Michael Raymond To: Brenda Edwards-Jones/EE/DQE@DOE

cc:

04/18/2007 08:43 AM Subject: E-mail to be put into Docket EE-RM/TP-02-002

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Thanks

Michael 0. Raymond

Project Manager

Building Technologies Program

Energy Efficiency and Renewable Energy

Department of Energy, EE-2J

1000 Independence Ave., SW

Washington, DC 20585-0121

phone - (202) 586-9611

fax - (202) 586-4617

Forwarded by Michael Raymond/EE/DOE on 04/18/2007 08:23 AM

"Brian Dougherty To: michael.raymond@ee.doe.gov

<brian.dougherty@nist.g cc:

ov> Subject: Fwd: RE: A few DOE test procedure related questions

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Do we want to make this follow-up to my questions part of the official docket?

Brian

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Subject: RE: A few DOE test procedure related questions

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Thread-Topic: A few DOE test procedure related questions

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From: 'Amrane, Karim <KAmraneari.org>

To: "Brian Dougherty" <brian. doughertynist.gov>

Cc: "Woodford, Mike" <Woodfordari.org>

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X-NIST-MailScanner-From: kamrane@ari.org

Brian,

I apologize for this late reply. However, it took a while to get feedback from the ART membership.

Below are the responses to your questions.

Karim

From: Brian Dougherty [ mailto:brian.doughertvnist.crov]

Sent: Wednesday, February 21, 2007 4:19 PM

To: Amrane, Karim

Subject: A few DOE test procedure related questions

Karim,

Before I finalize a few things, I wanted to ask a few questions.

1. Please clarif' for me ART's written conmient that is listed under the heading Shorting the maximum

duration of a Frost Accumulation Test on a two-capacity heat pump when it is operating at low capacity

Does the comment apply to just the one Frost Accumulation Test called out in the NOPR (and

repeated in this underlined heading) or does ARI recommend the change apply for ALL Frost

Accumulation Tests?

ARI recommends 1/ic change apply for ALL Frost Accumulation Tests.

2. Can ART provide DOE/NIST with any data that supports the ART comment that "preliminary testing

done by manufacturers shows a variation in HSPF of less than one tenth when the test is reduced from

12 to 3 hours."

Included is a spreadsheet, provided by one member, that shows the percentage change in total test

time spent in defrost cycle decreases significantly less as time extends beyond 3 hours. Thus the

ncgative impact due to defrosting on capacity and power consumption due to the defrost cycle is

relatively less and less as total defrost test time increases. We believe that test times beyond 3 hours

have diminishing returns

3. With regard to the proposed changing of the cooling-mode test conditions for units having a

two-capacity compressor (Page 3 of ARI's Nov. 9 comments), ART states: "These two additional test

will do very little to improving the accuracy of the SEER. On the other hand, they will significantly

increase the testing burden on manufacturers." The DOE/NIST proposal was not to add two additional

tests but to have the existing Cd tests conducted at 67 F rather than at the current 82 F outdoor

condition. I nonetheless tend to agree with ART's recommendation on this item but mainly over

concern that changing the Cd test condition may cause a unit's rating to change enough to cause them to

retest/rerate. I'm inclined to recommend that changing the Cd test condition be "tabled" until a future

rulemaking that addresses the test procedure on which any new NAECA minimums are based

(assuming, for the moment, that such a rulemaking ever takes place).

ARI reiterates its November 9, 2006 opposition to the proposal because the change is of no benefit to

 EE-RM/TP-02-002 COMMENT 25
any party.

4. On the issue of the ARI's ever improving policy on how to deter inflated ratings by an 1CM, I

wanted to play devil's advocate and ask whether ART is concerned whether an 1CM may give the same

indoor coil two or more model numbers so that, in the event of a failure, they really don't have to

rerated all the combinations with that particular indoor unit. I've heard the option proposed but have

not investigated whether anyone has tried to implement it.

ARI's USE Compliance Committee is looking at specifj'ing geometries of coils fi.r determining basic

model groupings for ICM's n'hich vo old address the hypothetical option posed here.

Please reply when you have an opportunity.

Regards,

Brian afrc tthi.x1

 EE-RM/TP-02-002 COMMENT 25
Total Defrost

Cycle Length

Defrost Duration (minutes)

