1

1 BEFORE THE 

2 UNITED STATES DEPARTMENT OF ENERGY 

3 

4 PUBLIC MEETING ON 

5 TEST PROCEDURES FOR RESIDENTIAL 

6 CENTRAL AIR CONDITIONERS AND HEAT PUMPS 

7 

8 TRANSCRIPT OF PROCEEDINGS 

9 

10 

11 

12 

13 

14 

15 11 June 2010 

Washington, D.C. USA 

16 ___________________________________________________ 

17 BUNN & ASSOCIATES 

Registered Professional Reporters Worldwide 

18 Post Office Box 297 

310 South Main Street 

19 Lusk, Wyoming 82225 USA 

20 In USA 1-800-435-2468 Worldwide 001-307-334-2423 

21 Worldwide Telefax 001-307-316-0388 

22 E-mail: BUNNWORLDWIDE@aol.com 

23 Copyright 2010 
 

 

 

2

1 ATTENDEES: 

2 DOUGLAS BROOKMAN 

Moderator 

3 

KARIM AMRANE 

4 Vice President 

5 

Regulatory and Research

Air-Conditioning, Heating and Refrigeration

Institute 

6 2111 Wilson Boulevard 

Suite 500 

7 Arlington, Virginia

USA 

22201-3001 

8 PH 703-600-0307 

FX 703-562-1942 

9 

10 

kamrane@ahrinet.org

WES ANDERSON 

11 

12 

13 

Technical Manager

Test Procedures for Central Air Conditioning and

Heat Pumps

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, D.C.

USA 

14 

TIMOTHY BALLO 

15 Associate Attorney

EarthJustice 

16 1625 Massachusetts Avenue NW 

Suite 702 

17 Washington, D.C.

USA 

20036 

18 PH 202-667-4500 

FX 202-667-2356 

19 

20 

tballo@earthjustice.org

JAMES CRAWFORD 

Trane 

21 3301 Pebblebrook Drive 

22 

Tyler, Texas

USA 

75707 

PH 903-509-7273 

23 
 

 

 

 

 

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1 ATTENDEES (Continued):

2 BRIAN P. DOUGHERTY 

Mechanical Engineer

3 Building and Fire Research Laboratory

U.S. Department of Commerce

4 National Institute of Standards and Technology

100 Bureau Drive 

5 MS 8632 Building 226 Room 304

Gaithersburg, Maryland 20899-8632 

6 USA 

PH 301-975-6396 

7 FX 307-975-5433 

brian.dougherty@nist.gov

8 

PAUL L. DOPPEL 

9 Director of Factory Liaison & Government Affairs

Mitsubishi Electric & Electronics USA, Inc. 

10 3400 Lawrenceville Suwanee Road 

Suwanee, Georgia 30024 

11 USA 

PH 678-376-2900 

12 pdoppel@hvac.mea.com

13 KATE HOUREN 

Natural Resources Defense Council 

14 1200 New York Avenue 

Suite 400 

15 Washington, D.C. 20005 

USA 

16 PH 202-5513-6267 

hourenk@gmail.com

17 

RICHARD KARNEY 

18 U.S. Department of Energy

Building Technologies Program

19 1000 Independence Avenue, SW

Washington, D.C.

20 USA 

21 

22 

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1 ATTENDEES (Continued):

2 DAVID L. KOESTERER 

Director of Engineering

3 Nordyne

8000 Phoenix Parkway

4 O'Fallon, Missouri 63368-3827 

USA 

5 PH 636-561-7482 

FX 636-561-7393 

6 koestererd@nordyne.com

7 JOANNA MAUER 

Technical Advocacy Coordinator

8 Appliance Standards Awareness project

529 Fourteenth Street NW 

9 Suite 600 

Washington, D.C. 20045

10 USA 

PH 202-507-4034 

11 jmauer@standardsASAP.org

12 MOLLY TRUMBLEY-McCANN 

Project Manager

13 Energy Solutions

1610 Harrison Street 

14 Oakland, California 94612 

USA 

15 PH 510-482-4420 x 239 

FX 510-482-4421 

16 mmccann@energy-solution.com

17 JEFFREY N. NICHOLS 

Director 

18 Engineering & Advanced Technology

Heat Pump Products Building Efficiency

19 Johnson Controls 

Post Office Box 19014 

20 3110 North Mead 

Wichita, Kansas 67204-9014 

21 USA 

PH 316-832-6577 

22 FX 316-832-6598 

jeffrey.n.nichols@jci.com 

23 
 

 

 

 

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1 ATTENDEES (Continued):

2 GRAHAM B. PARKER 

Senior Staff engineer

3 Technology Planning & Deployment

Pacific Northwest National Laboratory

4 902 Battelle Boulevard 

Post Office Box 999 

5 NSIN K6-05 

Richland, Washington 99352 

6 USA 

PH 509-375-3805 

7 FX 509-372-4370 

graham.parker@pnl.gov

8 

MICHAEL RAYMOND 

9 U.S. Department of Energy

1000 Independence Avenue, SW

10 Washington, D.C.

USA 

11 PH 202-586-9611 

michael-raymond@ee.doe.gov

12 

HARVEY SACHS 

13 Senior Fellow 

Buildings Program

14 American Council for an Energy Efficient Economy

529 Fourteenth Street, NW 

15 Suite 600 

Washington, D.C. 20045 

16 USA 

PH 202-507-4014 

17 FX 202-429-2248 

hsachs@aceee.org

18 

JANE E. SIDEBOTTOM 

19 President 

Applied Marketing Knowledge, LLC

20 6404 Orchid Hill Place 

Louisville, Kentucky 40207 

21 USA 

CL 502-759-9760 

22 JSidebottom@amk-llc.com 

23 
 

 

 

 

 

 

 

 

 

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1 ATTENDEES (Continued): 

2 COLLIN WEBER 

Navigant Consulting 

3 PH 202-973-2400 

collin.weber@navigantconsulting.com 

4 

JENNIFER L. WILLIAMSON 

5 Associate Engineer 

Technology Planning & Deployment 

6 Pacific Northwest National Laboratory 

902 Battelle Boulevard 

7 Post Office Box 999 

NSIN K6-05 

8 Richland, Washington 99352 

USA 

9 PH 509-372-4168 

FX 509-372-4370 

10 jennifer.williamson@pnl.gov 

11 MICHAEL WOODFORD 

Air-Conditioning, Heating, and Refrigeration 

12 Institute 

2111 Wilson Boulevard 

13 Suite 500 

Arlington, Virginia 

14 USA 

PH 703-841-8331 

15 FX 703-528-3816 

mwoodford@ahrinet.org 

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7

1 I N D E X 

Page 

2 

WELCOME, INTRODUCTIONS AND AGENDA REVIEW 8 

3 By Doug Brookman 

4 INTERESTED PARTIES STATEMENTS 

By Doug Brookman 

5 

TEST PROCEDURE HISTORY 14 

6 By Wes Anderson 

7 SCOPE OF TEST PROCEDURE REVISIONS 16 

By Brian Dougherty 

8 

PROPOSED REVISIONS SET Nbr. 1 18 

9 By Brian Dougherty 

10 PROPOSED REVISIONS SET Nbr. 2 120 

By Brian Dougherty 

11 

RULEMAKING SCHEDULE AND IMPACT ON MANUFACTURERS 194 

12 By Jennifer Williamson 

13 SUMMARY AND NEXT STEPS 207 

By Wes Anderson 

14 

QUESTIONS & COMMENTS AND CLOSING REMARKS 199 

15 By Doug Brookman 

16 ADJOURNMENT 209 

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8

 BEFORE THE 

UNITED STATES DEPARTMENT OF ENERGY 

PUBLIC MEETING ON 

TEST PROCEDURES FOR RESIDENTIAL 

CENTRAL AIR CONDITIONERS AND HEAT PUMPS 

TRANSCRIPT OF PROCEEDINGS 

Public Meeting was held pursuant to 

Notice at the Conference Room 8E-089, U.S. 

Department of Energy, 1000 Independence Avenue, SW, 

Washington, D.C., 20585, USA, commencing on the 

11th day of June, 2010, at 9:00 a.m. ET. 

MR. BROOKMAN: Good morning, everyone, 

and welcome. This is U. S. Department of Energy 

Public Meeting on Test Procedures for Residential 

Central Air Conditioners and Heat Pumps. 

We're going to start off this morning 

with welcoming remarks from Rich Karney. 

MR. KARNEY: Thank you, Doug. 

I know some of you. Some of you are new 

acquaintances. 

My name's Richard Karney. I'm with the 

U.S. Department of Energy's Building Technologies 

Program. 
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 Those of you who know me in the past, I 

used to run the ENERGY STAR Department for the 

Department with the portions of the products we 

managed. We no longer manage any products for 

ENERGY STAR, so my duties have shifted to being in 

charge of verification tests and, for ENERGY STAR, 

and with the additional duties of also leading up 

the Test Procedure Team out of the Regulatory 

Branch of the Buildings Technology Program. 

And I'm here to welcome you. I've gone 

through the presentation. 

Looks like it will be a very interesting 

discussion this morning. And one thing I would 

just like to, to put out is that the Consent Decree 

will, will not be discussed today. 

That's not part of the Agenda. We are 

to be concentrating on the test procedure itself. 

So, with that, I'd like to introduce Wes 

Anderson, our Technical Manager for the Test 

Procedures For Central Air Conditioning and Heat 

Pumps. 

MR. ANDERSON: Doug, if you want to go 

ahead and start? 
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 MR. BROOKMAN: Great. 

I know Wes has some substantive 

presentation, so we'll do the introductions first. 

It's our tradition to provide each person an 

opportunity to just introduce him- or herself. 

Everyone, please state your name and 

affiliation. I'll go around the room. 

Those of you sitting at the table, this 

will, will be recorded. And the little green LED 

light's got to be on. 

But, everybody else, we know you're 

here. You registered, so there will be a record of 

your presence here. 

Name and organization. 

(Whereupon, self-introductions were made 

as are reflected on the Attendees Page, after which 

the following occurred:) 

MR. BROOKMAN: Thanks for, everyone, for 

being here, giving us an opportunity to start on 

time. Well, I'm going to do a very brief agenda 

review, and you can, you can -- I think all of you 

received a packet as you registered downstairs at 

the Registration Desk. 
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 In the packet is not only an Agenda, but 

the PowerPoint slides which will be the focus of 

both the presentation and an opportunity for 

discussion and comment as the day goes on. 

Immediately following this agenda review 

there is an opportunity for anyone that wishes to 

do so to make brief summary remarks, brief opening 

remarks about the issues that may be of concern to 

you and your interests. 

Following that we're going to have some 

test procedure history from Wes, and then going 

straight on to scope of test procedure revisions, 

and then proposed revisions, the first set, as 

listed in the Agenda. 

We'll take a break midmorning, around 

about 11:00 or so, and then the proposed second set 

of revisions after the midmorning break. And then 

following that, rulemaking schedule and impact on 

manufacturers, and a summary and description of 

next steps. 

There is another opportunity at the end 

of the day for anybody to raise any additional 

issues they don't think have been covered 
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 sufficiently. So, that's the way we'll do it. 

The way the Agenda reads, we intend to 

be, to be out of here at 12:30. We'll see how well 

that works. 

Try our best to stay on time and, and be 

efficient in the use of our time. 

Questions and comments about the Agenda? 

(Whereupon, no response was had.) 

MR. BROOKMAN: I'd ask your 

consideration, what has emerged as, I think, common 

courtesy in these meetings. Please speak one at a 

time. 

Please say your name for the Reporter. 

You don't need to say your organization, 

affiliation each time; your name will be 

sufficient. 

We'll -- There will be a complete 

Transcript of this meeting available and posted on 

the web site. More information on that later. 

I'm going to be calling people as best I 

can by name to speak. Also, wish to encourage 

follow-on comments. 

Sometimes that's very useful for the 
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 Department to hear the, the ebb and flow. And 

please keep the focus here. 

If you'd turn your cell phones on 

"silent" mode and limit the sidebar conversations, 

that will be helpful. And if you could, please be 

concise. 

Share the air time. There's a lot to be 

said in this short span of time today. 

Questions and comments before we 

proceed? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Great. Let's have --

Let's have opening remarks, issues that people wish 

to raise here at the outset. 

(Whereupon, no response was had.) 

MR. BROOKMAN: No opening remarks? Is 

everybody bored? 

Okay, Harvey. 

DR. SACHS: Okay. I want to welcome Jim 

Crawford back to the group. 

MR. BROOKMAN: Thank you. 

MR. CRAWFORD: I won't rebut that. I 

feel glad to be here. 
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 MR. BROOKMAN: Okay. So, then let's 

proceed. 

Wes Anderson. 

MR. ANDERSON: Morning again. My name 

is Wes Anderson, and just some housekeeping points 

I want to go over. 

All correspondence should have these 

three bulleted items in it so it can make sure we 

get to see it: The regulatory identification, 

Energy Conservation Test Procedure for Residential 

Central Air Conditioners and Heat Pumps; the Docket 

Number, EERE-2009-BT-TP-0004; and title, Regulatory 

Identification Number, or RIN, 1904-AB94. 

You can submit your comments also by 

using the Federal Rulemaking Portal at 

http://www.regulations.gov, or e-mail to the e-mail 

address posted here, and post mailed through the 

Mail Stop EE-2J. Or, for human courier, to 950 

L'Enfant Plaza. 

Please note that the comment period 

closes August sixteenth, 2010. And this is the 

reiteration of what Rich said earlier. 

DOE is aware and, and evaluating the 
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 Consensus Agreement. DOE is also aware of the 

interested parties' desire to address issues 

related to the Agreement, and we will make our 

determination at a later time on that Agreement. 

Therefore, please limit your comments 

and questions today to the issues related to the 

test procedure. You may submit further concerns 

related to the Agreement and other relevant issues 

in your written comments. 

Okay, we did the, we did opening 

remarks. After the test -- Now for the 

test-procedure history. 

The Final Rule for, was published in 

October, 2007, and the purpose for that Final Rule 

for the test procedure for central ACs, residential 

central ACs was to expand coverage such as the 

small-duct high-velocity, multi-split systems; to 

address minor updates; and to improve the 

complementary sections to, of the CFR for testing 

requirements and rating options. 

No changes that affected the SEER and 

HSPF, and we've addressed some minimally compliant 

units. 
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 Expectation was to, for the test 

procedure was to address all adequate, address 

adequately all foreseeable future issues. 

Unfortunately, -- Well, not 

unfortunately, but fortunately, the EISA came out 

and, in December, which required us to address up 

to two regional standards, and to, on, on top of 

the national standard, and to account for a standby 

and off-mode energy consumption. 

DOE concludes that a test procedure 

rulemaking is merited to assume, to assure 

compliance with EISA and to consider a few non-EISA 

test procedure updates. 

So, we'll take an opportunity to address 

some of, additional concerns that came up after the 

publication in October. 

Now it's time for Brian Dougherty, from 

NIST. 

SCOPE OF TEST PROCEDURE REVISIONS 

MR. DOUGHERTY: Thank you, Wes. 

So, today we're going to look at the 

scope of the test procedure revisions in two sets, 

as was introduced earlier. The first set includes 
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 the types of, of multi-splits. 

We're also going to look into some 

issues tied to laboratory installation provisions; 

next, on the test tolerances and in-situ 

calibration in two areas. 

First one, test tolerances with regard 

to the indoor air flow and with regard to the 

calibration that impacts the cyclic degradation. 

We also wish to address the two Waivers that came 

in from that Final Rule that was completed in 

October, 2007, one having to do with the 

application of uses of multiple indoor blower 

units; the second having to do with what is termed 

here a triple-capacity northern-climate heat pump. 

Offer a few other additional 

miscellaneous items, and that will complete Set 1. 

And then after our break, we'll, we'll resume with 

Set 2. 

And Set 2 will look at more of the 

EISA-generated issues, the first one having to do 

with addressing standby/off-mode measurement 

requirements, and the measurement of that 

reporting. Touch on how potentially should the 
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 test procedure be affected by the need to 

complement the regional Standards, and then finally 

some related extras that come in part as, as, as a 

result of these actions, and also some admitted 

omissions that weren't in there that maybe we 

should yet try to grab. 

PROPOSED REVISIONS SET Nbr. 1: 

MR. DOUGHERTY: Okay, so let's just 

start with this Proposed Set Number 1. And they 

are partitioned in a way that this, this first set 

would be ones that would not affect the SDHV. 

They could be introduced in the near 

term, would not require retests, and we could just 

move forward on them immediately. 

The second set would be timed to occur 

to become the same as Standards, so it would be out 

into the future time, potentially 2016. And so it 

would be timed to occur then, and so that's why 

they're partitioned the way they are. 

Okay, the first one, let's talk about 

multi-splits. 

MR. DEPPEL: Thank you. 

MR. DOUGHERTY: The first one has to do 
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 with the definition of "Tested Combination." This 

occurs in the test procedure currently, and follows 

the publication in 2007. 

Industry noted that there are several 

changes they would still like to see in that 

definition; three, in particular. Two were, in 

fact, proposed in this rulemaking. 

The first had to do with the definition 

of "capacity" to clearly delineate that any 

recommendations to capacity mean the nominal value. 

In matching indoor to outdoor, they'll slightly 

broaden the indoor combinations that qualify. 

Examples had to do with nominal values 

not measured, and they were associated with cooling 

performance, not heating. 

So, there was an effort in there to be 

clear that in trying to evaluate whether or not 

your particular indoor combination meets the 

definition that's needed for testing, to show that, 

yes, we're talking about cooling; we're talking 

about nominal values. 

MR. BROOKMAN: Slow down just a little 

bit. Just a little bit. 
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 MR. DOUGHERTY: Okay. And any time 

someone wants to --

MR. BROOKMAN: Yeah. You're covering a 

lot of content here. I want it --

MR. DOUGHERTY: Okay. Sorry. 

The second item had to do with the fact 

that when you test minimum external statics for 

multi-splits, there's a requirement there as to the 

matching of the outdoor unit's capacity to the 

cumulative capacity of the indoor unit. 

And the, the criterion in there now was 

that you had to be within a certain bracket. And 

the thing that we failed to do with that bracket 

was to cover more specific, the more typical cases 

where it would end up with these whole numbers of 

95 and 105 percent. 

So, there's an effort there to clearly 

say that you can hit those and it's acceptable 

combination. 

And there's also a stipulation, we 

realize, for smaller-tonnage units. There's cases 

where you may feel you didn't meet that bracket. 

So, there's caveats that that can be 
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 waived if, in fact, you cannot meet that because 

you don't have combinations that will allow you to 

do so. 

The final item that was proposed but was 

not, was, we received feedback on but was not 

proposed in this NOPR was to address the case of 

commercial systems, specifically allowing more 

indoor units to be at the high end used to make up 

this match. 

Because this test procedure is limited 

to residential, less than 65,000 BTUs per hour, the 

DOE has chosen not to address that in this 

rulemaking. We'll have to address that with some 

other mechanism, but not use this as a means for 

addressing commercial. 

MR. BROOKMAN: Paul? 

MR. DOPPEL: Paul Doppel, Mitsubishi. 

One thing we've done with the HR&I 1230 

Standard approved last year was to incorporate 

multi-split systems, no matter what size, into that 

1230 Standard. So, we're -- It's kind of 

differentiating between HRI Standard 210, 240, to 

bring all the multi-splits into one. 
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 And I notice that has not been addressed 

in this rulemaking, and just bring that up for 

consideration. We're going to put that in our 

comments, written comments later, but I just wanted 

to make sure that that was noted. 

And the Engineering Committee from the 

Ductless Engineering Committee will be putting some 

comments forth on that, also. 

DR. AMRANE: I have a question for, for 

Brian. Yes, I know it's to follow this, these 

proceedings for the commercial products, but we 

have not, as 90.1 has now a category for VRF and 

represents HRI 1230 as the test procedure. 

And I guess I'd like to urge DOE to, to 

look at that and, and try to establish a better 

test procedure for VRA system for commercial for 

about 1,000 BTUs. 

MR. BROOKMAN: Okay. Thank you. 

Other comments at this point? 

MR. DOUGHERTY: The next issue with 

regard to multi-split systems was the comment that 

they are ducted multi-split systems, although, 

although the majority tend to be nonducted. 
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 But, in ducted systems, as it came out 

of the Final Rule, 2007, they would be subject to 

the same minimal external static requirements that 

are applied to conventionally ducted systems. 

And the, the, the response there was 

that typically these duct systems would be much 

shorter in length, and often the systems wouldn't 

be rated anywhere near these minimum statics that 

would be applied to conventional systems. 

So, the proposal that came forward was 

to allow them to be tested at the rated external 

static. 

I'm going in the wrong direction. Get 

me back. 

MR. ANDERSON: The "up" arrow. 

MR. DOUGHERTY: Oh, shoot. Start this 

before. 

MR. ANDERSON: Fifteen. 

MR. DOUGHERTY: Fifteen? Thank you. 

MR. ANDERSON: Fifteen. 

MR. DOUGHERTY: Look here, just to make 

sure. Okay. 

Sorry about that. Okay. 
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 And as far as the, the proposal that's 

in the test procedure specific to multi-splits, 

ducted multi-splits is an additional question that 

came into the NOPR Preamble, is if it applied for 

multi-splits, should it be considered for other 

systems that potentially had a comparative? 

And so the two that would come out of 

here are in the case of a ducted mini-split, and 

also potentially the furred-down ceiling-mounted 

units that you would see in a space where you have, 

the unit would tend to be, be in a joist space, and 

so constrained as far as its size, but nevertheless 

have a short duct to supply that indoor unit. 

In the test procedure, what, the numbers 

that are recommended, let's start with what's in 

there now. What's in there now is a category for 

small-duct high-velocity that was imposed last 

rulemaking. 

And as always, the ones for the others 

have been there since the start of the procedure. 

And the proposal here is, rather than to go with a 

rated value that the manufacturer specifies, let's 

do as we do with the conventional systems and 
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 specify a hard number that you have to equal or 

exceed in order to constitute a valid testing, a 

valid setup. 

And so the numbers there are ones that, 

in trying to proportion things, given the fact that 

the, the ducted systems are at these values, what 

may be a ducted system associated with that, and 

then compare that to the relative ratio: 

Potentially, what will you see with the 

multi-split to come up with these hard numbers? 

