....MITSUBISHI ELECTRIC

Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville·Suwanee Road, Suwanee, GA 30024

February 18, 20 II

The Honorable Cathy Zoi

Assistant Secretary for Energy Efficiency and Renewable Energy

U.S. Department of Energy

1000 Independence Ave, SW

Washington, DC 20585-0121

Re: Update to Previously-Granted Test Procedure for Waivers for CITY MULTI

VRFZ WR2 and WY Series and S&L Class Air Conditioners and Heat

Pumps

Dear Assistant Secretary Zoi:

On December 15, 2009, the Department of Energy (DOE) granted Mitsubishi Electric &

Electronics USA, Inc. (MEUS) a waiver from the DOE commercial air conditioner and heat

pump test procedures for MEUS's WR2 and WY Series productsl and the S&L Class products 2

These products are part of MEUS's CITY MULTI Variable Refrigerant Flow Zoning (VRFZ)

line of multi-split central air conditioners and heat pumps. As explained in MEUS's petitions for

waiver for the WR2 and WY Series and the S&L Class products, these systems cannot be tested

according to the prescribed test procedures for commercial products. Pursuant to DOE's grant of

the waivers, MEUS is not required to test or rate 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 of indoor units 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 Waiver and 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 of models covered by the applicable test procedure

I Energy Conservation Program for Certain Industrial Eqaipmem: Decision and Order Grallting a Waiver to

MilSltbishi Electric alld Electronics USA, Inc. From the Department ofEnergy Commercial Package Water-Source

Heat Pump Test Procedure, 74 Fed. Reg. 6631 J (Dec. 15,2009) (''WR2 and WY Series Waiver").

2 Energy Conservation Program for Certain Industrial Equipment: Decision and Order Granting a Waiver to

Mitsubishi Electric & Electronics USA, fnc. From the Department ofEnergy Commercial Package Air Conditioner

alld Heal 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 cover these additional indoor models. 3 MEUS simultaneously requests an interim

waiver covering systems using these additional indoor models.

MEUS frames this request to update the list of models covered by two already-granted

waivers pursuant to the requirements for granting new test procedure waivers' Given that this

request simply addresses the addition of certain new indoor models for MEUS's WR2 and WY

Series and the S&L Class products, and that DOE previously has granted waivers for the outdoor

units and other indoor units for these systems, if DOE would prefer to utilize a procedurally

simpler approach for updating the covered list of models, MEUS would welcome such an

approach.

Background

On October 30, 2006, MEUS submitted a Petition for Waiver from the test procedures

applicable to the water-source WR2 and WY Series of its CITY MULTI VRFZ line of

commercial package heat pump equipment. Mitsubishi sought a waiver from the applicable test

procedures because the design characteristics of these models prevented testing according to the

currently prescribed test procedures. Specifically, these models can connect an outdoor unit to

many more indoor units than the test laboratories can physically test at one time, and it is not

practical to test all of the potentially available combinations. DOE granted the requested waiver

because "the basic model [of these products] contains one or more design characteristics which .

. . prevent testing of the 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 of commercial

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

of indoor units with a single outdoor unit to test. DOE agreed with MEUS that the existing

testing facilities have limited ability to test multiple indoor units at one time, and that the number

of possible combinations of indoor and outdoor units 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 Series Waiver 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 of these indoor model families, MEUS has developed

an additional model with a capacity 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 customer demands for

specialized applications.

When MEUS originally applied for a waiver for 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 of available indoor units to suit consumers' specific needs. MEUS

plans to add five new types of indoor unit families to the line-up of indoor units that can be

matched with the CITY MULTI outdoor units. 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

of the 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 Waiver be

updated to cover the following additional indoor units:

• PCFY-Series - Ceiling Suspended - with a capacity of 15 MBtu/h

• PEFY Series - Ceiling Concealed Ducted (Low Profile) - with a capacity of 15 MBtulh

• PKFY Series - Wall Mounted - with a capacity of 15 MBtu/h

• PLFY Series - 4-Way Airflow Ceiling Cassette - with a capacity of 15 MBtulh

• The PEFY-AF Series - 100% outdoor air ventilation systems (Concealed ducted)-

PEFY-AFI200CFM/CFMR** - with a maximum outside air ventilation capability of

1200CFM

• The PVFY Series - Vertical air handler (Concealed ducted) - with capacities of

12/18/24/30/36/42/48/54 MBtulh

• PWFY Series- Commercial Hot Water Heat Pump Indoor Units - with capacities of

36/72 MBtulh and 36 MBtulh with booster unit.

