UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS 

FOR CERTAIN COMMERCIAL AIR CONDITIONING, 

HEATING AND WATER HEATING EQUIPMENT, i.e., 

CERTAIN EQUIPMENT IN ASHRAE STANDARD 90.1.2010 

 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, D.C. 20585 

Room SE-089 Review Center 

9:00 a.m. 

Tuesday 

February 14, 2012 

 

Facilitator: 

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Robert Wilkins 

Danfoss 

Gary Nettinger 

Panasonic Air Conditioning Group 

Dave Winningham 

Allied Air 

Steve Rosenstock 

Edison Electric Institute 

Joanna Mauer 

Appliance Standards Awareness Project 

Karim Amrane 

Air Conditioning, Heating and Refrigeration Institute 

Paul Doppel 

Mitsubishi Electric 

Warren Beeton 

Emerson Climate Technologies 

Gabriel Nelson 

E&E Publishing 

Mark Sharp 

Panasonic 

Julia Farmer 

Underwriters Laboratories 

Jay Perkins 

Mitsubishi Electric 

Participants from DOE:

Mohammed Khan 
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Ashley Armstrong 

Eric Stas 

General Counsel’s Office 

Participants from Consultants:

Adam Darlington 

Navigant Consulting 

Knute Svenson 

Navigant Consulting 

Alison Williams 

Lawrence Berkeley National Laboratory 

Greg Rosenquist 

Lawrence Berkeley National Laboratory 

David Winiarski 

Pacific Northwest National Laboratory 

Mike Scott 

Pacific Northwest National Laboratory. 

 

Presenters:

Mohammed Khan 

Adam Darlington 

Knute Svenson 

Dave Winiarski 

Michael Scott 

Alison Williams 

Ashley Armstrong
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AGENDA

 ITEM PAGE 

 

Welcome, Doug Brookman 5 

Welcome for DOE, Mohammed Khan 5 

Introductions 6 

Agenda Review, Doug Brookman 8 

Meeting overview, Mr. Khan 11 

Scope, Mr. Darlington 15 

Test Procedures, Mr. Darlington 26 

Market Assessment, Mr. Svenson 57 

 

Engineering Analysis, Mr. Svenson 73 

Introduction to Markup Analysis, Energy 

Use Analysis, Life Cycle Costs and Payback 

Period Analysis, Mr. Winiarski 86 

Markup Analysis, Life Cycle Costs, Mr. Scott 92 

Shipments Analysis, National Impact 

Analysis, Utility Impact and Emissions 

Impact Analysis, Ms. Williams 123 

Certification, Compliance & Enforcement 

 Ms. Armstrong 138 

Closing Remarks 

 Mr. Khan 145 
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Good morning everyone and 

3 welcome. This is the U.S. Department of Energy’s 

4 public meeting on Energy Conservation Standards for 

5 Certain commercial air conditioning, heating and water 

6 heating equipment, i.e., certain equipment in ASHRAE 

7 Standard 90.1.2010. 

8 Today is Tuesday, February 14, 2012 here at 

9 the Forestall Building in Washington, D.C. My name is 

10 Doug Brookman from Public Solutions in Baltimore. Glad 

11 you’re here. Glad we’re going to get an early start on 

12 the day. 

13 We’re going to start today with welcoming 

14 remarks from Mohammed Khan. 

15 Welcoming Remarks 

16 MR. KHAN: Good morning, everybody. My 

17 name’s Mohammed Khan. First and foremost I want to 

18 welcome and thank everybody for participating today. 

19 Today’s rulemaking is on certain ASHRAE commercial 

20 equipment, and it includes a variety of classes of 

21 There is a lot of information, technical information, 

22 a lot of discussion in there, and so today we want to 

23 do our best to convey and summarize the points that 

24 are in the NOPR. We want to get your comments, hear 

25 your questions, and then also ask you some questions 
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1 about it as well. 

2 So, because we have a lot to cover, I think 

3 that’s it and we probably can get started. 

4 MR. BROOKMAN: Okay, so let’s then proceed. It’s 

5 our tradition to do introductions around the room. 

6 I’ll start over here to my left, please say your name, 

7 organizational affiliation. You can get used to 

8 turning on the microphone. We’ve had a little bit of 

9 an audio issue going this morning, so in order to get 

10 a really clean, clear transcript, we need to be 

11 diligent about speaking directly into the microphone. 

12 So let’s – name and organizational affiliation. 

13 Introductions 

14 MR. WILKINS: Robert Wilkins, Danfoss. 

15 MR. NETTINGER: Good morning. Gary 

16 Nettinger. Panasonic Air Conditioning Group. 

17 MR. WINNINGHAM: Dave Winningham. Allied 

18 Air. 

19 MR. ROSENSTOCK: This is Steve Rosenstock, 

20 Edison Electric Institute. 

21 MS. MAUER: Joanna Mauer, Appliance 

22 Standards Awareness Project. 

23 DR. AMRANE: Karim Amrane, Commercial 

24 Heating and Refrigeration Institute. 

25 MR. DOPPEL: Paul Doppel, Mitsubishi 
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1 Electric. 

2 MR. BEETON: Warren Beeton, Emerson Climate 

3 Technologies. 

4 MS. ARMSTRONG: Ashley Armstrong, Department 

5 of Energy. 

6 MR. STAS: Eric Stas, DOE, General Counsel’s 

7 Office. 

8 MR. KHAN: Mohammed Khan, Department of 

9 Energy. 

10 MR. BROOKMAN: Let’s go over here, Dave. 

11 MR. WINIARSKI: David Winiarski, Pacific 

12 Northwest National Laboratory. 

13 MR. ROSENQUIST: Greg Rosenquist, Lawrence 

14 Berkeley National Laboratories. 

15 MS. WILLIAMS: Alison Williams, Lawrence 

16 Berkeley National Laboratory. 

17 MR. SVENSON: Knute Svenson, Navigant 

18 Consulting. 

19 MR. DARLINGTON: Adam Darlington, Navigant 

20 Consulting. 

21 MR. SCOTT: Mike Scott, Pacific Northwest 

22 National Laboratory. 

23 MR. BROOKMAN: You. Stand up, say your 

24 name. 

25 MR. NELSON: Gabriel Nelson, E&E Publishing. 
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1 MR. BROOKMAN: Thank you. 

2 MR. SHARP: Mark Sharp, also with Panasonic. 

3 MS. FARMER: Julia Farmer, with Underwriters 

4 Laboratories. 

5 MR. PERKINS: Jay Perkins, Mitsubishi 

6 Electric. 

7 MR. BROOKMAN: Okay, so thanks to all of 

8 you. Once again, glad to see you here and get an 

9 early start on the day. All of you received a packet 

10 when you walked in the door. I hope all of you 

11 registered with Brenda or with Debby downstairs and 

12 handed off a business card. The Department will 

13 typically make a Xerox copy of all of those business 

14 cards so that everybody knows who’s here. I’m going 

15 to do a very brief agenda review and then we’ll just 

16 proceed. 

17 Agenda Review

18 MR. BROOKMAN: As you can see, and you all 

19 have a copy of this in your hands, I hope, 

20 immediately following this agenda review, there’s an 

21 opportunity –- we’re going to have a brief overview by 

22 Mohammed, and then there’s an opportunity for opening 

23 remarks, for anybody that wishes to do so. Brief 

24 summary comments on issues that are important to you. 

25 From there, we’ll go directly into a 
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1 description of the determination of scope and test 

2 procedures. 

3 We’ll take a break mid-morning, round about 

4 10:30 or so, following the break we’re going to have 

5 market assessment and engineering analysis presented. 

6 And all of you received this packet of slides as well, 

7 that will be the general format. This content will be 

8 projected up on the screen and there’s opportunities 

9 to comment as we go along. Following the market 

10 assessment, we’re going to be talking about market 

11 analysis, energy analysis, life cycle cost and payback 

12 curve analysis. 

13 We’ll break for lunch round about 12:15 or 

14 so and then following lunch, shipments analysis, 

15 national impact analysis, utility impact and emissions 

16 impact analysis. And then rounding out the day, 

17 certification and compliance, enforcement and finally 

18 it is an opportunity for anybody that wishes to do so, 

19 to make final comments, things that haven’t been 

20 covered sufficiently in that time block you see at the 

21 end of the agenda there, 2:15 to 2:30 or so. We’ll 

22 also cover next steps and closing remarks there. 

23 I think the Federal Register notice 

24 suggested this meeting might go to four o’clock today. 

25 We probably will get done a little bit early, but 
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1 we’ll just see how it goes. We’ll try to be very 

2 efficient about the conduct of the meeting as we’re 

3 going along. 

4 Questions and comments about the agenda? 

5 There are several individuals that have 

6 joined us via the web. We’ll do our best to 

7 accommodate those that have joined us via the web, 

8 that is, if you have questions that you would like – 

9 or comments that you would like to have inserted into 

10 the record, we’ll do our best to work with you. If 

11 you send a question via the web, try and make it brief 

12 and we’ll try and get it answered here. 

13 So then, finally, I’d ask for your 

14 consideration. If during the course of the meeting 

15 today, if you could please speak one at a time. If 

16 you could say your name for the record each time you 

17 speak. There will be a complete transcript of this 

18 meeting. I’m going to be cuing individuals by name 

19 as best I can. I also wish to encourage follow on 

20 comments. Sometimes the back and forth between 

21 individuals can be very useful for the Department. If 

22 you can, be concise. Share the air time. There’s a 

23 lot to be said, I’m certain. 

24 And keep the focus here. Please turn your 

25 cell phones on silent. And limit sidebar 
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1 conversations. We’re going to have to really focus on 

2 getting our faces into these microphones today so we 

3 get a nice, clean transcript. 

4 Questions or comments before we begin. So I 

5 think then we’ll go to Mohammed for an overview. 

6 Overview 

7 MR. KHAN: Well, good morning everyone. 

8 Welcome, and thank you for participating in the 

9 Department’s public meeting on energy conservation 

10 standards and test procedures for certain commercial 

11 heating, air conditioning, and water heating 

12 equipment. My name again is Mohammed Khan and I’m the 

13 project manager for this activity. 

14 Today’s meeting serves multiple purposes. 

15 Generally, our goal is to have a two-way discussion. 

16 We want to convey the key points and concepts 

17 associated with this rulemaking as well as hear and 

18 listen to your thoughts and potential concerns. So 

19 first the Department wants to receive comments on the 

20 proposed standard levels and present the approaches 

21 and results of the supporting analyses. Additionally, 

22 we want to receive input on any aspect of the 

23 methodologies, assumptions, and data sources used in 

24 the analyses. 

25 Let it be clear this forum is also for all 
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1 interested parties to discuss and hear the issues 

2 raised by others, and because your feedback is very 

3 important, I encourage everyone to fully participate 

4 and I urge you to submit any relevant data that will 

5 help the Department. And finally, our goal today is 

6 to describe the next steps in the rulemaking. 

7 Let me point out also that today’s public 

8 meeting is not the only opportunity for you to provide 

9 comments. You may submit written comments to the 

10 Department within the 75 day comment period for this 

11 NOPR, which closes on the second of April. 

12 This slide provides a sample call-out box 

13 that we’ll use throughout our presentation today to 

14 identify specific issues on which the Department 

15 either seeks comment or information. The number and 

16 order in which these boxes are presented correspond to 

17 the 18 issues listed at the end of the NOPR. 

18 As I mentioned earlier, your feedback is 

19 very important, and I want to make sure that everyone 

20 is clear on how to submit their comments. This slide 

21 provides a postal, courier, email address, which are 

22 appropriate for submitting your comments. Please 

23 include the information here at the top so that it is 

24 properly identified and catalogued once we receive it. 

25 And let me restate that the comment period closes on 
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1 April second. 

2 There’s also another way that you can submit 

3 your comments that’s not on the slide here, but it’s 

4 in the Federal Register notice, and that’s 

5 www.regulations.gov. 

6 MR. BROOKMAN: Steve Rosenstock. 

7 MR. ROSENSTOCK: Hi. Steve Rosenstock, 

8 Edison Electric Institute. It says that in addition, 

9 if you want to send by mail to submit items on a 

10 compact disk, in which case it’s not necessary to 

11 include printed copies. Are you still accepting one 

12 printed copy instead of the CD? 

13 MS. DERR: His mic’s not on. 

14 MR. BROOKMAN: So will you restate? 

15 MR. KHAN: Yeah, I’ll restate what I just 

16 said, which is typically -- currently these days we’re 

17 not really receiving hard copy. You know, I guess, 

18 with the other technology, it’s easier and more 

19 efficient to – 

20 MR. BROOKMAN: Yeah, so I guess what 

21 Mohammed is saying is the Department’s prefers to 

22 receive it in some sort of electronic media, either 

23 via email or CD. 

24 MR. ROSENSTOCK: Thank you. Steve 

25 Rosenstock, again, I thank you. In other matters it’s 
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1 been send electronically but also submit a signed 

2 original, so that’s why I was just double-checking. 

3 MR. BROOKMAN: Thank you for that. Okay. 

4 MR. KHAN: Yeah. What’s driving this effort? 

5 The Energy Policy and Conservation Act enacted in 1975 

6 provides the legal authority and guidelines DOE must 

7 follow to promulgate standards. EPCA directs DOE to 

8 consider amending its energy conservations standards 

9 for equipment listed in the relevant sections of 42USC 

10 6313 every time ASHRAE Standard 90.1 is amended with 

11 respect to this equipment. Additionally, DOE is 

12 directed to review and adopt these standard levels 

13 equal to the ASHRAE levels unless clear and convincing 

14 evidence supports the adoption of more stringent 

15 efficiency levels that would result in significant 

16 additional energy savings, be technologically feasible 

17 and be economically justified. 

18 So at this point, we’d like to invite anyone 

19 wanting to provide an opening statement or remark. 

20 MR. BROOKMAN: Brief summary statement or 

21 comments here at the outside? No comments at this 

22 time? Okay. So we’re going to proceed with the 

23 content in your packet. And first we’re going to hear 

24 from Adam Darlington. 

25 
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1 Determination of Scope 

2 MR. DARLINGTON: Good morning. I’m Adam 

3 Darlington with Navigant Consulting. I’ll be going 

4 through the determination of scope and the test 

5 procedure updates being conducted as part of this 

6 rulemaking. First let’s start with the determination 

7 of scope. Basically, when determining the scope, DOE 

8 first identified any changes in ASHRAE Standard 90.1. 

9 Basically, the DOE is looking for an increase in the 

10 efficiency levels in ASHRAE as compared to the federal 

11 efficiency levels, and then DOE also looked at the 

12 test procedures to identify updates to the test 

13 procedures in ASHRAE 90.1. 

14 This slide is basically – it’s a little bit 

15 of what you saw, so I’ll just kind of summarize the 

16 key points, but basically the point on this slide is 

17 that previous versions of ASHRAE Standard 90.1 before 

18 the 2010 version did not cover industrial 

19 manufacturing or commercial process equipment. The 

20 2010 edition now covers some of that equipment, 

21 specifically air conditioners and condensing units 

22 used in computer rooms. So DOE standards historically 

23 have not covered the industrial process equipment in 

24 the scope of its regulations. 

25 And basically, this slide, the key point 
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1 there is probably the last point in determining 

2 whether a manufacturer’s products are within the scope 

3 of DOE’s regulations, because there are a lot of 

4 similarities between the types of equipment used for 

5 comfort conditioning or space conditioning, versus the 

6 industrial process equipment. And basically this 

7 slide is meant to convey that these determinations are 

8 going to be made on a case-by-case basis, depending on 

9 factors such as how the model is advertised, marketed, 

10 and used in buildings. 

11 And now that brings us to the first issue of 

12 the day. DOE is seeking comment on ways that 

13 manufacturers differentiate commercial air 

14 conditioning equipment used solely for manufacturing 

15 industrial processes, versus the type that’s used to 

16 cool buildings for comfort conditioning for occupants. 

17 MR. BROOKMAN: A rather broad question here 

18 at the outset. 

