NOPR Public Meeting

February 6, 2015

Energy Conservation Standards: 

Notice of Proposed Rulemaking for

Single Package Vertical Units

Ronald Majette

SPVU2012STD0041@ee.doe.gov

Building Technologies Office

Energy Efficiency & Renewable Energy

Department of Energy
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of 

this meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar 

conversations.

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Agenda

9:00 – 9:15 am Welcome; Introductions; and Agenda Review

Doug Brookman

9:15 – 9:30 am Purpose of Public Meeting; Opening Statements; Comment Submission Instructions; Regulatory 

Authority; Rulemaking Overview 

Ronald Majette

9:30 – 9:45 am Market and Technology Assessment; Screening Analysis

Samuel McClive

9:45 – 10:15 am Engineering Analysis

Samuel McClive

10:15 – 10:30 am BREAK

10:30 – 11:00 am Energy Use Analysis; Markups Analysis; Life-Cycle Cost and Payback Period Analysis

Abinesh Selvacanabady, Scott Morris

11:00 – 11:20 am Shipments; National Impact Analysis

Alison Williams

11:20 – 11:30 am Manufacturer Impact Analysis

Christopher Lau

11:30 – 11:40 am NOPR Analyses

Alison Williams

11:40 – 11:50 am Proposed Standards

Samuel McClive

11:50 – 12:00 pm Closing Remarks from Interested Parties

Ronald Majette
4

Participating Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

who are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in, view the 

slides, and participate directly.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
5

Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate 

potential energy conservation standards for single package 

vertical air conditioners (SPVACs) and single package vertical 

heat pumps (SPVHPs), collectively referred to as single 

package vertical units (SPVUs).

• Invite comment on the energy conservation standards notice 

of proposed rulemaking (NOPR) and technical support 

document (TSD), including DOE’s proposed standard levels.

• Invite participants to provide summary comments or 

statements and raise additional issues for discussion. 
6

Issues for Discussion

The deadline for submitting comments is March 2, 2015.

Issue Box: DOE welcomes comments, data, and information 

concerning its proposed standards for SPVUs. Issues that 

correspond to those raised in DOE’s published material will be 

numbered in accordance with that material. Whether invited by 

an issue box or not, comments are welcome on any part of 

DOE’s analysis.
7

Opening Remarks

Meeting participants are invited to provide opening 

remarks or statements at this time.
8

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
9

Regulatory Authority

• The Energy Policy and Conservation Act of 1975 (EPCA), as amended by the 

Energy Independence and Security Act of 2007 (EISA 2007), prescribes energy 

conservation standards and definitions for single package vertical air 

conditioners and single package vertical heat pumps. (42 U.S.C. 6313(a)(10)(A))

• One-Time SPVU Review: EISA 2007 amended EPCA to require that DOE review 

the most recently published ASHRAE Standard 90.1 with respect to SPVACs and 

SPVHPs. (42 U.S.C. 6313(a)(10)(B))

• ASHRAE Trigger: EPCA also directs DOE to consider amending the existing 

Federal energy conservation standard for each type of equipment listed at 42 

U.S.C. 6313(a)(6)(A)(i), including SPVUs, each time ASHRAE Standard 90.1 is 

amended with respect to such equipment. (42 U.S.C. 6313(a)(6)(A)-(B))

• 6-Year Look Back: Pursuant to the EISA 2007 and the American Energy 

Manufacturing Technical Corrections Act (AEMTCA) amendments to EPCA, under 

42 U.S.C. 6313(a)(6)(C), DOE must also review its already-established energy 

conservation standards for each class of ASHRAE equipment every six years.

• This rulemaking simultaneously satisfies all 3 review requirements.
10

Rulemaking History

• 2007: 

– EISA 2007 establishes standards for SPVUs identical to those in the thencurrent version of ASHRAE Standard 90.1 (i.e., ASHRAE Standard 90.1-2004).

– EISA 2007 directs DOE to conduct a one-time review of the SPVU standards.

• 2011:

– DOE commenced the statutorily required review with a notice of data 

availability (NODA) published on May 5, 2011, considering levels above 

those in ASHRAE, which were still equivalent to the Federal standards (as 

contained in ASHRAE Standard 90.1-2010). 76 FR 25622.

• 2013:

– Prior to DOE issuing a NOPR, ASHRAE published Standard 90.1-2013 on 

October 9, 2013, triggering DOE’s obligation to consider the revised ASHRAE 

levels for SPVUs, unless clear and convincing evidence justified higher levels.

• 2014:

– DOE published an analysis of energy savings potential on April 11, 2014. 79 

FR 20114.

– DOE published the NOPR on December 30, 2014. 79 FR 78614.
11

Definitions

EISA 2007 defines SPVUs as follows:

• A single package vertical air conditioner (SPVAC) is air-cooled commercial package airconditioning and heating equipment that is: 

– (1) Factory-assembled as a vertically arranged, single package encased combination of 

cooling and optional heating components, mounted on or through an exterior wall*;

– (2) Powered by a single- or 3-phase current;

– (3) May contain 1 or more separate indoor grilles, outdoor louvers, various ventilation 

options, indoor free air discharges, ductwork, wall plenum, or sleeves; and

– (4) The optional heating components may include electrical resistance, steam, hot 

water, or gas, but may not include reverse cycle refrigeration as a heating means.

• A single package vertical heat pump (SPVHP) is an SPVAC that: 

– (1) Uses reverse cycle refrigeration as its primary heat source; and

– (2) May include secondary supplemental heating by means of electrical resistance, 

steam, hot water, or gas.

