacity are based on estimates provided by ART for the DOE

Screening Analysis. The breakdown by size category is shown in Table A - 3.

Table A -3: Shipments for PTACs and PTHPs by Capacity

Capacity Range Shipments (%)

(Btu/h) PTAC PTHP

<7,000 7.1 7.4

7,000-10,000 36.9 41.2

10,000-13,000 38.5 34.3

>13,000 17.5 17.1

Source: Screening Analysis (DOE 2000).

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
A-1.3.3 Shipments by Physical Dimension

There is a market for PTAC and PTHP products based on sleeve sizes that are no

longer considered industry standards. The current industry standard size is 42"x16". For

products designed for sleeves smaller that 42"x16", a separate set of lower EER and COP

curves was developed by ASHRAE. This was done to provide attainable efficiency

levels for these smaller products, since it would generally not be considered costeffective to resize the building opening to accept larger sleeve size products. According

to K. Amrane from ARI, only two ARI manufacturers currently make these non-standard

products - EMllRetroAire and McQuay (personal communication, June 14, 2002).

However there are a number of smaller manufacturers (e.g., Islandaire) who have

specialized in this market. Because of antitrust concerns, ART did not gather and provide

separate estimated shipments for these smaller sleeve size products since they would

cover only two manufacturers. However, the Center for Energy and Environment (CEE)

estimates PTAC shipments of major manufacturers (CEE 1999). Table A - 4 summarizes

this information. Estimates are based on Minneapolis product representative surveys and

may differ from national rankings.

Table A -4: PTAC and PTHP Regional Market Ranks by Equipment Type

Brand PTAC - PTHP

Amana Large Large

Zoneline Large Large

Carrier Large Small

Friedrich Medium Large

McQuay Small Large

Trane Medium Medium

Climatemaster* * Unknown Unknown

Source: A Practical Guide to Commercial A/C Rebates for Municipal Utilities (GEE 1999).

Note: Within each size category (i.e. Large, Medium, and Small), manufactures are listed alphabetically.

* Suppliers were categorized as "large," "medium," or "small" based on representatives estimates of

regional market shares (normalized to 100%) as follows: large supplier typically has at least 15% of

regional market share, medium 6-14%, and small 5% or less.

** The survey with the ClimateMaster representative could not be completed. ClimateMaster's market

share is believed to be very small based on the reports of other PTAC/PTHP representatives.

Estimates for the product shipments which would fall in the lower "non-industry

standard" size classes are highly speculative. However, given the market share of

McQuay at roughly 15% for PTHP products and 5% or less for PTAC products and

assuming that sales by EMllRetroaire, Islandaire and other non-standard equipment

manufacturers are very small, one can estimate the size of the non-standard market at

approximately 10-15% of the total market. It is recognized that this is a very rough

estimate. For the purposes of this analysis, DOE assumes that 15% of the total packaged

terminal product shipments are in the non-industry standard size market and 85% are in

the industry standard size 42"x 16" market.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
A-1.3.4 Total Estimated Shipments

Based on the information presented above, estimated shipments that are used in

the revised cooling mode energy savings analysis are presented in Table A - S below by

equipment type, capacity range, and physical dimensions.

Table A - 5: Estimated PTAC and PTHP Shipments

Capacity Range

B /h

Estimated Shipments ^42"x16" Estimated Shipments

<42"x16" ( tu )

__________

PTAC PTHP PTAC PTHP

7,000 14,109 12,237 2,490 2,160

7,000-10,000 73,326 68,131 12,940 12,023

10,000-13,000 76,506 56,721 13,501 10,010

>13,000 34,775 28,278 6,137 4,990

Iota! Shipments 198,716 165,368 35,068 29,183

A-1.3.5 Shipments by Building Application

The estimated maximum savings potential for PTAC and PTHP products is based

on an update to the DOE Screening Analysis for these commercial products. The

updated methodology modified the estimates for building shares using PTAC/PTHP

equipment to reflect use of packaged AC equipment and heat pumps in lodging facilities.

This is in response to comments on the 2000 "Screening Analysis for EPACT-Covered

Commercial HVAC and Water-Heating Equipment" that loads more representative of the

PTAC/PTHP application be used. The impact of modifying the shipment estimates for

this work is to modify the full-load equivalent operating hours (FLEOH) to reflect those

for lodging facilities. It is noted that packaged terminal products are used primarily in

motel/hotel applications, but there is a significant fraction are found in healthcare and

assisted living facilities. Estimates of usage by three major manufacturers are shown

below.