So, these certainly are subject to change, but 

there's an effort here to have things treated in a 

similar fashion, but yet recognize the fact that 

these systems would have less ductwork to overcome, 

and so should be subject to lower minimals. 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs, AC-triple-E. 

I think a number of us would greatly 

value an effort by the Department to give a 

justification for the existing values for, quote, 

"all other systems." 

The empirical evidence from field 

studies of both new and existing systems is neither 
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 credence to having ESPs staged by capacity, nor for 

values anywhere near this range. They tend to be 

substantially higher. 

I think this is an important issue as 

you're getting into the revision of the test 

procedure, and look forward to the revision 

including a justification for these particular 

values. 

MR. BROOKMAN: Okay. 

Yes, Paul. 

MR. DOPPEL: Paul Doppel, Mitsubishi. 

I think the proposal that we sent 

forward for the ducted mini-splits was, did not 

intend to include all the ducted mini-splits in 

that lower category because there are, there are a 

certain number of systems that have that short-run 

capability, but there are other systems that have a 

little bit longer. So, --

MR. DOUGHERTY: So, the, the, the -- As 

I recall the comment, that was typically they would 

be between .02 and .1, and that will --

MR. DOPPEL: Yeah. Yeah, there are 

some, there are some ducted models that do not 
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 produce a-tenth of external static pressure, so 

there was no way that they could be tested. 

And that was more the intent of, of our 

comment, was more: Cover those special systems, 

special ducted systems, rather than, you know, all 

of the ducted multi-splits. 

MR. DOUGHERTY: But, how do you 

differentiate "special"? Isn't there a potential 

there that everyone becomes special? 

And then comes the rated values. 

MR. DOPPEL: Well, it's within, it's 

within the manufacturer's capability. The way, the 

note we have that we put in the 1230, and also 

what's in the 1230 Standard, I think covers, covers 

that. 

MR. DOUGHERTY: Okay. 

MR. DOPPEL: We'll, we'll put some 

further comments in there, but we just didn't want 

to have -- I don't think we want to have the ducted 

portions of the multi-splits categorized in this in 

this way. 

MR. BROOKMAN: Where are we in these 

categories? I'm confused. 
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 MR. DOUGHERTY: They are subject to the 

red entries for external based on their nominal 

capacities. 

MR. DOPPEL: But, most of the ducted 

indoors with the multi-split systems would comply 

with the "all other systems." And then there are 

just, there are some that would fall in this 

"Other" category. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

Just to make the observation that with 

traditional systems, the flip side of what Harvey 

Sachs pointed out is that there is a tremendous 

diversity on the downside in terms of ducting. 

And we've all stayed in, in hotels, 

probably, that, that had the unit just above the 

entry. And some of those are one-on-one, simple, 

conventional systems with, you know, ducts that are 

12 to 18 inches long. 

So, there's -- For all these systems, 

there's a tremendous variety. 

MR. DOUGHERTY: Thank you. 

Okay. And throughout this presentation 
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 I'll reference questions with these yellow boxes, 

and differentiate the two based on the fact that in 

some cases at the end, well, in the case of the, 

the first box up here, at the end of the, the, the, 

the, the Notice of Proposed Rulemaking that was 

published on June second, there were 11 questions 

that were put together at the very end of it. 

And so some of those will be repeated 

here, but I'm, not in the same order that they 

appear in the written document. 

And then there's a separate set that we, 

as we developed this presentation, we thought, 

well, maybe we'll have people who want to ask those 

as well. So, the first one actually appeared as 

the, the 3. 

And it asked the question: Is a 

separate set of minimum external static pressures 

an acceptable way to address the testing of ducted 

multi-splits? 

And that's setting a hard value for 

them, as opposed to doing some other method, 

particularly letting them be specified by the 

manufacturer and testing at the rated value be the 
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 way to go forward with testing these products? 

That was the, the first question there. 

And I think it sounds like we have kind of covered 

that to a certain degree already. 

The second question was: Should we 

extend this coverage, whatever it might be, to 

other systems that have a short duct besides ducted 

multi-splits? 

Should we apply it to, in the case of 

ducted mini-splits or the furred-down 

ceiling-mounted units Jim was mentioning? 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Yeah, Jim Crawford. 

I'm a little bit confused here in that 

when I look at the details that are on that page, 

they weren't the same as what I've got in front of 

me, and specifically, the first item you referred 

to as Issue Number 3, and on the hard copy is 

referred to as Issue Number 2. 

And kind of wonder how many other 

differences there are. 

MR. BROOKMAN: It's the same question, 

though. 
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 MR. DOUGHERTY: Good point. And what 

happened here is there was an edit that occurred 

after the publication. 

So, you're right. 

MR. CRAWFORD: Where's Issue Number 2? 

MR. DOUGHERTY: It's a little later. 

Unfortunately, there were two Number 2s. 

MR. ANDERSON: This is Wes, at DOE. We 

made some changes at the last minute. 

It takes about three or four days to get 

the publication, get the publication of these 

copies done, given our resources. Please bear with 

us. 

When we find changes, we try to make it 

so that in the Public Meeting we address what we're 

trying to say. And so -- And the orders in the 

numbers for the NOPR issues are the numbers related 

to, as they were written in the Federal Register, 

but we chose to change the direction of the 

presentation. 

It seemed more logical to address it 

that way, as we have it here. So, please don't get 

confused by the numbers. 
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 Just focus on the questions. Thank you. 

MR. CRAWFORD: Assuming our comments 

deal with this morning's efforts in one way or 

another, how do we refer to that issue? Is it 

Issue Number 2, or Issue Number 3? 

MR. ANDERSON: This will drive the 

conversation, so it's, it's Issue Number 3, or 

Public Meeting Question Number 1. 

MR. CRAWFORD: Then could I request that 

we have a corrected copy? 

MR. ANDERSON: You'll have a corrected 

copy once it will go up on the web page. We'll put 

this presentation up on the web page after the 

public meeting. 

MR. BROOKMAN: We'll try and have it so 

our presenters call out the changes. 

Paul? 

MR. DOPPEL: Yeah. I just wanted to, to 

read out the statement that we had in this 1230 

procedure for these, the, the mini-splits. 

If the manufacturers' rated external 

static pressure is less than 0.1 inches water, then 

the indoor unit should be tested at that rate at 
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 external static pressure. 

MR. DOUGHERTY: And I guess my concern 

is: What would stop a manufacturer from saying 

their rated value is always less than that value? 

So, that's the concern. 

MR. BROOKMAN: Paul, you've got a, 

you've got a way to address that? 

MR. DOPPEL: We were essentially relying 

on the honesty and integrity of, of manufacturers 

in order to do that, but it, that could be easily 

said of the manufacturers in, in any, any of these 

tests. 

You know, manufacturer could provide any 

kind of documentation to alter what was presented 

in order to try to get around some of these test 

procedures. But, in these cases the intent is that 

these systems just do not have the cap- -- They, 

there's no way they can run at .1 static pressure. 

MR. BROOKMAN: Karim? 

DR. AMRANE: I think I understand your 

concern, Brian, and so that's the comments. 

MR. BROOKMAN: Okay. Harvey, you want 

in here? No? 
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 DR. SACHS: Okay. I'm too confused. 

MR. BROOKMAN: I'm glad I'm not the only 

one. 

DR. SACHS: Sorry. Harvey Sachs. 

I'd like a clarification. In our 

comments, rather than writing out each of the 

questions, are, is the request, Wes, that we use 

this numbering, the numbering in our handouts, or 

some other numbering? 

MR. ANDERSON: The numbering in this 

presentation matches the numbering in the Federal 

Register Notice, --

DR. SACHS: Okay. 

MR. ANDERSON: -- so use the 

presentation for, the Federal Register for the NOPR 

issues. 

MR. BROOKMAN: The stuff that's on the 

screen, that's, --

MR. DOUGHERTY: Correct. 

MR. BROOKMAN: -- that's the form --

MR. ANDERSON: That's the, the form; 

correct. 

MR. BROOKMAN: -- that you wish, that he 
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 wishes for you to follow in your comments. 

Molly? 

MS. TROMBLEY-McCANN: I just wanted to 

check in with the gentleman from Mitsubishi. 

So, for this special subsection of 

multi-splits that can't meet the Standard, are the 

proposed levels something that they could meet? 

MR. DOPPEL: Yeah. Those, those 

shouldn't be a problem. 

MS. TROMBLEY-McCANN: Okay. So, it's 

just a question of which multi-splits are assigned 

to those levels. 

MR. DOPPEL: (Nodded yes.) 

DR. SACHS: Number 3 is just a number. 

MR. BROOKMAN: Did we address both the 

questions? 

MR. DOUGHERTY: Yeah. 

Just to review, then, Question 1, that 

was not in the published document. It was a 

question whether or not we should apply, if, in 

fact, whatever comes forward to cover ducted 

multi-splits, should that be applied to ducted 

mini-splits and also the furred-down 
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 ceiling-mounted systems that we were talking about. 

And the asterisk there is just to try 

to -- The key thing here is always to try to define 

this category so it's fairly well-defined, and not 

something that can be potentially abused. And so 

the definition here is to say that indoor units 

that would fall in this furred-down category would 

be ones that were no more than 11 inches high, 

tall, no more than 24 inches deep. 

So, it's meant to fit between the joist 

space. And the single-split application, as far as 

the coil perpendicular to the flow stream and the 

rated capacity for the system doesn't exceed 

39,000. 

Now, maybe there is a split core, but I 

haven't seen it. And also, a capacity of 39,000. 

MR. DOPPEL: All of our coils would be 

splits. 

DR. SACHS: For furred-down? 

MR. DOPPEL: For all the --

MR. DOUGHERTY: For multi-splits, that's 

a different category. 

DR. SACHS: Different category. 
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 MR. BROOKMAN: Did you get that? 

MR. DOUGHERTY: What I'm familiar with 

as far as the furred-down, I've only seen a select 

few manufacturers that offer those. So, maybe 

they're more prevalent than I'm understanding. 

But, I'm thinking at least two 

manufacturers. I didn't know if it was a pervasive 

product or not. 

Can you answer that, Jim, as far as --

MR. BROOKMAN: The question I think was 

directed towards manufacturers. Can you, can you 

--

MR. DOPPEL: We don't, we don't 

manufacture those kinds of products. 

MR. BROOKMAN: Okay. Hang on just a 

second, Harvey. 

Is there -- State, state -- You -- Do 

you want to restate your question, or do you think 

you've gotten as much as you can get? 

MR. DOUGHERTY: Well, they're not 

particularly furred-down ceiling-mount units, 

because I've looked at two manufacturers that I'm 

familiar with that offer this product. Maybe I 
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 should be looking at others, because I've got a 

certain understanding of what the geometry is, but 

maybe I haven't looked at enough. 

So, I would be interested to know if 

there's more than two manufacturers out there that 

make this particular product. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

Are you referring simply to --

MR. DOUGHERTY: The indoor unit. 

MR. CRAWFORD: -- a cassette unit in 

the, in the ceiling? 

MR. DOUGHERTY: Usually sometimes has 

two side-by-side blowers using the slab. It's just 

a vertical slab, vertical --

MR. DOPPEL: He's talking a furred-down 

hotel room-type unit. 

MR. CRAWFORD: But, if I had a circular 

coil, I think that meets your definition. I don't 

think that's what you intend. 

MR. DOUGHERTY: No, and that's not what 

I intend. 

MR. CRAWFORD: The single slab, and the 
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MR. DOUGHERTY: Okay. So, it needs to 

be --

MR. CRAWFORD: And, you know, cassette 

units are, I, I believe, made by numerous 

manufacturers, and very common in Europe in 

commercial applications. 

MR. DOUGHERTY: Okay. Maybe I have to 

look at that. 

MR. BROOKMAN: Jim, would you suggest 

how the definition would be altered to --

MR. CRAWFORD: I'd defer to AHRI to 

define, to get together with, with Brian and come 

up with a definition. And one of the things --

When I go home I'm going to have to look at and try 

to figure out what the mini-split is as contrasted 

to a small traditional system. 

Where does it get "mini"? 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. 

I'm, I'm, I'm now confused about 

different issues. 

MR. DOUGHERTY: Okay. 
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 DR. SACHS: Are furred-down units as 

described here sold in the residential market as 

part of residential equipment? 

MR. BROOKMAN: Do we have any pictures? 

MR. DOUGHERTY: They were of capacity 

range that would have them covered by this test 

procedure. As far as a true residential system as 

a detached home, maybe not. 

But, I've certainly seen them in 

multi-family applications. 

DR. SACHS: Okay. Well, that's, that's 

helpful, and I appreciate it. 

And I certainly haven't done the 

calculations, but under, with, with, with air 

velocities characteristics of residential 

applications, can I get 39,000 BTUs out of a single 

unit that fits into an 11-by-24 perpendicular? 

MR. DOUGHERTY: I'll go back and look. 

I thought that was at the high end of what was 

available. 

DR. SACHS: It sounds very generous in 

terms of residential, and it was, sounds very 

generous in terms of the capacity that I would, in 
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 terms of residential zone that might be served by 

this equipment, which is basically an elaborate 

room air conditioner. 

So, I would think that we might all feel 

more comfortable with a substantially more 

restrictive definition if the furred-down units are 

actually sold in the residential sector. Thank 

you. 

MR. BROOKMAN: Thank you. I just want 

to check with the group. 

Do you have a clear understanding of 

what these units are and what the break points are, 

or is, is that understood now? 

(To Mr. Dougherty): Can you draw us a 

picture on a flip chart? 

MR. DOUGHERTY: I could try. 

MR. BROOKMAN: I'll get a pen. 

MR. ANDERSON: There's a --

MR. DOPPEL: Here. 

MR. BROOKMAN: Here. Here, use this 

one. 

I'm, I'm seeing a lot of confused looks 

around the room. That's the reason I, I'm doing 
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 this. 

MR. ANDERSON: This is Wes at DOE, Wes 

Anderson. 

Is the question about furred-down, or 

confusing with furred-down, or, and mini-splits, or 

is it just the furred-down units that you're 

questioning? 

DR. SACHS: Harvey Sachs. 

Wes, I take that as addressed to me, and 

I was thinking of it in terms of furred-down units 

in residential applications, whether they would be 

part of a multi-split system or single condensing 

unit, single evaporating unit. 

I'm just not familiar with the 

application. That's, that's my fault. 

MR. DOUGHERTY: So, I believe as far as 

on the return side there could be a duct prior to 

that before it gets to the blower, or the return 

could actually be right at the unit. But, 

basically the air is just brought in, and that, 

that, to generate over the coil. 

And maybe a short duct is to get it out 

to your drywall drop-down, and then that is, 
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 exhausts into the room. 

MR. BROOKMAN: That helped me. 

Karim, do you want --

DR. AMRANE: No. No. Fine. 

MR. DOUGHERTY: You're fine? Okay. 

MR. CRAWFORD: Relative to Harvey's --

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Jim Crawford. Sorry. 

Relative to Harvey's question, certainly 

you'd find this in hotels and residential, I 

believe, in these Regulations is defined bin 

capacity range, and by single-phase versus 

three-phase. 

And if we're talking about single-phase 

equipment under 65,000 BTUs per hour for the 

system, we're talking about residential, regardless 

of how it's applied. 

MR. DOUGHERTY: Good. Thank you. 

MR. BROOKMAN: That -- Thank you, Jim. 

Wes? 

MR. ANDERSON: This is Wes at DOE. I'd 

like to reiterate that about ten percent of the 

residential market is considered a commercial 
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 application, so it's --

MR. BROOKMAN: Okay. Thanks for drawing 

that diagram. It's good. 

Okay, are we all set? We're going to 

move on now. 

MR. DOUGHERTY: Okay, go to the 

laboratory installation provisions. And the first 

one here is a proposed adjustment in, as to how you 

set up your system, and particularly your indoor, 

indoor section, your indoor blower. 

Considering here the condition of 

fixed-speed motors and variable-speed constant 

torque motors, whether or not the proposal was to 

allow reducing the air volume rate by as much as 

ten percent below the rated value, your target 

value, if you're not at it, which we showed on the, 

on the previous table or two, before having to 

switch to the next-highest conversion, and 

therefore a higher power draw conversion. 

The second proposal was, was pointed out 

to us in making sure that although the next 

incremental change on particularly your dip 

switches may, may be the next one in line, that may 
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 actually be an alternative configuration as to your 

fan delay. 

So, just to, in addition there, whenever 

you make these incremental changes and you're 

forced to make these incremental changes in your 

fan configuration, that you do not change the 

blower delay. That is what, what is intended by 

the manufacturers for the rating purpose. 

So, the goal of this set-up test 

procedure is to produce repeatable setups, and 

ultimately, then, consistent ratings so if, if a 

particular model is tested one day by the 

manufacturer, and that same model's tested another 

time by an independent test laboratory, what you 

ultimately want to have is that configuration to be 

the same. 

You want the same dip-switch settings to 

be in place so that the, the power and the blowing 

characteristics of the unit are as similar as 

possible. 

Currently in the test procedure there is 

an allowance to reduce this air volume if, in fact, 

when you set up, you're not at the minimal static 
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 by as much as five percent to get to that minimal 

static. 

And so the idea now is, particularly now 

with the constant torques supporting the 

variability, might be greater, such that the five 

percent may be too slight. 

So, in looking at this, it, if we went 

from five percent to ten percent from a modeling, 

the effect appeared to have been you had a maximum 

on the high end as much as two percent degrees. 

And the implication of that is that 

although the DOE doesn't have a certification 

requirement associated with capacity, the industry 

certification process does. 

So, if, in fact, this is allowed, 

there's a chance of, more chance of a failure 

occurring as a part of that third-party 

certification process. 

And maybe if you're giving up as much as 

two percent from the get-go, and the tolerance is 

five percent, you're getting closer and closer to 

that, that borderline of potentially failing. So, 

that would be one of the implications of allowing 
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 this tolerance. 

The second thing is more from a DOE 

perspective, allowing us the seasonal descriptors 

SEER. 

Because that reduction in air volume 

would also have the reduction in power, the effect 

on SEER is less. It's more of four percent. 

So, the effect there wouldn't be as 

problematic as the effect on capacity is. So, --

But, ultimately the, the, the goal is to have the 

consistent configuration. 

And the concern, again, is that if you 

don't have the same configuration, the 

configuration at the next-highest speed would 

attach to a better HSCR than even this effect. 

So, the question then becomes, as 

identified in the fourth entry in your June second 

document, was: Will these proposed adjustments of 

five percent to ten percent allow, provide a more 

consistent setup, a more repeatable laboratory 

installation, and then ultimately more consistent 

rating guides of at least SEER and HSPF? 

MR. BROOKMAN: I see a few heads 
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 nodding, but we would like to make that verbal. 

Karim? 

DR. AMRANE: I guess the comments came 

from us, so we do support that. 

MR. BROOKMAN: Okay. Thank you. 

That's good for the Record. Department 

wants that. 

Other comments on the, this, the, the, 

identified as Issue Number 4? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: Okay, now changing now 

to the refrigerant charging procedure, I want to 

improve a few things. The first thing that's in 

the DOE test procedure, it doesn't cover certain 

cases. 

And one of the cases it does not cover 

is to give more guidance in the vent installation 

instruction, giving a range for a particular 

parameter. And in that case, the idea is to give 

more guidance in the mid-point as opposed to just 

the, the range. 

Another item that was pointed out 
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 through the AHRI was the fact that, well, as right 

now it's not explicitly covered, that you cannot 

change the refrigerant charge during the testing 

process. 

In general, let's hope that that would 

not happen, but to be definitive and explicit. 

There's a proposal to state just that: You can't 

have a certain charge for the cooling test and 

another area that, for heat tests. 

There's also a proposal to delete 

language allowing for the published installation 

and charging instructions to be, to be changed 

during the testing process and then revised based 

on whatever the manufacturer proposed to make a 

change during the testing process. 

This was something that came about in a 

previous rulemaking in that the DOE test procedure 

was seen as a potential vehicle for getting better 

information out there as to how to charge a system. 

Well, after further consideration by the 

industry members and DOE, we feel like this isn't 

the mechanism for doing that. You should test the 

unit according to the, the published installation 
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 instruction. 

And that's a little -- It's not 

something where this should be used as an 

opportunity to reevaluate whether or not those 

instructions are correct. 

So, the expected outcome is to remove 

potential loophole for adjusting the refrigerant 

charge during the testing process once it's set for 

that first test, stating that published 

installation/charging instruction cannot be 

overridden during DOE's testing. 

So, the option of using the DOE test 

mechanism as a mechanism for getting better 

charging done is now not encouraged, and overall 

it's just better alignment with the AHRI 

certification testing program. 

Before I go on to, would there be any 

questions or comments regarding the 

refrigerant-charging proposed changes? 

MR. BROOKMAN: No comments? No, no 

commitment? Or no --

DR. AMRANE: I guess as AHRI, we 

support. 
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 MR. BROOKMAN: Thank you, Karim. 

MR. DOUGHERTY: Going on now, 

installation, some clarifications with regard to 

the system setup procedure. And, and in this 

effort, it's mainly focused on the fact that the 

DOE testing is testing for certification purposes, 

at least comes at the very beginning of the 

product, actually before it's even, it's 

distributed for sale, as opposed to them saying 

that occurred thereafter, as in terms of 

certification or enforcement tests. 

So, there's an effort in the test 

procedure to better delineate these two cases. And 

to that end, the first one is that a manufacturer, 

if they choose to go to an outside entity and have 

them do the testing for initial DOE testing, that, 

in fact, they have the right in full for 

interacting with that entity just as if they were 

having it done in their own test facility. 

So, in this case, the application 

saying, no, it should be an interaction between the 

testing facility and the manufacturer, is waived 

because it's at the beginning and we wanted to 
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 treat them fairly whether or not they had the 

capability to go in-house or had to go outside to 

do that testing, and trying specifically to 

incorporate tests where DOE certification can be, 

often be done on preproduction and before the 

publication of the installation instructions. 

And those are not published with the 

units. They're actually not still finalized. 

So, it's something -- That issue is 

addressed. The obvious thing here is once they 

were finalized, they need to be what was ultimately 

used to do the test on that preproduction unit. 

