## Letterll

February 07 , 2011

Mr. John Cymbalsky

Program Manager, Building Technology Program

Energy Efficiency and Renewable Energy , EE

- 2J

U.S. Department of Energy

1000 Independence Ave., SW

Washington, DC 20585

Dear John :

I am writing to bring your atten tion to some errors in the 2010 version of ASHRAE 90.1

that have the potential to negatively impact manufacturers of through

- the

- wall heat

pumps and evapor atively cooled air conditioners. More specifically, Table 6.8.1A of

ASHRAE 90.1

- 2010 incorrectly lis t s the minimum energy efficiency standard for through

the

- wall heat pumps at 13 SEER and for evaporatively cooled air conditioners with

cooling capacities betwe en 240,000 and 760,000 Btu/h (heating section other than

electric) at 12.2 EER.

The correct m inimum energy efficiency standard for through

- the

- wall heat pumps is 12

SEER. This minimum energy efficiency standard is the same as the efficiency standard

for residential through

- the

- wall heat pumps that were established by DOE and which

became effectiv e on January 1, 2010. The correct minimum energy efficiency standards

for evaporatively cooled air conditioners with cooling capacities between 240,000 and

760,000 Btu/h is 11.7 EER , which is 0.2 EER less than the efficiency for the same product

class wit h electric resistance or no heating element. In fact, a 0.2 EER deduction applies

to all product classes listed in Table 6.8.1A when a heating element o ther than electric

heat is present in the equipment. Obviously, the 12.2 EER for evaporatively cooled air

conditioners with cooling capacities between 240,000 and 760,000 Btu/h is an anomaly

as it is 0.3 EER higher and not 0.2 EER lower than the 11.9 EER established for products

with electric heat or no heat.

At its w inter 2011 meeting in Las Vegas, the ASHRAE 90.1 committee approved a n

addendum for public review that corrects the error s (see attached copy)

. The

addendum review process will start in the sp ring a nd final approval is expected at the

2011 su mmer meeting of the committee in Montreal. However, AHRI understand s that

the Department of Energy (DOE) is currently assessing the energy efficiency standards of

### John Cymbalsky

U.S. Department of Energy Page | 2



## federally covered equipment amended by ASHR AE 90.1

- 2010 and will shortly issue a

Notice of Proposed Rulemaking (NOPR) recommending new federal minimum energy

efficiency standards

. Therefore, i t is essential that DOE’s review of the minimum energy

efficiency standards for both through

- the

- wall heat pumps and evaporatively cooled air

conditioners be based on the corrected Table 6.8.1A as shown in the addendum and not

the table published in the 2010 version of ASHRAE 90.1

.

T hank you in advance for your consideration and attention to this matter. Pl ease do not

hesitate to contact me if you have questions.

Sincerely,

Karim Amrane

Vice President

, Regulatory & Research

Tel: 703/524

- 8800 ext.307



## Email: kamrane@ahrinet.org

Attachment: As stated

Cc: Dan iel Cohen, Department of Energy

Steve Skalko, Chairman ASHRAE 90.1 Committee

Ned Heminger, Chairman ASHRAE 90.1 Mechanical Subcommittee

### BSR/ASHRAE /IESNA Addendum ??

to ANSI/ASHRAE /IESNA Standard 90 .1

- 20 10



# Public Review

Draft

_____________________________________



# ASHRAE **** 

# Standard

Proposed Addendum ?? to

Standard 90 .1

- 200 7

, **Energy**

**Standard for Buildings**

**Except Low**

**- Rise** 

**Residential Buildi ngs** 

First Public Review ( February 2011 )

(Draft Shows Proposed Changes to

Current Standard )

This draft has been recommended for public review by

the responsible project committee. To submit a

comment on this proposed addendum, use the comment

form and i nstructions provided with this draft. The draft

is subject to modification until it is approved for

publication by the Board of Directors and ANSI. Until

this time, the current edition of the standard (as

modified by any published addenda on the ASHRAE

web site) remains in effect. The current edition of any

standard may be purchased from the ASHRAE

Bookstore @ http://www/ashrae.org or by calling 404

-

636

- 8400 or 1

- 800

- 727

- 4723 (for orders in the U.S. or

Canada).