(42 U.S.C. 6311(22)-(23))

*Note: In the Notice of Data Availability (NODA) initiating this rulemaking, DOE published a determination 

stating that, based on product literature and definitions in EPCA, certain units which fit the above definition of 

an SPVU are primarily advertised for multi-family residential use and are appropriately classified as 

residential central air conditioners and heat pumps. 79 FR 20114, 20122-23 (April 11, 2014).
12

Energy Conservation Standards for SPVUs

Equipment 

Type Cooling Capacity (Btu/h) EISA 2007* ASHRAE 90.1-2013

SPVAC

<65,000 Btu/hour EER: 9.0 EER: 10.0

≥65,000 Btu/h and <135,000 Btu/h EER: 8.9 EER: 10.0

≥135,000 Btu/h and <240,000 Btu/h EER: 8.6 EER: 10.0

SPVHP

<65,000 Btu/hour EER: 9.0, COP: 3.0 EER: 10.0, COP: 3.0

≥65,000 Btu/h and <135,000 Btu/h EER: 8.9, COP: 3.0 EER: 10.0, COP: 3.0

≥135,000 Btu/h and <240,000 Btu/h EER: 8.6, COP: 2.9 EER: 10.0, COP: 3.0

• SPVUs are divided into six different equipment classes based on cooling 

capacity and whether they are SPVAC or SPVHP.

• Energy efficiency standards are distinguished by EER (energy efficiency 

ratio) for SPVACs, and EER supplemented by a corresponding heating mode 

COP (coefficient of performance) value for SPVHPs.

• The DOE test procedure for SPVUs is outlined in 10 CFR 431.96(b). The test 

procedure incorporates AHRI 390-2003 by reference, which provides a 

method for determining EER and COP. 

*Current Federal energy conservation standard cited in 10 CFR 431.97
13

Criteria for Selecting Standard Levels

• For each type of equipment, EPCA directs that if ASHRAE 

Standard 90.1 is amended, DOE must review and adopt 

amended standards at the new efficiency level in ASHRAE 

Standard 90.1, unless clear and convincing evidence supports a 

determination that adoption of a more-stringent efficiency level 

would:

– Produce significant additional energy savings;

– Be technologically feasible; and

– Be economically justified. (42 U.S.C. 6313(a)(6)(A)(ii))

• DOE must either adopt the amended ASHRAE levels within 18 

months after publication of ASHRAE 90.1 or promulgate morestringent standards not later than 30 months after publication 

of ASHRAE 90.1. (42 U.S.C. 6313(a)(6)(A)(ii)(I) and (B)(i))
14

Criteria for Selecting Standard Levels

The Energy Policy and Conservation Act directs DOE to consider seven factors 

when setting energy conservation standards higher than the ASHRAE level. 

(42 U.S.C. 6313(a)(6)(B)(ii))

EPCA Factor Corresponding DOE Analysis

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analysis

Manufacturer impact analysis

2. Lifetime operating cost savings Life-cycle cost analysis

3. Total projected energy savings National impact analysis 

4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of competition Manufacturer impact analysis

6. Need for national energy conservation National impact analysis

7. Other factors the Secretary considers 

relevant

Emissions analysis

Utility impact analysis

Employment impact analysis
15

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
16

Energy Conservation Standards Rulemaking

 

Framework

Document

Preliminary 

Analysis NOPR FinalRule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
17

Market and Technology Assessment: Introduction

• The goal of the market assessment was to develop a 

qualitative and quantitative characterization of the SPVU 

industry and market structure based on data that DOE 

gathered from manufacturers, other interested parties, and 

literature review.

• The technology assessment was performed to develop a list 

of technologies (“design options”) that could be used to 

improve the energy efficiency of SPVUs. 
18

Market Assessment: General Overview

• SPVACs and SPVHPs are used primarily for cooling and heating of 

the following structures, with the noted approximate percentage 

of shipments devoted to each end usage:

• Educational facilities (i.e., modular classrooms) (~35% of 

shipments)

• Modular and portable buildings (~30% of shipments)

• Telecommunications and electronics enclosures (~35% of 

shipments)
19

Market Assessment: General Overview (cont.)

• SPVUs have similar cooling/heating capacities as products used in 

residential applications, but are subject to different operational 

cycles and operating hours than are typically encountered in 

residential applications. 

• As noted earlier, there are some products which meet the EISA 

2007 definition of an SPVU, but are advertised for use in residential 

applications. These products are classified as residential central air 

conditioners and heat pumps, and are not covered under this 

proposed rule.

• The market is composed of 2 major manufacturers, and 5 other 

manufacturers with relatively smaller market shares. 

– There are 2 domestic small business manufacturers.
20

Market Assessment: Equipment Class Distribution

• DOE developed a database of products available on the market by using 

data from the Air-Conditioning, Heating, and Refrigeration Institute 

(AHRI)’s Directory of Certified Product Performance, and product listings 

available on manufacturers’ websites. The number of products found in 

each equipment class is shown below:

• Approximately 97% of SPVUs available on the market have a cooling 

capacity less than 65,000 Btu/hr. There are no models on the market in 

the SPVAC ≥135,000 Btu/h and <240,000 Btu/h, SPVHP ≥65,000 Btu/h and 

<135,000 Btu/h, and SPVHP ≥135,000 Btu/h and <240,000 Btu/h 

equipment classes.

Equipment 

Type Cooling Capacity (Btu/h) Number of Models Offered

Percentage of Total 

Equipment Offerings

SPVAC

<65,000 Btu/hour 288 50%

≥65,000 Btu/h and <135,000 Btu/h 13 2%

≥135,000 Btu/h and <240,000 Btu/h 0 0

SPVHP

<65,000 Btu/hour 276 48%

≥65,000 Btu/h and <135,000 Btu/h 0 0

≥135,000 Btu/h and <240,000 Btu/h 0 0
21

Market Assessment: Efficiency Distribution

• The most common efficiency of equipment on the market is 9 EER, which 

is the current EPCA minimum efficiency level; 19% of equipment models 

have an efficiency of 9 EER. The highest efficiency unit on the market is 

12.3 EER. 

• The distribution of models across efficiency levels is skewed towards the 

lower end of the efficiency spectrum. Only about 11% of models are 

greater than 11 EER in efficiency. There are no models in the SPVAC ≥ 

65,000 Btu/h and <135,000 Btu/h equipment class which are greater than 

10 EER in efficiency.

• More detailed information on the efficiency distribution for each product 

class can be found in Chapter 3 of the NOPR TSD.