So, the expected outcome here is to 

better differentiate between DOE initial 

certification tests and testing that's conducted 

thereafter, that there, in fact, there are 

installation instructions packaged with the unit. 

The unit is packaged. It's --

Everything -- It's a commercial entity that's being 

sold. 

It's not something that's still nearly 

at the end of its design process. 

Any questions or comments on these? 
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 MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. 

I certainly understand the, the logic to 

the proposed changes, but there's something 

philosophically troubling as well, that the end of 

the day these boxes are installed by human beings 

who do not interact with the manufacturer. 

At best, they will have been trained by 

a distributor. And in that context, the 

installation instructions, the set-up instructions 

are a key component of the product itself. 

And I'm not sure how to operationalize 

this, but I want to point out that there's a loss 

in the proposed change, as well. Thank you. 

MR. BROOKMAN: Jeff. 

MR. NICHOLS: The way I'd interpret 

this, I -- If it's a private testing lab that the 

manufacturer is using, it's, for all practical 

purposes, it's an extension of what we're doing. 

And the certification testing for DOE, 

the final DOE testing is part of the development 

process. And recat- is -- The literature's not 

going to be finalized until you finalize those 
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 tests. 

So, so, it's, it's almost impossible to 

have everything done. And when you're working to 

do that DOE certification, you're going to be 

pretty ruthless and make sure you have installation 

done the way it's intended to be done, even though 

it's in a third-party, private testing laboratory. 

DR. SACHS: Thanks, Jim. 

MR. BROOKMAN: Thank you. Okay. 

Are there comments on these issues? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: Changing now to test 

op-, test operating tolerances that apply to the 

air volume measurements, and also in-situ 

calibration efforts with regards to degradation 

tests, starting first on the air side. 

The issue is airflow test operating 

tolerances are usually exceeded if using electronic 

pressure transducers that are, that are of the 

higher sensitivity. Currently in the test 

procedure, and these are longstanding values, there 

was a test operating tolerance. 
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 Now, test operating tolerances during 

your test, a maximum minus the minimum value, that, 

that range cannot exceed these values. Vis-à-vis, 

in the case of the external static, that maximum 

range cannot exceed .05 inches. 

And as far as your pressure drop across 

your nozzles, that cannot exceed two percent of 

the, of the reading. These tolerances are, are, 

are, predate the DOE test procedure. 

They are something at least appear in 

ASHRAE Standard 37-78, and I suspect they actually 

precede that, that, that publication date. 

These tolerances are relatively easy to, 

to achieve when you use a liquid manometer to make 

the measurement because of the liquid's inherent 

damping characteristics. 

It can become a different story, 

however, with these high sensitive electronic 

pressure transducers, and more noticeable where you 

have a higher sample rate, and also where you have 

a variable-speed CMF blower where it's regulating 

during the tests. 

So, those test operating tolerances go 
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 in there in an effort to define a steady-state 

window in which to collect the data. 

So, as potential corrective actions that 

were considered by DOE, the first one is to just 

eliminate those two tolerances and use other 

metrics as a means for defining steady-state 

conditions. 

The second option would be, consider 

integrating the signal over time interval and, and 

calculating an average for that subinterval and 

using it for, as evaluating compliances with those 

test operating tolerances. 

The third option is to try to 

mechanically dampen the pressure in an effort to 

mimic a liquid manometer. And there are these 

things called pressure snubbers that seem to do 

that. 

And then, finally, the option would be 

to increase the magnitudes of these tolerances, 

given that this is what's happening. And the, the, 

the graph here shows a typical case of a system 

where you can see the fluctuations occurring; in 

this case are for the external static pressure. 
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 And they do exceed the .05 tolerance 

that exists currently. So, at this point in the, 

in the test procedure, because we lacked sufficient 

data to evaluate in particular the third option 

there, we went with the idea: 

Okay, let's, let's, let's consider the 

idea of, of, of wide-opening these tolerances. 

But, then, of course, the question becomes: At 

what point do they become ineffective in the 

practice of helping identifying a steady-state 

period? 

So, then the proposed numbers are going 

from .05 up to .12 as far as that maximum/minimum/ 

maximum variation, going from 2 percent overall as 

to that pressure difference across the nozzles, to 

as much as eight percent. 

And these are not plus or minus. These 

are the total, absolute values for the ranges. 

So, so, so, okay, so, so, so this item, 

then, there's a question in the NOPR identified as, 

as Number 5, and are greater tolerances the 

solution in terms of using electronic pressure 

transducers, because we certainly want to know that 
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 we have pressure, not having someone having to read 

that liquid manometer. 

So, in this case DOE's seeking comments 

on other actions as well as the one proposed. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: I didn't want to 

interrupt. This is not a technical point, but it's 

a, an, an important procedural point. 

In the Federal Register Notice, this 

actually, 37-78 is repeatedly referred to as, as an 

industry Standard. It is not. 

This is a consensus Standard of 

professional associations. And I don't know what 

the current composition of the committee is. 

Industry is always represented in the 

minority on an ASHRE Committee, and it's very 

common that employees of the Federal Government 

represent a significant percentage of the 

composition of ASHRE committees. 

So, that is an important distinction. 

And its consequence, don't know at the moment. 

But, I just -- It's something that needs 

to be kept in mind. 
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 MR. DOUGHERTY: Thank you, Jim. 

MR. BROOKMAN: Despite the fact that 

industry participates and it's considered a 

consensus Standard? 

MR. CRAWFORD: It is a consensus 

Standard. 

MR. BROOKMAN: And Industry 

participates? 

MR. CRAWFORD: And, and the participants 

all represent themselves as professional 

individuals. They do not represent their 

employers, --

MR. BROOKMAN: Got 'cha. 

MR. CRAWFORD: -- whether their 

employer's industrial or federal. 

MR. BROOKMAN: Harvey. 

DR. SACHS: Harvey Sachs. 

Indeed, they even let folks like me on 

them committees. That's not what I wanted to 

comment on, though. 

Brian, I'm just not clear. When I look 

at the graph on Slide 24 which shows a small number 

of outliers, -- It's the preceding slide. 
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 MR. DOUGHERTY: Yes. And I'm stuck 

here. 

DR. SACHS: Don't bother. I think we 

can all see it. 

But, it shows a reasonable distribution 

and a small number of outliers. 

Thank you. 

Somehow it seems to me that those, in 

this respect, not in others, wasn't broke. So, I'm 

not sure why we're trying to fix it. 

That -- Your Bullet Number 2, full 

signal integration, just seems like an aweful lot 

cleaner way that allows for the evolution beyond 

today's generation of sensors or anything else that 

happens in terms of preserving the relationship 

between the sensor and the test apparatus giving 

maximum flexibility. 

I need to understand why I would not 

prefer Option 2, the integration to broadening them 

to accommodate these few. 

MR. BROOKMAN: Meg? 

MS. WALTHNER: Meg Walthner, NRDC. 

I just wanted to agree with Harvey's 
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 comment. 

MR. BROOKMAN: Thank you. 

Karim? 

DR. AMRANE: I guess, of course, we 

checked with Interteck ourselves, but have you 

talked to them and --

MR. DOUGHERTY: It's their data. 

DR. AMRANE: It's their data. 

MR. NICHOLS: But, no. Jeff Nichols, 

Johnson Controls, wouldn't want to see the 

tolerance change. 

We would prefer something where you're 

taking an average. If you couple this change with 

the opening the air flow tolerance up, you're 

opening yourself up to too much. 

The variation gets too much. 

DR. SACHS: Harvey Sachs again. 

Just as a follow-up, I think there has 

to be a bound on integration, period. Clearly 

extreme. 

It can't be longer than the test 

interval. 

MR. DOUGHERTY: Right. Right. 
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 And, in fact, that's one of the keys, 

Harvey, we looked at. Seemed like one minute in 

some cases didn't get us back, and we took two 

minutes. 

Is there anything magical about two 

minutes? So, that, that, that, that's a key point. 

MR. BROOKMAN: Jeff, please. 

MR. NICHOLS: I think whatever, if you 

take an average, you want to maintain a -- Because 

a manufacturer may sample the minimal or they may 

sample a lot --

MR. DOUGHERTY: Correct. 

MR. NICHOLS: -- more than that, 

depending on their software and sampling rates. 

So, you want to leave them the ability to average 

it over and beyond what the minimal sample is. 

MR. BROOKMAN: Okay. Thank you. 

Are there comments on these test 

tolerances and these four options? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: Okay, now going to the 

effort to have an in-situ calibration. Need to 
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 reduce the measurement bias that's created when 

using two different sets of air-side temperature 

sensors between the steady-state test and the 

cyclic tests that are used in tandem to come up 

with your cyclic degradation coefficient. 

So, just as a review, you have that, 

these two companion tests. They come one right 

after the other; you know, the steady-state and 

cyclic. 

And as far as that C-, CD value, it is 

used in estimating a part load factor which is a 

ratio of the EER when, when cycling to the EER at 

steady state. 

So, the EER at steady state would 

reflect one set of temperature sensors used to get 

its capacity element, and the EER for steady state 

would be determined using the second set of 

temperature sensors. 

And why do you have this potential for 

two different temperature sensors? Well, the test 

procedure couple automatically to ASHRAE Standard 

41.1 which covers the temperature requirements. 

There's requirements associated with 
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 steady-state tests, and also for transient tests, 

and for steady-state tests there's more of a focus 

on accuracy, whereas for the transient test, of 

course, you have to also have lower time constants. 

So, you have to have the faster 

responding. So, there's some differing 

differential equations that are needed to meet 

those two different requirements, given end 

application. 

But, as applied here in the DOE test 

procedure, especially because it's used in a ratio 

form, it can have some impacts on the bias because 

you have two sets of temperature sensors, and 

ultimately you're never -- Well, not never, but 

unlikely. I don't think you're going to get those 

two just on their own to line up exactly when 

they're making a temperature-difference 

measurement. 

So, the proposal in the DOE test 

procedure is to offer a correction method where you 

measure that temperature difference using both sets 

of instrumentation during the steady-state test. 

Then you apply whatever ratio is 
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 determined from that steady, steady, steady-state 

test to create the Delta-T that's measured during 

the cyclic test that follows. 

So, you're getting them correlated 

during the steady-state test, and then you're using 

that correlation for your capacity correlation 

during your cyclic test. 

As far as this proposed temperature 

difference Delta-T correction process, it would be 

one, again, that you would measure the Delta-T 

during the steady-state test. 

And the proposal is to actually require 

that that measure be made at least every five 

minutes during the steady-state test, and that is a 

deviation from what's currently required. 

Currently the, you can sample everything as much as 

every ten minutes in the case of the Delta-T. 

So, we're asking that to be reduced in 

half so we get enough data at least during that 

30-minute interval. If you only test, you only 

tell us every five minutes, that will alter that 

Delta-T ratio that you calculate. 

And so from the measurements you make, 
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 you calculate the Delta-T for the steady-state 

sensors, a Delta-T for the cyclic sensors, and you 

would calculate then this ratio of Delta-Ts, and 

that would be used for the steady state. 

That's what would be used to correct the 

Delta-T measurement during the second test. And 

now to, to at least avoid the case where there's 

something terribly wrong with the system where you 

have this great deviation in the Delta-T 

measurements, placing a, a limit on how much they 

can differ from one another before you're forced to 

stop your test and figure out: 

"Well, I have two different sets of 

temperature sensors, and they're a degree, a degree 

apart. That's not acceptable. 

"There's something wrong somewhere. I 

need to figure out where this, this error occurs," 

and potentially have to do a recalibration of one 

or two sets of instrumentation. 

So, the proposal is to put a six-percent 

ratio on that that that can vary. So, the idea 

would be between .94, that Delta-T could vary from 

.94 and 1.06, and you could go forward. 
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 But, if you find that that ratio is 

beyond that range, you'd have to again stop and 

reevaluate why the two sets are so different in 

their measurement of the same temperature 

differences. 

And, and, and in an effort to avoid 

having to run a complete 30-minute test, we were 

trying to put limits on how short of interval could 

you run before you make that evaluation. 

"Am I good or not good?" just to save a 

little time in the, in the laboratory on, per se. 

And the idea is to say you have to have at least 

seven data samples. 

And that is if you make tests every five 

minutes, you'll get seven samples. But, you can't 

make seven samples in seven seconds. 

You have to have some minimal value to 

evaluate that, and we're putting a minimum of six 

minutes. So, we're saying you have to have at 

least seven samples, and you have to have checked 

those seven samples at least over a six-minutes or 

longer interval before you make this decision as to 

whether or not I'm going to go forward or not. 
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 So, at this point I'd welcome comments 

on this particular proposed effort. And I might 

point out here, although it is not part of the DOE 

test procedure currently, it is something that, 

that is being used as part of the AHRI series 

certification to evaluate their tests of the cyclic 

coefficient measurement. 

MR. BROOKMAN: Jeff. 

MR. NICHOLS: Brad, what's the maximum? 

If it's seven data points, the maximum interval, 

then I guess my mind is running short. 

MR. DOUGHERTY: But, as far as if you 

use six minutes, that would be the interval. 

MR. NICHOLS: Thirty minutes? 

MR. DOUGHERTY: The interval would be 

six minutes. If you were taking more than seven 

samples in six minutes, six minutes would be the 

limiting factor that you have. 

However many measurements you've made, 

you use all of them, they would be spaced at 

individual equal intervals. So, in most cases I 

think it would be six minutes for most 

manufacturers. 
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 I think most of you sample at least 

every minute, if not less, in this Delta-T measure. 

MR. NICHOLS: Okay, during, during the 

details, during the cyclical --

MR. DOUGHERTY: During the steady-state 

test, these measurements would occur. 

MR. NICHOLS: Okay. So, so, you're --

So, the current sampling rate required is, is what 

interval? 

MR. DOUGHERTY: Okay. Yeah. 

The -- You could, you could sample every 

five minutes, but you, as a program, then would 

have to go to 30 minutes before you made your 

evaluation of whether or not you met the six. 

MR. NICHOLS: But, the current, current 

sampling rate is what interval? 

MR. DOUGHERTY: At least every five 

minutes, if not more frequently. 

MR. NICHOLS: Yeah. Okay. 

MR. BROOKMAN: At least every five, if 

not more frequent. 

MR. DOUGHERTY: Right. If you prefer to 

make them every 30 seconds, that's okay, but to get 
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 seven measurements you have to go 30 minutes to get 

seven measurements; one at the beginning and then 

-- Well, it ends up being seven. 

Thirty divide by five and six, you've 

got the beginning and the end. 

MR. BROOKMAN: So, there's a lot of, of 

specificity here. What do you think? 

The Department's requesting comment on 

this proposed Delta-T correction. 

Jim Crawford. 

MR. CRAWFORD: Jim Crawford, Trane. 

I think that although there's a lot of 

specificity here, there are at least as many open 

questions as there are specifics. And I think 

people need to deliberate on this before coming 

back. 

MR. BROOKMAN: Okay. End with comments, 

then? 

Okay. Well, then there are additional 

questions you want to put to Brian at this point, 

or can we get some additional comments on what's 

being proposed here? 

Jeff, please. 
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 MR. NICHOLS: Conceptually I think it's, 

it's a good idea. I think we want to work through 

the mechanics of how you, you, you, you correlate. 

MR. BROOKMAN: Thank you. 

Paul, anything for you? 

MR. DOPPEL: (Nodded no.) 

MR. BROOKMAN: Nothing. Okay. 

Okay. Jim? 

MR. CRAWFORD: Jim Crawford. It's 

well-intentioned. 

MR. BROOKMAN: Thank you. Okay. 

MR. DOUGHERTY: Since the Final Rule of 

October of 2007, the Department -- I'm sorry. 

DR. SACHS: I'm -- It took me --

MR. BROOKMAN: Harvey? 

DR. SACHS: Harvey Sachs. 

It took me a while of how to think of a 

way to respond to Doug's comment that there's a lot 

of specificity here, and I want to phrase it in, as 

a question to Brian. 

My sense is that the intent of these is 

to make the testing process, the certification 

process more rational, more replicable, and it will 
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 not bias the results either up or down. 

If that's the, the sense of it, then I 

think for those of us in the advocacy community, if 

it's not going to lead to loop-holing and it's 

going to achieve these results, we're all in favor 

of them. 

MR. DOUGHERTY: It's meant to improve 

report repeatability. 

MR. BROOKMAN: Okay, thanks. 

Final comments on this? 

MR. DOUGHERTY: Since the last Final 

Rule in 2007, the Department of Energy has received 

two Waiver Requests for products that are, have 

features not currently covered as part of the test 

procedure. 

The first one that I'm referencing has 

to do with the case where the indoor blower unit 

has two cycles to the coil, but ultimately has 

multiple blowers used with that coil. And in 

August, 2008, DOE granted a waiver for a line of 

these such products as applied to the specific 

application as a single-speed heat pump outdoor 

unit and one two-capacity heat pump outdoor unit, 
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 and the case of where there's two separate 

single-speed heat pumps applied with this specific 

outdoor requirement. 

Because of the utilization of those 

commercially, the test procedure add-ons that are 

proposed are similar to what was granted in the 

Waiver. They're, they're basic, and it's minimum 

until we see how this progresses to understand 

whether or not this takes an industry and how it's 

applied. 

So, the scope and the waiver, as well as 

the test procedure, is to cover products where the 

indoor system has between two and eight indoor 

blowers, and, as I mentioned, either the single- or 

dual-circuited indoor, indoor coil. 

As far as simplifications, just looking 

at, at limited cases here. So, modelling on the 

indoor side mainly is a two-capacity system in the 

case of just looking at the, when half the blowers 

are on and when all the blowers are on, and not to 

look at other combinations that are possible there. 

And for two-stage system, for those 

cases where there's either a type of two 
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heat pump, in those cases we would define "minimum 

capacity" as occurring when half the blowers were 

on, and, and full capacity occurring when all 

blowers are on. 

So, at this, I, I, I'm going to package 

them together and assess as a group, as opposed to 

individually, if that's okay. 

MR. DOPPEL: Can I make a comment? 

MR. BROOKMAN: Paul? 

MR. DOPPEL: Paul Doppel. 

In a way, I'd like to sort of object to 

this because this is like a multi-split if it has 

two indoor coils, and multi-split systems are 

required to turn one indoor unit off at low speed. 

And so this is being treated 

differently, because both coils are allowed to 

remain active, unlike multi-splits. And that's one 

of the things that we, we, that we have proposed, 

change to the multi-split testing, which I was 

going to bring up later anyway. 

But, I just wanted to make that 

association with that, that this, this, this type 
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 of a system is being treated differently. 

MR. BROOKMAN: Can you say -- Maybe I 

missed it. How would you address -- How would --

what kind of fix that you would like to see? 

MR. DOPPEL: I think the testing 

procedure for the multi-split systems to allow all 

systems to operate at all times, all the indoor 

units to operate at all times. 

MR. BROOKMAN: Thank you. 

Do you want to follow on there, Brian? 

MR. DOUGHERTY: I don't know that we can 

mimic that same requirement for multi-split stuff 

because in this case you can't turn off -- There's 

only one indoor, one coil to turn off, and if you 

turn off, there's no capacity, whereas a 

multi-split, you can turn off one coil at a time. 

MR. DOPPEL: But, from what I saw on 

these systems, there should be a way to block 

refrigerant to one, and certainly turn off the 

blowers to one of the indoor sections. 

MR. DOUGHERTY: Well, we are -- We're 

turning off both blowers in some of, in some of 

these. 
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 MR. DOPPEL: But, both coils are 

working. 

MR. DOUGHERTY: The case of a dual-cycle 

circuit maybe you could, but in the case of a 

single circuit I don't know how you can do what you 

describe. 

MR. BROOKMAN: Well, operationally 

what's the common case? 

MR. DOPPEL: Well, for the multi-split 

systems, again, the testing is intended to look at 

operations at low conditions. But, in low 

conditions you don't turn off one indoor unit, 

because all areas would be calling for heating or 

cooling. 

So, -- But, the test requires one of the 

indoor units to be turned off, which inactivates a 

lot of the evaporator's surface, so you're losing 

capacity. 

MR. DOUGHERTY: With the multi-split 

test procedure there is a need for test data to 

evaluate the impacts of having, keeping, moderating 

where you have all units remain on. But, now you 

can modulate between maximum and minimum values. 
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 But, you do, in fact, turn off certain 

indoor units. So, in trying to capture those 

different features, the current test procedure 

does, at one test state you have to turn at least 

one of the indoor units off. 

But, there's, there's an opportunity 

here soon to provide some test data that may help 

you evaluate what is the best way for generating a 

performance map for a multi-system, and that's been 

lacking up to now. 

MR. BROOKMAN: Harvey. Pardon me. 

Jim Crawford. 

MR. CRAWFORD: Do we look that much 

alike? Yes. 

DR. SACHS: I resemble that. 

MR. CRAWFORD: The -- Are we talking 

about you're going to continue to have refrigerant 

flowing through the unit that is turned off? 

MR. DOUGHERTY: Well, --

MR. CRAWFORD: If so, it's going to ice 

up, is it not? 

MR. DOUGHERTY: Correct. And so, yeah, 

that's -- I don't see how to make the parallel 
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 condition occur that's proposed for multi-splits in 

this product. 

MR. BROOKMAN: No additional comments? 

Paul. 

MR. DOPPEL: No, I was just turning that 

mic off. 

MR. CRAWFORD: Jim Crawford again. 

I guess I would conclude from what you 

just said that you weren't really proposing a 

solution to the problem. 

The problem remains. It changes 

character. 

MR. BROOKMAN: Can you propose a 

solution to the problem? 

MR. CRAWFORD: Not my product. 

MR. DOUGHERTY: Well, I guess -- And, 

again, this product, to my knowledge, has not 

become a commercial entity at this point. In some 

ways maybe the expectations for doing that were 

overstated. 

But, regardless, in trying to cover this 

product, I don't know what the typical mode would 

be to, in fact, turn off a circuit. The unit would 
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 either have the refrigerant active, and if the 

refrigerant's flowing, the fan's got to be on, 

whereas when you have a multi-stage you can say, 

"Okay, that fan's going to be off." 

I don't think that's a capability for 

shutting and taking it to zero. It's a different 

base. 

I don't see how they correlate. 

DR. SACHS: Harvey Sachs. 

Brian, I'm hearing that so much lately 

that I'm wondering if it's premature to do a test 

procedure if we don't have a performance map. 

