2201 Dwyer Ave. ● Utica, NY 13501 ● Ph: 315-797-1310 ● Fax: 315-797-3762 ● E-Mail: info@ecrinternational.com ● Web: www.ecrinternational.com 

 March 26, 2013 

U.S. Department of Energy 

Building Technologies Program 

Test Procedure Waiver 

1000 Independence Avenue, SW, Mailstop EE-2J 

Washington, DC 20585-0121 

Dr. David Danielson 

Assistant Secretary for Conservation and Renewable Energy 

U.S. Department of Energy 

Forrestal Building 

1000 Independence Avenue, SW 

Washington, DC 20585-0121 

Re: Petition for Waiver and Application for Interim Waiver, ECR International, Inc.: Multi-Zone 

Unitary Small Air Conditioners and Heat Pumps 

Dear Dr. Danielson: 

ECR International, Inc. (“ECR”) respectfully submits this petition for waiver and application for 

interim waiver of the Department of Energy (“Department”) test procedures defined in 10 CFR 

430, Subpart B, Appendix M, which incorporate by reference the following third party standards: 

AHRI 210/240-2008, AHRI 1230-2010, and ASHRAE 41.2, on the grounds that the prescribed 

test procedures yield results that are unrepresentative of actual energy consumption for ECR’s 

Enviromaster International (“EMI”) line of multi-zone unitary small air conditioners and heat 

pumps. 

Company Background

ECR, with headquarters in Utica, New York, is a full-service provider of American engineered 

and manufactured boilers, water heaters, hydronic and forced air products at its facilities in Utica 

and Dunkirk, NY. ECR and its predecessor companies have been located in New York State 

since 1928 and employ a full-time workforce of |||||||. As a full-service provider of American 

engineered-and-manufactured hydronic and forced air products, ECR is recognized for its 

innovation, quality, performance and reliability, and is the only North American company to 

make and market all of these products under one corporate roof. Our products are sold under 

multiple brands in addition to EMI, including Airco, Argo, Dunkirk, Olsen, Pennco, RetroAire, and 

Utica. 

The Affected Products

The affected line of products—condensers serving the EMI brand of fixed speed multi-zone 

systems--subject to this petition and application are listed herein at Appendix A. The company’s 

unitary product line is AHRI-certified under both Unitary Small Air Conditioning (USAC) and 
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Unitary Small Heat Pumps (USHP) programs. The multi-zone products use the same models of 

compressors, indoor air handlers, reversing valves, accumulators, line sets, thermostats, tubing 

diameters, expansion valves, and indoor air handlers as the single-zone fixed-speed 13 SEER 

systems manufactured by ECR. While the multi-zone outdoor coil is physically different than the 

single-zone outdoor coil, it is comparable in performance per zone to its single-zone capacity 

counterpart. As such, the system/circuit performance was expected to be near identical to the 

single-zone performance. This belief was confirmed in ECR’s own psychrometric laboratory, i.e. 

that the multi-zone circuit-to-circuit metrics were nearly identical to the single-zone metrics. This 

relationship between the two systems, however, is not borne out through AHRI certification 

tests, where tests have rated the product as low as ||| |||||||||||. 

Overview

The test procedures currently being applied to the affected line of products are in fact 

inapplicable to those products, and therefore unrepresentative of the energy consumption 

characteristics of the products at issue, in the following ways: (1) they do not appropriately 

classify the applicable systems manufactured by ECR; (2) there is no authoritative standard that 

can be accurately applied to ECR’s products; (3) as a result of these factors, the current testing 

procedures do not produce consistent, accurate and repeatable data. ECR herein provides an 

alternative testing procedure for the affected products. 

1. The test procedures do not appropriately classify the applicable systems 

manufactured by ECR.

ECR’s fixed speed multi-zone systems are comprised of multiple independent refrigeration 

circuits sharing a single outdoor fan and defrost logic. Each circuit has a single fixed speed 

compressor, a single air handler, a single control circuit, with individual expansion, without any 

mixing of refrigerant between the zones. Each fully independent circuit can have different 

loading, cycle on and off independent of the other zones, as well as operate in different modes 

(heat/cool) simultaneously. The design is merely a collection of single-zone systems built into a 

common chassis to reduce the condenser footprint. As stated above, the multi-zone and singlezone systems manufactured by ECR utilize many of the same components. 

The current certification testing does not measure the loading of each individual circuit of the 

system. Under current test procedures, a multi-zone system consisting of 4 equal capacity 

circuits with 4 identical air handlers is logically expected to evenly distribute the total capacity at 

25% per zone. While this logic is valid for VRF- based multi-zone systems running all 

refrigerant through a single compressor, it is not applicable when evaluating multiple 

independent circuits. The test procedures do not verify the individual circuit performance, and 

instead only record the total. This results in an averaging of the individual circuits’ performance, 

whereas a summation of the individual circuits would be more representative of the true system 

performance. Without each circuit having individual performance data collected, it is impossible 

to assess the true performance of the test series after the fact, due to the lack of collected data. 

