# arl MEMORANDUM FOR THERECORD FROM: Kathi Epping, EE-43 Gi/ SUBJECT: Meeting with AHAM Re: Room AirConditioner Energy Conservation Standards [DocketNumbers EE-RM-93-801 and EE-RM-93-801-RAC] OnSeptember 26, 1996, theDOE metwith members ofthe Association ofHome Appliance Manufacturers (AHAM) todiscuss theroom airconditioner rule. The list of-attendees are contained inattachment A. Issues such as problems associated with anincrease inchassis size, the computer simulation model,the calculation ofaverage equipment lifetime, the design options usedformax. tech., and theimpact ofalternative refrigerants were discussed. Acopy of AHAM's presentation is contianed in attachment B. DOE proposed a setofstandards identical tothe standards recommended by AHAM with the exception ofclasses 2 and 3. The Departmentproposed setting classes 2 and 3 at 10.0 EER. (See attachment C.) AHAM did notaccept this proposal. The graph showing the percent ofproduction thatmoves to alarger chassis size ateach EER standard level, included inAHAM's 1994comments to theNOPR wasdiscussed (EE-RM-93- 801 No. 1at 14.) DOEthen suggested asetofstandards at efficiencies forthefirstfive classes that arebetween those standards recommended by AHAM and thoserecommended jointlybyACEEE and NRDC. These standards would liein the 9.7 to 9.8 range for classes 1through 4 and 8.7forclass 5. AHAM indicated their need to discuss thisproposal amongst themselves before giving their comments. AHAM, however, expressed their desireto "round" numbers to .5EER increments (i.e., 8.5, 9.0,9.5...)

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### ROOM AIR CONDITIONER STANDARDS PROBLEMS ASSOCIATED WITH AN INCREASE INCHASSIS SIZE

1. COST PREMIUM IS SIGNIFICANT ($30 TO $100) 2. GENERALLY NOT JUSTIFIED (LCC) 3. WIDE DIVERSITY OF CHASSIS SIZES BETWEEN MANUFACTURERS 4. MANUFACTURERS DO NOTALL HAVE TO CHANGE CHASSIS SIZE ATTHE SAME EER LEVELS AT ANY LEVEL THAT COULD REASONABLY BE CONSIDERED FOR NEW STANDARDS, SOME PORTION OF PRODUCTION WILL MOVE TO LARGER CHASSIS SIZES. (GRAPH)

9/26/96

### ROOM AIRCONDITIONER STANDARDS PROBLEMS ASSOCIATED WITH AN INCREASE IN CHASSIS SIZE 5. DIFFERENT MANUFACTURERS EMPHASIZE DIFFERENT MARKETS: SOME FOCUS ON ONE OR MORE NICHES HIGH EFFICIENCY THROUGH-THE-WALL SLIDER/CASEMENT REVERSE CYCLE OTHERS FOCUS ON THE MASS MARKET THE FOCUS STRONGLY INFLUENCES CHASSIS SIZES FOR EACH MANUFACTURER 6. BECAUSE OFTHE NICHES, AVAILABILITY OFA PARTICULAR HIGH EFFICIENCY DOES NOT MEAN ITWOULD MAKE A GOOD STANDARD (EXAMPLE-- 10,000 BTUH, 7.5 AMP, 11.6 EER UNIT)

9/26/96

### Room Air Conditioner Standards EER 

### Proposals for New Standards % of 

## Product Class 1/1/90 Efficiency NRDC/ energy Std. Level 3 Fedders AHAM ACEEE use 

## Without Reverse Lessthan 6,000 Btuh 8.0 10.0 10.0 9.5 10.0 15% Cycle, with Side 6,000to 7,999 Btuh 8.5 9.9 10.0 9.5 10.0 9% Louvers 8,000to 13,999 Btuh 9.0 10.1 10.0 9.5 10.0 31% 

## 14,000to 19,999 Btuh 8.8 10.15 10.6 9.5 10.0 19% 20,000 Btuh and more 8.2 8.5 9.6 8.5 9.0 13% Total 87% % ofproduction requiring larger chassis 0% 39% 47% 17% 39% * No specific comment 

## 9/26/96

### ROOM AIR CONDITIONER STANDARDS THE SIMULATION MODEL 1.AFTER MANY MONTHS OF EXTENSIVE EFFORT OVER SEVERAL YEARS, THE SIMULATION MODEL WAS TUNED TO SIMULATE CLASSES 1TO5 WITHIN REASONABLE LIMITS. 2. THIS TUNING HAS PROVED NQI TO GIVE REASONABLE RESULTS FOR NO SIDE LOUVER AND REVERSE CYCLE UNITS. 3. MANY MORE MONTHS OF EXTENSIVE EFFORT WOULD BE REQUIRED TO TUNE THE MODEL TO GIVE REASONABLE RESULTS FOR NO SIDE LOUVER AND REVERSE CYCLE UNITS. 4. RATHER THAN EXPEND THE CONSIDERABLE RESOURCES FOR SUCH A PROJECT, ITWOULD SEEM TO MAKE MORE SENSE TO ACCEPT THE RECOMMENDATIONS BASED ON INDUSTRY EXPERIENCE FOR THESE PRODUCTS.

