On May 18, 2011, representatives of Trane (Ingersoll Rand) met with DOE and Navigant 

Consulting to discuss DOE’s Request for Information on alternative efficiency determination methods 

(AEDMs) and alternative rating methods (ARMs), which was published on April 18, 2011. 76 FR 21673. 

This meeting was requested by Trane and occurred at their facility in Clarksville, Tennessee with the 

following people in attendance: 

Ashley Armstrong, DOE 

Jay Baggett, Trane 

Richard Bishop, Trane 

Richard Campbell, Trane 

Al Fullerton, Trane 

Andrew Geffken, Navigant Consulting 

Jill Hootman, Trane 

Ken Parks, Trane 

Jim VerShaw, Trane 

Roger Voorhis, Trane 

 The Trane representatives made several key points pertaining to issues in the Request for 

Information: 

1) AEDMs and ARMs are applicable to both residential and commercial heating, ventilation and airconditioning (HVAC)products, but Trane tests furnaces instead of using simulations because of 

safety concerns. Additionally, water heaters and boilers may be difficult to accurately model. 

2) The second round of substantiation testing for an AEDM to be applied to commercial HVAC and 

water heaters is unnecessary and sufficient accuracy can be achieved through a single round of 

testing. 

3) There is no added value in requiring pre-approval for either ARMs or AEDMs. This requirement 

would only add additional burden to the manufacturers and could lead to delays in making 

products available to consumers. 

4) The current 1% tolerance for overall averages between AEDM predicted efficiency and tested 

efficiency is exceedingly strict and unreasonable. A more appropriate tolerance is between 3% 

and 5%. 

5) Standardized tolerances across similar products are feasible, but a single standardized set for all 

products may not be. 

6) For low-volume, custom products, Trane believes that sufficient accuracy for substantiation can 

be accomplished by testing one unit. If necessary, a second unit could be tested, but not more than 

that because of the excessive costs of testing certain units. For example, the testing of a large 

HVAC unit can cost between $30,000 and $50,000. Additionally, 3rd party test labs are operating 

at close to capacity and may not be able to meet the new demand that would be created if DOE 

required more testing for substantiation of AEDMs and ARMs. 
7) When there is a change in standards, manufacturers should re-substantiate an AEDM or ARM 

with units that are capable of meeting the new standard levels. 

8) The creation of a standardized package for verification to streamline the process of DOE review 

was discussed. This package would give manufacturers a sense of security in knowing exactly 

which documents need to be submitted to DOE and also reduce the likelihood of requests for 

additional documentation. Trane agreed that the package would need to include the underlying 

test data used to substantiate the AEDM or ARM as well as specific unit numbers. However, 

Trane suggested that a summary of the test data or AEDM/ARM output might be better than 

requiring all data because of the complexity of these programs and also because of the volume of 

data which is collected during the actual testing of units.