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ElECTRONICS SAMSUNG ELECTRONICS AMERICA,INC. 

October 17,2011 

Dr. Henry Kelly 

QA Lab America 

18600 Broadwick Street 

Rancho Dominguez, CA 90220 

TEL 310 900 5230 FAX 310 537 5500 

Energy Efficiency and Renewable Energy 

Department of Energy 

1000 Independence Avenue, SW. 

Washington, DC 20585 

Re: Samsung Petition for Waiver and Application for Interim Waiver, DVM Air 

Conditioner and Heat Pumps 

Dear Assistant Secretary Kelly: 

Sam sung Electronics America, on behalf of Samsung Electronics Co. (Samsung), respectfully 

submits this petition for interim waiver and application for waiver to allow Samsung to fairly 

evaluate its new line of DVM air conditioners and heat pumps. 

Under 10 CFR 431.40 I (a)( I), any interested person to submit a petition to waive for a particular 

basic model any requirement for commercial equipments, upon the grounds that either the basic 

model contains one or more design characteristics which prevent testing of the basic model 

according to the prescribed test procedures, or the prescribed test procedures may evaluate the 

basic model in a manner so unrepresentative of its true energy consumption characteristics as to 

provide materially inaccurate comparative data. 

Sam sung originally submitted a petition for waiver and application for interim waiver for its 

DVM system on October 7, 2003, seeking relief from 10 CFR 430 based on the fact that the 

multitude of combinations of outdoor and indoor units makes it highly impractical for Samsung 

to test every single combination. For this reason, DOE granted Samsung the Interim Waiver on 

February 8, 2005. 

On December 8, 2006, the Department of Energy (DOE) published a final rule adopting ARI 

Standard 210/240-2003 for commercial package air conditioning and heating equipment with 

capacities <65,000 Btu/h and 340/360-2004 for commercial package air conditioner and heating 

equipment with capacities 2:65,000 Btu/h and <240,000 Btu/h. However, under these new test 

procedures, Samsung would still be required to test every single combination of its commercial 

DVM outdoor and indoor units. Based on DOE's recognition that (I) there is a problem of being 

physically unable to test most of the complete systems in a laboratory; (2) there are difficulties 

associated with the regulatory requirement to test the highest-sales-volume combination; and (3) 

there is the lack of a method for predicting the performance of untested combinations, DOE 
granted Samsung the waiver from having to test every single combination of its DVM system in 

72 FR 71387, on December 17,2007. 

Since then, Samsung has further improved its DVM system, establishing new models not 

covered in the waiver published in 72 FR 71387. Even though model numbers changed, the 

difficulty with testing the multitude of combination of Samsung's DVM models remains; 

therefore, Samsung is seeking DOE's granting of waiver and interim waiver for the following 

Samsung DVM models: 

Type Model Description Cooling/Heating 

rBtu/h] 

