# ....MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville·Suwanee Road, Suwanee, GA 30024

February 18, 20II The Honorable Cathy Zoi Assistant Secretary for Energy Efficiency and Renewable Energy U.S. Department ofEnergy 1000 Independence Ave, SW Washington, DC 20585-0121 Re: Update to Previously-Granted TestProcedure forWaivers for CITY MULTI VRFZ WR2 and WY Series and S&L Class Air Conditioners and Heat Pumps DearAssistant Secretary Zoi: On December 15, 2009, the Department ofEnergy (DOE) granted Mitsubishi Electric & Electronics USA, Inc. (MEUS) awaiver from the DOE commercial air conditioner and heat pump test procedures for MEUS's WR2 and WY Series products l and the S&L Class products2 These products are part ofMEUS's CITY MULTI Variable Refrigerant Flow Zoning (VRFZ) line ofmulti-split central airconditioners and heat pumps. As explained in MEUS's petitions for waiver for the WR2 andWY Series and the S&L Class products, these systems cannotbe tested according to the prescribed test procedures for commercial products. Pursuant to DOE's grant of the waivers, MEUS is not required to test orrate the products listed in the waivers based on the currently applicable test procedure. Instead, MEUS is required to test and rate these products according to the alternate test procedure set forth in the waivers. MEUS has now developed additional models ofindoorunits for these multi-split systems. These include both models in certain existing model families that have capacities not previously offered, as well as new indoor model families to be used with these systems. These additional indoor models face the same testing challenges as the models already covered by the WR2 and WY Series Waiverand the S&L Class Waiver. Specifically, they contain one or more design characteristic that prevents testing according to the test procedures. Therefore, MEUS respectfully requests that DOE update the list ofmodels covered by the applicable test procedure

I Energy Conservation Programfor Certain Industrial Eqaipmem: Decision and OrderGrallting a Waiverto MilSltbishi Electric alldElectronics USA, Inc. From the Departmentof Energy Commercial Package Water-Source Heat Pump Test Procedure, 74 Fed. Reg. 6631 J (Dec. 15,2009) (''WR2 and WY Series Waiver"). 2 Energy Conservation Programfor Certain Industrial Equipment: Decision and OrderGranting a Waiver to Mitsubishi Electric & Electronics USA, fnc. From the Departmentof Energy Commercial PackageAirConditioner alldHeal PUIllP Test Procedures, 74 Fed. Reg. 66315 (Dec. 15,2009) ("S&L Class Waiver").

# '\'MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 waivers to coverthese additional indoor models. 3 MEUS simultaneously requests an interim waivercovering systems using these additional indoor models. MEUS frames this request to update the list ofmodels covered by two already-granted waivers pursuantto the requirements for granting new test procedure waivers' Given that this request simply addresses the addition ofcertain new indoormodels for MEUS's WR2 and WY Series and the S&L Class products, and thatDOE previously has granted waivers for the outdoor units and otherindoor units for these systems, ifDOEwould preferto utilize aprocedurally simplerapproach for updating the covered list ofmodels, MEUS would welcome such an approach. 

### Background On October 30, 2006, MEUS submitted a Petition for Waiverfrom the test procedures applicable to the water-source WR2 and WY Series ofits CITY MULTI VRFZ line of commercial package heat pump equipment. Mitsubishi sought a waiver from the applicable test procedures because the design characteristics ofthese models prevented testing according to the currently prescribed test procedures. Specifically, these models can connect an outdoorunit to many more indoor units than the test laboratories can physically test at one time, and it is not practical to test all ofthe potentially available combinations. DOE granted the requested waiver because "the basic model [ofthese products] contains one or more design characteristics which
.

. . prevent testing ofthe basic model according to the prescribed test procedures.' ,5 The waiver included an alternate test procedure pursuant to which MEUS must test and rate the products covered by the waiver. On March 28, 2008, MEUS submitted a Petition for Waiver from the test procedures applicable to the S&L Class models from MEUS's CITY MULTI VRFZ line ofcommercial package heat pump equipment. MEUS based its request on the fact that the testing laboratories cannot test systems with so many indoor units, and that there are too many possible combinations ofindoor units with a single outdoorunit to test. DOE agreed with MEUS that the existing testing facilities have limited ability to test multiple indoorunits at one time, and that the number ofpossible combinations ofindoor and outdoorunits is impractical to test, and thus granted MEUS's requested waiver.6 DOE approved an alternate test procedure pursuant to which MEUS must test and rate the models covered by the waiver.

3 The existing WR2 and WY Series Waiver and S&L Class Waiver would remain in effect until DOE modifies those waivers in accordance with this request.