This s tandard is under continuous maintenance. To

propose a change to the current standard, use the

change submittal form available on the ASHRAE web

site @ http://www/ashrae.org

.

The appearance of any technical data or e ditorial

material in this public review document does not

constitute endorsement, warranty, or guaranty by

ASHRAE of any product, service, process, procedure, or

design, and ASHRAE expressly disclaims such.

© March 1 6 , 200 7 . This draft is covered under AS HRAE

copyright. Permission to reproduce or redistribute all or

any part of this document must be obtained from the

ASHRAE Manager of Standards, 1791 Tullie Circle, NE,

Atlanta, GA 30329. Phone: 404

- 636

- 8400, Ext. 1125. Fax:

404

- 321

- 5478. E

- mail: standards .section@ashrae.org.

AMERICAN SOCIETY OF HEATING, REFRIGERATING

AND AIR

- CONDITIONING ENGINEERS, INC.

1791 Tullie Circle, NE Atlanta GA 30329

- 2305

### BSR/ASHRAE /IESNA Addendum “ ” to ANSI/ASHRAE /IESNA Standard 90 .1

- 20 1 0

, Energy Standard for

Buildings Except Low

- Rise Residential Buildings



## First Public Review Draft

(This foreword is not part of this standard. It is merely informative and does not contain

requirements necessary for conformance to the standard. It has not been processed

according to the ANSI requirements for a standard and may contain material that has not

been subject to public review or a consensus process. Unresolved objectors on informative

material are not offered the right to appeal at ASHRAE or ANSI.)



# FOREWORD

During the final preparation of the ASHRAE 90.1

- 2010 addendum S, BG, and CO to the

ASHRAE 90.1

- 2007 standard and addendum g to the ASHRAE 90.1

- 2004 standard

were consolidated into the fina l released version of table 6.8.1A and table 6.8.1B.

Several errors were made that need to be corrected. This addendum has been

generated to make these corrections.

In addition the small duct high velocity requirements have been dropped by DOE and

the y are only allowing such systems under waiver clause so the addendum has also

made a change to remove the small duct high velocity systems form table 6.8.1a and

