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 U.S. DEPARTMENT OF ENERGY

 + + + + +

 PACKAGED TERMINAL AIR CONDITIONERS AND

 PACKAGED TERMINAL HEAT PUMPS

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 PUBLIC MEETING

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 MONDAY

 APRIL 28, 2014

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 The Public Meeting convened in Room

8E-089, Department of Energy Headquarters,

1000 Independence Avenue, S.W., Washington,

D.C., at 9:00 a.m, Doug Brookman, Facilitator,

presiding.

PRESENT

DOUG BROOKMAN, Facilitator, Public 

 Solutions, Inc.

ASHLEY ARMSTRONG, Department of Energy

JAVIER BURGOS, Navigant Consulting

DAVE CASE, Department of Energy

GARY FERNSTROM, California Investor-Owned

 Utilities 

RONALD MAJETTE, Department of Energy

LAURA PETRILLO, Air-Conditioning Heating and

 Refrigeration Institute

RUSTY THARP, Goodman Manufacturing Company
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 A-G-E-N-D-A

Welcome, Introductions and

 Opening Statements . . . . . . . . . . . . . 3

Regulatory History . . . . . . . . . . . . . . 8

Covered Products . . . . . . . . . . . . . . .10

Test Procedure Amendments. . . . . . . . . . .10

Closing Remarks. . . . . . . . . . . . . . . .55
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1 P-R-O-C-E-E-D-I-N-G-S

2 9:06 a.m.

3 MR. BROOKMAN: Good morning,

4 everyone. Welcome. This is the test

5 procedure notice of proposed rulemaking for

6 packaged terminal air conditioners and

7 packaged terminal heat pumps.

8 Today is April 28th, 2014, here in

9 the Forrestal Building in Washington, D.C. My

10 name is Doug Brookman from Public Solutions in

11 Baltimore and we're going to start with

12 welcoming remarks from Ashley Armstrong. 

13 MS. ARMSTRONG: Sure. I'd just

14 like to welcome everyone here to the

15 department and our public meetings. We

16 appreciate those that have come all the way

17 here in person especially.

18 We expect this meeting to be

19 pretty brief but the point of these meetings

20 is to really get feedback from you guys. So

21 we encourage you to participate, ask

22 questions, tell us where we have done a good
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1 job, tell us where we haven't done such a good

2 job and maybe further work is needed or

3 anything like that.

4 So like I said, we appreciate you

5 guys coming and for those participating on the

6 Web participation is key to us. It helps us

7 get a better product for everyone in the end.

8 So with that, Doug, do you want me

9 to go through the next couple of slides really

10 quick or do you want to - 

11 MR. BROOKMAN: Sure. Go right

12 ahead.

13 MS. ARMSTRONG: Maybe that's not

14 going to work. 

15 MR. BROOKMAN: Maybe I'll just do

16 the agenda. Have all of you received a packet

17 of information? But before we do that we'll

18 do introductions around the room, our name and

19 organizational affiliation.

20 MR. THARP: Rusty Tharp with

21 Goodman Manufacturing.

22 MS. PETRILLO: Laura Petrillo,
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1 AHRI.

2 MR. FERNSTROM: Gary Fernstrom,

3 representing the California Investor Owned

4 Utilities which are Pacific Gas & Electric,

5 Southern California Edison, San Diego Gas &

6 Electric and the Southern California Gas

7 Company.

8 MR. BURGOS: Javier Burgos, from

9 Navigant Consulting.

10 MR. MAJETTE: Ron Majette, U.S.

11 DOE.

12 MR. BROOKMAN: Please introduce

13 yourself. 

14 MR. CASE: Dave Case, DOE.

15 MR. BROOKMAN: Thank you. All of

16 you received a packet of information. The

17 agenda as you see before you there on Page 4

18 is pretty straightforward. After this and a

19 few introductory remarks there's an

20 opportunity for brief opening statements for

21 anyone that wishes to do so.

22 Following that, we'll have a
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1 description of regulatory history and directly

2 following on covered products and from there

3 test procedure amendments, and at the end of

4 the day today whenever we get there you get

5 another opportunity for comments and closing

6 remarks and I'd ask for your consideration -

7 please speak one at a time, saying your name

8 for the record each time you speak. 

9 There will be a complete

10 transcript of this meeting. If you can be

11 concise, share the air time with your friends

12 here. Keep the focus here please. 

13 Turn your cell phones on silent

14 mode and webinar participants, we welcome you. 

15 The Department of Energy is trying hard to

16 make these meetings accessible to all.

17 If you'd keep your telephone on

18 mute and raise your hand to be recognized to

19 speak and we'll try and get you verbally into

20 the room here. It's been working most of the

21 time that you can just speak and we can hear

22 you well in the room. So we wish to make this
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1 accessible that way.

2 So then having said that, back to

3 Ashley.

4 MS. ARMSTRONG: Well, the only

5 thing I'm going to highlight left before we do

6 opening statements is we have these issue

7 boxes throughout the discussion. The issue

8 boxes are specific issues for which we'd like

9 your comment and feedback on.

10 The numbering matches up to the

11 numbering in the notice so you can go back and

12 forth and see what those are. Obviously, feel

13 free to bring up other issues though that

14 aren't just highlighted at the issue boxes. 

15 So opening, right?

16 MR. BROOKMAN: Any opening

17 statements here at the outset? Gary

18 Fernstrom.

19 MR. FERNSTROM: So Gary Fernstrom

20 for the California Investor Owned Utilities. 

21 Just quickly, the California IOUs seek test

22 procedures in general that fully describe the
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1 energy efficiency performance characteristics

2 of products being tested.

3 In this case, that would be the

4 performance at different outside and inside

5 temperature and humidity conditions and the

6 performance at full as well as part load

7 value.

