1 | Energy Efficiency and Renewable Energy 

Public Meeting:

Portable Air Conditioners

Test Procedures and

Energy Conservation StandardsMarch 18, 2015

Bryan BerringerDepartment of Ene

Building TechnologiEERE‐2014‐BT‐TP‐0

PortableAC2014TP0

Ronald B. Majette

Department of Ene

Building Technologi

EERE‐2013‐BT‐STD‐

PortableAC2013STD
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete tra

meeting.

– Be concise – share the ‘air‐time’.

– Keep the focus here – cell phones on silent; limit sidebar co

– Webinar participants turn phone on mute; “raise your hand

recognized to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

AgendaTest Procedures:9:00 AM Introductions for Test Procedures

9:15 AM Stakeholder Opening Statements

9:30 AM Regulatory History9:45 AM Covered Products

10:00 AM Test Procedure Proposals

11:00 AM Break11:30 AM Compliance

12:00 PM Closing Remarks for Test Procedures

12:00 – 1:00PM Lunch Break

Standards:

1:00PM Introductions for Standards

1:30PM Market and Technology Assessment and Screening
4

Agenda (con’t)Standards (con’t):1:45 PM Engineering Analysis

2:15 PM Preliminary Manufacturer Impact Analysis

2:30 PM Markups and Energy Use Analysis

2:45 PM Life‐Cycle Cost and Payback Period Analysis

3:00 PM Shipments and National Impact Analysis

3:15 PM Overview of NOPR Analyses and Next Steps

3:30 PM Closing Comments from Participants3:45 PM Closing Remarks for Standards
5

Public Meeting Topics for Test Procedures

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Covered Products5 Appendix CC Proposals6 Compliance

7 Closing Remarks
6

Listening Via the Webcast• The Department is broadcasting this meeting live ov

Internet.

• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
7

Purpose of the Public Meeting• Present DOE’s issues pertaining to test procedures a

conservation standards for Portable Air Conditioners 

• Invite comment on the notice of proposed rulemakin

document for test procedures and preliminary analy

standards.

• Discuss next steps in the rulemakings.

• Invite participants to provide summary comments or

statements and raise additional issues for discussion
8

Steps in the Test Procedure Rulemaking• NOPR issued by DOE on February 12, 2015• NOPR published in the Federal Register on February 

(80 FR 10211)

• NOPR Public Meeting today, March 18, 2015

• Comments on NOPR from interested parties

• Transcript records oral comments from today’s public m

• Written comments (comment period closes May 11, 201

• DOE reviews and considers all comments• Final Rule Publication

• The Final Rule is expected to be issued by December 31, 

DOE determine to classify portable ACs as a covered pro

Final

Rule NOPR
9

Public Meeting Topics for Test Procedures

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Covered Products5 Appendix CC Proposals6 Compliance

7 Closing Remarks
10

Opening Remarks

Meeting participants are invited to provide opening remark

statements at this time.
11

Issues for DiscussionIssue “boxes” correspond to the list of issues for which 

Department seeks comments.

Issue Box: DOE welcomes comments, data, and information concerning portable ACs. Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis.
12

Public Meeting Topics for Test Procedures

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Covered Products5 Appendix CC Proposals6 Compliance

7 Closing Remarks
13

Regulatory History: Portable AC Test Procedures• There are currently no portable AC test procedures or energy c

standards.

• DOE issued a notice of proposed determination (NOPD) of cove

5, 2013. (78 FR 40403)

• DOE tentatively determined that portable ACs meet the Energy 

Conservation Act (EPCA) covered products criteria:

– Necessary for purposes of EPCA

– Average U.S. household energy use likely exceeds 100kWh.

• DOE published a notice of data availability (NODA) on May 9, 2

evaluated industry test procedures and other modified approa

26639)

• Concurrent to this test procedure rulemaking, DOE conducted 

analysis to consider establishing energy conservation standard

ACs (to be discussed in this afternoon’s meeting).

In this NOPR, DOE proposes to establish portable AC procedures in a new Appendix CC.
14

Public Meeting Topics for Test Procedures

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Covered Products5 Appendix CC Proposals6 Compliance

7 Closing Remarks
15

Portable AC Definition• DOE proposes to define a portable air conditioner as

An encased assembly, other than a “packaged terminal air condition

conditioner”, or “dehumidifier”, designed as a portable unit for deliv

conditioned air to an enclosed space, that is powered by a single pha

current, which may rest on the floor or other elevated surface. It inc

of refrigeration, and may include means for air circulation and heatin

• DOE also proposes to clarify product configurations:

Single‐Duct – a portable air conditioner that draws all of the conden

from the conditioned space without the means of a duct, and discha

condenser outlet air outside the conditioned space through a single 

Dual‐Duct – a portable air conditioner that draws some or all of the 

air from outside the conditioned space through a duct, and may draw 

condenser inlet air from the conditioned space. The condenser outle

discharged outside the conditioned space by means of a separate du

Spot Cooler – a portable air conditioner that draws condenser inlet a

discharges condenser outlet air to the conditioned space, and draws 

inlet air from and discharges evaporator outlet air to a localized zone 

conditioned space.
16

Portable AC Configurations – Ctd.• Although spot coolers would meet the proposed def

portable AC, DOE is not considering a test procedure coolers at this time.

1 Capacity is reported by the manufacturer and based on current industry test methods.2 Based on vendor sizing charts.

Portable AC Configuration Single‐ and Dual‐Duct Spot C

(no conde

Cooling Capacity Range1 5,000 to 14,000 Btu/h >14,00

Weight >50 pounds >100 

Intended Application Rooms <525 feet2 Large Spa

Applic

Primary Construction

Material Plastic M

Condensate Collection Auto‐Evaporation Internal Col

Market Share ~98.5% ~1
17

Issue for Discussion

Product Type Definitions

DOE seeks comment on the proposed definitions for portabl

their specific configurations.

DOE seeks comment on the proposal that spot coolers wou

tested under the proposed test procedure.
18

Public Meeting Topics for Test Procedures

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Covered Products5 Appendix CC Proposals6 Compliance

7 Closing Remarks
19

Portable AC Modes Identified

Off‐Cycle Mode

Cooling

Heating

Air Circulation

Dehumidification

Inactive

Bucket‐Full

Off

Active Mode Standby and Off Mode
20

Active Mode – Proposed Definitions

Active Mode –

• Portable AC is connected to a mains power source

• Has been activated• Is performing the main functions of: cooling or heating the condi

space, circulating air through activation of its fan or blower witho

activation of the refrigeration system, or defrosting the refrigeran

Cooling Mode –• Has activated the main cooling function

according to the thermostat or

temperature sensor signal

• Has activated the refrigeration system, or

has activated the fan or blower without

activation of the refrigeration system.

Heating Mode –• Has activated the main heatin

according to the thermostat o

temperature sensor signal, inc

activating a resistance heater, 

refrigeration system with a rerefrigerant flow valve, or the f

without activation of the resis

or refrigeration system.
21

Other Active Modes

Additional active modes identified but not separately measured 

proposal:

Air Circulation

Mode

• Consumer initiated• Main cooling or heating function disabled

• Fan or blower operating either cyclically or continuous

air in the conditioned space

• Not included because DOE lacks information on the co

of this feature

Dry orDehumidificationMode

• Operation automatically adjusted to maximize latent ra

sensible heat removal (e.g. reduced evaporator blower 

• Duct setup modified and drain setup required.

• Not included because:

• Not a primary mode of operation (i.e. low impact 

energy consumption)

• No users in a recent metering study reported usin

dehumidification mode

• Would disproportionately increase test burden
22

Active Mode Definitions

DOE seeks comment on the proposed active mode defini

specifically, the proposed definitions for cooling and heatin

Issue for Discussion
23

Cooling Mode• Three industry test procedures currently measure portable AC 

in cooling mode:

– AHAM PAC‐1‐2014, “Portable Air Conditioners”

– CSA C370‐2013, “Cooling Performance of Portable Air Conditione– ANSI/ASHRAE Standard 128‐2011, “Method of Rating Unitary Spo

Conditioners”

• These test procedures measure cooling capacity and energy eff

(EER) based on an air enthalpy approach by monitoring:

– Airflow rate

– Dry‐bulb temperature

– Water vapor content

• DOE found no significant differences that would produce varyin

among the three test procedures.
24

Cooling Mode – General Test Approach• DOE conducted baseline testing (AHAM PAC‐1‐2009*) and calo

testing (ANSI/ASHRAE Standard 16‐1983).

• Results of baseline testing generally indicated that current indu

procedures for portable ACs neglect significant heat transfer du

infiltration and other heat losses. (May 2014 NODA)

* Current version of AHAM PAC‐1 at the time of DOE’s baseline testing.

