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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

TABLE OF CONTENTS

12A.1 PORTABLE AIR CONDITIONERS ............................................................................1
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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

12A.1 PORTABLE AIR CONDITIONERS

Portable Air Conditioner Rulemaking 

Manufacturer Impact Analysis Interview Guide
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QUESTIONS FOR ENGINEERING ANALYSIS 

AND PRELIMINARY 

MANUFACTURER IMPACT ANALYSIS

DOE would like to confirm information on the incremental costs of increasing product efficiency 

by understanding the design options involved in the efficiency improvement. 

1. Which design features impacting energy use are generally incorporated into a “baseline” 

portable air conditioner in the following product classes:

a. Single-Duct Portable Air Conditioner, ≤ 8,000 Btu/h?

b. Single-Duct Portable Air Conditioner, 8,001 – 10,000 Btu/h?

c. Single-Duct Portable Air Conditioner, 10,001 – 12,000 Btu/h?

d. Single-Duct Portable Air Conditioner, 12,001 – 14,000 Btu/h?

e. Single-Duct Portable Air Conditioner, > 14,000 Btu/h?

f. Dual-Duct Portable Air Conditioner, ≤ 8,000 Btu/h?

g. Dual-Duct Portable Air Conditioner, 8,001 – 10,000 Btu/h?

h. Dual-Duct Portable Air Conditioner, 10,001 – 12,000 Btu/h?

i. Dual-Duct Portable Air Conditioner, 12,001 – 14,000 Btu/h?

j. Dual-Duct Portable Air Conditioner, > 14,000 Btu/h?

k. Spot Coolers, ≤ 12,000 Btu/h?

l. Spot Coolers, 12,001 – 14,000 Btu/h?

m. Spot Coolers, > 14,000 Btu/h?

2. Are there other product classes that DOE should consider? Should DOE consider 

combining or splitting any of these product classes?

3. DOE is proposing to analyze the following efficiency levels for the proposed product 

classes:
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Single-Duct Portable Air Conditioners

Level

Efficiency 

Level 

Source

Efficiency Levels (EER)

≤ 8,000 Btu/h 8,001-10,000 

Btu/h

10,001-

12,000 Btu/h

12,001-14,000 

Btu/h

> 14,000 Btu/h

Baseline Minimum 

Available 7.0 8.05 8.09 8.19 9.87

1 Gap Fill

(10,001-

12,000 and 

12,001-

14,000)/

Max 

Available 

for other 

product 

classes

8.0 9.0 9.0 9.0 11.0

2 9.0 10.0 10.0 10.0 12.47

3 10.0 11.0 11.0 11.0 --

4 10.8 11.6 12.0 12.0

--

5

Maximum 

Available -- -- 12.63 12.8 --

Dual-Duct Portable Air Conditioners
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Level

Efficiency 

Level 

Source

Efficiency Levels (EER)

≤ 8,000 Btu/h 8,001-10,000 

Btu/h

10,001-12,000

Btu/h

12,001-14,000 

Btu/h

> 14,000 Btu/h

Baseline Minimum 

Available 9.0 9.2 8.78 8.9 9.87

1

Gap Fill

(12,001-

14,000)/

Max 

Available 

for other 

product 

classes

9.5 9.5 9.0 9.5 11.0

2 10.0 10.09 10.0 10.0 12.47

3 -- -- 10.9 11.0 --

4

Maximum 

Available -- -- -- 11.7 --

Spot Coolers

Level

Efficiency 

Level Source

Efficiency Level (EER)

≤ 12,000 Btu/h 12,001-14,000 Btu/h > 14,000 Btu/h

Baseline Minimum 

Available 9.54 10.0 9.87

1

Gap Fill

(12,001-

14,000 and 

>14,000)/

Max 

Available 

(≤12,000)

10.09

10.5 11.0

2

Maximum 

Available 11.17 12.47
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1. Do you agree with the proposed efficiency levels?

a. Do you believe that the gap-fill efficiency levels defined by DOE as shown above 

are appropriate? If not, can you suggest appropriate gap-fill values?

2. If you believe that other portable air conditioner product classes should be analyzed, can 

you suggest baseline, max-tech, and if necessary, gap fill efficiency levels for those 

product classes?

Single-Duct Portable Air Conditioners

3. Which design changes are associated with converting a baseline single-duct portable <

8,000 Btu/hr air conditioner (7.0 EER) to efficiency level 1 (8.0 EER)? To efficiency 

level 2 (9.0 EER)? To efficiency level 3 (10.0 EER)? To the maximum level (10.8 EER)? 

What are the costs of the individual design options selected?

4. Which design changes are associated with converting a baseline single-duct portable 

8,001-10,000 Btu/h portable air conditioner (8.05 EER) to efficiency level 1 (9.0 EER)? 

To efficiency level 2 (10.0 EER)? To efficiency level 3 (11.0 EER)? To the maximum 

available level (11.6 EER)? What are the costs of the individual design options selected?

5. Which design changes are associated with converting a baseline single-duct portable 

10,001-12,000 Btu/hr air conditioner (8.09 EER) to efficiency level 1 (9.0 EER)? To 

efficiency level 2 (10.0 EER)? To efficiency level 3 (11.0 EER)? To efficiency level 4 

(12.0 EER)? To the maximum available level (12.63 EER)? What are the costs of the 

individual design options selected?