8 Having this information allows us

9 to identify the energy use and savings

10 potential in different climate zones and

11 applications, fully understanding that

12 performance then allows us to decide if we

13 want to structure rebate programs for these

14 things.

15 So we appreciate DOE's work in

16 setting test standards and determining minimum

17 energy efficiency performance levels. Of

18 course, we'd like to see the latter be as high

19 as possible. But important to us is the

20 information that comes out of the testing. 

21 Thank you.

22 MR. BROOKMAN: Thank you very
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1 much. Other comments here at the outset? I

2 guess that's it then. We'll go to Ron

3 Majette.

4 MR. MAJETTE: Okay. Briefly,

5 going to go over the next three slides

6 concerning the regulatory history. Okay. 

7 Again, my name is Ron Majette from the U.S.

8 Department of Energy.

9 The test procedure for today

10 covers packaged terminal air conditioners and

11 heat pumps, and procedures were discussed in

12 10 CFR 431.96. 

13 In December of 2006, DOE

14 established the test procedure in a final rule

15 and this final rule incorporated ANSI/AHRI

16 Standard 310/380-2004 by reference.

17 On May 16th, 2012, we established

18 the final rule for commercial heating and air

19 conditioning equipment and water heating

20 equipment, and this rule amends the test

21 procedure for PTACs and packaged terminal heat

22 pumps.
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1 Now, the early part of last year

2 DOE published a notice of public meeting to

3 discuss the availability of the framework

4 document for this. I think some of you might

5 have actually attended that meeting.

6 All right, and in that particular

7 framework document we were seeking comments,

8 mainly about the equipment break-in period,

9 wall sleeve ceiling, pre-filling the

10 condensate pan, barometric pressure correction

11 and the differences between the different

12 standards - ASHRAE Standard 16 and ASHRAE

13 Standard 37.

14 Okay. On February 26th, 2013, the

15 ASRAC committee formed a working group to

16 engage in negotiated rulemaking to amend

17 commercial HVAC certification requirements.

18 The group gave recommendations and

19 a number of test procedure amendments for the

20 PTACs, a lot of which we were able to

21 incorporate into this document, and DOE

22 proposed these test procedure amendments
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1 without modification in today's rulemakings.

2 So yes, we do not expect this to

3 be very, very controversial. It seems like

4 it's well vetted throughout the industry. 

5 All right. So I think at this

6 point we're going to go ahead and turn this

7 over to Javier Burgos from Navigant.

8 MR. BURGOS: Hello. My name is

9 Javier Burgos. I'm a consultant at Navigant. 

10 Here we'll go over the next couple of

11 sections.

12 The first one is covered products. 

13 This section is pretty simple. It basically

14 contains the definitions as they are written

15 in the CFR for PTACs and PTHPs. 

16 You'll note that the definition

17 includes the wall sleeve, the refrigeration

18 system as well as the choice of heating. So

19 there's no questions on that.

20 We'll go on straight to the next

21 section, which is proposed changes to a test

22 procedure. This section was really the meat
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1 of the NOPR. We'll start out. 

2 As Ron mentioned, the current test

3 procedure right now is AHRI 310/380(2004. 

4 It's actually contained in 10 CFR 431.96. I

5 mean, this is sort of the section in the CFR

6 that incorporates such procedures for multiple

7 different kinds of commercial AC equipment. 

8 So it's all kind of intermingled in there.

9 AHRI 310/380 in its stead

10 references ASHRAE 16, ASHRAE 37 and ASHRAE 58. 

11 All right. These are these

12 proposed changes to the test procedure. One

13 is explicitly allowing for a break-in period. 

14 Two is requiring sealing of gaps between the

15 wall sleeve and test facility wall. 

16 Three is explicitly allowing for

17 pre-filling of the condensate drain water pan

18 with water. Four is requiring ASHRAE 16 as

19 the sole method of test for measuring cooling

20 capacity. 

21 Five is requiring testing of a

22 14-inch wall sleeve, and six is requiring
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1 testing of the most typical filter option

2 shipped with a unit. 

3 Now, some of these items came out

4 of the ASRAC working group recommendations. 

5 Some of these DOE requested comment on in the

6 framework. There was also a number of items

7 here that DOE considered but did not propose

8 changes on.

9 Each one of these items is

10 described in greater detail in the NOPR but in

11 this presentation we'll basically be going

12 through each one of these items one by one and

13 there will be comment boxes - an opportunity

14 to comment on each one of these things.

15 All right. If there is no

16 questions on that we'll start with the first

17 item, which is the break-in duration. And

18 now, this is one of the items that DOE

19 requested comment on in the framework

20 document. 

21 We'll point out that in 10 CFR

22 431.96 there's actually a provision for
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1 conducting break-in testing on other pieces of

2 commercial AC equipment including unitary air

3 conditioners, SPVUs and VRFs. And so DOE

4 requested comments on whether break-in would

5 be appropriate for PTACs and PTHPs.

6 DOE received comments that were

7 supportive of the proposal including break-in

8 periods. As well DOE conducted some testing

9 on PTACs to investigate the impacts of

10 break-in performance and that also supported

11 sort of using the proposal for 20 hours, which

12 is already contained in the CFR.

13 And so DOE's proposing to allow

14 PTAC and PTHP testing to use an optional

15 break-in period of up to 20 hours. That's

16 consistent with what's contained already in

17 the CFR for other commercial air conditioning

18 equipment and they're also proposing to

19 require manufacturers to report the duration

20 of the break-in period that they choose to

21 use. 

22 At this point we're going to hit
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1 our first comment box. We're asking for a

2 comment on, you know, this proposal in terms

3 of adding the optional break-in period, and

4 are there any questions or comments on the

5 break-in proposal?

