# Energy Conservation Standards Notice of Proposed Rulemaking on Small, Large, and Very Large Air

- Cooled Commercial Package Air Conditioning and Heating Equipment

Public Meeting on

November 6, 2014 CommPkgACHP2013STD0007@ee.doe.gov2 

# 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 transcript of this meeting.

– Be concise

– share the ‘air

- time ’.

– Keep the focus here

– cell phones on silent; limit sidebar conversations.

– Webinar participants turn phone on mute; ‘raise your hand’ to be recognized
to speak.



## • Housekeeping Items

• Agenda Review

• Opening Remarks3 

# Listening Via the Webcast

• The Department is broadcasting this meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view the slides.

• All stakeholders are encouraged to submit written comments after the public meeting.4 

# Agenda

9:30

– 9:40 am Welcome, Introductions, Opening Statements
9:40

– 10:30 am Overview, Scope, Proposed Standard, Market and Technology Assessment, Screening Analysis
10:30

– 11:15 am Engineering Analysis
11:15

– 11:30 am Break
11:30 am

– 12:00 pm Energy Use, Markup Analysis, Life

- Cycle Cost and Payback Period Analysis
12:00

– 12:30 pm Shipments, National Impact Analysis
12:30

– 1:30 pm Lunch
1:30

– 2:00 pm Manufacturer Impact Analysis
2:00

– 2:30 pm Utility Impact Analysis, Employment Impact Analysis, Environmental Assessment, Regulatory Impact Analysis
2:30

– 2:45 pm Break
2:45

– 3:15 pm Proposed Standard
3:15

– 3:30 pm Closing Remarks5 

# Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate potential energy conservation standards for commercial package air conditioning and heating equipment.

• Invite comment on the energy conservation standards notice of proposed rulemaking (NOPR) and technical support document (TSD ), including DOE’s proposed standard levels.

• Invite participants to provide summary comments or statements and raise additional issues for discussion.6 

# Issue “Boxes” for Discussion

• Issue “boxes” correspond to the list of issues for which the Department seeks comments.

Issue Box: DOE welcomes comments, data, and information concerning the standards it is considering for small, large, and very large air

- cooled commercial package air conditioning and heating equipment. Issues that correspond to those raised in DOE’s published material will be presented. Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis.



## • The deadline for submitting comments is December 1, 2014

.7 

# Opening Remarks

Meeting participants are invited to provide opening remarks or statements at this time.8 

# Public Meeting Topics

1 Overview; Scope; TP; Proposed Standard;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks9 

# Background and Current Standards

• The Energy Policy Act of 2005 (EPACT 2005), Pub. L. No. 109

- 58 (Aug. 8, 2005), amended EPCA to prescribe standards for small, large, and very large air

cooled commercial package air conditioning and heating equipment (CUAC and CUHP).

• The American Energy Manufacturing Technical Corrections Act ( AEMTCA) amended EPCA to require DOE to initiate a rulemaking to consider amending the standards for any covered equipment as to which more than 6 years has elapsed since the issuance of the most recent final rule establishing or amending a standard as of the date of AEMTCA’s enactment, December 18, 2012. (42 U.S.C. 6313(a)(6)(C)(vi ))

• AEMTCA required DOE to issue either a notice of determination that the current standards do not need to be amended or a NOPR containing proposed standards.

• On Feb. 1, 2013, DOE published a request for information (RFI) and notice of document availability to solicit information to help DOE determine whether

more stringent standards would be technologically feasible and economically justified for CUACs and CUHPs.10 

# EPCA Factors

EPCA directs DOE to consider seven factors when setting energy conservation standards. (42 U.S.C. 6313(a)(6)(B ))

EPCA Factors Corresponding DOE Analyses

1. Economic impact on customers and manufacturers Life

- Cycle Cost Analysis Manufacturer Impact Analysis
2. Lifetime operating cost savings compared to increased cost for the equipment Life

- Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis

4. Impact on utility or performance Engineering Analysis Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers relevant Environmental Assessment Utility Impact Analysis Employment Impact Analysis11 

# Energy Conservation Standards Rulemaking Process

NOPR RFI Final Rule12 

# Energy Efficiency Descriptor

– Cooling Efficiency

• The current energy conservation standards for air

- cooled CUAC and CUHP are based on energy efficiency ratio (EER) for cooling efficiency and coefficient of performance (COP) for CUHP heating efficiency. 10 CFR 431.97(b).

• In the RFI, DOE noted that it was considering whether to replace the existing efficiency descriptor, EER, with a new descriptor , IEER

.

• EER metric only uses the efficiency of operating at full load

.

• IEER metric also factors in the efficiency of operating at part

- loads of 75%, 50%, and 25% of capacity, weighting the full

- and part

- load efficiencies with the average amount of time operating at each loading point.

• The usage pattern weights for the IEER metric were developed by analyzing equipment usage patterns of several buildings across the 17 ASHRAE Standard 90.1

– 2010 climate zones.

• The weighting factors accounted for the hours of operation where mechanical cooling was active.13 

# Energy Efficiency Descriptor

– Cooling Efficiency

• Current DOE test procedure incorporates by reference specific sections of AHRI Standard 340/360

– 2007.

• Includes methods and procedures for testing and rating equipment with the IEER metric

.

• ASHRAE Standard 90.1

– 2010 specifies two performance requirements: EER and IEER

.

• EPCA requires that test procedures be reasonably designed to produce test results that measure the energy efficiency of covered equipment during a representative average use cycle. (42 U.S.C. 6314(a)(2))

• The IEER metric weights the efficiency of operating at different partial loads and full load based on usage patterns, which provides a more representative measure of annual energy use than the EER metric.

• DOE is proposing to amend its standards based on the IEER metric.14 

# Energy Efficiency Descriptor

– Heating Efficiency

• The current standards for air

- cooled CUHP heating efficiency are based on the COP metric

.

• DOE is not aware of any test procedures that have been developed that measure part load performance in heating mode for air

- cooled CUHP.

• DOE is not aware of any data regarding the annual usage for CUHP under part

- load heating conditions to determine whether part

- load heating hours are significant or of data that would reveal usage patterns to help determine appropriate test conditions under partial loads.

• DOE is proposing standards for the heating efficiency based on the COP metric.15 

# The Proposed Standard

Equipment Class Heating Type Baseline TSL 1 TSL 2 TSL 3 TSL 4

Small Commercial Packaged Air Conditioners and Heat Pump (Air

Cooled)

– ≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 11.4 IEER 12.9 IEER 14 IEER 14.8 IEER 19.9 IEER
All Other Types of Heating 11.2 IEER 12.7 IEER 13.8 IEER 14.6 IEER 19.7 IEER

HP Electric Resistance Heating or No Heating 11.2 IEER 3.3 COP 12.2 IEER 3.3 COP 13.3 IEER 3.4 COP 14.1 IEER 3.5 COP 19.2 IEER 3.7 COP All Other Types of Heating 11.0 IEER 3.3 COP 12 IEER 3.3 COP 13.1 IEER 3.4 COP 13.9 IEER 3.4 COP 19.0 IEER 3.6 COP

Large Commercial Packaged Air Conditioners and Heat Pump (Air

Cooled)

– ≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 11.2 IEER 12.2 IEER 13.2 IEER 14.2 IEER 18.4 IEER
All Other Types of Heating 11.0 IEER 12.0 IEER 13.0 IEER 14.0 IEER 18.2 IEER

HP Electric Resistance Heating or No Heating 10.7 IEER 3.2 COP 11.4 IEER 3.2 COP 12.4 IEER 3.3 COP 13.4 IEER 3.3 COP 17.6 IEER 3.3 COP All Other Types of Heating 10.5 IEER 3.2 COP 11.2 IEER 3.2 COP 12.2 IEER 3.3 COP 13.2 IEER 3.3 COP 17.4 IEER 3.3 COP

Very Large Commercial Packaged Air Conditioners and Heat Pump (Air

- Cooled)

– ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 10.1 IEER 11.6 IEER 12.5 IEER 13.5 IEER 15.5 IEER
All Other Types of Heating 9.9 IEER 11.4 IEER 12.3 IEER 13.3 IEER 15.3 IEER

HP Electric Resistance Heating or No Heating 9.6 IEER 3.2 COP 10.6 IEER 3.2 COP 11.5 IEER 3.2 COP 12.5 IEER 3.2 COP 14.5 IEER 3.2 COP All Other Types of Heating 9.4 IEER 3.2 COP 10.4 IEER 3.2 COP 11.3 IEER 3.2 COP 12.3 IEER 3.2 COP 14.3 IEER 3.2 COP16 

# Rationale for Adopting the Proposed Standard

EPCA directs DOE to consider seven factors when setting energy conservation standards. (42 U.S.C. 6313(a)(6)(B ))

TSL Benefits Burdens

3 • Energy savings: 11.8 quads

• Environmental savings (CO 2

Savings: 1085 million metric tons)

• NPV (2013$) at a 7% discount rate:

$16.5 billion

• Positive mean LCC savings for all

equipment classes • Industry Conversion Costs total $226.4 million over 4 years

• Up to a loss of 24.7% of industry net present

value17 

# Sample Market Plot of CUACs with Proposed Level

IEERs and TSLs for CUAC with Other Types of Heating

Proposed Standard (TSL3) Addendum CL (TSL1) ASHRAE 90.1

- 2010 (Baseline)18 

# Request for Comment

Issue 1: DOE seeks comment on the use of the IEER as the cooling efficiency metric and COP as the heating efficiency metric (for CUHP) for the proposed energy conservation standards, including additional data and input regarding the uncertainty of IEER test measurements.19 

# Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks20 

# Market Assessment: Equipment Classes

• The proposed energy conservation standards would apply to small
, large, and very large, air

- cooled CUAC and CUHP as defined under section 342(a) of EPCA.