*
22

Technology Assessment: Overview

• Purpose

– To develop a preliminary list of design options that could improve the 

efficiency of SPVUs.

– This list is examined in greater detail, and inappropriate technologies 

are removed, in subsequent analyses. 

• DOE identified design options from:

– Literature review

– Manufacturer brochures and specification sheets for commerciallyavailable equipment

– Comments and input from stakeholders

• All design options are described in Chapter 3 of the TSD.
23

Technology Assessment: Technologies Identified

Potential Design Options for Improved Energy Efficiency of SPVUs

Increased frontal coil area Improved fan motor efficiency

Increased depth of coil Improved fan blades

Increased fin density Improved compressor efficiency

Improved fin design Multi-speed compressors

Improved tube design Thermostatic expansion valves

Hydrophilic film coating on fins Electronic expansion valves

Microchannel heat exchangers Thermostatic cyclic controls

Dual condenser heat exchangers
24

Screening Analysis: Purpose

• Purpose

– To determine which design options will be considered in downstream 

analyses.

• Design options are “screened out” if they

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to customers

– Have adverse impacts on health or safety

• In this analysis, DOE also removed from consideration technologies 

that do not affect calculated energy consumption as measured by 

the test procedure.

• In addition, technologies that are already common in baseline SPVU 

designs were not considered further.

• The methodology and results are presented in detail in Chapter 4 of 

the NOPR TSD.
25

Screening Analysis: Technologies Removed

• The following technologies were removed because they do not 

affect calculated energy consumption per the DOE test procedure:

– Thermostatic expansion valves and electronic expansion valves

– Thermostatic cyclic controls

– Multi-speed compressors

• The following technologies are already common baseline SPVU 

designs and were not considered further:

– Increased fin density

– Improved fin design

– Improved tube design

– Hydrophilic film coating on fins
26

Screening Analysis: Technologies Removed (cont.)

• DOE also removed microchannel heat exchangers from further 

consideration in the engineering analysis. Although DOE is aware 

that SPVU manufacturers have been experimenting with this 

technology, DOE is not aware of any research or data that 

documents the effect that microchannel heat exchangers have on 

the energy efficiency of SPVUs.
27

Screening Analysis: Remaining Technologies

The following 6 design options were further considered in the 

Engineering Analysis:

Design Options considered in the Engineering Analysis for Improved Energy 

Efficiency of SPVUs

Increased frontal coil area Improved fan motor efficiency

Increased depth of coil Improved fan blades

Dual condenser heat exchangers Improved compressor efficiency
28

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
29

NOPR Rulemaking Stage

 

Framework

Document

Preliminary 

Analysis NOPR FinalRule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
30

Engineering Analysis: Sources of Information

DOE incorporated information from the following sources in the 

Engineering Analysis:

Product teardowns & manufacturing cost modeling

Manufacturer interviews

Product literature

AHRI product certification data

Product testing
31

Engineering Analysis: Efficiency Levels Analyzed

• For each equipment class, DOE selected efficiency levels for 

analysis which included:

- Both the current EPCA and ASHRAE 90.1-2013 baseline efficiency 

levels

- Efficiency levels with the highest number of models available on 

the market

- Efficiency levels only achievable via substantial technological 

changes

- The maximum technologically feasible (“max-tech”) efficiency 

level 
32

Engineering Analysis: SPVAC Efficiency Levels Analyzed 

Equipment Class

Efficiency Levels (EER)

EPCA 

Baseline

ASHRAE 

Baseline

EL0

<65,000: EL1 <65,000: EL2 <65,000: EL3 <65,000: EL4

SPVAC <65,000 

Btu/h 9.0 10.0 10.5 11.0 11.75 12.3

SPVAC ≥65,000 

Btu/h and <135,000 

Btu/h

8.9 10.0 - - - -

SPVAC ≥135,000 

Btu/h and <240,000 

Btu/h

8.6 10.0 - - - -
33

Engineering Analysis: SPVHP Efficiency Levels Analyzed

Equipment Class

Efficiency Levels (EER/COP)

EPCA 

Baseline

ASHRAE 

Baseline

EL0

<65,000: EL1 <65,000: EL2 <65,000: EL3 <65,000: EL4

SPVHP <65,000 

Btu/h 9.0/3.0 10.0/3.0 10.5/3.2 11.0/3.3 11.75/3.9 12.3/3.9

SPVHP ≥65,000 

Btu/h and <135,000 

Btu/h

8.9/3.0 10.0/3.0 - - - -

SPVHP ≥135,000 

Btu/h and <240,000 

Btu/h

8.6/2.9 10.0/3.0 - - - -
34

Engineering Analysis: Correlating EER and COP

• Appropriate COP levels were selected to correspond with 

each EER level analyzed.

• Manufacturer feedback indicated that most SPVHP are 

designed to achieve a certain EER goal, with COP as a 

secondary concern. Thus, when selecting efficiency levels for 

analysis of SPVHP, DOE focused on selecting and analyzing EER 

levels and chose appropriate COP levels at each EER level 

based on equipment currently on the market. 

• DOE believes that the median COP value at each EER level is 

the most representative value of equipment performance at 

that EER efficiency level. The mean COP value at each EER 

could be skewed by a small number of outliers, so it was not 

selected.
35

Engineering Analysis: Correlating EER and COP (cont.)

• The distribution of COP values DOE found among SPVHP at 

each EER level is shown below. 

3

3

3

3

3.85

3.07

3.1

3.2

3.25

3.9

3.13

3.15

3.25

3.3

3.2

3.95

3.2

3.3

3.31

3.41

3.5

3.4

3.5

3.49

3.63.7

0

10

20

30

40

50

60

70

9 10 10.5 11 11.75

Number of Units

Energy Efficiency Ratio (EER) Bins

Distribution of COP ratings within each EER Bin
36

Engineering Analysis: Teardown Analysis

Manufacturing Production Costs (MPCs) and Manufacturer Selling Prices 

(MSPs) were developed by DOE at each efficiency level analyzed as part of 

the efficiency-level approach.