6 MR. BROOKMAN: Gary Fernstrom.

7 MR. FERNSTROM: I'll pass. Thank

8 you.

9 MR. THARP: Rusty Tharp with

10 Goodman. We'll say that we support DOE adding

11 the break-in provision. We would support a

12 longer time than 20 hours.

13 The reality of our products now we

14 probably would not use them longer than 20

15 hours but we do have - I have seen some data

16 where some compressors do require longer than

17 20 hours to maintain - to attain full ready

18 performance.

19 MR. BROOKMAN: How much longer

20 would you like to see it?

21 MR. THARP: In our other testing

22 in unitary small products for AHRI we'd go as
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1 high as 72 hours.

2 MR. BROOKMAN: Wow.

3 MS. ARMSTRONG: This is Ashley

4 from DOE. So I'm going to request then that

5 as we have in other products that you submit

6 data, because to date what we have seen,

7 especially what was submitted for some of the

8 other unitary products was some curves that

9 show leveling out a little before 20 and very

10 little difference post-20 as compared with the

11 cost and expense of leaving that unit to be

12 broken in longer.

13 So like I said, we're always open

14 to data and we're really interested to see

15 that data if you have any additional data that

16 would suggest a longer period is warranted.

17 Just to make one clarification to

18 this, the second bullet is really key. We are

19 allowing up to 20 hours. If you don't do it

20 and don't report it we don't have to do it.

21 If you do use an AEDM to rate your

22 product we will always do it. That's what the
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1 proposal at least specifies now, which is very

2 consistent with what we're doing for unitary

3 - other types of commercial air conditioning

4 equipment where we already have provisions

5 adopted.

6 MR. BROOKMAN: And if you wish to

7 - anybody wishes to comment on that second

8 provision that she noted. Gary Fernstrom.

9 MR. FERNSTROM: So this is Gary

10 for the California IOUs. You noted that in

11 some cases you find it desirable to use a

12 longer break-in period I presume because the

13 mechanical components wear in and perhaps seal

14 better, you know, giving a better performance.

15 We would - we would want to

16 recognize that performance and would support

17 AHRI in utilizing a longer period when it's

18 appropriate to get a better indication of the

19 equipment's steady state performance for final

20 performance after break-in.

21 MR. BROOKMAN: Okay. Thank you. 

22 Rusty.
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1 MR. THARP: We'll supply some data

2 with our written comments that would, we

3 believe, support longer break-in times.

4 MR. BROOKMAN: Okay. Thank you.

5 MR. BURGOS: All right. Javier

6 Burgos. Thank you, everyone. We will

7 continue on to the next item, which is wall

8 sleeve sealing. Again, DOE asked for comment

9 on this issue in the framework document. 

10 Here, PTACs and PTHPs are tested

11 as described in testing set-ups that are in

12 ASHRAE 16 and ASHRAE 37. One concern right

13 now is that air leakage through the gaps

14 between the sleeve and the insulating material

15 can impact the test in ways that, one, are not

16 representative of field use, and two, can

17 introduce variability, especially variability

18 between test labs.

19 And so currently DOE asked for

20 comments. Comments were generally supportive

21 of adding air sealing into the test procedure.

22 And so DOE's proposal is to
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1 propose that - to require that test facilities

2 who install PTACs and PTHPs in the test

3 chamber seal all potential gaps between the

4 wall sleeve and the dividing wall.

5 And in this case we have an item

6 for comment. Especially, we're asking for two

7 specific things on this proposal, whether the

8 test procedures should specify the method of

9 sealing, and two, whether a test, you know,

10 exists that could sort of either verify or

11 quantify sort of this installation.

12 MR. BROOKMAN: Rusty.

13 MR. THARP: Rusty Tharp with

14 Goodman. I would suggest that a specific

15 method of sealing should not necessarily be

16 specified either to - mandatory a manufacturer

17 to use either tape or caulk or putty, whatever

18 their choice is.

19 I am - the second issue I am not

20 aware of a test that would define how to

21 measure how well it's sealed. I guess what I

22 would support is requirement for documenting
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1 with pictorial pictures how it was sealed in

2 the test report.

3 MR. BROOKMAN: Okay. Thank you.

4 MS. PETRILLO: Laura Petrillo,

5 AHRI. All the manufacturers state that even

6 duct tape would be adequate. So as long as

7 the entire perimeter is sealed we're good to

8 go.

9 MR. BROOKMAN: Gary Fernstrom.

10 MR. FERNSTROM: Gary for the

11 California IOUs. As I understand it, the AHRI

12 standard contains some specifications

13 regarding the seal. Is that correct? I am

14 speaking specifically of AHRI 310/380-2004.

15 MS. ARMSTRONG: So this is Ashley

16 from DOE. My understanding, and I can go back

17 and look at this - I don't have it in front of

18 me - my understanding is it does specify or it

19 does suggest that it should be sealed.

20 My understanding, though, is it

21 doesn't exactly get to the level of detail

22 that either some may want or some may not want
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1 as long as it's sealed. 

2 So I think what we're trying to

3 get at is - at with this question is I think

4 there's a general agreement that sealing is a

5 good thing. It's just a matter of do we need

6 additional specificity before what - besides

7 what is already there, and what I'm hearing at

8 least from these two is maybe not, just good

9 documentation that it's on.

10 MR. FERNSTROM: This is Gary

11 again. I agree, sealing is good. I don't

12 think that's so important exactly how it's

13 done.

14 MR. BURGOS: Okay. Thank you. 

15 All right. Great. In that case we'll move

16 on. The next item is pre-filling of the

17 condensate drain pan. 

18 This is pretty similar to the last

19 two provisions in the sense it is an item that

20 it isn't explicitly addressed in the test

21 procedure.