Table A -6: Shipments by Building Category

____________ Application

Manufacturer

_____________________

Hotel/Motel

____________

Assisted

Living/Healthcare Office/Residential/Misc.

_______________________

AMANA/GOODMAN 50% 35% 15%

Carrier 65% 25% 10%

Trane 95% <5% <5%

Source: "PTACS Are Not Just For Hotels and Motels", ACH&R News, June 10, 2OO2.

A-1.4 New Versus Replacement Equipment Market

The tools developed for the analysis provide for estimates of shipments to new

and to replacement markets. The non-standard size products which are allowed lower

efficiency levels by ASHRAE Standard 90.1-1999 must be explicitly labeled for use only

as replacement products in existing buildings and therefore 100% of the shipments are

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
assumed to go to replacement applications. For 42"x16" products, it is estimated that

approximately 80% of the market will be for replacement applications and 20% for new

building applications within a given year.

A-L5 Energy Savings Potential for Larger Sleeve Size PTACs and PTHPs

Table A - 7 shows energy and carbon savings estimates developed for packaged

terminal products for new standards. The savings estimates are relative to the current

standard (EPCA 1992) levels and are cumulative savings through 2030. It is assumed

that currently, it would not be possible for DOE to complete the rulemaking process for

establishing a higher efficiency standard prior to 2004, which would result in a final

standard in 2008 (scenario 4). It is assumed that simple adoption of the ASHRAE

standard at this time (2003) would allow for a manufacturing standard at those levels to

be in place by 2005 (scenario 2).

The analysis suggests that for these 42"x 16" products, the maximum energy

savings potential in proceeding to a final rule with a standard at a level higher than

Standard 90.1-1999 versus adoption of Standard 90.1-1999 levels in 2005 is

approximately 0.05 quads through 2030. Again it is assumed that these industry standard

products cover approximately 85% of the existing market. The adoption date strongly

influences the energy savings potential. If a final rule could be established at market

maximum efficiency levels by 2005, the energy savings potential would be

approximately 0.135 quads.

Table A - 7: Cooling Energy Savings Scenarios Analyzed for 42"x16" PTACs and

PTHPs

Carbon

Electricity Savings Reduction

Adoption Scenario Effective EPCA 92 Baseline EPCA 92

Date (Quads Primary) Baseline

(Million

_______________________________ ___________ Metric Tons)

1) Adopt 90.1-1999 Efficiency

______________________

Level for small sleeve size January 0.068 1 06

products 2005 .

2) Adopt 90.1-1999 Efficiency

___________

January

_____________________ _______________

Level for 42 x 16 products 2005

0.450

___________________

7.06

3) Adopt 90.1-1999 Efficiency January

_____________

Level for 42 x 16 products 2008

0.382

___________________

6.00

4) Develop Standard at Market January 0.498

_____________

7 81

Max Efficiency Level 2008

____________________

.

5) Develop Standard at Market January 0.586

______________

9 19

Max Efficiency Level 2005

____________________

.

Scenario (4) -Scenario (2) - 0.048

______________

0.075

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Table A - 8: Summary of Potential Energy Savings for Large (New Construction)

PTACs and PTHPs - Cooling Mode

Potential Energy Savings (guads)

Category Standard 90.1-1999 Relative Market Maximum

to EPCA Relative to Standard

________________________ __________________________ 90.1-1999

PTAC & PTHP - Cooling

Mode * **

New Construction (Large

0.450 0.048

PTHPs) _______________________ ____________________

* Assumes having an effective date for the adopted ASHRAE standard in 2005 with energy savings

calculated to 2030.

** Values represent adopting the market maximum efficiency level in 2008 relative to adopting the

Standard 90.1-1999 New Construction efficiency levels in 2005.

A-1.6 Energy Savings Potential for Small Sleeve Size PTHPs

The Department estimates the market for smaller-sleeve size heat pump products

at a maximum of 15% of the entire PTAC/PTHP market, with a distribution among

cooling capacities similar to the 42"x16" sleeve products. For the default baseline

cooling mode energy savings analysis, DOE assumes that the replacement efficiency

levels for small-sleeve size products are adopted in 2005. Savings from adoption of the

Standard 90.1-1999 efficiency levels for small sleeve replacement PTAC/PTHP are

calculated as

Cooling Mode Energy Savings for Small Sleeve Size PTACTPs = [__0.15__lx 0.068 quads

[(1-0.15)]

= 0.0 12 quads

Maximum potential energy savings were estimated by assuming a "Market Max"

efficiency level equivalent to the 90.1-1999 efficiency level for 42x16 products over a

baseline of EPCA levels based on the estimated savings in Scenario 3 of Table A - 11 but

applied to the 15% of the market represented by the smaller sleeve size products.