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

06/08112115118124127/30/36/48 MBtuth

• PLFY Series-2'-by-2' frame 4-Way Airflow Ceiling Cassette -with capacities of

8112115 MBtuth

For DOE's convenience, MEUS is attaching comprehensive lists of all of the models for

the WR2 and WY Series and S&L Class systems that include the outdoor and indoor models

covered by previously granted waivers in the WR2 and WY Series Waiver and the S&L Class

Waiver, plus the additional indoor models that are the subject of this petition. MEUS

respectfully requests that DOE replace, in its entirety, the lists of models included in the WR2

and WY Series Waiver and the S&L Class Waiver with the lists included as Attachment A and

Attachment B to this petition upon grant of this waiver petition. Having an updated

comprehensive list will assist DOE and market participants in easily keeping track of all of the

WR2 and WY Series and S&L Class models that are subject to a DOE-granted waiver.

Test Procedures from which Waiver is 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.

For the water source products, DOE's regulations provide the test procedures for small

and large commercial package air conditioning 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 135,000 Btuth, are those included in

[SO Standard 13256-1 (1998). The capacities of MEUS'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 air conditioning equipment with capacities between

65,000 and 760,000 Btuth, ARI Standard 340/360-2004 is the applicable test procedure under 10

C.F.R. § 431.96. The capacities of MEUS'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&L Class

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&L Class 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 of Test Procedures

The Department's regulations contain provisions allowing a person to seek a waiver from

the test procedure requirements for commercial equipment. These provisions are set forth in 10

C.F.R. § 431.40 I. The waiver provisions allow DOE to temporarily waive test procedures for a

particular basic model when a petitioner shows that the basic model contains one or more design

characteristics that prevent testing according to the prescribed test procedures, or when the

prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its

true energy consumption as to provide materially inaccurate comparative data 9

As explained above, DOE granted the WR2 and WY Series products a waiver because

"the basic model [of these products] contains one or more design characteristics which ...

prevent testing of the 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 of possible

combinations of indoor and outdoor units is impractical to test, and thus granted MEUS's

requested waiver. I I The additional indoor models that are the subject of this petition would be

used just 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 of the 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 outdoor units. 12 MEUS is not proposing to add new outdoor units to

the WR2 and WY Series Waiver and S&L Class Waiver. The indoor units described above will

be combined with the same outdoor unit 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 of the Energy Policy and Conservation Act (EPCA) to

promote energy efficiency. Testing procedures should not inhibit the commercial success of

these products in the United States. Without a waiver of the 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 of the

CITY MULTI products in the U.S. marketplace, and a significant number of engineers and

contractors are currently requesting these WR2 and WYand S&L Class products for their

projects because of the great advantages they offer. Thus, MEUS respectfully requests that DOE

grant a waiver from the applicable test procedures.

Alternative Test Procedures

Both the WR2 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&L class products. 13

No changes to those alternate test procedures are needed to cover the additional indoor units that

are the subject of this petition. Therefore, MEUS requests that the products listed herein be

subject to the same alternate test procedures as in the WR2 and WY Series Waiver and the S&L

Class Waiver, as applicable.

For DOE'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.

Similar Products

To the best of our knowledge, water-source VRFZ products or products similar to

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 of the 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 of such prescribed test procedures. 14 As DOE has stated,

"an Interim Waiver will be granted if it is determined that the applicant will experience

economic hardship if the Application for Interim Waiver is denied, if it appears likely that 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 relief pending a determination for the

Petition for Waiver." 15 MEUS will experience economic hardship if the application for interim

13 WR2 and WY Series Waiver aI 66313; S&L Class Waiver at 66317.

" 10 C.FR. § 431.401 (a)(2).

15 Energy Conservation Program/or Consumer Products: Publication a/the Petition/or Waiver and Grantin.g of

the Application/or Imerim Waiver ofSarnsun.g Air Conditioning From the DOE Residelllial and 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 DOE to 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 a time-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

number of months. If an interim waiver is not granted, MEUS will suffer economic hardship

because MEUS will be required to delay its introduction of these 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 wai vel'. for the WR2 and WY Series and S&L Class products. The indoor models that

are the subject of this request include the same design characteristics that prevented testing of the

basic model of the products listed in the WR2 and WY Series Waiver and the S&L Class

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

Package Air Conditioner and Heat 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).