– This category of equipment has a rated cooling capacity between 65,000 Btu/h and 760,000 Btu/h.



## • The current equipment classes established by EPACT 2005 divide this equipment into twelve classes characterized by rated cooling capacity, equipment type (air conditioner versus heat pump), and heating type.

• DOE is proposing standards based on the existing equipment class structure.21 

# Equipment Classes

Equipment Type Cooling Capacity Sub

- Category Heating Type

Small Commercial Packaged Air

- Conditioning and Heating Equipment (Air

- Cooled) ≥65,000 Btu/h and <135,000 Btu/h AC Electric Resistance Heating or No Heating
All Other Types of Heating

HP Electric Resistance Heating or No Heating
All Other Types of Heating

Large Commercial Packaged Air

- Conditioning and Heating Equipment (Air

- Cooled) ≥135,000 Btu/h and <240,000 Btu/h AC Electric Resistance Heating or No Heating
All Other Types of Heating

HP Electric Resistance Heating or No Heating
All Other Types of Heating

Very Large Commercial Packaged Air

- Conditioning and Heating Equipment (Air

- Cooled) ≥240,000 Btu/h and <760,000 Btu/h AC Electric Resistance Heating or No Heating
All Other Types of Heating

HP Electric Resistance Heating or No Heating
All Other Types of Heating22 

# Request for Comment

Issue 3 : DOE requests comments and detailed information regarding any design features that DOE should consider for establishing separate equipment classes in this rulemaking. DOE requests that such information provide test data illustrating the additional challenges faced by models having such design features and a discussion of the customer utility aspects of the design feature. In particular, DOE requests detailed comments regarding the definition of such equipment classes, and any detailed information, such as test data, test conditions, key component design details, as well as other relevant information (e.g., fan power consumption) that may help DOE evaluate potential alternative equipment class standard levels.23 

# Technology Assessment: Purpose

• Purpose

– To develop a preliminary list of technology options that could improve the efficiency of air

- cooled CUAC and CUHP.

– This list is examined in greater detail, and inappropriate technologies removed, in subsequent analyses.



## • Method

– DOE identified technology options:

• Technical support documents from previous rulemakings

• Literature review and manufacturer specification sheets

• Equipment teardowns

• Comments and input from interested parties



## • The full list of technologies that DOE identified can be found in Chapter 3 of the TSD.24 

# Commercial Rooftop Challenge

- Daikin McQuay Rebel

The appliance standards program utilized the expertise gained by working with industry in the commercial rooftop challenge in its analysis

.

“With industry

- best efficiencies up to 20.6 IEER, Rebel delivers unprecedented energy savings of 60

- 70% above ASHRAE’s 90.1 efficiency standard, allowing for complete system payback in as little as two years .”
http ://www.daikinmcquay.com/mcquaybiz/DocumentStorage/RooftopSystems/Brochures/Rebel6pg_final.pdf25



# Commercial Rooftop Challenge Cont’d

- Carrier WeatherExpert TM

“As an innovator and market leader, Carrier embraced the RTU Challenge and committed to the energy savings initiative more broadly with its entire line of WeatherExpert models ranging from 3

- to 23

- ton units reaching a high

- IEER rating of 21.0, making the WeatherExpert one of the most efficient packaged rooftop units available .” http://www.carrier.com/carrier/en/br/news/news

- article/carrier__weatherexpert__rises_to_department_of_energy_challenge_reaching_ 20_8_ieer_rating.aspx26 

# Screening Analysis: Purpose

• Purpose

– To determine which technology options will be considered in downstream analyses.



## • Technology options are “screened out” if they

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to customers

– Have adverse impacts on health or safety



## • Screened

- Out Technologies:

– Electro

- hydrodynamic enhanced heat transfer

– Alternative refrigerants

– Sub

- coolers



## • The screened

- in design options are listed in the engineering section.27 

# Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks28 

# Engineering Analysis

• In the Engineering Analysis, DOE characterizes the relationship between manufacturer cost and energy efficiency.

Downstream Analyses

• Life

- Cycle Cost and Payback Period Analysis

• National Impacts Analysis

• Shipments Analysis

• Manufacturer Impact Analysis Output: Cost

– Efficiency RelationshipIncrementalManufacturing Cost

Energy Efficiency29 

# Engineering Analysis: Design Options

Design Options
Condenser and evaporator fan and fan motor improvements:

• Larger fan diameters

• More efficient fan blades (e.g., air foil centrifugal evaporator fans, backward

- curved centrifugal evaporator fans, high efficiency propeller condenser fans)

• High efficiency motors (e.g., copper rotor motor, high efficiency induction, permanent magnet, electronically commutated)

• Variable speed fans/motors Larger heat exchangers Compressor Improvements

• High efficiency compressors

• Multiple compressor staging

• Multiple

- tandem or variable

- capacity compressors Thermostatic expansion valves Electronic expansion valves
Reduced indoor fan belt loss:

• Synchronous (toothed) belt

• Direct

- drive fans30 

# Request for Comment

Issue 4: DOE requests comment and data regarding additional design options or variants of the considered design options that can increase the range of considered efficiency improvements, including design options that may not yet be found on the market.31 

# Engineering Analysis: Methodology

Identify Representative Equipment

Develop Baseline

Identify and Model Design Options

Calculate Costs

Generate Cost

Efficiency Curves 

# 



 Choose representative equipment classes and capacities, based primarily on their high market volumes, to streamline analysis.

Establish baseline specifications for each equipment class and calibrate energy model.

Identify design options for increasing equipment efficiency and use energy modeling to determine IEER efficiency impact.
Conduct teardown and cost modeling analysis for representative equipment and design options at the efficiency levels identified.

Generate cost

- efficiency curves, which account for full manufacturer production costs (MPCs). 

#  32 

# Representative Equipment

• DOE first selected representative equipment classes for which to conduct the full engineering analysis.

• DOE analyzed three specific capacities to represent each of the three cooling capacity categories (small, large, and very large).

• These equipment classes and cooling capacities were selected based on a review of equipment offerings and information obtained from manufacturer interviews

.
Representative Equipment Classes Representative Cooling Capacity
Small Air

- Cooled CUAC, ≥65,000 Btu/h and <135,000 Btu/h cooling capacity, electric resistance heating or no heating

. 90,000 Btu/h (7.5 tons)

Large Air

- Cooled CUAC, ≥135,000 Btu/h and <240,000 Btu/h cooling capacity, electric resistance heating or no heating

. 180,000 Btu/h (15 tons)

Very Large Air

- Cooled CUAC, ≥240,000 Btu/h and <760,000 Btu/h cooling capacity, electric resistance heating or no heating

. 360,000 Btu/h (30 tons)33 

# Baseline Efficiency Levels

• DOE is typically obligated either to adopt the standards developed by ASHRAE or to adopt more stringent levels if there is clear and convincing evidence in support of doing so.

– ASHRAE Standard 90.1

– 2010 specifies minimum efficiency requirements using both EER and IEER.



## • DOE evaluated the relationship between EER and IEER for models rated at the current DOE standard levels (EER) and analyzed the distribution of corresponding rated IEER values.

– Lowest IEER values generally correspond with the ASHRAE Standard 90.1

– 2010 minimum efficiency requirements.



## • DOE proposes to use the ASHRAE Standard 90.1

– 2010 minimum IEER requirements to characterize the baseline cooling efficiency for each equipment class.

• For CUHPs, DOE proposes to use the current COP standard levels to characterize the baseline heating efficiency for each equipment class.34 

# Baseline Efficiency Levels

Equipment Type Heating Type Baseline Efficiency Level

Small Commercial Packaged AC and HP (Air

Cooled)

– ≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 11.4 IEER All Other Types of Heating 11.2 IEER

HP Electric Resistance Heating or No Heating 11.2 IEER 3.3 COP
All Other Types of Heating 11.0 IEER 3.3 COP

Large Commercial Packaged AC and HP (Air

Cooled)

– ≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 11.2 IEER All Other Types of Heating 11.0 IEER

HP Electric Resistance Heating or No Heating 10.7 IEER 3.2 COP
All Other Types of Heating 10.5 IEER 3.2 COP

Very Large Commercial Packaged AC and HP (Air

Cooled)

– ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 10.1 IEER All Other Types of Heating 9.9 IEER

HP Electric Resistance Heating or No Heating 9.6 IEER 3.2 COP
All Other Types of Heating 9.4 IEER 3.2 COP35 

# Incremental Efficiency Levels

• DOE established incremental efficiency levels (ELs) based on a review of industry standards and available equipment.

• EL 1 is based on the draft of addendum CL to ASHRAE Standard 90.1

– 2010.

• Higher ELs for CUACs with electric resistance heating or no heating:

– Range of ELs associated with equipment listed in the AHRI certification database and the California Energy Commission’s (CEC) database

.

– DOE evaluated the full range of capacities for the small, large, and very large equipment classes with a specific focus on 7.5

- ton, 15

- ton, and 30

- ton as the representative cooling capacities

.



## • Higher ELs for CUACs with all other types of heating:

– DOE adopted the same trend of heating

- type IEER drop vs. electric/no

heat IEER used in Draft Addendum CL: 0.2 IEER.