MR. DOUGHERTY: I think that's a 

justified comment, and I guess the question, maybe 

it's good to understand, too, in the waiver process 

that at one point is that appropriate to occur? 

Maybe in that case it's the, it's more 

to be on the front end of things as opposed to test 

procedures, to wait until you actually have an 

established product to make decisions on how to 

cover them. 

DR. SACHS: But, Brian, I have -- If I 

have a Waiver Request come in over the threshold, 
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 that would be accompanied with data. You'd 

certainly have the ability to ask for performance 

map in these conditions. 

MR. DOUGHERTY: Data's available on 

prototype units, but I haven't seen a commercial 

product offered. So, it's kind of vague. 

Test procedure options only come around 

every so often, so the timing's always: Should we 

try to grab it, or, now, or not? 

The Waiver goes in place and stays in 

place until the next time we have an opportunity to 

discuss it, and there is this, the next time the 

test procedure is up for revision, that there be a 

way to do away with that waiver so it's no longer 

on the books. 

MR. BOOKMAN: Karim? 

DR. AMRANE: Karim Amrane, AHRI. 

Maybe the best approach here, I don't 

know if there's no units on the market. The 

manufacturer has a Waiver. 

Let's wait and see how it goes. And 

maybe, yes, that would be, yes, sometime in the 

future we'll assess whether that should be brought 
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 into the test procedure or not. 

MR. BROOKMAN: Okay. Thank you. 

Yes, Jeff. 

MR. NICHOLS: I'm not familiar with the 

product, but is this, as opposed to having a 

multi-speed fan motor that turns the blower speeds 

down, is this several, just several blowers that's, 

that's modulating the air flow in the same fashion? 

MR. DOUGHERTY: Yes. And ultimately, 

potentially something, what would be the zoning 

feature that would be provided. 

But, being able to, for example, we have 

to switch. Four of the eight blowers would be on. 

MR. NICHOLS: So, a correlation to how 

multi-speed motors would be managed in this stage 

now would be the way to cover this? 

MR. DOUGHERTY: The current test covers 

the case where you would have a modulating -- You'd 

have a single with a modulating that may have two 

stages or more of air-volume change. And so this 

is modeled after that. 

MR. NICHOLS: Okay. 

MR. DOUGHERTY: Coverage of it is 
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 modeled after that. 

MR. BROOKMAN: Final comments of this 

segment? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: Okay. Another waiver 

was granted that affected a line of, a term here, 

triple-capacity northern-climate heat pumps. 

And so from February of this year, DOE 

granted an additional Waiver on a line of such 

products that offer three stages of compressor 

capacity modulation at heating, two stages when 

cooling. 

So, the, the features of this product 

would require changes to the current coverage for 

the heating seasonal performance factor, HSPF, but 

not for the SEER determination. 

The SEER test procedure currently covers 

the case of having two stages of, of capacity 

modulation and, and cooling. 

As far as what's in the Notice of 

Proposed Rulemaking, it is a little bit different 

in one sense from what was granted as part of that 
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83

 Decision and Order. 

So, what's proposed in the, in the, in 

the June second document is to additional testing 

to characterize the performance at this, the 

highest stage of heating capacity, this, this third 

stage of heating capacity. 

There is a new outdoor test condition 

currently in the DOE test procedure on the heating 

side. The test conditions as far as the dry bulb 

conditions are 62, 37, 35, and 17. 

The test procedures propose to use a 17 

test, but in addition, require an additional 

lower-temperature test. And in the NOPR what is 

proposed is a dry bulb temperature of two degrees 

Fahrenheit and a wet bulb temperature of 1 degrees 

Fahrenheit. 

And this does differ as far as the, the 

offset as opposed to what is in the, in, in the 

Waiver. In the Waiver, the manufacturer asks for 0 

degrees and minus two. 

The proposed change there is based on 

some feedback from laboratory tests that says a 

one-point depression is a whole lot easier to 
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 achieve than a two-point, two-degree depression. 

As far as the calculation side of 

things, the proposal is to define the heating load 

line based on the capacity at the second stage of 

heating at 47 degrees outdoor temperature, and this 

is consistent with their approach that's currently 

used for available speed conditions that have the 

capability of operating at a higher capacity during 

heating as opposed to cooling. 

So, if any of you dug into it, there's a 

nominal test when testing variable heat pumps. So, 

this would be similar to that in defining the 

building load line that's used in calculating the 

HSPF. 

As far as the calculations themselves, 

it's just an extension of what is in there now with 

regard to coverage to two-capacity systems. You 

just now have to consider a, a third step of 

modulation, and the algorithm does attempt to 

account for manufactured features that would say, 

"Okay, at certain outdoor temperature ranges I'm 

going to lock out certain capacity capabilities, as 

at the lowest temperatures. 
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85

 "For example, I may not let my system 

operate at, at the, at my lowest capacity, and 

likewise, at the more moderate temperatures I may 

not let my system operate at this, this highest 

capacity of, of, of operation." 

So, the, the question that was 

collective here on these Waiver-covered products 

was Issue, Issue Number 10 in the, the June second 

published document, and that's the question: 

Is -- Are this -- Are these appropriate 

ways to address these particular products, those 

having multiple-blower indoor units and the 

triple-capacity northern heat pumps as the, and are 

these effective? 

Are they sufficiently generic to cover? 

Because, obviously, the waiver process would be 

focused on that particular line of products. 

And do we sufficiently make it generic, 

and do we capture the, the features that are being 

brought forward as part of it, these new product 

lines? 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. 
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 Brian, I guess the overarching question 

to me is, given that heat pump sizing for Northern 

heat pumps in particular is done to meet the load 

at lower temperatures, was any consideration given 

to moving the, the stipulated point from 47 for, 

for capacity, down to a more appropriate 

temperature, both for these and for all so-called 

northern heat climate zones? 

We've, we've had the problem that the, 

the HSPFs are never reported for the, the northern 

zones anyhow. 

MR. DOUGHERTY: And that's an option. 

There was an effort here to have a consistency so 

there would be a better way to, of, of comparing 

more conventional system. 

So, what people tend to focus on is 

Region IV, and minimal designed heating 

requirement. So, to show the added effect of this 

added capacity at the lowest temperatures, there 

was a desire to have consistency to allow that 

comparison. 

But, it could be possible, as you 

mentioned here, to do something, as stated, for 
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 Region V, because it has a different bend 

distribution, has a different design temperature, 

had the calculation of the building load be 

different. 

So, that's an option. Again, this 

should not be done in a way that dif-, dif-, 

disadvantages these emerging units, but it is a 

question of fair comparisons at the customer 

beneficial conditions and the contractor-selecting 

conditions. 

DR. SACHS: Selecting a Wisconsin heat 

pump on the basis of 47-degree temperature probably 

is not going to make the Wisconsin utilities happy 

anymore, either. 

MR. DOUGHERTY: And without too much 

time, you could, you could actually apply the, the 

rating method, the bin calculations for a select 

region application and follow those comparisons. 

If you wanted to find the load in a 

different fashion, you could do that and make the 

comparisons. Now, it would be somewhat burdensome 

then to have all the manufacturers to do that, but, 

I mean, the calculation is possible. 
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88

 It's just a question of, of can, can a, 

can, can a DOE test procedure be used to that 

extent? And I guess I'm not sure that it can meet 

all needs, so to speak, in this case. 

DR. SACHS: Thank you. 

MR. BROOKMAN: Paul. 

MR. DOPPEL: Paul Doppel, Mitsubishi. 

Variable speeds have a, a similar 

problem in that the requirement is to run the 

compressors at the same speed at 47 and 17 degrees 

for capacity for HSPF testing, when in actuality 

the variable-speed systems, most of them can 

generally rate more capacity at lower temperatures. 

And it -- So, then they become like a 

triple-capacity or a high-capacity northern unit. 

And then some of the systems can even operate at 

lower conditions, down to minus-18. 

So, there's -- You know, that sort of 

feature of these variable-speed systems is not 

really adequately measured by the current setup, 

the current testing. 

MR. DOUGHERTY: Okay. I mean, there is 

an effort, because everything -- You had the 
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89

 performance-map-generation side. 

MR. DOPPEL: Yeah. 

MR. DOUGHERTY: So, the effort there is 

to have con-, consistent operating occurring at the 

47- and 17-degree test that you can interpolate for 

the outdoor temperature. 

So, if it's a maximum, you should be 

able to get those two points and they should be 

able to extrapolate down to those. And the same 

way on the outdoor low side get that. 

But, then you have to overlay that 

building load line. So, that's what that 

particular load, that once you had the performance 

map generated, what load line do you put over the 

top so they're related? 

But, I'd be curious to see a little more 

of the understanding as far as why the current 

algorithm of the similar linear between the two 

outdoor is not quite generating the outdoor needed 

to cover these products. 

MR. DOPPEL: Well, when you -- You know, 

for the homeowner, what they're concerned about is 

not whether the, really, the HSPF is at 17 degrees, 
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90

 because with the variable-speed system they can get 

higher capacities than the compressor running at 

the same speed that it's, runs at 47. 

So, what's important to the customer is: 

How much heat can they get at 17 degrees? And then 

that heat has a value to them. 

And if it -- You know, it may cost them 

a little bit more energy, but, you know, it's 

still, the important factor is, and, you know, in 

some cases, like in a 12,000 system, 12,000 

available-speed system, the rated heating capacity 

using the current test method would be 9,000, 

roughly. 

So, that would be misleading to the 

consumer when they actually could get up to maybe 

13,000 heating capacity. 

MR. DOUGHERTY: But, the maximum is 

maximum. So, if you're generating your performance 

curve at whatever the maximum compressor capacity 

is at 1, what are saying? 

The maximum at 1 is not the same at 47 

that will allow top rate? Is that what you're 

saying? 
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 MR. DOPPEL: That's what I'm saying. 

It's supposed to run at the same speed at 47 as 1. 

MR. DOUGHERTY: Right. So, the next 

question is: Can you go to 1 and extrapolate it? 

Because you're trying to create a 

bracketing of the performance, and in between there 

you're trying to get an intermittent point that 

will give you some idea of the nonlinearities going 

from minimum to maximum. 

So, as long as maximum is maximum, we're 

okay. But, if it's not, is --

MR. DOPPEL: It's not. Yeah. 

MR. BROOKMAN: Paul, it's not -- I want 

to make sure we fully hear what you've got to say. 

MR. DOPPEL: Okay. Well, what -- The 

issue is that the variable-speed systems have a lot 

greater capabilities than the current testing. 

MR. BROOKMAN: Uh-huh. 

MR. DOPPEL: And, and that's -- There, 

there's a comment on that in the first few pages of 

the NOPR, and so we, we, in the letter that we sent 

in before, we tried to identify some of those 

inconsistencies with the current testing procedure. 
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 MR. BROOKMAN: And what about --

MR. DOPPEL: And this just happens to be 

one of those, that on a heating side you can 

generate a lot greater capacity at lower 

temperatures because the systems are not fixed by 

compressor speeds like standard systems where 

you're on or off or maybe one or two stages. 

MR. BROOKMAN: So, would you suggest 

additions to this proposed test procedure the way 

he's, the way Brian's described it? 

MR. DOUGHERTY: This doesn't -- This is 

a separate issue. 

MR. DOPPEL: Separate issue. 

MR. BROOKMAN: Then, Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

I think, if I understand correct, this 

is an incremental version of something that 

supposedly was resolved about 25 years ago. There 

was a variable-speed heat pump manufactured by a 

company in the room, not my employer, that had a, a 

restriction of 60 Hertz for the drive of the 

compressor at, in the cooling mode, and 90 Hertz in 

the heating mode. 
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93

 And I suspect that the capacity, 

assuming the load line was defined probably at 60 

Hertz at 47, not at 90, and the heat pump, the 

whole premise of the heat pump was the fact that it 

could do as, as Paul is saying, and could operate 

at the higher speed at lower RPM. 

And I suggest that -- Excuse me. At 

lower temperature. 

I suggest that we need to revisit the 

history on that. You're familiar with the product 

of which I speak, are you not? 

MR. DOUGHERTY: Yes. And the current 

test procedure covers that case. 

You're absolutely right. 

MR. CRAWFORD: And, you know, it ought 

to be fairly straight-forward, forward, forward. 

If I understood Harvey correctly, he questioned 

whether the utilities would like or not like this 

type of system. 

And this type of system should defer the 

use of strip heat, so the electric utilities, if 

they're winter peaking, ought to really like it. 

MR. BROOKMAN: Harvey Sachs. 
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94

 DR. SACHS: Thanks, Jim. 

MR. CRAWFORD: That's what I was trying 

to imply, that the rating method that does, does 

not easily allow a utility to give credit for the 

low-temperature performance is probably not sound 

public policy over the next decade. 

I really think that I see a complex 

thing on the overlay on our present rating method, 

but we certainly, I don't want to obscure the 

performance at low temperatures of advanced systems 

of whatever type they are that you speak well. 

In fact, in keeping the building low 

lined in a comparative basis would help, as opposed 

to: Did we get the higher HPF? 

Because the load line would be typical 

of one not having that extra rating. So, the 

balance point would be so the A resistance heating 

that's going to be accounted for is going to be 

less. 

HSPF is going to go up. So, I don't 

know how big of an impact, but it will have a 

positive impact, all other things being equal. 

DR. SACHS: Yeah. Harvey Sachs. 
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95

 And I very much appreciate that. The 

question is that if it's giving little bit of 

difference at the time that the utility is under 

maximum strain, it has much less value. 

And I'm hammering on this because I'm 

trying to advance a slightly different agenda in 

terms of value of performance maps, and I apologize 

for trapping you in that slime. Thank you. 

MR. BROOKMAN: Okay. Thank you. 

Do you have any additional follow-on 

questions or anything here, Brian? 

MR. DOUGHERTY: I did not. 

MR. BROOKMAN: Any other comments on 

this segment? 

(Whereupon, no response was had.) 

MR. BROOKMAN: I think that we should 

take a break. This is rather dense material and 

there is more of it to go through, and so let's 

take a 15-minute break. 

And we're going to -- The way I 

understand it, the Department has in mind this 

will, this will end around about 12:30. We may go 

a little bit longer than 12:30, so if you need to 
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96

 have a piece of fruit or muffin or something to 

sustain you to 1:00 or, you should do it now, 

please. 

Wear your badge in the building. 

There's a coffee shop on the ground floor straight 

on down the elevator. 

If you're going to go out for coffee, go 

quickly, because it takes a while to get back in. 

We'll resume at 10:55. 

(Whereupon, those present took a brief 

recess and returned, after which the following 

occurred:) 

MR. BROOKMAN: Let's take your seats and 

start back up. In this morning's session I was 

getting concerned that somehow all this information 

was not landing in a comprehensible fashion, to be 

frank. 

I, I, I saw a lot of kind of glazed 

looks as I cast my eyes around the room, so I put 

the burden on all of you. If you're confused or if 

you want further explanations, please speak up so 

that -- This is the purpose of this, is to educate, 

answer questions, and also deliver feedback to the 
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97

 Department of Energy. 

So, please weigh in that way. 

Jim Crawford. 

MR. CRAWFORD: Jim Crawford, who seldom 

admits to being confused. But, the -- I think the 

point is that the lead time here was very, very 

short on this meeting --

MR. BROOKMAN: Got yeah. 

MR. CRAWFORD: -- and most of us have 

some deliberation on the issues that we need to do 

between now and the time that the final comments 

are due. And I think that explains perhaps some of 

the blank stares occasionally. 

MR. BROOKMAN: That's good. That's --

And I appreciate that. 

So, we could make this more tending 

toward a workshop format, where there was the 

exchange of information that would then benefit you 

in making your final comments. 

Okay. That is to say, the exchange 

could be different, slightly different. 

Okay. So, then let's proceed. 

As I understand it, we are on about 35. 
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98

 MR. DOUGHERTY: Correct. 

Okay, I'm going to go into the weeds 

again; try to clarify inputs that are used in this 

demand defrost credit equation. There's a demand 

defrost, and the identified Fdef. 

And it's a direct multiplier with the 

calculation of the heating seasonal performance 

factor. And historically that value ends up being 

some value between 1 and 1.03. 

So, as a maximum benefit of a 

three-percent increase, if, in fact, you offered 

demand defrost capability on your heat pump. And 

that's to be positively verified during the frost 

accumulation test at 35 degrees outdoor 

temperature. 

In the previous Final Rule in the 

previous rulemaking process there was comments to 

the effect that there, that there, this particular 

frost, the frost accumulation test could be, be 

extended, is allowed to extend as much as twelve 

hours. 

And that can become excessively 

burdensome to conduct and to maintain the test 
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99

 conditions and the tolerances over that long a 

(sic) interval. And so the proposal was that that 

needs to be shortened. 

And that, in fact, was what was enacted. 

It was reduced as the maximum test duration from 

twelve hours to six hours, with the understanding 

that if most systems haven't gone through a defrost 

by six hours, they're either not going to go into 

defrost, or they're beyond help. 

So, it made a lot of sense to decrease 

that interval, because the gain in extending it 

wasn't there. So, it -- That, that change was made 

on the testing side. 

Full consideration on the calculation 

side was not given. So, we're going to now see, 

now that that test duration was changed, should we 

reconsider a modification to the cal-, the cal-, 

the equation of this demand defrost credit? 

And two possible corrective actions were 

considered. Just to bore you with the equation, 

that appears in the test procedure. 

This is what they used to come up with 

that crediting. It's, again, can be as much as 
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100

 three percent. 

And the two key elements here are in the 

enumerator. In one case, the Delta Taudef is the 

time interval between frost determinations. 

So, -- Or, 1.5. It has to be at least 

1.5, whichever is greater. 

And the second one is what the 

manufacturer has as the maximum interval that 

they'll allow the unit to operate before they 

invoke a defrost; so, regardless of the demand side 

of the feature that says, "Okay, there's, there's a 

hard number that I'm not going to let it go beyond 

before I put it through defrost to make sure 

everything's good to go, or 12 hours." 

So, right now that limit on Delta T-max 

was set on 12 hours. And so in part, it could be, 

to a certain degree, verified, though not in the 

laboratory, because the laboratory tests would 

allow you to go all the way to twelve hours. 

But, now we're allowing that to only go 

to six hours to -- So, the question is: Should we 

make some adjustments here to the, to the, to the 

equation? 
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 So, as far as potential corrective 

actions, -- I'm on Slide 37. -- one would be to 

update that equation that we were just looking at 

and change out that twelve-hour value with a 

six-hour value for that Delta T-max. 

As to if the manufacturer offers a 

system that goes beyond twelve hours, we've gone 

six hours. No, you've got, you've got to limit to 

six hours. 

Or, let's keep that current equation, 

but clarify the inputs that are used for it such 

that people still realize that the maximum time for 

the test is, is, in fact, six hours. 

So, here's a graph of that, how that 

demand defrost would, credit factor would change 

for -- So, first let's start with what's currently 

on the books, what was part of the rule of 2007. 

Well, actually, let's start pre-2007, 

where, in fact, you were allowed to go 12 hours for 

your test. For any defrost that would occur 

between 0 time and 90 minutes, one and a-half 

hours, you'd get the full three-percent benefit. 

But, as far as after that time, if you 
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 defrost at 100 minutes, two hours or beyond, you'd 

be at some value less than that. And how you would 

scale to 0 would depend on what the, the maximum 

value that was assigned for the manufacturer for 

that unit. 

So, so, to the end point on the, the, 

the, what would intersect the X axis would be the 

hours associated with the maximum that, that the 

unit is allowed by the manufacturer. 

And in -- So, in the case of the 

manufacturer allowed it to go up to 12 hours, it 

would be that, that blue line. And so any time 

defrost occurred at two hours, four hours, six 

hours, what it, it would fall on that blue line and 

that would be given at the, the credit. 

Now, if we change from that twelve-hour 

being the maximum to that six hours being the 

maximum, you end up reverting back to the curve 

designated by the green line, the green dotted line 

there. 

So, that's, that's the impact of saying 

no, because we can't truly confirm to the extent 

that we may want. Let's say we only can prove what 
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 was the limit of six hours, and that will be our 

new line. 

But, in that case you're going to have a 

unit, a system that's going to change its demand 

defrost unit because of this limit that's put on 

the test, not fail as to how the unit performs. 

It's actually just an artifact of changing the 

maximum test duration. 

It may not be representative of, of, of 

what really happens. So, the alternative there is 

to stay with what is currently projection of that 

line, allowing it to be at a number beyond what is 

currently the green dotted line, but accepting the 

fact that because the test ends at six hours, you 

can only go vertically from your six-hour point. 

So, any, any curve that would come down 

here, you'd have to take the intercept here, even 

though the unit defrosted beyond six hours. So, 

there would be units, although very few, that would 

take a defrost beyond six hours. 

Now, I'm not familiar. That's the next 

point. 

So, the DOE proposal is to the second 
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 option, with the expectation that it's not going to 

change your HSPF if we go with this. It wouldn't 

change the HSPF for those units that defrost after 

an hour and a-half. 

So, rather than do that, let's stay with 

our current approach, but in some way benefit units 

that would defrost beyond six hours. And there 

aren't many units that would defrost beyond this 54 

dry bulb, 33 wet bulb, and not go into defrost 

within six hours. 

And I think the majority of the units 

would be, "No, we'll be going through our defrost 

much earlier than that if we have a demand 

defrost." 

So, the impact, you're going to affect 

units to one degree or another because of this 

change in the test duration. And I think the 

impact would be much less with the proposed 

approach as opposed to implementing that dotted 

line that's, that was shown on the previous graph 

to, to say, "No, we're going to limit to only what 

it correlates during the test of the maximum time 

of six hours." 
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 Hopefully that was somewhat discernible, 

understandable. If not, let's talk about it more. 

But, in, as part of the public meeting 

questions here is whether or not interested parties 

agree with this approach, or more or less leaving 

that characteristic line alone, but potentially 

having a slight benefit to units that would defrost 

beyond six hours, even though, as the context here 

is currently done, you stop the test. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

The, the comment that I'd like to make 

is that it, it appears that either option is going 

to change the HSPF of the product. And if we make 

a test procedure change that changes ratings, that 

raises all kinds of issues about the whole rating 

numbers, and whether, if they go down, that's going 

to confuse the consumer considerably that a product 

that, that on one day is, is X, and the next day is 

something less than X with their performance. 

