EE-RM/STD-98-440M /

November 15, 2000

Memorandum to Docket

Subject: Correspondence on Central Air Conditioner Rulemaking Analyses Regarding.

Request from ACEEE

Background: The Department posted to the public web site the spreadsheet computer programs

used in conducting the engineering and economic analyses which provide the basis for the

proposed rule for Central Air Conditioners and Heat Pumps. The spreadsheet programs were

intended for use of the interested parties to facilitate review of the underlying assumptions made

by the Department and, if so desired, to modify those assumptions and to view the resulting data.

Discussion: The American Council for an Energy Efficient Economy (ACEEE) requested

assistance from the Department in preparing their comments for the proposed rule. The ACEEE

requested that DOE perform Life Cycle Cost (LCC) and National Energy Savings/Net Present

Value (NES/NPV) analyses using the Department's spreadsheet models with input assumptions

that differed from those used in the analyses leading to the proposed rule.

Attachment 1 consists of two parts: a) the ACEEE request; and b) the Department's response to

the ACEEE request.

Attachment 2 is the November 3, 2000 letter from Ted Rees, President of the Air-Conditioning

& Refrigeration Institute (ARI) to Dan Reicher, Assistant Secretary, Energy Efficiency and

Renewable Energy commenting on the ACEEE analysis.

Michael E. McCabe

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EE-RM-STD-98-440 COMMENT 70

EE-RM/STD-98-440 y#: 7(J 

November 15, 2000 

Memorandum to Docket 

Subject: Correspondence on Central Air Conditioner Rulemaking Analyses Regarding " 

Request from ACEEE 

Background: The Department posted to the public web site the spreadsheet computer programs 

used in conducting the engineering and economic analyses which provide the basis for the 

proposed rule for Central Air Conditioners and Heat Pumps. The spreadsheet programs were 

intended for use of the interested parties to facilitate review of the underlying assumptions made 

by the Department and, if so desired, to modify those assumptions and to view the resulting data. ' 

Discussion: The American Council for an Energy Efficient Economy (ACEEE) requested 

assistance from the Department in preparing their comments for the proposed rule. The ACEEE 

requested that DOE perform Life Cycle Cost (LCC) and National Energy SavingslNet Present -

Value (NESINPV) analyses using the Department's spreadsheet models with input assumptions 

that differed from those used in the analyses leading to the proposed rule. 

Attachment 1 consists of two parts: a) the ACEEE request; and b) the Department's response to 

the ACEEE request. 

Attachment 2 is the November 3,2000 Jetter from Ted Rees, President of the Air-Conditioning 

& Refrigeration Institute (ARl) to Dan Reicher, Assistant 8ecretary,Energy Efficiency,;and .. 

Renewable Energy commenting on the ACEEE analysis. 

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Michael E. McCabe , . 

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EE-RM/STD-98-44Q4 )7

Attachment 1;part (a) of letter to docket

Efficiency Advocates Request for Alternative Scenarios for DOE Central Air Conditioner

and Heat Pump Rulemaking

A. Please conduct a revised lifecycle cost-analysis using the following assumptions. - :-

1. Start with the reverse engineering analysis

2. Increase average marginal air conditioning electricity prices by 1.36 cents/kWh. This

figure is based on the differential between summer and annual average wholesale electric

prices for four regional power systems in 1999 and 2000 (average differential of 1.86

cents/kWh) minus the summer average marginal retail price difference used in the DOE

analysis (-0.5 cents/kWh). Details will be provided in ACEEE's written comments.

[Note: we are also considering scenarios with higher (2X) and lower (0.5X) adders so it

would be best model this in ways that the adder can be easily changed].

3. Apply emerging technology cost reduction estimates to SEER 13 - 15 per DOE's

analysis on page 4-37 in the TSD. The SEER 14 and 15 numbers are important because

they affect the NES, GRIM, and employment analyses.

4. Reduce the manufacturing cost of all models (baseline and higher efficiency),by- :-

0.84%/year from the base year of the analysis data (1998). Over the past five years,

Census Bureau Current Industrial Reports data indicates that the real cost of air

conditioners has declined by 1.7% annually. To be conservative, we suggest that DOE - :--:

model annual cost reductions at half this level. [Note: we are also considering scenarios. :

with higher (2X) and lower (0.5X) annual rates so it would be best model this in ways - :

that the rate can be easily changed].

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B. In addition to "A", conduct a lifecycle cost analysis with the following additional change., .

Adjust the energy savings analysis to show an improvement in SEER as follows: -

Split AC Split HP. Pkgd AC. & Pkgd HP

SEER 11 Model as SEER 12.2 Model as SEER 12.5

SEER 12 Model as SEER 12.96 Model as SEER 13.6 

SEER 13 Model as SEER 13.68 Model as SEER 14.7

SEER 14 Model as SEER 14.36 Model as SEER 15.8-

These adjustments are based on data in Neal 1998 (copy previously submitted) on savings

with TXVs and data in the TSD Appendix B on the percent of units that do not presentlyuse TXVs at different SEER levels. Add the cost of TXVs to the reverse engineering cost

estimates to the extent these costs are not already incorporated.

C. Review the inputs to the utility analysis and revise the kW savings per unit to reflect a

baseline peak demand of 2.75 kW (details to be provided in ACEEE's written comments) and

peak savings relative to the baseline as follows:.. - ::

% Reduction from Baseline ... . -. .

EE-RM-STD-98-440 COMMENT 70

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Attachment 1; part (a) of letter to docket :, .. :., .... 