Evaporator Exhaust (Temp/Water Vapor)

Condenser Inlet an(Temp/Water Vapor

Evaporator Exhaust (CFM)

Evaporator Inlet (Temp/Water Vapor)

AHAM PAC‐1‐2009 Test Setup
25

Cooling Mode – Test Results• Test results based on 17 single‐duct and 7 dual‐duct 
26

Cooling Mode – General Test Approach• Based on DOE’s testing, DOE preliminarily determined that:

– ANSI/ASHRAE Standard 16 requirements are burdensome and con

difficult to maintain.

• Requires a calorimeter chamber

• May require additional components to maintain conditions (e.g. fans

dehumidifiers, scales)

• Complex analysis required to incorporate heating/cooling effects of a

– AHAM PAC‐1 approach is least burdensome, but requires modific

representative of typical use.

– DOE did not identify differences between AHAM PAC‐1‐2009 and 

version, AHAM PAC‐1‐2014, that would substantively affect testin
27

Cooling Mode General Test Approach

DOE seeks comment on the proposed reference of AHAM P

as the basis for DOE’s portable AC test procedure

Issue for Discussion• DOE proposes that AHAM PAC‐1‐2014 should be the basis of a D

procedure for portable ACs.

– The test method and setup for AHAM PAC‐1‐2014 is less burdenso

calorimeter method.

– DOE is proposing that AHAM PAC‐1‐2014 be the basis for the test

additional measurements and calculations to account for the infil

and duct heat transfer effects.
28

Cooling Mode – Infiltration Air• Portable AC operation creates negative pressure cau

infiltration to the conditioned space.

• DOE assumed infiltration air originates from uncond

outdoor space.

SingleെDuct:	ܯܨܥ௡௢௖ௗ௘௡௦௘௥	௘௫௛௔௨௦௧

DualെDuct:	ܯܨܥ௡௢௖ௗ௘௡௦௘௥	௘௫௛௔௨௦௧ െ ܯܨܥ௡௢௖ௗ௘௡௦௘௥	௜௡௟௘

Portable

AC

Indoors Outdoors

Single-Duct

Portable

AC

Indoors 

Dua

80.6°F/66.2°F 95°F/75.2°F 80.6°F/66.2°F 
29

Cooling Mode – Infiltration Air Equations• Dry Air Mass Flow Rate (lb/m)• Sensible Heat Contribution (Btu/h)

• Latent Heat Contribution (Btu/h)

• Total Infiltration Air Heat Transfer (Btu/h)

݉

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1൅߱௖௢

െ

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ሶ ൌܸൈߩൈ

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ሶ

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60

ܳ௟ ൌ

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ሶ ൈ ܪ ௚௙ൈ ሺ߱௜௔ െ ߱௘௜ሻ

60

ܳ௜௡௙௜௟௧௥௔௧௜௢௡ ൌ ܳ௦ ൅ ܳ௟
30

Infiltration Air Test Approach

DOE also seeks comment on the proposal to modify the cooliequation as included in AHAM PAC-1-2014 to address the effeinfiltration air.DOE seeks comment on the proposed approach to estimate iflow rate and heat transfer. Specifically, on the proposal to use bulb and 75.2 °F wet-bulb temperature conditions for the infilt

Issue for Discussion
31

Cooling Mode – Standard Rating Conditions• DOE proposes ambient conditions based on AHAM PAC‐1‐2014

• These conditions are close to those required by the DOE room 

procedure1, so test results for cooling mode under the propose

test procedure would be comparable to those for room ACs.

Test Configuration

Evaporator Inlet Air, °F (°C) Condenser Inlet A

Dry Bulb Wet Bulb Dry Bulb W

3 (Dual‐Duct) 80.6 (27) 66.2 (19) 95.0 (35) 7

5 (Single‐Duct) 80.6 (27) 66.2 (19) 80.6 (27) 6

1Room AC test procedure conditions:

Evaporator Inlet (80 dry‐bulb, 67 wet‐bulb)

Condenser Inlet (95 dry‐bulb, 75 wet‐bulb)
32

Cooling Mode – Inlet Air Tolerance• ANSI/ASHRAE Standard 37 (referenced by AHAM PAC‐1‐2014) r

condenser inlet and evaporator inlet dry‐bulb temperatures ar

within a range of 2.0 °F and an average within 0.5 °F of the nom

• Because for single‐duct units both inlets are drawing from the 

chamber, slight variation between the two inlet conditions is lik

• DOE proposes to specify a more stringent tolerance for the eva

dry‐bulb, consistent with the evaporator inlet wet‐bulb temper

tolerance, within a range of 1.0 °F with an average difference o

• The condenser inlet dry‐bulb temperature would be maintaine

original test tolerance.
33

Inlet Air Conditions and Tolerance

DOE seeks comment on the proposed ambient conditions f

mode based on the conditions in AHAM PAC-1-201

DOE also seeks comment on the proposal to tighten the ev

inlet dry-bulb temperature tolerance to minimize confusion w

test condition (evaporator or condenser inlet) should take 

Issue for Discussion
34

Cooling Mode – Duct Heat Transfer• DOE determined that uninsulated ducts significantly contribute 

to the conditioned space.

• Additional specifications proposed for the duct heat transfer m

in ANSI/ASHRAE Standard 37 (referenced by AHAM PAC‐1‐2014

– Minimum of 4 equally spaced thermocouples (TCs) adhered to th

length of condenser duct(s)

– Temperature measurement accuracy within ±0.5 F

– Convective heat transfer coefficient of 4 Btu/h per square foot pe

• Duct Surface Area (ft2)

• Duct Heat Transfer (Btu/h)

ܣௗ௨௖௧_௝ ൌ 	ߨ ൈ ݀௝ ൈ ܮ௝

ܳௗ௨௖௧_௖௠ ൌ݄ൈܣௗ௨௖௧_௝ ൈ ܶௗ௨௖௧_௝ െ ܶ௘௜
35

Cooling Mode – Case Heat Transfer• DOE determined that heating effects from all internal compone

the evaporator fan (as required in AHAM PAC‐1‐2014), should b

• Provisions proposed for determining case heat transfer:

– Minimum of 4 equally spaced TCs adhered to each side of the cas

TC would be placed on an air intake/exhaust grille

– Temperature measurement accuracy within ±0.5 F

– Convection heat transfer coefficient of 4 Btu/h per square foot pe

• Case Surface Area (ft2)

• Case Heat Transfer (Btu/h)

ܣ௔௖௦௘_௞ ൌ	ܦଵ_௞ ൈ ܦଶ_௞

ܳ௖௔௦௘_௖௠ ൌ ෍ ݄ൈܣ௔௖௦௘_௞ ൈ ܶ௖௔௦௘_௞ െ ܶ௘௜ ௞
36

Cooling Mode – Adjusted Cooling Capacity• DOE proposed that the cooling capacity determined 

PAC‐1‐2014 be adjusted for infiltration air and duct a

heat transfer effects.

ሻܥܥܣሺ	ݕݐܽܿ݅݌ܽܥ	݈݅݊݃݋݋ܥ	݁݀ݐݏݑ݆݀ܣ

ൌ 	 ܥܽ݌ܽܿ݅ݕݐ ௠௖െ ܳ௜௡௙௜௟௧௥௔௧௜௢௡_௖௠ െ ܳௗ௨௖௧_௖௠ െ ܳ
37

Additional Heat Transfer Considerations

DOE seeks comment on the proposed approach to charact

determine heat transfer from the condenser duct(s) to the co

space. 

DOE seeks comment on the proposed approach to include 

transfer effects instead of evaporator fan heat, based on ave

surface temperature and evaporator inlet temperatu

DOE also seeks comment on the proposal to consider duct 

heat transfer effects, in addition to infiltration air heat transf

adjusted capacity calculation.

Issue for Discussion
38

Cooling Mode – Condensate Collection• DOE conducted testing with a drain line attached to monitor cond

collection if necessary, but the line was elevated to simulate testin

plug.

• DOE observed that all test units had an auto‐evaporation feature a

cycled off during testing due to a full internal condensate collectio

• Therefore, DOE proposes that the portable AC be set up in accorda

manufacturer instructions and as follows:

– If an auto‐evaporative feature is provided, any drain plug provided s

place as shipped.

– If no auto‐evaporation feature is provided, or if the internal bucket f

testing:

1. The test is invalid and stopped;2. The drain plug is removed;3. The condensate drain line is installed; and4. The test is restarted.