Accordingly, the energy savings over EPCA are estimated to be:

Maximum Potential Cooling Energy Savings for Small Sleeve Size PTAC1Ps = [__0A5__1 0.382 quads

[(1-0.15)]

= 0.067 quads

The cooling mode energy savings potential for pursuing a standard higher than

90.1-1999 level through rulemaking for these smaller sleeve size PTHPs is estimated at

0.055 quads (0.067-0.12).

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Table A - 9: Summary of Potential Energy Savings for Small (Replacement) PTHPs

-Cooling Mode --

Potential Energy Savings (guads)

Category Standard 90.1-1999 Relative Market Maximum

Relative to Standard to EPCA

_______________________ ___________________________ 90.1-1999

PTAC & PTHP - Cooling

Mode 0.012* 0.055**

Replacement

(Small PTHPs) ___________________________ _______________________

* Assumes having an effective date for the adopted ASHRAE standard in 2005 with energy savings

calculated to 2030.

** Values represent adopting the market maximum efficiency level in 2008 relative to adopting the

Standard 90.1-1999 Replacement efficiency level in 2005.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Appendix A-2 Heating Mode Energy Savings Analysis

A-2.1 Background

The heating mode energy savings analysis develops the heating load estimates by

using both heating and cooling data developed for the Screening Analysis.

A-2.2 Heating Load Estimates

The heating mode energy savings analysis uses the "No Economizer No Setback"

(NENS) loads simulated as the basis for the PTAC/HP analysis work. The analysis

divides the peak heating loads and peak cooling loads from the 7 buildings types

simulated in the Screening Analysis by the floor space of the simulated buildings in order

to establish peak heating and cooling load densities (in Btu/h-sf). In addition, the

analysis divides the annual heating loads and annual cooling loads by the floor space for

each building type in order to establish annual heating and cooling load densities (Btu/yrSf). While these steps were undertaken for all buildings, only the lodging building type is

used in the following steps of the heating mode energy savings analysis.

The heating mode energy savings analysis simulates each building type used in

the Screening Analysis in 11 different climate locations. The analysis divides the annual

heating load density from the lodging building simulation in each climate location by the

peak cooling load density. This results in a ratio of annual heating load to cooling peak

capacity that has the units of hours/yr, similar to the FLEOH used in the Screening

Analysis. The concept of annual heating to cooling peak load ratio allows the estimation

of the heating load faced by a space served by a given capacity PTHP equipment

(assumed sized to meet the cooling load).

Using the mapping between climates and sub-census divisions described in the

Screening Analysis TSD the heating mode energy savings analysis obtains a value for the

annual heating load (Btu/yr) per unit of cooling capacity (Btu/h) for each sub-census

division. The analysis then calculates a national average value for the annual heating to

cooling peak load ratio based on the estimated shipment weightings for PTAC and PTHP

products used for the revised cooling mode energy savings analysis. These weightings

were based on estimates of the current stock and predicted growth of lodging facilities in

11 different sub-census divisions. While the distribution for PTHP products may be

different than that for PTAC in general, DOE found no information source available that

could be used to develop PTHP only shipments. For this analysis, DOE assumes the

same shipment distribution for both.

The heating mode energy savings analysis uses the national average heating load

per cooling capacity in place of the FLEOH in all of the energy consumption roll up tabs

of the heating mode energy savings analysis spreadsheet (see Appendix A).

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
A-2.3 Equipment Efficiencies

The heating mode energy savings analysis casts the heating efficiencies in terms

of annual average heating efficiency for products on the market. For simplicity, DOE has

assumed that the heating load profiles faced by equipment used in lodging applications

largely mirror the heating load profiles for residences and that the HSPF metric used to

characterize the performance of residential heat pumps is a reasonable tool for estimating

the annual heating performance of a PTHP. Further, DOE assumes that the relationship

between HSPF and C0P47o F for a residential heat pump is similar to that for a PTHP

product. The analysis uses these two assumptions in the estimation of the national

heating energy savings for PTHP products.

The Department established the relationship between HSPF and C0P47o F for a

residential heat pump through review of the ARI January 2003 Certification Directory. A

regression analysis established the following relationship for small (<65,000 Btu/h

cooling capacity) unitary equipment.