Raw 

Materials

Finished 

Materials

Purchased 

Parts

Physical 

Teardown

Selection of 

Units

Fabrication 

Processes

Bill of 

Materials

Assembly 

Processes

Manufacturing 

Cost

• A physical teardown analysis was 

conducted using representative 

products.

• Bills of material (BOMs) were 

generated during the product 

teardown analysis and entered into the 

cost model.

• The cost model generated MPCs for 

each unit torn down, which include 

material, labor, depreciation, and 

overhead costs.

• Manufacturer interviews were 

conducted to further refine the 

analytical inputs and the results 

generated by the cost model.
37

Engineering Analysis: Cost-Efficiency Curves 

Using the results of the teardown analysis, MPCs representative of the 

industry as a whole are calculated for the efficiency levels analyzed. 

These MPCs are depicted using cost-efficiency curves. The costefficiency curves are developed in 4 steps:

• Develop an MPC representative of a standard baseline unit.

• Identify the design options used to achieve each specific efficiency 

level above baseline (depicted on the following slide).

• Calculate the incremental costs of achieving each efficiency level 

above baseline using teardown data and component cost data 

gathered from manufacturer interviews and other sources.

• Generate cost-efficiency curve, which depicts the manufacturer 

production cost at each efficiency level.

Develop 

Baseline

Calculate

Costs

Develop Efficiency 

Pathway

Generate CostEfficiency Curves
38

Engineering Analysis: Design Options and Efficiency Levels

Efficiency

Levels

Design Options

BLDC 

Indoor Fan 

motor

Increased 

HX Face 

Area

Additional 

HX tube 

row

Higher 

Efficiency 

Compressor

BLDC 

Outdoor 

Fan 

motor

HighEfficiency 

Outdoor 

Fan Blade

Dual 

Condenser 

Heat 

Exchangers

EPCA

Baseline

9.0 EER

ASHRAE 

Baseline

10.0 EER

X X

.3 EER .7 EER

EL1 

10.5 EER

X

.5 EER

EL2 

11.0 EER

X

.5 EER

EL3 

11.75 EER

X X

.42 EER .33 EER

EL4 

12.3 EER

X X X

.3 EER see note 

below*

.25 EER

*Due to a lack of definitive research or data available on the efficiency gains 

provided by higher-efficiency fan blades, DOE is not able to attribute a specific 

efficiency improvement to the use of this technology option.
39

Engineering Analysis: SPVAC Final MPCs

$1,149.47 (9 EER)

$1,424.10 (10 EER)

$1,492.81 (10.5 EER)

$1,561.53 (11 EER)

$1,766.36 (11.75 EER)

$2,150.71 (12.3 EER)

$1,503.07 (8.9 EER)

$1,884.72 (10 EER)

 $900.00

 $1,100.00

 $1,300.00

 $1,500.00

 $1,700.00

 $1,900.00

 $2,100.00

 $2,300.00

8.5 9 9.5 10 10.5 11 11.5 12 12.5

MPC (2013$)

EER

<65,000 Btu/h SPVAC MPCs

≥65,000 and <135,000 Btu/h SPVAC MPCs
40

Engineering Analysis: SPVHP Final MPCs

$1,320.55 (9 EER)

$1,636.06 (10 EER)

$1,715.00 (10.5 EER)

$1,793.94 (11 EER)

$2,029.26 (11.75 EER)

$2,470.82 (12.3 EER)

$1,726.78 (8.9 EER)

$2,165.24 (10 EER)

 $900.00

 $1,100.00

 $1,300.00

 $1,500.00

 $1,700.00

 $1,900.00

 $2,100.00

 $2,300.00

 $2,500.00

 $2,700.00

8.5 9 9.5 10 10.5 11 11.5 12 12.5

MPC (2013$)

EER

<65,000 Btu/h SPVHP MPCs

≥65,000 and <135,000 Btu/h SPVHP MPCs
41

Engineering Analysis: Deriving MSPs from MPCs

• The MSP is the price at which the manufacturer can recover 

all production and nonproduction costs and earn a profit.

• Shipping costs are typically considered a non-production 

cost, and are included in the MSP. The shipping costs are 

presented in greater detail in Chapter 5 of the NOPR TSD.

• The MSP is calculated by multiplying the MPC by a 

manufacturer markup, and then adding shipping costs.
42

Engineering Analysis: Production and Nonproduction Costs

Structure/Classification of Manufacturing Costs

Full Manufacturer Selling 

Price (MSP)

Non-Production Cost **

Selling General & 

Admin. R & D Interest

Full Manufacturing Production Cost (MPC)*

Direct Labor Direct 

Material Overhead

Indirect labor

Indirect material

Maintenance

Depreciation

Taxes

Insurance related 

to assets

Market research

Advertising

POS promotion

Sales person 

compensation & 

travel

Logistics

- Warehousing

- Delivery

- Record keeping

Costs of 

service & 

staff units

General 

corporate 

costs –

comp., etc.

Costs 

associated with 

efforts to find 

new or 

improved 

products or 

production 

processes

Costs of 

borrowing 

funds

* Tax Reform Act of 1986 essentially requires companies to measure cost of goods sold as the full production cost of the goods sold.

** In a company’s income statement, many of these costs are reported as a lump sum, under selling, general, and administration (SG&A). 
43

Engineering Analysis: Manufacturer Markup

• The manufacturer markup is normally developed by looking 

at Securities and Exchange Commission (SEC) 10-K reports 

for public companies, which provide an indicator of industry 

profitability. For SPVUs, however, most of the industry is 

privately held and, therefore, does not have financial 

information readily available.

• The Packaged Terminal Air Conditioner and Heat Pump 

(PTAC/PTHP) industry is a comparable industry to the SPVU 

industry. As such, the markup published in the final rule for 

PTAC/PTHP on October 7, 2008, was used as a starting point 

for developing the markup for SPVU. 73 FR 58772.