table 6.8.1b

**Note: In this addendum, changes to the current standard are indicated in the text**

**by underlining (for additions) and strikethrough (for deletions) unless the**

**instructions specifically mention some other means of indicating the changes.**

**Only these changes are open for review and comment at this time. Additional**

**material is provided for context only and is not open for comment except as it** 

**relates to the proposed substantive changes.**

### BSR/ASHRAE /IESNA Addendum “ ” to ANSI/ASHRAE /IESNA Standard 90 .1

- 20 1 0

, Energy Standard for

Buildings Except Low

- Rise Residential Buildings



## First Public Review Draft

TABLE 6.8.1 A Electrically Operated Unitary Air Conditioners and Condensing

Units

– Minimum Efficiency Requirements

Equipment Type Size Category Heating S ection

Type Sub

- Category or

Rating Condition Minimum

Efficiency a 

### Test

Procedure b

Air Conditioners,

a ir Cooled <65,000 Btu/h c b All Split System 13.0 SEER

AHRI

210/240 Single Package 13.0 SEER

Through

- the

- wall

(air cooled) ≤30,000 Btu/h c b All Split s ystem 12.0 SEER

Single Package 12.0 SEER

Small

- duct high

- velocity

(air cooled) <65,000 Btu/h c b All Split System 10.0 SEER

Air conditioners,

air cooled ≥ 65,000 Btu/h and

<135,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 1 1.2 EER

11.4 IEER

A H RI

340/360 All other Split System and

Single Package 11.0 EER

11.2 IEER

≥ 135,000 Btu/h and

<240,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11.0 EER

11.2 IEER

All other Split System and

Single Packa ge 10.8 EER

11.0 IEER

≥ 240,000 Btu/h and

<760,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 10.0 EER

10.1 IEER

All other Split System and

Single Package 9.8 EER

9.9 IEER

≥ 760,000 Btu/h Electric Resistance

(or None) Spl it System and

Single Package 9.7 EER

9.8 IEER

All other Split System and

Single Package 9.5 EER

9.6 IEER

Air Conditioners,

w ater Cooled < 65,000 Btu/h All Split System and

Single Package 12.1 EER

12.3 IEER A H RI

210/240

≥ 65,000 Btu/h and

<135,0 00 Btu/h Electric Resistance

(or None) Split System and

Single Package 11.5 EER (before 6/1/2011)

12.1 EER (as of 6/1/2011)

11.7 IEER ( before 6/1/2011 )

12.3 IEER (as of 6/1/2011)

A H RI

340/360 All other Split System and

Single Package 11. 3 EER (before 6 /1/2011)

11.9 EER (as of 6/1/2011)

11. 5 IEER ( before 6/1/2011 )

12.1 IEER (as of 6/1/2011)

≥ 135,000 Btu/h and

<240,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11. 0 EER (before 6/1/2011)

12.5 EER (as of 6/1/2011)

11. 2 IEER ( before 6/1/2011 )

12.5 IEER (as of 6/1/2011)

All other Split System and

Single Package 1 0.8 E ER (before 6/1/2011)

12.3 EER (as of 6/1/2011)

11. 0 IEER ( before 6/1/2011 )

12.5 IEER (as of 6/1/2011)

≥ 240 ,000 Btu/h and

<760,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11. 0 EER (before 6/1/2011)

12.4 EER (as of 6/1/2011

) 1 1. 1 EER (before 6/1/2011)

12.6 EER (as of 6/1/2011)

All other Split System and

Single Package 1 0.8 EER (before 6/1/2011)

12.2 EER (as of 6/1/2011)

1 0.9 EER (before 6/1/2011)

12.4 EER (as of 6/1/2011)

### BSR/ASHRAE /IESNA Addendum “ ” to ANSI/ASHRAE /IESNA Standard 90 .1

- 20 1 0

, Energy Standard for

Buildings Except Low

- Rise Residential Buildings



## First Public Review Draft

TABLE 6.8.1A Electrically Operated Unitary Air C onditioners and Condensing

Units

– Minimum Efficiency Requirements **(continued)**

Equipment Type Size Category Heating Section

Type Sub

- Category or

Rating Condition Minimum

Efficiency a 

### Test

Procedure b

Air Conditioners,

w ater Cooled ≥760,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11. 0 EER (before 6/1/2011)

12.2 EER (as of 6/1/2011)

1 1.1 EER (before 6/1/2011)

12.4 EER (as of 6/1/2011 A H RI

340/360

All other Split System and

Single Package 1 0.8 EER (befor e 6/1/2011)

12.0 EER (as of 6/1/2011)

1 0.9 EER (before 6/1/2011)

12.2 EER (as of 6/1/2011)

Air Conditioners,

evaporatively cooled < 65,000 Btu/h c b All Split System and

Single Package 12.1 EER

12.3 IEER A H RI

210/240

≥ 65,000 Btu/h and

<135,000 Btu/h El ectric Resistance

(or None) Split System and

Single Package 11.5 EER (before 6/1/2011)

12.1 EER (as of 6/1/2011)

11.7 IEER ( before 6/1/2011 )

12.3 IEER (as of 6/1/2011)

A H RI

340/360 All other Split System and

Single Package 11. 3 EER (before 6/1/2011)

11 .9 EER (as of 6/1/2011)

11. 5 IEER ( before 6/1/2011 )

12.1 IEER (as of 6/1/2011)

≥ 135,000 Btu/h and

<240,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11. 0 EER (before 6/1/2011)

