Oral Statement of Lou Sullivan Director, Split Systems

Carrier Corporation Before the Office ofEnergy Efficiency and Renewable Energy U.S. Department ofEnergy

on The Energy ConservationProgram for Consumer Products: TestProcedures for Central Air Conditioners and Heat Pumps DocketNo. EE-RM/TP-97-440 As published inthe January 22,2001 Federal Register March 29,2001Test Procedures for Central Air Conditioners and Heat Pumps Comments ofCarrier Corporation March 29, 2001 DocketNo. EE-RMlTP-97-440 Good Morning. I am Lou Sullivan with Carrier Corporation, the world's largest manufacturer ofair conditioning, heating and refrigeration equipment for commercial, residential and transportation applications. We employ over 14, 000 people in the US with 24 manufacturing plants in 17 states. Iwould like to thankthe DepartmentofEnergy for the opportunityto address this workshop and present ourviews onthe Test Procedures for Central Air Conditioners and Heat Pumps. Specifically, I would like to comment onthree areas ofthe proposedrule: 1) Defaults for the cooling and heating mode cyclic degradation coefficients (Cd's) 2) The use ofdevices (e.g., thermostatic expansion valves) that help compensate for an incorrectrefrigerant charging and insufficient indoor coil airvolume rate problems in field installations 3) Rating untested split-system combinations.

1)Efforts to seek new defaults for the cooling and heating mode cyclic degradation coefficients (Cd's) DOE should set new default Cd values for both cooling and heating. The industry has been aggressively working to improve the cyclic performance ofthis equipment for over two decades, since the inception ofSEER. Many different methods to improve cyclic Page 2Test Procedures for Central Air Conditioners and Heat Pumps Comments ofCarrier Corporation March 29, 2001 DocketNo. EE-RMlTP-97-440 performance have beentried and several are being utilized in today's equipment. Improvements have been so significantthat there is little opportunity for additional Cd improvement. The default value of0.25 is significantlyhigherthanthe typical cooling Cd. The average Cd for fixed expansion device equipment is more like 0.10 for air conditioning units and 0.15 for heatpumps. The most prevalent cyclic enhancement devices are indoor fan delay (TDR) and non-bleed TXV. Liquid line solenoids (LLS) and electronic expansion valves (EXV) are also utilized, butto a much lesser extent. Each ofthese enhancement devices, when applied separatelyreduces the Cdvalue by about 50%. IfTDR is applied with TXV, LLS, orEXV, the Cdvalue is reduced another 50%. The industry members are spending a significant amount oftesttime and effortto determine the cyclic performance ofsystems. This testing serves only to document the system performance as required by law. Manufacturers can easilypredictthe Cd value for a given system, based upon the expansion and enhancement devices utilized. The testing simply confirms what is already known and wastes valuable time. Manufacturers could utilize this valuable test time to run additional steady state tests, such as ISO conditions or high ambient. The industry could also use the time to advance newHVAC technology and concepts, orresolve industry issues. The establishment ofdefault Cd values will also serve to correct an inaccuracy inthe NIST method for rating mixed systems. As written, this procedure gives a 5% credit for Page 3TestProcedures for Central Air Conditioners and Heat Pumps Comments ofCarrier Corporation - March 29, 2001 DocketNo. EE-RMlTP-97-440 non-bleed TXV usage stemming from improved cyclic performance. This credit does not account for the fact thatthe matched system may already have an improved cyclic performance through the usage ofan indoor fan delay (TDR). While these two devices can be used together the improvement in the cyclic performance due to the TXV is nowhere near 5%. Itis more like 1to 2%. DOE should establish lower default Cd values and completely eliminate the cyclic testing option. Values for the fixed restrictor system, as well as the current enhancement devices (TDR, TXV, LLS, EXV) couldbe established immediately. This should be done in conjunction with the revised test procedures and not wait for the new minimum in 2006. Ifnewenhancement devices are created, DOE should oversee a test program and assign the appropriate enhanced Cd level. 2) Should changes be incorporated into the test procedure that encourage the use of devices (e.g., thermostatic expansion valves) that help compensate for incorrectrefrigerant charging and insufficient indoor coil air volume rate problems in field installations? DOE shouldNOTconsider changes to the test procedure that encourage the use of devices thathelp to compensate for improper charge or airflow. In orderto consider such a change, DOE needs to fund independentresearch, which thoroughly examines multiple