• After consultation with industry, DOE estimated the average 

manufacturer markup for the SPVU industry to be 1.28.
44

Engineering Analysis: SPVAC Final MSPs

$1,517.36 (9 EER)

$1,890.59 (10 EER) 

$1,978.54 (10.5 EER)

$2,066.50 (11 EER)

$2,349.71 (11.75 EER)

$2,876.87 (12.3 EER)

$1,994.38 (8.9 EER)

$2,482.89 (10 EER)

 $900.00

 $1,400.00

 $1,900.00

 $2,400.00

 $2,900.00

 $3,400.00

8.5 9 9.5 10 10.5 11 11.5 12 12.5

MSP (2013$)

EER

<65,000 Btu/h SPVAC MSPs

≥65,000 and <135,000 Btu/h SPVAC MSPs
45

Engineering Analysis: SPVHP Final MSPs

$1,736.35 (9 EER)

$2,161.90 (10 EER)

$2,262.95 (10.5 EER)

$2,363.99 (11 EER)

$2,686.23 (11.75 EER)

$3,286.61 (12.3 EER)

$2,280.73 (8.9 EER)

$2,841.95 (10 EER)

 $900.00

 $1,400.00

 $1,900.00

 $2,400.00

 $2,900.00

 $3,400.00

 $3,900.00

8.5 9 9.5 10 10.5 11 11.5 12 12.5

MSP (2013$)

EER

<65,000 Btu/h SPVHP MSPs

≥65,000 and <135,000 Btu/h SPVHP MSPs
46

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
47

NOPR Rulemaking Stage

 

Framework

Document

Preliminary 

Analysis NOPR FinalRule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
48

Energy Use Analysis

• Calculates annual per-unit energy consumption (UEC) for all 

combinations of building types, equipment classes, and 

efficiency levels.

Building 

Characteristics

Internal Loads & 

Schedules

SPVU Equipment 

Details

Weather Data

Energy Plus 

Simulation 

Architecture

Location 

Weighting 

Factors

Annual UEC by 

Equipment 

Class and 

Efficiency level
49

Energy Use Analysis

Efficiency Level

Equipment Class

SPVAC <65,000 Btu/h

(kWh/yr)

SPVHP<65,000 Btu/h

(kWh/yr)

EPCA Baseline 6,880 20,921

ASHRAE Baseline 6,175 20,383

Level 1 5,923 19,921

Level 2 5,694 19,629

Level 3 5,387 18,775

Level 4 5,185 18,633
50

Markups Analysis
51

Markups Analysis

Baseline Markup Incremental Markup

New Construction

Weighted Average Air-Conditioning Equipment Wholesale Distributor Markup 1.177 1.051

Building Manufacturer Markup, Weighted Average for Wood and Metal 

Prefabricated Buildings 1.467 1.369

Building Manufacturer Markup for Concrete Prefabricated Buildings 1.756 1.591

Building Wholesale Distributor Markup, Weighted Average for Wood and 

Metal Buildings 1.283 1.283

Building Wholesale Distributor Markup, Concrete Buildings 1.539 1.539

General Contractor Markup 1.311 1.197

Sales Tax (National Population-Weighted Average) 1.072 1.072

Overall Markup (Weighted U.S. Average) 2.308 1.941

Replacement

Weighted Average Air-Conditioning Equipment Wholesale Distributor Markup 1.177 1.051

Mechanical Contractor Markup 1.474 1.184

Building Wholesale Distributor Markup, Weighted Average for Wood and 

Metal Buildings 1.283 1.283

Building Wholesale Distributor Markup, Concrete Buildings 1.539 1.539

Sales Tax (National Population-Weighted Average) 1.072 1.072

Overall Markup (Weighted U.S. Average) 1.609 1.337

Baseline Markups - Convert MSPs to final customer purchase prices for 

baseline efficiency equipment.

Incremental Markups - Applied to the incremental cost difference 

between baseline and higher-efficiency equipment.
52

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
53

NOPR Rulemaking Stage

 

Framework

Document

Preliminary 

Analysis NOPR FinalRule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
54

Life-Cycle Cost and Payback Period Analysis

Purpose

• Estimate the total customer cost (life-cycle cost, or LCC) over the lifetime of 

the equipment for all equipment classes and efficiency levels. 

• Determine the payback period (PBP, measured in years) for customers to 

recover the typically higher purchase price of more energy efficient 

equipment through lower operating costs.

Method

• Develop a spreadsheet model to calculate customer costs and savings.

• Use Monte Carlo simulations to capture input variability. 
55

Life-Cycle Cost and Payback Period Analysis

Installed Cost Inputs

• MSPs from Engineering Analysis

• Overall Markups

• Baseline and Incremental Markups

• Sales Tax

• Installation (Labor and Materials)

Operating Cost Inputs

• Equipment Lifetime and Operating Hours

• Current and Projected Energy Prices

• Repair and Maintenance Costs

• Discount Rates
56

Life-Cycle Cost and Payback Period Analysis

LCC Results – SPVAC <65,000 Btu/h

TSL EER Installed Cost

(2013$)

Average LCC Savings

(2013$)*

Median PBP

(years)

Equipment 

Lifetime (years)

ASHRAE

Baseline 10.0 4,795 --- --- 15

1 10.5 4,939 116 7.9 15

2 11.0 5,083 179 8.4 15

3 11.75 5,546 (24) 14.4 15

4 12.3 6,407 (825) 27.3 15

* Values in parentheses are negative values
57

Life-Cycle Cost and Payback Period Analysis

LCC Results – SPVHP <65,000 Btu/h

TSL EER/COP Installed Cost

(2013$)

Average LCC Savings

(2013$)*

Median PBP

(years)

Equipment 

Lifetime (years)

ASHRAE

Baseline 10.0/3.0 5,363 --- --- 15

1 10.5/3.2 5,529 358 4.1 15

2 11.0/3.3 5,695 424 4.8 15

3 11.75/3.9 6,224 819 6.2 15

4 12.3/3.9 7,210 (177) 13.6 15

* Values in parentheses are negative values
58

Life-Cycle Cost Subgroup Analysis

Purpose

• Determine the effects of a standard on identifiable subgroups within the 

general population.