– DOE believes these decreases in IEER appropriately reflect the additional power required for furnace pressure drop.36 

## • Higher cooling ELs for CUHP equipment classes:

– DOE adopted the same trend of heat pump IEER drop vs. electric/no

heat IEER used in Draft Addendum CL: ranging from 0.2 to 1.0 IEER.

– DOE believes these decreases in IEER are representative of the efficiency differences that occur due to losses from the reversing valve and coil circuitry required in heat pumps for both heating and cooling operation

.



## • Maximum

- available ELs rely on the performance of recently introduced models.

– DOE evaluated available equipment literature and energy use information on these maximum

- available efficiency models.

– Conducted energy modeling to determine the feasibility of achieving these efficiency levels. 

# Incremental Efficiency Levels37 

## • For CUHP equipment classes heating efficiency levels, the correlations between COP and EER were used to justify DOE’s prior final rule adopting ASHRAE 90.1 levels.

• Because this method was generally accepted by industry and interested parties, DOE considered a similar approach for proposing heating efficiency levels based on the variation of COP with IEER.

– DOE evaluated AHRI and CEC data for air

- cooled CUHP units with electric resistance heat or no heat to analyze the relationship between COP and both IEER and EER.

– The correlations between COP and IEER using linear regressions are no less strong than the correlations between COP and EER for each capacity range.

– DOE observed only a small variation in COP from baseline to max

- tech. 

# Incremental Efficiency Levels38 

## • DOE is proposing to use the functions relating COP to IEER based on AHRI and CEC data to establish COP efficiency levels.

– For each CUHP equipment class, DOE selected COP levels corresponding to each incremental IEER level

.

– Details of this analysis are presented in Chapter 5 of the TSD. 

# Incremental Efficiency Levels39 

# Incremental Efficiency Levels

Equipment Type Heating Type Efficiency Levels

Baseline EL1 EL2 EL3 EL4 (max tech)

Small Commercial Packaged AC and HP (Air

- Cooled)

– ≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 11.4 IEER 12.9 IEER 14 IEER 14.8 IEER 19.9 IEER
All Other Types of Heating 11.2 IEER 12.7 IEER 13.8 IEER 14.6 IEER 19.7 IEER

HP Electric Resistance Heating or No Heating 11.2 IEER 3.3 COP 12.2 IEER 3.3 COP 13.3 IEER 3.4 COP 14.1 IEER 3.5 COP 19.2 IEER 3.7 COP All Other Types of Heating 11.0 IEER 3.3 COP 12 IEER 3.3 COP 13.1 IEER 3.4 COP 13.9 IEER 3.4 COP 19.0 IEER 3.6 COP

Large Commercial Packaged AC and HP (Air

- Cooled)

– ≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 11.2 IEER 12.2 IEER 13.2 IEER 14.2 IEER 18.4 IEER
All Other Types of Heating 11.0 IEER 12.0 IEER 13.0 IEER 14.0 IEER 18.2 IEER

HP Electric Resistance Heating or No Heating 10.7 IEER 3.2 COP 11.4 IEER 3.2 COP 12.4 IEER 3.3 COP 13.4 IEER 3.3 COP 17.6 IEER 3.3 COP All Other Types of Heating 10.5 IEER 3.2 COP 11.2 IEER 3.2 COP 12.2 IEER 3.3 COP 13.2 IEER 3.3 COP 17.4 IEER 3.3 COP40 

# Incremental Efficiency Levels

Equipment Type Heating Type Efficiency Levels

Baseline EL1 EL2 EL3 EL4 (max tech)

Very Large Commercial Packaged AC and HP (Air

- Cooled)

– ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity AC Electric Resistance Heating or No Heating 10.1 IEER 11.6 IEER 12.5 IEER 13.5 IEER 15.5 IEER
All Other Types of Heating 9.9 IEER 11.4 IEER 12.3 IEER 13.3 IEER 15.3 IEER

HP Electric Resistance Heating or No Heating 9.6 IEER 3.2 COP 10.6 IEER 3.2 COP 11.5 IEER 3.2 COP 12.5 IEER 3.2 COP 14.5 IEER 3.2 COP All Other Types of Heating 9.4 IEER 3.2 COP 10.4 IEER 3.2 COP 11.3 IEER 3.2 COP 12.3 IEER 3.2 COP 14.3 IEER 3.2 COP41 

# Request for Comment

Issue 5: DOE requests comment on the incremental and max

tech ELs identified for the analyses, including whether the ELs identified by DOE can be achieved using the technologies screened

- in during the screening analysis, and whether higher efficiencies are achievable using technologies that were screened

- in during the screening analysis.42 

# Equipment Testing, Teardown, and Energy Modeling

• DOE selected 8 representative test units for the engineering analysis:

– Conducted testing according to the IEER test method specified in AHRI Standard 340/360

– 2007 at a third party laboratory.

– Conducted physical reverse

- engineering teardowns on each test unit to develop a manufacturing cost model and to evaluate key design features (e.g., heat exchangers, compressors, fans/fan motors, control strategies, etc .)



## • Supplemented these data by conducting virtual teardowns using catalog specifications on models spanning the full range of capacities from all manufacturers to verify cost

- efficiency estimates.

• Used information from test results and equipment teardowns to conduct energy modeling for CUACs.43 

# Energy Modeling

• DOE used the modeling tools developed by the Center for Environmental Energy Engineering from the University of Maryland at College Park to calculate cooling capacity and compressor power consumption at different operating conditions.

• The tools include a detailed heat exchanger modeling program ( CoilDesigner) and a refrigeration cycle modeling program ( VapCyc).

– The refrigeration cycle model integrates the heat exchanger and compressor models to construct a refrigeration cycle model

.



## • Power consumption of fans and controls based on power measurements and information available in product literature.

• Energy Modeling Validation:

– Applied the key design features identified during physical equipment teardowns.

– Generated detailed performance data (e.g. capacity and EER ) for one test unit in each capacity range class (small, large, and very large) and validated them against the results obtained from laboratory testing at each IEER capacity level

or with the published performance data

.

– Modeled performance data was within 5% of the tested value for each test unit.44 

# Energy Modeling

• DOE expanded the modeling tasks with various system design options and identified the key design features required for 7.5

- ton, 15

- ton, and 30

- ton air

- cooled CUAC units with electric resistance heating or no heating to achieve each efficiency level.

– In some cases the models were developed to represent designs of specific equipment models that are available for sale or that were tested and reverse

- engineered

.

– In other cases, the models represented modifications of these designs based on consideration of alternative design options, but still consistent in general with equipment available on the market.



## • DOE used the model to generate energy use profiles for air

- cooled CUACs to serve as inputs for the energy use analysis.

– Included wattage inputs for key components (i.e., compressor, indoor and outdoor fan motors, and controls) at each operating load level measured for the IEER test method, for each efficiency level.45 

# Energy Modeling

• DOE used these design features developed by the energy modeling to determine the incremental manufacturing costs for each efficiency level for 7.5

- ton, 15

- ton and 30

- ton air

- cooled CUAC units.

Issue 6: DOE requests comments , information, and data that would inform adjustment of energy modeling input and/or results that would allow more accurate representation of the energy use impacts of design options using the modeling tools developed by the Center for Environmental Energy Engineering from the University of Maryland College Park.46 

# Manufacturing Cost Model

Manufacturing cost models were developed by DOE as part of the reverse

engineering approach.

Raw Materials

Finished Materials Purchased Parts Physical Teardown Selection of Units

Fabrication

Processes Bill of Materials

Assembly Processes

Manufacturing Cost 

### • Bills of material were generated during the equipment teardown analysis and entered into the cost model.

• Cost model generated manufacturing, material, labor, and overhead costs.

• Physical teardown analysis conducted with representative equipment.

• Manufacturer interviews conducted to further refine the analytical inputs and the results generated by the cost model.47 

# Manufacturing Cost Model Structure/Classification of Manufacturing Costs

Full Manufacturer Selling Price (MSP)

Non

- Production Cost **

Selling General & Admin. R & D Interest Full Manufacturing Production Cost (MPC)*

Direct Labor Direct Material Overhead

Indirect labor

Indirect material

Maintenance
Depreciation

Taxes

Insurance related to assets Market research
Advertising
POS promotion
Sales person compensation & travel
Logistics

- Warehousing

- Delivery

- Record keeping Costs of service & staff units

General corporate costs

– comp., etc. Costs associated with efforts to find
new or improved equipment or production processes Costs of borrowing funds

* Tax Reform Act of 1986 essentially requires companies to measure cost of goods sold as the full production cost of the goods sold. ** In a company’s income statement, many of these costs are reported as a lump sum, under SG&A expenses.48 

# Manufacturer Interviews

• DOE requested interviews with CUAC and CUHP manufacturers to develop a deeper understanding of the various combinations of technologies used to increase equipment efficiency, and their associated manufacturing costs

.

– DOE conducted interviews with 7 CUAC and CUHP manufacturers.



## • As part of the interviews, DOE sought feedback on the proposed efficiency levels, design options, inputs for the energy and manufacturing cost models, and resulting manufacturing costs generated from the reverse

- engineering analyses.

• DOE also sought to better understand the impact that the proposed standard levels would have on manufacturers businesses (e.g., the size and nature of capital expenditures).

• DOE refined its analysis based on all data and feedback provided to date.49 

# Cost

- Efficiency Results

• Based on these analyses, DOE generated cost

- efficiency results for each cooling capacity range.

