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. Barhydt, Assistant General Counsel 

U.S. Department of Energy U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy Office of Enforcement 

Building Technologies Program, EE-2J Office 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 Meeting 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. Armstrong and Ms. Barhydt: 

On behalf of Daikin AC (Americas), Inc. (Daikin), I would 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 the meeting. We appreciate your observations and 

comments regarding Daikin’s contemplated Alternate Rating Method (ARM) application that we are 

planning to file with DOE for our residential central air conditioner and heat pump split systems. 

During our discussion, you told us that Ashley Armstrong 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 meeting. 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 the 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 current ARM regulation allows DOE to approve an ARM 

based on a methodology where product performance may be determined by calculating product 

performance variation based on measuring core elemental components, and by then supporting these 

calculations with the required complete system testing. Since DOE is now in the process of revising the 

ARM rule, Daikin encourages DOE to either: (1) make clear in the rule text or in the preamble that the 

current ARM rule at 10 C.F.R. §429.70 allows the 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 the ARM regulation does not allow it. 

Thanks again for meeting with us and for considering 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)