19 MR. DARLINGTON: Yes, does anyone have any 

20 kind of ideas – we’re looking for feedback or any ways 

21 that would differentiate it, that would allow DOE to 

22 differentiate between, okay, this is equipment that’s 

23 only going to be used for industrial purposes, for 

24 process cooling, versus this is equipment that’s only 

25 going to be used for comfort cooling? 
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1 DR. AMRANE: I’m going to give this a try. 

2 I think you have to look at the test procedure and how 

3 the equipment is being advertised. If it’s, for 

4 example, advertised as being tested to, let’s say, in 

5 the case of AHRI 340/360, then it’s fine. All 

6 products tested to AHRI 340/360 then should meet the 

7 minimum energy efficiency requirements of ASHRAE 90.1. 

8 That’s how the ASHRAE standard looks at those 

9 products. 

10 MR. BROOKMAN: Ashley. 

11 MS. ARMSTRONG: Hi, Karim, so a question 

12 back to you. What if you have the same product by two 

13 different manufacturers one that is tested to AHRI 

14 340/360 and one that is not? They have a difference 

15 of opinion about whether their product may or may not 

16 be covered, and it seems like ASHRAE’s scope may be 

17 fairly wide. 

18 DR. AMRANE: Karim Amrane again, you say 

19 it’s the same product? 

20 MS. ARMSTRONG: Pretty much same exact 

21 product in terms of design and functionality. 

22 DR. AMRANE: By different companies? 

23 MS. ARMSTRONG: By different companies. One 

24 believes it may be covered, and one believes that it’s 

25 not. What do you do in that case? If it can be 
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1 tested? I mean, I would say scope of coverage, under 

2 DOE is – and Eric, feel free to speak up here, but 

3 it’s not determined whether it can or cannot be 

4 tested. I mean that’s obviously one thing the 

5 Department can consider, but scope of coverage – that 

6 is not the ultimate determination. We have a waiver 

7 process for those products that may be covered and 

8 don’t feel like the test procedure may apply to them. 

9 MR. BROOKMAN: Paul, go ahead. 

10 MR. DOPPEL: Paul Doppel, Mitsubishi 

11 Electric. You know, when a manufacturer designs their 

12 equipment and markets it, it’s for a specific – 

13 generally for purposes and applications that the 

14 manufacturer deems that they can support. The 

15 contractors in the U.S. market can take any piece of 

16 equipment and apply it in their own way, like a lot of 

17 – we’ve seen situations where Mitsubishi equipment has 

18 been used for wine cellars, which is not an intended 

19 process for that, and we’ve seen it for other things 

20 too. It depends on where you’re looking defining, and 

21 again, there’s not a standard for wine cellars, you 

22 know, but our equipment is being used for that. So 

23 our main intention – I think you have to look at what 

24 the company’s main intention is, and their main 

25 application is for that product. 
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1 MR. BROOKMAN: In their product literature? 

2 MR. DOPPEL: In their product literature and 

3 how they’re supporting that. 

4 MR. BROOKMAN: Ashley. 

5 MS. ARMSTRONG: So are there – let me open 

6 this up to anyone. Are there certain characteristics 

7 that would be defined in the product literature that 

8 makes it more for industrial applications as compared 

9 to commercial building type applications? 

10 MR. BROOKMAN: Karim. 

11 DR. AMRANE: Karim Amrane. It could be 

12 rating conditions. I mean, obviously, if you’re 

13 selling a product for industrial processes you would 

14 have different rating conditions, so in my opinion, it 

15 is what I said. If a manufacturer is advertising this 

16 as an air conditioner and publicizing the ratings 

17 based on AHRI 340/360 which is covered by DOE, then 

18 they should meet the minimum for those standards. 

19 Now if it’s different application, industrial process, 

20 then it’s different. 

21 MR. BROOKMAN: I think that’s what the 

22 Department was hoping for. Other simple descriptions 

23 of how these systems would be differentiated? Or 

24 thematic descriptions of how these systems would be 

25 differentiated? Okay. Let’s proceed. 
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1 MR. DARLINGTON: And as I just mentioned on one 

2 of the previous slides, previous versions of ASHRAE 

3 Standard 90.1 didn’t cover equipment that’s used 

4 primarily to provide industrial manufacturing 

5 commercial process cooling. ASHRAE Standard 90.1 in 

6 2010 expanded its scope and now includes air 

7 conditioners and condensing units used in computer 

8 room applications. In the Notice of Data Availability 

9 which DOE published on May 5, 2011, DOE tentatively 

10 concluded that it has the authority now to cover 

11 computer room air conditioners with the increase in 

12 scope in ASHRAE Standard 90.1. DOE has reiterated 

13 that position in its NOPR. 

14 In addition to the computer room air 

15 conditioners, DOE looked at the other products for 

16 which ASHRAE Standard 90.1 increased its efficiency 

17 levels, and this process shown here – the one 

18 exception being on this slide that for single package 

19 vertical air conditioners and heat pumps, ASHRAE 

20 Standard 90.1 2010 did not contain increased standard 

21 levels, but they were included in the NODA phase due 

22 to a separate requirement in EPCA to review those 

23 products. And this slide also shows DOE is proposing 

24 to adopt the ASHRAE levels for all of the equipment 

25 classes shown here on the slide, again with the 
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1 exception of the single package vertical air 

2 conditioners and heat pumps for which a separate 

3 rulemaking is being conducted. 

4 MR. BROOKMAN: Yes, Karim. 

5 DR. AMRANE: Karim Amrane, AHRI. Regarding 

6 single package vertical air conditioners, ASHRAE did 

7 amend the standards for those products, although those 

8 were not included in the 2010 revision, but they were 

9 included as an addendum to 2010 version, and the 

10 intent was for DOE to look at that as part of this 

11 rulemaking. I understand the nuances here, but we, as 

12 an industry, we do want DOE to review those levels as 

13 well as part of this rulemaking. 

14 MR. DARLINGTON: Yeah, and in light of the 

15 addendum that came out for the SPVUs, I think, and I 

16 can let DOE speak to this, but traditionally, they 

17 review it on the three year cycle when the full 

18 version is released, so – and I believe that was a 

19 little bit after, so that’s the reason. 

20 MR. BROOKMAN: Steve Rosenstock. 

21 MR. ROSENSTOCK: Yes, just as an FYI, 

22 following with Karim, I know those have been approved 

23 by the board and I think they’re in the supplement, 

24 aren’t they? Yes, they – so ASHRAE’s publishing a 

25 supplement to 90.1 2010 where those levels will be 
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1 included as an appendix list. So, officially it’s not 

2 the – it wasn’t version 2010, but it will be 

3 definitely published in the 2014, and basically it’s a 

4 supplement to the 2010 version where those levels are 

5 included. 

6 MR. BROOKMAN: Thank you. Karim. 

7 DR. AMRANE: If I may add, Karim Amrane, 

8 AHRI, I guess we would like DOE to consider those 

9 levels during this rulemaking that you’re doing right 

10 now, seriously consider those levels 

11 MR. BROOKMAN: Thank you. Ashley. 

12 MS. ARMSTRONG: Hi Karim. So one of the 

13 things that’s specific to us ... is the statute requires 

14 DOE to do a rulemaking within a – added to EISA, as a 

15 separate provision that requires DOE to do a separate 

16 rulemaking regardless of whether ASHRAE acts, so we 

17 are doing the separate rulemaking as part of that. We 

18 will take into consideration that it’s there, that’s 

19 just why it’s not in this rulemaking. 

20 MR. BROOKMAN: And that is for single 

21 package vertical air conditioners? Okay. Additional 

22 comments – that slide, I think, is well written and 

23 very descriptive. Additional comments related to that 

24 slide? 

25 MR. DARLINGTON: Okay. So we’ll just move 
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1 on. This slide basically shows the reasoning for the 

2 proposed adoption of the ASHRAE Standard 90.1 2010 

3 levels for these equipment classes. You can see that 

4 under the first bullet, there are very minimal energy 

5 savings for a few classes of equipment, the water 

6 cooled, evaporatively cooled equipment classes, as 

7 well as those two particular sized classes of VRF heat 

8 pumps. For computer room air conditioners, though, 

9 there is a lack of clear and convincing evidence that 

10 more stringent standards would be justifiable. This 

11 was due to several factors, including the uncertainty 

12 in the efficiency data, sort of a lack of efficiency 

13 data available since these products weren’t previously 

14 regulated. Uncertainty in the price-efficiency 

15 relationship which we’ll discuss a little bit later, 

16 once we talk about that, the inability to assess 

17 future changes in equipment efficiencies, and then the 

18 lack of shipment information for the United States – 

19 and again, we’ll touch on both of those later when we 

20 talk about the analysis for computer room air 

21 conditioners. 

22 And then as we mentioned on the previous 

23 slide for SPVU – or single package vertical air 

24 conditioners and heat pumps, the analysis is part of a 

25 separate rulemaking. So this slide – 
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1 MR. BROOKMAN: Hang on. Paul, please, go 

2 ahead. 

3 MR. DOPPEL: Paul Doppel, Mitsubishi 

4 Electric. The inclusion of the room – the computer 

5 room air conditioners brings up a question in that 

6 Mitsubishi Electric has manufactured a certain product 

7 type that over the years has been used in server rooms 

8 and things of that nature. So, is there going to be a 

9 clear definition of a system that’s called a computer 

10 room unit, because again, our systems are established 

11 as comfort air conditioners, but because they have 

12 capabilities to operate at low ambient conditions in 

13 cooling, they have been used for many years in those 

14 type of applications. 

15 MR. DARLINGTON: Right, and it’s difficult 

16 to come up with a definition that clearly 

17 distinguishes between those products that can be used 

18 in comfort conditioning and also are sometimes used in 

19 applications for computers. We’ll discuss that a 

20 little bit later on when we talk about the proposed 

21 definition, and you’ll see DOE’s proposed definition – 

22 we’ll ask for comment at that time. 

23 MR. BROOKMAN: Yes, Eric Stas. 

24 MR. STAS: Eric Stas, DOE. I mean that’s an 

25 area where we would specifically invite comments to 
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1 help us come up with an objective and robust 

2 definition for that term, so as much as just reacting 

3 to what we put out there, we’d really like your input 

4 to help come up with an objective distinction. 

5 MR. BROOKMAN: Paul Doppel. 

6 MR. DOPPEL: Paul Doppel, Mitsubishi 

7 Electric. I just wanted to make sure that, you know, 

8 a product like that wasn’t going to be sort of 

9 required to meet both standards, just because it’s 

10 being used. Again, if we don’t promote it, but it’s 

11 used in that fashion, that’s the question that we 

12 have. 

13 MR. BROOKMAN: Ashley. 

14 MS. ARMSTRONG: I think when we get to the 

15 definitions part, the definitions for VRFs are right 

16 before the definitions for computer room air 

17 conditioners. If you read them as not being mutually 

18 exclusive, like in other words, there could be some 

19 overlap, please point that out to us. Because I don’t 

20 think the intention would be two standards for the 

21 same product. 

22 MR. BROOKMAN: Thank you, that’s helpful. 

23 Yes. 

24 MR. DARLINGTON: And so now this briefly 

25 summarizes the analysis for water-cooled and 
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1 evaporatively-cooled air conditioners. The potential 

2 energy savings analysis was done as part of the May 5, 

3 2011 NODA that I alluded to earlier. And basically 

4 the results of the potential energy savings analysis 

5 was a very, very minimal amount of energy savings 

6 above the ASHRAE Standard 90.1 2010 levels, which is 

7 why DOE is proposing to adopt those levels. 

8 And then similarly, with the variable 

9 refrigerant flow water source heat pumps above 135 

10 kBtu per hour, DOE conducted a potential energy 

11 savings analysis as part of this NOPR and the details 

12 of that are in the TSD. Some of the details are shown 

13 on this slide, but essentially the sum of the national 

14 energy savings for standards exceeding ASHRAE Standard 

15 90.1 2010 were again found to be minimal. So that 

16 takes us to the end of the determination of scope, and 

17 if there are no comments, we’ll move on to the test 

18 procedure section. 

19 MR. BROOKMAN: Additional comments on 

20 determination of scope? Okay. 

21 Test Procedures

22 MR. DARLINGTON: Very briefly here. This 

23 slide shows that EPCA requires DOE to amend its test 

24 procedures to update them to the most recently 

25 accepted industry standard, as referenced in ASHRAE 
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1 Standard 90.1 2010, obviously, unless the Secretary 

2 determines that clear and convincing evidence exists 

3 that it would not meet the requirement for test 

4 procedures in EPCA. Those requirements are shown in 

5 the third bullet on this slide, that they be 

6 reasonably designed to produce results reflecting 

7 energy efficiency or energy use and that they not be 

8 overly burdensome to conduct. And in addition to 

9 that, EPCA requires DOE to conduct an evaluation of 

10 its test procedures for the covered equipment at least 

11 once every seven years. 

12 And DOE reviewed the test procedures in 

13 ASHRAE Standard 90.1 2010. Now in reading those test 

14 procedures, DOE found that ASHRAE Standard 90.1 2010 

15 updated its reference test procedures for a number of 

16 test procedures. So the first group of test 

17 procedures here on the slide are the ones that DOE is 

18 proposing to update to the most recent version. 

19 Basically, for all of these test procedures, DOE 

20 reviewed the changes in the new version of the test 

21 procedure as compared to the old version of the test 

22 procedure to see if anything would greatly impact the 

23 energy efficiency ratings of those equipments, or add 

24 to the burden of the test method. In all of these 

25 cases, DOE found that the changes were relatively 
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1 minor and that they still met the requirements of EPCA 

2 for test procedures, so DOE is proposing to adopt the 

3 updated test methods. 

4 And for the test procedures listed in the 

5 second bullet, DOE is also proposing to adopt test 

6 procedure AHRI 390 for single package vertical air 

7 conditioners and heat pumps. AHRI 1230 with Addendum 

8 1 for VRF multi-split systems, and ASHRAE 127 for 

9 computer room air conditioners. 

10 MR. BROOKMAN: Question. 

11 MR. DOPPEL: Paul Doppel with Mitsubishi 

12 Electric. On the 1230 standard, I think there’s – 

13 it’s not real clear when you read through here – one 

14 of the things that we did when we developed the 

15 standard was to include systems that we called VRF 

16 that are less than 65,000. So there’s a broad range 

17 of products, as well as a water source, and, you know, 

18 so in essence, these would be systems that are 

19 covered, the multi-split systems less than 65 would 

20 then be removed, sort of, from 210/240 and brought 

21 into – underneath 1230. That is what we would hope 

22 would come of this. 

23 MR. DARLINGTON: This would apply only to 

24 the commercial equipment classes. So as far as 

25 residential – 
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1 DR. AMRANE: Correct, we’re not thinking 

2 about the residential right now, we’re thinking about 

3 related 65 three-phase product here, that – 

4 MR. DARLINGTON: Yes, DOE – 

5 DR. AMRANE: -- covered within 90.1. 

6 MR. DOPPEL: Commercial. When you say 

7 commercial that usually is – there’s an implication 

8 that’s three-phase. 

9 MR. DARLINGTON: Right. 

10 MR. DOPPEL: So the equipment we’re talking 

11 about is single phase less than 65. 

12 MR. BROOKMAN: Thanks, Paul. Was that 

13 clear? 

14 MR. DARLINGTON: Not sure. So are you 

15 asking specifically about the single phase less than 

16 65? 

17 MR. DOPPEL: Right, because those are 

18 covered by 1230 standard also. 

19 MR. BROOKMAN: So, Paul, would you restate 

20 what – what you’re trying to accomplish here? 

21 MS. ARMSTRONG: Quick question before – 

22 MR. BROOKMAN: Ashley Armstrong. 

23 MS. ARMSTRONG: -- Ashley. They are covered 

24 under a waiver now? Are they currently covered by a 

25 waiver? 
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1 MR. DOPPEL: They were at one time, but I 

2 think it was three, at least three years ago, there 

3 was a rulemaking that had multi-split systems -- 

4 MS. ARMSTRONG: Correct. 

5 MR. DOPPEL: -- put under 210/240 and 

6 waivers were removed. So now with the 1230 standard, 

7 the 1230 standard covers testing of systems less than 

8 65,000, with all the appropriate references that would 

9 be needed to do that. 