22 But to, you know, the item we're
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1 discussing here is to reach equilibrium as

2 described in DOE test procedure in ASHRAE 16

3 PTACs and PTHPs generally need to reach a

4 certain level of condensate in the pans and

5 this equilibrium level has to be reached

6 before you're allowed to continue ongoing

7 testing.

8 Now, the process of achieving this

9 condensate level can actually be very time

10 consuming if you rely solely on the device. 

11 And so in order to accelerate the - basically

12 the point of reaching equilibrium so you can

13 go ahead and conduct the test, test labs have

14 filled the drain water - the drain water pan

15 with water prior to testing.

16 This is an issue that DOE sought

17 comment on in framework documents and then the

18 commenters, again, were generally supportive

19 of the addition to the test procedure.

20 And so DOE is proposing to add a

21 provision to allow manufacturers the option of

22 pre-filling the condensate drain pan before
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1 starting the efficiency test, and here we're

2 asking for comment on this proposal,

3 specifically as well on two different things,

4 you know, perhaps regarding the water's

5 characteristics.

6 We're asking whether DOE should

7 require recording and documenting of, one, the

8 temperature of the water, and two, the purity

9 of the water.

10 MR. BROOKMAN: Rusty.

11 MR. THARP: Rusty Tharp with

12 Goodman Manufacturing, and I believe that it

13 would be good. As of right now we don't have

14 some specific test data to support it but I

15 think we should specify that the water

16 temperature should be measured before - at a

17 minimum measured as it goes in because in the

18 design of many PTACs and PTHPs the liquid line

19 will actually be routed through the condensate

20 and so the temperature of the condensate can

21 have a measurable impact on the liquid feeding

22 evaporator. 
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1 Also, the temperature of the water

2 could have an impact on as it's being splashed

3 onto the condenser coil it could have an

4 impact on the condensing temperature, which

5 has a measurable impact on the power

6 consumption of the compressor.

7 So even half a degree difference

8 as far as the condensing temperature will be

9 measurable on the compressor performance. 

10 Therefore, I think we - and then we should

11 record it. 

12 We're doing some internal testing

13 ourselves so that we can provide some

14 information and submit written comments. But

15 I think it's good to, at a minimum, have it

16 recorded.

17 MS. PETRILLO: Thank you.

18 MR. BROOKMAN: Okay. Thank you. 

19 Gary.

20 MR. FERNSTROM: This is Gary for

21 the California IOUs. We support that. Also,

22 we think if we're going to require that or
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1 allow that the pan be filled with external

2 water that it be filled to the overflow point,

3 that some specification be given regarding how

4 full it's filled.

5 MR. BROOKMAN: Okay. Laura.

6 MS. PETRILLO: Laura Petrillo,

7 AHRI. As Rusty mentioned, the quality isn't

8 that important but the temperature may be and

9 we're going to try to take some measurements

10 of some naturally filled condensate pans, you

11 know, from while we're doing our certification

12 program tests. 

13 It's been suggested that in the 40

14 to 50 degree Fahrenheit range might be the

15 most appropriate. But we'll see what actually

16 happens and we'll let you replicate that.

17 MR. BROOKMAN: Okay. Thank you. 

18 And nothing about mineral content, nothing

19 additional about that?

20 MS. PETRILLO: No.

21 MR. BROOKMAN: Okay. 

22 MR. BURGOS: All right. Thank
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1 you. Javier Burgos. The next item we have

2 here is ASHRAE 16 and ASHRAE 37. DOE

3 requested comment on this item in the

4 framework document. 

5 Right now, the current test

6 procedure allows for testing of PTACs and

7 PTHPs using either ASHRAE Standard 16 or

8 ASHRAE Standard 37 to determine the cooling

9 capacity.

10 However, there are some

11 significant differences in the methodology of

12 these two standards, with potential for

13 significant differences in the test results.

14 Something DOE went ahead and did

15 was we had some testing of equipment comparing

16 ASHRAE 16 and ASHRAE 37 and we did find that

17 there could be significant differences, and

18 some of those results are summarized here on

19 this slide.

20 And so DOE also requested comment

21 on this item and the comments were generally

22 supportive of adopting ASHRAE 16. And so in
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1 order to standardize this testing DOE is

2 proposing to require that only ASHRAE 16 be

3 used when conducting a cooling mode test for

4 PTACs and PTHPs. 

5 And one thing we're very

6 interested in learning is, you know, if there

7 is a burden on manufacturers with this

8 requirement, you know, specifically how many

9 products may be being tested using ASHRAE 37.

10 MR. BROOKMAN: Rusty.

11 MR. THARP: Thank you. Rusty

12 Tharp with Goodman, and I just want to clarify

13 one of the comments from the March meeting we

14 had last year.

15 Goodman noted as indicated in this

16 NOPR that we supported DOE adopting ASHRAE 16. 

17 That was based upon the assumption that at

18 that time that ASHRAE 16 would be adopting

19 psychometric testing into its procedure.

20 We have a fair amount of - we

21 actually do more psychrometric testing than

22 calorimetric testing in our facilities. We
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1 have two psych rooms and one cal room and

2 based on our test data we see - we do not see

3 the type of difference that was indicated in

4 these testing. 

5 We specifically did some testing

6 earlier this year and in our testing I can say

7 that our average psychrometric was .14 ER

8 higher than the cal testing, and we find that

9 our psychrometric rooms are fairly in line

10 with what we see from the cal testing that's

11 performed in AHRI audit tests. 

12 So we believe that these should

13 not eliminate psychrometric testing from

14 cooling load. Another major reason for that

15 is because cal testing is - takes a lot longer

16 than psych testing. 

17 Talking with our lab manager we

18 can get maybe two cal tests done in an

19 eight-hour shift if things go well, and if

20 things go well with psych testing we can get

21 five tests done. 