Method

• Use the LCC model to examine specific customer subgroup characteristics, 

and determine how those results may differ from the general population.

Identified Subgroups

• Temporary Office Customers

• Public Education Customers

• Businesses with Higher Capital Costs
59

Life-Cycle Cost Subgroup Analysis

SPVAC <65,000 Btu/h

TSL

LCC Savings

(2013$)*

Median Payback Period

(years)

Equipment 

Lifetime (years)

Temp. Office Education High Rate All Temp. Office Education High Rate All All Groups

1 (27) 98 101 116 13.8 9.6 7.9 7.9 15

2 (60) 148 153 179 14.7 10.1 8.3 8.4 15

3 (429) (92) (66) (24) 26.7 17.5 14.3 14.4 15

4 (1,323) (944) (867) (825) 55.0 33.5 28.1 27.3 15

TSL

LCC Savings

(2013$)*

Median Payback Period

(years)

Equipment 

Lifetime (years)

Temp. Office Education High Rate All Temp. Office Education High Rate All All Groups

1 259 440 342 358 4.2 3.8 4.1 4.1 15

2 274 549 403 424 5.4 4.6 4.8 4.8 15

3 527 1,056 769 819 6.3 6.1 6.2 6.2 15

4 (488) 83 (222) (177) 14.5 12.7 13.6 13.6 15

* Values in parentheses are negative values

* Values in parentheses are negative values

SPVHP <65,000 Btu/h
60

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
61

Shipments Analysis

Purpose

• To estimate SPVU shipments over the 30-year analysis period (2015-2044 

for the ASHRAE level, and 2019-2048 for higher levels).

• Shipments are inputs to National Impact Analysis and Manufacturer 

Impact Analysis.

Method

• Develop an equipment stock accounting model which tracks shipments for 

replacements and new construction.

• To estimate shipments of replacement units, the model utilizes shipments 

data from previous years and assumptions about the lifetime of each 

product.

• To estimate shipments to new construction, DOE uses input variables as 

drivers, such as construction forecasts.
62

Shipments Inputs and Methodology

• Initial Shipments

– DOE started with shipment estimates for units <65,000 Btu/h from 2005 AHRI data

– DOE estimated shipments of units ≥65,000 Btu/h and <135,000 Btu/h make up 3 

percent of the market based on manufacturer interviews.

• To project shipments to new construction (starting in 2006), DOE relied on 

sector-based estimates:

• Education: 35% of market

– DOE estimated a saturation rate for 2005 and applied this to AEO 2013 projections of 

new construction floor space to project shipments to new construction.

• Office: 30% of market

– DOE used the saturation/AEO approach in the NODA, but based on stakeholder 

comments, DOE determined that the increasing trend in AEO for small offices does 

not adequately represent the modular building industry. Therefore, DOE held 

shipments to offices constant at 2005 levels.

• Telecom: 35% of market

– DOE developed an index based on County Business Pattern data for establishments 

related to Power and Communication Line and Related Structures Construction, and 

projected this trend forward.
63

Projected Shipments
64

Projected Shipments by Equipment Class
65

Request for Comment

Issue Box: DOE seeks comment on whether amended standards 

would affect shipments, and if so, DOE also requests data with 

which to estimate the elasticity of shipments for SPVUs as a 

function of first costs, repair costs, or operating costs.
66

National Impact Analysis

Purpose

– Determine the projected national energy savings and customer national 

net present value.

Method

– Develop annual series of national energy and economic impacts.

– Use the shipments model to estimate the total stock of SPVUs in service 

each year. 

– Aggregate the costs and energy use per unit in any given year.

– Report estimates for economic impact as change in consumer National Net 

Present Value (NPV) (in constant year dollars).

• Only reported for levels above ASHRAE

– Account for the time-value of money through defined discount rates.
67

Shipments 

Model

National 

Energy 

Savings

National

Economic

Impacts

LCC 

Analysis 

Results and 

Other Inputs

National 

Energy Savings 

(Quads)

National 

Net Present Value 

(NPV)

(2013 US $, billion)

National Impact Analysis: Process

• National energy savings calculated for equipment shipped over the period 

from 2015 – 2044 or 2019 - 2048 (30 years of shipments).

– Difference between standards case cumulative energy use and base case cumulative 

energy use.

• NPV calculated for equipment shipped over the period from 2019 - 2048 (30 

years of shipments).

– Compare standards case to base case

• Cumulative operating cost savings: energy, maintenance, and repair cost

• Cumulative installed cost increase: equipment and installation cost 

– Apply discount rate
68

National Impact Analysis: Inputs

Input Description

Total Installed Cost Weighted-average per unit values as a function of efficiency level taken from the LCC analysis.

Equipment costs vary with efficiency level while installation costs do not.

Repair and Maintenance 

Costs

Maintenance costs taken from the LCC analysis; do not vary as a function of efficiency level.

Repair costs taken from the LCC analysis; estimated to vary with efficiency.

Annual Energy Use Annual weighted-average per unit values as a function of efficiency level taken from LCC 

analysis.

Energy Prices Projected energy prices from EIA AEO 2013 forecasts (to 2040) and extrapolation thereafter.

Base-Case Efficiencies Shipments-weighted efficiencies determined for the compliance year. Based on base-case 

efficiency distribution from LCC analysis. Projected growth of 1 EER every 35 years.

Standards-Case 

Projected Efficiencies

Roll-up scenario for the compliance year, followed by same rate of growth in efficiency as used 

in the base case.

Full-Fuel-Cycle Multiplier to convert site energy to full-fuel-cycle energy.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A-4.