HSPF =l.5843COP+2.4909 (1)

12

10

Ua- (I,

'a

a,

=

A plot showing this relationship is shown in Figure A - 1, below.

2 2.5 3 3.5 4 4.5

Heating COP - High Temperature 47 F

Figure A - 1: HSPF versus COP47o F for Unitary Heat Pumps <65,000 Btu/h

Source: ARI Database for Unitary Products, January 2003, Split System: HP with Remote Outdoor Unit &

Single-Package HP- Air-Source (ARI 2003c).6

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
Table A - 10 shows the COP47 F for the four different cooling capacity PTHP

products analyzed in the heating mode energy savings analysis. The COP values for the

EPCA efficiency level products are established by EPCA. The COP values for the

Standard 90.1-1999 standard are established in that standard. The heating mode energy

savings analysis bases the "maximum" COP values used in establishing the possible

savings potential on the highest reported COPs in the ARI January 2003 directory for

PTHP products in the identified capacity ranges. The product with the highest COP does

not necessarily correspond to the product with the highest EER, but it does consistently

represent either the maximum or very near the maximum EER available.

Table A - 10 also shows the corresponding HSPF values obtained from applying

Equation 1. The heating mode energy savings analysis uses these resulting HSPF

efficiencies as the basis for estimating the annual average heating performance for the

different PTHP capacities.

Table A - 10: COP and HSPF Estimates for PTHP Products

C i

_____ COP47 F _____ HSPF Estimate

apac ty

Range 90.1-1999 Highest in 90.1-1999 Highest in

(Btu/h) EPCA 42"x16" ARI EPCA 42"x16" ARI

__________ _______

Products Directory _______

Products Directory

<7,000 2.72 3.04 3.50 6.80 7.31 8.04

7-10,000 2.67 2.98 3.50 6.72 7.21 8.04

10-13,000 2.59 2.90 3.30 6.60 7.09 7.72

>13,000 2.54 2.84 3.10 6.52 6.98 7.40

Sources: EPCA and ART for PTHPs.

A-2.4 Energy Savings Potential for Large Sleeve Size PTHPs

The heating mode energy savings analysis estimates the heating energy savings

from adoption of the different heating efficiency levels in a fashion similar to the revised

cooling mode energy savings analysis for the cooling mode. The national average ratio

of annual heating load to cooling capacity replaces the cooling FLEOH. The estimated

HSPF replaces the EER. For each equipment size (cooling capacity), the per unit heating

energy consumption is estimated using the following equation:

Annual Unit Ener' Consumption - National Average Ratio of Annual Heating Load to Cooling Capacity 2ooling Capacity (2)

HSPF

To maintain the basic structure of the cooling aggregation analysis spreadsheet,

which covers both PTAC and PTHP equipment, the analysis assumes an HSPF of 3.413

Btu/W-h (corresponding to electric resistance heating) for all PTAC products. Since this

electric resistance heating efficiency does not change between efficiency scenarios, it

results in no heating energy savings for PTAC products.

The heating mode energy savings analysis multiplies the unit energy consumption

by the estimated annual shipments for each capacity range for each year analyzed out to

2030. This is used to determine energy consumption for units shipped in each year.

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
The heating mode energy savings analysis calculates the total energy consumed

for shipped products by summing the annual energy savings for each shipped product

over the life of that product (assumed to be 15 years in this analysis). The Department

received comments in response to the Screening Analysis that the in-service life of PTAC

products was likely shorter than this value. However, for the purpose of this estimate of

heating savings, the analysis assumes the same 15-year life used in the Screening

Analysis and the revised cooling mode energy savings analysis.

The heating mode energy savings analysis calculates the source energy

consumption based on the national average estimate for source energy conversion factors

for electricity established by the EIA (AEO 2000) and used for the PTAC and PTHP

cooling mode analysis. The analysis also uses the same electricity cost assumptions as

those used for the PTAC and PTHP cooling mode analysis.

The Department examined four different scenarios for adopting a final rule. The

heating energy savings for each scenario is shown in Table A - 11 and discussed below.

