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## L I ^ EG(07-90) 

### EE-RM/STD-98-440 

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## United States Government Department of Energy EE-/S ArD

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# memorandum

DATE:/ / REPLY TO ATTN OF: M,
SUBJECT: 

### Meeting with Representatives ofthe Trane Company TO: 

### Docket No. EE-RM-94-003 On October 31, 2000, Dan Reicher, Assistant Secretary forEnergy Efficiency and Renewable Energy, met with representatives ofthe Trane Company, a manufacturer ofcentral 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: DanReicher, 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 oftheir heat exchanger and how it limited the efficiency improvements they were capable ofmaking with their central air conditioners and heat pumps;

· Also discussed anEER standard and why Trane believed it wasn't necessary; * Trane volunteered that intheir opinion, the analysis does not support a SEER 12 standard, much less the DOE proposal;

· Trane discussed a number ofspecific areas ofthe analysis they felt were flawed, including choice ofa seven percent discount rate. They believe the discount rate is too low;

· Trane reviewed the markups found in Table V.3 ofthe DOE TSD and how they were not representative ofwhat is occurring in themarketplace. 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 islittle 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 •. DSlEF 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 withRepresentatives ofthe Trane Company DocketNo. EE-RM-94-003 On October 31, 2000, DanReicher, Assistant Secretaryfor EnergyEfficiency and Renewable Energy, met with representatives ofthe Trane Company, a manufacturer ofcentral air conditioners and heat pumps, to discuss theDepartment'srulemaking regarding energy efficiency standards for central air conditioners and heat pumps. (DocketNo. EE-RM-94-003). Attending the meeting were the following: DOE: DanReicher, Michael 

### 1. McCabe, Edward O. Pollock, Jr. and EugeneMargolis Trane: Jim Wolf, VicePresident GovernmentRelations 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 oftheir heat exchanger and howit limited the efficiency improvements they were capable ofmaking 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 ofspecific areas ofthe analysis they felt wereflawed, including choice ofa seven percent discount rate. They believethe discount rate is too low; • Tranereviewedthe markups found in Table V3 oftheDOE TSD and howthey were not representative ofwhat is occurring in the marketplace. The DOE analysis, as shown in Table V3, indicates mark-ups decrease with increasing efficiency; • Tranebelieve thatthe 13 SEERcentral air conditioneris state-of-art and is too high to considerfor 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 supportfor TXYrequirement, eventhoughthey find there is little benefit in specifYing TXY's since theybelieve they arebecoming common place.

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