So, we've got concerns about it which we 

will elaborate in our formal comments. 

MR. BROOKMAN: Would you imagine it's a 
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 significant change? 

MR. CRAWFORD: Any change --

MR. BROOKMAN: Got ya. 

MR. CRAWFORD: -- is significant, --

MR. BROOKMAN: Okay. 

MR. CRAWFORD: -- because -- Unless you 

want to, unless DOE wants to open up the tolerance 

band. 

MR. BROOKMAN: Molly? 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

So, I just -- I'm not entirely clear. 

When you also clarify equation input, what are you 

clarifying, that, that you're adding the maximum 

and minimum values in here where it can't be 

greater than 1.5 or less than the 12, or --? 

MR. DOUGHERTY: Right now, just to 

explain to the fact in that equation that appears 

here, there were some comments that came back, 

"Hey, there's a 12-hour now," when, in fact, we 

reduced it to six. "Should I put six, or stay with 

the 12?" 

In this case, no, just stay with the 12, 
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 because it's something provided by the 

manufacturer, and during the tests you don't want 

that to vary; that unless you have to go all the 

way to 12 hours in the defrost, there's nothing in 

the, just to clarify, yes, just do a -- The 

equation shows they'll be, don't be reading into 

this, because the test only goes six hours, and 

that fact that 12 should be a, a six. 

MS. TROMBLEY-McCANN: Thank you. 

MR. DOUGHERTY: And to Jim's comment, it 

makes a lot of sense. And we have partitioned the 

proposed changes into sets being one near-term and 

a second set that would be timed to coordinate with 

the Standards compliance date; that maybe this one 

should be pulled out, the first set, and included 

into the second set. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

To the, the point raised about the 

clarification, I read that as the goal of this 

investigation rather than the effect of that chart. 

MR. BROOKMAN: Karim? 

DR. AMRANE: I guess question for Brian. 
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 Have you, have you assessed the change on the HSPF 

percentage-wise? 

MR. DOUGHERTY: Yeah. So, as a, as a 

worse-case, so you're always going to be coming 

vertically here. 

As to the intersection point for any 

units, again, for the very small population of the 

heat pumps out there that would defrost beyond six 

hours, in, if we would go all the way to 12 hours, 

in this case they would get a 1.0-percent higher 

HSPF than they would in the worse case where they 

went to 12 hours and didn't defrost over that 

interval. 

That's the biggest improvement they can 

get. Anything lower would be, would be lower than 

that. 

So, if they defrosted down here, they 

would only get this incremental improvement, 

whereas they go further down this line --

MR. BROOKMAN: Karim, yes? 

DR. AMRANE: Okay. 

MR. BROOKMAN: Molly? 

MS. TROMBLEY-McCANN: Molly 
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 Trombley-McCann. 

So, just to clarify, no HSPF is going to 

go down under the proposal. 

MR. DOUGHERTY: Correct. 

MS. TROMBLEY-McCANN: They would only go 

up. 

MR. DOUGHERTY: Correct. 

MR. BROOKMAN: Harvey? 

DR. SACHS: Harvey Sachs. 

And on those that defrost beyond six 

hours. 

DR. AMRANE: Brian, this is helpful, but 

can you walk through that diagram for something 

that defrosts after five hours? I'm having trouble 

with that vertical axis. 

MR. DOUGHERTY: Sure. Okay. 

Okay. Okay. 

Okay, you'll be coming in here then. As 

additional thing, as a manufacturer, you'd have to 

tell me what is the maximum that you would 

otherwise defrost, okay? 

If you would otherwise defrost at six 

hours, you'd go to that line. So, your credit 
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 would be 1., 1.01. 

You'd have one percent. But, if you 

say, "I wait 12 hours," then you'd have a 1.22, so, 

a 2.2-percent improvement. 

This is -- This equation was implemented 

in 1988 as part of the rulemaking done then, and 

had stood over time and there was no changes made 

to it. 

As part of it, this last Final Rule, 

what was changed, it was maximum test duration of 

that laboratory test, this frost accumulation test, 

from a maximum of 12 hours to six hours. 

MR. BROOKMAN: Jim. 

MR. CRAWFORD: Jim Crawford. 

Two points. One is you mentioned that 

you, you're not aware of many of them that defrost 

at longer intervals than six hours. 

I, I'd point out that there are 

varieties of technologies of coils in the industry, 

and their frosting properties are not all uniform. 

The second point is that the, the 

reading that I have received thus far is that, in 

fact, with units with longer defrost time, this is 
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 a penalty. 

MR. DAUGHERTY: I'd like -- Good. I 

would like to receive more understanding on that, 

if I could, part of the comments. 

MR. BROOKMAN: Do you -- Can you 

elaborate on that comment, Jim? 

MR. CRAWFORD: That will be elaborated 

upon in our formal comments. 

MR. BROOKMAN: Okay. Okay, thank you. 

MR. DAUGHERTY: Okay. 

MR. BROOKMAN: So, final comments on --

Yeah, go back to the -- Go forward. Uh-huh. 

You see the Public Meeting Question 

Number 2 does, seeks comments on the NOPR proposal 

to leave the equation for the demand defrost credit 

unchanged. 

Are there additional comments on that 

one? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: Changing now to 

miscellaneous items, the first is to explicitly add 

a calculation for something that is well-understood 
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 in the industry, and that is: How do you calculate 

sensible heat ratio? 

And the particular element that's added 

is with regard to the recommendation that it be 

calculated with the B Test, which is conducted at 

an outdoor temperature of 82 degrees dry-bulb 

temperature. 

As far as this proposed addition, it 

would not increase the test burden, as these 

measures of the sensible versus the total are 

already made as part of the laboratory test. DOE 

is not considering using the sensible heat ratio as 

part of the SEER calculation, so SEER's unaffected 

by this proposed change. 

When humidity control is a concern, 

consumers and their contractors may wish to know 

this value. So, this is just an opportunity for 

DOE to endorse its existence by adding it to the 

test procedure. 

And it's something -- Where it goes from 

here, the potential next step would be if FTC so 

chose, they could see, have a rulemaking to see 

whether it should be added to the Energy Guide 
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 label, for example. 

But, we thought as a first step, to 

endorse it, especially for those folks who are 

proponents of hot, humid climate and don't have it. 

At least it would be a test procedure for adding 

endorsing that. 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. 

Southern Company is not present today, 

but in prior workshops has been a very strong 

advocate of having that information available, 

although they do not offer currently any rebate 

programs. 

This could be a very important input to 

incentive programs in the Southeast. We would 

strongly endorse your proposal. 

MR. BROOKMAN: Thank you. 

Yes, Molly. 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

Just to echo what Harvey has said, as a 

utility we would very much like to see that, see 

that on the energy guidelines. 
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 MR. BROOKMAN: Okay. 

Jim? 

MR. CRAWFORD: As an informational 

point, we concur with the motivation here. The 

information is published by at least some 

manufacturers today. 

The -- There is a, a measure of concern. 

As we talk about testing in different environments, 

we need to be careful that we define the, the 

environment and that set of conditions under which 

we are going to specify HSR. 

And we are taking it that you're talking 

about an informational point here to be published 

in literature or web sites or whatever, as 

contrasted to another certified rating point. 

MR. ANDERSON: Yeah, that's fine. 

MR. BROOKMAN: Wes, you -- For the 

Record, Wes Anderson. 

MR. ANDERSON: Wes Anderson on DOE. 

That's, that's fine. Thank you. We 

don't have any comment on that. 

MR. BROOKMAN: Okay. Thank you. 

Karim? 
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 DR. AMRANE: Karim Amrane, AHRI. 

I guess what's being asked here is, is 

for manufacturers to report that information? I 

mean, okay, today, as you said, it's part of it, 

the test procedure. 

So, it can be captured. So, what is, 

what would be the requirement of the manufacturer? 

MR. DOUGHERTY: As far as the test 

procedure, this was just a starting point because 

it's not explicitly given in the test procedure 

right now. So, this was just the first attempt to 

get the very short list. 

I'm not sure where this goes, Karim. 

It's something that needs to be discussed maybe at 

the Standards rulemaking. 

But, as far as a test procedure is 

offered by some manufacturers, DOE felt like they 

wanted to endorse its use, so, so, to explicitly 

spell it out in the test procedure. 

MR. BROOKMAN: Are there other questions 

or comments? Okay. 

Yes, Jim Crawford. 

MR. CRAWFORD: I -- Unless I've 
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 misunderstood, when I say we publish the 

information today, the information is not published 

currently for most products probably in a format 

that the average consumer would even begin to 

comprehend. 

There are performance tables that are 

published that have a variety of parameters from 

which one can derive the sensible heat ratio, but 

it isn't a block that says "Sensible heat ratio 

equals X." 

MR. BROOKMAN: Okay. Any other comments 

on this? 

We're going to move on. 

MR. DOUGHERTY: Okay, the next one is 

just to clarify that if a manufacturer would choose 

in some cases to run optional frost accumulation 

tests and take on the extra test burden by doing 

so, then they would, then they would still have the 

option of using whatever gets the better results. 

So, it's an attempt to clarify this and 

to encourage testing. And such a clarify-, such a 

clear statement as to if you run the optional test 

in the case of the cyclic degradation coefficient, 
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 it says in there that if you run those tests and 

you still find that the default is the better 

option, which is unlikely, but if it was, you still 

have the option of using that default. 

You have not forfeited it by running the 

test. So, it's the same as the frost accumulation 

type test. 

And as far as making that decision of 

which one gives me the better value, because you 

can do it for different regions, there is a 

statement that says, "Okay, you use the one that 

gives you the better performance with regard to 

HSPF for Region IV." 

And design heat, minimal heat design 

heating is a requirement. So, that would be the 

basis, as opposed to, "Should I use the Region V 

number? Should I use the Region III? 

No, let's use the ones that are used for 

Region IV minimal design. 

Any question with offering this, making 

this clarification within the test procedure? 

MR. ANDERSON: This is Wes with DOE, 

directed to Jim Crawford. 
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 Do you -- Would this address your 

environmental --

MR. CRAWFORD: I'm sorry? 

MR. ANDERSON: You said -- Your previous 

comment was, "I'm saying the HSPF was the 

environment." 

The -- I'm -- I assume the environment 

can affect that number. Does this Region IV 

satisfy that concern? 

MR. BROOKMAN: You mean being specified 

as a default? 

MR. ANDERSON: As a default. 

MR. BROOKMAN: Yeah. 

MR. CRAWFORD: I, I, I can't answer that 

question at this time, Wes. 

MR. BROOKMAN: Okay. Well, the intent 

is clear. 

MR. DOUGHERTY: Yes. 

MR. BROOKMAN: Okay. Quick comments on 

this? 

(Whereupon, no remarks were made.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: Okay. Finally, as far 
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 as proposed miscellaneous items, one is to 

reference within the Consensus Statement actual 

ASHRAE 116 to have a little bit more resolution on 

their equation steps as to when you're going 

through the calculations for a variable-speed 

system, how you, in fact, do those interpolations 

for SEER. 

So, it's proposed to reference those 

more, more resolution equations. So, rather than 

repeat them in the DOE document, refer to the 

ASHRAE document. 

And then while we have the opportunity, 

we may have to add to these lists because there's 

always new Standards coming out, revisions and 

reaffirmations, to try to keep up with things. So, 

to reference the things as far as consensus, the 

ASHRAE and 210/240, we reference each other. 

So, we're always catching up, and 

probably need to figure out a way to both be 

referencing our most current document also. 

But, we'll reference the 2008, and then 

you'll revise yours and we'll be trying to 

reference it. So, this, this is kind of norming, 
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 kind of trying to keep up with the Standards that 

are available. 

MR. BROOKMAN: Paul first. 

MR. DOPPEL: Please add HRI Standard 

1230. 

MR. DOUGHERTY: Right. 

MR. BROOKMAN: Jim. 

MR. CRAWFORD: I'm going to step back 

to, to Wes Anderson's question. I can't answer it 

now. 

MR. ANDERSON: What was my question, 

again? 

MR. CRAWFORD: The question dealt -- The 

question dealt with whether or not the choice 

between default or testing on CD would resolve the 

issue I raised earlier. 

And the answer is, no, because the, I 

believe that, that the situation we were discussing 

earlier relates to tested, testing of, of cycling, 

and so the use of the default would not resolve 

that. 

The whole purpose of testing is to 

hopefully demonstrate that your product delivers a 
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 CD less than the default, a more favorable CD. And 

so anything that would adversely affect that is 

adversely affecting the, the rating of the product. 

MR. BROOKMAN: Okay. I think we're 

about to move on to another section, --

MR. DOUGHERTY: Yes. 

MR. BROOKMAN: -- which would be the 

Proposed Revision Set 2. 

Before we leave Set 1, effective with 

the test procedure rule, that's, that's the 

differentiation point that the Department's making 

here. There -- Before we move on, any final 

comments on this entire section? 

(Whereupon, no response was had.) 

MR. BROOKMAN: There was a lot of 

content here. Okay. 

So, -- And if anything additional 

occurs, we can back up --

MR. DOUGHERTY: Absolutely. 

MR. BROOKMAN: -- to accommodate. 

So, it -- Now we're going to proceed 

with Brian. 

PROPOSED REVISIONS SET Nbr. 2: 
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 MR. DOUGHERTY: So, the second set, as 

we discussed earlier, is dominated primarily to the 

EISA that came into play in December, 2007, and 

with regard to the demand defrost credit would be 

timed to occur at the same time as the compliance 

date for the Standards. 

So, projected, maybe 2016. Okay. 

One of the two things that were in, was 

in the EISA legislation had to do with --

DR. SACHS: I have a question. 

MR. BROOKMAN: Yeah, sure. 

DR. SACHS: Can we go back to the, the 

chart with the ASHRAE Standards? 

MR. DOUGHERTY: Yes. 

DR. SACHS: I'm going to ask a really 

stupid question, and I had to check with that. I 

-- It really is stupid. 

MR. BROOKMAN: No, we have no stupid 

questions here. Really. 

And I do my best to set a low bar. 

DR. SACHS: What does "RA" stand for? 

MR. DOUGHERTY: "Reaffirmed" in that 

year, 2009. Two-thousand-nine. 
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 So, it's the '06 version. 

MR. BROOKMAN: Okay. So, we'll proceed. 

MR. DOUGHERTY: Okay. So, within EISA 

there was a requirement that products have to 

account for all modes of energy consumption. 

They termed it "standby." And then 

there was "everything other." 

And so its all-inclusive. And so the 

question is: Well, is standby accounted for in --

And, yes, SEER accounts for all modes of energy 

consumption that occur during the cooling season, 

including times when the air conditioner or heat 

pump is cycled off. 

And same for HS-, HSPF. It does, also. 

So, we're good in there as far as the 

heating and cooling season, but then why did, do I 

have another slide? 

Well, it's because the cooling seasons 

and heating seasons in all cases, well, in all 

cases don't account for an annual basis. So, some 

energy consumption is being missed. 

And in this case in particular, the main 

culprit is air conditioner, the air conditioner 
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 sitting there idling. It uses some minimal amount 

of parasitic power, and that's not accounted for 

currently within the existing metric of SEER. 

And, also, energy consumed by an air 

conditioner or a heat pump during the shoulder 

season. And where does that shoulder season come 

from? 

If you take the current basis that is 

used for coming up with the energy consumption 

which converts to operations costs to cooling 

seasons and heating seasons, it used these maps 

that are called cooling load and heating load maps. 

And if you look at any particular 

combination of any generalized region or particular 

location, those two can be converted to individual 

numbers of hours associated. 

And if you sum those two, they were less 

than 8,760, which would constitute a full year. 

So, this is something that was, needed an ASHRAE 

Standard for compliance as ASHRAE 137. 

And so it's a Standard here for moving 

forward with a standby/off-mode element for air 

conditions and heat pumps. So, DOE proposes to 
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125

 account for this out-of-seasons energy consumption. 

And as part of that proposal, they, they 

propose to define off-mode to, to define the 

seasons in terms of mode, and that was off-mode. 

And so they were redefining a generic 

definition that applied to all products, to a 

definition that is specific to products covered by 

this test procedure of air conditioners and heat 

pumps. 

So, for air conditioners, the off-mode 

is defined as when the units are off but powered 

during the heating season. And the shoulder off 

mode for heat pumps, that would be the same as air 

conditioners, except only apply to the shoulder 

seasons because it's actively performing a function 

during the heating season. 

In addition to adding the, the 

definitions, to also look at adding additional 

laboratory testing to help quantify this parasitic 

power use, and then taking that laboratory data and 

adding calculations that could be used for 

representing the, the performance. 

And so there's a proposal in there to 
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 add two new parameters generically designated as P1 

and P2. 

P1 would be representative of the 

off-mode power consumption for shoulder seasons. 

So, that would be applicable to both an air 

conditioner and a heat pump. 

So, whether or not it's 12 watts, 20 

watts, whatever that representative value would be 

during a period, that would be representative of 

the outdoor temperature during a shoulder season 

period to so quantify that. 

P2 applies to air conditioners only, and 

it assumes the same type identifier, a 

representative power consumption or rate quantity 

associated with the air conditioner sitting there 

during a, a, a representative heating season. 

So, in this case we're doing away with 

the, with reference to "standby," because we've 

defined "off-mode" as such as covering this 

out-of-season period. We'll just stick to that 

terminology here for --. 

Okay. With regard to the laboratory 

testing that's proposed for the off-mode 
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 characterization, the testing -- I'm sorry. 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. 

MR. BROOKMAN: You're not on, Harvey. 

DR. SACHS: I'm definitely not on. 

MR. BROOKMAN: That was the microphone I 

was referring to. 

DR. SACHS: You have defined P1 and P2 

in terms of power consumption. 

MR. DOUGHERTY: Yes, sir. 

DR. SACHS: Am I to infer that the units 

are watts? 

MR. DOUGHERTY: Yes, sir. 

DR. SACHS: Okay. The legislation 

speaks of "energy consumption," so this will be fed 

in --

MR. DOUGHERTY: To an hourly value to 

get watt hours; yes, sir. 

DR. SACHS: Okay. So, I still have the 

opportunity to get confused. 

Okay, thanks. 

MR. DOUGHERTY: Okay. Yes, Harvey. 

DR. SACHS: This is a rate quantity, 
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 power quantity. The legislation talks in terms of 

energy. 

So, we'll have to multiply the hours 

associated by these particular, which will depend 

on the region. Maybe I'm jumping ahead of myself, 

but the DOE divides the country up into six 

climatic regions. 

So, they'll be multiplied by these rate 

quantities to give up watt hours. 

MR. BROOKMAN: Paul. 

DR. SACHS: Brian? 

MR. DOUGHERTY: Yes, sir. It --

DR. SACHS: Harvey Sachs. 

A generic question that maybe shouldn't 

be addressed to you, but to industry. How 

prevalent are crankcase heaters in today's market? 

MR. BROOKMAN: You said crankcase 

heaters? 

DR. SACHS: Right. 

MR. BROOKMAN: Do any of you wish to 

address that? 

DR. SACHS: Are there any crankcases, 

crankcase heaters around? 
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 MR. BROOKMAN: Jim Crawford wants to 

respond. 

MR. CRAWFORD: The answer to the last 

question is yes, there are crankcase heaters 

around. 

MR. BROOKMAN: You made it easy for him 

after I -- The earlier question was more 

open-ended, but do you want to respond to this one, 

Paul? 

MR. DOPPEL: Not on crankcase heaters. 

MR. BROOKMAN: No on crankcase. 

MR. NICHOLS: I just affirm Jim's 

comment. 

MR. BROOKMAN: Okay. We want -- I 

don't, I don't know where we go with that. 

Do you want to follow on with that, 

Harvey? 

DR. SACHS: No. 

MR. BROOKMAN: Okay. Okay, so then 

we're going to take it back then. 

You had another comment, Paul, yes? 

MR. DOPPEL: Right. For the off-mode 

consideration, did you look at the various types of 
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 single-speed, two-speed, variable-speed in 

determining this impact on this? 

MR. DOUGHERTY: Take me a little 

further. As far as -- ? 

MR. DOPPEL: Well, variable-speed 

systems would operate more, at more these times and 

not be in an off mode, as opposed to single-speed. 

MR. DOUGHERTY: So, they should be 

covered under the calculation of seasons 

calculations. So, this is outside of what's 

covered by those seasons. 

MR. BROOKMAN: Yeah, Jeff. 

MR. NICHOLS: I think Paul's question 

is, you're saying variable speed's more likely to 

run during the shoulder seasons because it's 

providing some small measure of, of comfort 

different than what a single-stage is. 

Is that -- That's the point you were 

trying to make? 

MR. DOPPEL: Correct. 

MR. BROOKMAN: Molly? 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 
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 So, the shoulder season hours are 

different for a single-speed as opposed to a 

variable-speed; is that what you were saying? 

MR. DOUGHERTY: Actually, as calculated, 

they are not, because in coming up with the, the, 

the, the annual operating, the, the, the operating 

costs for the cooling season, you get that by 

defining a, a load. 

And you define that load in part by, by, 

by designating the number of cooling load hours. 

And that is -- Cooling load hours can be converted 

into actual hours, which, if you would plug those 

into the original -- I'm getting too much of the 

bin calculations. -- you'd come up with the 

original energy. 

So, you get the credit during the C and 

HF gift numbers. But, this is outside. 

Everybody would be sitting there idle 

during this peak period. So, whether that should 

be reevaluated, we would have to go back and try to 

make things consistent then in this calculation. 

So, that's a little more tricky. But, 

we could. 
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132

 Right now the credit would occur with 

CHSWF. 

MR. ANDERSON: Could I --

MR. BROOKMAN: Yes, Wes. 

MR. ANDERSON: This is Wes at DOE. This 

also was addressed at the preannounced, this 

meeting. 

DOE is also seeking comment, seeking 

data on the shoulder and off-season energy usage. 

So, if you could provide that information, that 

would be helpful in this analysis so we can get a 

more accurate reading, understanding of the, the 

hours that the sump, pump heater's being, that's on 

during that, during the year. 

MR. BROOKMAN: Okay. 

Karim? 

DR. AMRANE: Well, a following question 

on Wes. Karim Amrane, AHRI. 