Efficiency Advocates Request for Alternative Scenarios for DOE Central Air Conditioner 

and Heat Pump Rulemaking 

A. Please conduct a revised lifecycle cost-analysis using the following assumptions. 

1. Start with the reverse engineering analysis 

2. Increase average marginal air conditioning electricity prices by 1.36 centslkWh. This 

figure is based on the differential between summer and annual average wholesale electric 

prices for four regional power systems in 1999 and 2000 (average differential of 1.86 

centslkWh) minus the summer average marginal retail price difference used in the DOE 

analysis (-0.5 centslkWh). Details will be provided in ACEEE's written comments. 

[Note: we are also considering scenarios with higher (2X) and lower (0.5X) adders so it 

would be best model this in ways that the adder can be easily changed]. 

3. Apply emerging technology cost reduction estimates to SEER 13 - 15 per DOE's . 

':., . 

analysis on page 4-37 in the TSD. The SEER 14 and 15 numbers are important because'. -

they affect the NES, GRIM, and employment analyses. 

4. Reduce the manufacturing cost of all models (baseline and higher efficiency) ,bye0.84%/year from the base year of the analysis data (1998). Over the past five years, 

Census Bureau Current Industrial Reports data indicates that the real cost of air . 

'. '". '. ~ ". 

conditioners has declined by 1.7% annually. To be conservative, w.e.~ugges~ that DOE . 

model annual cost reductions at half this level. [Note: we are also considering ,scenario&',::;",~ 

with higher (2X) and lower (0.5X) annual rates so it would be best model this iIi ways ',. ~ :' ... ,:: ':', ,,' 

that the rate can be easily changed]. . ,.""" 

B. In addition to "A", conduct a lifecycle cost analysis with the following additional change .. 

Adjust the energy savings analysis to show an improvement in SEER as follows: 

SEER 11 

SEER 12 

SEER 13 

SEER 14 

Split AC Split HP, Pkgd AC,& Pkgd HP 

Model as SEER 12.2 Model as SEER 12.5 

Model as SEER 12.96 Model as SEER 13.6 

Model as SEER 13.68 Model as SEER 14.7 ' 

Model as SEER 14.36 Model as SEER 15.8 

. ':'- . '.'. 

These adjustments are based on data in Neal 1998 (copy previously subIilitted) pn savings .,"" 

with TXV s and data in the TSD Appendix B on the percent of units that do not preseQ.t}y" ' 

use TXV s at different SEER levels. Add the cost of TXV s to the reverse engineering cost 

estimates to the extent these costs are not already incorporated. 

, C. Review the inputs to the utility analysis and revise the kW savings per unit .to reflect ~ 

baseline peak demand of2.75 kW (details to be provided in ACEEE's written comme~ts)and, 

peak savings relative to the baseline as follows: ', .. : :;,'1 ::;(. ,:' . '-' 

% Reduction from Baseline ' " , " t~:;' i'i·=:.::'~ :' ~.!:~f~ .. ~ :."-'._.' 

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SEER 11 7%

SEER 12 14%

SEER 13 20%

SEER 14 Examine ARI database to calculate median EER at this SEER

These percent savings are based on the differences in median EER levels shown in Table '

4.27 of the TSD.

D. Conduct scenarios for NES, GRIM, and employment using scenarios "A" and "B" described

above. In these scenarios include a SEER 14 trial standard.

E. Conduct NES runs for the following four alternative scenarios, using the assumptions from

scenario "A" and scenario "B":

1. A SEER 12 standard effective 1/1/05 followed by a SEER 14 standard effective 1/1/10.

2. A SEER 11 standard effective 1/1/04 followed by a SEER 13 standard effective 1/1/07.

3. A SEER 12 standard effective 1/1/04 followed by a SEER 13 standard effective 1/1/07.

4. A SEER 12 standard for the northern half of the U.S. and a SEER 13 standard for the:

southern half of the U.S. For purposes of this analysis, define South to include the 

following Census Bureau regions: South Atlantic, East South Central, West South

Central, and the southern half of the Western region (e.g. including CA, NV, UT, CO, AZ

andNM). :

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EE-RM-STD-98-440 COMMENT 70 .. , . ~. r 

SEER 11 

SEER 12 

SEER 13 

SEER 14 

7% 

14% 

20% 

Examine ARI database to calculate median EER at this SEER 

These percent savings are based on the differences in median EER levels shown in Table; 

4.27 of the TSD. 

D. Conduct scenarios for NES, GRIM, and employment using scenarios "A" and "B" described. 

above. In these scenarios include a SEER 14 trial standard. 

E. Conduct NES runs for the following four alternative scenarios, using the assumptions from 

scenario "A" and scenario "B": 

1. A SEER 12 standard effective 111105 followed by a SEER 14 standard effective 111110. 

2. A SEER 11 standard effective 111104 followed by a SEER 13 standard effective 111107. ': 

3. A SEER 12 standard effective 111104 followed by a SEER 13 standard effective lIii07; .' ". ': ' 

4. A SEER 12 standard for the northern half of the U.S. and a SEER 13 standard' for the "':: ;':::' , .. 

southern half of the U.S. For purposes of this analysis, define South to include the'.. . .... --, 

following Census Bureau regions: South Atlantic, East South Central, West South . - .. . " .. ' . 

Central, and the southern half of the Western region (e.g. including CA, NV, UT, CO, ~ -_~. '7. c 

andNM). - . 

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