10 MS. ARMSTRONG: Okay. 

11 MR. DARLINGTON: Yeah, this rulemaking is 

12 only going to cover the three-phase commercial 

13 equipment, so I believe that single phase equipment 

14 under 65,000 would be classified with the residential 

15 product category. 

16 MS. ARMSTRONG: So – 

17 MR. DARLINGTON: So this would not update 

18 the test method for those, right. 

19 MS. ARMSTRONG: Right, and to change it from 

20 210/240 you need a waiver, unless we address it in the 

21 central air conditioner test procedure rule. 

22 DR. AMRANE: I think it has already been 

23 addressed. 

24 MS. ARMSTRONG: Correct. 

25 MR. BROOKMAN: Okay, Karim, thank you. 
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1 Paul, did we resolve that? 

2 MS. ARMSTRONG: Kind of. 

3 MR. DOPPEL: I’m continuing to listen. 

4 MR. BROOKMAN: Okay, that’s probably a good 

5 practice. Do you have anything to add at this point? 

6 MR. DOPPEL: No, I think I’m okay. 

7 MR. BROOKMAN: Yes, please, Gary. 

8 MR. NETTINGER: Gary Nettinger, Panasonic 

9 Air Conditioning. Following up to Paul Doppel’s 

10 comment, the VRF multi-split product below 65 is 

11 designed virtually identical to that product above 65. 

12 The phase is the main difference. So longer term, 

13 what would be the process for us to get that type of 

14 product incorporated into a commercial? 

15 MR. DOPPEL: Paul Doppel with Mitsubishi 

16 Electric. I think the – we sort of put the testing 

17 procedures for those products in 1230, and the 210/240 

18 I don’t think adequately addresses the VRF type 

19 product, because that’s – I mean it was, I think at 

20 AHRI was considered that that product would fold under 

21 the 1230, because since we wrote the 1230 to include 

22 those products. 

23 MR. NETTINGER: And the testing process is, 

24 of course, different between 210/240 and 1230. 

25 MR. DOPPEL: Well, the testing – for 
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1 variable systems – for variable speed equipment and 

2 for VRF multi-split under 65, the testing is 

3 essentially saying what is lacking in 210/240 is how 

4 to deal with multiple indoor units, and that’s covered 

5 in 1230. 

6 MS. ARMSTRONG: And so – this is Ashley – 

7 and 1230 you get out for single phase units, a SEER ... 

8 comfort three phase unit in EER metric? 

9 MR. DOPPEL: Yes, it’s all covered. Yes, 

10 it’s all covered in 1230. 

11 MS. ARMSTRONG: Okay. So maybe a couple 

12 different processes, but we hear what you’re saying 

13 what we have to deal with. We deal with residential 

14 separate than commercial. This rulemaking is going to 

15 be commercial three-phase, residential may be 

16 separately, but we hear what you’re saying and we can 

17 figure out where to go from here. 

18 MR. DOPPEL: Right. 

19 MR. DARLINGTON: Okay. I’ll just go on to 

20 the last bullet of this slide. Basically, it’s to 

21 clarify certain AHRI and ASHRAE test methods that are 

22 being adopted or updated here contain certain 

23 tolerances that allow the published ratings to be 

24 within a certain percent of the measured ratings. For 

25 example, some of them read that measured test results 
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1 shall not be less than 95 percent of published 

2 ratings. I just want to clarify here that DOE does 

3 not intend to adopt those provisions when it updates 

4 the test procedures. 

5 MR. BROOKMAN: Yes, Steve Rosenstock. 

6 MR. ROSENSTOCK: Steve Rosenstock. I 

7 haven’t looked at the test procedures but aren’t they, 

8 just because I’ll say, of testing equipment, 

9 variations, that usually isn’t there – a lot of 

10 equipment that I’ve seen, it’s plus or minus x percent 

11 in terms of your final accuracy. So again, let’s just 

12 say 13 SEER or whatever EER, there is going to be some 

13 plus or minus in there just because of the accuracy of 

14 the test equipment. This seems to indicate, this 

15 slide, you know, I may be – it looks like, we’re not 

16 going to allow any tolerance, so – and that’s not 

17 good. 

18 

19 MR. DARLINGTON: DOE establishes its own 

20 tolerances as part of the certification program, and 

21 Ashley can – if you have anything to add on to that? 

22 MR. BROOKMAN: Ashley. 

23 MS. ARMSTRONG: We do have tolerances, and 

24 they are meant for just that. We recognize that there 

25 is unit to unit variation coming off the line, there’s 
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1 the variation inherent in test equipment, there’s 

2 variation inherent in lab to lab variability. There 

3 are tolerances. They are product specific, and we 

4 have them across the board for all the testing 

5 manufacturers made for certification purposes. We 

6 just want to make clear that our tolerances are in 

7 Part 421, they’re applicable to this equipment, and 

8 there are some – there is some language in the test 

9 procedures being incorporated by reference that is not 

10 completely consistent. It’s not exactly the same as 

11 we do apply our tolerances, so we want to make clear 

12 that our tolerances are different. It doesn’t mean 

13 that you can have an additional tolerance, or one in 

14 lieu of the other. But DOE does have separate 

15 tolerances as we recognize the need for them. 

16 DR. AMRANE: And what are they? Karim 

17 Amrane with AHRI. Tell us the tolerances that you 

18 have. 

19 MS. ARMSTRONG: So it’s not as simple as the 

20 five percent. It’s based on the unit to unit 

21 variation, but effectively they’re based on the 95 

22 percent confidence level which if you take two 

23 identical units could correspond to close to five 

24 percent. 

25 DR. AMRANE: But again, you are applying 
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1 something that was developed for white goods and 

2 appliances 30 years ago to commercial product, and I 

3 don’t think it’s applicable here. 

4 MS. ARMSTRONG: So if you have suggestions 

5 on how – 

6 DR. AMRANE: Keep those tolerances in AHRI 

7 standards, absolutely. 

8 MS. ARMSTRONG: Okay. 

9 MR. BROOKMAN: Mohammed. 

10 MR. KHAN: Mohammed Khan, DOE. Karim, we 

11 definitely appreciate that and recognize that there 

12 definitely could be differences in what would be the 

13 applicable appropriate tolerances, and to come up with 

14 that accurate or appropriate tolerance level would 

15 definitely require some significant testing. So if, 

16 as you said, if you would provide something based on 

17 some testing, that would be really great for the 

18 Department. 

19 MR. BROOKMAN: Steve Rosenstock. 

20 MR. ROSENSTOCK: Steve Rosenstock – 

21 MR. BROOKMAN: Steve – let Karim follow on. 

22 I’m sorry. 

23 DR. AMRANE: Karim Amrane, AHRI. Again, I 

24 put the question to DOE, have you done any testing 

25 that shows that the five percent tolerance that we 
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1 have at AHRI still is not appropriate, and when you 

2 compare the tolerances with what DOE has in its own 

3 regs, have you done some testing? 

4 MR. BROOKMAN: Ashley. 

5 MS. ARMSTRONG: Yes. 

6 DR. AMRANE: Tell us. 

7 MS. ARMSTRONG: So some of the testing I 

8 can’t share those results yet because it’s not public, 

9 but yes, we’ve done some testing. I think some of 

10 it’s going to be unit specific or model specific as to 

11 what the results may show. Some may show quite a bit 

12 wider variability than the five percent, others may 

13 show a smaller variability. And like I said, we 

14 welcome comments as to why they should be different 

15 tolerances, in terms of the level, the 95 percent 

16 confidence level, the 98, the 97 are product-specific. 

17 They’re meant to apply the product specific 

18 variability inherent within that product. They’re not 

19 all – some of our lighting products that are high 

20 volume, pretty streamlined manufacturing, are at 99 

21 percent tolerance level. That is not something we 

22 have adopted for commercial equipment. We would 

23 recognize the differences there. 

24 DR. AMRANE: If I may follow. Karim Amrane 

25 with AHRI again. Those products were regulated since 
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1 1992. The five percent tolerance in the HR still has 

2 been there even before 1992. Why is it that DOE now, 

3 suddenly, is changing the game? 

4 MS. ARMSTRONG: I would say that, you know, 

5 in 2006 we adopted ... for certification testing and 

6 enforcement testing for commercial equipment. As part 

7 of that rulemaking, we went through all this with 

8 different types of tolerances. That rulemaking had 

9 been going on for a number of years, and it set up 

10 those tolerances then. We have never had the AHRI 

11 five percent tolerance in our regs whole heartedly. 

12 What we did have there was – and it wasn’t – that’s 

13 how you run your verification program, and that is up 

14 to you guys. But when manufacturers do their testing 

15 for certification purposes, there are tolerances, 

16 they’re now effective in Part 429, and they have been 

17 around since 2006, that people should be using. 

18 MR. BROOKMAN: Hang on one second. Are you, 

19 Karim, nothing additional? Steve I want to finish 

20 this stream out here, okay? So Robert, please. 

21 MR. WILKINS: Robert Wilkins with Danfoss. 

22 Let me preface my comment by saying I’m not taking 

23 sides. I’m not saying one way of doing it is better 

24 than the other way of doing it. But I would urge that 

25 DOE work with industry to resolve and to come up with 
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1 a common set of tolerances so that, for goodness sake, 

2 we don’t come out of this rulemaking process with two 

3 separate sets of standards, and two separate purposes. 

4 So, I’m just urging DOE to work with the industry to 

5 find a solution and find tolerances that are practical 

6 and workable, rather than having two separate sets. 

7 MR. BROOKMAN: Any additional comments on 

8 this subject, because we’re about to move on? Steve 

9 Rosenstock. 

10 MR. ROSENSTOCK: Thank you. Steve 

11 Rosenstock, EEI. We normally don’t comment on test 

12 procedures, but I’m just thinking, just based on this 

13 discussion that, you know, if, I’ll say the DOE 

14 tolerances are a lot higher confidence level, let’s 

15 say it’s 98, 99 percent in terms of some of the 

16 certain products, there are additional costs to 

17 manufacturers and at some point is going to be 

18 reflected in probably the cost of the products, so in 

19 some ways I can understand, well, you know, maybe 

20 there’s a thought that we need to test to a tighter 

21 tolerance to make sure we’re getting those energy 

22 savings, but the end result could be, if those costs 

23 go up to the consumers for the higher efficiency 

24 product and an increase in incremental cost, again, 

25 laws of unintended consequences is you raise the 
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1 initial price, fewer customers are willing to make 

2 that incremental investment for that higher efficiency 

3 savings. So again, just down the road, a possible 

4 unintended consequence of I’ll say, two different 

5 tolerances meeting separate tests for certification 

6 versus DOE. Thank you. 

7 MR. BROOKMAN: Warren. 

8 MR. BEETON: Warren Beeton, Emerson. I’d 

9 also add that the DOE process is a snapshot in a short 

10 period of time compared to what AHRI’s analysis of 

11 test tolerance requirements are, product standard 

12 tolerances has been done over years, as Karim said. 

13 So there’s a risk for DOE on both sides of being too 

14 tight or too wide, because they’re looking at a very 

15 limited test set in a limited period of time. So I 

16 would encourage DOE to strongly consider what the 

17 industry has already established as the best set of 

18 tolerances to use. And also, I assume that DOE – and 

19 this is a question – will DOE be showing what they are 

20 going to propose and the analysis behind it for 

21 discussion before trying to set tolerances. 

22 MR. BROOKMAN: Hold on for a minute. 

23 MS. ARMSTRONG: Can I answer that real quick 

24 before you move on? 

25 MR. BROOKMAN: Ashley, please. 
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1 MS. ARMSTRONG: So our tolerances are 

2 adopted. They’ve been adopted since 2009, I mean 

3 2006, and they’ve been established for the commercial 

4 HVAC equipment. To Steve’s point, I believe off the 

5 top of my head, I don’t have the CFR in front of me, I 

6 don’t believe there’s anything tighter than the 

7 manufacturer’s 95 percent confidence for the equipment 

8 we’re talking about to here. Some cases I believe 

9 it’s a little bit broader than that, but that’s just 

10 off the top of my head. We did that through the 

11 rulemaking process. That being said, we’re happy to 

12 work with Karim and industry to see if they need to be 

13 revisited. I don’t know that we will do it in this 

14 proceeding, but we will definitely look at that. 

15 MR. BROOKMAN: Warren, you want to follow 

16 on? 

17 MR. BEETON: Were those tolerances different 

18 than AHRI tolerances? 

19 MR. BROOKMAN: Ashley? 

20 MS. ARMSTRONG: The way we do our tolerances 

21 is not a flat five percent. It’s based on the 

22 variation of the sample that was tested. So yes, the 

23 way it’s done is different. 

24 MR. BEETON: My question wasn’t the way it 

25 is done, my question was are the tolerances that you 
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1 ended up with different than what AHRI uses in its 

2 standards? 

3 MS. ARMSTRONG: What I said is you can’t 

4 apply five percent equally. In certain cases, 

5 depending on the variation of the sample, the five 

6 percent doesn’t go across the board, because if you 

7 use a 95 percent confidence limit, it’s going to 

8 depend on the distribution of that sample. So it’s 

9 not just a five percent on top of the standard. It 

10 could be tighter or looser depending on the variation 

11 in that sample itself. 

12 MR. BROOKMAN: Paul Doppel. 

13 MR. DOPPEL: Paul Doppel, Mitsubishi 

14 Electric. The five percent standard has been around 

15 for a number of years and here’s the real implication 

16 for this. Manufacturers have known this five percent, 

17 and so when they’re developing, designing systems, 

18 they look for ways to come up with consistency within 

19 a certain level. And then that design has to be 

20 developed into an assembly process, and that assembly 

21 process, those things have to – everything has to work 

22 together to be within that tolerance. So if there’s a 

23 variable tolerance, I mean, it’s like Russian 

24 roulette. And if you’re going to make something 

25 tighter, then manufacturers have to go back and spend 
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1 significant amounts of money to review all their 

2 process, review all their designs, and what Steve 

3 Rosenstock said, is exactly what’s going to be true. 

4 Even for the standard efficiency products, especially 

5 with those, because there’s no tolerance less than the 

6 minimum, then the products are going to be almost out 

7 of reach because, you know, manufacturers have to have 

8 certainty about what they are doing when they do their 

9 designs, do their manufacturing processes. And this 

10 does not provide that at all. 

11 MR. BROOKMAN: Karim. 

12 DR. AMRANE: Karim Amrane, AHRI. I guess I 

13 would like to add that those DOE tolerances were not 

14 developed for commercial products. I don’t think DOE 

15 did any analysis on those products. I think they 

16 adopted what was done for white goods and consumer 

17 products. Again, commercial products are very 

18 different and I think they need special attention. 

19 Now, the idea to do over the tolerance without 

20 changing what DOE has today is not going to be 

21 acceptable to industry. Somehow those have to go 

22 together. If you want to use the 95 percent AHRI 

23 standard, you will have to address that standard in 

24 the DOE regs at the same time. 

25 MR. BROOKMAN: Any additional comments? 
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1 Okay. 

2 MR. DARLINGTON: Okay. Moving on. A number 

3 of comments that DOE is – a number of issues that DOE 

4 is seeking comment on, I know we had a lot of 

5 discussion about the tolerances, but here DOE is also 

6 seeking comment on its proposed adoption of the test 

7 procedures that we went over on the previous slide, so 

8 if anyone has any general comments about those test 

9 procedures or DOE’s proposed adoption of them, now 

10 would be the time. 

11 MR. BROOKMAN: Joanna Mauer. 

12 MS. MAUER: Joanna Mauer. So I want to 

13 comment on the proposed test procedure for the 

14 computer room air conditioners and I don’t pretend to 

15 be an expert on computer room air conditioners, but my 

16 understanding is that these products essentially are 

17 always operating at part load in the field. But I 

18 think DOE notes in the NOPR that the SCOP metric 

19 doesn’t capture part load performance. And so my 

20 understanding is that the SCOP metric doesn’t well 

21 reflect how these products are actually performing in 

22 the field. And I also understand there can be 

23 significant energy savings from variable speed fans, 

24 for example, and those technologies might not be 

25 captured in the SCOP metric. So I don’t have a 
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1 specific recommendation at this point, but we’d urge 

2 DOE to consider a test procedure that does capture 

3 part load performance. 