– Unit is only tested with an included pump activated if required by the 

installation and setup instructions, or no other condensate removal o

available.
39

Cooling Mode – Control Settings• DOE proposes the following settings:

Fan Speed = Maximum (if user adjustable)

Temperature Controls = Lowest Available

Louver Opening = Maximum Area, Parallel to Air Flow (if user adjusta

Louver Oscillation = Off/Disabled (if user adjustable)

• DOE believes these settings represent the consumer settings to 

primary function of cooling as quickly as possible and to mainta
40

Cooling Mode – Test Unit Placement• ANSI/ASHRAE Standard 37 (referenced by AHAM PAC

specifies space requirements for only the outdoor ch

• DOE proposes that the outdoor chamber space requ

also be applicable for the indoor chamber:

– No less than 6 feet from the evaporator inlet to any chamb

surface (and condenser inlet for single‐duct units)

– No less than 3 feet between the other surfaces of the porta

no air inlet/exhaust and any wall surface.
41

Cooling Mode – Electrical Supply• AHAM PAC‐1‐2014 does not specify a single test volt

states that the nameplate voltage shall be used.

• To maintain repeatability, DOE proposes that:

– The input standard voltage be maintained at 115 V ± 1%

– The electrical supply be maintained at the nameplate listed 

within ± 1%.
42

Additional Cooling Mode Proposals

DOE seeks comment on the proposed setup requirements 

with and without means for auto-evaporation to remove c

condensate, including the use of an internal pump if require

manufacturer during cooling operation.

DOE seeks comment on the proposed control settings that i

speed (maximum), temperature controls (maximum cooling

oscillation (disabled where available), and louver opening (m

DOE also seeks comment on the proposed test unit placem

the chamber wall surfaces, and the electrical supply prop

Issue for Discussion
43

Heating Mode• DOE proposes that the same test setup and general conduct fo

mode be used for heating mode (generally based on ANSI/ASH

37).

• Additional test requirements from cooling mode are also applic

– Infiltration Air

– Duct Heat Transfer

– Case Heat Transfer

– Control Settings

– Test Unit Placement– Electrical Supply
44

Heating Mode – Test Conditions• ANSI/AHRI 210/240 “Performance Rating of Unitary Air‐Condit

Air‐Source Heat Pump Equipment” provides test conditions in 

for a heat pump with a single‐speed compressor and a fixed‐sp

fan.

• DOE believes H1 test conditions are most representative of typ

mode use (supplemental or low capacity)

Test Condition Indoor Inlet Air, °F Outdoor Inlet A

Dry Bulb Wet Bulb Dry Bulb W

H1 “High Temperature” 70 60 47 H2 “Frost Accumulation” 70 60 35 

H3 “Low Temperature” 70 60 17 

TestConfiguration

Evaporator1 Inlet Air, °F (°C) Condenser1 Inlet Air

Dry Bulb Wet Bulb Dry Bulb W

3 (Dual‐Duct) 70.0 (21.1) 60.0 (15.6) 47.0 (8.33) 43

5 (Single‐Duct) 70.0 (21.1) 60.0 (15.6) 70.0 (21.1) 60

1 “Evaporator” and “Condenser” refer to the heat exchanger configuration in cooling mode
45

Heating Mode – Adjusted Heating Capacity• The calculations in AHAM PAC‐1‐2014 would result in 

cooling (i.e. heating) capacity.

• DOE proposes multiplying the measured capacity by

represent heating capacity.

• Negative heating values (e.g. Qduct_hm and Qinfiltration_h

added to the adjusted heating capacity.

ܥܪܣ 	ݕݐܽܿ݅݌ܽܥ	݅݊݃ݐ݁ܽܪ	݁݀ݐݏݑ݆݀ܣ

ൌ 	 ܥܽ݌ܽܿ݅ݕݐ ൅ ௠௛ܳ௟௜௙௡௜௧௥௔௧௜௢௡_௛௠ ൅ ܳௗ௨௖௧_௛௠ ൅ 
46

Heating Mode Proposals

DOE seeks comment on the proposed test setup, standar

conditions, and conduct for determining heating mode perfo

portable ACs.

Issue for Discussion
47

Air Circulation Mode• DOE does not have information on prevalence of the 

initiated air circulation mode.

• Therefore, at this time DOE is not proposing to meas

mode.

Air Circulation Mode Proposal

DOE seeks feedback on usage information for the consume

air circulation mode.
48

Portable AC Modes Identified

Off‐Cycle Mode

Cooling

Heating

Air Circulation

Dehumidification

Inactive

Bucket‐Full

Off

Active Mode Standby and Off Mode
49

Off‐Cycle Mode ‐ Definition• Off‐Cycle Mode

A mode in which the portable air conditioner:

(1) has cycled off its main heating or cooling function by therm

temperature sensor signal;

(2) may or may not operate its fan or blower; and

(3) will reactivate the main cooling or heating function accord

thermostat or temperature sensor signal.
50

Off‐Cycle Mode – Test Conduct and Settings• Test Conduct

– Following cooling mode testing, the setpoint is adjusted to 

temperature higher than the chamber conditions.

– Adjustable fan speeds are set to maximum.

– Off‐cycle mode energy consumption begins 5 minutes follo

of the last compressor cooling cycle.

– Power consumption is monitored for 2 hours.

• Does not penalize the utilization of cold evaporator c

additional room cooling at the end of a compressor c

• Conducted only once following cooling mode to min

burden.
51

Off-Cycle Mode Proposals

DOE seeks comment on the proposed provisions for measur

consumption in off-cycle mode, including the use of the m

speed setting for those units with adjustable fan speed sett

the measurement period specifications. 

DOE seeks comment on whether off-cycle mode energy con

is independent of ambient conditions. 

Issue for Discussion
52

Portable AC Modes Identified

Off‐Cycle Mode

Cooling

Heating

Air Circulation

Dehumidification

Inactive

Bucket‐Full

Off

Active Mode Standby and Off Mode
53

Standby Mode – Definitions

Standby Mode –

• Portable AC is connected to a mains power source

• Offers one or more of the following user‐oriented or protective 

which may persist for an indefinite time:

(a) To facilitate the activation of other modes (including activ

deactivation of active mode) by remote switch (including 

control), internal sensor, or timer; or

(b) Continuous functions, including information or status dis

(including clocks) or sensor‐based functions. A timer is a 

clock function (which may or may not be associated with 

that provides regular scheduled tasks (e.g., switching) an

operates on a continuous basis.

Inactive Mode –• Facilitates the activation of active mode by remote switch (including remote c

internal sensor, or timer, or that provides continuous status display.
54

Other Low‐Power Modes

Additional low‐power modes identified but not measuredBucket‐Full Mode

• Initiated when the condensate level in the internal co

reaches a manufacturer‐specified threshold or remov

• Active modes are disabled and reactivated when the c

is drained, emptied, or installed

Delay‐Start Mode

• Comparable power consumption level to inactive mod

• Facilitates the activation of an active mode by a timer, 

persist for an indefinite period of time.
55

Low‐Power Modes• DOE expects the power draw of these low‐power mo

(inactive, bucket‐full, and delay‐start modes) to be s

• To reduce test burden and simplify testing, DOE prop

measure power consumption for only inactive mode

• The annual hours associated with delay‐start and bu

modes (which DOE expects to be low) would be com

those for inactive mode.
56

Off Mode – Definition• All units in DOE’s test sample had electronic controls 

default to inactive mode when connected to a powe

• However, some units (typically with electromechanic

would be capable of entering off mode.

Off Mode –

• Portable AC is connected to a mains power source

• Is not providing any active mode or standby mode function

• May persist for an indefinite time• An indicator that only shows the user that the portable air condit

the off position is included within the classification of an off mod
57

Standby/Off Mode – Power Consumption• In accordance with the requirements of the Energy

Independence and Security Act of 2007, DOE propos

inactive mode and off mode for portable ACs be testaccording to IEC Standard 623011.

• Clarifications:

– Testing may be conducted at the cooling mode or heating m

conditions (80.6 or 70.0 ± 0.5 °F, respectively) as they meet 

Standard 62301 conditions (73.4 ± 9 °F).

– Electrical supply voltage and frequency maintained at 115 V 

and supply frequency maintained at the rated frequency w

percent, the same as proposed for cooling mode and heati

– Inactive mode and off mode testing conducted after the po

dropped to the lowest level.

1 International Electrotechnical Commission (IEC) “Household electrical appliances–

Measurement of standby power,” Publication 62301, Edition 2.0 (2011-01)
58

Standby Modes and Off Mode Proposals

DOE seeks comment on the proposed definitions and prov

measuring energy consumption in standby mode and off 

Issue for Discussion
59

Combined Energy Efficiency Ratio (CEER)• Combines the energy use for active mode, standby m

cycle mode, and off mode into a single efficiency me

• Cooling and heating capacity (where applicable) are 

• Total annual energy consumption is calculated using 

average based on annual operating hours and averag

each mode.