, See 10 C.F.R. § 431.40 I. 5 WR2 and WY Series Waiver at 66313. 'S&L Class Waiver at 66317. 2

# ;,MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 New Indoor Models Both the WR2 and WY SeriesWaiver and the S&L Class Waiver covered the following indoor model families: (I) PCFY Series

- Ceiling Suspended; (2) PEFY Series

- Ceiling Concealed Ducted (Low Profile); (3) PKFY Series

- Wall Mounted; and (4) PLFY Series

- 4- Way Airflow Ceiling Cassette. For each ofthese indoor model families, MEUS has developed an additional model with acapacity of 15 MBtulh. At the time MEUS initially filed its petitions for waiver for the WR2 and WY Series and S&L Class products, this capacity product was not available. MEUS has developed this additional capacity product to meet customerdemands for specialized applications. When MEUS originally applied for a waiverfor its WR2 and WY Series and its S&L Class products, it only included those indoor units that were being produced at that time. MEUS has now developed new indoor model types to expand its CITY MULTI product line to offer consumers a greater variety ofavailable indoor units to suit consumers' specific needs. MEUS plans to add five new types ofindoor unitfamilies to the line-up ofindoor units that can be matched with the CITY MULTI outdoorunits. The new indoor model families will be: (1) PEFY-AF; (2) PVFY; (3) PWFY; (4) PLFY Series

- 2'-by-2' frame 4-Way Airflow Ceiling Cassette; and (5) PEFY Series

- Ceiling Concealed Ducted. The difference between these new indoor models and the models previously covered by the waivers relates to their application. All ofthe new models have been developed for specialized applications to meet consumers' unique demands. MEUS requests that the WR2 and WY Series Waiver and the S&L Class Waiverbe updated to cover the following additional indoor units:

• PCFY-Series

- Ceiling Suspended

- with acapacity of 15 MBtu/h

• PEFY Series

- Ceiling Concealed Ducted (Low Profile)

- with acapacity of 15 MBtulh

• PKFY Series

- Wall Mounted

- with acapacity of 15 MBtu/h

• PLFY Series

- 4-Way Airflow Ceiling Cassette

- with acapacity of 15 MBtulh

• The PEFY-AF Series

- 100% outdoor air ventilation systems (Concealed ducted)- PEFY-AFI200CFM/CFMR**

- with amaximum outside air ventilation capability of 1200CFM

• The PVFY Series

- Vertical air handler (Concealed ducted)

- with capacities of 12/18/24/30/36/42/48/54MBtulh

• PWFY Series- Commercial HotWaterHeat Pump Indoor Units

- with capacities of 36/72 MBtulh and 36 MBtulh with boosterunit.
3

# .....MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

• PEFY Series-Ceiling Concealed Ducted-with capacities of 06/08112115118124127/30/36/48MBtuth

• PLFY Series-2'-by-2' frame 4-Way Airflow Ceiling Cassette -with capacities of 8112115 MBtuth ForDOE's convenience, MEUS is attaching comprehensive lists ofall ofthe models for the WR2 and WY Series and S&L Class systems that include the outdoorand indoor models covered by previously granted waivers in the WR2 andWY Series Waiver and the S&L Class Waiver, plus the additional indoor models that are the subject ofthis petition. MEUS respectfully requests that DOE replace, in its entirety, the lists ofmodels included in the WR2 and WY Series Waiver and the S&L Class Waiverwith the lists included as Attachment A and Attachment B to this petition upon grant ofthis waiver petition. Having an updated comprehensive list will assist DOE and market participants in easily keeping track ofall ofthe WR2 and WY Series and S&LClass models that are subject to aDOE-granted waiver. 

### TestProcedures 

### from which 

### Waiveris Requested MEUS's petition requests waiver from the applicable test procedures for its additional indoor models to be used with the WR2 and WY Series and S&L Class CITY MULTI products. Forthe water source products, DOE's regulations provide the test procedures for small and large commercial package airconditioning and heating equipment7 Pursuant to 10 C.F.R. 

### § 431.96, the test procedures applicable to small commercial packaged air conditioning and heating water-source heat puniPs, with capacities less than 135,000Btuth, are those included in [SO Standard 13256-1 (1998). The capacities ofMEUS's WR2 and WY CITY MULTI watersource products covered by this petition fall in that range. Therefore, MEUS requests waiver from ISO Standard 13256-1 (1998), as incorporated by reference in DOE's regulations for its WR2 and WY Series products. MEUS's petition also requests waiver from the commercial test procedures for its S&L Class products. For commercial package airconditioning equipment with capacities between 65,000 and 760,000 Btuth, ARI Standard 340/360-2004is the applicable test procedure under 10 C.F.R. § 431.96. Thecapacities ofMEUS's S&L Class CITY MULTI products sold for commercial use fall in that range. Therefore, MEUS requests waiver from ARI Standard 340/360-2004 as incorporated by reference in DOE's regulations for MEUS's S&LClass products.

