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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTE RVIEW GUIDE

TABLE OF CO NTENTS

12A.1 PORTABLE AIR CONDITI ONERS

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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW G UIDE

12A.1 PORTABLE AIR CONDITI ONERS



## Portable Air Conditioner Rulemaking
Manufacturer Impa ct Analysis Interview Guide12A

- 2 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 “base line”
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 fo llowing efficiency levels for the proposed product

classes:12A

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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

(1 0 ,001

- 1 2 ,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 1 2.47

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 Conditioners12A

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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 12.4712A

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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 b aseline, 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 associate d 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 B tu/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 port able

1 2 ,001

- 1 4 ,000 B tu/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 co sts 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?12A

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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 associat ed with converting a baseline dual

- duct portable

1 2 ,001

- 1 4 ,000 B tu/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 cos ts 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)? W hat 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 c osts 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/h r 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 applica tions versus commercial applications?12A

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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 Costs12A

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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 chan ge 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, dis tribution
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 stan dards, 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 ne w 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 p roduct 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?