The following is a draft U.S. Department of En ergy guidance document that specifies a means by which manufacturers of residential central air conditioning systems and air conditioning heat pump systems that are designed to use HCFC-22 refrigerant could comply with the applicable energy conservation standards. This draft gui dance document represents the Department’s interpretation of its existing regulations and is exempt from the notice and comment requirements of the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A). Nevertheless, given that the Department has not previously expressed its views on this issue, we are interested in receiving feedback from the public. Therefor e, the Department is accepting comments and suggestions from the public until November 22, 2010. Comments and suggestions should be provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to CACHP-R22-Guidance-2010-TP-0038@ee.doe.gov

. Pl ease also include the docket numb er: EERE-2010-BT-TP-0038. At the end of the comment period, this draft guidance document may be adopted, revised or withdrawn.



## TESTING OF R-22 SYSTEMS Last Day for Comments: November 22, 2010

DOE regulations require that residential spli t system central air conditioners and heat pumps be tested using the “the evap orator coil that is likely to have the largest volume of retail sales with the particular mode l of condensing unit.” 10 C.F.R. § 430.24(m)(2). Effective January 1, 2010, the U.S. Environmental Protection Agency (EPA) banned the sale and distribution of those central air condit ioning systems and heat pump syst ems manufactured after January 1, 2010, that are designed to use R-22 refrigerant. 74 Fed. Reg. 66450 (Dec. 15, 2009). EPA’s rulemaking included an exception for the manufacture and importation of replacement components, as long as those components are not pre-charged with R-22. Id . at 66459-66460. In light of EPA’s rulemaking, DOE has received numerous inquiries regarding the sale of R-22 systems and the applicability of our regulations with respect to these types of systems. Specifically, manufacturers have questioned how to rate R-22 sy stems given that DOE’s test

1procedure requires a determinati on of the coil/condensing unit combination likely to have the largest volume of retail sales.

EPA’s recent rulemaking had no effect on DOE ’s longstanding regulatory framework for the energy conservation standards for residential split system central air conditioners and heat pumps, which are refrigerant-blind. Currently, th ese systems must meet the energy conservation standards effective January 23, 2006, and must be certified prior to distribution in commerce. 10
C.F.R. § 430.24(c)(2) and 10 C.F.R. § 430.62. DOE recognizes that many of the R-22 systems and components are part of legacy offerings that have been available over the past five years. As such, many of these R-22 systems were in produ ction before January 1, 2010, and have already been tested and rated by their manufacturers. EPA’s rulemaking had no effect on the efficiency rating of these systems. These ratings continue to be valid and already sh ould have been certified as compliant to DOE. 1

For manufacturers that are producing new or redesigned R-22 components or systems of split system air conditioners or heat pump s after January 1, 2010, DOE is clarifying the applicability of the test procedure. DOE’s test procedures state that split system central air conditioning systems and heat pumps, including sy stems designed to use R-22 refrigerant, should be tested by pairing “the evaporat or coil that is likely to have the largest volume of retail sales with the particular model of condensing unit.” 10 C.F.R. § 430.24(m)(2). This regulatory provision continues to apply; however, if a manufacturer has difficulty determining the

1 DOE is aware that the Air-Conditioning, Heating, and Re frigeration Institute (AHRI) recently dropped systems utilizing R-22 refrigerant from its certification programs. Because AHRI is no longer including R-22 systems in its certification program, manufacturers, including AHRI me mbers participating in the AHRI certification program, should ensure that their R-22 systems have been certif ied to DOE as compliant in accordance with 10 C.F.R. § 430.62. 2appropriate R-22 coil that is likel y to have the largest volume of retail sales due to the EPA prohibition on the sale of complete pre-charged systems, DOE will assume that a manufacturer that tests and rates a system usi ng any R-22 evaporator coil with a capacity of 1⁄2 ton less than the condensing unit will have tested the system with th e coil that is likely to have the largest volume of retail sales. DOE encourages this appro ach, as it will ensure that R-22 systems do not overstate the efficiency, while providing a simple and transpar ent means for manufacturers to continue to test and rate the products. DOE notes that manufacture rs electing to use this method to test R-22 systems should explicitly document the methodology in their te st records that they maintain per DOE’s regulations in 10 C.F.R. § 430.62(d) in case compliance issues arise.

Manufacturers should note that testing performed using this method would not be valid for use in conjunction with any existing approve d alternate rating method (ARM). Therefore, manufacturers would either need to apply for a new ARM using the procedures in 10 C.F.R. § 430.24(m) in conjunction with new test data or each combination would have to be tested and rated individually.

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