7 10 C.F.R. § 431.96. 8 10 C.F.R § 431.96, Table 1. 4

# ) ...MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

MEUS proposes to test and rate a tested combination for eacb individual ollldoor unit of the WR2 and WY Series products and the S&LClass products pursuant to the applicable alternate test procedure already specified in the WR2 and WY Series Waiver and the S&L Class Waiver, as discussed below. 

### Need for Waiver ofTestProcedures The Department's regulations contain provisions allowing aperson to seek a waiver from the test procedure requirements for commercial equipment. These provisions are set forth in 10 C.F.R. 

### § 431.40I. The waiverprovisions allow DOE to temporarily waive test procedures for a particularbasic model when apetitioner shows that the basic model contains one or more design characteristics that preventtesting according to the prescribed test procedures, or when the prescribed test procedures may evaluate the basic model in amanner so unrepresentative ofits true energy consumption as to provide materially inaccurate comparative data9 As explained above, DOE granted the WR2 and WY Series products a waiverbecause "the basic model [ofthese products] contains one or more design characteristics which
... prevent testing ofthe basic model according to the prescribed test procedures." 10 DOE made the same finding with respect to the S&L Class products, stating that the existing testing facilities have limited ability to test multiple indoor units at one time, and that the number ofpossible combinations ofindoor and outdoor units is impractical to test, and thus granted MEUS's requested waiver. I I The additional indoor models that are the subject ofthis petition would be usedjust as the products covered by the WR2 and WY Series Waiver and the S&L Class Waiver, and thus present exactly the same testing challenges. Thus, DOE should grant the requested waiver.As DOE found in its grant ofthe WR2 and WY Series Waiver and the S&L Class Waiver, indoor models are not the primary efficiency drivers for these systems-the primary efficiency drivers are the outdoorunits. 12 MEUS is not proposing to add new outdoorunits to the WR2 and WY Series Waiver and S&LClass Waiver. The indoor units described above will be combined with the sameoutdoorunit models covered by the prior waivers to create VRFZ systems. It should be noted that these CITY MULTI products employ advanced technologies and their marketing will advance the goals ofthe Energy Policy and Conservation Act (EPCA) to promote energyefficiency. Testing procedures should not inhibit the commercial success of these products in the United States. Without a waiverofthe test procedures, MEUS will be at a

9 10 C.F.R. § 431.401 (a)(I). 10 WR2 and WY Series Waiver at 66313.
" S&L Class Waiver at 66317. 12 "DOE believes that allowing MEUS to make energy efficiency representations for non-tested combinations by adopting this alternative test procedure as described above is reasonable because the outdoor unit is the principal efficiency driver." S&L Class Waiver at 66317. See also WR2 and WY Series Waiver at 66313. 5

# ;"'MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 competitive disadvantage in the market. Consumers have come to expect the availability ofthe CITY MULTI products in the U.S. marketplace, and a significant number ofengineers and contractors are currently requesting these WR2 and WYand S&L Class products for their projects because ofthe great advantages they offer. Thus, MEUS respectfully requests that DOE grant a waiver from the applicable test procedures. Alternative Test Procedures Both theWR2 and WY Series Waiver and the S&L Class Waiver include alternate test procedures pursuant to which MEUS tests and rates its water source and S&Lclass products. 13 No changes to those alternate test procedures are needed to coverthe additional indoor units that are the subjectofthis petition. Therefore, MEUS requests that the products listed herein be subjectto the same alternate test procedures as in the WR2 and WY Series Waiver and the S&L Class Waiver, as applicable. ForDOE's convenience, MEUS is reproducing the alternate test procedures included in the WR2 and WY Series Waiver and the S&L Class Waiver as Attachment C and Attachment D to this petition. SimilarProducts To the best ofour knowledge, water-source VRFZproducts orproducts similarto MEUS's S&L Class products are also offered in the United States by Daikin AC (Americas), LG Electronics U.S.A., Inc., Fujitsu Gen America Inc, Samsung Electronics Company, LTD., and Sanyo Fisher (USA) Corp. Application for Interim Waiver Pursuant to 10 C.F.R. 

