Daikin AC (Americas), Inc

. 1645 Wallace Drive, Suite 110 Carrollton, TX 75006 USA TEL: 866-4DAIKIN

FAX: 972-245-1038

www.daikinac.com

Ashley Armstrong Laura L. Ba rhydt, Assistant General Counsel U.S. Department of Energy U.S. Department of Energy Office of Energy Efficiency and Renew able Energy Office of Enforcement Building Technologies Program, EE-2J Offi ce of the General Counsel, Room 6B-222 1000 Independence Avenue, S.W. 1000 Independence Avenue, S.W. Washington, DC 20585 Washington, DC 20585

By Email ( Ashley.Armstrong@ee.doe.gov ; Laura.Barhydt@hq.doe.gov ; AED/ARM-2011-TP0024@ee.doc.gov )

September 1, 2011

RE: Follow-up Information from August 31, 2011 Meet ing to Discuss Data Collection and Certification Requirements under 10 C.F.R. Part 429, Subpart B; Comments Relating to Improvement of Alternate Rating Methods under 10 C.F.R. §429.70 -- Docket No. EERE-2011-BT-TP-0024

Dear Ms. Armstr ong and Ms. Barhydt:

On behalf of Daikin AC (Americas), Inc. (Daikin), I w ould like thank you very much for taking time to meet with us in your office on August 31, 2011 and also for inviting David Case and Michael Raymond from the Department of Energy (DOE) to participate in t he meeting. We appreciate your observations and comments regarding Daikin’s contemplated Alternat e Rating Method (ARM) application that we are planning to file with DOE for our residential c entral air conditioner and heat pump split systems.

During our discussion, you told us that Ashley Arms trong would promptly provide us with guidance on the scope of Daikin’s products that could be covered by a single ARM based on the methodology that Mr. Suzuki from Daikin explained to you during our meeti ng. We are interested in obtaining DOE approval of an ARM that covers the broadest possible range of Daikin’s residential products that are certified under AHRI Standard 210/240. You can survey the range of these products by reviewing Daikin’s current product certifications to DOE. Please let me know your view on this question as soon as possible.

Also, during our meeting we discussed the DOE’s current open rulemaking on the ARM regulation, in which DOE has solicited comments. Even though t he formal comment period has closed on this rulemaking, Ms. Barhydt told us that DOE would consider any additional comments it receives before publishing a proposed or final rule that DOE intends to do in the next few months. As we explained in our August 31 meeting, Daikin believes that the curr ent ARM regulation allows DOE to approve an ARM based on a methodology where product performanc e may be determined by calculating product performance variation based on measuring core el emental components, and by then supporting these calculations with the required complete system testi ng. Since DOE is now in the process of revising the ARM rule, Daikin encourages DOE to either: (1) make cl ear in the rule text or in the preamble that the current ARM rule at 10 C.F.R. §429.70 allows t he use of the core elemental component process described by Daikin in our August 31 meeting and in its previous July 5, 2011 letter to DOE (copy attached for rulemaking docket); or (2) modify the ARM regulation specifically to authorize the use of this type of methodology if DOE concludes that the current version of t he ARM regulation does not allow it.

Thanks again for meeting with us and for consider ing our comment on the open rulemaking on the ARM regulation. I look forward to hearing back from you soon with the answer to our ARM scope question.

Please contact me at 202-669-2002 or mstanga@verizon.net if you need more information from Daikin.

Sincerely,

Mark V. Stanga For Daikin AC (Americas), Inc.

Encl. (Attachment #1 (Confidential) Daikin Method to Determine Performance Values – July 5 2011)