How -- Did you cut labels out of 137? 

MR. DOUGHERTY: Correct. Correct. 

MR. BROOKMAN: Okay, Jim Crawford. 

MR. CRAWFORD: Jim Crawford. I think 

perhaps we need to clarify a point here about 
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133

 variable-speed versus single-speed systems. 

During the cooling season, 

variable-speed should be expected to run more 

hours. During the shoulder season, when there's 

not a demand for cooling, responsible management at 

variable speeds says it's not running, and 

therefore there should be no difference in the 

shoulder season hours between variable-speed and 

single-speed, given that the shoulder-season hours 

are properly determined. 

MR. BROOKMAN: Molly? 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

So, this is a divergent question on the 

same topic. 

MR. BROOKMAN: Please. 

MS. TROMBLEY-McCANN: So, there are six 

regions that DOE defined. So, that's -- I'm 

interpreting that there will be six different 

off-season energy consumption values for each 

model. 

MR. DOUGHERTY: You could go to that 

level, level of rigor, but the idea was to try to 
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134

 get a representative value, because the likelihood 

is that, you know, the, the, depending upon heating 

season, it's not going to be that big of a 

difference as far as the power planning. 

What's going to be the big effect is the 

hourly quantity because they differ so much from 

the southern to the northern climates. So, you're 

going to have much more. 

If you had a heat pump, excuse me, an 

air conditioner in a northern climate, there's 

going to be a lot of off-load energy consumption, 

whereas if that same air conditioner was in the 

South, it would have a longer cooling season. 

MS. TROMBLEY-McCANN: I thought that's 

what I was saying, not the hours, because you had 

the overall energy consumption. 

MR. DOUGHERTY: Correct. 

MS. TROMBLEY-McCANN: So, there are 

going to be six off-mode energy consumption values 

for each model. 

MR. DOUGHERTY: There could be as many 

as up to multiple. But, once you have them, you 

can apply them to different application cases. 
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135

 So, I look at it as more of an 

application issue as opposed to a rating issue. We 

have to pick one, one, one condition to rate them 

by, and I would assume it's probably going to be 

Region IV. 

MS. TROMBLEY-McCANN: That was my 

question. 

MR. DOUGHERTY: Yes. 

MR. BROOKMAN: Okay. Other --

Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

Brian just used the word "rating." I'm 

assuming that it is not the intent that there, that 

there will be a standard minimum, a maximum 

standard set for P1 and P2 to which a given product 

will be held; that it's, it's a matter of the data 

to be provided for the information of the, the 

consumer and other parties, but it is not a rating 

in the usual sense. 

MR. ANDERSON: This is Wes of DOE. We 

would probably defer that conversation for the 

Standards meeting, not the test procedure. 

MR. BROOKMAN: Thank you. Okay. 
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136

 So, Brian. 

MR. DOUGHERTY: Yes. 

MR. BROOKMAN: Yes. 

MR. DOUGHERTY: As far as the test 

burden added because of the proposed testing, 

trying to keep it as short as possible, and it 

would be of a shorter duration. 

In the case of an air conditioner, the 

testing is proposed to occur after you've finished 

all your cooling mode tests; in the case of the 

heat pump, to do it between the heating and cooling 

tests if, if we didn't sort of characterize 

crankcase heater. 

So, if it didn't have a crankcase 

heater, it should be relatively simple to let it 

sit there and know that you have confidence in the 

average value that's generated. It can be 

relatively short duration for a crankcase heater 

that's on continuously, because, again, you'd need 

to characterize its function as amps. 

The duration of the testing becomes a 

little more if, in fact, you have a crankcase 

heater that's thermostatically controlled, which 
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137

 would be often the case here, though. 

Because a heat pump is only being 

evaluated for its shoulder seasons, we were going 

to limit the, the temperature range that we're 

going to consider. And, in fact, the proposal is 

just look at, try to keep the dry-bulb temperature 

or pressure, and see whether or not, before 64 and 

66, and see whether or not it cycles on and off, 

and do it for an interval to see, and make that the 

basis for the P1 value. 

Now, for air conditioners, because we're 

looking at the heating season, heating season side 

of things, if it has a thermostatically controlled 

crankcase heater we have to look at other 

temperatures other than this nominal 65. 

We may have to have it in a test room 

where we absolutely regulate the room temperature 

and see how that crankcase heater responds based on 

the fact of having to dissipate the heat in a 

colder environment. 

And here it talks about once you'd have 

that laboratory value, what would be the 

calculation step? On Slide 47, to convert these 
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138

 power values, you'd be multiplying them by, in the 

case of the P1, by the shoulder season hours. 

So, if we just start at the columns to 

the left of the vertical green break, currently in 

the DOE test procedure it recognizes six 

generalized climatic temperature regions. In 

addition, it has rating values that are typically 

associated with HSPS that come out of the Region 

IV. 

So, you can see how they varied, Region 

V being southern; Region V being a northern 

climate; Region VI being a Pacific Coast. And you 

can see how the heating hours and cooling load 

hours varied based on the location in the country. 

And, if you want to see a map, I have a 

map I can probably bring forward later to show you 

how the country is partitioned. And so then 

looking at the right-hand side, using a logarithm, 

you can convert load hours into actual hours. 

And that's done here to show what the 

corresponding actual hours are for these different, 

could be these different cases. And so if you look 

at the cooling season hours and heating season 
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139

 hours, and the sum of those two, and they are less 

than 8,760, and the difference is what appears in 

the far right column of shoulder season hours. 

So, the P1 value would be, would be 

calculated by quantity in the far right column to 

get the number associated with off-mode during the 

shoulder seasons. 

And so for purposes of a value to, a 

single value to report that people could use for 

comparison basis, the idea would be -- Well, let's 

just use the same approach that's used now, and 

base it on the Region IV, but tie it to these 

ratings values of 1,000 and 2080 load hours. 

And so the number would be 739 in this 

case. And then for air conditioners, that P2 value 

would be multiplied by the column that's two in 

from the right, the season, Heating Season's Hours, 

to come up with the energy that's representative of 

the system when it's sitting there idle during the 

heating season. 

Is there interest to discuss any table 

and this proposed algorithm of going from power to 

energy quantities? 
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140

 MR. DOPPEL: Can you go over the math on 

that one more time? Because it's --

MR. DOUGHERTY: Oh, you're funny. The, 

the watt values, and then you add them to times to 

get the watt hours. 

MR. BROOKMAN: Go to the screen and walk 

them through it one more time. 

MR. DOUGHERTY: Okay. I'm sorry. 

So, so, P1 and P2 are, are watt 

quantities. They're watts. 

So, to get watt hours, you have to 

multiply it by the hours that it's sitting there 

generating that, consuming that, that, that rate of 

energy. So, it's just watts times hours to give 

you watt hours. 

So, P1, watts, shoulder season hours, 

watt hours. Same with P2 is a watt quantity, and 

so times here is a -- So, watt hours. 

So, so -- And, and energy is -- Watt 

hours is a, is a, is a unit of energy. 

MR. DOPPEL: I was looking at, more at 

how you came up with shoulder season hours. 

MR. DOUGHERTY: Okay. As far as that is 
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141

 concerned, you can take these combinations of 

cooling load hours and heating load hours and 

convert them to hours associated with actual watt 

hours of heating season and cooling season to 

where, for example, if you were doing your bin 

calculations, and rather than use those fractional 

bin hours that summed to one, if you actually used 

these numbers, you'd get the same using the 

fractional. 

And you would get, you'd get the same 

HSPF of Region IV. So, finally, if you add these 

together, they end up being less than 7,606 of 

9,760, and that is the difference between 8,760 and 

the sum of these two. 

MR. BROOKMAN: Jim. 

That was good. 

Jim. 

MR. CRAWFORD: Yeah, Brian. Jim 

Crawford. 

What is the relationship between the two 

columns, "Cooling Load Hours" and "Cooling Season 

Hours"? And I'll have a follow-up. 

MR. DOUGHERTY: Okay. So, the cooling 
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142

 load hours are full load hours that the compressor 

would run during that season. 

And it was developed when the, the test 

was originally in place. And that number is used 

to multiply by the capacity of the unit at its full 

load condition. 

So, if you take this number and multiply 

it by the capacity of 95 from the A Test, that 

gives you your building load. And you divide that 

building load by your SEER value to come up with 

the watt hours that you consume. 

So, these were used as part of the 

calculation algorithm to come up with energy 

consumed, and then ultimately the operating costs 

during the cooling seasons, and to operate the air 

conditioner or the heat pump during the cooling 

season. 

So, these are full-load compressor 

numbers that were generated and, again, multiplied 

by 95 to come up with your season load. And divide 

that by efficiency SEER to come up with your energy 

consumption. 

MR. BROOKMAN: Jim. 
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143

 MR. CRAWFORD: Okay, thank you. I'm 

sorry. 

So, if you would go -- If you would plug 

and use this to define the load, -- And in the 

calculation of SEER they use fractional bin hours 

for each bin. So, there's a percentage of time 

that you're operating between 65 and 70; a 

percentage of time that you're operating between 70 

and 75, all the way up to between 100 and 105. 

If you would change out those fractional 

bin hours and multiply them by the total numbers, 

-- Well, lets go to Region IV. -- by this number, 

you'd end up with the number of hours in each of 

those bins that, once you did the calculations, 

you'd come up with the same SEER value that you got 

using fractional bin hours. 

MR. BROOKMAN: Jim. 

MR. CRAWFORD: All right. The, the 

reason I asked the question is that cooling load 

hours don't correlate real well with compressor 

running hours, and compressor running hours is, you 

shouldn't be counting the time when the compressor 

is, is running as off-time. 
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144

 So, you're, you're in danger of doing 

that. I, I think is that, that -- I'll stop there. 

MR. BROOKMAN: Well, what would you 

suggest the Department do to remedy that? 

MR. CRAWFORD: Well, I, I think that, 

that I, I'm not going to try to solve that, that 

problem extemporaneously. 

MR. BROOKMAN: Could be --

MR. CRAWFORD: It's a nontrivial issue 

that I've raised. 

MR. DOUGHERTY: Yeah. I'm starting --

That exists now, and so if I'm starting with 

something now not quite right, I'm making it worse. 

I should go back one more step, because 

currently the test procedure that has those numbers 

in it for use in coming up with operating costs --

So, if, if they're wrong here, they're also wrong 

as applied. 

MR. BROOKMAN: I'm wondering, Karim, for 

example, do they -- Are the manufacturers, are they 

able to say, to, to, to, to document the kind of 

the difference that Harvey's, pardon me, that Jim 

is describing there? 
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145

 DR. AMRANE: Again, we've been -- I 

mean, this, those hours have been used, like 

Brian's saying, from, since the beginning. So, 

again, I mean, we haven't looked at that. 

Maybe it's time to go back and look at 

it. I don't know. 

I mean, it's something that, you know, 

if Jim has some concerns about it, we need probably 

to dig into it a little more, I feel. 

MR. CRAWFORD: If you listened carefully 

to what Brian said, those are the hours equivalent 

to running at the rated performance of the unit. 

MR. DOUGHERTY: That's right. 

MR. CRAWFORD: Load at the rated 

conditions is much higher than the, than the load 

during most of the system. They do not represent 

the running hours, the compressor running hours. 

And, you know, industry is in no better 

position to address that question than is NIST. 

And as long as the chart's up there and I've got 

the microphone, if I am not mistaken, Region I is 

kind of like Key West, and not much, not much more 

than that. 
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146

 MR. DOUGHERTY: Yes. 

MR. CRAWFORD: The tiny tip of southern 

Florida. 

DR. AMRANE: It, it doesn't come up to 

Tyler. 

MR. CRAWFORD: And Region VI is what? I 

believe Alaska. 

MR. DOUGHERTY: Region VI is in 

California. But, yeah, Canada often uses VI. 

MR. CRAWFORD: Point being that of those 

having heating and cooling ranges is somewhere 

between -- It's not a huge spread. 

And speaking of huge spreads, I would 

speak to the test conditions under which you 

suggested one might test the thermostat for pump 

heater control. 

MR. DOUGHERTY: Okay. 

MR. CRAWFORD: I think you said 65 plus 

or minus two degrees. 

MR. DOUGHERTY: I did. 

MR. CRAWFORD: I think it, it's probably 

unrealistic to anticipate that the thermostat used 

for that function would be accurate to that kind of 
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147

 precision. 

MR. DOUGHERTY: And there's an effort in 

the test procedure to actually ask the manufacturer 

first what the values would be, and to agree if, to 

verify those. If they're in the bracket, use what 

was given to you and say, "Okay, that's what," so 

we have repeatable numbers. 

MR. BROOKMAN: Paul, you want to comment 

here? 

MR. DOPPEL: Yeah. Paul Doppel. 

Just another point that variable-speed 

systems, again, would be operating, unlike 

single-speed, which would be operating on and off 

in the cooling seasons, and variable-speed 

operating systems would be operating probably more 

at the time, but at a probably much reduced energy 

consumption. So, --

MR. DOUGHERTY: Right. And I think the 

test was to confirm that, so I think in some 

degrees, hopefully would capture that. 

MR. BROOKMAN: Karim? 

DR. AMRANE: I guess I have another 

question for Brian. Have you done some tests? 
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148

 Have you measured that, that off-mode 

energy consumption? No. 

MR. DOUGHERTY: No, I have not. There's 

a Petition to try to get some testing done. 

In fact, we met this week with our 

counterparts here to, to discuss having that 

opportunity before the Final Rule is, is issued. 

MR. BROOKMAN: Are we ready to move on 

now? I think so. Okay. 

Oh, Harvey, go ahead. 

DR. SACHS: Harvey Sachs. Brian, this 

may be an area you're going to get to, but it keeps 

coming back and haunting me, that the objective I 

believe from EISA was to bring off-mode power out 

of the shadows. 

And it's very important to set up a 

rating or reporting method that will encourage 

methods, technologies that minimize that. A, a 

thermostatically controlled heater that kicks in at 

40 degrees instead of 65 would be an example. 

I hope that you all are paying attention 

to that as you're developing a rating method. 

MR. DOUGHERTY: The test procedure seeks 
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 to, to generate a representative value for the 

power consumption value of the unit during the 

shoulder seasons and during the heater seasons. 

How it's used thereafter, I defer. So, --

MR. CRAWFORD: What would Justice 

Roberts say? 

MR. BROOKMAN: Karim? 

DR. AMRANE: Yes. Karim Amrane from 

AHRI. 

For example, you're proposing some 

additional tests. 

MR. DOUGHERTY: Yes. 

DR. AMRANE: But, you haven't done any 

tests so far? 

MR. DOUGHERTY: I've had limited 

communications with folks, so we will be better 

informed about this. Go ahead, please. 

DR. AMRANE: So, you're expecting 

industries to try what you're proposing here to see 

if it works in a lab? Or, how -- I mean, are 

you -- I mean, because these are -- I mean, again, 

before going forward with this we should learn, as 

an industry, that this is going to work. 
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 And I'm not sure finalizing -- When are 

you expecting to have a Final Rule on this? 

MR. BROOKMAN: Graham, can you comment 

on that? 

Graham Parker. 

MR. PARKER: Graham Parker, Pacific 

Northwest National Lab. 

That's a good question. And we do have 

a slide on that. 

I believe the slide says 2011. 

DR. AMRANE: That doesn't give us a lot 

of time here to, to test, make sure that, that we 

can get to billable numbers and things like that. 

MR. BROOKMAN: Okay, thanks for raising 

it. 

Jeff? 

MR. NICHOLS: Could we go back to the 

testing requirements and walk through that, I mean, 

a little bit in more, more depth? 

MR. DOUGHERTY: Sure. Unfortunately, I 

don't have a slide prepared, but, but, yes. 

So, the idea would be, is to have this 

test occur after the cooling tests are conducted, 
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 whether it be heat pump or air conditioners. 

In terms of heat pumps, you do it before 

you start your heating tests. So, it would be in 

that transition period from your outdoor chamber, 

from cooling to heating outdoor conditions. 

So, so, that's the -- If your, if your 

system that has either, does not have a crankcase 

heater or has a crankcase heater that's on all the 

time, you would operate for at least -- I can't 

remember if it's 20 minutes, but will collect data 

over a five-minute period where you would integrate 

the power. 

And that would be used at your average 

value for your off-load energy consumption in all 

cases. That would be your P1. 

And P2, because you do not have a 

crankcase, or it's on all times, it's not affected 

by outdoor temperature. 

MR. NICHOLS: And that was within a 

range? 

MR. DOUGHERTY: I'm trying to keep these 

in a range, and maybe these bracketings, but trying 

to stay close to your dry bulb. But, now I think 
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 we're allowing, as you work towards that 70 degrees 

on the indoor, allowing that to occur so you're not 

holding up the testing. 

So, there's a bracket on the indoor 

saved to where it would naturally go in extended 

idle condition. And then, so, yes. 

So, then 656 is, is the target value for 

-- Excuse me. Sixty-five is only the target value 

if it's a thermostatically controlled unit. 

If it's not thermostatically controlled, 

it should not be affected by outdoor temperature, 

so you should be able to make that while it's 

sitting idle. Nothing's working long. 

Now, it will get where you can get 

representative energy, where you can get an average 

value. So, that's the first, where it doesn't have 

a crankcase heater; where that's well-understood. 

I'll -- It's on all the time. The next 

time would be if you have a thermostatically 

controlled crankcase heater and where it's allied 

on a heat pump. 

And in that case, where it's only, it's, 

the purpose is to test at an outdoor temperature of 
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 65 and see what the parasitic power is in that 

condition. Now, if that crankcase heater is on, 

it's going to be reflected as being on all the 

time. 

If that heater takes off, we're going to 

say it's off the time, not wanting to add too much 

test burden. So, that's the next. 

The final case is if it's, is actually 

to start at a temperature in this outdoor to start 

before it's cycling. All these are off, and we're 

asking the manufacturer to tell us: 

What is the temperature, outdoor 

temperature is going to be representative of coming 

on, and what's the representative temperature where 

it could stay on continuously, and then do a linear 

interpolation of those numbers based on that amount 

of time associated with operating at the different 

outdoor temperatures that are used as part of the 

HSPF calculation. 

But, as far as the tests, it's to start 

with your chambers at a warm enough outdoor 

condition where your crankcase is not operating, 

and then decrease that temperature to where it does 
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 start to cycle on. 

At that point, see if that's within two 

and a-half degrees of what the manufacturer said. 

If it is, use the manufacturer's numbers as to that 

for your calculations. 

Then you're supposed to decrease the 

outdoor temperature between ten and 15 degrees 

further on the outdoor side, and then monitor again 

how much, for an interval, how much is that cycling 

on, and versus off. 

So, you get a two point on your linear 

point as far as percentage time on. And then you 

can extrapolate that to see if that correlates with 

what the manufacturer says, whether to be a hundred 

percent on time --

Sorry. We're in the weeds here. 

-- to see if that's a good number. 

If it is, you use the manufacturer's 

numbers to say, "Okay, 65 is first time it's going 

to cycle on, and going to off-cycle once it gets to 

ten degrees outdoor." 

And so you would adjust linearly refer 

to periods of specific operation. I'm not sure if 
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 that quite made sense, but at, it's a long type of 

a process. 

But, that's, that's the idea behind it, 

is trying to some degree ask the manufacturer what 

would be the characteristic response of this 

crankcase heater, and to the degree possible, 

verify those numbers before using them in a 

calculation. 

MR. BROOKMAN: Jim, go ahead. 

MR. CRAWFORD: Jim Crawford. 

I would urge that NIST communicate with 

AHRI Small Unit Engineering Committee on this and 

come up with something that represents both the 

rigor sought by NIST, as well as the feasibility 

sought by the manufacturers of the equipment. 

I suspect that there's more variability 

than you may have, --

MR. DOUGHERTY: Okay. 

MR. CRAWFORD: -- than you may be taking 

into account. 

MR. BROOKMAN: Okay. 

Harvey. 

DR. SACHS: Harvey Sachs. 
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 Brian, this seems to be a very hard 

problem, and I don't know much about thermostatic 

controllers, but, one, I know of two end members. 

One would be -- One is that you will 

attach sitting somewhere in the sheet metal. The 

other extreme, some premium manufacturer of 

compressors says, "I'm going to put that inside the 

can." 

MR. DOUGHERTY: Right. 

DR. SACHS: "I'm going to put that 

inside the, inside the compressor can." 

And at that point the time constant for 

changing the temperature of the test chamber 

becomes a very different animal in terms of 

response to that system. 

MR. DOUGHERTY: Well, it would have an 

affect as far as: How long do you think you should 

sit and wait until it's gone? 

But, because we're going to maintain 

fixed temperatures during these times, even though 

we're going to two different values. So, it's not 

as though the thermostatic is going to respond 

differently in, based on the rate of change in the 
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 outdoor temperature. 

DR. SACHS: Sure, if, if I'm dropping 

that rate quickly. But, will I have a low response 

time because it's mounted well inside the can? 

Then I might well have gotten down to an 

outside temperature of 35 before the inside of the 

can has gotten to 65. 

MR. DOUGHERTY: Yeah. Okay. 

So, if it's going to be, the outdoor 

condition's going to be steady-state for these 

tests. 

DR. SACHS: I understand. But, 

depending with what I'm suggesting, --

MR. DOUGHERTY: How long we wait before 

we'll start seeing --

DR. SACHS: Is that -- If you're trying 

to get hours out of this, you have to control for 

the rate at which you're changing the chamber, I 

think. 

MR. DOUGHERTY: Well, I think once you 

got to the steady-state conditions in the chamber, 

the question is: How long do you have to wait 

until you can get repeatable responses from your 
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 system? 

DR. SACHS: Right. Right. Right. 

Thank you. 

MR. BROOKMAN: Jeff. 

MR. NICHOLS: Harvey's got a very good 

point, because you have, as you require, you soak 

the system. And if someone gets innovative and 

puts something inside the compressor, that soak 

time is substantially higher than a thermostat out 

in the air. 

I mean, you're talking in terms of 

several hours for soaking. 

MR. DOUGHERTY: Okay. 

MR. NICHOLS: In my opinion it's a very 

burdensome test for the minuscule value that is 

being received. It's not worth the pay. 

The payback's not there for that, that 

burden. 