16 See WR2 and WY Series Waiver and the S&L Class Waiver. See also, Energy Conservation Program for

COI/SLimer Prodltcts: Decision alld Order Grallfillg a Waiver From the DOE Commercial Package Air Conditioner

and Heat PUIllP Test Procedure to Mitsubislii Electric (Case No. CAC- 008),69 Fed. Reg. 52660 (Aug. 27,2004);

Energy Consen/arion Program/or Consumer Prodlicts: Decision and Order Graliling a Waiver From the

Departmellt ofEnergy (DOE) Residemial and Commercial Package Air Conditioner alld Heal Pump Test

Procedures to Mitsubishi Electric, and Modification oj(l 2004 Waiver Gramed to Mitsubishi Electric From the

Same DOE Test Procedures (Case No. CAC-OI2), 72 Fed. Reg. 17528 (Apr. 9, 2007); Energy Conservatiou

Program for Consumer Products: Decision and Order Graming a Waiver to Fujitsu General From the Department

ofEnergy Residelllial Celllral Air Couditioner and Heat Pump Test Procedure rCase No. CAC-OIOr, 72 Fed. Reg.

71383 (Dec. 17,2007); Energy Conservation Programfor Consumer Products: Decision and Order Grallting a

Waiver to Samsllng Air Conditioning From the Departmellt ofEnergy Residelltial and Commercial Package Air

Couditioueraud Heat Pump Test Procedures rCase No. CAC-009J, 72 FR 71387 (Dec. 17,2007); Energy

Conservation Program/or Consumer Products: Decision and Order Granting a Waiver to Daikin u.s. Corporation

From the Department ofEnergy Commercial Package Air Conditioner alld Heat Pump Test Procedures alld

Den)'ing a Waiver From the Residential Central Air Conditioner and Heat Pump Test Procedures, 73 Fed. Reg.

39680 (July 10,2008); Energy Conservation Program/or Commercial Equipment: Decision and Order Graming a

Waiver to Daikin AC (Americas), Inc. From tlte Department ofEnergy Commercial Package Air Conditioner and

Heat Pump Test Procedures, 74 Fed. Reg. 15955 (Apr. 8,2009); Energy Conservation Program for Commercial

Equipment: Decision alld Order Granting a Waiver to 5an)'0 Fisher Company From the Department of Energy

Commercial Package Air Conditioner and Heat Pump Test Procedure and Denying a Waiver From the Residelltial

Central Air Conditioner and Heat Pump Test Procedure, 74 Fed. Reg. 16193 (Apr. 9,2009); Ellergy Conservation

Program/or Certain Industrial Equipmellt: Decision and Order Granting (l Waiver to Daikin AC (Americas), lllc.

From the Department 0/Energy Commercial Package Water-Source Air Conditioner and Heat Pump Test

Procedure, 74 FR 16373 (Apr. 10,2009); Ellergy Conservation Program/or Commercial Equipment: Decision and

Order Granting a Waiver to Daikin AC (Americas). Inc. (Daikin) From the Departme1lt of Energy Commercial

Package Air Conditioner and Heat Pump Test Procedures, 75 Fed. Reg. 22581 (Apr. 29, 20 I0); and Energy

Conservation Program/or Certain Commercial and Indusrrial Eqllipment: Decision and Order Grallting 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

if he determines that it would be desirable for public policy reasons to grant immediate relief

pending a determination 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 of the Petition for Waiver has been demonstrated, based upon DOE having granted

a waiver for a similar product design, it is in the public interest to have similar products tested

and rated for energy consumption on a comparable 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 by the earlier waivers. Therefore, since

it is in the public interest to have similar products tested and rated on a comparable basis, DOE

should grant MEUS's Application for Interim Waiver.

Conclusion

MEUS respectfully requests that DOE update the list of models 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 of covered products, as updated,

"contain[] one or more design characteristics which ... prevent testing of the 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 Department ofEnergy Commercial Package Air Conditioner and

Heat PUIIlP Test Procedures, 75 Fed. Reg. 41845 (July 19,2010);

11 Ellergy Conservation Program for Consumer Products: Publication ofrhe Petition for Waiver alld Granting of

the Application for Interim Waiver ofMirSflbishi Electric 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).

8
Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

If you have any questions or would like to discuss this request, please contact Paul

Doppel, at (678) 376-2923, or Douglas Smith at (202) 298-1902. We greatly appreciate your

attention to this matter.

Sincerely,

, 'v·&-

William Rau

Senior Vice 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

I hereby certify that I have this day served the foregoing Petition for Waiver and

Application for Interim Waiver 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 MULTT VRFZ system design. I have notified

these manufacturers that the Assistant Secretary 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.

300 I Northern Star Blvd

Ft Worth TX 76137

Attn: Malt Wall

Sanyo Commercial Solutions

HVAC Solutions

1690 Roberts Blvd Nw

Suite 110

Kennesaw, GA 301

Attn: Gary ettinger, Vice President, 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 of February, 2011.