• It is necessary to identify the cooling and heating sea

lengths to determine annual mode operating hours.
60

Cooling and Heating Season Lengths• Cooling season length based on room AC rule (2,160 

• DOE developed three estimates for heating season le

– Estimate 1 (4,160 hours)

• Furnace fan rulemaking estimate

– Estimate 2 (4,388 hours)

• 2012 national climate analysis of hours ≤ 55 °F

• Based on NYC threshold for building heating season

– Estimate 3 (2,903 hours)

• Adjusted climate analysis to hours ≤45 °F

• Reduced portable AC heating season for use as supplementa

Usage by Location

Identify room AC (portable

AC) ownership in regions,

sub‐regions, and states.

Data: RECS 2009

Hours at TemperatureCalculated number of hours

per state associated with

each temperature

Data: NOAA and NCDC 2012

Analyze D

Weighted average t

individual state’s h

below certain temp

determine sub‐r

regional, and natio
61

Annual Mode Operating Hours• Cooling season mode operating hours based on the 

rulemaking.

– Off‐cycle mode includes fan‐only mode hours from room A

– Inactive/off mode hours include delay‐start mode and buck

hours

• DOE assumed that the percentage of operating time 

with each mode within heating season is the same adetermined for cooling season.

• Outside of cooling and heating season, DOE assumed

– 3⁄4 of all portable ACs are unplugged

– 1⁄4 of all portable ACs are unplugged half of the time

– Plugged in hours are considered inactive/off mode hours
62

Annual Mode Operating Hours• Mode operating hours based on the cooling only roo

estimates and three heating season length estimates

• For units with heating capability, DOE proposes the u

annual operating hours in Cooling/Heating Estimate 

DOE expects that portable ACs are used only as supp

heating during periods of cool outdoor temperatures 

Modes Cooling Only Cooling/Heating Estimate 1 Cooling/Heating Estimate 2 Co

Cooling Mode 750 750 750 

Heating Mode 0 1,444 1,524 

Off‐Cycle Mode 880 2,575 2,668 

Off/Inactive Mode 1,355 1,856 1,883 
63

Alternate Cooling Season Scenarios• A recent study developed a model to estimate perce

in cooling, fan‐only, and standby modes as a function 

outdoor temperature.

• DOE expects that the modes in the study align with c

mode, off‐cycle mode, and inactive/off mode.

• The study identified two applications for portable AC 

– Residential use: daily consumer interaction

– Commercial use: minimal consumer interaction

• DOE determined average outdoor temperature for e

based on the NCDC data from June through Septemb

• Using a weighted average based on RECS data, DOE d

a representative average cooling season outdoor tem

of 70 °F.
64

Alternate Cooling Season Scenarios• Using the metering study models, DOE calculated th

time spent in each mode during cooling season.

• DOE also determined a third scenario, an average of 

use and high‐use applications.

• The proposed off‐cycle and off/inactive mode hours 

be updated to account for adjusted cooling season p

Modes Scenario 1 – Low‐Use Scenario 2 – High‐Use Scenari

Average

Cooling Mode 5.9% 41.1% 23.5

Off‐Cycle Mode 2.2% 21.7% 12.0

Off/Inactive Mode 91.9% 37.9% 64.9

Cooling Mode Hours

Based on 2,160 Hour

Cooling Season

126 887 507
65

Annual Mode Operating Hours

DOE seeks comment on the proposed cooling and heating 

lengths and mode operating hours to be used when calcul

combined energy efficiency ratio.

Issue for Discussion
66

Energy Efficiency Ratio (EER)• Energy Efficiency Ratio for cooling and heating (EERc

EERhm)

– Adjusted cooling and heating capacity, ACC and AHC, in Btu

– Average power in cooling and heating, Pcm and Phm, in Watt

• Due to variations in operating hour estimates, the pr

analysis for a concurrent energy conservation standarulemaking uses the EERcm as a basis for efficiency le

ൌ௖௠ ܴܧܧ

ܥܥܣ

ൌ௛௠ ܴܧܧ ௠௖ܲ

ܥܪܣ

ܲ௛௠
67

Annual Energy Consumption (AEC)• Annual Energy Consumption per mode (AECm)

– Calculated for each mode, m.

– Uses the mode annual hours, t.

– Average power, P, in Watts.

– Converted to kWh, k.

• Total AEC for all modes other than cooling/heating m

(AECT)

• Used to calculate annual operating cost, proposed in 

430.23

௠ ௠ܥܧܣ ෍ ൌ ்ܥܧܣ

ܥܧܣ ௠ൌ ܲ௠ ൈ ݐ ௠ൈ ݇
68

Combined Energy Efficiency Ratio (CEER)• Combined energy efficiency ratio in cooling mode (C

– “Cooling Only” operating hours used to calculate AECT

• Combined energy efficiency ratio (CEER)

– For units with no heating mode, CEER = CEERcm– For units with heating mode, use Cooling/Heating Estimate 

ൌ௖௠ ܴܧܧܥ

ܥܥܣ

்ܥܧܣ	൅ ௠௖ܥܧܣ

ݐൈ݇

ൌ ܴܧܧܥ

൅ ௠௖ݐ 

௛ݐ ൈ ܥܪܣ ൅ ௠௛ݐ ൅ ௠௖ݐ ௠௖ݐ ൈ ܥܥܣ

்ܥܧܣ	൅ ௠௛ܥܧܣ ൅ ௠௖ܥܧܣ

ݐൈ݇

Note: The CEER equation in this presentation differs from that published in the NOPR. The variable for time

spent in each mode is “t” instead of “h”. This modification will be incorporated in future notices.
69

CEER Equations

DOE seeks comment on the proposed equation for calc

individual cooling combined energy efficiency ratio (CEERc

overall CEER that incorporates performance in both cool

heating modes, in addition to other low-power mode

Issue for Discussion
70

Sampling Plan and Rounding Requirements• For EERcm, EERhm, CEERcm, CEER, or other efficiency m

representative value shall be less than or equal to th

– The mean of the sample, or

– The lower 95 percent confidence limit (LCL) of the true me

0.90

• The values of cooling or heating mode capacity, and 

of the EER or CEER would be the mean of the measu

for each tested unit of a basic model.

– Capacities would be rounded to the nearest 50, 100, 200, o

according to Table 1 in PAC‐1‐2014.

– EER and CEER would be rounded to the nearest 0.1 Btu/Wh
71

Small Business Impacts• DOE identified one small business manufacturer with ma

facilities in the United States.

• DOE selected the AHAM PAC‐1‐2014 air enthalpy approac

minimize test burden.

• Active mode test procedure impacts

– Manufacturers commonly report cooling capacity and EER acc

ANSI/ASHRAE Standard 128‐2001

– AHAM PAC‐1‐2014 is an industry‐accepted standard that utiliz

equipment and basic methodology

• Off‐cycle, standby, and off mode test procedure impacts

– IEC Standard 62301 may be conducted in the same test chamb

cooling/heating mode testing, so minimal additional testing co

– Wattmeter that meets requirements is about $2,000

• Therefore, DOE concludes that the proposed rule would n

significant economic impact on small entities.
72

Test Burden and Small Business Impact

DOE seeks comment on the testing burden, including DOE’

conclusion that the proposed test procedure would not be 

burdensome to conduct.

Issue for Discussion
73

Public Meeting Topics for Test Procedures

1 Introductions2 Stakeholder Opening Statements3 Regulatory History4 Covered Products5 Appendix CC Proposals6 Compliance

7 Closing Remarks
74

How to Submit Comments...• Public Meeting – oral comments will be captured in the transcr

become part of the public record.

• Written comments – NOPR comment period open until May 11

Reference docket #: EERE–2014–BT–TP–0014 and/or RIN #: 190

Email: PortableAC2014TP0014@ee.doe.gov

Mail: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program1000 Independence Avenue SW., Mailstop EE‐5B

Washington, DC 20585‐0121

Courier: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program950 L'Enfant Plaza, Suite 600Washington, DC 20024Telephone: (202) 586‐2945
75

Opening Remarks for Standards

Meeting participants are invited to provide open

remarks or statements at this time.
76

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
77

Regulatory History• Energy Policy and Conservation Act of 1975 (EPCA) P.L. 94‐163

– Amended by National Energy Conservation Policy Act of 1978, P.L

establish the “Energy Conservation Program for Certain Industrial 

– Authorizes DOE to establish conservation standards for covered p

equipment that would likely result in significant national energy s

– Specifies a list of covered residential and commercial products an

provisions to classify additional products as covered products:

• Necessary to fulfill the purposes of EPCA

• Average annual per‐household energy use is likely to exceed 100 kW

• Notice of Proposed Determination (NOPD) (78 FR 40403)

– Published July 5, 2013

– DOE tentatively determined that portable ACs meet the classifica

– Note there are currently no Federal test procedures and standard

ACs
78

Definition of Covered Products• The February 25, 2015 test procedure NOPR propos

a portable air conditioner as follows:

A consumer product, other than a “packaged terminal air conditioner,

air conditioner,” or “dehumidifier,” designed as a portable unit for deli

cooled, conditioned air to an enclosed space, that is powered by singl

electric current, which may rest on the floor or other elevated surface

includes a source of refrigeration and may include additional means fo

circulation and heating.
79

Portable AC Standards Rulemaking Timeline

2013 2016 2014 2015 

Milestone D

Preliminary Analysis Publication Februar

Preliminary Analysis Public Meeting March Comment Period Ends April 2

NOPR Publication (projected) DecembeFinal Rule Publication (projected) August 
80

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
81

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
82

Market and Technology AssessmentPurpose:• Define product classes• Characterize the portable AC industry• Identify existing regulatory and voluntary efficiency 

• Gather historical shipments and other relevant mar

• Identify technology options for improving efficiency
83

Product Classes• When evaluating and establishing energy conservati

standards, DOE generally divides covered products inclasses by the type of energy used or by capacity or o

performance‐related features that affect efficiency.