– Incremental manufacturing costs are expected to be equivalent for each of the equipment classes within a given cooling capacity range (e.g., the analysis for electric resistance/no heating AC units would apply to the other heating and/or HP units of the capacity range).



## • Small Commercial Packaged AC and HP (Air

- Cooled ):

Efficiency Level Incremental Costs ($2013)
MPC Shipping
Baseline

- - EL 1 $115.93 $0

EL 2 $583.47 $0

EL 3 $788.88 $0

EL 4 (Max

- Tech) $1,277.04 $102.8650 

# Cost

- Efficiency Results

• Large Commercial Packaged AC and HP (Air

- Cooled ):

• Very Large Commercial Packaged AC and HP (Air

- Cooled ): Efficiency Level Incremental Costs ($2013)
MPC Shipping
Baseline

- - EL 1 $419.16 $0

EL 2 $792.76 $192.86

EL 3 $1,236.98 $192.86

EL 4 (Max

- Tech) $1,554.26 $192.86

Efficiency Level Incremental Costs ($2013)
MPC Shipping
Baseline

- - EL 1 $542.65 $0

EL 2 $1,296.41 $0

EL 3 $1,834.67 $0

EL 4 (Max

- Tech) $2,753.32 $444.0051 

# Request for Comment

Issue 7: Input and data on the estimated incremental manufacturing costs, including the extrapolation of incremental costs for equipment classes not fully analyzed, in particular for heat pump equipment classes.52 

# Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks53 

# Energy Use Analysis

Purpose

• Determine annual energy use (UEC) of CUACs at the considered efficiency levels to find annual energy costs and savings.

• Annual energy costs are inputs to Life

- Cycle Cost and Payback Period Analysis

. 

## Method

• Utilized building simulation analysis results from prior DOE analysis of CUAC energy efficiency standards (2004 ).

• CUAC cooling and ventilation energy use derived by applying detailed equipment performance data to the simulated hourly time series of cooling load and fan operation.

• Created a generalized building sample to capture the energy use of CUACs in buildings since 1996.54 

# Energy Use Analysis: Modeling of CUAC equipment

• Utilized building simulation analysis results from prior DOE analysis of CUAC energy efficiency standards (2004)

– Simulations performed on buildings from Energy Information Administration (EIA) Commercial Building Energy Consumption Survey (CBECS), 1995.

– 1033 buildings utilizing package rooftop air conditioners were modeled.

– Simulations provided “8760

- hour” cooling load and fan operating hour profiles for air

- conditioning and ventilation for CUACs at various EER levels.

– The 11 EER CUAC simulations were used to represent equipment performance for the baseline IEER levels: 7

- 5

- ton: 11.4 IEER; 15

- ton: 11.2 IEER 30

- ton: 10.1 IEER.

– The 11 EER simulations were chosen as they most closely represented equipment performance at current standard levels.55 

# Energy Use Analysis: Modeling of CUAC equipment

• DOE derived CUAC cooling and ventilation energy use by applying detailed equipment performance data to the simulated hourly time series of cooling load and fan operation

– AHRI 340/360 defines the required performance data and rating conditions to define the test procedure energy use for 7.5

- ton, 15

- ton, and 30

- ton CUACs

– Outdoor rating conditions are 95, 81.5, 68, and 65 ° F

– For each of the 1033 buildings, the outdoor temperature was obtained from the TMY2 (Typical Meteorological Year) weather file used in the original simulations

– The temperature data were adjusted to account for changes between TMY2 (1995) and the more recent TMY3 edition (2008)56 

# Energy Use Analysis: Modeling of CUAC equipment

• Energy use calculations are based on equations for the net capacity (BTU/hr), compressor power (W), condenser fan power (W), indoor fan power (W) and control power (W) at each IEER level.

• The net capacity and compressor power are linear functions of the exterior dry

- bulb temperature.

• Indoor fan power is also a function of dry

- bulb temperature for higher temperature conditions.

• The engineering analysis provides these fields for the baseline and each efficiency level at the rating conditions.

• DOE used linear interpolation to develop more general equations as a function of outdoor dry bulb temperature.

• The linear equations, and the TMY2 temperature time series for each simulated building, were used to determine the energy consumption of each component for each hour of the year.57 

# Energy Use Analysis: Results of Modeling CUAC equipment

• Summing up hourly component power use over “8760

- hour” load profile provides annual use for the baseline and each efficiency level for each building in the set of the 1033 building sample.

1000 10000 100000 1000000 10000000Building Energy Use for Cooling (kWh/yr)

Building ID (from highest to lowest energy use) Baseline
EL 1
EL 2
EL 3
EL 4

1000 10000 100000 1000000 10000000Building Fan Energy Use (kWh/yr)

Building ID (from highest to lowest energy use) Baseline

EL 1
EL 2
EL 3
EL 4 15

- ton CUAC cooling energy use 15

- ton CUAC fan energy use58 

# Energy Use Analysis: Generalized Building Sample

• DOE developed a generalized building sample to define the population of buildings that use CUAC equipment in 2014.

• The generalized building sample serves as the customer sample that is provided to the Life

- Cycle Cost (LCC) and Payback Period (PBP) analysis.

• The generalized building sample is an estimate of the total commercial building floor space that uses CUAC as a function of four characteristics: building activity, size, vintage, and location.

• These characteristics are the primary source of variability in cooling energy use and operating costs.

• The floor space estimate is used to define the relative weights of each generalized building in the customer sample.

– For example, if large offices in region 1, vintage 1981

- 1999 are 3.5% of total floor space, then generalized buildings of this type constitute 3.5% of the customer sample.



### • The results from the simulation data for the individual buildings in the sample of 1033 were averaged to create load profiles for each generalized building.59 

# Energy Use Analysis: Generalized Building Sample

• The region in which the building is located affects both the cooling loads and the price of electricity.

• The building activity affects building schedules and occupancy, which in turn influence the cooling and internal loads.

• The building size influences the price of electricity because larger facilities tend to have lower marginal prices.

• The building vintage influences shell characteristics that can affect cooling loads.

– The energy use for building vintages after 2004 was adjusted using scaling factors for cooling loads taken from the Annual Energy Outlook commercial demand module60 

# Energy Use Analysis: Results

• Cooling and Fan energy use were developed for the CUAC units for each generalized building in the sample; weighted averages shown below:

Region EL IEER Cooling Fan Total Cooling Fan Total Cooling Fan Total kWh/ton kWh/ton kWh/ton kWh/sq.ft. kWh/sq.ft. kWh/sq.ft. kWh/unit kWh/unit kWh/unit U.S. Base 11.2 1,000 523 1,523 2.7 1.4 4.2 15,005 7,845 22,850 U.S. 1 12.2 919 477 1,396 2.5 1.3 3.8 13,785 7,151 20,936 U.S. 2 13.2 797 443 1,240 2.2 1.2 3.4 11,955 6,645 18,600 U.S. 3 14.2 881 222 1,102 2.4 0.6 3.0 13,212 3,324 16,536 U.S. 4 18.4 594 231 825 1.6 0.6 2.3 8,916 3,463 12,379 Warm Base 11.2 1,186 512 1,698 3.5 1.5 5.1 17,784 7,679 25,463 Warm 1 12.2 1,093 467 1,559 3.3 1.4 4.7 16,389 6,999 23,389 Warm 2 13.2 960 434 1,394 2.9 1.3 4.2 14,402 6,511 20,914 Warm 3 14.2 1,034 223 1,257 3.1 0.7 3.8 15,514 3,346 18,860 Warm 4 18.4 731 242 972 2.2 0.7 2.9 10,960 3,624 14,584 Cool Base 11.2 848 532 1,380 2.1 1.3 3.5 12,718 7,982 20,700 Cool 1 12.2 776 485 1,261 2.0 1.2 3.2 11,643 7,276 18,918 Cool 2 13.2 663 450 1,113 1.7 1.1 2.8 9,941 6,755 16,696 Cool 3 14.2 755 220 975 1.9 0.6 2.5 11,318 3,306 14,624 Cool 4 18.4 482 222 704 1.2 0.6 1.8 7,234 3,331 10,565 15

- ton CUAC Average Cooling and Fan Energy Use61 

# Request for Comment

Issue 9: DOE requests comments on the use of a ‘‘ generalized building sample’’ to characterize the energy consumption of CUAC equipment in the commercial building stock. Specifically, whether there are any data or information that could improve the method for translating the results from the 1,033 simulated buildings to the generalized building sample.62 

# Markups Analysis
Purpose

• Determine customer prices based on manufacturer’s selling price for baseline and higher efficiency equipment

• Characterize CUAC and CUHP distribution channels



## Method

• Analyze company direct costs, expenses, and profits

– Manufacturers: 2006

- 2011 SEC 10

- K Reports

– Wholesalers: HARDI 2012 Profit Report

– Mechanical Contractors: ACCA 1995 Financial Analysis for the HVACR Contracting Industry and U.S. Census Bureau, 2007 Plumbing, Heating, and Air

- Conditioning Contractors

– General Contractors: U.S. Census Bureau, 2007 Commercial and Institutional Building Construction

– Sales Taxes: The Sales Tax Clearinghouse Manufacturer Consumer National Account Wholesaler Small Mechanical Contractor General Contractor Consumer

Manufacturer

Large Mechanical Contractor General Contractor Consumer

Manufacturer Consumer National Account Wholesaler Small Mechanical Contractor Consumer

Manufacturer

Large Mechanical Contractor Consumer

New Construction Replacements63 

# Markups Analysis 

# Markups Analysis: Markup Types

• Baseline Markups

– Relate the MSP of baseline equipment to the customer purchase price.