4 MR. BROOKMAN: Okay. Thank you. 

5 MR. DARLINGTON: And just a note. So DOE is 

6 proposing this because this was the industry standard 

7 adopted by ASHRAE. I noted our concerns with the part 

8 load operation and the variable speed, but I think 

9 it’s a similar situation for all other commercial 

10 products are rated using an EER metric. 

11 MR. BROOKMAN: Joanna. 

12 MS. MAUER: So I guess, you know, DOE does 

13 have the ability – DOE certainly has to look at the 

14 ASHRAE test procedures, and I understand that. I 

15 think DOE does have the ability to make changes if the 

16 test procedures don’t do a good job of representing 

17 the actual performance of the products. I think the 

18 products, you know, we’d like DOE to adopt the IEER 

19 metrics that are also an ASHRAE standard which capture 

20 part load, but that’s a separate issue. 

21 MR. BROOKMAN: Do you think that in this 

22 case that what DOE is proposing doesn’t reflect real 

23 world conditions? 

24 MS. MAUER: Yeah. That’s right. And 

25 because of that, DOE can’t capture these technologies 
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1 that will have significance in the field, but the 

2 benefits won’t be reflected in the test procedure. 

3 MR. BROOKMAN: Karim. 

4 DR. AMRANE: Karim Amrane, AHRI. I guess to 

5 answer your question, I think right now that’s the 

6 only test procedure available, that’s the ASHRAE 

7 standard and I think DOE has, well, is basically 

8 adopting what ASHRAE has done. But in the future we 

9 are, the AHRI, are putting together a product section 

10 on data centers and we will be writing a standard and 

11 that standard will definitely have a part load metric 

12 eventually. So I think it’s for maybe the next round, 

13 eventually that one day there will be a test procedure 

14 to look at, I think, it would be a good idea too. 

15 MR. BROOKMAN: Do you have a time table for 

16 that, Karim? 

17 DR. AMRANE: Again, no, we’re just putting 

18 the product section together, you know, when the 

19 standard will be written, I don’t know, but I – 

20 MR. BROOKMAN: Will it be a three year 

21 cycle? 

22 DR. AMRANE: Oh, yes, it will be before the 

23 three year cycle. Yes, for sure. 

24 MR. BROOKMAN: Mohammed. 

25 MR. KHAN: Mohammed Khan, DOE. And of 
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1 course, the Department will consider whatever 

2 potential benefits there really would yield from that 

3 revised test procedure, versus whatever potential 

4 additional burdens there may be as well, in making its 

5 determination as to whether it makes sense to adopt 

6 it. 

7 MR. BROOKMAN: Additional comments? You see 

8 three issues boxes here. The Department is seeking 

9 comment on all of these test procedures and also 

10 adoption of the new test procedures. So any 

11 additional comments because we’re about to move on 

12 from here. And of course, if you come up with more, 

13 the Department would like details in writing. Okay. 

14 MR. DARLINGTON: All right? 

15 MR. BROOKMAN: Yeah. 

16 MR. DARLINGTON: So this test procedure, 

17 this slide basically relates to DOE’s efforts as it is 

18 testing equipment. DOE sometimes receives ad hoc 

19 requests to tailor the test procedures during the 

20 testing set up and operation. This slide is basically 

21 to provide general guidance that for DOE’s efforts, 

22 the Department only uses conditions that are specified 

23 in the DOE test procedures or that is presented in the 

24 installation operating manuals, and DOE is not 

25 currently using any additional information. 
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1 Now DOE just wishes to harmonize the way it 

2 conducts its testing, with the way that the testing is 

3 being done by manufacturers and independent test labs. 

4 And that brings us to the next issue, which is, you 

5 know, for these given test procedures that we’ve 

6 discussed, are there additional settings, other 

7 additional tolerances and specifications in the test 

8 procedure where more information would help DOE to 

9 replicate the tests and the ratings that are being 

10 achieved in those tests? 

11 MR. BROOKMAN: Adam, will you go back to the 

12 preceding slide? Please? Twenty-two. 

13 MR. DARLINGTON: Sure. 

14 MR. BROOKMAN: Let’s just give everybody a 

15 chance to digest this. 

16 MR. DARLINGTON: So it’s a lot written on 

17 the slide, but the basic point that it’s conveying 

18 here is that, what I just said basically, that the 

19 Department’s only going to use, and is only using, you 

20 know, information in its test procedures and in the 

21 installation manuals. 

22 MR. BROOKMAN: Okay. Karim. 

23 DR. AMRANE: Karim Amrane, AHRI. As you 

24 know, AHRI runs certification programs, verification 

25 programs and has been running those for many years, 
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1 and it is true that every program that we run we have 

2 what we call an operational manual. It’s documented, 

3 describes the verification program, and in those 

4 documents sometimes there are clarification about test 

5 procedures and how to run the test. And to the extent 

6 that this could help DOE, then we are going to 

7 encourage DOE to look at those documents and to adopt 

8 them, reference them, any way DOE can, absolutely. 

9 MR. BROOKMAN: Paul. 

10 MR. DOPPEL: Paul Doppel, Mitsubishi 

11 Electric. I think, especially in the case of VRF 

12 systems, it would be essential to adopt also the – or 

13 incorporate the operations manual because that 

14 provides good guidance in there, additional guidance 

15 on how to set up the systems and what things are 

16 required by the manufacturer in order to do the 

17 testing. 

18 MR. BROOKMAN: Okay. Additional comments? 

19 MR. DARLINGTON: Okay. This brings us to 

20 the break-in provisions. So in DOE’s review of AHRI’s 

21 certification program that Karim just alluded to, DOE 

22 discovered that AHRI allows for a compressor break-in 

23 period for its certification program for commercial 

24 equipment. Basically this allows the compressor to 

25 warm up to achieve optimum performance, and DOE 
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1 believes this is more representative of the 

2 performance in the actual field, so DOE is proposing 

3 to allow manufacturers optionally, at their 

4 discretion, to use this break-in period. Now DOE is 

5 proposing the break-in period be allowed up to 16 

6 hours to break in the product, and if manufacturers do 

7 choose to use this optional period, DOE would require 

8 them to report the length of time used to break in the 

9 product. 

10 And DOE is seeking comments about the use of 

11 this compressor break-in period as part of the AHRI 

12 test procedures which it’s adopting, and about the 

13 need for this break-in period. 

14 MR. BROOKMAN: Warren. 

15 MR. BEETON: Is that break-in period the 

16 same as what we allow, Karim, do you know? It is. 

17 Okay. The break-in period is absolutely required for 

18 compressor – to stabilize compressor performance and 

19 efficiency. That would be my comment. 

20 MR. BROOKMAN: Thank you. Karim. 

21 MR. AMRANE: Karim Amrane, AHRI. I think we 

22 would support that proposal. 

23 MR. BROOKMAN: Thank you. Great. Additional 

24 comments on the break-in period. Going on. 

25 MR. DARLINGTON: And moving on. Again, a 
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1 lot of language on this slide, but I’ll just summarize 

2 quickly. So AHRI 1230 for VRF systems, DOE reviewed 

3 it and found certain provisions that allowed for or 

4 required manufacturer assistance in conducting the 

5 test. So DOE, basically, the purpose of this slide is 

6 to facilitate some discussion so DOE can learn more 

7 about how these systems operate and achieve steady8 state conditions for testing, and DOE is interested, I 

9 guess, sort of somewhat limiting the manufacturer’s 

10 role in the testing so that independent and repeatable 

11 tests could be achieved without as much manufacturer 

12 involvement. 

13 And so that brings us to the comment 

14 request, issue number nine, DOE is seeking comment 

15 about the testing conditions, operating points, test 

16 set-up, anything else for the VRF systems that would 

17 allow DOE to run the test independently. 

18 MR. BROOKMAN: Paul Doppel. 

19 MR. DOPPEL: Paul Doppel, Mitsubishi 

20 Electric. You know, I think we have to take a look at 

21 really how these systems operate and then how we came 

22 up with the testing for them. And VRF, or variable 

23 speed, variable refrigerant flow, or variable speed 

24 systems, all the sensors, everything within the system 

25 is providing information to the inverter drive or to 
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1 the intelligence in that system to tell the compressor 

2 to move to speeds, change speeds to achieve the 

3 optimum to provide the necessary heating or cooling 

4 for that condition. 

5 However, when we do the testing, when we set 

6 up the testing, what we had to do was use something 

7 that was sort of equivalent with what the unitary 

8 manufacturers were doing so that we could provide 

9 similar ratings, similar efficiencies. We requested 

10 waivers from AHRI standard 340/360, which was based on 

11 EER and COP and IPLV at the time, which has changed to 

12 IEER. So in doing those, what we’ve ended up having 

13 to do is to – and this actually also applies to 

14 systems less than 65,000, where we have to do five 

15 tests to determine SEER and five tests to determine 

16 HSPF. But all of these, whether it’s the below 65 or 

17 greater than 65, we’re having to fix the compressor 

18 speed which is fully intended, when the system is 

19 operating, to float. So this creates additional 

20 stabilization issues within the system, and in some, 

21 many cases it takes longer to test these systems, and 

22 actually they’re not operating as efficiently as they 

23 would if they were allowed to float freely. 

24 So, that’s kind of the background on how we 

25 got to where we’re testing these standards. So with 
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1 the VRF systems, and even with the multi-split systems 

2 less than 65, these are complex systems and it’s not 

3 like taking a five ton or a 20 ton rooftop unit and 

4 rolling it into the test room and attaching the 

5 thermostat and some duct work and running it. These 

6 systems have to be fully assembled, could have up to 

7 three outdoor units that have to be put together. You 

8 could have up to 12 indoor units that would have to be 

9 put together. You have all the piping, all the wiring 

10 joining those together, so there’s – you have to make 

11 sure that the systems are functioning properly from a 

12 mechanical perspective, and also on a control basis. 

13 And each of the manufacturers has a different type of 

14 control. Each of the manufacturers does heat recovery 

15 differently. So there’s a lot that goes into setting 

16 up and running these systems. 

17 You know, a rooftop system can be set up and 

18 tested almost within one shift at the Intertek or 

19 whatever lab. VRF systems take sometimes more than 

20 two shifts of work just to set the system up to be 

21 tested. So it’s extremely complex, and there has to 

22 be verification that the system is operating properly, 

23 and each manufacturer has special diagnostic tools to 

24 be able to go in there. So that – these diagnostic 

25 tools require special training. And so, to do these 
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1 tests and it’s just – I don’t think it’s possible to 

2 be able to independently set up one and test one of 

3 these systems without the manufacturer there, not only 

4 to verify the setup, but also to provide assistance in 

5 making sure that the system is operating properly, to 

6 properly set the conditions for each of the tests that 

7 are being conducted, and then also to provide 

8 assistance if there’s issues in stabilization of 

9 system operation. 

10 MR. BROOKMAN: Yes, Gary. 

11 MR. NETTINGER: Gary Nettinger, Panasonic. 

12 I, as a manufacturer of VRF equipment, I appreciate 

13 the Department’s interest to take the manufacturers’ 

14 involvement out of the testing process to insure 

15 consistency, but with this type of product, as Paul 

16 Doppel mentioned, the equipment is constantly 

17 fluctuating. Without the manufacturer’s intervention 

18 to fix the compressor speed, I don’t believe that 

19 steady state could be achieved in a test facility. 

20 MR. BROOKMAN: Is that what the 

21 manufacturer’s doing? 

22 MR. NETTINGER: They’re fixing the 

23 compressor speed. 

24 MR. BROOKMAN: Speed. 

25 MR. NETTINGER: So that we can achieve – 
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1 MR. BROOKMAN: They’re not doing other 

2 things as well? 

3 MR. NETTINGER: No, motor speed only. And 

4 that’s defined in the operations manual of 1230. Also 

5 I think it’s important to have the manufacturers’ 

6 involvement to oversee the installation of the 

7 equipment. There are so many distribution joint kits 

8 and restrictions on the piping, we need to be sure 

9 that ITS or whatever the test facility that’s testing 

10 the equipment is doing it the same way it’s designed 

11 to be installed and the same we’ve tested it in our 

12 own facilities, otherwise, there’s no way that we 

13 would be within tolerance. So manufacturers have to 

14 be involved, at least at this time, I believe. 

15 MR. BROOKMAN: Okay. Paul. 

16 MR. DOPPEL: Paul Doppel, initial comment on 

17 the testing. The collection of the data is extremely 

18 important and again, the comparison to a rooftop, you 

19 have one point of air flow. With VRF systems, you 

20 could possibly have 12 points of air flow that have to 

21 be gathered together, or tested individually, in order 

22 to get the proper capacity measurements. And if 

23 that’s not done properly, and if there’s not agreement 

24 that it’s being done properly, then it’s really not an 

25 adequate test. And Intertek has worked with AHRI in 
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1 setting up the testing procedures and the collection. 

2 In fact, there’s another meeting that’s going on with 

3 the engineering committee of the ductless products 

4 section to further that comparison of testing – 

5 collection data to make sure that those things are 

6 being adequately measured. 

7 Now, at AHRI, you know, the fact that 

8 manufacturers are present for these conditions is 

9 something that has been in this 1230 standard, and 

10 non-VRF manufacturers, you know, like Carrier, Trane, 

11 Lennox, Johnson Controls or Emerson or all other 

12 manufacturers that are present there, have been – have 

13 seen this and these test standards have been approved. 

14 So what we do is deemed to be equal with every other 

15 test standard, and it’s passed the scrutiny of all 

16 other manufacturers, otherwise we would not have been 

17 able to have had that test standard approved. So it’s 

18 an accepted practice at AHRI by all the manufacturers. 

19 MR. BROOKMAN: Okay. Warren. 

20 MR. BEETON: Our company – Warren Beeton, 

21 Emerson. Our company also makes compressors that are 

22 used in these products, they’ve variable capacity and 

23 our experience is exactly what we’re hearing from our 

24 customer base here. In fact, I go so far to say if 

25 you did not have the manufacturer involvement, I think 
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1 that would be counterproductive to try to achieve good 

2 test results, which we’re all interested in. 

3 MR. BROOKMAN: Okay. Thank you. I thought 

4 that was covered pretty thoroughly there. Final 

5 comments before we move on? Did we get all the issues 

6 that you wanted covered, Adam? 

7 MR. DARLINGTON: Yes. 

8 MR. BROOKMAN: Okay. Let’s move on. 

9 MR. DARLINGTON: So that actually ends my 

10 segment. Are we scheduled for a break now? 

11 MR. BROOKMAN: Yeah, let’s take a break now. 

12 Now is a good time. It’s ten minutes after ten. For 

13 those of you that aren’t familiar with the Forrestal 

14 Building, you must wear this badge in a visible spot 

15 above your waist in the building. There are rest 

16 rooms on both ends of the hall. There’s a coffee shop 

17 down on the ground floor directly down the elevator 

18 shafts, just about where we’re situated here, across 

19 the hallway. We’re going to break for 15 minutes, 

20 which means we’ll resume at 10:25. For those of you 

21 who are joining us via the web, I’m glad you’re still 

22 with us. We’ll try and keep you engaged and answer 

23 questions as that opportunity presents itself. We’ll 

24 resume at 10:25. 

25 (Whereupon, at 10:10 a.m., the meeting was 
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1 recessed for a 15 minute period.) 

2 MR. BROOKMAN: Okay. Let’s resume. I 

3 should start by saying I thought the discussion this 

4 morning was very productive, and so that’s appreciated 

5 by the Department. Thanks to all of you for doing 

6 that. We’re going to proceed with the next content 

7 area, which is market assessment and engineering 

8 analysis. All of you have this content in your 

9 slides. We’re going to hear from Knute Svenson. 

10 But before we do, I’ve been asked to tell 

11 those that are joining via the webinar that our 

12 webmaster has already sent those of you – there were 

13 questions about how you access the slides, and still 

14 participate in the webinar, and our webmaster has sent 

15 you a direct link so you ought to be able to toggle 

16 that direct link and pull up those slides for those of 

17 you that haven’t already done so via the web. 