6. Which design changes are associated with converting a baseline single-duct portable 

12,001-14,000 Btu/hr air conditioner (8.19 EER) to efficiency level 1 (9.0 EER)? To 

efficiency level 2 (10.0 EER)? To efficiency level 3 (11.0 EER)? To efficiency level 4 

(12.0 EER)? To the maximum available level (12.8 EER)? What are the costs of the

individual design options selected?

7. Which design changes are associated with converting a baseline single-duct portable 

>14,000 Btu/h air conditioner (9.87 EER) to efficiency level 1 (11.0 EER)? To the 

maximum available level (12.47 EER)? What are the costs of the individual design 

options selected?

Dual-Duct Portable Air Conditioners

8. Which design changes are associated with converting a baseline dual-duct portable <

8,000 Btu/hr air conditioner (9.0 EER) to efficiency level 1 (9.5 EER)? To the maximum 

level (10.0 EER)? What are the costs of the individual design options selected?
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9. Which design changes are associated with converting a baseline dual-duct portable 8,001-

10,000 Btu/h portable air conditioner (9.2 EER) to efficiency level 1 (9.5 EER)? To the 

maximum available level (10.09 EER)? What are the costs of the individual design 

options selected?

10. Which design changes are associated with converting a baseline dual-duct portable

10,001-12,000 Btu/hr air conditioner (8.78 EER) to efficiency level 1 (9.0 EER)? To 

efficiency level 2 (10.0 EER)? To the maximum available level (10.9 EER)? What are the 

costs of the individual design options selected?

11. Which design changes are associated with converting a baseline dual-duct portable 

12,001-14,000 Btu/hr air conditioner (8.9 EER) to efficiency level 1 (9.5 EER)? To 

efficiency level 2 (10.0 EER)? To efficiency level 3 (11.0 EER)? To the maximum 

available level (11.7 EER)? What are the costs of the individual design options selected?

12. Which design changes are associated with converting a baseline dual-duct portable 

>14,000 Btu/h air conditioner (9.87 EER) to efficiency level 1 (11.0 EER)? To the 

maximum available level (12.47 EER)? What are the costs of the individual design 

options selected?

Spot Coolers

13. Which design changes are associated with converting a baseline spot cooler <12,000 

Btu/hr (9.54 EER) to the maximum available level (10.09 EER)? What are the costs of 

the individual design options selected?

14. Which design changes are associated with converting a baseline spot cooler 12,001-

14,000 Btu/h (10.0 EER) to efficiency level 1 (10.5 EER)? To the maximum available 

level (11.17 EER)? What are the costs of the individual design options selected? 

15. Which design changes are associated with converting a baseline spot cooler > 14,000 

Btu/h (9.87 EER) to efficiency level 1 (11.0 EER)? To the maximum available level 

(12.47 EER)? What are the costs of the individual design options selected? 

16. Are there fundamental differences between required design changes that could make the 

cost increment higher for some product classes than others, in particular between the 

portable greater than 14,000 Btu/hr and spot coolers product classes?

General

17. Are there fundamental design differences between portable air conditioners and spot 

coolers?

18. Are there fundamental design differences between portable air conditioners to be used 

mainly for residential applications versus commercial applications?
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19. Are there additional design options not mentioned in the sections above that may be used 

to improve portable air conditioner efficiencies? What are the costs and efficiency gains 

associated with these design options?

20. Do you test your products according to any of the available industry test methods? Are 

any of these test methods appropriate for rating the energy efficiency of portable air 

conditioners? What are the limitations associated with the industry test methods?

21. Do you collect consumer use data for portable air conditioners?

22. What are the typical ambient conditions for each of the operating modes available on 

your products? What are the maximum/minimum ambient conditions?

PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS

1 Issues

1.1 What are the key issues for your company regarding this portable air conditioner

rulemaking?

2 Shipment Projections

2.1 What is your company’s approximate market share in each of the product classes? 

2.2 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels?

2.3 How would you expect shipments to change for the industry as a whole as a function of 

standards and why?

2.4 Looking at price/cost effects only, how would you expect shipments to change for a 10%, 

25%, 50%, or 100% manufacturer price/cost increase?

3 Conversion Costs
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3.1 What level of capital expenditure and product conversion costs would you anticipate to 

make at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes.

3.2 How would the imposition of new energy conservation standards affect employment, 

capacity utilization and manufacturing assets at your domestic production facilities? Would 

a new standard result in stranded capital assets? Would any facilities be closed or 

downsized? Added or upgraded?

3.3 How might a new standard impact product innovation?

4 Product Mix and Profitability

4.1 How would your company’s product mix and marketing strategy change with a new

efficiency standard?

4.2 What distribution channels are used from the manufacturer to the retail outlet? What is the 

share of product going through each distribution channel?

4.3 Generally how would new product standards impact your customer mix, distribution 

channels, and corresponding profit margins?

4.4 What is the approximate percentage of shipments (i.e., market share) for each product, or 

more specifically, for each product class?

5 Market Shares and Industry Consolidation

5.1 In the absence of new standards, do you expect any industry consolidation?

5.2 How would new standards affect your ability to compete?

5.3 Could new standards disproportionately advance or harm the competitive positions of 

some firms?

5.4 Are there concerns over intellectual property?

5.5 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

5.6 Beyond price and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or 

other features?

6 Cumulative Regulatory Burden

6.1 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry?

6.2 If so, what is the total expected impact of those other regulations?