– Indicate a customer price that covers the wholesaler’s expenses plus profit.



## • Incremental Markups

– Relate the increase in MSP of more efficient equipment to the increase in customer purchase price.

– Cover only expenses that vary with MSP, in this case, expenses that increase due to an efficiency standard

.



## • DOE applies baseline markups to the MSP of the baseline level, and the incremental markups to the incremental difference in MSP at each level above the baseline.64 

# Markups Analysis: Distribution Channels

Distribution Channel Share of Market

New Construction, Small Mechanical Contractor 10.0%

New Construction, Large Mechanical Contractor 6.5%

New Construction, National Account 3.5%

Replacement, Small Mechanical Contractor 40.0%

Replacement, Large Mechanical Contractor 26.0%

Replacement, National Account 14.0% 

## The CUAC and CUHP market has six primary distribution channels65 

# Markups Analysis 

# Markups Analysis: Overall Markups

Distribution Channel Replacement New Construction
Baseline Incremental Baseline Incremental
Manufacturer* 1.34 1.34 1.34 1.34
Wholesaler 1.36 1.10 1.36 1.10 Mechanical Contractor (large/small) 1.38 / 1.58 1.10 / 1.26 1.30 / 1.50 1.04 / 1.20
General Contractor

-- -- 1.31 1.20
Sales Tax 1.07 1.07

-- -- Overall (large/small contractor) 2.68 / 3.08 1.75 / 2.00 3.10 / 3.58 1.84 / 2.12
National Account** 1.96 1.42 2.20 1.50



### * Markup is for large equipment class (135

- 240 kBtu/h); markup varies by equipment class (lower for small and higher for very large)

** National account markup is one

- half of that of the overall markup for the corresponding distribution channel66 

# Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks67 

# Life

- Cycle Cost (LCC) and Payback Period (PBP) Analysis

Purpose

• Provide an economic evaluation from the consumer’s perspective.

• Life

- Cycle Cost (LCC) is the total consumer cost over the life of the equipment.

• Payback Period (PBP) is the time required to recover the increased purchase price of more energy

- efficient equipment through reduced operating costs

. 

## Method

• Use consumer samples developed in the energy use analysis.

• Determine total installed costs for each efficiency level (EL).

• Determine first

- year and equipment lifetime operating costs

.

• Calculate PBP by dividing average increase in installed cost by average decrease in first

- year operating cost.

• Calculate LCC by adding installed cost and lifetime operating costs.

• Calculate LCC savings by subtracting LCC of each EL from LCC of the EL that customer would purchase in the absence of a new standard

.68 

## • Consumer samples were based on the generalized building sample developed in the energy use analysis for each of the three CUAC equipment classes.

• Each consumer has a unique energy use and energy price.

• Other inputs (e.g. discount rates and lifetimes) are characterized by probability distributions

.

• Monte Carlo sampling was used to create a consumer list with variable values for these inputs

. 

# LCC and PBP Analysis: Consumer Sample69 

# LCC and PBP Analysis: Total Installed Cost

• Total Installed Cost is the sum of equipment price and installation cost.

• Equipment price provided by Markups A nalysis

.

• Constant real prices used to project CUAC and CUHP equipment prices.

- Producer Price Index (PPI) series for “unitary air

- conditioners, except heat pumps” spanning 1978 to 2013 was analyzed to forecast future equipment prices; no discernable long

- term declining trend.



## • Installation costs represent the labor and materials necessary to install the equipment

• Costs based on RS Means

.

• Installation costs are assumed to increase proportionally with equipment weight, which increases with efficiency level. Therefore installation costs are assumed to vary by efficiency level.70 

### • Annual energy savings provided by Energy U se A nalysis.

• Electric utility tariff data used to develop average and marginal electricity prices

.

– Average electricity prices and marginal energy and demand prices developed for nine Census Divisions and California.

– Baseline energy bill determined by multiplying energy consumption by average price.

– Energy bill savings determined by multiplying energy savings by marginal energy price and demand reduction by demand price.



### • DOE used Annual Energy Outlook (AEO) 2013 for projections of future average energy prices for each census division. 

# LCC and PBP Analysis: Annual Energy Cost

Region Average Electricity Price ¢/kwh Marginal Demand Price $/kW Marginal Consumption Price ¢/kwh annual summer winter annual summer winter annual summer winter New England 14.91 15.56 14.22 12.14 13.96 10.85 9.64 9.75 9.47 Mid

- Atlantic 15.27 15.92 14.59 12.69 13.77 11.87 9.27 9.58 9.00 East North Central 12.36 12.59 12.00 12.54 13.25 12.00 6.28 6.36 6.18 West North Central 7.80 8.30 7.41 5.55 6.33 4.98 5.53 5.86 5.28 South Atlantic 10.16 10.10 10.12 7.94 8.17 7.79 7.03 7.00 7.02 East South Central 8.46 8.11 8.73 6.90 7.25 6.67 5.72 5.58 5.80 West South Central 7.65 8.25 6.97 3.92 4.38 3.57 5.87 6.44 5.20 Mountain 10.35 10.35 10.25 7.87 8.04 7.72 7.12 7.12 7.11 Pacific

– WA,OR 6.93 7.01 6.84 2.59 2.59 2.58 5.51 5.50 5.51 Pacific

– CA 16.41 17.50 15.28 6.80 9.36 4.49 12.15 12.35 11.77 US Average 11.17 11.52 10.75 8.33 9.11 7.71 7.34 7.53 7.1271 

## • Maintenance costs represent the labor and materials necessary to maintain the equipment

– Costs based on RS Means

.

– Maintenance costs do not increase with efficiency of the equipment.

• Repair costs are associated with repairing or replacing components that have failed.

– Routine repairs were included in maintenance costs.

– One

- time cost for major repair (for compressor replacement) included as part of the repair vs. replacement decision in the Shipments Analysis. 

# LCC and PBP Analysis: Maintenance and Repair Costs72 

# Request for Comment

Issue 10: DOE requests comments on the use of RS Means cost data to develop maintenance, repair, and installation costs for CUAC and CUHP equipment. If not appropriate, DOE requests information and data that can be used to estimate these costs.73 

## • ASHRAE database served as source of information for CUAC equipment lifetime.

– Included 215 packaged rooftop units listed as in service, with a median age of 16 years.

– Five units that had been replaced had a median age of 22 years.

– Data suggest that median lifetime is longer than 15 years.



## • Shipments Model calibration yielded equipment lifetimes based on a Weibull probability distribution.

– CUAC: median value = 18.7 years.

– CUHP: median value = 15.4 years

. 

# LCC and PBP Analysis: CUAC and CUHP Equipment Lifetime74 

# Request for Comment

Issue 11: DOE requests comments , information and data on the equipment lifetimes developed for CUAC and CUHP equipment. Specifically , any information that would indicate whether the retirement functions yielding median lifetimes of 18.7 years and 15.4 years for CUAC and CUHP equipment, respectively, are reasonable.75 

### • Used to convert streams of annual operating expenses to the year of purchase (i.e., 2019).

• Estimated as the weighted average cost of capital using capital asset pricing model (CAPM).

• Damodaran Online is a source of information about company debt and equity financing.

– Financial cost of any debt incurred to purchase equipment

– Opportunity cost of any equity to purchase equipment



### • Discount rates were estimated for the types of firms on whose premise a CUAC or CUHP is located.

– Sectors for which discount rates were developed: Retail, Property Owners, Medical Services, Lodging, Food Service, Offices, Industrial, and Public

– Weighed

- average real discount rate = 4.66% 

# LCC and PBP Analysis: Discount Rates76 

### • LCC and PBP analysis typically analyzes standard levels relative to a baseline efficiency level.

– Not all consumers purchase products at baseline levels.



### • Base case efficiency distributions define the percentage of products being purchased at various efficiency levels.

– Consumers already purchasing products at efficiencies greater than or equal to a prospective standard level are not impacted by the standard.

– Allows more accurate estimation of consumer impacts.



### • EER market share data from 1999

- 2001 were used as a basis for the base case distribution.

– EERs were mapped into IEERs using the same method as the Engineering Analysis.



### • Historical IEER market shares and the Shipments model were used to estimate base case efficiency in the year of compliance (2019). 

# LCC and PBP Analysis: Energy Efficiency in the Base Case

Small CUAC : ≥65,000 Btu/h and < 135,000 Btu/h Large CUAC: ≥ 135,000 Btu/h and < 240,000 Btu/h Very Large CUAC: ≥ 240,000 Btu/h and < 760,000 Btu/h
IEER Market Share IEER Market Share IEER Market Share 11.4 61% 11.2 78% 10.1 63% 12.9 39% 12.2 20% 11.6 24% 14.0 0% 13.2 2% 12.5 7% 14.8 1% 14.2 0% 13.5 4% 19.9 0% 18.4 0% 15.5 1%77 

# Request for Comment

Issue 12: DOE requests comments, information and data on the base case efficiency distributions of CUAC equipment. Given that historical market share efficiency data from 1999

– 2001 were used to inform a consumer choice model in the shipments analysis to develop estimated base case efficiency distributions in the compliance year (2019), DOE seeks more recent historical market share efficiency data that would be useful for validating the estimated base case efficiency distributions.78 

# LCC and PBP Analysis: Results

Efficiency Level IEER Life

- Cycle Cost Life

- Cycle Cost Savings

Payback Period years Total Installed Cost $ Average Lifetime Operating Cost $ Average Life

cycle Cost $ Average Savings $ Percent of Consumers With Net Cost

1 12.2 14,935 32,143 47,078 1,038 3% 6.0

2 13.2 16,858 29,021 45,880 2,214 8% 7.2

3 14.2 17,753 26,866 44,619 3,469 6% 6.6

4 18.4 18,975 21,599 40,575 7,508 2% 5.179 

# Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks80 

## Purpose

• To estimate CUAC and CUHP shipments over the 30

- year analysis period (2019

- 2048 ).