DR. SACHS: But, the, the flip side of 

that, --

Harvey Sachs again. Yes. 

-- is the -- I'm trying to think in 

terms of strapping that, minimize the use of this 
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 off-cycle power, and something which has a longer 

integration constant. Something which does require 

the heater to come up during the shoulder seasons 

which has a high dial usually actually has an 

advantage in terms of energy use. 

So, I'm just asking you that you set up 

your writing nod in the way that, urging managers 

to design in ways that reduce this off-load power. 

Thank you. 

MR. BROOKMAN: Okay. 

Other comments on, on this? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Let's move on. 

MR. DOUGHERTY: Before I leave this, a 

couple of key points here is that the off-mode 

internal consumption will not be used to adjust the 

existing metrics of CNF. Doing so would have the 

following impacts: 

You'd change the cooling season 

descriptor of SEER to an annual descriptor in the 

case of air conditioners, and into a part-year 

descriptor in the case of heat pumps. 

And, you would change SEER from being a 
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 regionally independent quantity that applies 

regardless of latitude or longitude, to one that 

would be specific to a particular combination of 

cooling season hours, heating season hours, and 

shoulder season hours. 

So, I want -- I -- So, I just want to 

maybe head something off at the pass. So, we'll 

require in the test procedure when the Energy 

Conservation Standards become effective that the 

measuring of P1 and P2 be conducted if this goes 

forward. 

And so it's, it's not something in the 

near term, but, in fact, it's something that will 

be proposed for additional test burden five years 

out or so if it, if it's enacted. 

So, the questions that are in the, the 

written document, the published document is we seek 

comments on this definition of "off-mode." And, as 

far as generally the algorithm that we've been just 

going over, which appears in this Section 3.13 of 

the regulatory language part of the Notice of 

Proposed Rule as to this algorithm of going through 

and coming up with a representative character, 
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 characterization of how this, if it is a 

thermostatically controlled crankcase, operates. 

MR. BROOKMAN: So, why don't you back up 

one slide? 

Comments on these key points with 

respect to off-mode? 

Karim. 

DR. AMRANE: I think we agree with, 

with, with DOE on, on having this off-mode being 

totally separated. 

MR. BROOKMAN: Harvey? 

DR. SACHS: We do, too. 

MR. BROOKMAN: Okay. Concurrent. 

DR. SACHS: Harvey Sachs. 

MR. BROOKMAN: Thank you. We're going 

to move on. 

MR. DOUGHERTY: Okay. 

MR. BROOKMAN: Jeff's got a comment. 

MR. NICHOLS: And perhaps this isn't the 

proper meeting, but I guess, assuming if, if that 

gets enacted for testing, we, is to say I guess 

I'm, I don't know what the Standard is to know what 

the test procedure is, so am I going to be subject 
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 to multiple samples like I am for my, my SEER and 

HSPF requirements, or is this one item, since it, 

it's only being baked into the annual energy 

concepts, or what's the conceptual framework? 

MR. ANDERSON: This is Wes at DOE. That 

is a Standards question and it will be addressed in 

the NOPR or, or, or at the NOPR meeting for 

Standards of CAC. 

It's -- We are setting measures now. 

MR. NICHOLS: Okay. 

MR. BROOKMAN: Karim? 

DR. AMRANE: That begs another question. 

I mean, we are talking about -- What? -- less than 

a year. 

Okay, you going to come -- You going to 

finalize this test procedure at the same time 

you're finalizing rulemaking on central AC and 

furnaces, and at the same time you're going to get 

the manufacturers to come up with a, you know, with 

a binding off-mode. 

And where there's been no test done on 

the equipment, we don't even know if the test 

procedures will work or not. I mean, I've -- Those 
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 issues are very important for us, and I think that, 

I hope that DOE is taking those into account, 

because we are running out of time here. 

MR. ANDERSON: Wes Anderson, DOE. Yes, 

we are. Thank you. 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. And it's 

perhaps foreshadowing Standard-setting, but we do 

have a difference here between P, P1 and P2 on the 

one hand, which are measurable numbers, the, the 

power consumed during off-mode, presumably, with 

the heater at once present and in operation. 

It's relatively easy to do that as a 

certified number. It's extremely difficult, I 

think, from this conversation, to do the, the 

hours. 

And I wonder if DOE would meet many of 

its objectives by restricting the certification to 

the P1/P2 class, and then it's much less important 

how we do the computation of the annual energy as 

simply an arbitrary algorithm. 

MR. ANDERSON: This is Wes Anderson of 

DOE. 
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 Could you put that also in your --

DR. SACHS: I promise to try if I 

remember it. 

MR. ANDERSON: Okay. 

MR. BROOKMAN: Thank you. 

So, we ready to move on? 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. 

MR. DOUGHERTY: The second aspect 

brought forward in the energies legislation of 2007 

was the idea of where, for air conditioners and 

heat pumps, as well as furnaces, in addition to a 

national Standard which we have now, that they 

could investigate the possibility of implementing 

regional Standards, in the case of air conditioners 

and heat pumps up to a maximum of two regional 

Standards, and overlay to the national Standard. 

And so the question then becomes to, to 

allow, though, consideration: Is there a need for 

changes in the test procedure? 

And so we'll, we'll go through some of 

that right now as far as the influencing factors, 

then, are constraints on the test procedure, given 
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 the framework that exists. Out of this came the 

idea that, "Well, there's a leading interest to the 

Standards rulemaking to these regions that would be 

defined as hot humid and hot dry. 

Because of that focus, then, the 

necessary parameter of choice and the operating 

mode of choice is therefore cooling. 

One of the requirements of EISA that 

also influenced the, the, the test procedure here 

is the fact that when you define a region, it must 

be composed of contiguous States. 

So, in the case of a calculation that 

has weather data, it will depend on what States are 

selected for that region as to what the, the 

temperature distribution that will be considered in 

coming up with that rating if seasonal rating is 

pursued. 

And it's dependent, then, ultimately, on 

these regions, what States make up these regions. 

And that, in turn, depends on these established in 

Standards rulemaking that are going on for central 

air conditioners, and also furnaces and boilers. 

And ultimately, then, too, given the 
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 current structure of the test procedure, how can, 

can we go about addressing a regional issue? And 

given that current, the current approach of using 

seasonal representation through the SEER 

descriptor, can that be used in a way to allow an 

evaluation for a regional metric? 

So, as far as the test is concerned, the 

options before it were: Let's make no changes to 

the test procedure, not with regard to the 

laboratory testing or the calculations. 

We will use the existing metrics, the 

national metrics of SEER on this case because it's 

the cooling-dominated focus as the regulating 

focus. So, if it was to be used, if a regional 

Standard was found to be feasible, we would use a 

SEER value that would be higher than what is 

required at the national level. 

So, to, to sell in that particular 

region you'd have to have a SEER value that's 

otherwise higher than what was specified for the 

region, for, for the nation, excuse me. See, so 

that's one option: Don't change the test procedure 

at all. 
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 The second is: Don't add test burden. 

So, in that case, you don't add to the testing in 

the laboratory, but you look to think that could be 

done on, on paper, and one would be coming up with 

SEER data that is more aligned with the weather 

conditions in the area you're considering. 

And the third option there is: Add to 

the test burden. Add both laboratory tests and 

alternative calculation algorithms that would allow 

you to come up with a region-specific regulate-, 

metric. 

And you could come up with SEER hot dry, 

or hot humid, or some other within the bound 

allowed you by, by, by legislation. 

So, we chose to go the all-encompassing 

route with the, with the, the understanding that 

the going from a proposal to the fodder rule, it's 

easier to go more expansive and curtail it back, as 

opposed to coming up with something more focused 

and expand it. 

So, we chose in the Notice of Proposed 

Rule to, to go the route of saying: Let's see the 

option of adding testing burden, and along with 
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168

 calculations that are new, and, and focus those, 

though, on the, to, on the dry region and see what 

kind of reception that gets. 

And it's kind of taking a step back here 

in part on Slide 52. Let's maybe discuss what we 

seek with regard to a regional regulating metric. 

Certainly from the DOE's standpoint it 

would be one that would allow better, that would 

promote better use of our natural resource, our 

energy resources. 

From the standpoint of the consumer, 

they would like information that would help them 

determine their, their energy bill. And part of it 

that is -- Most of that is usually associated with 

seasonal operation: how much energy you consume 

over a season; how many kilowatt hours you consume. 

So, SEER has done, has attempted to do a 

job and providing more information. But, as more 

utilities also go to split-meters and have, and are 

capable of handling a charge and demand to that, 

maybe that metric falls short. 

So, maybe there's a need to transition 

to some degree because of the evolution of the 
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 metering and charge practices. 

As far as another thing, utilities often 

seek information that helps them toward their 

avoidance of peak-demand situations. So, they 

would be most likely interested in full loads 

conditions, and so regulating Regulations that 

would help them in understanding those full-load 

characteristics. 

And finally, this can be used by 

manufacturers to help differentiate the products 

from one another. 

So, at this point I'll throw out the 

question that's, appears as Number 9 in the, in the 

published Federal Register Notice. DOE seeks 

comments on the usage and effectiveness of the SEER 

hot dry metrics and its advantages and 

disadvantages. 

There has been some feedback provided 

because of the timing from the Standards Rulemaking 

public meeting that occurred, and comments that 

have occurred and come into this, to this meeting. 

And so we would like to see if those comments would 

like to be reiterated here, or otherwise new 
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 comments as to whether or not SEER hot dry is the 

way to go, and if not, potentially how to proceed, 

to proceed. 

MR. BROOKMAN: Yes, Molly. 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

First of all I just want to note that 

the NOPR Issue Number 9 is phrased differently in 

the printout, and I like the way it's phrased in 

the printout better --

MR. DOUGHERTY: Okay. 

MS. TROMBLEY-McCANN: -- because in the 

printout it specifically calls out the use of EER 

as opposed to SEER hot dry. And that is definitely 

the priority of the California utilities. 

Also, the way SEER has been designed 

with regard to NOPR, it does not adequately 

represent conditions at full load. It doesn't give 

the manufacturer the opportunity to differentiate 

products that will perform very well at high 

temperatures, and EER, at 95, is going to do a much 

better job of that. 

We in the past said, and I would say 
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 again that we would prefer an EER at 115, but I 

think we're not going to push our luck at this 

point. But, I do believe an EER is a much more 

appropriate metric for this region and for the 

goals that you've listed on that slide. 

MR. BROOKMAN: Karim? 

DR. AMRANE: Karim Amrane, AHRI. 

I believe that the first slides here 

don't talk about the Consensus Agreement, but I 

think we'll have to talk the, the Agreement, 

because we specifically agreed to EER in those 

regions to address the concerns that, that Molly 

raises. 

So, we would like to abandon this idea 

of SEER dry, and dump the Agreement, and I believe 

we'll resolve these issues. 

MR. BROOKMAN: Okay. Thank you. 

Harvey. 

DR. SACHS: Harvey Sachs. 

I'd like to turn attention in this 

context to the top paragraph on Page 32-, 31240, 

Column 1. 

MR. BROOKMAN: Of the Federal Register? 
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 DR. SACHS: Yes. The last sentence 

says, "EER and COP, for example, cannot be used." 

MR. BROOKMAN: Wait a second. Let us 

get there. 

Thirty-one- --

DR. SACHS: Two-forty. 

MR. BROOKMAN: -- 240. Thank you. 

DR. SACHS: After the section that, "... 

SEER and HSPF ...." Well, let me go up one. 

"Notably, DOE does not have authority to 

use a performance metric other than SEER and 

HSPF...." And continues. 

"EER and COP, for example, cannot be 

used." 

MS. KOHL: Sir, this is Betsy Kohl. 

Just to cut off this discussion, we're still 

considering that issue. 

DR. SACHS: Thank you, Betsy, but I feel 

it's very important to make two points. I 

appreciate that you all have had a filing and some 

discussions that may be helpful on this. 

First point is that I'm a simple man, 

but I've tried my best to understand the rating 
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 method, and SEER for single-stage equipment is 

nothing except a coefficient multiplied by EER at 

82. 

We would assemble to say that we cannot 

use EER because we've been using the EER at 82 

since 1979. 

The second point I want to make is with 

respect to the defined SEER hot dry. And again, I 

may have misunderstood it, but this proposes to use 

an adjustment of the bin hours, but still to base 

that for simple equipment on the measured 

performance at 82. 

This absolutely confounds the 

engineering decisions that would be made in design 

as I understand it of a unit optimized for 

high-temperature performance. This is the most 

clever, ingenious proposal I've seen for defeating 

the intent of a hot-dry SEER. 

It must be based on a temperature at 95, 

for which the measurements are already required in 

the rating method, instead of being based on a, a 

steady state at 82. Thank you. 

And I'm -- I hope I'm wrong in my 
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 inference, but --

MR. DOUGHERTY: I believe you are, 

Harvey, because --

DR. SACHS: Please explain it to me. 

MR. DOUGHERTY: Two steps here. As far 

as the shortcut method that's in place now, the 

reason the shortcut method came in place was it 

gave you the same SEER as you did if you used the 

bin. 

And to capture the effect of the 

regional performance, you, in fact, are forced to 

go to the bin calculations for the single source 

for hot-dry system if you want to go that. 

So, maybe we missed the boat. So, 

that's what the intent was to be in there. 

And I hope that's in there. It's used a 

different bin distribution as far as a weather 

data, and ended up with a load because of the, 

because of it. 

You actually end up with a, an outdoor 

temperature that is exactly what we have now, 95 

degrees. So, you're hot now. 

The SEER hot-dry as proposed now does 
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 not do it as far as identifying performance at the 

more extreme conditions. 

DR. SACHS: And, thank you, Brian. 

Again, this is Harvey Sachs, and at that point I 

found myself somewhat surprised as I tried to 

understand Table 3.2 on the following page, 31241, 

where we still have a situation in which we are 

basing our calculations on a system in which 69 

percent of the bin hours are at temperatures, as I 

recall, less than 79 degrees. 

But, I'll support that in my statement 

so that, again, in terms of the, the goal here of 

reflecting society's interest in high-temperature 

performance. Even though I think I may have been 

early in proposing this approach, I'd like to 

formally renounce it. 

Thank you. 

MR. DOUGHERTY: You're right, Harvey, as 

far as the, the, the -- Because of the way the 

legislation is written, and that you have to have 

full States included, and contiguous States, and 

you have to partition up for a four-State region 

that ultimately was proposed here, we did look at 
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 the two-State region, too, to get into calculations 

of hot and dry. 

But, because of the population along the 

coast, and because you have California, it really 

pushes things to a much more moderate condition. 

So, it, it drives this thing to a large degree, and 

it really starts to separate what we can even call 

close to hot-dry. 

MR. BROOKMAN: Molly? 

MS. TROMBLEY-McCANN: I want to 

reiterate the vague NRC -- I just -- Molly 

Trombley-McCann. 

I wanted to follow on Harvey's statement 

and note that we also submitted comments in support 

of the SEER. We would also like to backtrack and 

renounce our support for, for SEER hot dry in favor 

of EER, based on, you know, subsequent 

conversations with Industry and the Consensus 

Agreement. 

We feel that that is something that the 

Department can do and should do as the best option. 

I also did want to note that, you know, we don't 

support SEER hot-dry. 
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 We support EER, and there are a host of 

questions about how long SEER is supposed to be 

tested in this NOPR. But, not only do we not 

support SEER hot-dry, but in particular, we have a 

lawsuit concerning how it's to be. 

MR. BROOKMAN: So, you reflect that in 

your detailed --

MR. DOPPEL: Mitsubishi would oppose 

SEER hot-dry because it would increase testing 

burden on manufacturers, and we're not in favor of 

that. And, we would support a Consensus Agreement. 

MR. BROOKMAN: Thank you. 

Harvey? You want --

Jim, you want in here? 

MR. CRAWFORD: Harvey? 

DR. SACHS: Jim, go ahead. 

MR. CRAWFORD: Age before beauty. 

DR. SACHS: I know. That's what I said. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Jim Crawford. 

The, the interesting thing about this 

table that Harvey points out is that is, it 

suggests that the hot dry climate is very, very 
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 cool --

MR. DOUGHERTY: Right. 

MR. CRAWFORD: -- and temperate, to 

which Brian alluded. 

If you look, for example, at the bins 

that represent 90 to 100 degrees, there are less 

hours, excuse me, a smaller number of the seasonal 

hours in that bin in the hot dry climate than there 

are in the standard climate. 

And if you look at the coolest bin, you 

have double the number of hours in the coolest bin 

in the hot dry climate than you do in the national 

calculations. And the significance of this is that 

if, if that's all you changed, the SEER in the hot 

dry climate would be higher than, than the national 

calculations. 

The reason I believe, and I've not 

gotten into all the details, but, but the reason 

that isn't is, at least to some degree, a function 

of two things, one of which is the indoor 

conditions have been changed, and indoor conditions 

have a significant effect on the performance of a 

system. 
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 And the second is that the load line has 

been changed. And I'm going to have to look more 

at the load line, because it looks like, again, the 

climate shown is a milder climate than the national 

figures. 

MR. BROOKMAN: Okay. Thank you. 

Harvey. 

DR. SACHS: Harvey Sachs. 

I'd like to ask a question about the 

last two columns, the right-most columns in Table 3 

dash-2. I'm inferring on no particular data, that 

the resulting cooling load profile reflects the, 

the building and does not include the effects of 

degraded performance of the equipment. 

As the lift becomes higher, the lowered 

performance -- I don't say "degraded." That's 

value-laden. 

MR. BROOKMAN: He was searching for it. 

You might need to restate that. 

DR. SACHS: Sure. My inference --

Repeating, Harvey Sachs. -- on the last two 

columns of Table 3 dash-2, Resulting Cooling Load 

Profile, that this refers to the load line and to 
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 the change in load of the building, but does not 

affect the change in performance of the equipment. 

It seems that the equipment operates at 

a constant EER throughout these bins. 

MR. DOUGHERTY: I believe that was how 

that was calculated. These -- This work in 

particular was done by PNNL, and so they were 

providing me with the, the bin distributions to, to 

add to the testing. 

So, unfortunately, I believe you're 

correct, Harvey, but I'd have to check with the, 

the, the individual who worked that to, to -- I'll 

check. I'll confirm it. 

DR. SACHS: Please do, --

MR. DOUGHERTY: Yeah. 

DR. SACHS: -- because with all due 

respect to Paul's magic equipment, it would seem to 

me that I'm missing the point, and my operating 

hours will go, will be greatly impacted if the 

equipment is running at the lower EER than we would 

expect, as I believe would be reflected in this 

profile. 

MR. DOUGHERTY: I'll check. 
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 DR. SACHS: Thank you. 

MR. BROOKMAN: Okay. 

Jim Crawford. 

MR. CRAWFORD: Dr. Sacks, your 

arithmetic is better than that. Your running hours 

are determined by the capacity, not by the EER. 

The power consumption is determined by 

the EER and the running hours. 

DR. SACHS: Thank you, sir. 

MR. BROOKMAN: Okay. Okay, let's keep 

moving along. 

MR. DOUGHERTY: Okay. Because of the 

expectation that we would get the response that we 

received this morning, -- And, and thank you for 

following up, because we, as I had mentioned, we, 

we had the opportunity to sit in at the, the 

Standards public meeting and see the comments. --

at this point, to save your time, potentially, and, 

and all our time, I wasn't going to go into the 

detail any further of SEER hot dry unless someone 

wants to do that. 

MR. BROOKMAN: I don't, I don't see 

anyone -- I'm casting my eyes about. 
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 MR. DOUGHERTY: Thank you. 

MR. CRAWFORD: Off-line. 

MR. DOUGHERTY: Yes. Okay, agreed. 

Okay, changing now to some -- In fact, 

one of the things that Harvey brought up earlier, 

some related extras that are proposed, and some 

admissions, at least some admissions, and probably 

certainly others. 

One extra is in, in bringing to the 

forefront this off-load energy consumption when you 

test a coil-only system. So, this is a system 

where it, it comes without its, its blower. 

It's, it, it would have to typically get 

its power from the, the furnace to which it is 

retro, with which it is applied within field. 

There's no stipulation to your test 

currently that you have to have a certain size 

transformer, and also whether or not you need to --

There's no specific statement whether or not you 

would need to meter the power consumed, albeit 

small, by that transformer. 

So, in the spirit of trying to cover 

everything as EISA is pointing us to, there's a 
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 proposal in there for such coil-only systems to say 

you have to use either a 40- or 50-volt/amp 

transformer to power your indoor site controls to 

allow the units to be tested and to actually have 

that power system into the overall metering of the 

system, the second bullet there. 

Question? 

MR. BROOKMAN: Harvey Sachs. 

MR. DOUGHERTY: Okay. Sorry. 

DR. SACHS: Thank you, Brian. This is 

Harvey Sachs. 

You have used the term "transformer" 

rather than the more general term "power supply." 

MR. DOUGHERTY: Okay. 

DR. SACHS: And given what's happened in 

other industries, it would certainly seem to be in 

the public interest to consider using some default 

in allowing the manufacturer to show that the unit 

is to be installed with a better unit. 

This would be comparable to the way we 

treat fan power in the air-conditioner test. 

MR. DOUGHERTY: So, you wanted a default 

that -­
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 DR. SACHS: Well, you're requiring a 40-

and 50-amp power. What happens if Jeff comes in 

with a unit that's using a very low-level power 

supply to drive his forward? 

Should he not get some credit? 

MR. DOUGHERTY: Well, if it, it's 

provided in the unit, certainly they'll get that. 

DR. SACHS: But, if this is a coil-only, 

would it not be provided with it? 

MR. DOUGHERTY: Correct. 

DR. SACHS: So, now, given the potential 

for it, maybe that will be captured when Jeff does 

his with coil units, or when he does his furnaces, 

because now he will get credit on the, the front 

side. 

But, I hate to say "standard setup" with 

a, in a way that will distance, discourages 

innovation that would save energy. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: Well, if I may, let me 

address Harvey's point first. I, I understand the 

point that he's making, and I think it deserves 

consideration. 
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 However, we need to keep in mind that 

the overwhelming majority of systems in North 

America in the foreseeable future will probably not 

be variable-speed, and that means that they will be 

using contractors, and "transformer's" the correct 

term. 

"Power supply" carries a, a bit of an 

implication of also conversion from AC to DC, which 

would not be the case for most systems. 