### § 431.401(a)(2), MEUS also submits an application for interim waiver ofthe applicable test procedures for the WR2 and WY CITY MULTI indoor models and the S&L Class indoor models listed above. DOE's regulations contain provisions allowing DOE to grant an interim waiver from the test procedure requirements to manufacturers that have petitioned the Department for a waiver ofsuch prescribed testprocedures. 14 As DOE has stated, "an InterimWaiver will be granted ifit is determined that the applicant will experience economic hardship ifthe Application for InterimWaiver is denied, ifit appears likelythat the Petition for Waiver will be granted, and/or the Assistant Secretary determines that it would be desirable for public policy reasons to grant immediate reliefpending adetermination for the Petition for Waiver." 15 MEUS will experience economic hardship ifthe application for interim

13 WR2 and WY Series Waiver aI 66313; S&LClass Waiver at 66317.
" 10 C.FR. § 431.401 (a)(2). 15 Energy Conservation Program/or Consumer Products: Publication a/the Petition/or Waiver andGrantin.g of theApplication/orImerim Waiverof Sarnsun.gAirConditioning From the DOEResidelllialand Commercial 6

# ;,MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 waiver is denied. Additionally, precedent indicates that DOE will likely grant MEUS's petition for waiver. Finally, it is in the public interest to grant an interim waiver. Therefore, MEUS respectfully requests DOEto grant the application for interim waiver. MEUS plans to introduce the additional WR2 and WY Series and the S&L Class indoor models into the U.S. market soon. The procedure for granting a waiver is atime-consuming process - DOE must publish the request in the Federal Register, allow time for public comment, and then consider any comments before it makes a decision. Thus, the process typically takes a numberofmonths. Ifan interim waiver is not granted, MEUS will suffereconomic hardship because MEUS will be required to delay its introduction ofthese products to U.S. customers. In addition, DOE will likely grant MEUS's request to update the previously-granted waivers to include the products covered by this request. As described above, DOE has already granted a waivel'. for the WR2 and WY Series and S&L Class products. The indoor models that are the subject ofthis request include the same design characteristics that prevented testing ofthe basic model ofthe products listed in the WR2 and WY Series Waiver and the S&LClass Waiver. The best evidence that DOE is likely to grant this request is the fact that it previously granted similar waivers to MEUS and other manufacturers. 16 PackageAirConditionerandHeat PUIllP Test Procedures (Case No. CAC-009), 70 Fed. Reg. 9629 al 9630 (Feb. 28,2005). See 10 C.FR. § 431.201(e)(3) (2005). 16See WR2 and WY Series Waiver and the S&L Class Waiver. See also, Energy Conservation Programfor COI/SLimerProdltcts: Decision alld OrderGrallfillga Waiver From the DOE Commercial PackageAir Conditioner andHeat PUIllP Test Procedure to Mitsubislii Electric (Case No. CAC- 008),69 Fed. Reg. 52660 (Aug. 27,2004); Energy Consen/arion Program/or ConsumerProdlicts: Decision andOrderGraliling a Waiver From the DepartmelltofEnergy (DOE) ResidemialandCommercialPackageAir Conditioneralld HealPump Test Procedures to Mitsubishi Electric, andModification oj(l 2004 WaiverGramedto Mitsubishi Electric From the Same DOETest Procedures (Case No. CAC-OI2), 72 Fed. Reg. 17528 (Apr. 9, 2007); Energy Conservatiou Programfor ConsumerProducts: Decision andOrderGraming a Waiver to Fujitsu GeneralFrom the Department of Energy Residelllial CelllralAirCouditionerandHeat Pump Test Procedure rCase No. CAC-OIOr, 72 Fed. Reg. 71383 (Dec. 17,2007); Energy Conservation Programfor ConsumerProducts: Decision and OrderGrallting a Waiver to SamsllngAir Conditioning From the Departmellt of Energy Residelltialand Commercial PackageAir CouditioueraudHeat Pump Test Procedures rCase No. CAC-009J, 72 FR 71387 (Dec. 17,2007); Energy Conservation Program/or ConsumerProducts: Decision andOrderGrantinga Waiverto Daikin 

## u.s. Corporation From the Departmentof Energy CommercialPackageAir ConditioneralldHeat Pump Test Procedures alld Den)'ing a Waiver From the Residential CentralAir ConditionerandHeatPump TestProcedures, 73 Fed. Reg. 39680 (July 10,2008); Energy Conservation Program/or CommercialEquipment: Decision andOrderGraming a Waiverto Daikin AC (Americas), Inc. From tlte Department ofEnergy CommercialPackageAirConditionerand Heat Pump Test Procedures, 74 Fed. Reg. 15955 (Apr. 8,2009); Energy Conservation Programfor Commercial Equipment: Decision alldOrderGranting a Waiver to 5an)'0 Fisher Company From the DepartmentofEnergy CommercialPackage AirConditionerandHeat Pump Test Procedure andDenyinga Waiver From the Residelltial CentralAirConditionerandHeat Pump Test Procedure, 74 Fed. Reg. 16193 (Apr. 9,2009); Ellergy Conservation Program/or Certain Industrial Equipmellt: Decision andOrderGranting (l Waiver to Daikin AC (Americas), lllc. From the Department