22 So there's a pretty significant
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1 difference in the amount of tests that we can

2 get. Also, when you're talking about heat

3 pumps, and I know the energy advocates and

4 others are pushing for eliminating or at a

5 minimum reducing cooling only PTACs, and if

6 you're going to do cal testing and the cooling

7 testing in a cal room and then heating tests

8 in a psych room that's a major burden pulling

9 the unit in and out between the two and

10 especially during development testing.

11 If you're - you know, as the

12 manufacturer if you're looking at, you know,

13 using 18, 20 or 22 per inch your manufacturer

14 may have those three coils ready to go in a

15 unit and if you're doing psych testing you can

16 probably get all three of those done in an

17 eight-hour shift to see the relative

18 performance difference whereas in a cal room

19 that's three days. So we are a proponent of

20 keeping psychrometric testing.

21 

22 MR. BROOKMAN: Thank you. Gary
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1 Fernstrom.

2 MR. FERNSTROM: This is Gary for

3 the California IOUs. So Rusty, I don't

4 profess to know what the best way to test

5 these things is but I do wish to know what

6 their performance is under all the different

7 conditions that we might see. This goes to my

8 opening comment. 

9 So a question - when you're

10 testing the cooling performance in a

11 psychrometric room do you test down to low

12 humidity areas like we might experience in the

13 high desert of southern California?

14 MR. THARP: Rusty Tharp with

15 Goodman. We do a fair amount of testing for

16 different things before efficiency testing. 

17 We don't necessarily do anything besides the

18 mandated tests. For example, AHRI we

19 typically do high ambient 115 degrees in both

20 - in psych room or cal room.

21 MR. FERNSTROM: Okay. Well, the

22 reason I asked that question was to try and
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1 see whether the performance measurements might

2 reflect those field conditions. Also, on the

3 heating end we're particularly interested in

4 the situation where electric resistance heat

5 might come on and significantly change the

6 heating characteristic of the heat pump. 

7 So we'd be interested in covering

8 in the test procedure the operating point

9 where we switch to electric heat and we can

10 understand the energy impacts of that. Thank

11 you.

12 MR. BROOKMAN: Okay. Thank you. 

13 Additional comments here? 

14 MR. THARP: This is Rusty Tharp

15 with Goodman for - Gary, for clarification I

16 don't think - for the 16 versus 37 I don't

17 think there's a significant difference for the

18 issues that you're commenting on there as far

19 as wanting the high ambient. 

20 So if you're testing on 115 you

21 could do it either in a cal room or a psych

22 room but you could get the data faster in a
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1 psych room.

2 MR. FERNSTROM: Thank you.

3 MS. ARMSTRONG: And this is

4 Ashley. Just to follow up on that point, my

5 understanding also is that neither of the

6 procedures, right, would get you the

7 additional data that you want for the points,

8 either, you know, when the heat - when the

9 electric - what's the tipping point as to when

10 the electric resistance heater is going to

11 come on as well as something in the high

12 ambient low humidity range. 

13 That would be explicit changes DOE

14 would need to consider to one or both

15 procedures depending. So - 

16 MR. FERNSTROM: Thank you, Ashley. 

17 That's right. We're just trying to make the

18 point we would wish to have information that

19 covers the full range of performance. Thanks.

20 MS. ARMSTRONG: So I guess the

21 question that - I'm going to turn his question

22 back to Rusty. If you were able to provide us
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1 data because obviously we tested a limited

2 number of products, if you were to provide us

3 data and a larger data set showing that the

4 impacts that DOE characterized were really

5 less when you consider a larger data set and

6 DOE should consider both methods as equitable

7 results.

8 Would then manufacturers be open

9 to the idea of additional data points, as Gary

10 asked, since it's easier to do in a psych

11 room?

12 MR. THARP: We are open to working

13 with the stakeholders for what's best.

14 MR. FERNSTROM: Well, this is

15 Gary. We realize there's a tradeoff between

16 testing burden and having every little piece

17 of information, you know, you would wish to

18 have. 

19 But similarly we'd like to be open

20 to this and hope to have a reasonable

21 compromise.

22 MR. BROOKMAN: Thank you, Rusty. 
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1 Laura.

2 MS. PETRILLO: Yes. I'd like to

3 suggest a compromise. So like Rusty

4 mentioned, eight trials supported going to

5 ASHRAE 16 if the eight included both test

6 procedures. 

7 Now that, you know, we're here and

8 it hasn't we'd like to see the data that you

9 all collected for those units as well so that

10 we can make a comparison between some, you

11 know, data on our own and what you guys have

12 done.

13 And because of the additional

14 burden to build the calorimeter room, and not

15 all of our manufacturers have them and they

16 would have to conduct testing on their entire

17 product line if they had previously tested it

18 using the psych room test, you know, the time

19 to build a calorimeter room to, you know,

20 validate its performance and obtain all the

21 test data that they would need to for all

22 their units would - you know, we would like an
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1 extension on the compliance date. So two

2 years instead of one.

3 MR. BROOKMAN: Okay. Thank you. 

4 Gary.

5 MR. FERNSTROM: So just for the

6 record I'd like to say we'd be open to that. 

7 You know, we think an additional year is well

8 worth the trade of having additional

9 information.

10 MR. BROOKMAN: Okay. Thank you. 

11 MS. ARMSTRONG: We aren't there

12 yet but while we're on the topic - so this is

13 Ashley from DOE - just to clarify your

14 position, you're open to an extension of the

15 compliance date if we end up proposing or

16 adopting additional data points. 

17 Do you stick with the one-year

18 compliance date if we leave the procedure as

19 is with the single point - well, with the

20 single ambient conditions and full load?

21 MR. FERNSTROM: Precisely. Thank

22 you for that clarification.
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1 MR. BROOKMAN: Good clarification. 