The second point is addressing the 

substance of the issue, and, and that is that if 

these coils are currently tested without 

transformer power being accounted for, reasons for 

wanting to account for it is, are, are fairly 

clear. 

But, it's also fairly clear that the 

effect of that will be to reduce the SEER ratings 

of existing rated equipment. And I was rather 

under the impression that that was not the intent 

of the current rulemaking process. 

MR. DOUGHERTY: You bring up a good 

point, Jim. At least it wouldn't affect it in the 

near term, but you're right. 
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 In five years out, or whenever the, the 

Conservation Standards were enacted, you'd have an 

effect on that rating against an existing piece of 

equipment. 

MR. BROOKMAN: Go ahead. 

MR. DOUGHERTY: Okay. Going on to the 

second bullet, then, as we mentioned earlier when 

we were talking about the additional measurements 

that would be made to try to affect this 

correlation during the cyclic degradation tests 

during the steady-state cycle, we talked about 

reducing the sampling interval from five minutes to 

ten minutes. 

So, there's a new recommendation in 

there. Since we're going to do it for that test, 

maybe we should just, you know, bite the bullet and 

put five minutes in as the, as the maximum planning 

interval in all cases, because we've come a long 

ways since the, the test procedures was originally 

put in place. 

And ten minutes really was not, doesn't 

give you much resolution. It would be nice to have 

more measurements; rather than having four 
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 measurements, having seven measurements for 

calculations of your EER. 

And so that's gone into. Given the 

progression to automation in the laboratories over 

the years, there's no reason they couldn't achieve 

that. 

The last one gets back to Harvey's point 

earlier in that there's a shortcut system for 

calculating SEER, and it is a very simple one of 

the EER during the B Test of two times the 

part-load factor evaluated at a load factor of .5. 

And so it's just EER B times 1, minus 

the CC B over 2. And it's a very simple 

calculation, but yet that calculation was generated 

because when they first came up with the algorithm, 

they found that, in fact, they correlated well. 

So, if you do the full-blown, full-blown 

bin analysis versus the shortcut method, you get 

very close to the same SEER value. And I don't 

know more than that, but that's why it came into 

being. 

But, maybe it's time to revert back. 

Maybe it's time to revert back so we can avoid that 
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 kind of confusion, and also get some benefits. 

Because it is tied to EER B, maybe it 

emphasizes A to B. So, if we go for the bin 

calculation, it would give more rating to the A 

Test, and it would avoid the confusion we have as 

to: Where did this method come from? 

And ultimately, if we -- It would 

promote consistency because two, they're based on a 

bin. Maybe in five years from now we should 

implement that for single-speed. 

MR. BROOKMAN: So, let's just pause 

there. Comments on these last two bullets? 

Jim Crawford. 

MR. CRAWFORD: Just the obvious comment 

on the middle bullet there that the -- Excuse me. 

I'm sorry. -- the last bullet, that the only 

reason that one would consider as a change is 

because you expect it's going to change some SEERs. 

And so that's the same issue I mentioned 

a moment ago, that if we're positive doing things 

that is going to change the writing of existing 

rating equipment, that needs to be taken into 

consideration as to the scope of the, of the 
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 rulemaking. 

MR. BROOKMAN: Um-hum. Thank you. 

Paul? 

MR. DOPPEL: Paul Doppel, Mitsubishi. 

The, the current way of doing the 

testing for variable-speed systems puts an extra 

burden on variable-speed manufacturers because 

they're required to do ten tests to calculate SEER 

and HSPF, as compared to the four required by those 

allowed to use the short-cut method. 

So, we have tremendous testing burden 

placed on us. 

MR. BROOKMAN: So, what are you 

suggesting the Department do with this? 

MR. DOPPEL: Make it, make it the same 

for everybody. 

MR. BROOKMAN: Just wanted to be clear 

best we can. Okay. 

Okay, final comments on these two? 

Harvey. 

DR. SACHS: Harvey Sachs, AC-triple-E. 

Harvey Sachs, AC-triple-E, supports eliminating the 

shortcut method. 
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 MR. BROOKMAN: Okay. 

DR. SACHS: We do not believe that it 

should impact the testing, but elimination, should 

eliminate the shortcut method. 

MR. BROOKMAN: All right. Thank you. 

Yes, Jim Crawford. 

MR. CRAWFORD: I would say that despite 

the wishes on, of, of, of some parties, 

variable-speed systems represent a, a, a large, 

excuse me, a small minority of the systems in the 

market today, and that situation is likely to 

prevail. 

Being the first, or one of the first 

companies to have, have introduced variable-speed 

into the U.S. market, I think that when one does 

that, we have to recognize that you, you take on 

board certain burdens in terms of your design, in 

terms of your, your product features, in terms of, 

of testing. 

More complex systems reasonably involve 

more complex testing. 

MR. DOUGHERTY: Yes. You're trying to 

generate a performance map, and so as the systems 
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 become more complex, it takes more points. 

MR. ANDERSON: This is Wes, DOE. 

Paul, if you could submit some 

information on what that burden is, or what the 

effect is? And I don't want to say "cost data," 

but some, the impact on your business, that would 

be helpful. 

MR. BROOKMAN: I see Jeff. 

MR. DOPPEL: Okay. We will do it. 

And the greatest impact is in the area 

of testing on an annualized basis. While it's not 

great, but that's where it rally shows, as test 

requirements on an annualized basis. 

MR. BROOKMAN: Jeff is the final 

comment. 

MR. NICHOLS: Well, this slide in 

general, the top one, I agree with what Jim said. 

There, there would be an effect on SEER, and we, 

you know, that has to be taken into account. 

The bottom, the bottom bullet, I think 

maintaining the short-cut method is, is probably 

appropriate, and it definitely has -- If you modify 

the, the bin, it definitely would affect SEER as 
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 well, and the existing product would be affected. 

The -- And the last one on test burden, 

single-stage product is different than two-stage, 

and their performance envelopes are different, 

which is different than variable. 

So, I think there is a natural 

progression of, of testing required to map the 

behavior of, of the systems, and it's a, it's a 

reasonable expectation that, that, that there 

should be differences along that way. 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs. 

And I'd just like to note that the 

document that, that shall not be named does call 

for the release of EER by bin for all equipment, 

including single-stage. 

So, the data for the bin calculations 

are widely available, and it's really a matter of 

checking the spreadsheet that it actually adds up 

to, to the SEER. 

So, I don't think this is actually a 

burden if, if the document that is not to be named 

does take effect. 
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 MR. DOUGHERTY: Okay. So, at least --

MR. CRAWFORD: Doug? Doug? 

MR. BROOKMAN: Jim, question? 

MR. CRAWFORD: We talked about bins 

enough that I should make the observation that, 

that doing calculations on a bin basis probably 

doesn't disturb too many people. 

Doing testing on a bin basis for 

conventional, single-speed systems would disturb a 

lot of people. It's a matter of the test burdens 

not as relates to that that is on the table. 

DR. SACHS: We didn't ask for that. 

MR. CRAWFORD: Humm? 

DR. SACHS: We didn't ask for that. 

MR. CRAWFORD: I didn't say that. Not 

everybody understand it as much as you do. 

MR. DOUGHERTY: One omission -- And, 

again, there may be others, but the test you may 

refer to was through-the-wall air conditioners and 

heat pumps. In particular, there's nothing stated 

in case of the refrigerant line, where currently 

you need to have ten feet outdoors, whether or not 

it should have the same refrigerant tubing 
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 requirements of 25 feet, or how to best measure the 

outdoor temperature, given that the, the inlet and 

outlet are usually right over the top of one 

another. 

How -- What's the best place to make 

that measurement so you get a consistent setup from 

one laboratory to the next? So, that's something 

that, if anybody wants to comment on that, those 

would be welcome as well. 

(Whereupon, no response was had.) 

MR. DOUGHERTY: Okay, going on, then, 

I'm going to turn it over to Jennifer and let her 

talk about the scheduling and the impact on 

manufacturing. 

MR. BROOKMAN: And as we're nearing the 

end of the presentation slides I'm going to hand 

out the Department's compilation of the business 

cards that were handed in so everyone's got one. 

DR. SACHS: As we're doing this 

transition, I have one other technical question 

that I'd like to get on the Record. 

MR. BROOKMAN: Sure. Would you want to 

address it to Brian? 
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 DR. SACHS: It's addressed to Brian, but 

I'm not sure he'll have to respond at this point. 

On Page 31230 there's a claim that EER 

at 115 can be linearly extrapolated from EER at 95 

and 82. And I would certainly appreciate 

documentation of that for 410-A systems. 

MR. BROOKMAN: You don't need to respond 

now, Brian, okay? 

Okay. 

Yes, Molly. 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

I also had another issue I wanted 

brought up which has to do with the default fan 

power and external --

MR. BROOKMAN: Would you like to make 

that as a concluding comment? 

MS. TROMBLEY-McCANN: Sure. I'm not 

attached to when I say it. 

I don't want it to get lost. 

MR. BROOKMAN: Don't let it get lost. 

RULEMAKING SCHEDULE AND IMPACT ON MANUFACTURERS: 

MS. WILLIAMSON: Okay, I'm Jennifer 
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 Williamson with the Pacific Northwest National 

Laboratory. And fortunately for everyone, 

everything I'm going to talk about has already been 

covered. 

First of all, written comments are due 

no later than August sixteenth to the Department. 

As we have said before, we expect the Final Rule on 

this test procedure to be published in 2011, and 

the effective dates of the changes that are 

proposed will come in two steps, as Brian talked 

about. 

The non-EISA changes become effective 30 

days following the publication of the Final Rule, 

and the Set 2 revisions will become effective on 

the same date as the Energy Conservation Standards. 

MR. BROOKMAN: Jim Crawford. 

MR. CRAWFORD: I just make the point 

that this is why I have several times during this 

morning's discussions indicated that some of the 

technical changes being proposed by Ryan, excuse 

me, Brian, will affect the performance measures. 

And that being the case, a 30-day 

implementation lead time is totally inappropriate, 
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 and perhaps not consistent with law. 

MR. BROOKMAN: Okay. Thank you. 

Jeff? 

MR. NICHOLS: Twenty-eleven is a fairly 

broad target, and we're only six months away from 

that date. So, is there a, a more targeted -- you 

know, like a month or quarter that's targeted for 

this target to being realized? 

MR. ANDERSON: I'm sorry, I, I didn't 

hear the question. 

MR. NICHOLS: Is there a month or a 

quarter that -- Preferably in a month. 

MR. BROOKMAN: In 2011, for the test 

procedure, is there a target date, where it just 

says 2011? 

MR. ANDERSON: This is Wes at DOE. 

Yes, we, we can't -- We, we don't -- We 

-- Let's -- We're going to try to make that date. 

That's it. 

MR. NICHOLS: Is there one that you can 

communicate? 

MR. BROOKMAN: Molly, go ahead. 

No, Karim, go ahead. 
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 DR. AMRANE: Karim Amrane, AHRI. 

I mean, you have to compete to develop 

the air-conditioner rulemaking by June of 2011, 

which means that this has to happen before. 

MR. ANDERSON: Correct. 

DR. AMRANE: So, we're talking at less 

than a year at the most. 

MR. DAUGHERTY: Okay, thank you, Wes. 

Okay, Harvey Sachs. 

DR. SACHS: With respect to --

Harvey Sachs. 

With respect to Jim's concern that the 

so-called non-EISA revisions might affect existing 

equipment, Wes, how do we handle that? Is it, is 

it possible to set this up in such a way that 

existing equipment is, existing models are not 

impacted and do not have to be retested for these? 

The new method would apply to all new 

equipment? 

MR. ANDERSON: Yes. This is Wes, DOE. 

That would be the goal. We will 

revisit -- We'll take his comment into 

consideration, and, and yours as well, and come out 
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 with a, an answer in the, in the Final Rule. 

But, the goal of DOE is not really to 

impact manufacturers in, adversely, so --. 

MR. BROOKMAN: Okay, thank you. 

Okay, let's proceed with the slides. 

MS. WILLIAMSON: All right. So, we've 

just covered this. 

When the Test Procedure Final Rule is 

published, it was our view that the test procedure 

revisions in that first group would not trigger 

immediate retesting or rewriting of any existing 

products, and also that SEER and HSPF are not 

triggered as a result, altered as a result of those 

test-procedure revisions. 

MR. BROOKMAN: Jeff. 

MR. NICHOLS: Just one more final 

comment on the 30-day comment time. Some of the 

non-ESAI changes are programming-type changes in, 

in the test cell lab environment, and, you know, 

probably not logistically reasonable to expect 

those could be executed within 30 days of the Final 

Rule. 

It's just probably not a reality when, 
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 unless you go higher, more resources to go do it, 

both privately and at third-party institutions. 

MR. BROOKMAN: What time frame would you 

suggest would be necessary? 

MR. NICHOLS: I think a minimum of 180 

days is a reasonable expectation. 

MR. BROOKMAN: Wow. Okay. 

Okay, thank you. 

MS. WILLIAMSON: All right. And then 

finally, when the Energy Conservation Standards 

become effective, any regional Standard, if 

promulgated, will require that additional rating of 

any equipment that is sold or installed in that 

region, and will require testing of some existing 

and any new units, adding coverage within the 

alternative reading methods. 

And with that, I'm going to turn it over 

to Wes to finish up. 

QUESTIONS & COMMENTS AND CLOSING REMARKS 

MR. BROOKMAN: Yeah. Well, before Wes 

finishes, --

Wes, pass that down. 

We wanted -- Molly's the first to raise 
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 additional concerns, and then I go back to Jim. 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

When we submitted comments during the 

framework phase, our comments recommended changes 

to both the default external static pressure and 

the default fan power that are used in the test 

procedure. 

In the NOPR, the Department expressed 

their intent not to change either of those values. 

And in particular, I wanted to start with external 

static pressure, because -- Let me see if I can 

find the quote here. 

The Department essentially stated that 

there was not data available to justify a change in 

external static pressure. However, there's no data 

available to justify the current external static 

pressure. 

It's a value been in place since 1980, 

and there's no justification whether or not that is 

appropriate at this time. There is some data, and 

we did submit that, to supplement higher value, 

particularly in hot dry region. 
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 So, my example, I think, goes to the 

Department, is: Why choose a value that has no 

backup data, as opposed to some that has at least 

some to justify it? 

And what data would you need to see to 

feel comfortable changing the external static 

default value? 

MR. BROOKMAN: Okay. Thank you. 

Jim Crawford. 

MR. CRAWFORD: I'm going to defer for a 

moment. I think that if someone's going to answer 

that, they ought to. 

MR. BROOKMAN: I don't think the 

Department wants to answer that one now. 

MR. CRAWFORD: I thought -- Well, I 

thought the Department answered it in the Notice. 

MR. ANDERSON: Yeah. 

MR. CRAWFORD: Not to the satisfaction 

of some Parties, but I thought they answered it. 

The -- Okay. Yeah. 

The, the point on the, the preceding 

chart was that the light rating will be required 

for equipment sold and installed in the hot dry 
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 region. I think that, that this assumes that there 

is such a thing as a hot-dry air conditioner. 

And it's been ably demonstrated 

repeatedly that that is a misconception. And the 

recently funded project on that demonstrated what 

I've just said. 

If you really look at it objectively, 

the, the products of this industry are national 

products. It's unlikely that there will be three 

different sets of products for different regions. 

And so recognize that, that if you 

impose testing for a hot-dry region, you impose 

that testing on every product in the industry. 

MR. BROOKMAN: Okay. Thank you. 

Yes, Karim. 

DR. AMRANE: I guess I wanted to follow 

up on, on what Molly said about the static 

pressure. I think I agree with the Department's 

determination here with respect to the static 

pressure; that we, that we are, by establishing 

such a criteria, I think there is evidence that we 

can design to static pressure, we can design ducts 

to static pressure. 
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 The question is: Why are they not 

designed that way? So, I think instead of focusing 

on this test procedure, I think the focus should be 

on designing better ducts. 

MR. BROOKMAN: Paul? 

MR. DOPPEL: Item Number 6 on Page 34122 

references Mitsubishi's comments from the previous 

meeting. And the, the issue there is that we're 

saying that the current test method does not 

accurately incorporate the energy-saving 

capabilities of the VRF systems, or I should say 

variable-speed systems. 

And the one thing I wanted to bring out 

in regard to that, I know you're asking for more 

additional information for another testing method, 

and I've been working with the R-factor in Japan to 

try to come up with something. 

But, basically what happens is the 

system's intended for all the measurements to force 

the compressor to change speeds in order to 

accommodate for the loads. 

What the test procedure does is freezes 

that which is supposed to be floating to match the 
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 loads to try to contort the system to operate at 

the certain level. And that creates a lot of 

inefficiencies in how the system not only operates, 

but how long the testing takes. 

It requires a lot longer for the systems 

to stabilize once you fix those conditions. So, 

that's, that was the intent of our comments there, 

and that, there, there just needs to be a better 

way of testing those systems. 

And, again, we're still working with our 

folks in Japan to do that. 

Then I just also wanted to reiterate 

that, the fact that for the multi-split systems 

there should not be a requirement to turn your 

indoor system off during operations where the 

compressors are operating at their minimum speed. 

MR. BROOKMAN: Okay. 

So, Molly. 

MS. TROMBLEY-McCANN: Molly 

Trombley-McCann. 

So, this question has to do with default 

fan power, and it ties into the furnace fan test 

procedure rulemaking that is just beginning. And I 
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 believe the public meeting is next Friday for that. 

And my question is: How is the 

Department going to reconcile what happens in that 

test procedure rulemaking with what's happening in 

this test procedure rulemaking? 

Because it seems to me that once those 

test procedures go into effect, every fan will have 

to have that. And the option of using default 

power when every fan has an actual tested 

capability doesn't make sense. 

I don't know how they're going to line 

up, but they obviously line up with each other. 

And I'm wondering what the Department's planning to 

do to manage that. 

MR. ANDERSON: This is Wes at DOE. 

The way we see it, the furnace fan rule, 

I think it publishes in 2013. 

MS. TROMBLEY-McCANN: That's the 

deadline; yeah. 

MR. ANDERSON: Yeah, that's the 

deadline, for 2013. And then the effective date is 

some years after that. 

So, we're using our, our rulemaking 
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 schedule to, to handle -- That's a, a secondary as 

far as air conditioner's concerned. I know it's a 

very large impact to air conditioners, but we look 

at that as another step in the process. 

But, it's -- But, because it's been set 

up as a furnace fan rule, we have to work with it 

at, on this schedule. So, I believe that's not a 

direct answer for you, but we're kind of stuck here 

with this. 

MR. BROOKMAN: Harvey Sachs. 

DR. SACHS: Harvey Sachs, and I want to 

commend Karim for his observation that it's 

possible to design and install a lowest P duct 

system. 

On the other hand, what we know is that 

even in good times for construction, the vast 

majority of central air conditioners today are sold 

for existing houses. 

The wet fit cost for putting in one of 

these very lowest-P duct systems is prohibitive in 

an existing house. Therefore, the existing market 

will remain dominated by systems that have high fan 

power and highest P. 
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 The ratings that DOE uses are, were the 

best guesses that could be made by this industry in 

the 1980s. I've not been able to find data on 

which they were based. 

They do not have data, not adequate, not 

well-distributed across all duct-type 

installations, but we know enough today that to 

insist on using a 30-year-old guess instead of a 

data set seems to be perverse in terms of this 

legislation. 

MR. BROOKMAN: Okay. Thank you. 

So, this is the occasion for anybody 

that wishes to make additional, or, and perhaps 

final comments. 

(Whereupon, no response was had.) 

MR. BROOKMAN: Okay. So, then do you 

want to put the last slide up there? 

MR. ANDERSON: Yeah, sure. 

MR. BROOKMAN: So, from my perspective, 

I'm turning it back to Wes. And I thank all of 

you. 

We've covered a lot of ground in this 

meeting, some of it really technical. You've all 
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 hunched in there, and best wishes. 

We'll see you soon. 

SUMMARY AND NEXT STEPS 

MR. ANDERSON: Yeah. This is Wes of 

Department of Energy, Wes Anderson, Department of 

Energy. 

In summary I'm going to reiterate: The 

comment period ends on the sixteenth of August. 

You made some great comments here. 

Please, some of them were statements, but please 

back up those statements with, or with data or 

explanation as to how you came to your conclusions. 

And use the three bulleted points here 

as, so we know how, when, when the information 

comes to us, we know where to send it. You can 

also submit your comments to -- Oh, I'm sorry. --

our web page, where we'll put up the latest edition 

of the presentation as soon as possible, as soon as 

we can get it to the web mavens. 

Well, preferably early next week will be 

the, it will be up there, up there by then. And 

also as a final statement, the Consensus Agreement 

is being considered by DOE, all facets of the 
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 Consensus Agreement. 

Thank you. 

The next milestone is the NOPR for the 

Standards rulemaking, which will be for sometime in 

the fall. The test procedure will continue to 

progress concurrent with that, and it is DOE's goal 

not to burden anyone with this test procedure, so 

it will be, it will be out in time for this won't 

be impactful for anyone. 

Questions? 

Harvey? 

MR. BROOKMAN: Thank you for your 

patience, everyone. 

MR. ANDERSON: All right. I officially 

close these proceedings. 

MR. BROOKMAN: Thank you. 

(Whereupon, at 12:58 p.m. ET, the above 

Public Meeting was concluded.) 

I certify the foregoing to be a 

true transcript from my notes. 

E-signature: D. I. Bunn 

CSR CP RPR 

CERTIFICATION 
 

 

 

 

 

 

 

 

 

 

211

1 I, D. I. Bunn, a Registered 

2 Professional Reporter, Certified Conference 

3 Reporter, and Notary Public, do hereby certify that 

4 the foregoing public meeting was duly taken and 

5 reduced to writing before me at the place and time 

6 therein mentioned. I further certify that I am 

7 neither related to any of the parties by blood or 

8 marriage, nor do I have any interest in the outcome 

9 of the above matter. 

10 In witness whereof, I have hereunto set 

11 my hand and affixed my official seal, at Lusk, 

12 Wyoming, USA, this 14th day of June, 2010. 

13 

E-signature: D. I. Bunn 

14 

Notary Public 

15 

16 My Commission expires January 5, 2012. 

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