RVXVHT075FE Condensing unit heat pump 72,000/8 t ,000 

RVXVHTIOOFE Condensing unit heat pump 96,00011 08 ,000 

Outdoor RVXVHT125FE Condensing unit heat pump 120,000/ 135,000 

Unit RD075VRXF A Condensing unit heat pump 72,000/81 ,000 

RD 100VRXF A Condensing unit heat pump 96 ,00011 08 ,000 

RDI25VRXFA Condensing unit heat pump 120,0001135,000 

A VXCMH032CE 4-Way Ceiling Cassette Heat pump 9,500/1 0,500 

A VXCMH040CE 4-Way Ceiling Cassette Heat pump 12,000/ 13 ,500 

A VXCMH052CE 4-Way Ceiling Cassette Heat pump 18,000/20,000 

A VXCMH060CE 4-Way Ceiling Cassette Heat pump 20,000/23 ,000 

A VXC4H052CE 4-Way Ceiling Cassette Heat pump 18,000/20,000 

A VXC4H072CE 4-Way Ceiling Cassette Heat pump 24,000/27,000 

A VXC4H 1 OOCE 4-Way Ceiling Cassette Heat pump 30,000/34,000 

AVXC4HIIOCE 4-Way Ceiling Cassette Heat pump 36,000/40,000 

AVXC4HI45CE 4-Way Ceiling Cassette Heat pump 48 ,000/54,000 

A VXDSH020CE Built-in Slim Duct(Low pressure) 6,000/7,000 

Indoor A VXDSH032CE Built-in Slim Duct(Low pressure) 9,50011 0,500 Unit 

A VXDSH040CE Built-in Slim Duct(Low pressure) 12,000/13,500 

A VXDSH052CE Built-in Slim Duct(Low pressure) 18 ,000/20,000 

A VXDSH072CE Built-in Slim Duct(Low pressure) 24,000/27,000 

A VXDSH 1 OOCE Built-in Slim Duct(Low pressure) 30,000/34,000 

AVXDSHIIOCE Built-in Slim Duct(Low pressure) 36,000/40,000 

A VXDSH 145CE Built-in Slim Duct(Low pressure) 48,000/54 ,000 

A VXDUH 100CE Built-in Duct(Mid pressure) 30,000/34,000 

A VXDUH 11 OCE Built-in Duct(Mid pressure) 36,000/40,000 

A VXDUH 145CE Built-in Duct(Mid pressure) 48,000/54,000 

AVXWVH020CE High Wall Mount Heat Pump 6,000/7,000 
A VXWVH032CE High Wall Mount Heat Pump 9,500/ 10,500 

A VXWVH040CE High Wall Mount Heat Pump 12,000/13,500 

A VXWVH052CE High Wall Mount Heat Pump 18,000/20,000 

A VXWVH060CE High Wall Mount Heat Pump 20,000/23 ,000 

A VXWNH020CE High Wall Mount Heat Pump 6,00017 ,000 

A VXWNH032CE High Wall Mount Heat Pump 9,500110,500 

A VXWNH040CE High Wall Mount Heat Pump 12,000/13,500 

AVXWNH052CE High Wall Mount Heat Pump 18,000/20,000 

A VXWNH060CE High Wall Mount Heat Pump 20,000/23 ,000 

A VXCSH023CE 1-Way Ceiling Cassette Heat pump 7,500/8,500 

A VXCSH032CE I-Way Ceiling Cassette Heat pump 9,500/1 0,500 

A VXCSH040CE I-Way Ceiling Cassette Heat pump 12,00011 3,500 

Each outdoor unit may be combined with up to ten different indoor units and each indoor unit 

may be independently turned on, off, standby, etc. depending on user-desired settings. With up to 

33 different indoor units for the consumer to choose from and combined, and as evident in the 

chart above, there are thousands of different combinations, creating an extremely burdensome 

task for Samsung or any testing laboratory to evaluate all possible combination. Being 

responsible to test every conceivable combination would place an unfair burden upon Samsung, 

while offering no added value for purpose of energy testing. 

Samsung's new DVM system is very similar to Samsung's old DVM system, which DOE had 

granted a waiver for in 72 FR 71387. Until a final test procedure addressing commercial central 

air conditioners and heat pumps, similar to Samsung's DVM systems, is prescribed, Samsung 

believes that the interim waiver as granted by the Department in 70 FR 9629 and waiver as 

granted by the Department in 72 FR 71387, be granted for Samsung's new DVM system in order 

for Samsung to feasibly evaluate its new line of DVM central air conditioners and heat pumps. 

Sincerely, 

1frl~1Yi~ 

Michael Moss 
Carrier Corporation 

7310 West Morris Street 

Indianapolis, IN 46231 

Attn: Dr. John Galbraith, VP for RCS Engineering 

Daikin AC (Americas), Inc. 

1645 Wallace Drive 

Suite 110 

Carrollton, TX 75006 

Attn: Akinori Atarashi, President 

Fujitsu General America, Inc. 

353 Route 46 West 

Fairfield, NJ 07004 

Attn: Roy Kuczera, Senior Vice President of HV AC Sales, and Arturo Thur De Koos, 

Engineering & Technical Support 

Mitsubishi Electric & Electronics USA, Inc. 

3400 Lawrenceville-Suwanee Road 

HV AC Advanced Products Division 

Suwanee, GA 30024-2403 

Attn: Paul Doppel 

SANYO North America Corp. 

1690 Roberts Blvd., NW 

Suite 110 

Kennesaw, GA 30144 

Attn: Garry Nettinger, Vice President, Applied Products Group 

Air-Conditioning, Heating, and Refrigeration Institute 

2111 Wilson Blvd. 

Suite 500 

Arlington, VA 22201 

Attn: Stephen R. Yurek, Esq., President 

LG Electronics USA, Inc. 

1750 K Street NW 

Washington, DC 20006 

Attn: John Taylor