Present Year Future expenses are discounted to the year 2014.
69

National Impact Analysis: Trial Standard Levels

Equipment Class Efficiency Level

SPVAC <65,000 Btu/h Cooling Capacity 1 2 3

4 

(Max-Tech)

SPVHP <65,000 Btu/h Cooling Capacity 1 2 3

4 

(Max-Tech)

SPVAC ≥65,000 Btu/h and <135,000 Btu/h Cooling 

Capacity

ASHRAE Baseline

SPVHP ≥65,000 Btu/h and <135,000 Btu/h Cooling 

Capacity

SPVAC ≥135,000 Btu/h and <240,000 Btu/h Cooling 

Capacity

SPVHP ≥135,000 Btu/h and <240,000 Btu/h Cooling 

Capacity
70

National Impact Analysis: National Energy Savings

Equipment Class quads

SPVAC <65,000 Btu/h Cooling Capacity 0.15 0.06 0.13 0.22 0.24

SPVHP <65,000 Btu/h Cooling Capacity 0.07 0.04 0.10 0.15 0.16

SPVAC ≥65,000 Btu/h and <135,000 Btu/h Cooling 

Capacity

0.01 - - - -

TOTAL 0.22 0.09 0.23 0.37 0.39

Cumulative Full-Fuel-Cycle National Energy Savings

Note: Energy savings at the ASHRAE level are calculated with respect to the current EPCA 

baseline level. Energy savings above the ASHRAE level are calculated with respect to the ASHRAE 

level.
71

National Impact Analysis: Consumer NPV

Equipment Class Billion 2013$

SPVAC <65,000 Btu/h Cooling Capacity 0.13 0.13 (0.64) (1.05)

SPVHP <65,000 Btu/h Cooling Capacity 0.13 0.32 0.14 (0.06)

TOTAL 0.26 0.44 (0.50) (1.10)

National Net Present Value at 3% real discount rate 

National Net Present Value at 7% real discount rate 

Equipment Class Billion 2013$

SPVAC <65,000 Btu/h Cooling Capacity 0.04 0.01 (0.38) (0.66)

SPVHP <65,000 Btu/h Cooling Capacity 0.04 0.10 0.01 (0.12)

TOTAL 0.09 0.11 (0.37) (0.78)
72

Request for Comment

Issue Box: DOE seeks comment on whether a rebound effect 

should be included in the determination of annual energy 

savings. If a rebound effect should be included, DOE seeks data 

to assist in calculation of the rebound effect.
73

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
74

Purpose: 

• Assess the impacts of amended energy conservation standards on 

manufacturers.

• Identify and estimate impacts on manufacturer subgroups that may be more 

severely affected than the industry as a whole.

• Examine the direct employment, manufacturing capacity, and cumulative 

regulatory impacts on the industry.

Methodology:

• Analyze industry cash flow and industry net present value (INPV) through use 

of the Government Regulatory Impact Model (GRIM); and

• Interview manufacturers to refine inputs to the GRIM, develop subgroup 

analyses, and address qualitative issues

Manufacturer Impact Analysis
75

• Phase 1

– DOE creates an industry profile to characterize the market and identify 

important issues that require further investigation.

• Phase 2

– DOE prepares an industry cash-flow model and an interview questionnaire to 

guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards both 

quantitatively (using the GRIM) and qualitatively (impacts on employment, 

competition, manufacturing capacity, and regulatory burden).

– DOE also evaluates subgroups of manufacturers that may be 

disproportionately impacted by standards or that may not be accurately 

represented by the average cost assumptions used to develop the industry 

cash-flow analysis.

Manufacturer Impact Analysis
76

Industry Cash-Flow Model

• Upstream Inputs

– Market and Technology Assessment (MTA) Industry Profile 

– Engineering MPCs

– Shipments

• MIA Inputs

– Markup Scenarios

– Conversion Costs

Manufacturer Impact Analysis
77

• Size constraints

– Footprint

– Wall space

• Compliance tolerances

– CC&E tolerances would be difficult for manufacturers to meet

• Constrained innovation and customization

– Higher standards push manufacturers towards similar designs.

– Standards draw time, resources, and focus away from innovation, 

customization, and customer responsiveness.

Key Issues
78

Manufacturer Markup Scenarios

– Preservation of Gross Margin Percentage

– Preservation of Operating Profit

Manufacturer Impact Analysis

Product Classes Pres. Of Gross Margin 

Scenario

Pres. Of Operating 

Profit Scenario 

(TSL 2)

SPVAC <65,000 Btu/h 1.28 1.27

SPVHP <65,000 Btu/h 1.28 1.27

SPVAC ≥65,000 Btu/h and <135,000 Btu/h 1.28 1.28

SPVHP ≥65,000 Btu/h and <135,000 Btu/h 1.28 1.28
79

Estimated Industry Conversion Costs total $7.2M over 4 years at TSL 2.

Manufacturer Impact Analysis

Product Conversion Cost 

($)

Capital Conversion Cost 

($)

Industry Total 

($)

TSL 1 4.1 2.4 6.5

TSL 2 4.8 2.4 7.2

TSL 3 13.2 2.9 16.1

TSL 4 22.8 11.0 33.9
80

Manufacturer Impact Analysis

Base Case TSL 1 TSL 2 TSL 3 TSL 4

INPV 

($M) 36.5

32.4 

to 

34.2

33.2 

to 

38.0

27.5 

to 

49.2

3.0

to 

47.4

Change in INPV

(%) - 

(11.3)

to 

(6.3)

(9.0)

to 

4.1

(24.7) 

to 

34.9 

(91.7)

to 

29.9 

Conversion Costs

($M) - 6.5 7.2 16.1 33.9

INPV Results

Summary of TSL 2

• Expected INPV change in the range of -9.0% to 4.1%

• Expected conversion costs total $7.2M for the industry
81

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards
82

Emissions Analysis

Purpose

• To estimate the emissions reductions resulting from amended energy 

conservation standards. 

– Includes full-fuel-cycle emissions; both power plant emissions and “upstream” 

emissions.

– Includes fugitive methane emissions.

Method

• National Impact Analysis provides an annual time-series of energy savings over 

the analysis period.

• Energy Information Administration’s National Energy Modeling System (NEMS) 

is modified to represent the impacts of amended standards (modified code is 

known as NEMS-BT).