• DOE considered separating product classes based on 

configuration (single‐duct or dual‐duct) and capacity

• DOE research found no consumer utility associated w

different duct configurations.

– All installation locations accommodate both single‐duct an

units.

– There is no correlation between published noise performan

configuration.

• DOE determined that duct configuration does not wa

separate portable AC product classes.
84

Product Classes• Portable AC efficiencies are a function of product cap

– Higher‐capacity units typically achieve higher efficiencies t

capacity units when measured according to the proposed t

procedure.

– DOE observed that the relationship between efficiency and 

consistent across the range of measured capacities.

• Accordingly, DOE maintained one product class for p

and developed an equation to relate efficiency to ca

considering different efficiency levels.
85

Request for Comment

Item 1: DOE invites comments and recommendations from inparties on the proposed single product class that includes sing

and dual‐duct configurations. DOE invites comment on the

determination that portable AC efficiency is a function of pro

capacity.

Product Classes
86

Manufacturers and Market Share• DOE estimates that the majority of portable ACs are

manufactured overseas by 3 major OEMs.

• Products are sold in the United States under approxi

brands.

• DOE estimates that the companies that sell portable 

the United States have the following approximate m

breakdown:

>20% ‐ Haier America Trading LLC

>20% ‐ LG Electronics Inc.

10% ‐ Delonghi America Inc.

10% ‐ American Comfort Worldwide10% ‐ Danby<5% ‐ Remaining entities each
87

Efficiency Distribution• Current availability of portable ACs on the market

– Data is from the California Energy Commission (CEC) Appliance Efficiency 

only intended to provide a general overview for those products.

– The EER and capacity values are based on ANSI/ASHRAE Standard 128‐200

the CEC.

Source: CEC portable AC database (http://www.appliances.energy.ca.gov/QuickSearch.aspx)

02468

1012141618

2000 4000 6000 8000 10000 12000 14000 16000

EER (Btu/Wh)

Capacity (Btu/h)

0

102030405060708090

100

<= 6,000 6,001 ‐

8,000

8,001 ‐

10,000

Number of Models

Capacity Bins (Bt
88

Technology Assessment• Portable ACs contain a refrigeration system to remove sensible 

heat from the air.

• Primary components include:

– Compressor– Heat Exchangers

• Evaporator• Condenser

– Expansion Valve or Capillary Tube

– Fan(s)/Blower(s)– Duct(s) with Mounting Bracket

– Condensate Removal Components

• Slinger (auto‐evaporation)

• Gravity drain• Collection pan (non‐removable)

• Pump Conde

Unco

Condenser Inlet Air from Conditioned Space

Conditioned Air from 

Evaporator Outlet

Retu

Evapo
89

Technology Assessment• DOE identified the following initial technology option

organized into four categories that could be used to 

energy efficiency in portable ACs:

– Increased Heat Transfer Surface Area

• Increased frontal coil area

• Increased depth of coil (add tube

rows)

• Increased fin density

• Add subcooler to condenser coil

– Increased Heat Transfer Coefficients

• Improved fin design

• Improved tube design

• Spray condensate onto condenser coil

• Microchannel heat exchanger

– Component Improvem

• Improved compresso• Improved blower/fa• Low‐standby‐power 

controls

• Ducting insulation• Improved duct conn

• Case insulation

– Part‐Load Technology 

• Variable‐speed com

• Thermostatic or elec

valve
90

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
91

Screening Analysis• Purpose: Identify any technologies to be eliminated 

further consideration.

• DOE screens out technology options based on four fa

– Technological feasibility; practicability to manufacture, inst

service; impacts on product utility to consumers; and safet

technologies.

• DOE screened out ducting insulation.

– DOE is not aware of collapsible insulated ducts in any comm

available product or working prototype.

– If not collapsible, insulated ducts would not be practicable 

manufacture and would adversely impact consumer utility 

packaging reduces portability).
92

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
93

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
94

Engineering Analysis

Purpose

• Evaluate design options that improve efficiency• Characterize manufacturer production cost (MPC) ve

efficiency for higher‐efficiency portable ACs.

Downstream Ana

• Life‐Cycle Cost an

Payback Period A

• National Impact A

• Manufacturer Im

Analysis

Manufacturer Production Cost–

Efficiency Relationship

Manufacturer

Production Cost

Efficiency Level
95

Engineering Analysis ProcessThe engineering analysis for portable ACs was conduct

follows:

1. Select Test Sample

Choose market

representative units for

testing.

2. Product Testing

Conduct testing using the

proposed air enthalpy

method.

3. T

Perform 

determine 

and manu

4. Num

Use a num

estimate 

designs no

tes

5. Efficiency Levels

Determine appropriate

baseline and improved

efficiency levels.

6. Cost‐Efficiency Curves

Determine cost‐efficiency

relationships.
96

Product Testing• DOE selected 24 portable ACs

• 17 single‐duct

• 7 dual‐duct

• One test unit was shipped with a conversion kit to en

single‐duct and dual‐duct installation and was tested 

duct configurations.

• Selected units covered the range of capacities (5,000 

Btu/h) and efficiencies (EERs, 7.0 to 12 Btu/Wh) of pavailable on the market, based on the advertised val

multiple manufacturers.

• The rated capacities and EERs do not necessarily refl

performance under the proposed test procedure.
97

Product Testing ‐ Results• Test results indicated a positive trend between effici

cooling capacity.

• Infiltration air and heat transfer effects greatly impac

efficiency and capacity.
98

Product Teardowns• Based on teardowns and testing, DOE determined fiv

features that are currently or could be used to increaAC efficiency.

– Air flow optimization– Increased heat exchanger area

– Improved compressor efficiency

– Improved blower motor efficiency

– Low standby power electronic controls

• DOE did not specifically consider the remaining desig

that met the screening criteria for the following reas

– There is not sufficient information available on the specific eff

– The current DOE test procedure would not capture the potent

improvements.

– Manufacturers would likely pursue the features above or othe

implemented features that are more cost effective.
99

Product Teardowns• DOE calculated MPCs by disassembling portable ACs 

multiple manufacturers and creating bills of materia

• BOMs describe the product components in detail an

estimates of materials, labor, capital equipment, and 

costs.

• Chapter 5 of the preliminary TSD provides additiona

DOE’s teardown and cost model methodology.
100

Request for Comment

Item 2: DOE requests comment on whether it should consider options that may improve portable AC efficiency under varyin

operating conditions (i.e., improved controls, improved flow‐c

devices, and variable‐speed compressors). DOE notes that the 

and proposed test procedures measure active mode energy u

continuous unit operation at constant ambient conditions and 

not reflect efficiency gains associated with these technologies

Product Teardowns
101

Efficiency Levels• Although DOE tested and tore down a large sample o

did not cover the entire range of efficiency levels and options that are technically feasible.

• DOE numerically modeled performance with the des

identified through testing and teardowns.

EfficiencyLevels DescriptionBaseline Single‐duct units from the test sample

EL1 Dual‐duct unit with 50% infiltration air heat contribu

EL2 Dual‐duct unit with 25% infiltration air heat contribu

EL3 Dual‐duct unit with 0% infiltration air *

EL4 EL3 with additional component improvements**

*In addition to infiltration air heat transfer, air flow optimization also impacted condenser inlet air conditions, compresmotor power. DOE quantified these performance impacts using relationships developed with MarkN and assumption**Component improvements included increased heat exchanger area, improved compressor efficiency, improved blo

and low standby power electronic controls.
102

Combined Tested and Modeled Performance• DOE plotted efficiency performance improvements 

for each test unit.
103

Combined Tested and Modeled Performance• Because efficiency is driven by capacity as well, DOE 

power and capacity by unit to clearly observe trends efficiency level.
104

Combined Tested and Modeled Performance• Re‐plotting to observe improvements by efficiency le

(instead of by unit) results in linear relationships bet

power and capacity.
105

Combined Tested and Modeled Performance• Based on the linear relationships for power, DOE developed an 

each efficiency level.