18 Okay. So now we’re going to hear from Knute 

19 Svenson. 

20 Market Assessment 

21 MR. SVENSON: Okay. My name is Knute 

22 Svenson. I’ll be talking about the market assessment 

23 and engineering analysis in today’s presentation. As 

24 you can see, we’re on the second stage of (adjusting 

25 sound) – sorry – as you see, we’re on the second stage 
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1 of the rulemaking. On the first stage we talked about 

2 the NODA, that DOE released the Notice of Data 

3 Availability on May 5, 2011. In that document, DOE 

4 presented its preliminary energy savings analysis. 

5 Then DOE will take your comments today and any 

6 comments you submit and revised the analysis in the 

7 NOPR, and come out with a final rule some time later 

8 this year with an effective date three or four years 

9 after that. 

10 To begin the market assessment, DOE 

11 conducted a market assessment for those equipment 

12 classes DOE determined were within the scope of 

13 review. The purpose of the market assessment is to 

14 determine the available equipment efficiencies, 

15 manufacturers, and shipment information. DOE looked 

16 at three main sources for this information, the AHRI 

17 directory of certified product performance, the CEC 

18 appliance efficiency database, and individual 

19 manufacturers’ websites. 

20 Now, for computer room air conditioners, 

21 which is basically the subject of the bulk of the 

22 presentation, DOE got all its information from the CEC 

23 database and individual manufacturers’ websites, 

24 because AHRI doesn’t currently have a separate 

25 database for computer room air conditioners. 
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1 As always, if you want more details and 

2 descriptions of the methodology and results for the 

3 market assessment, please refer to chapter two of the 

4 NOPR TSD. 

5 Now I will get into definitions. There is 

6 no current formal definition for VRF systems for DOE, 

7 because these product classes were not a formal 

8 subclass of commercial air conditioners. Thus DOE is 

9 proposing this following definition for VRF systems. 

10 This definition was taken from AHRI, ASHRAE 90.1 and 

11 AHRI 1230. I don’t know if anyone needs to read the 

12 definition. It’s pretty lengthy. 

13 Then on the next slide we have a definition 

14 for VRF multi-split heat pumps and for heat recovery, 

15 a unique aspect of this equipment class. 

16 MR. BROOKMAN: Just pause for a moment 

17 there. Give them a chance. Okay. 

18 MR. SVENSON: Next, we have a definition for 

19 computer room air conditioners. This is a difficult 

20 equipment class to define because DOE must define an 

21 equipment class in such a way that it does not overlap 

22 with any other covered equipment class. Computer room 

23 air conditioners pose a difficulty because they have 

24 the same mechanical components as normal commercial 

25 air conditioners, and there are no physical 
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1 distinguishing elements of computer room air 

2 conditioners from normal commercial air conditioners. 

3 Thus DOE is proposing to define this equipment based 

4 on how it’s advertised, marketed or sold, and based on 

5 the test procedure used to rate its performance. 

6 DOE is seeking comment on the definitions we 

7 propose for the VRF systems and definition for 

8 computer room air conditioners. Specifically, DOE is 

9 interested in whether there’s any physical features or 

10 components that allow DOE to distinguish computer room 

11 air conditioners from commercial packaged air 

12 conditioners used for comfort conditioning. 

13 MR. BROOKMAN: Paul. 

14 MR. DOPPEL: Paul Doppel, Mitsubishi 

15 Electric. A concern I see when you have this 

16 definition is that you are specifically excluding the 

17 parts that are covered by standard 127 almost – it 

18 looks like you’re excluding them from being used in 

19 other applications. And my concern is that, you know, 

20 you might say that if your product is covered by 

21 210/240, 340/360, or 1230 should be included in this 

22 definition. My concern is that you might say you 

23 can’t use it if you’re covered by these other 

24 standards, you can’t use it in this application, when 

25 that, in fact, would be restricting trade. Because 
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1 there are a lot of applications, there are a lot of 

2 situations where products already on the market that 

3 are not computer room air conditioners can be used in 

4 those applications. 

5 So this definition, to me, seems to be 

6 lacking. I don’t have something that’s off the top of 

7 my head to use here instead, but this one I have 

8 concerns with. 

9 MR. SVENSON: Just to clarify, I guess your 

10 main issues just the fact that we’re specifying this 

11 test procedure that’s rated? Are you okay with the 

12 advertising sold and marketed part? Or just the whole 

13 definition? 

14 MR. DOPPEL: Well, you’re saying that such 

15 equipment may not be marketed or advertised as 

16 equipment in any other space conditioning application, 

17 and may not be rated in accordance with those others. 

18 So it just – it seems like you’re trying to provide a 

19 total exclusion of the application of these products 

20 when, in fact, they could be used in other – they 

21 possibly could be used in other applications. 

22 MR. BROOKMAN: Mohammed first. 

23 MR. KHAN: Mohammed Khan, DOE. We certainly 

24 appreciate that concern, but again, this is a proposed 

25 definition, and what we’re really intending to do here 
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1 is develop a definition that clearly delineates this 

2 product and so I appreciate the fact that you said you 

3 don’t have a proposed revised definition, if you will, 

4 at this time, but if you could think about it, and I 

5 encourage all others to do the same as well, because 

6 we understand that concern, to later come up with a 

7 suggestion that might be workable. 

8 MR. BROOKMAN: This gets back to the first 

9 question of the day in fact. Gary, go ahead. 

10 MR. NETTINGER: Gary Nettinger, Panasonic. 

11 It’s – I guess I have a question and a statement. 

12 First, I’d like to hear from DOE a little bit more 

13 about what the goal is of creating this product class. 

14 And my statement is, as you’ve heard earlier this 

15 morning, we manufacture products that are frequently 

16 used in computer rooms, ATMs, small data rooms. If we 

17 separate, or if this definition is created, I see a 

18 barrier to where we market the equipment and it’s 

19 basically going to force me to have the same product 

20 under two different categories, even though it’s 

21 identical. One I would have for comfort cooling, and 

22 the other would be computer room applications. They 

23 could then be rated to different standards even though 

24 it’s the same equipment. So it’s going to be a 

25 challenge for the manufacturers. 
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1 MR. BROOKMAN: Paul. 

2 MR. DOPPEL: Paul Doppel, Mitsubishi 

3 Electric. Gary was talking about the one to one 

4 systems, but I mean, if you look at a VRF system, a 

5 VRF system could do a data room with one indoor unit; 

6 it could do water heating with another indoor unit; it 

7 could process outside air with another unit. So, you 

8 know, with VRF systems there’s a lot of complexities, 

9 and I’m not trying to – I’m just saying that there’s 

10 concern again that by creating sort of barriers, 

11 saying you can’t advertise this as anything else, 

12 well, if we advertise that you can use our products in 

13 data rooms does that mean then that we have to 

14 register that as a data room product? 

15 MR. BROOKMAN: Okay. Warren. 

16 MR. BEETON: More of a question than 

17 anything else, but from what I just heard, it sounds 

18 like there are, even for the computer room 

19 applications, there are different ways of applying a 

20 product, and so this whole venture sounds like it 

21 might not be practical to have a separate category 

22 that has a meaningful rating procedure, a meaningful 

23 standard. 

24 MR. BROOKMAN: Eric Stas. 

25 MR. STAS: Eric Stas, DOE. Let me just try 
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1 to jump in here. I mean, when ASHRAE 90.1 in this 

2 latest version gave us standards and classes for 

3 computer room air conditioners, we’re trying to now 

4 find a way to figure out objectively which is in the 

5 computer room bucket and which is in the regular air 

6 conditioner bucket. So we’re asking you to help us 

7 and we’re trying to help you define what’s in and 

8 what’s out. So the concerns you’re raising are the 

9 same concerns we’re finding, and that’s why we’re 

10 asking these questions. So these definitions are 

11 trying to help delineate things. So, I understand 

12 your concerns, but, you know, when you say you don’t 

13 want to be rated to two standards, we’re also trying 

14 to find a way to not rate you to two standards. So 

15 we’re all trying to get to the same end point, so 

16 don’t misinterpret. 

17 MR. BROOKMAN: Robert. 

18 MR. WILKINS: Just curious here. Is it 

19 possible to be able to – to enable a product to be 

20 rated in one bucket or another bucket without putting 

21 any restrictions on possible use of that product. So 

22 you leave it to the manufacturer and leave it up to 

23 competitive pressures to decide which bucket it’s 

24 rated in, but then allow it to be marketed wherever 

25 it’s technically possible to market it. And I think 
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1 if you could do something like that – if manufacturer 

2 A rated the product in this bucket, and manufacturer B 

3 had difficulty competing, that manufacturer won’t get 

4 the product rated over there. So I think the 

5 competitive market forces can come to bear to help you 

6 achieve what you want to achieve without putting 

7 artificial barriers or restrictions in between. Just 

8 an idea. 

9 MR. BROOKMAN: Provided it’s rated properly 

10 then the manufacturer could deploy that product 

11 wherever – 

12 MR. WILKINS: Yeah, you can buy an 

13 automobile to use as a family automobile or to use as 

14 a commercial automobile. It’s still an automobile and 

15 it still gets 27 miles to the gallon. It has a 

16 rating, but it can be used in either/or. You don’t 

17 have a restriction that this must be rated as a 

18 commercial car or a residential car and therefore 

19 cannot be used in the other bucket. 

20 MR. BROOKMAN: Eric Stas. 

21 MR. WILKINS: Let me say I’m overly 

22 generalizing, but that could be a philosophy that 

23 might be helpful. 

24 MR. STAS: Eric Stas, DOE. Let me just 

25 raise this point back to you. I mean, we have two 
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1 separate product classes already, one for the computer 

2 room, one for the comfort conditioning side. The 

3 levels might vary over time. You know, they might not 

4 be in lock step forever, so if manufacturer is given 

5 the choice, what’s to stop everyone from suddenly 

6 making their product rated to the less stringent of 

7 the two categories – classes? 

8 MR. WILKINS: Robert Wilkins, Danfoss again. 

9 I think two things. One you folks are going to be 

10 watching this closely, and as you see one rating 

11 diverge from the other rating, you’re going to 

12 naturally say we need to level this up. So I think 

13 that’s one corrective mechanism. The other is just 

14 market pressures that customers want to buy efficient 

15 products and if one competitor’s marketed product is 

16 more efficient than the other one, business is going 

17 to migrate in that direction. It’s normal competitive 

18 market pressures. 

19 Now, I don’t know that that’s a perfect 

20 answer, but I’m urging that those kinds of ways of 

21 doing it – I’m urging consideration of those methods, 

22 not to create artificial barriers. You know, my wife 

23 drives an SUV. Someone else might use it in his 

24 construction business. But it doesn’tneed to have 

25 different kinds of ratings for different purposes. 
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1 MR. STAS: Eric Stas, DOE. I think DOE, of 

2 course, will fully consider once all the options are 

3 available, and I sort of mention some of these things 

4 to sort of sensitize you all to some of the things 

5 we’re worried about, so that while we maybe pursue 

6 that one line of exploration, at least you can think 

7 of some of the concerns we have and maybe come up with 

8 alternates that address some of those other concerns 

9 as well. So we fully flush out the whole range of 

10 possibilities. 

11 MR. BROOKMAN: Yes, Karim. 

12 MR. AMRANE: Karim Amrane, AHRI. I guess I 

13 – you know, is the distinction consistent with the 

14 actual definition? 

15 MR. SVENSON: Well, there’s no definition – 

16 agreed on definition in ASHRAE, just – 

17 MR. AMRANE: There isn’t? 

18 MR. SVENSON: All we – I found is you define 

19 data room, but there’s no definition specifically that 

20 describes computer room air conditioners. 

21 MR. AMRANE: Not in the ASHRAE 127 standard 

22 also there is no definition there? 

23 MR. SVENSON: I can’t – I was surprised, but 

24 my feeling is there probably isn’t, otherwise we would 

25 be set off of it. 
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1 MR. AMRANE: Okay. 

2 MR. BROOKMAN: Paul Doppel. 

3 MR. DOPPEL: Paul Doppel, Mitsubishi 

4 Electric. You know, a system, whether it’s a data 

5 room system or a comfort cooling system, I mean it’s 

6 like the old joke about the thermostat – how does it 

7 know whether it’s heating – keeping something hot or 

8 keeping something cold? The system blows cold air or 

9 blows hot air, and it may cold air that’s a little bit 

10 drier in this situation than that. And so to try to 

11 come up with – what you’re doing is basically you’d 

12 have to come up with different efficiency standards or 

13 some other metric, and that really makes it kind of 

14 difficult. I mean there are different standards for 

15 heat pumps and air conditioners because of the 

16 additional bits of equipment in there. But it just 

17 seems – this just seems like a problematic situation. 

18 MR. BROOKMAN: Gary. 

19 MR. NETTINGER: Gary Nettinger, Panasonic. 

20 Computer rooms – there’s very few that require very, 

21 very strict conditions. I suppose very sophisticated 

22 computer rooms, data centers, require maybe 50 percent 

23 RH, plus or minus ten percent, and a specific 

24 temperature, but there’s very few like that. So I 

25 think as you look into this a little bit more, you’ve 
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1 got to probably look at more the computer room itself, 

2 and, you know, there’s some equipment that is 

3 manufactured specifically for computer rooms. Their 

4 operating range is different. The tolerance on RH or 

5 temperature control is a little tighter, so you 

6 probably need to consider that. But 95 percent of the 

7 data centers that are used, or probably more than 

8 that, are less sensitive to those and they’re able to 

9 take on a more, let’s say, comfort cooling type of 

10 system. 

11 MR. BROOKMAN: So it might be possible to 

12 differentiate a few different types of computer rooms 

13 and that might be the way you subdivide this? 

14 MR. NETTINGER: I suppose you could, but I 

15 think what we’re looking at right now is getting 

16 probably over-complex, and, you know, I’m not sure the 

17 value, considering how many computer rooms require 

18 that specific of a HVAC system is maybe not worth the 

19 effort. 

20 MR. BROOKMAN: Eric. 

21 MR. STAS: Eric Stas, DOE. One thing I want 

22 to point out as we discuss this, you know, when ASHRAE 

23 90.1 put these computer room air conditioners in the 

24 latest version, that triggered DOE to act. And unless 

25 we come up with a clear and convincing evidence that 
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1 we need to go more stringent than the ASHRAE level, 

2 that could direct us to adopt the ASHRAE level, so to 

3 that extent, we’re sort of compelled to make these 

4 standards for computer room air conditioners. So it’s 

5 not necessarily that DOE necessarily even wanted to 

6 venture into this area, it’s a complex area. Maybe 

7 we’d all have less headaches if we didn’t have to 

8 confront it, but we’re directed to, so that’s why 

9 we’re trying to – 

10 MR. BROOKMAN: Gotcha. Karim. 

11 MR. AMRANE: Karim Amrane, AHRI. And I’d 

12 have to agree. And that proposal came from the data 

13 center – manufacturers of air conditioners for data 

14 centers, the few companies that are specialized in 

15 this area, and they work within the ASHRAE community 

16 and the ASHRAE has a Standard 127 that rates those 

17 products. Again, it’s something different, there’s no 

18 ... and so on, and ASHRAE worked with those 

19 manufacturers and basically came up with the proposal. 

20 So I guess test procedure or questioning the ... and so 

21 on. So I think we are passed that. 

22 Now, as I said, AHRI is putting together a 

23 product section that will look at – that will gather 

24 those manufacturers and there will probably be a 

25 revision to the standard because we have an 
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1 understanding with ASHRAE when AHRI arrives at their 

2 performance standard and ASHRAE writes the ... of test, 

3 and eventually that could change. The 127. And if it 

4 changes, we will have to go back to ASHRAE 90.1 and 

5 ASHRAE 90.1 will have to look at this and then 

6 eventually we’ll have to look at the test procedure. 

7 But I think, you know, first I understand 

8 why DOE – what’s DOE is facing now, and DOE has to 

9 look at what ASHRAE has done. 