devices (notjustTXV) and considers not only the benefits, but also the disadvantages. Carrier's written comments regarding the TXV question posed in the minimum efficiency NOPRwere as follows: Page 4Test Procedures for Central Air Conditioners and Heat Pumps Comments ofCarrierCorporation - March 29, 2001 DocketNo. EE-RM/TP-97-440 Carrier agrees withthe Department's assessment not to require TXV's on all equipment. In general, we do notbelieve the Department shouldbe mandating a specific technology since this stifles creativity, innovation and competition. TXV's, when installed and sizedproperly, can slightly improve the performance ofunits installed with improperrefrigerant charge or airflow. However, TXV's are not without problems. Since there are moving parts withinthese devices, they are potentially less reliable than a fixed expansion device which has no moving parts. Secondly, TXV bulb attachment and insulation ofthis bulb are critical to its operation. An improperly installed bulb can cause a TXV to "hunt" during startup and operationresulting inthe HVAC unit never attaining its steady state performance. Lastly, a TXV, coupled with improper charge or indoor airflow, cancreate issues at the extreme ambient conditions. At low ambient conditions, indoor coil freeze-up is possible, and at high ambient conditions, compressor overheating and shutdown can occur. Until the Departmentthoroughly investigates TXV's and their alternatives, it should notrequire their usage. 3) Should DOEpursue having one standard alternative method for rating untested split-system combinations? DOE should establish one standard method for rating untested combinations. Todaythere are inconsistent methods being used to rate mixed indoor coils. Evidence to supportthis are the many mixedratings in the ARI directory which raise the efficiency ofthe outdoor equipment by 1full SEER. Not so obvious are the mixed coils constructed with Page 5Test Procedures for Central Air Conditioners and Heat Pumps Comments ofCarrier Corporation- March 29, 2001 DocketNo. EE-RMlTP-97-440 considerably less material than the matched coils, buthave the same ratings. The consumer is being misled to believe they are getting a more efficient system. Their installed system will use more powerthan the improperlyrated system they purchased. Their electric bills will be higher as well. The utility companies and the country overall do not see the benefit ofthe power reduction from these improperlyrated systems. Assuming these ratings are overstated by 0.5 SEERand one quarter ofthe systems are soldthis way, there are about 250,000,000 more kilowatt-hours ofpower consumed inthe country annually. The NIST Mixed Rating Method was never officially adopted by DOE. Itis nowout of date and did not account for indoor fan delay (TDR). The most significant shortfall is that the NIST procedure gives a 5% credit for a non-bleed TXV applied to a mixed system. The basis ofthis improvement is an improvementto the cyclic performance ofthe system (Cd). This creditdoes not account for the fact that the matched system may already have an improved cyclic performance through the usage of an indoor fan delay (TDR). While these two devices canbe used together, the improvement inthe cyclic performance due to the TXV is nowhere near 5%. Itis more like 1to 2%. The second potential shortfall ofthe currentprocess is that each manufacturer may utilize their own simulationprogram after approval by DOE. As evidenced by the 1full SEER Page 6Test Procedures for Central Air Conditioners and Heat Pumps Comments ofCarrier Corporation- March 29, 2001 Docket No. EE-RM/TP-97-440 rating increases and the fact that the currentTXV credit is 5%, another 5% increase must be coming from the simulationprograms. This appears to be happening even when physical differences between matched and mixed coils are minimal. DOE needs to rectify this rating deficiency. This has been occurring for over a decade. DOE should develop newdefault Cd values and a select a single simulationprogramthat should be usedby the entire industry. DOE should complete this task in conjunction with the revised testprocedures and not wait until the newminimum in 2006.

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