12.0 EER (as of 6/1/2011)

11. 2 IEER ( before 6/1/2011 )

12.2 IEER (as of 6/1/2011)

All other Split System and

Single Package 1 0.8 E ER (before 6/1/2011)

11.8 EER (as of 6/1/2011)

11. 0 IEER ( before 6/1/2011 )

12.0 IEER (as of 6/1/2011)

≥ 240 ,000 Btu/h and

< 760 ,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11. 0 EER (before 6/1/2011)

11.9 EER (as of 6/1/2011)

1 1. 1 I EER (before 6/1/2011)

12.1 IEER (as of 6/1/2011)

All other Split System and

Single Package 1 0.8 EER (before 6/1/2011)

12.2 11.7 EER (as of

6/1/2011)

1 0.9 I EER (before 6/1/2011)

11.9 IEER (as of 6/1/2011)

≥760,000 Btu/h Electric Resistance

(or N one) Split System and

Single Package 11. 0 EER (before 6/1/2011)

11.7 EER (as of 6/1/2011)

1 1.1 I EER (before 6/1/2011)

11.9 IEER (as of 6/1/2011)

All other Split System and

Single Package 1 0.8 EER (before 6/1/2011)

11.5 EER (as of 6/1/2011)

1 0.9 I EER (b efore 6/1/2011)

11.7 IEER (as of 6/1/2011)

Condensing units

air cooled ≥135,000Btu/h 10.1 EER (before 6/1/2011)

10.5 EER (as of 6/1/2011)

11.4 IEER (before 6/1/2011)

11.8 IEER (as of 6/1/2011)



### AHRI

365 Condensing units

water cooled ≥135,000Btu/h 13.1 EER (before 6/1/2011)

13.5 EER (as of 6/1/2011)

13.6 IEER (before 6/1/2 011)

14.0 IEER (as of 6/1/2011)

Condensing units

evaporatively cooled ≥135,000Btu/h 13.1 EER (before 6/1/2011)

13.5 EER (as of 6/1/2011)

13.6 IEER (before 6/1/2011)

14.0 IEER (as of 6/1/2011)

a IPLV and part load rating conditions are only applicable to equipment with capacity modulation

b a Section 12 contains a complete specification of the referenced test procedure, including the reference year version of the te st procedure

c b Single phase, air cooled air conditioners <65,000 Btu/hr are regulated by NAECA, SEER valves are those set by NAECA