10 MR. BROOKMAN: Okay. Dave Winiarski. 

11 MR. WINIARSKI: This is – 

12 MR. BROOKMAN: Use the microphone, Dave. 

13 Hit the button. 

14 MR. WINIARSKI: This is Dave Winiarski, 

15 Pacific Northwest National Laboratory. I did want to 

16 make a statement here, trying to follow a little bit 

17 of the conversation, that there, as far as I 

18 understand, there will be no restrictions on the use 

19 of comfort cooling equipment for serving computer 

20 rooms. So if you have a VRF system or other system, 

21 that can still be used to satisfy a computer room in a 

22 building. This restriction is coming from the other 

23 side, which would prevent a product that is designed 

24 and marketed and tested, specifically, for use as a 

25 computer room air conditioner according to ASHRAE 127, 
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1 is restricted from being advertised for use in other 

2 applications. If those manufacturers have other 

3 applications they are certainly marketing their 

4 specific – what some people call precision cooling 

5 equipment,that may be a concern by itself. But I 

6 don’t think this is a strong concern for the other 

7 comfort cooling equipment. 

8 MR. BROOKMAN: Okay. Thanks for that. 

9 Okay. Additional comments? Nothing else at this 

10 point? Okay. 

11 MR. SVENSON: All right, so then DOE took 

12 the data from those two sources the CEC database and 

13 individual manufacturers’ websites and broke them out 

14 into 30 different equipment classes based on ASHRAE 

15 90.1. Those equipment classes depend upon the cooling 

16 type, the sensible cooling capacity, orientation, and 

17 whether or not there is a fluid economizer. DOE found 

18 1364 different models from 22 different equipment 

19 lines from five different manufacturers. That number 

20 may seem high, but what tends to happen is one unit 

21 could be optionally be air cooled, water cooled, or 

22 glycol cooled, and then within those, upflow or 

23 downflow, so for like that one unit, you would have 

24 six different optional configurations which will fall 

25 into six different equipment classes. So that kind of 
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1 describes why that number is a little high. 

2 

3 Engineering Analysis 

4 Next we’ll get into the engineering 

5 analysis. The goal of the engineering analysis is to 

6 characterize the relationship between the increased 

7 efficiency and the cost required to get to that 

8 increased efficiency. DOE chose an efficiency level 

9 approach in conjunction with pricing survey in this 

10 rulemaking. 

11 There are six steps here for the engineering 

12 analysis. We’ll go into each of those steps in more 

13 detail in the ensuing slides, but here are just a 

14 brief overview. 

15  First, DOE chooses a representative equipment 

16 size for analysis, then 

17  It will define the baseline model, then 

18  Develop the efficiency levels for analysis 

19  Then DOE obtains pricing data and constructs 

20 price efficiency curves 

21  Next, DOE takes such price efficiency curves 

22 and scales them to the equipment classes that 

23 were not directly analyzed, and 

24  Lastly will get into the results. 

25 Now, the first step, DOE needs to choose a 
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1 representative equipment size on which it will base 

2 all of its analysis. DOE chose the average sensible 

3 capacity rounded to the nearest ton for each equipment 

4 class for computer room air conditioners. DOE noted 

5 that within each size category for computer room air 

6 conditioners, there was not any variation between the 

7 cooling type, orientation, and the presence of a fluid 

8 economizer, so DOE was able to choose the 

9 representative sensible cooling capacity based on just 

10 the size categories. 

11 So for the small computer room air 

12 conditioners, those with cooling capacity less than 

13 65,000 BTUs, DOE chose the three ton capacity. Then 

14 for the large computer room air conditioners with a 

15 cooling capacity between 65,000 and 240,000 BTUs per 

16 hour, DOE chose 11 tons. And for the very large, DOE 

17 chose 24 tons. That said, DOE directed downstream 

18 analysis around these numbers. 

19 MR. BROOKMAN: Steve Rosenstock. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEI. For 

21 the large unit, does that tonnage represent kind of 

22 the high point of the bell curve in terms of 

23 distribution or -- because, you know, with the other 

24 it seems like the midpoint of the range, but here 

25 you’re on the low end of the range. 
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1 MR. SVENSON: So that number is based on the 

2 average of the sensible capacities found in that 

3 entire size category, and you’re talking about the 

4 very large, greater than 240,000, so most – we found 

5 that most equipment tended to be on the lower end of 

6 that range, so it’s closer to the lower range. 

7 MR. ROSENSTOCK: Thank you. 

8 MR. SVENSON: All right. Next, DOE defines 

9 the baseline model. The baseline level is used as a 

10 reference point against which DOE measures any changes 

11 resulting from amended energy conservation standards. 

12 A baseline model typically represents the model having 

13 features and technologies normally found in the 

14 equipment class offered for sale. Usually DOE will 

15 choose the baseline efficiency level as the federal 

16 energy conservation standard, however, in this case, 

17 computer room air conditioners are not currently 

18 regulated, so they do not have a federal energy 

19 conservation standard. But since EPCA requires DOE to 

20 adopt the ASHRAE levels or higher, DOE chose the 

21 ASHRAE efficiency levels as the baseline levels. 

22 And then, lastly, to simplify the 

23 engineering analysis, DOE only selected levels for the 

24 downflow class. We found that there’s really no 

25 difference between the upflow and downflow class. 
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1 They all have the same components, just organized in a 

2 different way, and they would have the same 

3 technological advancements as the downflow class, and 

4 so the class benefit analysis would be pretty much the 

5 same between these two classes. 

6 All right, next, DOE will develop the 

7 efficiency levels for analysis. Since DOE does not 

8 currently regulate the computer room air conditioners, 

9 manufacturers are not required to report their 

10 efficiency information. So DOE had to rely on 

11 efficiency information found in the manufacturer 

12 literature and the CEC appliance database. However, 

13 SCOP is a new metric adopted by ASHRAE, so all the 

14 efficiency information DOE did find was in a form 

15 ofEER, so DOE needed a method in order to convert 

16 these EER numbers into SCOP. In the appendix of 

17 ASHRAE Standard 127 there is this rule of thumb 

18 formula that converts the old EER into the SCOP, and 

19 you can see the formula on that slide. 

20 For those equipment classes for which DOE 

21 had enough efficiency information, DOE would identify 

22 the max tech efficiency level on the market, and then 

23 DOE chose three evenly spaced points between the 

24 baseline level and the max tech efficiency level for 

25 five efficiency levels for analysis. For those 
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1 equipment classes for which there were little or no 

2 efficiency information, DOE based its levels off of a 

3 similar equipment class using the efficiency 

4 difference found in ASHRAE 90.1. So, for instance, 

5 DOE didn’t have enough efficiency information for the 

6 water-cooled class with the fluid economizer, so DOE 

7 took the efficiency levels they developed for the 

8 water-cooled class without the fluid economizer and 

9 subtracted .05 from the SCOP, which is that difference 

10 found in ASHRAE. 

11 MR. BROOKMAN: Joanna Mauer. 

12 MS. MAUER: Joanna Mauer. Did DOE attempt 

13 to compare the SCOP levels in 90.1 to the current 

14 California standards that I recognize the difficulty 

15 of comparing SCOP to EER. 

16 MR. SVENSON: We did use the rule of thumb 

17 to compare those levels. Again, we’re not positive 

18 how accurate the rule of thumb formula is. 

19 MS. MAUER: Can you say, using the rule of 

20 thumb, how the levels in 90.1 compare to the 

21 California standards? 

22 MR. SVENSON: They’re close in some 

23 categories and I think they are – California levels 

24 may be a little higher than the current ASHRAE 

25 standards. 
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1 MS. MAUER: Okay. Again, I think we’d 

2 certainly be concerned if DOE is going to preempt the 

3 California standards and set standards – national 

4 standards at a level that are lower than the current 

5 California standards, and I believe the California 

6 standards have been in effect since like 2006 so these 

7 aren’t new standards based on kind of better than may 

8 be available now. 

9 And maybe if I can just ask another 

10 question. Is there some inherent difference between 

11 the computer room air conditioners and kind of 

12 conventional packaged AC equipment that would make the 

13 CRAC units less efficient? 

14 MR. SVENSON: I’m not aware of any. 

15 MS. MAUER: Okay, so, you know, if there’s 

16 no inherent – something inherent that makes the 

17 equipment less efficient, I don’t see a reason why the 

18 levels couldn’t be comparable in stringency to what 

19 the levels were in commercial package equipment, and I 

20 think if we are having – and I appreciate that DOE’s 

21 trying to resolve these issues, the definitions, but 

22 especially if there is possibility that manufacturers 

23 could rate their equipment to the product class with 

24 the lower standards that is a significant difference, 

25 I think that’s a concern. 
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1 MR. BROOKMAN: Thank you. Steve Rosenstock. 

2 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

3 was just thinking that typically for the computer room 

4 units, aren’t typical test conditions show much lower 

5 temperature and relative humidity compared to the 

6 packaged units, so that would have an impact on 

7 efficiency levels right there, just because of 

8 different test conditions. I mean significantly 

9 lower. So that, you know, when you have to take out 

10 much more humidity and lower – let’s say 68 degrees, 

11 50 percent humidity for the computer room, versus 74 

12 degrees, 55, 60 percent for – again, I don’t know what 

13 the test procedure numbers are, but just the internal 

14 conditions can make a significant difference in terms 

15 of the efficiency levels that you’re going to see 

16 because of the differences in the test procedure. 

17 MR. BROOKMAN: Karim. 

18 MR. AMRANE: Karim Amrane, AHRI. I believe 

19 those kinds of questions were raised within the ASHRAE 

20 90.1 committee when this proposal was discussed, and I 

21 think – and at that time we had a lot of input from 

22 those manufacturers who make those products, and I 

23 think there’s the understanding, from those 

24 discussions, that what they were proposing was somehow 

25 equivalent to those conventional air conditioners, 
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1 rooftop units, or something like that. 

2 So again, I think what’s happening here, we 

3 are talking about the first go-round, this is the 

4 first time they are going to be regulated, and 

5 eventually, if those manufacturers, as I said, AHRI is 

6 forming a product section, we will have a 

7 certification program, and within the next few years 

8 there will be a way to see those efficiencies and to 

9 be able to raise them if the efficiency needs to be 

10 raised. 

11 MR. BROOKMAN: Okay. 

12 MR. SVENSON: Next, DOE conducted a pricing 

13 survey. We contacted the five known manufacturers of 

14 this equipment and were able to obtain efficiency and 

15 pricing information from three of those manufacturers. 

16 DOE selected models for pricing that were close to 

17 representative sensible cooling capacity as possible, 

18 generally within 15 percent. DOE received pricing 

19 information for 32 total models and DOE used this 

20 pricing data, together with the SCOP information to 

21 produce price efficiency curves. 

22 Then DOE obtained efficiency information. 

23 DOE only had enough pricing and efficiency data to 

24 directly analyze four equipment classes - the small 

25 air-cooled equipment class, the large air-cooled 
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1 equipment class, and the small and large water-cooled 

2 equipment classes. Now for the remaining eleven 

3 equipment classes, DOE had to scale the price 

4 efficiency curves from these four classes. 

5 So this is a little bit of a graphic of how 

6 we scaled the price efficiency curves. Just to give 

7 you an example, if you look at the top right arrow, to 

8 go from the large air-cooled equipment class to the 

9 very large air-cooled equipment class, DOE subtracted 

10 0.2 from the SCOP which again, is that difference 

11 found in ASHRAE, and we also multiplied the price by 

12 1.44, which is the average increase in price we found 

13 from our pricing survey. 

14 Another thing to point out from our pricing 

15 survey is that we found that water-cooled computer 

16 room air conditioners were the same price as glycol17 cooled computer room air conditioners. 

18 And lastly, for classes with the fluid 

19 economizer, we used the corresponding class without 

20 the fluid economizer and subtracted .05 from the SCOP 

21 as we discussed earlier, and we multiplied the price 

22 by 1.0582 which is again the average price we found 

23 for having a fluid economizer. 

24 If you’d like to see a full set of results 

25 for the engineering – 
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1 MR. BROOKMAN: No, go ahead. Keep going. 

2 MR. SVENSON: If you’d like to see a full 

3 set of results for the engineering analysis, you can 

4 refer to chapter three of the NOPR TSD. Based on the 

5 pricing data that was obtained, DOE observed a 

6 positive correlation between price and increase 

7 efficiency for the small and large air-cooled 

8 equipment and the large water-cooled equipment. 

9 However, DOE observed that there was a negative 

10 correlation between price and increase efficiency for 

11 small water-cooled equipment class. DOE notes that 

12 there’s other factors other than the efficiency of the 

13 equipment that could impact the pricing. For 

14 instance, how competitive the market is, warranty, et 

15 cetera. DOE believes that this negative correlation 

16 is not representative of this equipment class because 

17 of these factors – and these factors also could have 

18 influenced results for the positive correlation 

19 equipment classes as well. DOE would also like to 

20 note that there was a lack of data and there’s a lot 

21 of uncertainty in the data that also could kind of 

22 increase the margin of error for these results. 

23 MR. BROOKMAN: Okay. Steve Rosenstock. 

24 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

25 Again, thank you for that, but going back to that 
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1 previous slide 44, I guess, you know, it said you only 

2 had data for the four classes, and then you have these 

3 scaling factors. I guess my – was there like limited 

4 pricing information, where you just got the 1.44 and 

5 1.9 scaling factors for all sizes? Or – it just seems 

6 like – you did the scaling, but how much information 

7 do you have to be confident those scaling factors 

8 worked across all sizes in those, especially for the 

9 very large units? 

10 MR. SVENSON: Well, as we said, there’s a 

11 lot of uncertainty in the data. We had some data for 

12 all these classes that we were able to make some of 

13 these general kind of correlations, but we are aware 

14 the data is very uncertain and we’re not extremely 

15 confident in any of these results, but that’s because 

16 of the uncertainty – 

17 MR. ROSENSTOCK: And Steve Rosenstock, EEI. 

18 What was the variation – I see the 1.44 and 1.9 – what 

19 was kind of the variation that you saw with the data 

20 set in terms of price differentials? In the range? 

21 MR. SVENSON: In terms of like a tolerance 

22 for the price? 

23 MR. ROSENSTOCK: No, no, no. In terms of 

24 what was the range? Was it 1.34 to 1.54 or was it 

25 1.04 to 1.84? What kind of variation did you see in 
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1 some of the – 

2 MR. SVENSON: I would – 

3 MR. DARLINGTON: We don’t have that off 

4 hand, but – 

5 MR. BROOKMAN: Use the microphone. This is 

6 Adam Darlington. 

7 MR. DARLINGTON: We don’t have that 

8 information off hand. We obviously don’t provide the 

9 actual pricing data that we collected, so that we 

10 don’t reveal anything. But as far as the range, I 

11 mean, so typically for the four green product classes, 

12 we were able to collect enough data, you know, four or 

13 five points, to get a general trend. And then in 

14 those remaining product classes, we only had a couple 

15 of points, and basically from those points we tried to 

16 come up with an average sort of difference. Now, you 

17 know, where it says the 1.44, whether that range, you 

18 know, we had one that was 1.33 and one that was 1.6, 

19 you know, the same price and one that was double it, I 

20 don’t know off the top of my head, but I don’t think 

21 that there was that big of a range, and we could 

22 probably look into the data and maybe follow up if 

23 you’re very interested. 

24 MR. ROSENSTOCK: Steve Rosenstock. And 

25 again, that’s fine, but I’m just saying, this 
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1 definitely is – has significant impact in terms of the 

2 economic analysis. 

3 MR. DARLINGTON: Yeah, I agree, absolutely, 

4 and that’s part of the issue here and part of why the 

5 approach is to sort of adopt the ASHRAE levels because 

6 DOE is charged with kind of presenting a clear and 

7 convincing case that more stringent levels are 

8 justifiable, and basically with the computer room air 

9 conditioners, there’s a specific problem because 

10 they’re currently unregulated, and so there’s not a 

11 whole lot of data out there to base an analysis on, 

12 especially with the lack, you know, the complete lack 

13 of efficiency data. And then for the few products 

14 that we were able to convert the efficiency data on to 

15 get the pricing data for that was also a challenge. 

