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 

### 0Federal Record 

# •Not a Federal Record

----- User Filed as: Not Categorized in ERMS

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 04/16/2007 03:45 PM 0 Federal Record • Not a Federal Record

User Filed as: Not Categorized in ERMS

If this external e-mail is a record and you are the first EERE recipient, click the File to ERMS' button in the toolbar to categorize this e-mail

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

Brian

X-Sieve: CMU Sieve 2.2 Subject: RE: A few DOE test procedure related questions Date: Mon, 16 Apr 2007 14:13:31 -0400 X-MS-Has-Attach: yes X-MS-TNEF-Correlator: Thread-Topic: A few DOE test procedure related questions Thread-Index: AcdV/hmtNr9PlJLxSumZjxnck7 1 0zAqU5D 1Q From: 'Amrane, Karim <KAmraneari.org> To: "Brian Dougherty" <brian. doughertynist.gov> Cc: "Woodford, Mike" <Woodfordari.org> X-Proofpoint-Virus-Version: vendor=fsecure engine=4.65.5502:2.3.11,1.2.37,4.0.164 definitions=2007-04- 1607:2007-04-14,2007-04-16,2007-04-16 signatures=0 X-PP-SpamDetails: rule=spampolicy2_notspam policy=spampolicy2 score=0 spamscore=0 ipscore=0 phishscore=0 adultscore=0 classifier=spam adjust=0 reason=mlx engine=3.1.0-0703060001 definitions=main-0704 160038X-PP-SpamScore: 0

X-NIST-MailScanner: Found to be clean 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: AfewDOE 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 totaltest 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 toany 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.x1Total 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 t9.0 540 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%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