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EE-RAi/41 TOe- -L Vo 

### November 30, 2000 Memorandum to Docket: From: Michael E. McCabe Re: Docket item Number 65: Letter dated 10/21/2000 from Michael G. Schwartz, Lennox International, to Edward Pollock, DOE, commenting on proposed changes to Niche Product Efficiency Standards Discussion: The reference docket letter describes aproduct manufactured byArmstrong Air Conditioning Inc. which they claim would be excluded from classification as a "through-the-wall air conditioner or heat pump", hereafter TTW product, under the definitions ofthe TTW product class in the proposed rule. The docket letter described Armstrong Air Conditioning's "Magic-Pak HWC", as aproduct that was installed in a through the wall configuration and which combined gas heating with electric cooling. The Magic-Pak HWC is shown to have a rectangular airintake and discharge grill that is 28 inches wide and 48 inches high with a total area of 1204 square inches. The docket letter stated that a portion ofthe unit size is needed for the gasheat exchanger and venting. The Department proposed to establish a separate class for TTW products having a cooling capacity ranging between 18,000 and 30,000 Btu/hr and the required SEER/HSPF would be less thanthat proposed for the single package and split air conditioners and heat pump product classes. To meet the DOE definition ofTTW product, the equipment must be installed partially within or immediately adjacent to a fixed size opening in an exterior wall. The opening in the wall would have amaximum combined surface area ofthe air inlet and outlet ofthe condenser limited to 830 square inches. The docket letter stated that because the proposed rule restricts sizes to 830 square inches, it would be unfair to exclude a product (from achieving a TTW classification), even though the product has a long history ofuse,just because the product required a 28 by 43 inch (1204 square inch) wall opening.

Mr. Dave Winningham ofArmstrong Air Conditioning Inc. (419 483 4840, ext 2382) telephoned me on 11/26/2000 to discuss their concerns over DOE's proposed face area limitations. Prior to Mr. Winningham's call, Iopened Armstrong's web site (URL: http//www.magic-pak.com) to familiarize my selfwith the Magic-Pak HWC product. Ilearned from the web site that in addition to the 2.5 ton cooling capacity gas/electric product (HWC) described in the docket letter, MagicPak also marketed two other through the wall product lines: a product with a 2.5 ton cooling capacity combined with a 20 kW electric resistance heater, EWC; and an electric heat pump

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### IEE·Rum ....440

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November30, 2000 Memorandum to Docket: From: MichaelE. McCabe Re: Docketitem Number 65: Letter dated 10121/2000from Michael G. Schwartz, Lennox International, to Edward Pollock, DOE, commenting onproposed changes to Niche Product Efficiency Standards Discussion: The reference docket letterdescribes a productmanufactured by Armstrong Air Conditioning Inc. which they claim would be excluded from classification as a "through-the-wall air conditioner or heatpump", hereafterTTWproduct, underthe definitions ofthe TTWproduct class in the proposedrule. The docket letter described Armstrong AirConditioning's "Magic-Pak HWC", as aproduct that was installed in athrough the wall configuration and which combined gas heating with electric cooling. The Magic-Pak HWC is shownto have arectangular air intake and discharge grill that is 28 inches wide and 48 inches high with a total area of 1204 square inches. The docket letter stated that a portion ofthe unit size is needed for the gas heat exchanger and venting. The Departmentproposedto establish a separate class for TTW products having a cooling capacity ranging between 18,000 and 30,000 Btu/hr and the required SEERlHSPF would be less thanthatproposed for the single package and split air conditioners and heatpumpproduct classes. To meetthe DOE definition ofTTWproduct, the equipment mustbe installedpartially within or immediately adjacentto a fixed size opening in an exteriorwall. The opening in the wall would have a maximum combined surface area ofthe air inlet and outlet ofthe condenser limited to 830 square inches. The docket letter statedthat because the proposedrule restricts sizes to 830 square inches, it would be unfairto exclude a product (from achieving a TTW classification), eventhoughthe product has a long history ofuse,justbecause the product required a 28 by 43 inch (1204 square inch) wall opening.

Mr. Dave Winningham ofArmstrong Air Conditioning Inc. (419 483 4840, ext 2382) telephoned me on 11126/2000 to discuss their concerns over DOE'sproposed face area limitations. Priorto Mr. Winningham's call, I opened Armstrong's web site (URL :http//www.magic-pak.com) to familiarize my selfwith the Magic-Pak HWC product. I learned from the web site that in addition to the 2.5 ton cooling capacity gas/electric product (HWC) described in the docket letter, MagicPak also marketed two otherthrough the wall product lines: a product with a 2.5 ton cooling capacity combined with a 20 kW electric resistance heater, EWC; and an electric heatpump

## ' - EE.RM/STD-98-44O4 

# 7 product line with a 1.5 tonto 2.0 ton cooling capacity, PWC. From the equipment drawings and architectural louver information posted to the web, it appeared that allthree product lines; the HWC, EWC and the PWC, all use the same fixed wall opening and use a similar size platform. Mr. Winningham's comments seemed to confirm this information. He stated that the outdoor fan, in these three products, because it was ofthe propeller type, required the additional discharge area. During the 11/26/00 telephone conversation, I suggested to Mr. Winningham that Armstrong Air Conditioning Inc. submit, prior to close ofthe comment period on December 4, 2000, data on the minimum wall opening area requirements for those products which combine through the wall air conditioners with electric heating (both resistance and heat pumps), for DOE's consideration of Armstrong's request to increase the opening size for TTW products to allowtheir existing equipment with 1204 square inch opening to be included in the proposed TTW product class. In a follow up-telephone conversation with Mr. Winningham on 11/29/00, I suggested that Armstrong's written comments focus on describing the impacts the proposed rule would have on Armstrong's TTW products, describe changes to the proposed rule that they advocate, and describe why theyneed the changes.

2 product line with a 1.5 tonto 2.0 ton cooling capacity, PWC. Fromthe equipment drawings and architectural louver informationposted to the web, it appeared that all three product lines; the HWC, EWC andthe PWC, all use the same fixed wall opening and use a similar size platform. Mr. Winningham's comments seemedto confirm this information. He stated thatthe outdoorfan, inthese three products, because it was ofthe propellertype, requiredthe additional discharge area. During the 11126/00 telephone conversation, I suggestedto Mr. Winningham that Armstrong Air Conditioning Inc. submit, priorto close ofthe commentperiod onDecember4, 2000, data onthe minimum wall opening area requirements for those products which combinethrough the wall air conditioners with electric heating (bothresistance and heatpumps), for DOE's consideration of Armstrong'srequestto increase the opening size for TTWproductsto allowtheir existing equipmentwith 1204 square inch opening to be included in the proposedTTWproduct class. In a follow up-telephone conversationwith Mr. Winningham on 11/29/00, I suggestedthat Armstrong's written comments focus on describing the impacts the proposed rule would have on Armstrong's TTWproducts, describe changes to the proposedrule that they advocate, and describe whythey need the changes.

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