16 So I think – I guess the overarching point is that 

17 there is a good amount of uncertainty in the actual 

18 price-efficiency relationship, based on what was done 

19 and the lack of data that was available to us. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

21 definitely appreciate that and since we’re going to be 

22 at the final rule stage, if there is a way to, in the 

23 final rule, just to say data sets were limited and 

24 we’re basing this on a limited data set in terms of 

25 all of the life cycle analysis that we’re going to do. 
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1 Thank you. 

2 MR. BROOKMAN: Thank you. 

3 MR. SVENSON: And DOE invites comment about 

4 the pricing analysis or any data information about the 

5 price-efficiency relationship for computer room air 

6 conditioners. 

7 MR. BROOKMAN: Any additional comments on 

8 these pricing issues? Or others? Nothing additional? 

9 Okay. Moving on to markups and next we’re going to 

10 hear from Michael Scott and actually Dave Winiarski’s 

11 to – Dave’s going to go first. Dave Winiarski. 

12 Introduction to Markups Analysis; Energy Use Analysis; 

13 Life-Cycle Costs and Payback Period Analysis 

14 MR. WINIARSKI: So, hi. My name is Dave 

15 Winiarski, I’m with the Pacific Northwest National 

16 Laboratory, and I’ll be introducing this section five 

17 which is up here, which is discussing markups 

18 analysis, energy use analysis, and how those feed into 

19 DOE’s life cycle cost and payback period analysis. 

20 I’m going to start off this with a 

21 discussion of energy use and then use load 

22 characterization section. This slide here shows how 

23 that and the markups analysis both feed directly into 

24 the life-cycle cost and payback period analysis. 

25 So for the energy use characterization of 
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1 computer room air conditioners, what we did is what’s 

2 called a bin temperature analysis, where first we 

3 establish a performance map for how the efficiency of 

4 a computer room air conditioner in any one of the 15 

5 classes that we’ve identified for the analysis behaves 

6 as a function of external conditions. In this case, 

7 external conditions being either defined by products 

8 which respond primarily to outdoor air dryable 

9 temperature – those are the air-cooled products, 

10 obviously; but also we’re presuming that the glycol11 cooled products respond outdoor air temperature 

12 because they are generally used with what’s called a 

13 dry evaporative cooler – or dry cooler outside which 

14 cools the glycol loop which the air conditioner is – 

15 or serving air conditioner for its condensing section. 

16 For water-cooled units, those are generally 

17 – they’re not used with a dry cooler, they’re used 

18 with an evaporative type cooler, either directly or 

19 indirectly, and so they are responding to outdoor wet 

20 bulb temperature performance. 

21 The basis of the analysis is we establish 

22 these performance maps for each class of equipment, in 

23 this case each specific size of equipment within those 

24 classes as a function of either the dry bulb 

25 temperature or wet bulb temperature, and then we 
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1 perform an annual energy consumption analysis where we 

2 pair the performance at each bin temperature – we bin 

3 them in five degree temperature bins, for instance 65 

4 to 70 degrees outdoor temperature would be a bin. We 

5 come up with the power use in that bin and then we end 

6 up multiplying it by the number of hours in that bin 

7 in a particular climate. The analysis was done for 

8 239 specific climates using typical meteorological 

9 year data, the specific set was the TMY3 data. And 

10 then we further aggregate from those 239 climate 

11 locations into state average unit energy consumption 

12 for each class of computer room air conditioners, and 

13 those state by state average numbers are what actually 

14 feed the life-cycle cost analysis. 

15 So the next slide, I want to discuss briefly 

16 the basic process and assumptions that are used in the 

17 performance maps. To start off with, the performance 

18 maps, you need to understand a little bit of what’s 

19 the load on these computer room air conditioners. And 

20 to be quite frank, there isn’t a lot of data out there 

21 on typical loading for computer room air conditioners. 

22 The assumption that we used for this was that in any 

23 given hour for which we’re establishing the power, the 

24 computer room is loaded or provides a load on the air 

25 conditioner equivalent to 65 percent of the sensible 
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1 capacity of the air conditioner. That number was 

2 based on an Australian study, a minimum energy 

3 performance standard study. It also correlates well 

4 with some California code enhancement studies that 

5 were produced, I think, just in the last couple years. 

6 The efficiency again, is assumed to be a 

7 function of the condensing fluid temperature, or where 

8 you’re looking at air-cooled products, the air 

9 temperature, unless it varies with the temperature 

10 bin. In addition, and somewhat unique for this 

11 product class, ASHRAE defined separate product classes 

12 for equipment with and without economizers, which is a 

13 little unique compared to other types of air 

14 conditioning equipment. So where economizers were 

15 fluid economizers, either the glycol-cooled products 

16 or the water-cooled products, with a separate fluid 

17 economizer that’s incorporated in the product, we 

18 actually included the load reductions from those 

19 economizers directly in this analysis. A key point is 

20 that we did not include reductions for air side 

21 economizers, which may be used with some air side 

22 equipment, but we had very little data on how often or 

23 how frequent that’s used. 

24 Supply fan power was based on manufacturer 

25 data that we could find for specific products. In 
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1 this analysis, the supply fan power is assumed to be 

2 constant at all levels, so the energy savings is 

3 coming from largely improvements in the refrigeration 

4 portion, not on the supply fan portion. 

5 MR. BROOKMAN: Yes, Steve. 

6 MR. ROSENSTOCK: Steve Rosenstock. Edison 

7 Electric Institute. On the graphic in this slide, on 

8 the Y axis it says EIR, what does that stand for? 

9 MR. WINIARSKI: EIR is the energy input 

10 ratio. It’s basically a term that’s often used in 

11 building performance models, like Energy Plus or DOE2, 

12 and it reflects the amount of power that’s used or 

13 provided to the condensing unit relative to the 

14 capacity output of the condensing unit. In this case, 

15 condensing unit, I’m really referring to the entire 

16 refrigeration system, minus the fan system. 

17 MR. ROSENSTOCK: So – Steve Rosenstock, 

18 thank you. So EIR T versus nominal, so T is based on 

19 the outdoor ambient? 

20 MR. WINIARSKI: Exactly, so if you’re 

21 looking at this graph, what you’re seeing here is that 

22 as the outdoor temperature gets lower and lower, the 

23 energy input required to achieve a certain amount of 

24 capacity also gets lower and lower. Which is, in this 

25 particular case, we didn’t have performance curves 
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1 from actual products that were being analyzed, 

2 however, the ASHRAE 127 standard has an appendix which 

3 had examples of performance at different conditions, 

4 and so the plots you see here are actually based on 

5 that appendix. 

6 MR. ROSENSTOCK: Thank you. 

7 MR. WINIARSKI: So that’s again taking into 

8 account that performance varies with condensing 

9 conditions and in addition we also have some part load 

10 performance curves as the equipment becomes unloaded 

11 in the analysis to take into account things like 

12 compressor cycling. So that’s also taken into 

13 account. And this allow us to come up with 

14 essentially a power – an average power consumption for 

15 each outdoor temperature bin. 

16 From then on, it’s a relatively 

17 straightforward analysis. The power in a given bin is 

18 equal to the power of what I’m calling the condensing 

19 section, which is really the compressor and the 

20 refrigeration portion of the system. That’s added to 

21 the supply fan power which gives you the total power 

22 in any given temperature bin. We then develop for 

23 each of the specific climates that were analyzed, 

24 essentially the sum product of the power in each bin 

25 times the number of hours in each bin over the year. 
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1 That gives us the unit energy consumption for that 

2 product class and particular size in that climate. 

3 In order to come up with the state energy 

4 consumption on average, we have specific weights that 

5 reflect the presence of that particular climate in a 

6 given state, for example, California might have – I 

7 don’t know the number off hand, but maybe 15 different 

8 climates that are included in that, each with a given 

9 weight. We weighed all the unit energy consumptions 

10 by climate with those weights to get the state by 

11 state energy use figures. And that’s what’s fed 

12 directly into the LCC spreadsheet. 

13 The LCC spreadsheet also is able, when it 

14 does its analysis, which will be discussed here 

15 shortly, to come with sort of national average unit 

16 energy consumption estimates. And this process is 

17 repeated for each of the efficiency levels analyzed. 

18 And that’s really the summary. If there’s 

19 any questions I can take them now. 

20 MR. BROOKMAN: No questions. 

21 MR. WINIARSKI: All right. 

22 MR. BROOKMAN: Michael Scott. 

23 Markups Analysis; Life-Cycle Costs Analysis 

24 MR. SCOTT: Okay, so moving on here, what 

25 I’ll be talking about is the markups analysis and the 
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1 life-cycle cost analysis. In order to do this, we 

2 have typically, when we’ve done one of these life3 cycle cost analyses and mark-up analyses, we have to 

4 specify distribution channels for the equipment of 

5 interest, and then to talk about what types of 

6 businesses a piece of equipment may go through until 

7 it reaches the consumer. And typically those may have 

8 several branches. 

9 However, in this case, it is our belief that 

10 computer room air conditioners really pretty much 

11 there’s a manufacturer dealing with a mechanical 

12 contractor who’s doing the installing, and may be 

13 doing some markup on the equipment, and that’s true 

14 for either replacement or new construction. Our 

15 belief is that in most cases computer rooms are not 

16 really installed in new construction as specifically 

17 as computer rooms and a general contractor, for 

18 example, would not be involved. And we have virtually 

19 no data on that. This is largely an assumption on our 

20 part, so we are interested in comments that people who 

21 are involved in the industry might have on that and 

22 tell us a bit more about how the equipment is actually 

23 distributed, because that may affect the analysis. 

24 However, with that particular distribution 

25 channel that’s shown on slide 52, then we proceed with 
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1 the markup analysis. Our source of data for the 

2 mechanical contractor, which is the only markup past 

3 the manufacturers in this case, the source of data for 

4 that was the 2007 economic census applied to the – for 

5 the particular part of the construction industry that 

6 is the most relevant for this kind of equipment, and 

7 that is HVAC contractors. It’s the most detailed code 

8 available for this type of construction. 

9 We do a workup of the components of the 

10 costs of the mechanical contractor. Those costs are 

11 divided into what we call variant costs which scale 

12 with the price of the equipment, or which we believe 

13 scale with the price of the equipment, and those 

14 portions of the costs of the contractor that do not 

15 scale with the cost of the equipment. And we scale 

16 that with the cost of – essentially the cost of goods 

17 sold, which in the case of the mechanical contractors 

18 is subcontractor costs, it’s installing labor costs, 

19 and one other component which is in the TSD but 

20 escapes my memory at the moment. 

21 The remaining costs are what constitutes the 

22 markup of the cost of goods sold, primarily the 

23 general operating costs of the contractor, and those 

24 are primarily labor, occupancy, factors like 

25 advertising, depreciation, and then finally profit. 
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1 And some of those components, particularly the labor 

2 and occupancy costs, we characterize as invariant with 

3 the price of the equipment, and so we have both a 

4 baseline markup, which is characteristic of baseline 

5 equipment, and then for more efficient equipment, as 

6 that price gets higher, the markup does not follow it, 

7 instead it’s somewhat less because the belief is that 

8 labor and occupancy costs do not scale with the price 

9 of the equipment. 

10 The averages that you see on the slide, the 

11 baseline markup of 1.474 and the incremental markup of 

12 1.184 are national averages, and we were able to 

13 provide in the technical support document, a range of 

14 occupancy cost factors that are unique to each state, 

15 because labor costs and occupancy costs, particularly, 

16 vary across the country. And then when we do the 

17 actual analysis using Monte Carlo analysis, then we 

18 are drawing from the cost in the individual states 

19 rather than the national average. 

20 Similarly, for sales taxes, what we see on 

21 the slide here is a population-weighted average for 

22 the country, however there are states that don’t 

23 actually have a sales tax, there are states for which 

24 that tax is higher, and so again, we’re drawing from a 

25 distribution of taxes. The information that’s 
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1 provided on the slide here is to give you an idea of 

2 the overall average. 

3 So I’ll stop right there for the markup 

4 factor and give people a chance to ask questions if 

5 they wish. Otherwise, I’ll just move on. 

6 MR. BROOKMAN: So comments both on the 

7 distribution channels and also these markup factors? 

8 No additional – Gary. 

9 MR. NETTINGER: I’ll make a comment. As we 

10 proceed through this process with computer room air 

11 conditioners, it’s becoming more and more clear to me 

12 that these are in fact – you are in fact looking at 

13 precision air conditioners, not products that are 

14 sometimes applied to computer room air conditioners. 

15 MR. BROOKMAN: And when you say precision, 

16 what are the characteristics there? 

17 MR. NETTINGER: They are designed strictly 

18 for computer room or industrial equipment cooling, not 

19 for comfort cooling at all, so that kind of goes back 

20 to our definition that – I guess from a definition 

21 standpoint, I’m becoming more and more opposed to this 

22 being regarded as computer room air conditioning or a 

23 computer room standard, because there’s lots of other 

24 systems that could be used for computer rooms. 

25 On the channel to the market, I can’t be 
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1 specific on this, but I do believe that in many cases 

2 it will be manufacturer to a distributor. There will 

3 be a markup there. There may sometimes be a sales rep 

4 agency or manufacturer’s rep agency involved. If it’s 

5 a sales rep agency, there will probably be a markup as 

6 well, and then it will go on to the mechanical 

7 contractor and the consumer. So I think that – 

8 generally I think you’re probably missing one step in 

9 the markup process. 

10 MR. SCOTT: Yeah, one thing I probably 

11 should have mentioned was that as we have them set up 

12 here and we’re going to have to double check with our 

13 colleagues over at Navigant, but our understanding 

14 when we were handed the original prices here that get 

15 marked up is that those were actually delivered prices 

16 from the manufacturer or the distributor. So we would 

17 have already accomplished that in the manufacturer/ 

18 distributor markup. But thank you very much for that 

19 information, that helps. 

20 MR. BROOKMAN: Would you be willing to 

21 venture on the scale of the markups listed here? 

22 MR. NETTINGER: No. 

23 MR. BROOKMAN: I didn’t think so. Okay. 

24 MR. SCOTT: All right. That it? We’ll move 

25 on. Oh, one more. 
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1 MR. BROOKMAN: Joanna Mauer. 

2 MS. MAUER: Joanna Mauer. Actually just a 

3 question for Gary or anyone else. Are there 

4 distinguishing equipment designed specifically for 

5 precision cooling from equipment that may be designed 

6 for comfort cooling but may be used in these other 

7 applications? Are there other characteristics, 

8 physical characteristics, other characteristics that 

9 could be – to distinguish those two types of 

10 equipment? 

11 MR. NETTINGER: That’s obviously going back 

12 to the definition. Very difficult to define a firm 

13 role. I think it’s just the requirements of that 

14 particular data room or computer room, and how 

15 precisely they need their humidity controlled. You 

16 know, computer room air conditioning is usually 

17 designed for primarily sensible cooling, not much 

18 latent. I just don’t want to see this going in the 

19 direction where the result of this analysis or testing 

20 efficiency rating, whatever is to become of this, 

21 prevents comfort cooling – or obstructs an HVAC system 

22 that’s designed for comfort cooling, such as Panasonic 

23 or any manufacturer’s equipment to be used or marketed 

24 into a common computer room application. Most 

25 computer rooms do not require high precision 
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1 equipment. 

2 MR. BROOKMAN: Paul. 

3 MR. DOPPEL: Paul Doppel, Mitsubishi 

4 Electric. Probably the most distinguishing 

5 characteristic would be the ability to apply cooling 

6 operation at very low temperatures, and most standard 

7 comfort cooling systems go down maybe 55 degrees, and 

8 then providing cooling lower than that is a stretch, 

9 and so systems have to be specially designed to be 

10 able to operate down to ten, zero, minus 20, that 

11 takes special requirements for those. 

12 But to Gary’s point, I can – again, I’m 

13 having the same concern that there could be an 

14 exclusion of products that normally could do this job 

15 because it says – the requirement might be that it has 

16 to comply with ASHRAE standard 127. 