• Shipments are inputs to National Impact Analysis and Manufacturer Impact Analysis. 

## Method

• Develop an equipment stock accounting model which tracks shipments for replacements, new construction, and existing buildings that do not already utilize the equipment.

• Deduce a historical repair rate from comparing the model’s estimate of historical shipments to actual shipments.

• Use historical equipment price and repair cost data to estimate how repair rates change as a function of efficiency. 

# Shipments Analysis81 

# Shipments Analysis: Overview

• The goal of the shipments model is to estimate the annual shipments of covered equipment in the reference case and for each EL

– Shipments drop under the standards case due to increased equipment price

– Lower shipments imply more people are repairing equipment that fails



### • Each equipment class is modeled separately using the same approach

• Total Shipments in each year, S = S N 

### + S E 

### + S R

– S N = new installations in new buildings

– S E = new installations in existing buildings (that did not previously use the equipment)

– S R = replacement installations in existing buildings



### • Equipment stock U is the number of units in all buildings

– Function of age (a) and the analysis year (y) with 

### U(y, a=0) = S(y)



### • Total equipment stock is related to total commercial building floor space through a market saturation parameter (m) which may vary with time

– Total commercial floor space that may use the covered equipment is partitioned across the six equipment classes

– Time

- dependent market saturation follows an S

- curve82 

# Shipments Analysis: Modeling Approach

• S N 

### : new installations in new buildings

– Equal to market saturation parameter (m) x new construction floor space

– Floor space projections taken from the AEO (2013)



### • S E 

### : new installations in existing buildings

– Equal to the change in market saturation parameter (m) x existing floor space

– Existing floor space projections taken from AEO (2013)



### • S R 

### : replacement installations in existing buildings

– Depends on the equipment stock model

– Other inputs include a survival function (probability that a unit of age a will break down), and an econometric model for the repair

- replace decision

– Econometric model depends on the total installed cost (TIC), operating and maintenance costs (OM), and repair costs (RC)

– These costs vary by EL, changing the proportion of units repaired and the shipments



### • The shipments model also includes a disaggregation of total shipments into efficiency bins

– Based on a second econometric model83 

# Shipments Model: Inputs

• Model is calibrated to historical shipments

– Data submitted by ARI (1980

- 2001) for the 2005 rule; includes efficiency information for 1999

- 2001 only

– Economic census for 1969

- 1979 and 2002

- 2010 (no efficiency information)

• Floor

- space projections obtained from AEO 2013

• Market saturations estimates are based on CBECS 1992, 1995 and 1999

– CBECS 2003 has no equipment data for shopping malls

– CBECS 2012 not available

– Significant source of uncertainty

• Equipment price, operating and maintenance costs

– Historical values developed from price indices and previous rule

– LCC provides values for the starting year of the analysis period (2019)

– Future operating costs estimated using AEO electricity price trends

– No price trend on equipment cost

• Repair costs (compressor replacement) obtained from RS Means

– Assumed to be proportional to equipment cost at each EL

– Significant source of uncertainty

• Lifetime/Survival function

– Use a Weibull distribution to estimate the probability of survival as a function of age

– CUAC: median = 18.7 years

– CUHP: median = 15.4 years84 

# Shipments Model: Equipment Stock Model

• Assume we know the stock U(y,a); what happens in year y+1?

– Unit survives and ages to a+1

– Unit breaks and is not repaired => new unit is shipped (add 1 to S R )

– Unit breaks and is repaired



### • Number of units that break = (stock of age a )*(probability of failure at age a )

• Average historic repair rate r is calculated by running shipments model assuming no repairs and comparing to data

• Starting with the first year of the standard (2019) the repair probability changes

• Use a logit model to estimate the probability of repair as a function of costs

• Key variable is the difference between the cost of repair and the cost of a new unit

• Model doesn’t include the difference in operating costs

• For very large equipment all units are repaired once then replaced85 

# Shipments Model: Projected Base Case Shipments86 

# Shipments Model: Base Case and Standards Cases

Note: In the figure, EL2 is overlain by EL3.87 

# Shipments Model: Repairs v s Replacements88 

# Request for Comment

Issue 13: DOE requests comments and information relating to the inputs to the shipments model, particularly updated shipments, repair costs and equipment mechanical lifetimes.

Variation in repair costs as a function of equipment first cost and age would be especially useful.

DOE also requests comment on its approach to estimating the repair rate.89 

# Shipments Model: Efficiency Distributions

• Use a consumer choice model to segregate each year’s shipments by efficiency

• The model uses the logit form, with the product utility equal to the sum of the total installed cost (TIC) plus the first year’s operating and maintenance cost (OM)

• W = α *TIC + β *OM

• The parameters α and β describe the relative sensitivity of purchasers to first cost vs. operating costs

• These parameters are estimated by calibrating the model to historic data on efficiency distributions

• DOE‘s model results show that, based on available data, purchasers are relatively insensitive to operating costs

• Thus, the model predicts that most purchases are first cost driven

• Within the shipments model, these results are equivalent to a “roll

- up” scenario, where nearly everyone purchases the least

- cost compliant unit at each EL

• This also results in a flat population

- average efficiency trend over the analysis period90 

# Request for Comment

Issue 14: DOE requests comments and data regarding the mechanical lifetime of equipment (time to first failure), and the lifetime of repaired equipment (to the next repair), and how these vary with the age of the equipment. This information will allow DOE to refine its shipments model and repair rate estimates.

Issue 15: DOE requests comments or data on the repair rate for very large CUACs and CUHPs (≥ 240,000 Btu/h and <760,000 Btu/h). For this equipment, the shipments analysis assumed that all failing equipment is repaired once, and replaced the second time it fails.91 

## Purpose

• Determine the projected national energy savings and customer national net present value. 

## Method

• Develop annual series of national energy and economic impacts.

• Use the shipments model to estimate the total stock of CUACs and CUHPs in service each year.

• Aggregate the costs and energy use per unit in any given year.

• Report estimates for economic impact as change in consumer National Net Present Value (NPV) (in constant year dollars).

• Account for the time

- value of money through defined discount rates. 

# National Impact Analysis92 Shipments Model National Energy Savings National Economic Impacts LCC Analysis Results and Other Inputs National Energy Savings (Quads)

National Net Present Value (NPV) (2013 US $, billion)



### • National energy savings calculated for equipment shipped over the period from 2019

- 2048 (30 years of shipments).

• NPV calculated for equipment shipped over the period from 2019

- 2048 (30 years of shipments ). 

# National Impact Analysis: Process93 

# National Impact Analysis: National Energy Savings Flow Diagram94 

# National Impact Analysis: Consumer NPV Flow Diagram95 Input Description
Total Installed Cost CUAC: Weighted

- average per unit values as a function of efficiency level taken from the LCC analysis. CUHP: Baseline costs developed in Engineering Analysis and incremental costs for increased efficiency estimated to be the same as CUAC; installation costs same as CUAC. Repair and Maintenance Costs Maintenance costs taken from the LCC analysis; do not vary as a function of efficiency level; estimated to be the same for CUHP as for CUAC. Repair costs estimated based on RS Means; estimated to vary with efficiency; estimated to be the same for CUHP and CUAC. Annual Energy Use CUAC: Annual weighted

- average per unit values as a function of efficiency level taken from LCC analysis. CUHP: Cooling

- side energy use same as CUAC; heating

- side energy use taken from buildings using CUHPs in CBECS 2003; correlated COP and IEER based on AHRI database to obtain energy use as a function of efficiency level.

Base

- Case Efficiencies Shipments

- weighted efficiencies determined for the compliance year. Based on base

- case efficiency distribution from LCC analysis.
Standards

- Case Projected Efficiencies Projected by the Shipments Model.

Energy Prices Projected energy prices from EIA AEO 2013 forecasts (to 2040) and extrapolation to 2078. Full Fuel Cycle Multiplier to convert site energy to full

- fuel cycle energy.

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

- 4.

Present Year Future expenses are discounted to the year 2014. 