If the current test logic is not applicable to the simple 4 equal capacity circuit system, its use with 

the more complex unequal capacity circuitry system is even less so. 

ECR proposes that a fixed speed multi-zone system have data collected and reduced for each 

individual circuit, then perform a summation of the individual circuits to arrive at the total system 

performance. This method would require the collection of the data required to independently 

verify the system’s performance. The existing method of only recording the combined 

performance of the system doesn’t record the values needed to determine that all zones are 

operating within acceptable limits. The absence of the required detail data prevents any 
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analysis regarding what wasn’t correct in either the set-up of the equipment or the operation of 

the equipment itself. 

2. As a result of the differences between standards authorities discussed below, there 

are no approved standard procedures that apply to the product line of ECR at issue. 

ASHRAE 41.2, “Standard Methods for Laboratory Airflow Measurement”, does not address the 

measurement of multiple zero static airflow. Section 7.4 of same states that “each plenum shall 

have an adjustable restrictor (damper) located in the plane where the plenums enter the 

common duct section for the purpose of equalizing the static pressures in each plenum.” This 

ASHRAE requirement conflicts with the requirements in 10 CFR Part 430 Subpart B Appendix M 

§ 3.5.2 which states, “Do not use air dampers when conducting cyclic tests on non-ducted 

units.” 

Furthermore, the diagrams in ASHRAE 41.2, at figures 8A and 8B, do not consistently result in 

accurate static pressure values when applied to zero static equipment. The AHRI Ductless 

Equipment Section Engineering Committee recently voted to allow multiple zero static air 

handlers to discharge into a large cubic plenum without any gradual transitions, contradicting 

ASHRAE 41.2 figure 9, which shows a 15o converging transition and a 7o diverging transition. 

3. As a result of the lack of classification for ECR’s product and lack of standardization 

in testing for that product, ECR is subject to arbitrary and inconsistent testing practices 

for its product line. 

There are many “best practice” procedures available amongst the myriad of test laboratories, 

and these procedures have been implemented without input from ECR. Typically, these 

procedures are not published for peer review, and are inconsistent in the accuracy of results. 

The existing published procedures do not yield consistent, accurate, and repeatable data 

between different psychrometric laboratories. 

The primary error occurs when the laboratory tries to analogize the performance within a duct to 

the performance of a free discharge zero static blower and a second air handler is combined 

into a common enthalpy tunnel. When attempting to join multiple air handlers into a common 

duct, each air handler has an influence on the other air handler’s performance. Ideally, each air 

handler should have blower motor voltage, current, and angular velocity measured prior to the 

connection of a duct or transition piece. Upon connection of the duct, those same values should 

be attained as verification that the air moving device is working in a similar manner with the duct 

as it did without the duct. At that point, the location of the 0.0 inWC pressure tap can be 

located, starting at the ASHRAE 41.2 recommended standard (2*SQRT(A*B)). Different air 

handlers will have different locations for the zero static pressure point due to the differing air 

velocities at the discharge grill of the air handler. It is only by matching the motor’s electrical 

current draw and revolutions per minute between the free air delivery and ducted delivery that 

equivalent performance can be verified. An iterative approach is required in order to achieve an 

accurate, balanced air flow measurement. 

4. The following alternate procedures are proposed: 

A. Air Flow Measurement 
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1) With laboratory rooms at conditions for capacity tests, refrigeration circuits in operation, 

and free air operation (without ducts), measure and record the blower motor RPM, 

current, and power consumed by each indoor air handler running with a wet evaporator 

independently. 

2) Connect the duct between a single air handler and enthalpy tunnel. Restart the entire 

system and adjust the air flow until the now ducted blower motor has same RPM and 

current draw as seen in step 1. The static pressure tap can now be applied to that point 

on the duct that is actually operating at zero static via empirical methods. The point 

along the duct operating at zero static will vary proportionally with the discharge velocity 

of the air handler. 

3) Air flow should be measured only when the RPM and power of the blower while 

connected to a duct matches that of the motor when running without a duct. This 

ensures that the zero static air mover is acting equivalently to free discharge. The 

location of the pressure tap can be found for each air handler by locating the “0.0 inch 

water column” pressure along the duct, starting at the prescribed ASHRAE 41.2 distance 

of 2*SQRT(A*B) and then moving closer or further away from the air handler until the 0.0 

inch of water column point is located. Each type and capacity air handler will be slightly 

different due to the differences in discharge air velocity. 

4) Tangential wheel blowers do not generate static pressure well. The more common 

centrifugal blower can generate static pressures within a duct to damp the variations in 

the discharged air flow, while the tangential wheel can only vary the speed of the 

discharged air in response to ambient parameters. Or stated another way, Bernoulli’s 

equation has both the gravitational and pressure terms equal to zero in a zero static 

environment, leaving only the velocity term with a non-zero value and a very sensitive 

flow system. Any changes in static pressure must come from a change in air velocity, 

there is no other mechanism available. 