### 0/Energy Commercial Package Water-SourceAirConditionerandHeat Pump Test Procedure, 74 FR 16373 (Apr. 10,2009); Ellergy Conservation Program/or CommercialEquipment: Decision and OrderGranting a Waiver to Daikin AC (Americas). Inc. (Daikin) From the Departme1lt ofEnergy Commercial PackageAir ConditionerandHeat Pump Test Procedures, 75 Fed. Reg. 22581 (Apr. 29, 20I0); and Energy Conservation Program/or Certain CommercialandIndusrrialEqllipment: Decision andOrderGrallting a Waiver
7

# ~MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

Finally, DOE's regulations state that the Assistant Secretary may grant an interim waiver ifhe determines that it would be desirable for public policy reasons to grant immediate relief pending adetermination for the Petition for Waiver. In response to MEUS's Application for Interim Waiver for its WR2 and WY products, DOE stated that "in those instances where the likely success ofthe Petition for Waiverhas been demonstrated, based upon DOE having granted a waiverfor a similarproduct design, it is in the public interestto have similarproducts tested and rated forenergy consumption on acomparable basis. ,,17 The same conclusion should be reached with respect to the additional indoor models listed in this petition. These products will suffer the same testing obstacles as the products covered bythe earlierwaivers. Therefore, since it is in the public interest to have similarproducts tested and rated on a comparablebasis, DOE should grant MEUS's Application for Interim Waiver. Conclusion MEUS respectfully requests that DOE update the list ofmodels covered by WR2 and WY Series Waiver and the S&L Class Waiver to cover the additional indoor models listed in this request. DOE should grant this request because the list ofcovered products, as updated, "contain[] one or more design characteristics which
... prevent testing ofthe basic model according to the prescribed test procedures." 18 MEUS further requests DOE to grant its request for an interim waiver while this request is pending.

to Sonyo North America Corporation From the DepartmentofEnergy Commercial Package Air Conditionerand Heat PUIIlP Test Procedures, 75 Fed. Reg. 41845 (July 19,2010); 11 Ellergy Conservation Programfor Consumer Products: Publication ofrhe Petitionfor WaiveralldGranting of the Applicationfor Interim WaiverofMirSflbishiElectric From the DOE Commercial Water Source Heat Pump Test Procedure [Case No. CAC-O/5[, 72 Fed. Reg. 17533 at 17535 (Apr. 9, 2007) 18 10 C.F.R § 431.201(.)(1) (2005). 8Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

Ifyou have any questions or would like to discuss this request, please contact Paul Doppel, at (678) 376-2923, orDouglas Smith at (202) 298-1902. We greatly appreciate your attention to this matter. Sincerely,



## , 'v·&- WilliamRau SeniorVice President and General Manager HVAC Advanced Products Division Mitsubishi Electric & Electronics USA, Inc. 4300 Lawrenceville-Suwanee Road Suwanee, GA 30024
Attachments

9

# .~MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024
CERTIFICATE Ihereby certify that Ihave this day served the foregoing Petition for Waiver and Application for InterimWaiver upon the Following companies known to Mitsubishi Electric & Electronics USA, Inc. to currently market systems in the United States that appear to be similar to the WR2 and WY Series or the S&L CITY MUL

### TT VRFZ system design. 

### Ihave notified these manufacturers that the AssistantSecretary for Energy Efficiency and Renewable Energy will receive and consider timely written comments on the Application for Interim Waiver. Daikin AC (Americas), Inc. 1645 Wallace Drive, Suite I 10 Carrollton, TX 75006 Attn: Mike Bregenzer, VP and GM LG Electronics U.S.A., Inc. 1000 Sylvan Ave Englewood CliFfs, NJ 07632 Attn: Johnson Christopher, Environmental Manager Samsung Air Conditioning Samsung Electronics Company, LTD. 300I Northern StarBlvd Ft Worth TX 76137 Attn: MaltWall Sanyo Commercial Solutions HVAC Solutions 1690 Roberts Blvd Nw Suite 110 Kennesaw, GA 301 Attn: Gary ettinger, VicePresident, Technical Solutions



### 10

# .·,MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 Fujitsu General America 353 US Highway 46 Fairfield, NJ 07004-2437 Attn: Rozylowicz Tedd, President & COO

Dated this 18th day ofFebruary, 2011.