William R u

Senior Vice President and General Manager

HVAC Advanced Products Division

Mitsubishi Electric & Electronics USA, Inc.

3400 Lawrenceville-Suwanee Road

Suwanee, GA 30024

1I
Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

ATTACHMENT A

Complete List of Models for the WR2 and WY Series

(As updated in February 2011)

CITY MULTI Variable Refrigerant Flow Zoning System Outdoor Equipment:

• WY-Series (PQHY) 208/230-3-60 and 460-3-60 split-system, water-sourced,

variable-speed heat pumps with individual model nominal cooling capacities of 72,000,

96,000, 108,000 and 120,000 Btulh.

• WR2-Series (PQRY) 208/230-3-60 and 460-3-60 split-system, water-sourced,

variable-speed heat pumps with heat recovery and with individual

model nominal cooling capacities of 72,000,96,000, 108,000 and 120,000 Btu/h.

CITY MULTI Variable Refrigerant Flow Zoning System Indoor Equipment: P*FY indoor

models, ranging from 6,000 to 48,000 Btulh, 208/230 I 60 and from 72,000 to 120,000 Btulh,

208/230-3-60 for use in split system variable-capacity air conditioner or heat pump systems:

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

30/54/72/96/120 MBtulh.

• 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 a maximum 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-Floor Standing (Concealed)-with capacities of 06/08/ 12/ 15/18/24

MBtulh.

• PFFY Series-Floor Standing (Exposed)-with capacities of 06/08/12/ 15/18/24

MBtulh.

• PKFY Series-Wall-Mounted-with capacities of 06/08/12/15/18/24/30 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 of 06/08/12/15

MBlu/h.

• PVFY Series - Vertical air handler (Concealed ducted) - with capacities of

12/18/24/30/36/42/48/54 MBtu/h

• PWFY Series- Commercial Hot Water Heat Pump Indoor Units - with capacities of

36/72 MBtulh and 36 MBtlIlh with booster unit.

13
,·,MITSUBISHI ELECTRIC

Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024

ATTACHMENTB

Complete List of Models for the S&L Class Systems

(As updated in Februarv 2011)

CITY MULTI Variable Refrigerant Flow Zoning System Outdoor Equipment:

• 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 144,000 Btu/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 speed heat

pumps with hyper-heat technology, 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.

CITY MULTI Variable Refrigerant Flow Zoning System Indoor Equipment: P*FY indoor

models, ranging from 6,000 to 48,000 Btu/h, 208/230-1-60 and from 72,000 to 120,000 Btu/h.

208/230-3-60 for use in split system variable-capacity air conditioner or heat pump 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 Concealed Ducted (Alternate High Static Option)-with

capacities of 15118/24/27/30/36/48/54/72/96 MBtu/h.

• PEFY-F Series-Ceiling Concealed Ducted (100% OA Option)-with capacities of

30/54172/961120 MBtu/h.

• PEFY Series-Ceiling Concealed Ducted-with capacities of

06/08112115118/24/27/30/36/48 MBtu/h.

14
Mitsubishi 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-Floor Standing (Concealed)-with capacities of 06/08/12/15/18/24

MBtulh.

• PFFY Series-Floor Standing (Exposed)-with capacities of 06/08/12/15/18/24

MBtulh.

• PKFY Series-Wall-Mounted-with capacities of 06/08/12/15/18/24/30 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 of 06/08/12/15

MBtulh.

• PVFY Series - Vertical air handler (Concealed ducted) - with capacities of

12/18/24/30/36/42/48/54 MBtu/h

• PWFY Series- Commercial Hot Water Heat Pump Indoor Units - with capacities of

36/72 MBtulh and 36 MBtulh with booster unit.

15
'+,MITSUBISHI ELECTRIC

Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road. Suwanee, GA 30024

ATTACHMENT C

Alternate Test Procedure 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-source WR2 and WY series models of its CITY

MULTI VRFZ equipment according to those test procedures for commercial package air

conditioners and heat pumps prescribed at 10 CFR Part 431.96, except that:

(i) Mitsubishi shall test a "tested combination" selected in accordance with the provisions of

subparagraph (B) of this paragraph. For every other system combination using the same outdoor

unit as the tested combination, Mitsubishi shall make representations concerning the WR2 and

WY CITY MULTI equipment 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

of units that are production units, or are representative of production units, of the basic model

being tested. For the purposes of this waiver, the tested combination shall have the following

features:

(I) The basic model of a variable refrigerant flow system used as a tested combination shall

consist of an 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 if the highest sales

model family does not provide sufficient capacity (see ii);