ݎ݁ݓ݋ܲ ݕݐܽܿ݅݌ܽܥ	݈݅݊݃݋݋ܥ	 ൌ௖௠ ܴܧܧ

Efficiency

Level

A Coefficient

(Wh/Btu)

Baseline 0.113 

EL1 0.1201 EL2 0.1222 EL3 0.1256 EL4 0.1205 

ܤ ൅ ݕݐܽܿ݅݌ܽܥ	݈݅݊݃݋݋ܥ ൈ ܣ ݕݐܽܿ݅݌ܽܥ	݈݅݊݃݋݋ܥ 	 ൌ௖௠ ܴܧܧ
106

Cost‐Efficiency Relationships• DOE developed MPC estimates for each unit include

teardown sample.

• DOE determined the incremental costs at higher effi

levels for each unit based on the design changes asswith each efficiency level.

• DOE averaged these costs for each unit in the teardo

to determine average incremental MPCs.

Average

$MPC

Efficiency Level

Unit Curves

$MPC

Efficiency Level

Unit #1Unit #2

Unit #3
107

• Changes from BL to EL1, EL2, and EL3 only represent

modifications to duct setup and airflow and therefor

minimally increase MPC.

• EL4 represents significant component modifications 

therefore represents a significant increase in MPC.

Cost‐Efficiency Relationships

Efficiency

Level

Incremental MPC

(2013$)

BL $‐

EL1 $4.09EL2 $4.67EL3 $5.26EL4 $47.76
108

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
109

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
110

• Purpose:

• To assess the impacts of standards on manufacturers;

• To identify and estimate impacts on manufacturer subgrou

may be more severely affected than the industry as a who

• To examine the impacts on direct employment, product co

manufacturing capacity, and cumulative regulatory burden

industry.

• Methodology:

• Analyze industry cash flow and industry net present value 

through use of the Government Regulatory Impact Model 

and

• Interview manufacturers to refine inputs to the GRIM, dev

subgroup analyses, and address qualitative issues.

MIA ‐ Overview
111

• Phase 1

– DOE creates an industry profile to characterize the industry and id

important issues that require consideration.

• Phase 2

– DOE prepares an industry cash‐flow model and an interview ques

to guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers, and assesses the impacts of stand

quantitatively (using the Government Regulatory Impact Model) a

qualitatively (impacts on competition, manufacturing capacity, em

and regulatory burden).

MIA ‐ Overview

Industry profile

Develop preliminary GRIM

Develop interview guide

Interviews& industrysubgroupanalyses

Assess employmcompetitcapacity, regulatorburdens

Phase 1 Phase 2 Phase 3
112

• Impacts of Higher Selling Prices

– Higher selling prices could price‐out a segment of portable 

consumers or cause customers to purchase room ACs in lie

portable ACs.

• Impacts on Competition

– Competition within the market could decrease. The situatio

manufacturers will improve (because of a new test procedu

would provide consistent portable AC ratings), while other 

may be forced to exit the market.

• Impacts on Consumer Utility

– Increased product efficiency may negatively impact consum

associated with product features such as size, noise level, a

water disposal.

• Cumulative Regulatory Burden

– Portable ACs are only one of a suite of products offered by

manufacturers.

Preliminary MIA Key Issues
113

Issues for Comment

Request for Comment

Item 3: DOE requests comment on its identification of key issues and data and information from interested parties that can assist in evalua

potential impact on manufacturers.

Item 4: DOE considers the impacts on certain manufacturer subgroup

including small business manufacturers, that have different cost struc

operate within different regulatory frameworks in the NOPR stage. D

requests feedback on subgroups to analyze and/or characteristics apfor subgroup analysis.
114

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
115

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
116

Markups Analysis

Total Installed Cost

Payback Period

Lifetime Op

Expen

Energy Consumption

Electricity Prices

Annual Energy

Expense

Repair Costs

Maintenance Costs

Electricity Price

Trend

Annual Operating

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

From EngineeringAnalysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups

Analysis

Baseline MSP

Std‐level MSP

From EngineeringAnalysisPrice is a function

of efficiency

From Energy UseAnalysis
117

• Purpose

– Determine customer prices under a standards scenario base

manufacturer costs.

• Method

– Characterize product distribution channels and market segm

– Describe portable AC retailer direct costs, expenses, and pro

• Output

– Manufacturer markups and baseline and incremental marku

portable ACs. Retailer and consumer markups.

Markups Analysis Markups Analysis

Overview

Manufacturers Retailers Consumer
118

Markups MarkupsAnalysis Analysis

• Baseline Markups

– Relate consumer price to cost of goods sold (CGS).

– Relate price to cost prior to a change in efficiency.

– Indicate a consumer price that covers all of a distributor’s o

contractor’s expenses plus profit.

• Incremental Markups

– Relate the incremental change in consumer price to the inc

change in CGS.

– Do not vary efficiency induced changes in CGS.

– Cover only expenses that vary with CGS in this case, expens

increase due to an increase in product efficiency.

Markup Types
119

Markups Analysis: Overall Markups

• Applied baseline markups to the MSP of the baseli

and the incremental markups to the incremental dMSP at each level above the baseline.

Residential and Commercial Applications

Markup Baseline Incremental

Manufacturer 1.42Retailer 1.36 1.11Sales Tax 1.071

Overall 2.07 1.69
120

Request for Comment

Item 5: DOE requests comments and information relating to inputs to the markups determination for residential users an

commercial users.

Request for Comment
121

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
122

Energy Use Analysis

Total Installed Cost

Payback Period

Lifetime Op

Expen

Energy Consumption

Electricity Prices

Annual Energy

Expense

Repair Costs

Maintenance Costs

Electricity Price

Trend

Annual Operating

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

From EngineeringAnalysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups

Analysis

Baseline MSP

Std‐level MSP

From EngineeringAnalysisPrice is a function

of efficiency

From Energy UseAnalysis
123

Purpose• Develop annual energy use data for the life‐cycle cost and simp

period analyses to calculate annual operating costs.

Method• Develop consumer samples from DOE‐EIA’s Residential Energy

Consumption Survey (RECS) and Commercial Buildings Energy

Consumption Survey (CBECS).

• Use research studies, RECS data along with Engineering Analys

develop annual energy use on a per‐household basis.

Energy Use Analysis

Overview
124

Calculation Flow

Energy Use Analysis

   

     

      Fan Fan 

Cool ENERGY X kW X 

EER CAP X Year TotalHours ofUse PAC 1000

X

Annual Operating Hours

(hours/year)

Annual Operating Hours

(hours/year)

Cool

Power (kW)

X

Mode (%)

Fan Power

(kW)

X

Fan Mode

(%)

SB Power

(kW)

X

SB Mode

(%)

+ +
125

Energy Use Analysis

Commercial       Residential

Study / Source Cooling Mode Operating Hours Consider

RECS 2009 for room ACs

AHAMConsumer Reports

Burke, et al. 2014

Product age, cooling capacity estimation (based oEnergy Efficiency Ratio (EER) for room AC

Portable AC in rooms < 250 ft2 can reach cooling c

Portable AC field‐metered data for mode percent

CBECS 2003 for room ACs Relationship between CDD and operating hours fo

and schedule

Energy Use Inputs: Operating Hours

Sources:U.S. Department of Energy–Energy Information Administration. Residential Energy Consumption Surve

Survey Data. 2009.

U.S. Department of Energy–Energy Information Administration. Commercial Buildings Energy Consum

2003.Consumer Reports. “Are Portable Air Conditioner Claims a Lot of Hot Air?” Published online June 12, 2

Burke et al., 2014.
126

EL EERcm (Btu/Wh) Cooling Capacity (Btu/h) Power Consumption (W

Cooling‐Mode Fan‐only Mode 

Baseline 2.08 2512 1208 93 

1 3.53 4327 1226 100 2 4.32 5293 1225 104 3 5.28 6539 1238 108 4 5.82 6604 1135 108 

Energy Use Analysis
127

Energy Use Analysis

Average Annual Energy Us

Efficiency Level EERcm (Btu/Wh) Residential Sector (kWh) Commer

Baseline 2.08 724 

1 3.53 525 2 4.32 473 3 5.28 434 4 5.82 400 

Range of Residential Operating Hours by Efficiency Level Range of Commercial Operating Hou
128

Request for Comment

Item 6: DOE requests comments and information relating to inputs to the energy use determination for residential users 

commercial users, specifically operating hours.

Request for Comment
129

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
130

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
131

Life‐Cycle Cost and Payback Period Analysis

Overview
132

Life‐Cycle Cost (LCC) and

Payback Period (PBP) Analysis Purpose

• Assess the net LCC and PBP for different efficiency levels compared to 

• Add the consumer price and the sum of annual operating costs discou

year (2019).

• Perform economic evaluation from the consumer perspective.