### BSR/ASHRAE /IESNA Addendum “ ” to ANSI/ASHRAE /IESNA Standard 90 .1

- 20 1 0

, Energy Standard for

Buildings Except Low

- Rise Residential Buildings



## First Public Review Draft

TABLE 6.8.1 B Electrically Operated Unitary and Applied Heat Pumps

— Minimum Efficiency Requirements

Equipment Type Size Category Heating Section

Type Sub

- Category or

Rating Condition Minimum

Efficiency a 

### Test

Procedure b

Air cooled

(cooling mode) <65,000 Btu/h c b All Split System 1 3 .0 SEER



### A H RI

210/240 Single Packaged 13.0 SEER

Through

- the

- wall,

air cooled ≤30,000 Btu/h c b All Split System 13.0 12.0 SEER

Single Packaged 13.0 12.0 SEER

Single

- d uct high

velocity

air cooled <65,000 Btu/h c b All Split System 10.0 SEER

Air Cooled

(Cooling Mode) ≥ 65,000 Btu/h and

<135,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 11.0 EER

11.2 IEER

A H RI

340/360 All other Split System an d

Single Package 10.8 EER

11.0 IEER

≥ 135,000 Btu/h and

<240,000 Btu/h Electric Resistance

(or None) Split System and

Single Package 10.6 EER

10.7 IEER

All other Split System and

Single Package 10.4 EER

10.5 IEER

≥ 240,000 Btu/h Electric Resista nce

(or None) Split System and

Single Package 9.5 EER

9.6 IEER

All other Split System and

Single Package 9.3 EER

9.4 IEER

Water source

(cooling mode) <17,000 Btu/h All 86 °F entering water 11.2 EER

ISO 13256

- 1 ≥17,000 Btu/h and

<65,000 Btu/h All 86 °F entering water 12.0 EER

≥65,000 Btu/h and

<135,000 Btu/h All 86 °F entering water 12.0 EER

Ground water source

(cooling mode) <135,000 Btu/h All 59 °F entering water 16.2 EER

All 77 F entering water 13.4 EER

Water source

water to water

(co oling mode) <135,000 Btu/h All 86 °F entering water 10.6 EER

ISO 13256

- 2 59 °F entering water 16.3 EER

Ground source

Brine to water

(cooling mode) <135,000 Btu/h All 77 °F entering water 12.1 EER

### BSR/ASHRAE /IESNA Addendum “ ” to ANSI/ASHRAE /IESNA Standard 90 .1

- 20 1 0

, Energy Standard for

Buildings Except Low

- Rise Residential Buildings



## First Public Review Draft

TABLE 6.8.1 B Electrically Operated Unitary and Ap plied Heat Pumps

— Minimum Efficiency Requirements **(continued)**

Equipment Type Size Category Heating Section

Type Sub

- Category or

Rating Condition Minimum

Efficiency a 

### Test

Procedure b

Water source

water to water

(cooling mode) <135,000 Btu/h All 86 °F ente ring water 10.6 EER



### ISO

- 13256

- 2 Groundwater source

water to water

(Cooling Mode) <135,000 Btu/h All 59 °F entering water 16.3 EER

Ground source

Brine to water

(cooling mode) <135,000 Btu/h All 77 °F entering water 12.1 EER



### Air cooled

(heating mode) <6 5,000 Btu/h c b – 

### Split System 7.7 HSPF

AHRI 210/240 – 

### Single Package 7.7 HSPF

Through

- the

- wall,

(air cooled, heating

mode) ≤30,000 Btu/h c b

(cooling capacity) – 

### Split System 7.4 HSPF

– 

### Single Package 7.4 HSPF

Small

- Duct high

velocity

(air cooled, heating

mode) <65,000 Btu/h c b

– 

### Split System 6.8 HSPF

Air Cooled

(Heating Mode) ≥ 65,000 Btu/h and

<135,000 Btu/h

(Cooling Cap acity) – 47oF db/43oF wb

Outdoor Air 3.3 COP

ARI

340/360 17oF db/15oF wb

Outdoor Air 2.25 COP

≥ 135,000 Btu/h

(Cooling Capacity) – 47oF db/43oF wb

Outdoor Air 3.2 COP

17oF db/15oF wb

Outdoor Air 2.05 COP

Water source

(heating mode) <135,000 Btu/h

(cooling capacity) – 68 °F entering water 4.2 COP

ISO 13256

- 1 Ground water source

(heating mode) <135,000 Btu/h

(cooling capacity) – 50 °F entering water 3.6 COP

Ground source

(heating mode) <135,000 Btu/h

(cooling capacity) – 32 °F entering flui d 3.1 COP

Water

- source

water to water

(heating mode) <135,000 Btu/h

(cooling capacity) – 68 °F entering water 3.7 COP

ISO 13256

- 2 – 50 °F entering water 3.1 COP

Groundwater source

water to water

(heating mode) <135,000 Btu/h

(cooling capacity) – 5 0 °F entering water 3.1 COP

Ground source

brine to water

(heating mode) <135,000 Btu/h

(cooling capacity) – 32 °F entering fluid 2.5 COP

a IPLV and part load rating conditions are only applicable to equipment with capacity modulation.

a b Section 12 contains a complete specification of the referenced test procedure, including the reference year version of

the test procedure

b c Single phase, air cooled air conditioners <65,000 Btu/hr are regulated by NAECA, SEER valves are those set by

NAECA