William R u SeniorVice President and General Manager HVAC Advanced Products Division Mitsubishi Electric & Electronics USA, Inc. 3400 Lawrenceville-Suwanee Road Suwanee, GA 30024

1IMitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 

### ATTACHMENT A Complete List ofModels for the WR2 and WY Series (As updated in February 2011) CITY MULTI Variable Refrigerant Flow Zoning System OutdoorEquipment:

• WY-Series (PQHY) 208/230-3-60 and 460-3-60 split-system, water-sourced, variable-speed heatpumps with individual model nominal cooling capacities of72,000, 96,000, 108,000 and 120,000Btulh.

• WR2-Series (PQRY) 208/230-3-60 and460-3-60 split-system, water-sourced, variable-speed heat pumps with heatrecovery and with individual model nominal cooling capacities of72,000,96,000, 108,000 and 120,000Btu/h. CITY MULTI Variable RefrigerantFlow Zoning SystemIndoorEquipment: P*FY indoor models, ranging from 6,000 to 48,000 Btulh, 208/230 I 60 and from 72,000 to 120,000Btulh, 208/230-3-60 for use in split system variable-capacity air conditionerorheatpump systems:

• PCFY Series-Ceiling Suspended- with capacities of 12/15/18/24/30/36MBtu/h.

•PDFY Series-Ceiling Concealed

### Ducted-with capacities of 06/08/12/15/18/24/27/30/36/48

### MBtu/h.

• PEFY Series-Ceiling Concealed Ducted (Low Profile)-with capacities of 06/08/12/15/18/24 MBtulh.

• PEFY Series-Ceiling Concealed

### Ducted (Alternate High Static Option)-with capacities of 15/18/24/27/30/36/48/54/72/96 MBtulh.

• PEFY-F Series-Ceiling Concealed Ducted (100% OA Option)-with capacities of 30/54/72/96/120MBtulh.

• PEFY Series-Ceiling Concealed Ducted-with capacities of 06/08/12/15/18/24/27/30/36/48 MBtu/h.

•The PEFY-AF Series

- 100% outdoor air ventilation systems (Concealed

### ducted)- PEFY-AFI200CFM/CFMR**

- with amaximum outside air ventilation capability of 1200

### CFM.

12

# ~MIT5UBI5HI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024



### • PFFY Series-FloorStanding (Concealed)-withcapacities of06/08/12/15/18/24 MBtulh.

• PFFY Series-FloorStanding (Exposed)-with capacities of06/08/12/15/18/24 MBtulh.

• PKFY Series-Wall-Mounted-withcapacities of06/08/12/15/18/24/30 MBtu/h.

• PLFY Series--4-Way Airflow Ceiling Cassette-with capacities of 12/15/18/24/30/36 MBtulh.

• PLFY Series-2'-by-2' frame 4-Way Airflow Ceiling Cassette -with capacities of 8/12/15 MBtulh.

• PMFY Series-I-Way Airflow Ceiling Cassette-with capacities of06/08/12/15 MBlu/h.

• PVFY Series

- Vertical airhandler (Concealed ducted)

- with capacities of 12/18/24/30/36/42/48/54MBtu/h

• PWFY Series- Commercial HotWater HeatPump IndoorUnits

- with capacities of 36/72 MBtulh and 36 MBtlIlh with boosterunit.

13

# ,·,MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024 

### ATTACHMENTB CompleteListofModels for the S&L Class Systems (As updated in Februarv 2011) CITY MULTI Variable RefrigerantFlow Zoning System OutdoorEquipment: • Y-Series (PUHY) 208/230-3-60

### and 460-3-60 split-system variable-speed heat pumps with individual model nominal capacities ranging from 65,000 to 144,000Btu/h, and combined model nominal capacities ranging from 130,000, to 480,000 Btu/h.

•H2I-Series (PUHY-HP) 2081230-3-60 

### and 460-3-60 split-system variable speedheat pumps with hyper-heattechnology, with individual model nominal capacities ranging from 65,000 to 120,000 Btu/h, and combined model nominal capacities ranging from 130,000 to 300,000 Btu/h.

•R2-Series (PURY) 208/230-3-60 

### and 460-3-60 split-system variable speed heat pumps with heat recovery and with individual model nominal capacities ranging from 65,000 to 144,000 Btu/h, and combined model nominal capacities ranging from 130,000 to 300,000 Btu/h. CITYMULTI Variable Refrigerant Flow Zoning SystemIndoorEquipment: P*FY indoor models, ranging from 6,000 to 48,000 Btu/h, 

### 208/230-1-60 and from 72,000 to 120,000Btu/h. 208/230-3-60

### for use in split system variable-capacity air conditionerorheatpump systems:

• PCFY Series-Ceiling Suspended- with capacities of 12115118/24/30/36 

### MBtu/h.

• PDFY Series-Ceiling Concealed Ducted-with capacities of 06/08112115118124127/30136/48 