• Express results as LCC impacts (baseline minus efficiency standard lev

• Simple payback is the incremental first cost divided by the first year u

operating cost savings .

Life‐Cycle Cost and Payback Period Analysis
133

Method

• Use Monte Carlo simulation analysis.

‒ Characterize the variability and uncertainty associated with 

using probability distributions.

‒ Use RECS household/CBECS enterprise samples to characte

variability in annual energy use and energy prices.

‒ Use probability distributions to characterize the variability 

operating cost inputs (e.g., discount rates, product lifetime

manufacturing costs.

• Develop base‐case efficiency distribution to calculate accurate

savings from increasing product efficiency.

Life‐Cycle Cost and Payback Period Analysis
134

Total Installed Cost

• Product Retail Price = Manufacturing Cost × Markup × Sales Tax

• Total Installed Cost = Retail Price + Installation Cost

‒ Manufacturing cost vs. efficiency relationships developed in 

Engineering Analysis

‒ Markups and Sales Taxes developed in the Markups analysis

• Installation costs represent the labor and materials necessary to 

appliance

‒ DOE did not consider installation costs for portable ACs

Life‐Cycle Cost and Payback Period Analysis
135

Lifetime Operating Cost

• Lifetime Operating Cost = f(annual operating cost, lifetime, disco

electricity price trend)

• Annual Operating Cost = Annual Energy Cost + Repair Cost + Ma

• Annual Energy Cost = f(energy use, electricity prices)

‒ Energy use by mode developed in the Energy Use Analysis

‒ Frequency of use by mode developed in the Energy Use Ana

‒ Electricity prices developed from DOE Energy Information A

(EIA) Form 861 and Annual Energy Outlook (AEO) 2014

Life‐Cycle Cost and Payback Period Analysis
136

Operating Cost Inputs: Electricity Prices and Price T

• Use electricity prices to convert energy use to energy costs.

• Develop electricity prices by geographic location from EIA Form 

• Use DOE‐EIA AEO 2014 for projections of future average energy 

(reference, high, and low scenarios).

• DOE used average energy prices for baseline energy costs and 

energy prices for incremental energy use from baseline usage.

ܱܥா௅ ൌ ܧ௏஺ீ ൈ ܷܥܧ௔஻௦௘௟௜௡௘ ൅ ܧ ௟௔௡௜௚௥௔௠ൈ ሺܷܥܧா௅ െ ܷܥܧ

஻

Life‐Cycle Cost and Payback Period Analysis
137

Operating Cost Inputs: Maintenance and Repair C

• DOE assumed changes in product efficiency incur little or no ch

repair and maintenance costs over baseline products.

• No difference in maintenance and repair costs based on efficie

Life‐Cycle Cost and Payback Period Analysis
138

Request for Comment

Item 7: DOE requests comments on the determination ofmaintenance, and repair costs. If not appropriate, DOE requ

information and data that can be used to develop appropriat

and maintenance costs for products more efficient than base

products.

Request for Comment
139

Operating Cost Inputs: Product Lifetimes

• Use information for room ACs from Appliance Magazine, RECS, 

establish specific portable AC lifetimes.

• Determine average lifetime for portable ACs: 10.5 years

Life‐Cycle Cost and Payback Period Analysis

0%

10%20%30%40%50%60%70%80%90%

100%

0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30

% retiring

years

Lifetime Distribution for Portable Air Conditioners

% Surviving% Retiring
140

Operating Cost Inputs: Discount Rates

• Use discount rates to convert streams of annual operating expe

present value in the LCC analysis.

‒ Derived from estimates of the “finance cost” to purchase r

products.

‒ Based on finance costs including:

• Financial cost of any debt incurred to purchase products (e.g

cards, home equity loans)

• Opportunity cost of any equity to purchase products (e.g., sto

savings accounts)

‒ Use Federal Reserve Board’s Survey of Consumer Finances 

equity and debt data.

Life‐Cycle Cost and Payback Period Analysis
141

Operating Cost Inputs: Energy Efficiency in the Bas

• Represent projected distributions of product efficiencies in firs

compliance year under base case. (Retailer data, 2014)

• Market shares estimated from analysis of portable AC models a

online retailers.

Life‐Cycle Cost and Payback Period Analysis

Efficiency Level Market Share (%)

Baseline 90

1 52 53 04 0
142

Request for Comment

Item 8: DOE requests comments, information and data on thcase efficiency distributions.

Request for Comment
143

LCC Savings Results:

Example from the LCC Analysis for Residential Application

Life‐Cycle Cost and Payback Period Analysis

Efficiency

Level

EERcm

(Btu/Wh)

Average Costs

2013$ 

P

Installed Cost First Year’s Operating Cost Lifetime Operating Cost LCC

Baseline 2.08 534 101 861 1,394 

1 3.53 540 72 617 1,156 

2 4.32 541 64 553 1,094 

3 5.28 542 59 505 1,046 

4 5.82 605 53 461 1,066 

Efficiency

Level

EERcm

(Btu/Wh)

Life‐Cycle Cost Savings

% of Consumers Who Experience

Net Cost

Average Sav

2013$

1 3.53 32 2122 4.32 34 2713 5.28 35 3194 5.82 37 300
144

Request for Comment

Item 9: DOE invites comments and recommendations from inparties on any other aspects related to the Life‐Cycle Cost anPayback Period Analysis.

Request for Comment
145

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
146

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
147

• Purpose

‒ Quantify changes over time in portable AC shipments due t

new energy conservation standards.

• Method

‒ Rely on a range of data sources.

‒ Account for replacements and first time owners.

Shipments Analysis

Historical Shipments Portable AC Lifetime

Replacement

Shipments

Total

Shipments

First‐Time

Owners

Market share by

user sector
148

Shipments Analysis: Model Inputs

Inputs Data Source / Description

Historical Shipments

 Natural Resources Canada (2007): Portable ACs account fo

10% of the total shipment of room ACs.

 Room AC shipments data:

‐ UBM, Market Research (2010 – 2012),

‐ AHAM (1995 – 2009)

‐ AHAM Factbook (1989 – 1994), and

‐ Appliance Magazine (1972 – 1988).

Shipments by user sector

Market share by user sector: derived from the LCC analysis

‐ Residential sector: 99%

‐ Commercial sector: 1%

Replacement Portable ACs lifetime retirement function developed from the 

‐ Average lifetime = 10.5 years

First‐Time Owners (FTOs)

Historical: FTO = Total shipments – replacement shipments

Future FTO (2013 – 2048): 0.17% × projected total housing sto

‐ AEO 2014

Product Prices and Operating

Costs

LCC provides product prices for 2019.

Product price trend is applied to product price for the period 2

Future operating costs estimated using AEO 2014 energy price 
149

• Base Case Shipments Projection (2019 – 2048)

− Capture base‐case shipments projection when new stand

adopted.

− Project shipments to account for replacements and first‐t− Develop base‐case projections for user sector.

• Standards Case Shipments Projection (2019 – 2048

− Project shipments for the base case using historical shipm− Develop standards case projections accounting for purcha

increases and operating cost savings through a “relative” 

elasticity of demand.

Shipments Analysis: Base Case vs Standards Case
150

Shipments Analysis: Projected Base Case Shipments

0.00.20.40.60.81.01.21.41.61.8

Shipments (million)

Base Case Shipments by Market Segment

Replacement FTOs

• Replacement shipments account for about 80% of the projected 

during the analysis period (2019 – 2048). 
151

Request for Comment

Item 10: DOE requests comments and information relating to inputs to the shipments model, particularly historical shipme

market share of residential users and commercial users.

DOE also welcomes input from interested parties on the effe

amended standards on future portable AC shipments.

Request for Comment
152

Preliminary Analysis Rulemaking Stage

Energy Use Analysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Markups Analysis

Preliminary Manufacturer Impact Analysis

Framework

Document

Fin

Ru

Preliminary

Analysis NOPR
153

National Impact Analysis• Purpose

– Determine the projected national energy savings and consu

net present value.

• Method

– Develop annual series of national energy and economic im

– Use the shipments model to estimate the total stock of por

service each year.

– Aggregate the costs and energy use per unit in any given ye

– Report estimates for economic impact as change in consum

Net Present Value (NPV) (in constant year dollars).