______ ______ ______ ______

Hours Minutes 6 7 8 9

______

10

1.0 60 10.0% 11.7% 13.3% 15.0% 16.7%

1.2 70 8.6% 10.0% 11.4% 12.9% 14.3%

1.3 80 7.5% 8.8% 10.0% 11.3% 12.5%

1.5 90 6.7% 7.8% 8.9% 10.0% 11.1%

1.7 100 6.0% 7.0% 8.0% 9.0% 10.0%

1.8 110 5.5% 6.4% 7.3% 8.2% 9.1%

2.0 120 5.0% 5.8% 6.7% 7.5% 8.3%

2.2 130 4.6% 5.4% 6.2% 6.9% 7.7%

2.3 140 4.3% 5.0% 5.7% 6.4% 7.1%

2.5 150 4.0% 4.7% 5.3% 6.0% 6.7%

2.7 160 3.8% 4.4% 5.0% 5.6% 6.3%

2.8 170 3.5% 4.1% 4.7% 5.3% 5.9%

3.0 180 3.3% 3.9% 4.4% 5.0% 5.6%

3.2 190 3.2% 3.7% 4.2% 4.7% 5.3%

3.3 200 3.0% 3.5% 4.0% 4.5% 5.0%

3.5 210 2.9% 3.3% 3.8% 4.3% 4.8%

3.7 220 2.7% 3.2% 3.6% 4.1% 4.5%

3.8 230 2.6% 3.0% 3.5% 3.9% 4.3%

4.0 240 2.5% 2.9% 3.3% 3.8% 4.2%

4.2 250 2.4% 2.8% 3.2% 3.6% 4.0%

4.3 260 2.3% 2.7% 3.1% 3.5% 3.8%

4.5 270 2.2% 2.6% 3.0% 3.3% 3.7%

4.7 280 2.1% 2.5% 2.9% 3.2% 3.6%

4.8 290 2.1% 2.4% 2.8% 3.1% 3.4%

5.0 300 2.0% 2.3% 2.7% 3.0% 3.3%

5.2 310 1.9% 2.3% 2.6% 2.9% 3.2%

5.3 320 1.9% 2.2% 2.5% 2.8% 3.1%

5.5 330 1.8% 2.1% 2.4% 2.7% 3.0%

5.7 340 1.8% 2.1% 2.4% 2.6% 2.9%

5.8 350 1.7% 2.0% 2.3% 2.6% 2.9%

6.0 360 1.7% 1.9% 2.2% 2.5% 2.8%

6.2 370 1.6% 1.9% 2.2% 2.4% 2.7%

6.3 380 1.6% 1.8% 2.1% 2.4% 2.6%

6.5 390 1.5% 1.8% 2.1% 2.3% 2.6%

6.7 400 1.5% 1.8% 2.0% 2.3% 2.5%

6.8 410 1.5% 1.7% 2.0% 2.2% 2.4%

7.0 420 1.4% 1.7% 1.9% 2.1% 2.4%

7.2 430 1.4% 1.6% 1.9% 2.1% 2.3%

7.3 440 1.4% 1.6% 1.8% 2.0% 2.3%

7.5 450 1.3% 1.6% 1.8% 2.0% 2.2%

7.7 460 1.3% 1.5% 1.7% 2.0% 2.2%

7.8 470 1.3% 1.5% 1.7P/o 1.9% 2.1%

8.0 480 1.3% 1.5% 1]/ 1.9% 2.1%

8.2 490 1.2% 1.4% 1.6% 1.8% 2.0%

8.3 500 1.2% 1.4% 1.6% 1.8% 2.0%

8.5 510 1.2% 1.4% 1.6% 1.8% 2.0%

8.7 520 1.2% 1.3% 1.5% 1.7% 1.9%

8.8 530 1.1% 1.3% 1.5/o 1.7% 1.9%

This chart shows that,

relatively the same (wl

the defrost test length*

cycle on the overall cai

little after 3 hours.

Defrost cycle = defrost

Defrost test = defrost t

 EE-RM/TP-02-002 COMMENT 25
9.0 540 1.1% 1.3% 1.5% 1.7% 1.9%

9.2 550 1.1% 1.3% 1.5% 1.6% 1.8%

9.3 560 1.1% 1.3% 1.4% 1.6% 1.8%

9.5 570 1.1% 1.2% 1.4% 1.6% 1.8%

9.7 580 1.0% 1.2% 1.4% 1.6% 1.7%

9.8 590 1.0% 1.2% 1.4% 1.5% 1.7%

10.0 600 1.0% 1.2% 1.3% 1.5% 1.7%

10.2 610 1.0% 1.1% 1.3% 1.5% 1.6%

10.3 620 1.0% 1.1% 1.3% 1.5% 1.6%

10.5 630 1.0% 1.1% 1.3% 1.4% 1.6%

10.7 640 0.9% 1.1% 1.3% 1.4% 1.6%

10.8 650 0.9% 1.1% 1.2% 1.4% 1.5%

11.0 660 0.9% 1.1% 1.2% 1.4% 1.5%

11.2 670 0.9% 1.0% 1.2% 1.3% 1.5%

11.3 680 0.9% 1.070 1.2% 1.3% 1.5%

11.5 690 0.9% 1.0% 1.2% 1.3% 1.4%

11.7 700 0.9% 1.0/ 1.1% 1.3% 1.4%

11.8 710 0.8% 1.0% 1.1% 1.3% 1.4%

12.0 720 0.8% I1o 1.1% 1.3% 1.4%

 EE-RM/TP-02-002 COMMENT 25
assuming the defrost cycle* stays

iich it typically does) regardless of

*, then the impact of the defrost

pacity of the system changes very

intiation to defrost termination

:ermination to defrost termination

 EE-RM/TP-02-002 COMMENT 25