### MBtu/h.

• PEFY Series-Ceiling Concealed Ducted (Low Profile)-with capacities of 06/08112115118/24 

### MBlU/h.

• PEFY Series-Ceiling ConcealedDucted (Alternate High Static Option)-with capacities of 15118/24/27/30/36/48/54/72/96

### MBtu/h.

• PEFY-FSeries-Ceiling ConcealedDucted (100% OA Option)-with capacities of 30/54172/961120

### MBtu/h.

• PEFY Series-Ceiling ConcealedDucted-with capacities of 06/08112115118/24/27/30/36/48 

### MBtu/h.

14Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024



### •The PEFY-AF Series

- 100% outdoor air ventilation systems (Concealed ducted)- PEFY-AFI200CFM/CFMR**

- with a maximum outside air ventilation capability of 1200 CFM.

• PFFY Series-FloorStanding (Concealed)-with capacities of06/08/12/15/18/24 MBtulh.

• PFFY Series-FloorStanding (Exposed)-with capacities of06/08/12/15/18/24 MBtulh.

• PKFY Series-Wall-Mounted-with capacities of06/08/12/15/18/24/30 MBtu/h.

• PLFY Series--4-Way Airflow Ceiling Cassette-with capacities of 12/15/18/24/30/36 MBtu/h.

• PLFY Series-2'-by-2' frame 4-Way Airflow Ceiling Cassette -with capacities of 8/12/15 MBtu/h.

• PMFY Series-I-Way Airflow Ceiling Cassette-with capacities of06/08/12/15 MBtulh.

• PVFY Series

- Vertical airhandler (Concealed ducted)

- with capacities of 12/18/24/30/36/42/48/54MBtu/h

• PWFY Series- Commercial HotWater HeatPump IndoorUnits

- with capacities of 36/72 MBtulh and 36 MBtulh with booster unit.

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# '+,MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road. Suwanee, GA 30024 ATTACHMENT C Alternate TestProcedure for the WR2 and WY Series (Established in the WR2 and WY Waiver, Dec. IS, 2009) (A) Mitsubishi shall be required to test its water-sourceWR2 and WY series models ofits CITY MULTI VRFZequipment according to those test procedures for commercial package air conditioners and heat pumps prescribed at 10 CFR Part431.96, except that: (i) Mitsubishi shall test a "tested combination" selected in accordance with the provisions of subparagraph (B) ofthis paragraph. Forevery other systemcombination using the same outdoor unit as the tested combination, Mitsubishi shall make representations concerning the WR2 and WY CITY MULTIequipment covered in this waiver according to the provisions of subparagraph (C) below. (B) Tested combination. The term "tested combination" means a sample basic model comprised ofunits that are production units, or are representative ofproduction units, ofthe basic model being tested. Forthe purposes ofthis waiver, the tested combination shall have the following features: (I) The basic model ofa variable refrigerant flow system used as atested combination shall consist ofan outdoor unit that is matched with between two and five indoor units. (2) The indoor units shall- (i) Represent the highest sales model family, or another indoor model family ifthe highest sales model family does not provide sufficientcapacity (see ii); (ii) Together, have a nominal cooling capacity between 95 percent and 105 percent ofthe nominal cooling capacity ofthe outdoor unit; (iii) Not, individually, have a nominal cooling capacity that is greaterthan 50 percent ofthe nominal cooling capacity ofthe outdoor unit; (iv) Operate at fan speeds that are consistent with the manufacturer's specifications; and (v) All be subject to the same minimum external static pressure requirement while being configurable to produce the same static pressure at the exit ofeach outlet plenum when manifolded as per section 2.4.1 of 10 CFR Part430, SubpartB, Appendix M, (C) Representations. In making representations about the energy efficiency ofits WR2 and WY CITY MULTI VRFZ equipment, for compliance, marketing, or otherpurposes, Mitsubishi must fairly disclose the results oftesting underthe DOE test procedure, doing so in a manner consistent with the provisions outlined below:
16Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road, Suwanee. GA 30024
(i) ForWR2 and WY CITY MULTI VRFZcombinations tested in accordance with this alternate test procedure, Mitsubishi may make representations based on these test results. (ii) ForWR2 and WY CITY MULTI VRFZcombinations that are not tested, Mitsubishi may make representations based on the testing results for the tested combination and which are consistent with either ofthe two following methods: (a) Representation ofnon-tested combinations according to an Alternative Rating Method (ARM) approved by DOE; or (b) Representation ofnon-tested combinations at the same energy efficiency level as the tested combination with the same outdoor unit. (5) This waiver shall remain in effect from the date ofissuance ofthis Decision and Order consistent with the provisions of 10 CFR 431.40I(g). (6) This waiveris conditioned upon the presumed validity ofstatements, representations, and documentary materials provided by the petitioner. This waiver may be revoked or modified at any time upon a determination that the factual basis underlying the petition is incorrect, or DOE determines that the results from the alternate test procedure are unrepresentative ofthe basic models' true energy consumption characteristics.