9/26/96

### Table 2.1 Average Equipment Lifetime ofRoom Air Conditioners Average Source Lifetime Years DOE, 1990 10 1981 Northern States Power 14 Appliance Trade Publication, 1984 11 1985 Northern States Power 15 Wisconsin Public Service Commission, 1986 15 The Saturation Picture, Appliance, Sept., 1989 11 EPRI, 1990 (Reports: EPRI CU-6746, EPRI CU-6925 15 Average ofAbove Sources 12.7

### ROOM AIRCONDITIONER STANDARDS USE OF VARIABLE SPEED COMPRESSORS AND BRUSHLESS PERMANENT FAN MOTORS FOR MAX TECH FEASIBLE 1. THE TSDASSUMES THESE OPTIONS TO BE "...CAPABLE OF BEING ASSEMBLED..." INTO RAC'S BY THE EXPECTED EFFECTIVE DATE. 2. THAT ISA POORASSUMPTION: VARIABLE SPEED COMPRESSORS DO NOT PROVIDE ANY BENEFIT WITH THE PRESENT TEST PROCEDURE. BPM FAN MOTORS SUITABLE FOR USE INRAC'S ARE HIGHLY UNLIKELY TO BE AVAILABLE. HIGH UNIT AND APPLICATION COSTS NOTAVAILABLE WITH DOUBLE ENDED SHAFT 9/26/96

### ROOM AIR CONDITIONER STANDARDS IMPACT OF REPLACEMENT REFRIGERANTS 1. REPLACEMENTS DEFINITELY REQUIRED IN 2010. 2. REPLACEMENTS MAY BE REQUIRED EARLIER. 3. SERIOUS CONCERN THAT REPLACEMENTS SUITABLE FOR USE INRAC'S WILL NOT BE AS EFFICIENT AS R-22. 4. AHAM POSITION: RECOMMENDED STANDARDS ARE BASED ON AVAILABILITY OF R-22. WHEN REPLACEMENTS ARE REQUIRED, IFTHE MOST APPLICABLE ISNOT AS EFFICIENT AS R-22, NEW CLASSES MAY BE REQUIRED WITH STANDARDS APPROPRIATELY SET FOR THE REPLACEMENT. WHEN NEW STANDARDS ARE ISSUED, DOE SHOULD FORMALLY RECOGNIZE THAT, INTHE FUTURE, SEPARATE CLASSES FOR THE NEW REFRIGERANT MAY BE NECESSARY. 9/26/96100%- 90% 80%

. 70% |I .I 60% /- <6000

, 8 4o- ________50% / .r l__ ______8 -- 6000-7999 ¢i ° 40 %

- , |8000-13999 

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+40/ o 0 % -A-14000-19999 > 30% - - -0- >=20000 20% 10% /

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0%8.0 8.5 9.0 9.5 10.0 10.5 11.0 11.5 12.0 EER Standard Level PerCentofroom air conditionerproduction thatrequires alarger size chassistomeetvarious standardlevels, Classes 1to 5. (1994 AHAM Comments on theNOPR)++Lc-A 

### ent 

### C

Product class Energy efficiency ratio Jan. Fedders AHAM NRDC/ DOE % of

1, ACEEE Proposal energ 1990

___ use 1. Without reverse cycle 8.0 10.0 9.5 10.0 9.5 15 and with louvered sides less than 6,000 Btu 2. Without reverse cycle 8.5 10.0 9.5 10.0 9.5 9 and with louvered sides 6,000 to 7,999 Btu 3. Without reverse cycle 9.0 10.0 9.5 10.0 10.0 31 and with louvered sides 8,000 to 13,999 Btu 4. Without reverse cycle 8.8 10.6 9.5 10.0 10.0 19 and with louvered sides 14,000 to 19,999 Btu 5. Without reverse cycle 8.2 9.6 8.5. 9.0 8.5 13 and with louvered sides 20,000 or more Btu 6. Without reverse cycle & 8.0 * 9.0 9.0 9.0 0.5 without louvered sides less than 6,000 Btu 7. Without reverse cycle & 8.5 * 9.0 9.0 9.0 2 without louvered sides 6,000 to 7,999 Btu 8. Without reverse cycle & 8.5 * 8.5 9.0 8.5 9 without louvered sides 8,000 to 13,999 Btu 9. Without reverse cycle & 8.5 * 8.5 9.0 8.5 0 without louvered sides 14,000 to 19,999 Btu 10. Without reverse cycle, 8.2 * 8.5 9.0 8.5 0 without louvered sides 20,000 or more Btu 11. With reverse cycle & 8.5 9.1- 8.5 8.5- 8.5 2 with louvered sides 10.1 9.5 12. With reverse cycle, 8.0 * 8.0 8.5 8.0 0.2 without louvered sides 13. Casement-only N/A N/A 8.7 9.0 8.7 14. Casement-Slider N/A N/A 9.5 9.0 9.5 Estimated Energy Savings N/A .3 7 .67 Approx. N/A

(OuadsN) .52 * No specific comment