– Account for the time‐value of money through defined disco
154

Shipments Model

National Energy Savings

NationalEconomicImpacts

LCC Analysis Results and Other Inputs

N

Ener

(

N

Net P

(2013 

• National energy savings calculated for period from 2019 ‐ 2048 

shipments)

• NPV calculated for products shipped over the period from 2019

years of shipments)

National Impact Analysis: Method
155

National Impact Analysis: National Energy Sav

Base Case

Annual Energy

Consumption

2048

Base Case

Annual Energy

Consumption

2021

Base Case

Annual Energy

Consumption

2020

Base Case

Annual Energy

Consumption

2019

Shipments

Analysis Stand

Case 

Base-Case Projection

Base Case

Annual Energ

Consumption

Base Case

Annual Energy

Consumption

2021

Base Case

Annual Energy

Consumption

2020

Standards Case

Annual Energy

Consumption

2019

Base-Case

Cumulative

Energy Use

Standards-Case 

Cumulative

Energy Use

Site to FFC

Energy

Conversion

National Energy

Savings
156

National Impact Analysis: Net Present Value
157

National Impact Analysis: Shipment‐Weighted Eff

Efficiency

Level

Annual Energy Use

(kWh/yr)

Market Share

(%)

Residential Commercial Base Case CSL 1 CSL 2 CS

Baseline 724 1,713 90 0 0 

1 525 1,411 5 95 0 2 473 1,330 5 5 100 3 434 1,274 0 0 0 14 400 1,173 0 0 0 

SWAEU

(kWh/yr)

Residential 701 522 473 4

Commercial 1,679 1,407 1,330 1,

• Derived base case efficiency distribution in 2019 from the LCC an

• Incorporate future improvements in efficiency and assumed an a

increase in efficiency of 0.25% between 2019 and 2048.

• “Roll up” inefficient equipment but do not affect efficient equipm
158

Input Description

Shipments Annual base case and standards case shipments from the Shipment analys

Total Installed Cost Annual weighted‐average per unit values as a function of efficiency level t

analysis.

Annual Energy Use Annual weighted‐average per unit values as a function of efficiency level t

analysis.

Base‐Case Efficiencies

Shipments‐weighted efficiencies determined for the effective year. Based 

efficiency distribution from LCC analysis. Assumes 0.25% efficiency improv

standards.

Standards‐Case

Forecasted Efficiencies

Roll‐up scenario assumed for determining shipment‐weighted efficiency fo

case.

Energy Prices Average prices and forecasted energy prices from EIA AEO 2014 forecasts 

extrapolation to 2048.

Full Fuel Cycle Multiplier for the primary fuel (electricity) used by portable ACs.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A‐

Present Year Future expenses are discounted to the year 2014.

National Impact Analysis: Inputs
159

National Impact Analysis: National Energy Saving Result

CSL

Portable ACs in

Residential Sites, FFC

(Quads)

Portable ACs in

Commercial Sites, FFC

(Quads)

Portable 

Secto

(Q

1 0.55 0.01 0

2 0.71 0.01 0

3 0.83 0.01 0

4 0.96 0.02 0
160

National Impact Analysis: Consumer NPV Results

CSL

NPV at 3% Discount Rate

(Billion, 2013$)

NPV at 7% Discou

(Billion, 2013

Residential Commercial Total Residential Commer

1 3.98 0.06 4.03 1.70 0.03 

2 5.10 0.08 5.18 2.19 0.03 

3 6.02 0.09 6.11 2.58 0.04 

4 6.02 0.11 6.14 2.48 0.05 
161

Request for Comment

Item 11: DOE requests comments, information and data on tcase efficiency distribution of portable ACs.

DOE also requests comments on whether the annual efficien

improvements (i.e., 0.25%) that DOE estimated is appropriat

base‐case analysis – and if not, what would be a more appro

approach for DOE to project the base‐case and standards‐cas

efficiency distribution for the analysis period.

Request for Comment
162

Public Meeting Topics for Standards

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment and Screening3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis8 Next Steps
163

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
164

• Purpose

– Develop a list of potential new standard levels from which impact

weighed and a proposed standard level is selected.

• Each trial standard level consists of a set of efficiency levels covering 

classes, and may vary between product classes.

• NOPR analyses assess impacts for trial standard levels (not efficiency 

product class).

• Method

– Assemble trial standard levels from the product classes and efficie

identified in the preliminary analyses.

• Trial standard levels cover a range of efficiencies and can include:

– Most energy efficient level (max‐tech);

– Efficiency level with the lowest life‐cycle cost;

– Efficiency level with a payback period of three years or less;

– Efficiency levels with noteworthy technologies; and

– Efficiency levels that fill in large gaps.

Trial Standard Levels
165

Request for Comment

Item 12: DOE requests feedback on the criteria it should use fthe selection of Trial Standard Levels.

Request for Comment
166

Consumer Subgroup Analysis• Purpose

– Evaluate the economic impacts of standards on consumer s

who may be disproportionately impacted compared with t

user population.

• Method

– Identify senior‐only and low‐income households.
167

Request for Comment

Item 13: DOE requests input as to which consumer subgroupsshould consider when developing standards for portable ACs.

Request for Comment
168

• Purpose

– Estimate the emissions reductions resulting from new ener

conservation standards.

– Includes estimating considers full‐fuel‐cycle emissions; bot

emissions and “upstream” emissions.

– Includes fugitive methane emissions.

• Method

– Provide from National Impact Analysis an annual time‐serie

savings over the analysis period.

– Use Energy Information Administration’s National Energy M

System (NEMS) to represent the impacts of new standards.

Emissions Analysis
169

Emission Monetization Analysis• Use the most current Social Cost of Carbon (SCC) values develo

interagency process.

– SCC is intended to be a monetary measure of the incremental dam

from greenhouse gas (GHG) emissions, including, but not limited 

productivity loss, human health effects, property damage from ris

and changes in the ecosystem.

• Use the most recent (2013) U.S. government interagency estim

SCC for emissions in 2015, per metric ton avoided (in 2013$):

– $12.0 (average value from distribution with a 5% discount rate)

– $40.5 (average value from distribution with a 3% discount rate)

– $62.4 (average value from distribution with a 2.5% discount rate)

– $119 (95th‐percentile value from distribution with a 3% discount 

• Report the SCC in constant dollars as increased over time.

• Monetize the NOx emissions reductions resulting from new sta

– Estimates of monetary value range from $476 to $4,893 per short 

– DOE calculated monetary benefits using a medium value of $2,68
170

Request for Comment

Item 14: DOE seeks input on its plans to use NEMS to conduct emissions analysis for the products covered by this rulemakin

Item 15: Are there any other emissions factors the Departmen

consider in this rulemaking?

Item 16: Are there other approaches to the emissions analysis 

Department should consider?

Request for Comment
171

Utility Impact Analysis• Purpose

– Estimate the changes in electric installed capacity and gene

result from new energy conservation standards.

• Method

– Provide from National Impact Analysis an annual time‐serie

savings over the analysis period.

– Use NEMS to represent the impacts of new standards.

• Output

– Reductions in total electricity generation.

– Reductions in primary fuel (e.g. coal, natural gas) consump

– Changes to the mix of electricity generation by fuel type.

– Changes to total installed capacity.
172

Request for Comment

Item 17: DOE seeks input from stakeholders on its plans to usto conduct the utility impact analysis. Examples of the type of 

sought by DOE include, but are not limited to, whether the NE

model is appropriate for assessing the utility impacts of efficie

standards — and if not, what would be a more appropriate m

use?

Request for Comment
173

Employment Impact Analysis• Purpose

– Estimate the national net impact on jobs as a consequence 

energy conservation standards, including indirect employm

• Method

– Use the ImSET (Impact of Sector Energy Technologies) mod

evaluation of indirect employment impacts; direct employm

to the portable air conditioning industry are developed in t

Manufacturer Impact Analysis.

– Input into ImSET the changes in national equipment and en

expenditures from the National Impact Analysis.
174

Request for Comment

Item 18: DOE welcomes feedback on its planned approach forassessing national employment impacts, both direct and indir

it is interested in whether other tools or factors should be con

as part of its analysis. If other tools or factors should be consi

please identify them and explain why, and how, they should b

integrated into DOE's analysis.

Request for Comment
175

Regulatory Impact Analysis• Purpose

– Investigate the national impacts of non‐regulatory alternat

mandatory new energy conservation standards.

• Method

– Modify the NIA spreadsheet to analyze the following non‐r

alternatives and their impact on purchase price and energy 

use.

• Output

– National Energy Savings and Net Present Value for the non

alternatives.

• No new regulatory action • Manufacturer tax cred

• Consumer rebates • Voluntary efficiency ta• Consumer tax credits • Bulk government proc
176

How to Submit Written Comments

In all correspondence, please refer to this rulemaking by:

– Standards for Portable Air Conditioners

– Docket Number EERE‐2013‐BT‐STD‐0033

– Regulation Identification Number (RIN) 1904‐AD02

Email: PortableAC2013STD0033@ee.doe.gov

Postal: CourierMs. Brenda Edwards Ms. Brenda Edwards

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

Building Technologies Program, Building Technologies Prog

Mailstop EE‐5B Suite 6001000 Independence Avenue, SW 950 L’Enfant Plaza, SW

Washington, DC 20585‐0121 Washington, DC 20024

Tel: 202 586‐2945

Comment period closes April 28 2015, 11:59 PM