B. Establishment of actual system performance

1) Due to this condenser design being a collection of independent refrigeration circuits, the 

test methodology should evaluate individual systems and then sum the results of circuits 

to arrive at accurate performance metrics, instead of averaging the results without 

knowing the performance of each individual circuit. 

2) ECR’s proposed procedure would run all zones during the test, but measure the 

performance of each individual zone, one at a time. This method minimizes the errors of 

multiple combined zero static air handlers by ensuring that each circuit is operating 

properly prior to the collection of data and calculation of DOE metrics. The data 

recording and reduction shall not occur until there is certainty that each independent zone 

is operating at its correct individual performance. 

It should be noted that this product line has received waivers from the Department of Energy 

in the past, specifically for Limited Range Multi-Zone Heat Pumps. However, these waivers 

were rescinded due to the published test procedures becoming applicable to all unitary 

products. These waivers designated the condensers as “limited range” heat pumps to allow 

for their inability to defrost discrete zones. Controls were modified so as to allow individual 

zones to call for a defrost cycle thereby negating the need for a waiver. 

Interim Waiver

 ECR also requests that the Department provide immediate relief by grant of an interim 

waiver, for the following reasons: 
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 1. The petition for the waiver is likely to be granted. The Department has, as discussed 

above, granted waivers for the multi-zone product line, albeit with a result towards test 

procedures being granted for unitary products which cannot be easily analogized to the multizone product of ECR. ECR’s process furthers the goal of the Energy Conservation Policy Act, 

42 U.S.C. §6291 et seq., to provide consumers with accurate information regarding the energy 

conservation attributes of the product. 

 2. Substantial economic harm and competitive disadvantage will result absent a 

favorable determination on this application. ECR sells ||||||| multi-zone systems per year and 

has realized on average $|||||||||||||| in sales per year. However, it should be noted that multizone systems are usually a minor percentage of a larger order, used to solve limited condenser 

footprint challenges on site. The resulting economic impact is therefore closer to $||| ||||||||||| |||||| 

||||||||, or nearly |||||||| of total sales, in overall lost sales when an individual sale is contingent on 

multi-zone availability. Furthermore, sales of ECR’s remaining product lines will suffer without a 

multi-zone offering. As discussed above, ECR has a considerable history and economic impact 

in the communities in which it is located; Upstate New York, and Central and Western New York 

in particular, have suffered from decades of decline in the manufacturing sector. 

 The specific sales information in this section (2) should be exempt from mandatory public 

disclosure under the Freedom of Information Act, specifically 5 U.S.C.§552(b)(4). This 

information has not been made publicly available by ECR nor is it publicly available through 

alternative sources, and is typically proprietary to ECR and its competitors. Disclosure of this 

information would result in a substantial advantage to ECR’s competitors and therefore 

substantial harm to ECR’s competitive position. 

Conclusion

ECR requests that the Department grant both the waiver and interim waiver from the existing 

testing procedures as defined in 10 CFR 430, Subpart B, Appendix M and the third-party 

standards incorporated by reference in that regulation, and that the alternative testing 

procedures discussed above be adopted and approved as a representative test procedure for 

ECR. 

ECR would be pleased to discuss this waiver request with the Department and shall provide 

additional information as needed to the Department. 

ECR International shall file a statement with the Department certifying the names and address 

of each person to whom the notice of Petition for Waiver and Application for Interim Waiver has 

been sent. 

Very truly yours, 

Ronald J. Passafaro 

President and Chief Executive Officer 

ECR International, Inc. 
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Of counsel: 

Donald T. Ross 

Phillips Lytle LLP 

30 South Pearl Street, Suite P1 

Albany, New York 12207 

Phone: 518-472-1224 

Fax: 518-472-1227 

dross@phillipslytle.com
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APPENDIX A

The following condenser basic model numbers comprise the scope of this Petition for Waiver 

and Application for Interim Waiver, where each of the individual circuits of a multi-zone 

condenser can have one of three air handlers combined with it to obtain over 270 unique, 

complete systems. 

S2CG2200D, S2CG9200D, S2CG9900D, T2CG2400D, T2CG4400D, T2CG8800D, 

T2CG9800D, T3CG2220D, T3CG2240D, T3CG9920D, T3CG9980D, T3CG9990D, 

T4CG2222D, T4CG9922D, T4CG9992D, T4CG9999D, S2HH2200D, S2HH9200D, 

S2HH9900D, T2HG2400D, T2HG4400D, T2HG8800D, T2HG9800D, T3HG2220D, 

T3HG2240D, T3HG9920D, T3HG9980D, T3HG9990D, T4HG2222D, T4HG9922D, 

T4HG9992D, T4HG9999D