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# •• ....MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road. Suwanee, GA 30024 

### ATTACHMENTD Alternate TestProcedurefor S&L Class Products (Established in 

### S&L Class Waiver, Dec. IS, 2009) (A) MEUS shall be required to test the products listed in paragraph (2) above according to the test procedure for central air conditioners and heat pumps prescribed by DOE at 10 CFR Part431 (ARl 340/360-2004, (incorporated by reference in 10 CFR431.95(b)(2)), except that MEUS shall test a "tested combination" selected in accordance with the provisions ofsubparagraph (B) ofthis paragraph. Forevery othersystem combination using the same outdoor unit as the tested combination, MEUS shall make representations concerning the S&LClass products covered in this waiver according to the provisions ofSUbparagraph (C) below. (B) Tested combination. The term "tested combination" means a samplebasic model comprised ofunits that are production units, or are representative ofproduction units, ofthe basic model being tested. For the purposes ofthis waiver, the tested combination shall have the following features: (i) The basic model ofa variable refrigerant flow system used as atested combination shall consist an outdoorunit (an outdoorunit can include multiple outdoorunits that have been manifolded into a single refrigeration system, with a specific model number) that is matched with between 2 and 8 indoor units in total; for multi-split systems, each ofthese indoor units shall be designed for individual operation. (ii) The indoor units shall- (a) Representthe highest sales model family, or another indoor model family ifthe highest sales model family does not provide sufficient capacity (see ii); (b) Together, have anominal cooling capacity that is between 95% and 105% ofthe nominal cooling capacity ofthe outdoorunit; (c) Not, individually, have a nominal cooling capacity that is greater than 50% ofthe nominal cooling capacity ofthe outdoorunit; (d) Operate at fan speeds thatare consistent with the manufacturer's specifications; and (e) Be subjectto the same minimum external static pressure requirement while being configurable to produce the same static pressure at the exit ofeach outletplenum when manifolded as per section 2.4.1 of 10 CFR Part430, SubpartB, Appendix M. (C) Representations. In making representations about the energy efficiency ofits S&LClass variable speed and variable refrigerant volume air-cooled multi-splitheatpump and heat recovery system products, for compliance, marketing, orotherpurposes, Mitsubishi mustfairly
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# ~MITSUBISHI ELECTRIC Mitsubishi Electric & Electronics USA, Inc. HVAC Advanced Products Division 3400 Lawrenceville-Suwanee Road. Suwanee, GA 30024 disclose the results oftesting under the DOE test procedure, doing so in a mannerconsistent with the provisions outlined below: (i) For S&L Class combinations using asingle outdoor unit tested in accordance with this alternate test procedure, Mitsubishi may make representations based on these test results. (ii) For S&LClass combinations using a single outdoor unit that have not been tested, Mitsubishi may make representations based on the testing results for the tested combination and which are consistent with either ofthe two following methods: (a) Representation ofnon-tested combinations according to an Alternative Rating Method (ARM) approved by DOE; or (b) Representation ofnon-tested combinations at the same energy efficiency level as the tested combination with the same outdoor unit. (iii) For S&L Class combinations utilizing multiple outdoor units that have been tested in accordance with this alternate test procedure, MEUS may make representations based on those test results. (iv) For S&L Class combinations utilizing multiple outdoor units that have not been tested, MEUS may make representations which are consistent with any ofthe three following methods: (a) Representation ofnon-tested combinations according to an Alternative Rating Method ("ARM") approved by DOE. (b) Representation ofnon-tested combinations at the same energy efficiency level as the tested combination with the same combination ofoutdoor units. (c) Representation ofnon-tested combinations based on the capacity weighted average ofthe efficiency ratings for the tested combinations for each ofthe individual outdoor units used in the system, as determined in accordance with the provisions ofthis alternate test procedure. (4) This waiver shall remain in effectfrom the date ofissuance ofthis Orderconsistent with the provisions of 10 CFR 431.40I(g). (5) This waiver is conditioned upon the presumed validity ofstatements, representations, and documentary materials provided by the petitioner. This waiver maybe revoked or modified at any time upon a determination that the factual basis underlying the Petition for Waiver is incorrect, orDOE determines that the results from the alternate test procedure are unrepresentative ofthe basic models' true energy consumption characteristics.

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