Results

Emissions Reductions TSL 1 TSL 2 TSL 3 TSL 4

CO2 (million metric tons) 8.3 20 33 35

SO2 (thousand tons) 22 53 86 91

NOX (thousand tons) 7.4 18 30 31

Hg (tons) 0.03 0.06 0.11 0.11

N2O (thousand tons) 0.11 0.28 0.45 0.47

CH4 (thousand tons) 24 59 97 103
83

• DOE used the most current Social Cost of Carbon (SCC) values developed by 

interagency process.

– SCC is intended to be a monetary measure of the incremental damage resulting from 

greenhouse gas (GHG) emissions, including, but not limited to, agricultural productivity 

loss, human health effects, property damage from rising sea levels, and changes in the 

ecosystem.

• The most recent (2013) U.S. government interagency estimates of the SCC 

for emissions in 2015, per metric ton avoided (in 2013$): 

– $12.0 (average value from distribution with a 5% discount rate)

– $40.5 (average value from distribution with a 3% discount rate)

– $62.4 (average value from distribution with a 2.5% discount rate)

– $119 (95th-percentile value from distribution with a 3% discount rate) 

• The SCC in constant dollars increases over time.

• DOE also monetizes the NOx emissions reductions resulting from amended 

standards. 

– Estimates of monetary value range from $476 to $4,893 per short ton. 

– DOE calculated monetary benefits using a medium value of $2,684 per short ton.

Emissions Monetization
84

Emissions Monetization: Results

Full-Fuel-Cycle Emissions Reduction Benefits (million 2013$)

TSL 1 TSL 2 TSL 3 TSL 4

CO2

52 to 773 124 to 1875 209 to 3112 224 to 3324

NOx 3 % discount rate 8.4 21 34 36

NOx 7 % discount rate 3.0 7.3 12 13
85

Utility Impact Analysis

Purpose

• To estimate the changes in electric installed capacity and generation that 

result from amended energy conservation standards (as compared to the 

base case).

Method 

• National Impact Analysis provides an annual time-series of energy savings 

over the analysis period.

• NEMS-BT is used to represent the impacts of amended standards.

Output

• Reductions in total electricity generation.

• Reductions in primary fuel (e.g., coal, natural gas) consumption.

• Changes to the mix of electricity generation by fuel type.

• Changes to total installed capacity.
86

Employment Impact Analysis

Purpose

• To estimate the national net impact on jobs as a consequence of 

amended energy conservation standards, including indirect employment 

impacts.

Method 

• Uses the ImSET (Impact of Sector Energy Technologies) model for the 

evaluation of indirect employment impacts; direct employment impacts 

to the commercial air-conditioning industry are developed in the 

Manufacturer Impact Analysis.

• The changes in national equipment and energy expenditures are taken 

from the National Impact Analysis and entered as inputs into ImSET.

Results

• Net labor market impacts are negligible over time due to the small 

magnitude of the short-term effects.
87

Regulatory Impact Analysis

Purpose

• To investigate the national impacts of non-regulatory alternatives to 

mandatory amended energy conservation standards.

Method

• DOE modified the NIA spreadsheet to analyze the following nonregulatory alternatives and their impact on purchase price and energy 

use.

Output

• National Energy Savings and Net Present Value for the non-regulatory 

alternatives.

• No new regulatory action • Manufacturer tax credits

• Customer rebates • Voluntary efficiency targets

• Customer tax credits • Bulk government procurement
88

Public Meeting Agenda

1 Overview

2 Market and Technology Assessment; Screening Analysis

3 Engineering Analysis

4 Energy Use Analysis; Markups Analysis

5 Life-Cycle Cost and Payback Period Analysis

6 Shipments; National Impact Analysis

7 Manufacturer Impact Analysis

8 NOPR Analyses

9 Proposed Standards Proposed Standards
89

Equipment Type

Efficiency Levels (EER/COP)

ASHRAE 

Baseline

EL0

TSL1 TSL2 TSL3 TSL4

Max Tech

<65,000: EL1

Other:EL0

<65,000: EL2

Other:EL0

<65,000: EL3

Other:EL0

<65,000: EL4

Other:EL0

SPVAC <65,000 Btu/h 10.0 10.5 11.0 11.75 12.3

SPVAC ≥65,000 Btu/h 

and <135,000 Btu/h 10.0 10.0 10.0 10.0 10.0

SPVAC ≥135,000 Btu/h 

and <240,000 Btu/h 10.0 10.0 10.0 10.0 10.0

SPVHP <65,000 Btu/h 10.0/3.0 10.5/3.2 11.0/3.3 11.75/3.9 12.3/3.9

SPVHP ≥65,000 Btu/h 

and <135,000 Btu/h 10.0/3.0 10.0/3.0 10.0/3.0 10.0/3.0 10.0/3.0

SPVHP ≥135,000 Btu/h 

and <240,000 Btu/h 10.0/3.0 10.0/3.0 10.0/3.0 10.0/3.0 10.0/3.0

The Proposed Standard
90

Rationale for Adopting the Proposed Standard

EPCA directs DOE to consider seven factors when setting energy 

conservation standards. (42 U.S.C. 6313(a)(6)(B))

TSL Benefits Burdens

2

• Energy savings: 0.23 quads

• Environmental savings (CO2Savings: 20 

million metric tons)

• NPV (2013$) at a 7% discount rate: 

$0.11 billion

• For the equipment classes that have 

shipments, the percentage of 

consumers experiencing net savings is 

73%

• Net decrease in INPV by as much as 9.0% ($3.3 

million) for the industry
91

Closing Remarks
92

How to Submit Written Comments

• In all correspondence, please refer to the SPVU rulemaking by:

– NOPR for Energy Conservation Standards for Single Package Vertical Air 

Conditioners and Single Package Vertical Heat Pumps,

– Docket Number EERE-2012-BT-STD-0041, and

– Regulatory Identification Number (RIN) 1904-AC85.

• Email: SPVU2012STD0041@ee.doe.gov

• Comment period closes: March 2, 2015, 11:59 PM EST

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Mailstop EE-5B

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Office, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: (202) 586-2945