### 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 Energy2 

# 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 Remarks3 

# 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 Majette4 

# 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 Standards9 

# 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 then

current 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 air

conditioning 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 431.9713 

# 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 more

stringent 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 analysis15 

# 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 Standards16 

# Energy Conservation Standards Rulemaking

Framework Document Preliminary

Analysis NOPR Final Rule

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 Analysis17 

# 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 0 021 

# 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 commercially

available 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 exchangers24 

# 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 c ontrols

– 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 fins26 

# 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 efficiency28 

# 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 Standards29 

# NOPR Rulemaking Stage

Framework Document Preliminary

Analysis NOPR Final Rule

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 Analysis30 

# 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 testing31 

# 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
level32 

# 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

3.95 3.2 3.2

3.3

3.4 3.31 3.41

3.5

3.5 3.49 3.6

3.7

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 Bin36 

# 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 cost

efficiency 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 Cost

Efficiency Curves38 

# 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 High

Efficiency
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 MPCs40 

# 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 MPCs41 

# 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 MSPs45 

# 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 MSPs46 

# 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 Standards47 

# NOPR Rulemaking Stage

Framework Document Preliminary

Analysis NOPR Final Rule

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 Analysis48 

# 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 level49 

# 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 18,63350 

# Markups Analysis51 

# 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

- C onvert 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 Standards53 

# NOPR Rulemaking Stage

Framework Document Preliminary

Analysis NOPR Final Rule

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 Analysis54 

# 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 Rates56 

# 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 values57 

# 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 values58 

# 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 Costs59 

# 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/h60 

# 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 Standards61 

# 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 Shipments64 

# Projected Shipments by Equipment Class65 

# 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 rate68 

# 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
Capacity70 

# 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 Standards74 

# 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 Analysis75 

# • 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 Analysis76 

# Industry Cash

- Flow Model

• Upstream Inputs

– Market and Technology Assessment (MTA) Industry Profile

– Engineering MPCs

– Shipments



# • MIA Inputs

– Markup Scenarios

– Conversion Costs 

# Manufacturer Impact Analysis77 

# • 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 Issues78 

# 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 1.2879 

## 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 33.980 

# 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 industry81 

# 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 Standards82 

# 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

CO 2 (million metric tons) 8.3 20 33 35

SO 2 (thousand tons) 22 53 86 91

NO X (thousand tons) 7.4 18 30 31 Hg (tons) 0.03 0.06 0.11 0.11

N 2 O (thousand tons) 0.11 0.28 0.45 0.47

CH 4 (thousand tons) 24 59 97 10383 

## • 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 NO

x 

## 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 Monetization84 

# Emissions Monetization: Results

Full

- Fuel

- Cycle Emissions Reduction Benefits (million 2013$)

TSL 1 TSL 2 TSL 3 TSL 4

CO 2 52 to 773 124 to 1875 209 to 3112 224 to 3324

NO

x 3 % discount rate 8.4 21 34 36

NO

x 7 % discount rate 3.0 7.3 12 1385 

# 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 non

regulatory 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 procurement88 

# 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 Standards89 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 Standard90 

# 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 (CO 2 Savings: 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 industry91 

# Closing Remarks92 

# 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