*S;E F- 1as eI. L I ^

EG (07-90) EE-RM/STD-98-440 |

United States Government Department of Energy

EE-/S ArD - -to memorandum

DATE:/ /

REPLY TO

ATTN OF: M,

SUBJECT:

Meeting with Representatives of the Trane Company

TO:

Docket No. EE-RM-94-003

On October 31, 2000, Dan Reicher, Assistant Secretary for Energy Efficiency and Renewable

Energy, met with representatives of the Trane Company, a manufacturer of central air

conditioners and heat pumps, to discuss the Department's rulemaking regarding energy efficiency

standards for central air conditioners and heat pumps. (Docket No. EE-RM-94-003).

Attending the meeting were the following:

DOE: Dan Reicher, Michael J. McCabe, Edward O. Pollock, Jr. and Eugene Margolis

Trane: Jim Wolf, Vice President Government Relations and Jim Crawford, Director, Government

Relations

The following items were discussed:

* Trane Company's press release in which they supported a 12 SEER standard for central

air conditioners and heat pumps as well as a requirement mandating thermal expansion

valves (TXV) on central air conditioners and heat pumps;

* Trane reviewed the unique design of their heat exchanger and how it limited the efficiency

improvements they were capable of making with their central air conditioners and heat

pumps;

· Also discussed an EER standard and why Trane believed it wasn't necessary;

* Trane volunteered that in their opinion, the analysis does not support a SEER 12 standard,

much less the DOE proposal;

· Trane discussed a number of specific areas of the analysis they felt were flawed, including

choice of a seven percent discount rate. They believe the discount rate is too low;

· Trane reviewed the markups found in Table V.3 of the DOE TSD and how they were not

representative of what is occurring in the marketplace. The DOE analysis, as shown in

Table V.3, indicates mark-ups decrease with increasing efficiency;

* Trane believe that the 13 SEER central air conditioner is state-of-art and is too high to

consider for a standard since it would result in a commodity market;

* Trane discussed how many in the industry are highly leveraged and the standards would

have significant negative impacts; and

* Trane discussed their support for TXV requirement, even though they find there is little

benefit in specifying TXV's since they believe they are becoming common place.

Q:\EE-41\Equipment, Materials, Tools\Appliance Stds\Residential\Central Air and Heat Pumps\Standard\trane 10_31.wpd

EE-RM-STD-98-440 COMMENT 128 •. DSlE F j,125.1!. 

. (8-89) 

EFG (07-90) 

United States Government 

EE-RM/STD-98-440 * 128 

Department of Energy 

memorandum 

SUBJECT: 

TO: 

1~,~«J Meeting with Representatives of the Trane Company 

Docket No. EE-RM-94-003 

On October 31, 2000, Dan Reicher, Assistant Secretary for Energy Efficiency and Renewable 

Energy, met with representatives of the Trane Company, a manufacturer of central air 

conditioners and heat pumps, to discuss the Department's rulemaking regarding energy efficiency 

standards for central air conditioners and heat pumps. (Docket No. EE-RM-94-003). 

Attending the meeting were the following: 

DOE: Dan Reicher, Michael 1. McCabe, Edward O. Pollock, Jr. and Eugene Margolis 

Trane: Jim Wolf, Vice President Government Relations and Jim Crawford, Director, Government 

Relations 

The following items were discussed: 

• Trane Company's press release in which they supported a 12 SEER standard for central 

air conditioners and heat pumps as well as a require~ent mandating thermal expansion 

valves (TXV) on central air conditioners and heat pumps; 

• Trane reviewed the unique design of their heat exchanger and how it limited the efficiency 

improvements they were capable of making with their central air conditioners and heat 

pumps; 

• Also discussed an EER standard and why Trane believed it wasn't necessary; 

• Trane volunteered that in their opinion, the analysis does not support a SEER 12 standard, 

much less the DOE proposal; 

Trane discussed a number of specific areas of the analysis they felt were flawed, including 

choice of a seven percent discount rate. They believe the discount rate is too low; 

• Trane reviewed the markups found in Table V3 of the DOE TSD and how they were not 

representative of what is occurring in the marketplace. The DOE analysis, as shown in 

Table V3, indicates mark-ups decrease with increasing efficiency; 

• Trane believe that the 13 SEER central air conditioner is state-of-art and is too high to 

consider for a standard since it would result in a commodity market; 

• Trane discussed how many in the industry are highly leveraged and the standards would 

have significant negative impacts; and 

• Trane discussed their support for TXY requirement, even though they find there is little 

benefit in specifYing TXY's since they believe they are becoming common place. 

Q:\EE-41 \Equipment, Materials, ToolslAppliance Stds\Residential\Central Air and Heat l'umps\Standard\trane 10_31. wpd