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MEMORANDUM FOR THE RECORD

FROM: Kathi Epping, EE-43 Gi /

SUBJECT: Meeting with AHAM Re: Room Air Conditioner Energy Conservation Standards

[Docket Numbers EE-RM-93-801 and EE-RM-93-801-RAC]

On September 26, 1996, the DOE met with members of the Association of Home Appliance

Manufacturers (AHAM) to discuss the room air conditioner rule. The list of-attendees are

contained in attachment A. Issues such as problems associated with an increase in chassis size,

the computer simulation model, the calculation of average equipment lifetime, the design options

used for max. tech., and the impact of alternative refrigerants were discussed. A copy of

AHAM's presentation is contianed in attachment B.

DOE proposed a set of standards identical to the standards recommended by AHAM with the

exception of classes 2 and 3. The Department proposed setting classes 2 and 3 at 10.0 EER.

(See attachment C.) AHAM did not accept this proposal.

The graph showing the percent of production that moves to a larger chassis size at each EER

standard level, included in AHAM's 1994 comments to the NOPR was discussed (EE-RM-93-

801 No. 1 at 14.)

DOE then suggested a set of standards at efficiencies for the first five classes that are between

those standards recommended by AHAM and those recommended jointly by ACEEE and NRDC.

These standards would lie in the 9.7 to 9.8 range for classes 1 through 4 and 8.7 for class 5.

AHAM indicated their need to discuss this proposal amongst themselves before giving their

comments. AHAM, however, expressed their desire to "round" numbers to .5 EER increments

(i.e., 8.5, 9.0, 9.5...)

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EE-RM-93-801-RAC COMMENT 11
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EE-RM-93-801-RAC COMMENT 11
ROOM AIR CONDITIONER STANDARDS

PROBLEMS ASSOCIATED WITH AN INCREASE IN CHASSIS 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 NOT ALL HAVE TO CHANGE CHASSIS

SIZE AT THE 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

EE-RM-93-801-RAC COMMENT 11
ROOM AIR CONDITIONER 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 OF THE NICHES, AVAILABILITY OF A PARTICULAR

HIGH EFFICIENCY DOES NOT MEAN IT WOULD MAKE A GOOD

STANDARD (EXAMPLE-- 10,000 BTUH, 7.5 AMP, 11.6 EER UNIT)

9/26/96

EE-RM-93-801-RAC COMMENT 11
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 Less than 6,000 Btuh 8.0 10.0 10.0 9.5 10.0 15%

Cycle, with Side 6,000 to 7,999 Btuh 8.5 9.9 10.0 9.5 10.0 9%

Louvers 8,000 to 13,999 Btuh 9.0 10.1 10.0 9.5 10.0 31%

14,000 to 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%

% of production requiring larger chassis 0% 39% 47% 17% 39%

* No specific comment

9/26/96

EE-RM-93-801-RAC COMMENT 11
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 1 TO 5 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, IT WOULD SEEM TO MAKE MORE

SENSE TO ACCEPT THE RECOMMENDATIONS BASED ON

INDUSTRY EXPERIENCE FOR THESE PRODUCTS.

9/26/96

EE-RM-93-801-RAC COMMENT 11
Table 2.1 Average Equipment Lifetime of Room 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 of Above Sources 12.7

EE-RM-93-801-RAC COMMENT 11
ROOM AIR CONDITIONER STANDARDS

USE OF VARIABLE SPEED COMPRESSORS AND BRUSHLESS

PERMANENT FAN MOTORS FOR MAX TECH FEASIBLE

1. THE TSD ASSUMES THESE OPTIONS TO BE "...CAPABLE OF

BEING ASSEMBLED..." INTO RAC'S BY THE EXPECTED

EFFECTIVE DATE.

2. THAT IS A POOR ASSUMPTION:

VARIABLE SPEED COMPRESSORS DO NOT PROVIDE ANY

BENEFIT WITH THE PRESENT TEST PROCEDURE.

BPM FAN MOTORS SUITABLE FOR USE IN RAC'S ARE

HIGHLY UNLIKELY TO BE AVAILABLE.

HIGH UNIT AND APPLICATION COSTS

NOT AVAILABLE WITH DOUBLE ENDED SHAFT

9/26/96

EE-RM-93-801-RAC COMMENT 11
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 IN RAC'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, IF THE MOST

APPLICABLE IS NOT 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, IN THE FUTURE, SEPARATE

CLASSES FOR THE NEW REFRIGERANT MAY BE

NECESSARY. 9/26/96

EE-RM-93-801-RAC COMMENT 11
100%-

90%

80%

. 70% |I

.I 60% /- <6000

, 8 4o- ________50% / .r l__ ______8 -- 6000-7999

¢i ° 40 - , |8000-13999 % 

.o +40/

o 0% -A-14000-19999 > 30% - - -0- >=20000

20%

10% / _

0%

8.0 8.5 9.0 9.5 10.0 10.5 11.0 11.5 12.0

EER Standard Level

Per Cent of room air conditioner production that requires a larger size

chassis to meet various standard levels, Classes 1 to 5. (1994 AHAM

Comments on the NOPR)

EE-RM-93-801-RAC COMMENT 11
++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

EE-RM-93-801-RAC COMMENT 11