2 Okay. 

3 MR. BURGOS: All right. Javier

4 Burgos. I think we'll move on. Thank you for

5 those comments.

6 The next item we're going to

7 address is wall sleeve size. This is one of

8 the items that are covered by the ASRAC

9 working group which Ron referred to a bit

10 earlier in the presentation.

11 And the issue here is that, you

12 know, these PTACs and PTHPs can come in

13 different sleeve sizes and specifically

14 different depths. 

15 This can have, you know, an impact

16 on the overall test result and so here we are

17 basically proposing a way to kind of

18 standardize this testing.

19 This is something that the working

20 group looked into. They recommended that

21 PTACs and PTHPs using sleeves - used sleeves

22 with a standard depth of 14 inches during
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1 testing.

2 DOE also did some market research

3 on this item and the market research showed

4 that 14 inches is actually the most common

5 sleeve depth.

6 And so DOE's proposal is to add a

7 provision to the test procedure to require

8 testing using the wall sleeve with a depth of

9 14 inches or if, you know - or if, you know,

10 that option isn't there the - basically the

11 wall sleeve option is closest to 14 inches in

12 depth. 

13 And this is - we believe this is

14 consistent with the working group's

15 recommendation and, you know, this is another

16 item where we're interested in comment on.

17 MR. BROOKMAN: Rusty.

18 MR. THARP: Goodman Manufacturing. 

19 We fully support it.

20 MR. BROOKMAN: Thank you. AHRI?

21 MS. PETRILLO: AHRI fully supports

22 this.
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1 MR. BROOKMAN: Thank you, Laura. 

2 Okay.

3 MR. BURGOS: All right. Thank

4 you. We'll move on to the next one which is

5 filter requirement. Again, this is another

6 item that is also covered by the ASRAC working

7 group.

8 Much like wall sleeves,

9 manufacturers can have different types of

10 filters for a PTAC and you know there's

11 limited guidance right now as to which filter

12 that should be used.

13 The working group basically

14 discussed this issue and adopted the position

15 that units should be tested as shipped with

16 respect to selecting a filter option.

17 And so DOE is proposing to add a

18 provision to the test procedure to acquire

19 testing using a wall - require testing using

20 a standard or default filter option that's

21 shipped with most units, and for all those

22 that are shipped without a filter DOE is
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1 proposing to use an off-the-shelf MERV-3

2 filter for testing. And I guess that's not on

3 - what's on the slide so I can repeat that if

4 anyone needs to hear it. 

5 This is an item as well that we're

6 looking for feedback on both on the proposal

7 to use the standard or default filter or on

8 the off-the-shelf MERV-3 filter for units that

9 are shipped without one.

10 MR. BROOKMAN: Would you repeat

11 what's not on the slide? I didn't - I missed

12 that.

13 MS. ARMSTRONG: It's in the - it's

14 in the issue box. That's fine.

15 MR. BROOKMAN: Okay. 

16 MR. BURGOS: Yeah. 

17 MR. THARP: Rusty Tharp with

18 Goodman. Participated in the commercial

19 specification working group so we're in

20 support of these proposed changes.

21 MR. BROOKMAN: Okay. Thank you. 

22 Laura?
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1 MS. PETRILLO: Yes, also support.

2 MR. BROOKMAN: Thank you. 

3 MR. BURGOS: All right. Thank

4 you. So we'll move on to the next item. Now

5 we're going to get to a couple of items that

6 DOE considered but ultimately proposed no

7 changes for. 

8 The first one was the barometric

9 pressure correction. This is an adjustment

10 that's found in ASHRAE 16. The slide lists

11 some of the details of that adjustment,

12 basically consists of an allowance to upwardly

13 adjust the cooling capacity when the measured

14 barometric pressure is below standard

15 pressure. 

16 Ultimately, DOE requested comment

17 on this in the framework document but, you

18 know, we had not received any data supporting

19 or rejecting this. 

20 And so, you know, as it currently

21 stands DOE is not proposing to amend or remove

22 this provision. But we're also looking for
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1 comments and especially any data showing what

2 are, you know, any modification or revision

3 that may be needed. 

4 MR. BROOKMAN: Rusty.

5 MR. THARP: Ashley and the DOE

6 notes our position and that we think that

7 barometric pressure adjustments are a good

8 thing to have. So we support no changes.

9 MR. BROOKMAN: Okay. And AHRI?

10 MS. PETRILLO: Same.

11 MR. BROOKMAN: The same. Okay. 

12 No additional comment.

13 MR. BURGOS: All right. Thank

14 you. Javier Burgos. All right, looking at

15 part load metrics. DOE also received some

16 comments during the framework meeting for

17 considering the part load metric.

18 The current test procedure

19 basically only considers performance at full

20 load cooling or full load heating at capacity. 

21 DOE considered these comments and we requested

22 additional comments and data. 
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1 But right now we're unaware of any

2 data showing that PTACs and PTHPs spend time

3 operating in conditions other than full load

4 and this data is essential in order to create

5 a part load metric that will show, you know,

6 how much time is spent at different part

7 loading conditions which have been the way,

8 you know, to create a full - to create a final

9 metric. 

10 And so DOE is currently not

11 proposing to adopt either a part load or a

12 seasonal efficiency metric for the cooling

13 mode or for the heating mode. But, again, we

14 welcome any comments and as well, especially,

15 data.

16 MR. BROOKMAN: Rusty.

17 MR. THARP: Let Gary go first.

18 MR. FERNSTROM: This is Gary. 

19 I've already made my comments. Thank you.

20 MR. THARP: This is Rusty with

21 Goodman and presently I think our

22 psychrometric rooms, cal rooms are not
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1 designed such they can go to really cold

2 ambient. So we can't even do a 17 in our

3 existing rooms. 