# National Impact Analysis: Inputs96 

# National Impact Analysis: Trial Standard Levels

TSL Formulation Criteria

1 Each equipment class moves up one efficiency level from the current baseline

2 Each equipment class moves up two efficiency levels from the current baseline

3 Each equipment class moves up three efficiency levels from the current baseline

4 Maximum technologically feasible level, maximum NPV and maximum NES. Ea ch equipment class moves up four efficiency level s from the current baseline97 

# National Impact Analysis: Trial Standard Levels

Equipment Class Efficiency Level Small Commercial Packaged Air Conditioners ≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 1 2 3 4

Large Commercial Packaged Air Conditioners ≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 1 2 3 4

Very Large Commercial Packaged Air Conditioners
≥ 240,000 Btu/h and <760,000 Btu/h Cooling Capacity 1 2 3 4

Small Commercial Packaged Heat Pumps
≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 1 2 3 4

Large Commercial Packaged Heat Pumps
≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 1 2 3 4

Very Large Commercial Packaged Heat Pumps ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 1 2 3 498 

# National Impact Analysis : National Energy Savings Results

Equipment Class quads Small Commercial Packaged Air Conditioners ≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 1.2 4.3 5.5 8.4

Large Commercial Packaged Air Conditioners ≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.8 1.8 2.6 3.8

Very Large Commercial Packaged Air Conditioners
≥ 240,000 Btu/h and <760,000 Btu/h Cooling Capacity 0.8 1.6 2.7 3.5

Small Commercial Packaged Heat Pumps
≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 0.1 0.5 0.7 1.0

Large Commercial Packaged Heat Pumps
≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.0 0.1 0.1 0.2

Very Large Commercial Packaged Heat Pumps ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 0.0 0.1 0.1 0.2



### TOTAL 3.0 8.4 11.8 17.1



## Cumulative Full Fuel Cycle National Energy Savings99 

# National Impact Analysis : Consumer NPV

Equipment Class Billion 2013$ Small Commercial Packaged Air Conditioners ≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 6.9 20.7 26 36.2
Large Commercial Packaged Air Conditioners ≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 3 6.8 9.7 15.6
Very Large Commercial Packaged Air Conditioners
≥ 240,000 Btu/h and <760,000 Btu/h Cooling Capacity 3.4 6.4 11 13.5
Small Commercial Packaged Heat Pumps
≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 0.8 2.3 3.1 4.2
Large Commercial Packaged Heat Pumps
≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.2 0.3 0.5 0.8
Very Large Commercial Packaged Heat Pumps ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 0.2 0.3 0.6 0.7



### TOTAL 14.4 36.9 50.8 71.0



## National Net Present Value at 3 % real discount rate100 

# National Impact Analysis : Consumer NPV

Equipment Class Billion 2013$ Small Commercial Packaged Air Conditioners ≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 2.5 7.1 9 11.8
Large Commercial Packaged Air Conditioners ≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.9 2 2.9 4.8
Very Large Commercial Packaged Air Conditioners
≥ 240,000 Btu/h and <760,000 Btu/h Cooling Capacity 1 1.8 3.3 3.9
Small Commercial Packaged Heat Pumps
≥ 65,000 Btu/h and <135,000 Btu/h Cooling Capacity 0.3 0.8 1.1 1.5
Large Commercial Packaged Heat Pumps
≥ 135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.1 0.1 0.2 0.3
Very Large Commercial Packaged Heat Pumps ≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 0.1 0.1 0.2 0.2



### TOTAL 4.8 11.9 16.5 22.5



## National Net Present Value at 7% real discount rate101 

# Request for Comment

Issue 16: DOE requests comments on its decision to not include a rebound effect for more efficient CUAC and CUHP.

Issue 21: DOE analyzed the effects of potential standards on equipment purchased over a 30

- year period, and it undertook a sensitivity analysis using 9 years rather than 30 years of product shipments. The choice of a 30

- year period of shipments is consistent with the DOE analysis for other products and commercial equipment . The choice of a 9

- year period is a proxy for the timeline in EPCA for the review of certain energy conservation standards and potential revision of, and compliance with , such amended standards. DOE is seeking input on ways to refine the analytical timeline.102 

# Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering;

4 Energy Use; Markups Analysis;

5 Life

- Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks103 

## Purpose:

• Assess the impacts of potential energy conservation standards on manufacturers.

• Identify and estimate impacts on manufacturer subgroups that may be more severely affected than the industry as a whole.

• Examine the direct employment, product competition, manufacturing capacity, and cumulative regulatory impacts on the industry.



## Methodology:

• Analyze industry cash flow and industry net present value (INPV) through use of the Government Regulatory Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop subgroup analyses, and address qualitative issues. 

# Manufacturer Impact Analysis104 

## • Certification and testing

– Definition of basic model

– Implementation of AEDMs

– Cost of I EER testing



## • Impact of standard on repair rates

– Increase in prices will lead more customers to choose to repair older units

– Impacts on industry profitability as well as energy savings



## • Alignment with industry standards

– ASHRAE 

# Key Issues105 

## • Phase 1

– DOE creates an industry profile to characterize the market and identify important issues that require further investigation.



## • Phase 2

– DOE prepares an industry cash flow model and an interview questionnaire to guide subsequent discussions with manufacturers.



## • Phase 3

– DOE interviews manufacturers and assesses the impacts of standards both quantitatively (using the GRIM) and qualitatively (impacts on employment, competition, manufacturing capacity, and regulatory burden). 

# Manufacturer Impact Analysis106 

## Industry Cash Flow Model

• Upstream Inputs

– Market and Technology Assessment (MTA) Industry Profile

– Engineering MPCs

– Shipments



## • MIA Inputs

– Markup Scenarios

– Conversion Costs 

# Manufacturer Impact Analysis107 

## Markup Scenarios

– Preservation of Gross Margin Percentage

– Preservation of Operating Profit 

# Manufacturer Impact Analysis

High

- Volume Product Classes Pres. Of Gross Margin Scenario Pres. Of Operating Profit Scenario (TSL 3) Small Commercial Packaged Air

- Conditioners 1.30 1.27 Small Packaged Heat Pumps 1.30 1.28 Large Commercial Packaged Air

- Conditioners 1.34 1.31 Large Commercial Packaged Heat Pumps 1.34 1.36 Very Large Commercial Packaged Air

- Conditioners 1.41 1.37 Very Large Commercial Packaged Heat Pumps 1.41 1.37108 

### Industry Conversion Costs total $226.4 M over 4 years at TSL 3 

# Manufacturer Impact Analysis

Product Conversion Cost Capital Conversion Cost Industry Total

TSL 1 $38.7 $14.9 $53.6

TSL 2 $58.5 $39.2 $97.7

TSL 3 $120.9 $105.5 $226.4

TSL 4 $210.9 $113.3 $324.2109 

# Manufacturer Impact Analysis

Base Case TSL 1 TSL 2 TSL 3 TSL 4

INPV ($M) 1,260.9 1,187.0 to 1,249.5 1,015.6 to 1,208.0 949.3 to 1,172.4 822.8 to 1,142.7

Change in INPV ($M) - (73.9) to (11.5) (245.3) to (52.9) (311.6) to (88.6) (438.2) to (118.1)

Change in INPV (%) - (5.9) to (0.9) (19.5) to (4.2) (24.7) to (7.0) (34.8) to (9.4)

Conversion Costs ( $M) 12.7 53.7 97.8 226.4 324.3 

## INPV Results

Summary of TSL 3

• Expected INPV change in the range of

- 24.7% to

- 7.0%

• Expected conversion costs total $226.4M for the industry110 

## Small Business Impacts

• 3 small manufacturers identified

• Small manufacturers could have differential impacts relative to larger competitors due to the following:

– Product conversion and certification costs tend to be fixed and do not scale with sales volume

– Small manufacturers have fewer engineering and testing resources

– Small manufacturers lack purchasing power for critical components

• Comparison of Conversion Costs 

# Manufacturer Impact Analysis

TSL 3 Average Large Manufacturer Average Small Manufacturer *

Conversion Costs as a % of Annual Revenue 19% 49%

*DOE assumed small manufacturers account for 5% of industry revenue111 

# Request for Comment

Issues 22

- 24: DOE seeks comment on the number of small manufacturers; on the potential impacts of new energy conservation standard on those small manufacturers; and on the severity of those impacts.

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD112 

## Purpose

• To evaluate the economic impacts of standards on customer subgroups who may be disproportionately impacted compared with the general user population.


## Method

• DOE identified small businesses in six building types from the building sample: assembly, small education, food services, small office, retail, and warehouses.

– The small business subgroup represents approximately 80% of floor space in the building sample.



### • DOE applied a small company discount rate premium in the LCC and PBP analysis instead of the sector average discount rates.


## Results

• LCC and PBP results were not appreciably different than for the general population. 

# LCC Subgroup Analysis113 

# Emissions Impact Analysis Purpose

• To estimate the emissions reductions resulting from amended energy conservation standards.

– Includes estimating considers full

- fuel

- cycle emissions; both power plant emissions and “upstream” emissions.

– Includes fugitive methane emissions. 

## Method

• National Impact Analysis provides an annual time

- series of energy savings over the analysis period.

• Energy Information Administration’s National Energy Modeling System (NEMS) is modified to represent the impacts of amended standards (modified code is known as NEMS

- BT ). 

## Results

TSL 1 TSL 2 TSL 3 TSL 4
CO 2 (million metric tons) 271 770 1085 1565
SO 2 (thousand tons) 727 2083 2934 4243
NO X (thousand tons) 252 725 1021 1477 Hg (tons) 0.89 2.53 3.57 5.16
N 2 O (thousand tons) 3.8 11 15.5 22.4
CH 4 (thousand tons) 772 2181 3072 4427114 

# Emissions Monetization

• DOE used the most current Social Cost of Carbon (SCC) values developed by interagency process.

– SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, agricultural productivity loss, human health effects, property damage from rising sea levels, and changes in the ecosystem.