Table A - 11: Heating Energy Savings Scenarios Analyzed for 42"x16" PTHPs

Cumulative Energy Cumulative Primary

Adoption Scenario Effective Cost Savings by Energy Savings by

Date 2030 2030

(S millions 1999) (guads) ________________________

1) Adopt 90.1-1999

___________

January Efficiency Level for small 2005 0 0.000

sleeve size products _____________________ ______________________

2) Adopt 90.1-1999

___________

January Efficiency Level 2005 247 0.037

for 42 x 16 products

__________________ ___________________

3) Adopt 90.1-1999

__________

January Efficiency Level 2008 211 0.032

for42x 16 products

_________________ __________________

4) Develop Std. at Market

_________

January 451 0.068

Max Efficiency Level 2008

___________________ ____________________

5) Develop Standard at January Market Max Efficiency 2005 528 0.081

Level

__________________ ___________________

Scenario (4) -Scenario

__________

-

204 0.031 (2)

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
o Adoption of 90.1-1999 efficiency levels for small sleeve replacement products with a

DOE effective date as a Federal standard by January 2005 results in a total estimated

savings for the heating mode of PTHPs over current EPCA-efficiency products of 0-

.0 quads of primary energy since the small sleeve size COPs do not differ from the

EPCA requirements.

o Adoption of 90.1-1999 efficiency levels for 42"x16" products with a DOE effective

date as a Federal standard by January 2005 results in a total estimated savings for the

heating mode of PTHPs over current EPCA-efficiency products of 0.03 7 quads of

primary energy by 2030.

• Adoption of 90.1-1999 efficiency levels for 42"x16" products with a DOE effective

date as a Federal standard by January 2008 results in a total estimated savings for the

heating mode of PTHPs over current EPCA-efficiency products of 0.032 quads of

primary energy by 2030.

• Developing a Federal standard for Market Maximum efficiency levels for 42"x16"

products with a DOE effective date as a Federal standard by January 2008 results in a

total estimated savings for the heating mode of PTHPs over current EPCA-efficiency

products of 0.068 quads of primary energy by 2030.

Developing a standard for Market Maximum efficiency levels for 42"x16" products

with a DOE effective date as a Federal standard by January 2008 results in a total

estimated savings for the heating mode of PTHPs over current EPCA-efficiency

products of 0.081 quads of primary energy by 2030.

• Estimated savings in achieving market maximum efficiency levels in 2008 over

adopting 90.1-1999 in 2005 is 0.03 1 quads.

Table A - 12: Summary of Potential Energy Savings for Large (New Construction)

PTACs -}Ieatini Mode

Potential Energy Savings (guads)

Market Maximum

Category Standard 90.1-1999 Relative to Standard 90.1-

Relative to EPCA

______________________

1999

PTHP - Heating Mode

New Construction 0.037* 0.03

(Large PTHPs)

_____________________

* Assumes having an effective date for the adopted ASHRAE standard in 2005 with energy savings

calculated to 2030.

** Values represent adopting the market maximum efficiency level in 2008 relative to adopting the

Standard 90.1-1999 New Construction efficiency levels in 2005.

A-2.5 Energy Savings Potential for Small Sleeve Size PTHPs

The Department estimates the market for smaller sleeve size heat pump products

at a maximum of 15% of the entire PTHP market, with a distribution among cooling

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EE-RM-STD-03-100 EE-RM-STD-03-200 EE-RM-STD-03-300 COMMENT 22.1
capacities similar to the 42"x16" sleeve products. For the heating mode energy savings

analysis, DOE assumes that the heating efficiency for this fraction of the market could

meet the Standard 90.1-1999 efficiency levels for 42" x 16" products by 2008. The

baseline heating COPs for these smaller sleeve size PTHP products in Standard 90.1-

2001 are the same as the current EPCA requirements. Since there is no change in

efficiency levels, this analysis assumes that there are zero heating energy savings from

adoption of the ASHRAE heating efficiencies for these products.

Energy savings for Market Max efficiency levels over EPCA levels are estimated

based on the estimated savings in Scenario 3 of Table A - 11 (adoption of Standard 90.1-

1999 efficiency levels for 42"x16" sleeve size products by 2008 over the current EPCA

efficiency levels) for the 15% of the market represented by the smaller sleeve size

products.

Accordingly, the energy savings for small sleeve size PTHPs are estimated to be:

Heating Mode Energy Savings =[(1 10032 quads = 0.006 quads (3)

Therefore, the heating mode energy savings potential for smaller sleeve size PTHPs is

estimated to be 0.006 quads.

Table A - 13: Summary of Potential Energy Savings for Small (Replacement)

PTHPs - Heating Mode

Potential Energy Savings (guads)

Category Standard 90.1-1999 Market Maximum

Relative to EPCA Relative to Standard 90.1-

PTHP - Heating Mode

Replacement 0 0.006*

(Small PTHP5)

* Values represent adopting the market maximum efficiency level in 2008 relative to adopting the

Standard 90.1-1999 Replacement efficiency level in 2005.

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