4 So if something were to be changed

5 we would have to get three brand new rooms

6 and, you know, we like this steady state

7 efficiency task that we have today. It's

8 simple and there's not as many issues as we

9 have like with SEER and IEER. 

10 So we like the idea of maintaining

11 a steady state efficiency. However, we also

12 don't mind working to provide data where

13 possible. 

14 But our preference is to stay with

15 a single point metric as a regulated value and

16 then working with other stakeholders to find

17 out specific information that's needed and

18 provide that outside of a DOE mandate.

19 MR. BROOKMAN: Gary.

20 MR. FERNSTROM: We're okay with

21 the single metric but we would like to have

22 this additional data reported so we could have
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1 confidence in it. I don't know that it

2 necessarily has to be required if it is in

3 fact reported and validated voluntarily.

4 And I understand there is some low

5 cost space available in North Dakota and

6 they'd be happy to accommodate your equipment

7 and budget.

8 MR. BROOKMAN: Okay. Thank you.

9 MS. PETRILLO: Laura Petrillo,

10 AHRI. In the testing that DOE conducted did

11 you guys look into this at all or - no?

12 MR. FERNSTROM: This is Gary. The

13 reason is obvious. There's a significant

14 energy impact when you go to resistance

15 heating and there's some new equipment coming

16 on the market that has pretty good, very low

17 temperature performance. So we'd like to be

18 able to capture that effect and differentiate

19 between those types of equipment. Thank you.

20 MR. BROOKMAN: Thank you. 

21 MR. BURGOS: All right. Thank you

22 for those comments. 
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1 MS. ARMSTRONG: One - sorry,

2 Javier, to interrupt. One question for you. 

3 Is it more important to - if DOE were to

4 consider an optional test or potentially an

5 optional with a reporting requirement type

6 test, that's not something typically we do but

7 that seems to be my understanding of what

8 you're asking for. 

9 So if we were to consider

10 something like that what is your most

11 important other tests? Is it low ambient? Is

12 it high humidity? I mean, is it low humidity? 

13 High temp? Is it part load? Is it a

14 combination?

15 MR. FERNSTROM: Well, thank you. 

16 That's an excellent question. If I were to

17 have to rank them I would say the low

18 temperature performance going to electric

19 resistance is most important. 

20 The high ambient is second most

21 important and the part load is third most

22 important. Thank you.
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1 MR. BROOKMAN: Thank you. Laura?

2 MS. PETRILLO: I'd be happy to

3 take this back to the manufacturers and see

4 what we can start working on. You know, it

5 was everyone's opinion that, you know, a part

6 load metric wasn't really representative of

7 this type of equipment. 

8 But, you know, if there is a way

9 to differentiate the performance at low

10 temperatures, you know, I could see if they're

11 open to that. 

12 MR. FERNSTROM: And the only

13 reason we want it reported is to have the

14 credibility associated with information that's

15 reported to DOE.

16 MS. ARMSTRONG: Sure. And one

17 thing where I'm going to ask of you if you

18 could also take back to your working group

19 whenever they tee up their next session, I

20 know DOE and AHRI have been working closely as

21 well as with manufacturers and other

22 stakeholders, which we want to commit to
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1 continue to doing. 

2 Part load is something that DOE I

3 think is very interested in and I think I'll

4 agree with you right now. 

5 When we did some research and

6 looked into this a little bit - it may be

7 premature now but that is something that we

8 would like to bring up and maybe, you know,

9 ask AHRI's working group along with the

10 department to look into. 

11 So maybe it's primed for the next

12 time we look at this, if we don't do it this

13 time.

14 MS. PETRILLO: Thanks, Ashley. We

15 really appreciated the close work with the

16 department and would be happy to continue that

17 when it comes to these part load and low temp

18 conditions. 

19 MR. BROOKMAN: Thank you, Laura. 

20 Gary?

21 MR. FERNSTROM: So this is Gary. 

22 I'd just like to point out that next time is
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1 a long way away and I may not be attending

2 these meetings at that point.

3 MR. BROOKMAN: Oh, Gary, come on. 

4 We assume you're a lifer here. Come on. 

5 MR. BURGOS: Thank you for those

6 comments. Now we're - have sort of a couple

7 items left here that really aren't as

8 technical. 

9 One is discussion of the

10 compliance state. Currently, what we have in

11 NOPR DOE does not consider that these changes

12 would basically materially alter the energy

13 efficiency of the equipment but most of them

14 require sort of clarifications of the test

15 procedure. 

16 And because DOE is not considering

17 any changes to the effective date as they

18 relate to the publication date of the final

19 rule, you know, I think we've heard a couple

20 of comments on this already. But are there

21 any questions or comments on the compliance

22 date?
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1 MR. BROOKMAN: Rusty?

2 MR. THARP: Rusty Tharp with

3 Goodman. If there's changes to psych versus

4 cal testing it will definitely need a longer

5 time. Other than that -

6 MS. ARMSTRONG: You ready? So I

7 think we obviously we need to clarify what

8 this would require but if we were to adopt a

9 singular method and make a determination that

10 essentially the measured energy consumption -

11 the ratings do not change under our adoption,

12 that just means your ratings would have to

13 still be valid. And once the new procedure is

14 effected it would have to be used to generate

15 new ratings going forward, and if old readings

16 were no longer valid under the new method then

17 you would have to retest. 

18 But if they continue to be valid

19 you're okay. Does that - that should help

20 with your point.

21 MR. THARP: And I would, you know,

22 again, based on our measurements that there's
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1 not a significant difference I wouldn't be too

2 concerned. 

3 But depending on, you know, if the

4 existing products are grandfathered the

5 reality remains that there's still any new

6 stuff for us to go from doing most of our

7 cooling testing in the psych room to cal

8 testing. That means that would delay new

9 product production.