(ii) Together, have a nominal cooling capacity between 95 percent and 105 percent of the

nominal cooling capacity of the outdoor unit;

(iii) Not, individually, have a nominal cooling capacity that is greater than 50 percent of the

nominal cooling capacity of the 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 of each outlet plenum when

manifolded as per section 2.4.1 of 10 CFR Part 430, Subpart B, Appendix M,

(C) Representations. In making representations about the energy efficiency of its WR2 and WY

CITY MULTI VRFZ equipment, for compliance, marketing, or other purposes, Mitsubishi must

fairly disclose the results of testing under the DOE test procedure, doing so in a manner

consistent with the provisions outlined below:

16
Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road, Suwanee. GA 30024

(i) For WR2 and WY CITY MULTI VRFZ combinations tested in accordance with this alternate

test procedure, Mitsubishi may make representations based on these test results.

(ii) For WR2 and WY CITY MULTI VRFZ combinations that are not tested, Mitsubishi may

make representations based on the testing results for the tested combination and which are

consistent with either of the two following methods:

(a) Representation of non-tested combinations according to an Alternative Rating Method

(ARM) approved by DOE; or

(b) Representation of non-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 of issuance of this Decision and Order

consistent with the provisions of 10 CFR 431.40 I(g).

(6) This waiver is conditioned upon the presumed validity of statements, 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 of the basic

models' true energy consumption characteristics.

17
••.... MITSUBISHI ELECTRIC

Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road. Suwanee, GA 30024

ATTACHMENTD

Alternate Test Procedure for 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 Part 431

(ARl 340/360-2004, (incorporated by reference in 10 CFR 431.95(b)(2)), except that MEUS

shall test a "tested combination" selected in accordance with the provisions of subparagraph (B)

of this paragraph. For every other system combination using the same outdoor unit as the tested

combination, MEUS shall make representations concerning the S&L Class products 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

of units that are production units, or are representative of production units, of the basic model

being tested. For the purposes of this waiver, the tested combination shall have the following

features:

(i) The basic model of a variable refrigerant flow system used as a tested combination shall

consist an outdoor unit (an outdoor unit can include multiple outdoor units 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 of these indoor units

shall be designed for individual operation.

(ii) The indoor units shall-

(a) Represent the highest sales model family, or another indoor model family if the highest sales

model family does not provide sufficient capacity (see ii);

(b) Together, have a nominal cooling capacity that is between 95% and 105% of the nominal

cooling capacity of the outdoor unit;

(c) Not, individually, have a nominal cooling capacity that is greater than 50% of the nominal

cooling capacity of the outdoor unit;

(d) Operate at fan speeds that are consistent with the manufacturer's specifications; and

(e) Be subject to the same minimum external static pressure requirement while being

configurable to produce the same static pressure at the exit of each outlet plenum when

manifolded as per section 2.4.1 of 10 CFR Part 430, Subpart B, Appendix M.

(C) Representations. In making representations about the energy efficiency of its S&L Class

variable speed and variable refrigerant volume air-cooled multi-split heat pump and heat

recovery system products, for compliance, marketing, or other purposes, Mitsubishi must fairly

18
~MITSUBISHI ELECTRIC

Mitsubishi Electric & Electronics USA, Inc.

HVAC Advanced Products Division

3400 Lawrenceville-Suwanee Road. Suwanee, GA 30024

disclose the results of testing under the DOE test procedure, doing so in a manner consistent with

the provisions outlined below:

(i) For S&L Class combinations using a single outdoor unit tested in accordance with this

alternate test procedure, Mitsubishi may make representations based on these test results.

(ii) For S&L Class 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 of the two following methods:

(a) Representation of non-tested combinations according to an Alternative Rating Method

(ARM) approved by DOE; or

(b) Representation of non-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 of the three following methods:

(a) Representation of non-tested combinations according to an Alternative Rating Method

("ARM") approved by DOE.

(b) Representation of non-tested combinations at the same energy efficiency level as the tested

combination with the same combination of outdoor units.

(c) Representation of non-tested combinations based on the capacity weighted average of the

efficiency ratings for the tested combinations for each of the individual outdoor units used in the

system, as determined in accordance with the provisions of this alternate test procedure.

(4) This waiver shall remain in effect from the date of issuance of this Order consistent with the

provisions of 10 CFR 431.40 I(g).

(5) This waiver is conditioned upon the presumed validity of statements, 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 for Waiver is

incorrect, or DOE determines that the results from the alternate test procedure are

unrepresentative of the basic models' true energy consumption characteristics.

19