### • The most recent (2013) U.S. government interagency estimates of the 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 rate)



### • The SCC in constant dollars increases over time.

• DOE also monetizes the NO x 

### emissions reductions resulting from amended standards.

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

– DOE calculated monetary benefits using a medium value of $2,684 per short ton.115 

# Emissions Monetization: Results

Full Fuel Cycle Emissions Reduction Benefits (million 2013$)

TSL 1 TSL 2 TSL 3 TSL 4

CO 2 1,564 to 24,219 4,350 to 68,057 6,127 to 95,856 8,794 to 137,933

NO x 3 % discount rate 267 753 1,060 1,527

NO x 7 % discount rate 89 243 343 490116 

# Request for Comment

Issue 18: DOE requests comment on the application of the new SCC values used to determine the social benefits of CO2 emissions reductions over the rulemaking analysis period. In particular , the agency solicits comment on its derivation of SCC values after 2050 , where the agency applied the average annual growth rate of the SCC estimates in 2040

– 2050 associated with each of the four sets of values.117 

# Utility Impact Analysis

Purpose

• To estimate the changes in electric installed capacity and generation that result from amended energy conservation standards

. 

## Method

• National Impact Analysis provides an annual time

- series of energy savings over the analysis period.

• Energy Information Administration’s National Energy Modeling System (NEMS) is modified to represent the impacts of amended standards (modified code is known as NEMS

- BT). 

## Output

• Reductions in total electricity generation.

• Reductions in primary fuel (e.g. coal, natural gas) consumption.

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

• Changes to total installed capacity.118 

# Employment Impact Analysis

Purpose

• To estimate the national net impact on jobs as a consequence of amended energy conservation standards, including indirect employment impacts. 

## Method

• Uses the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect employment impacts; direct employment impacts to the commercial air conditioning industry are developed in the Manufacturer Impact Analysis.

• The changes in national equipment and energy expenditures are taken from the National Impact Analysis and entered as inputs into ImSET. 

## Results

• Net labor market impacts are negligible over time due to the small magnitude of the short

- term effects.119 

# Regulatory Impact Analysis

Purpose

• To investigate the national impacts of non

- regulatory alternatives to mandatory amended energy conservation standards. 

## Method

• DOE modified the NIA spreadsheet to analyze the following non

regulatory alternatives and their impact on purchase price and energy
use.



## Output

• National Energy Savings and Net Present Value for the non

- regulatory alternatives. • No new regulatory action • Manufacturer tax credits

• Customer rebates • Voluntary efficiency targets

• Customer tax credits • Bulk government procurement

Details of the Analysis can be found in chapter 18 of the TSD.120 

# Closing Remarks121 

# How to Submit Written Comments

• In all correspondence, please refer to the CUAC/CUHP rulemaking by:

– Small, Large, and Very Large Air

- Cooled Commercial Package Air Conditioning and Heating Equipment Energy Conservation Standards Rulemaking,

– Docket Number EE

- 2013

- BT

- STD

- 0007 , and

– Regulatory Identification Number (RIN) 1904

- AC95.

• Email : CommPkgACHP2013STD0007@ee.doe.gov

• Comment period closes: December 1, 2014, 11:59 PM EST

Postal: Courier: Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE

- 2J 1000 Independence Avenue, SW Washington, DC 20585

- 0121 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Suite 600 950 L’Enfant Plaza, SW Washington, DC 20024 Tel: 202 586

- 2945122 

# Supporting Material123 

## Technology Options Identified for Market & Technology Assessment124 

# Technology Assessment: Technologies Identified

Technology Options
Heat transfer improvements:

• Electro

- hydrodynamic enhancement Alternative refrigerants Condenser and evaporator fan and fan motor improvements:

• Larger fan diameters

• More efficient fan blades (e.g., air foil centrifugal evaporator fans, backward

- curved centrifugal evaporator fans, high efficiency propeller condenser fans)

• High efficiency motors (e.g., copper rotor motor, high efficiency induction, permanent magnet, electronically commutated)

• Variable speed fans/motors Larger heat exchangers125 

# Technology Assessment: Technologies Identified

Technology Options (cont.)
Compressor Improvements

• High efficiency compressors

• Multiple compressor staging

• Multiple

- tandem or variable

- capacity compressors Thermostatic expansion valves
Electronic expansion valves

Sub

- coolers

Reduced indoor fan belt loss:

• Synchronous (toothed) belt

• Direct

- drive fans126 

## Determination of Incremental Heating Efficiency Levels for CUHP127 

# COP Efficiency Levels for CUHP

• Relationship between EER and COP for small CUHP, ≥65,000 Btu/h and <135,000 Btu/h cooling capacity
, electric heat/no heating equipment class

.128 

# COP Efficiency Levels for CUHP

• Relationship between EER and COP for large CUHP, ≥135,000 Btu/h and <240,000 Btu/h cooling capacity
, electric heat/no heating equipment class

.129 

# COP Efficiency Levels for CUHP

• Relationship between EER and COP for very large CUHP, ≥240,000 Btu/h and <760,000 Btu/h cooling capacity
, electric heat/no heating equipment class

.130 

# COP Efficiency Levels for CUHP

• Relationship between IEER and COP for small CUHP, ≥65,000 Btu/h and <135,000 Btu/h cooling capacity
, electric heat/no heating equipment class

.131 

# COP Efficiency Levels for CUHP

• Relationship between IEER and COP for large CUHP, ≥135,000 Btu/h and <240,000 Btu/h cooling capacity
, electric heat/no heating equipment class

.132 

# COP Efficiency Levels for CUHP

• Relationship between IEER and COP for very large CUHP, ≥240,000 Btu/h and <760,000 Btu/h cooling capacity
, electric heat/no heating equipment class

.133 

## Design Options and Energy Modeling Results for Analyzed Equipment Categories134 

# Design Options for Incremental Efficiency Levels

• Design options for 7.5

- Ton CUAC units

• Design options for 15

- ton CUAC units ID Airflow OD Airflow

# Basis IEER Ref. Circuit # of Comp. Type Stage Capacity ratio Speed Type Face

area [ft^2] Fin pitch Rows Stage Type Fin pitch Face

area [ft^2] Row Stage

Baseline Modeling 11.4 1 circuit 1 Scroll 1 100 Fixed Tube-fin 7.2 15 3 1 Tube-fin 17 16.6 2 1

EL1 Teardown / Testing 12.9 1 circuit 1 Scroll 1 100 Fixed Tube-fin 8.9 15 3 1 Tube-fin 17 20.5 2 1

EL2 Teardown / Testing 14.0 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 11.1 15 4 1 Tube-fin 17 25.1 2 1

EL3 Modeling 14.8 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 11.1 15 4 VS Tube-fin 17 25.1 2 2

EL4 Modeling with Published Manuf. Data 19.9 1 circuit 2 Scroll 3 64/36 Fixed Tube-fin 17.5 15 4 VS Tube-fin 18 36.1 2 3 Efficiency Level Compressor Indoor Heat Exchanger Outdoor Heat Exchanger

ID Airflow OD Airflow

# Basis IEER Ref. Circuit # of Comp. Type Stage Capacity ratio Speed Type Face

area [ft^2] Fin pitch Rows Stage Type Fin pitch Face

area [ft^2] Row Stage

Baseline Modeling 11.2 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 16.2 15 3 1 Tube-fin 21 26.6 2 1

EL1 Modeling 12.2 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 24.5 15 3 1 Tube-fin 21 40.4 2 1

EL2 Testing 13.2 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 22.0 15 4 1 Tube-fin 17 42.8 2 1

EL3 Modeling 14.2 2 circuits 2 Scroll 2 55/45 Fixed Tube-fin 22.0 15 4 VS Tube-fin 17 42.8 2 2

EL4 Modeling with Published Manuf. Data 18.4 1 circuit 2 Scroll 3 64/36 Fixed Tube-fin 26.4 15 4 VS Tube-fin 18 59.2 2 3 Efficiency Level Compressor Indoor Heat Exchanger Outdoor Heat Exchanger135 

# Design Options for Incremental Efficiency Levels

• Design options for 30

- Ton CUAC units

ID Airflow OD Airflow

# Basis IEER Ref. Circuit # of Comp. Type Stage Capacity ratio Speed Type Face

area [ft^2] Fin pitch Rows Stage Type Fin pitch Face

area [ft^2] Row Stage

Baseline Modeling 10.1 2 circuits 4 Scroll 2 25/25/ 25/25/ Fixed Tube-fin 21.9 15 4 1 Microchannel 23 23.0 1 1

EL1 Modeling 11.6 2 circuits 4 Scroll 2 25/25/ 25/25/ Fixed Tube-fin 31.3 15 4 1 Microchannel 23 32.9 1 2

EL2 Modeling 12.5 2 circuits 4 Scroll 2 25/25/ 25/25/ Fixed Tube-fin 31.3 15 4 1 Microchannel 23 46.1 1 2

EL3 Modeling 13.5 2 circuits 4 Scroll 4 25/25/ 25/25/ Fixed Tube-fin 31.3 15 4 VS Microchannel 23 46.1 1 2

EL4 Modeling with Published Manuf. Data 15.5 2 circuits 4 Scroll 4 25/25/ 25/25/ Fixed Tube-fin 31.6 15 4 VS Microchannel 23 68.4 1 4 Efficiency Level Compressor Indoor Heat Exchanger Outdoor Heat Exchanger136 

# Design Option Energy Modeling Results

• Detailed energy modeling performance data for 7.5

- ton incremental efficiency levels at different loading conditions.137 

## • Detailed energy modeling performance data for 15

- ton incremental efficiency levels at different loading conditions. 

# Design Option Energy Modeling Results138 

## • Detailed energy modeling performance data for 30

- ton incremental efficiency levels at different loading conditions. 

# Design Option Energy Modeling Results