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 attention 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 evaporatively cooled air conditioners. More specifically, Table 6.8.1A of 

ASHRAE 90.1-2010 incorrectly lists the minimum energy efficiency standard for throughthe-wall heat pumps at 13 SEER and for evaporatively cooled air conditioners with 

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

electric) at 12.2 EER. 

The correct minimum 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 effective 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 with 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 other 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 winter 2011 meeting in Las Vegas, the ASHRAE 90.1 committee approved an 

addendum for public review that corrects the errors (see attached copy). The 

addendum review process will start in the spring and final approval is expected at the 

2011 summer meeting of the committee in Montreal. However, AHRI understands 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 ASHRAE 90.1-2010 and will shortly issue a 

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

efficiency standards. Therefore, it 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.

Thank you in advance for your consideration and attention to this matter. Please 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: Daniel 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 90.1-2010

Public Review 

Draft _____________________________________

ASHRAE Standard

Proposed Addendum ?? to 

Standard 90.1-2007, Energy 

Standard for Buildings 

Except Low-Rise 

Residential Buildings

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 instructions 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 standard 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 editorial 

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 16, 2007. This draft is covered under ASHRAE 

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 90.1-2010, 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 final 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 

they 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 90.1-2010, Energy Standard for 

Buildings Except Low-Rise Residential Buildings

First Public Review Draft

TABLE 6.8.1A Electrically Operated Unitary Air Conditioners and Condensing 

Units – Minimum Efficiency Requirements

Equipment Type Size Category Heating Section

Type

Sub-Category or

Rating Condition

Minimum

Efficiencya Test 

Procedureb

Air Conditioners,

air Cooled <65,000 Btu/hcb All

Split System 13.0 SEER

AHRI

210/240

Single Package 13.0 SEER

Through-the-wall

(air cooled) ≤30,000 Btu/hcb All

Split system 12.0 SEER

Single Package 12.0 SEER

Small-duct high-velocity

(air cooled) <65,000 Btu/hcb 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

11.2 EER

11.4 IEER

AHRI

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 Package

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)

Split 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, 

water Cooled

< 65,000 Btu/h All Split System and

Single Package

12.1 EER

12.3 IEER

AHRI 

210/240

≥65,000 Btu/h and

<135,000 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)

AHRI

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

10.8 EER (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

)11.1 EER (before 6/1/2011)

12.6 EER (as of 6/1/2011)

All other Split System and

Single Package

10.8 EER (before 6/1/2011)

12.2 EER (as of 6/1/2011)

10.9 EER (before 6/1/2011)

12.4 EER (as of 6/1/2011)
BSR/ASHRAE/IESNA Addendum “” to ANSI/ASHRAE/IESNA Standard 90.1-2010, Energy Standard for 

Buildings Except Low-Rise Residential Buildings

First Public Review Draft

TABLE 6.8.1A Electrically Operated Unitary Air Conditioners and Condensing 

Units – Minimum Efficiency Requirements (continued)

Equipment Type Size Category Heating Section

Type

Sub-Category or

Rating Condition

Minimum

Efficiencya Test 

Procedureb

Air Conditioners, 

water 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)

11.1 EER (before 6/1/2011)

12.4 EER (as of 6/1/2011 AHRI

340/360

All other Split System and

Single Package

10.8 EER (before 6/1/2011)

12.0 EER (as of 6/1/2011)

10.9 EER (before 6/1/2011)

12.2 EER (as of 6/1/2011)

Air Conditioners, 

evaporatively cooled

< 65,000 Btu/hcb All Split System and

Single Package

12.1 EER

12.3 IEER

AHRI 

210/240

≥65,000 Btu/h and

<135,000 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)

AHRI

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

10.8 EER (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)

11.1 IEER (before 6/1/2011)

12.1 IEER (as of 6/1/2011)

All other Split System and

Single Package

10.8 EER (before 6/1/2011)

12.2 11.7 EER (as of 

6/1/2011)

10.9 IEER (before 6/1/2011)

11.9 IEER (as of 6/1/2011)

≥760,000 Btu/h

Electric Resistance

(or None)

Split System and

Single Package

11.0 EER (before 6/1/2011)

11.7 EER (as of 6/1/2011)

11.1 IEER (before 6/1/2011)

11.9 IEER (as of 6/1/2011)

All other Split System and

Single Package

10.8 EER (before 6/1/2011)

11.5 EER (as of 6/1/2011)

10.9 IEER (before 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 6/1/2011)

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 ba Section 12 contains a complete specification of the referenced test procedure, including the reference year version of the test procedure cb 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 90.1-2010, 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

Efficiencya Test 

Procedureb

Air cooled

(cooling mode) <65,000 Btu/hcb All

Split System 13.0 SEER

AHRI 

210/240

Single Packaged 13.0 SEER

Through-the-wall,

air cooled ≤30,000 Btu/hcb All

Split System 13.0 12.0 SEER

Single Packaged 13.0 12.0 SEER

Single-duct highvelocity

air cooled

<65,000 Btu/hcb 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

AHRI

340/360

All other Split System and

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 Resistance

(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

(cooling 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 90.1-2010, 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 (continued)

Equipment Type Size Category Heating Section 

Type

Sub-Category or

Rating Condition

Minimum

Efficiencya Test Procedureb

Water source

water to water

(cooling mode)

<135,000 Btu/h All 86 °F entering 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) <65,000 Btu/hcb

– Split System 7.7 HSPF

AHRI 210/240

– Single Package 7.7 HSPF

Through-the-wall,

(air cooled, heating 

mode)

≤30,000 Btu/hcb

(cooling capacity)

– Split System 7.4 HSPF

– Single Package 7.4 HSPF

Small-Duct high 

velocity

(air cooled, heating 

mode)

<65,000 Btu/hcb – Split System 6.8 HSPF

Air Cooled

(Heating Mode)

≥65,000 Btu/h and

<135,000 Btu/h

(Cooling Capacity)

–

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 fluid 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) – 50 °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.

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

the test procedure

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

NAECA