10 MS. ARMSTRONG: Sure. So this is

11 Ashley from DOE. I completely understand your

12 point with 16 versus the - allowing both. I

13 just wanted to clarify exactly what a

14 compliance - exactly what this would require.

15 MR. THARP: Thank you.

16 MR. BROOKMAN: Laura?

17 MS. PETRILLO: Laura Petrillo,

18 AHRI. Could we follow up on that question? 

19 So the test report requirements for products

20 that are already, you know, under compliance

21 in this - in the existing rule they don't have

22 to be resubmitted with, you know, to the new
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1 test procedure?

2 MS. ARMSTRONG: So it depends and

3 obviously this is something we will need to

4 clarify in the final rule depending on what

5 provisions actually get adopted.

6 But if DOE is to make a

7 determination that the measures of consumption

8 do not change, thus ratings would stay the

9 same more or less between the old procedure -

10 in other words, the proposals and/or

11 provisions that ultimately get adopted are

12 clarifications in nature, then as long as the

13 rating is still valid you're okay. 

14 Now, once the new proposal - once

15 the final rule test procedure is effect that

16 is the one that DOE will be using as well as

17 everyone else should be using going forward,

18 period. 

19 But if ratings are still valid

20 they could continue. So we will need to flesh

21 that out a little bit and obviously depending

22 on the comments and what we end up adopting in
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1 the final rule will have an impact on that. 

2 But we will definitely do that.

3 MS. PETRILLO: Thanks, Laura. I'd

4 be interested in hearing maybe some of the

5 department's determinations on that before the

6 comments are due. That may influence our

7 comments.

8 MS. ARMSTRONG: I mean - so this

9 is Ashley - I think what we have in there

10 right now is we believe everything that we've

11 proposed does not change the measures of

12 consumption based on the testing we had done

13 or some of the investigations. Some of these

14 things - it is my perception that they are

15 already being done. 

16 It's pretty common practice. So

17 that is our determination, that the ratings

18 should more or less stay the same. They would

19 continue to be valid.

20 MS. PETRILLO: Thank you.

21 MR. BURGOS: All right. Great. 

22 And so that's - Javier Burgos. At this point
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1 I'm going to hand it over to Ashley Armstrong

2 and she's going to take us home. 

3 MS. ARMSTRONG: So this is Ashley. 

4 Our final proposal that we put in the NOPR was

5 a verification and enforcement type proposal

6 around cooling capacity and why this is

7 important is because currently our product

8 classes in the standard are dependent upon

9 cooling capacity. 

10 And so what we've done here is

11 propose a method for utilizing rated cooling

12 capacity with an acknowledgment that cooling

13 capacity whenever a unit is tested and from

14 unit to unit may be slightly different.

15 We've proposed a method to ground

16 whether rated capacity is valid or not and

17 we've done that through - the proposal is 5

18 percent. If we test a unit basically and it's

19 within 5 percent of your rated we will be

20 going forward with rated. If it's not you

21 need to revise that rating. Okay?

22 MR. BROOKMAN: Laura?
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1 MS. PETRILLO: That's not a

2 two-sided tolerance, is it?

3 MS. ARMSTRONG: It's not a

4 two-sided, no.

5 MS. PETRILLO: Thank you.

6 MS. ARMSTRONG: Although I'm not

7 sure that we clarified that, though. I don't

8 think it's clear that that's - it's not. So

9 your point is well taken.

10 MS. PETRILLO: Thank you.

11 MR. BROOKMAN: Thank you. Rusty,

12 anything from you?

13 MR. THARP: No.

14 MS. ARMSTRONG: Do you support?

15 MR. THARP: That's what we live

16 with in AHRI today.

17 MS. ARMSTRONG: Okay. 

18 MS. PETRILLO: Until AHRI's.

19 MS. ARMSTRONG: Thank you.

20 MR. BROOKMAN: Thank you, Laura. 

21 Thank you, Rusty.

22 MS. ARMSTRONG: So just in
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1 closing, thank you guys all for coming. As I

2 said, this was going to be a fairly quick

3 meeting. But we appreciate everyone who

4 traveled as well as those participating on the

5 phone. 

6 Just a reminder, at the end of May

7 is when comment period deadline is. If you

8 have any issues - we've had some issues with

9 emails lately. We've been testing them out.

10 But if you wouldn't mind copying

11 myself or Ron we can make sure if there are

12 any issues that your comments get routed

13 appropriately. But otherwise thank you for

14 that and we look forward to getting your

15 comments and feedback.

16 MR. BROOKMAN: Final comment from

17 Gary Fernstrom and from anyone else who wishes

18 to make a final comment.

19 MR. FERNSTROM: So this is Gary. 

20 We have one remaining comment that wasn't

21 really on the agenda and that is we'd like to

22 observe the - we think there's some equipment
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1 now on the market that is of higher

2 performance than DOE considered in its max

3 tech evaluation.

4 And specifically that would be the

5 type of equipment that uses carbon dioxide as

6 a refrigerant gas, giving it a wider range of

7 performance.

8 So we'd encourage DOE to take a

9 quick look at that relative to their

10 assessment of max tech, and I'd like to thank

11 DOE and everybody for the collaborative nature

12 of this meeting.

13 MR. BROOKMAN: Thank you very

14 much. 

15 MS. PETRILLO: Thank you.

16 MR. BROOKMAN: Thank you. Thanks

17 to all of you and safe travels. 

18 (Whereupon, the above-entitled

19 meeting concluded at 9:56 a.m.)

20

21

22
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back 7:2,11 20:16

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9
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

65

Energy Conservation Standards for

Packaged Terminal A/C and Heat Pumps

US DOE

04-28-14

Washington, DC