EE-RM/STO 78I 

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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 a product manufactured by Armstrong 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 of the TTW product

class in the proposed rule. The docket letter described Armstrong Air Conditioning's "Magic-Pak

HWC", as a product 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 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 of the unit size is needed for the gas heat 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

than that proposed for the single package and split air conditioners and heat pump product

classes. To meet the DOE definition of TTW 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 a maximum combined surface area of the air inlet and outlet of the 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 of use, just because the product required a 28 by 43 inch (1204 square

inch) wall opening.

Mr. Dave Winningham of Armstrong 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, I opened Armstrong's web site (URL: http//www.magic-pak.com) to

familiarize my self with 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 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

1

EE-RM-STD-98-440 COMMENT 78

IEE·Rum .... 440 * 78 

November 30, 2000 

Memorandum to Docket: 

From: Michael E. McCabe 

Re: Docket item Number 65: Letter dated 10121/2000 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 a product manufactured by Armstrong 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 of the TTW product 

class in the proposed rule. The docket letter described Armstrong Air Conditioning's "Magic-Pak 

HWC", as a product 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 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 of the unit size is needed for the gas heat 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 SEERlHSPF would be less 

than that 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 a maximum combined surface area of the air inlet and outlet of the 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 of use, just because the product required a 28 by 43 inch (1204 square 

inch) wall opening. 

Mr. Dave Winningham of Armstrong Air Conditioning Inc. (419 483 4840, ext 2382) telephoned 

me on 11126/2000 to discuss their concerns over DOE's proposed face area limitations. Prior to 

Mr. Winningham's call, I opened Armstrong's web site (URL : http//www.magic-pak.com) to 

familiarize my self with 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 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 
' - EE.RM/STD-98-44O4 7

product line with a 1.5 ton to 2.0 ton cooling capacity, PWC. From the equipment drawings and

architectural louver information posted to the web, it appeared that all three 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 of the 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 of the 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 allow their 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 they need the changes.

2

EE-RM-STD-98-440 COMMENT 78

product line with a 1.5 ton to 2.0 ton cooling capacity, PWC. From the equipment drawings and 

architectural louver information posted to the web, it appeared that all three 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 of the propeller type, required the additional discharge 

area. 

During the 11126/00 telephone conversation, I suggested to Mr. Winningham that Armstrong Air 

Conditioning Inc. submit, prior to close of the 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 allow their 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 they need the changes. 

2