17 MR. BROOKMAN: Yes, Warren. 

18 MR. BEETON: Could DOE clarify something? 

19 I’m not a little confused here. I thought the 

20 proposal that was on the table was to prohibit the 

21 marketing or sale of precision cooling equipment for 

22 general air conditioning, but not prevent the sale or 

23 marketing of general equipment for computer room 

24 application. Is that wrong? 

25 MR. BROOKMAN: Dave Winiarski. Use the 
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1 microphone. 

2 MR. WINIARSKI: Yeah. Dave Winiarski. To 

3 preface that, we’re not trying to obviously restrict 

4 the sale, or we’re trying to make sure that the 

5 equipment that’s sold into that precision cooling 

6 application – let me rephrase that. That equipment 

7 that is designed specifically for that precision 

8 cooling and computer room application and is tested in 

9 accordance with that need, will meet this requirement, 

10 but the Department is not putting restrictions on the 

11 ability of using comfort cooling equipment for that 

12 computer room application. Does that clarify? 

13 MR. BROOKMAN: Karim. 

14 MR. AMRANE: Karim Amrane, AHRI. I guess 

15 what Gary is saying is that there is this equipment 

16 which is also sold in computer room application, which 

17 are not for precision cooling, but they still do the 

18 same kind of job. They are there for comfort cooling, 

19 but as well as for the computer rooms. 

20 MR. BEETON: Right, and I’m assuming that 

21 that equipment is rated to AHRI 220/240 or 340/360 and 

22 designed for comfort applications primarily, but could 

23 also be used for the computer room application. 

24 MR. BROOKMAN: Ashley. 

25 MS. ARMSTRONG: Just a comment – what the 
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1 Department, I think, is trying to do and it has little 

2 to do with how a manufacturer may market their 

3 equipment or what – if you want to get into 

4 overlapping markets – but we’re trying to clearly 

5 distinguish in our definitions what standards and 

6 testing procedures you need to use. In other words, 

7 where are you covered? And if the definition is 

8 overly vague or overly broad, then you could end up in 

9 a situation which encompasses two different testing 

10 procedures and two different standards for the same 

11 equipment, and this is where we need your help in 

12 distinguishing. We’re trying to clearly distinguish 

13 between the two. 

14 MR. BROOKMAN: Okay. Paul. 

15 MR. DOPPEL: Just a comment on the 

16 application side. I mean, if someone wants to use 

17 this type of equipment to do comfort cooling, I mean, 

18 they’ve got a lot of money for one. And there 

19 shouldn’t be a restriction from doing that. And 

20 again, the definition seems to imply restrictions on 

21 applicability, you know, both ways. 

22 MR. BROOKMAN: Warren. 

23 MR. BEETON: Just to clarify. Our company 

24 makes computer room air conditioning, so we have an 

25 interest in this. What we’re reading on the chart 
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1 that appeared some time ago was only the prohibition 

2 of marketing or sale of what I will call precision 

3 cooling units that are marketed as and tested to a 

4 precision cooling standard, the ASHRAE 127, to 

5 prohibit the sale in general air conditioning. That’s 

6 what that chart said. But there was nothing that said 

7 the other way around, to prohibit the application of 

8 general air conditioning equipment for computer room 

9 cooling. Am I correct? 

10 MR. BROOKMAN: Ashley. 

11 MS. ARMSTRONG: Right, so it seems like what 

12 you would advocate, if I’m stating this correctly, is 

13 that you guys would advocate in the definition section 

14 removing the part about marketing or advertising. 

15 MR. BROOKMAN: Ashley, can you refer to the 

16 slide that you’re looking at? 

17 MS. ARMSTRONG: Thirty-three. 

18 MR. BROOKMAN: Thirty-three. So let’s do 

19 that again, so we get this – 

20 MS. ARMSTRONG: We don’t have to go back, 

21 we’ve already dealt with that, but at the same time, 

22 that seems to be what I’m hearing. In other words, if 

23 somebody makes a particular design, what we need to 

24 make sure is the definition is clear as to which 

25 bucket if falls into. 
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1 MR. BROOKMAN: Hang on just a second. 

2 MR. BEETON: I’m not advocating, I’m just 

3 trying to clarify. And again, I thought it was a yes 

4 or no question. That what DOE proposed in that chart 

5 was simply to prohibit the sale and marketing of 

6 equipment rated to ASHRAE 127 for general air 

7 conditioning, but not to prohibit the application of 

8 equipment rated under the commercial air conditioning 

9 standards for computer room use. 

10 MS. ARMSTRONG: That is correct. 

11 MR. BROOKMAN: Okay. Thank you, Ashley. 

12 Robert. 

13 MR. WILKINS: Robert Wilkins, Danfoss. When 

14 we first started this conversation, we had this 

15 discussion about restriction of sale of this type of 

16 equipment in this sector or this type of equipment in 

17 that sector. But what I’ve kind of heard the 

18 evolution of the dialogue going is that there could be 

19 or there’s a suggestion there could be a standard for 

20 precision computer room air conditioning equipment, 

21 and a standard for conventional commercial air 

22 conditioning equipment. But the question I – and I 

23 think that makes sense. But the question I’m raising 

24 is, if you have those two standards – this is 

25 precision equipment with high cost, high performance 
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1 capability over wide outdoor ambient range, et cetera, 

2 et cetera, and standard equipment. Then is there any 

3 need at all for any restriction of sale, cross sale? 

4 If the computer manufacturer can figure out how to use 

5 a basic standard commercial air conditioner to meet 

6 those needs, why should we restrict him from doing 

7 that, and likewise, if that high end customer wants to 

8 spend an exorbitant amount of money to put a very 

9 precision piece of equipment into a commercial office 

10 building, why should we restrict that? 

11 MR. BROOKMAN: Warren, follow on. 

12 MR. BEETON: And I think a comment earlier 

13 was to the effect that no one is going to be likely to 

14 try to apply precision cooling equipment for general 

15 air conditioning. 

16 MR. BROOKMAN: Gary. 

17 MR. NETTINGER: Gary Nettinger, Panasonic. 

18 I’m not opposed to the marketing aspect of it in the 

19 definition. Within this room we’re speaking more and 

20 more often about precision air conditioning equipment. 

21 I think that term would be a lot more appropriate for 

22 use in this standard, rather than computer room, 

23 because if we – if it’s classified as precision air 

24 conditioning equipment, it doesn’t restrict any 

25 market. It doesn’t impeded how I sell my equipment or 
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1 how they sell their equipment. 

2 MR. BROOKMAN: Robert. 

3 MR. WILKINS: Gary, I think that’s a great 

4 point. For example, the equipment might be used in 

5 some specialized laboratory, biomedical laboratory for 

6 example, where you had to have very strict climate 

7 control. Same type of requirements is not a computer 

8 room. So the distinction that I’m hearing is more 

9 it’s precision equipment and standard commercial air 

10 conditioning equipment, with no prohibitions of where 

11 the equipment could be utilized. That would be left 

12 up to the commercial forces, market forces to 

13 determine. 

14 MR. BROOKMAN: Thank you. Paul. 

15 MR. DOPPEL: Paul Doppel, Mitsubishi 

16 Electric. I just wanted – I support those two 

17 comments, because again, that makes more sense for the 

18 market to determine how the product is being applied, 

19 rather than trying to use a definition in DOE language 

20 to try to sort that out. So I support Gary’s calling 

21 it precision. 

22 MR. BROOKMAN: Eric Stas. 

23 MR. STAS: So in your written comments, 

24 would it be possible to come up with some objective 

25 measures or distinctions of what constitutes a 
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1 precision air conditioner that could be put in this 

2 computer room definition? So that we don’t have to 

3 get into marketing and sale. 

4 MR. WILKINS: Eric, you’re looking at me 

5 because I made the comment, and that’s reasonable. 

6 But I would defer that to the people that manufacture 

7 those types of products, probably. 

8 MR. STAS: Let me ask the question more 

9 broadly. 

10 MR. WILKINS: And I – and just to add that I 

11 was only trying to facilitate a little bit here and – 

12 MR. BROOKMAN: So Eric would like to direct 

13 that question to manufacturers in the room. Would it 

14 be possible to describe this precision equipment in a 

15 way that is distinctive and – people are pointing at 

16 you, Warren. 

17 MR. AMRANE: Karim Amrane, AHRI. As I 

18 indicated several times already, we are bringing those 

19 manufacturers in house, so we will get you some better 

20 definition. 

21 MR. BROOKMAN: What’s the time frame? I’m 

22 sorry to press you on that. 

23 MR. AMRANE: Karim Amrane, AHRI. We will 

24 have a discussion on this particular rulemaking before 

25 the comment deadline, so we will get you some 
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1 information. 

2 MR. BROOKMAN: Thank you. Thanks a lot. 

3 Okay. That was productive. Final comments on this 

4 series of issues because we’re going to be moving on 

5 here. Okay. 

6 MR. SCOTT: Okay. Just to complete the 

7 life-cycle cost analysis and payback period analysis 

8 discussion, as people who have been involved in this 

9 before know, this is an economic evaluation from the 

10 end user perspective, so this is the value to the user 

11 when the equipment is put in place and operated. The 

12 results are expressed as life-cycle cost savings, that 

13 is, the difference between a baseline piece of 

14 equipment and the equipment at a standard level, and 

15 then we also calculate a simple payback period and we 

16 report that in the analysis. And I have a sort of a 

17 simple diagram here on the slide that reminds me that 

18 it’s a combination of first cost, which is the end 

19 user price, or the marked up price, plus installation 

20 costs for the equipment, and then looking out into the 

21 future, there’s a discounted cash flow of costs which 

22 are electricity, in this case, repair and maintenance 

23 costs. And all of those are combined using the 

24 discount rate so that we have an equivalent present 

25 value measure, and we can look at the differences in 
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1 life-cycle costs between the two levels. So that’s 

2 generally how it’s carried out. 

3 I’m not going to be talking so much about 

4 electricity cost today. Basically this equipment goes 

5 into commercial buildings of a couple of different 

6 types, for computer rooms in those buildings, and 

7 we’re using average commercial prices for each of the 

8 states, escalated going forward, using Energy 

9 Information Administration forecasts and then from the 

10 information types of buildings, then sometimes those 

11 have different prices than the commercial average, so 

12 we take that into account. 

13 What I am going to talk about a little bit 

14 more today is installation costs and the repair and 

15 maintenance costs because they’re kind of a unique 

16 problem to this rulemaking. There was virtually – 

17 there was very little installation costs information 

18 available. What we were able to find is that RS 

19 Means’s CostWorks system does provide information that 

20 allows mechanical contractors to bid jobs for 

21 installing computer room air conditioning, so what we 

22 were able to do is calculate installation costs at 

23 various cooling capacities and create a cost curve 

24 relationship for each of the cooling types, for air25 cooled, water-cooled, and glycol-cooled. 
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1 But we had no information about variation in 

2 that equipment cost by efficiency level, nor did we 

3 really expect any, because we believe that this 

4 equipment is—even more efficient equipment— is likely 

5 to be about as expensive to install as more 

6 conventional baseline equipment. The principal 

7 difference in installation costs appears to be the 

8 capacity of the system, and we were able to take that 

9 into account, but then we assume that installation 

10 cost itself would not vary with efficiency level. And 

11 that’s all reported in the technical support document. 

12 However, we are interested in observations 

13 from people in the room here and on the web concerning 

14 whether they believe installation costs really ought 

15 to increase as a function of efficiency as opposed to 

16 capacity. And if so, how should that increase in cost 

17 be estimated or derived? Because we have pretty much 

18 exhausted the data that we have. 

19 MR. BROOKMAN: See the question there. I 

20 don’t think we have anything. 

21 MR. SCOTT: I guess silence means consent. 

22 Not sure. 

23 MR. BROOKMAN: So as you reflect on this 

24 point, or you can come back later with comments, that 

25 would be helpful to get back to the Department on. 
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1 Yes, Robert. 

2 MR. WILKINS: Robert Wilkins, Danfoss. I 

3 don’t have anything to respond directly to this 

4 question. However, indirectly, I’m reminded of the 

5 work we did a few years ago when we established 13 

6 SEER in residential systems. And we raised the 

7 minimum from ten to 13, and that worked fairly well in 

8 new construction, but it created a lot of problems in 

9 retrofit and replacement, because the installation 

10 costs were so substantial. Maybe the installation 

11 costs were incrementally higher in new construction, 

12 but in the replacement market, they were substantially 

13 higher because the indoor unit simply wouldn’t fit in 

14 the closet where the old one was. It was much larger, 

15 the units were larger. And so I don’t know whether 

16 that’s directly relevant here, but I offer that as one 

17 point to consider. 

18 MR. BROOKMAN: Warren. 

19 MR. BEETON: I’d have to see if our folks in 

20 that division have any comments, but I question – I 

21 would bet that a lot of equipment that goes into 

22 installations where attention is paid to energy 

23 efficiency, that there will be costs, not caused by 

24 the equipment, but caused by the intention of the 

25 consulting engineer or whoever designed that and also 
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1 the equipment that goes with it, that will tend to be 

2 more efficient as a consequence. So they might be 

3 associated or correlated, but not necessarily driven 

4 by the equipment rating. I don’t know if you’re still 

5 – if that’s part of what you’re interested in or not. 

6 MR. SCOTT: We’re certainly interested in 

7 anything you can tell us about the installation 

8 process that – I don’t know what we can take into 

9 account and what we actually can’t take into account, 

10 but we’re certainly interested in everything you can 

11 tell us about it. 

12 MR. BROOKMAN: And it’s for that equipment 

13 or the ancillary equipment supporting that equipment? 

14 MR. SCOTT: If there is, say, substantial 

15 amount of cost in ancillary equipment, and 

16 particularly if it changes by efficiency level, that’s 

17 worth knowing here, I think. 

18 MR. BROOKMAN: Okay. So we’re moving on to 

19 repair costs. 

20 MR. SCOTT: Right. Again, there was very 

21 little data available, however RS Means did provide 

22 some data on one-time repair costs for air-cooled 

23 equipment. They really didn’t have anything on water24 cooled or glycol-cooled. And what we did as an 

25 attempt to do an analysis here was to use some logic 
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1 and look at repair costs as a percentage of original 

2 equipment cost for different equipment capacities. 

3 The reason for doing that was we felt we needed a 

4 percentage type relationship, since we didn’t have 

5 actual equipment cost – actual repair costs for all 

6 classes of equipment. And the other thing that we 

7 observed was when we graphed out the repair costs, it 

8 appeared as though initially there’s a relatively 

9 large amount of labor cost associated as a percentage 

10 of the overall cost, and then as the equipment gets 

11 larger, it’s more the equipment that begins to 

12 dominate the labor. And so the percentage of labor 

13 continued – the percentage of labor stopped going up 

14 as the equipment became more expensive, but the 

15 overall cost of labor went up proportionately. 

16 So in showing all that in some cost curves, 

17 and then estimated for each of the classes of 

18 equipment, we multiplied the calculated percentage 

19 from the cost curve at each capacity times the 

20 original equipment cost at that same capacity, and 

21 that allowed us to develop a table of one-time 

22 baseline repair costs which were then converted into a 

23 baseline average annual repair cost. Basically, we 

24 annualized a one-time repair cost over the life of the 

25 equipment. 
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1 And then for higher efficiency levels, we 

2 believe that to the extent that the material portion 

3 of the baseline repair cost was the most important 

4 thing, we scaled the material portion of the repair 

5 cost for the more efficient equipment, but we did not 

6 scale the labor portion of the repair cost, again, 

7 going with the philosophy that the material cost was 

8 the primary thing that distinguished the efficiency 

9 levels and with what we’ve just said about the 

10 installation cost, that may not be true. But that’s 

11 what we did. 

12 And then for maintenance cost, RS Means 

13 basically had two maintenance costs allowed in their 

14 system. About $84 a year for units up to about 20 

15 tons capacity, 240 KBTU per hour, and another quote of 

16 $102 per year for larger units. These are routine 

17 maintenance costs, so they’d include things like 

18 cleaning the evaporator coils, lubricating motors, 

19 cleaning condenser coils, checking and refilling 

20 refrigerant as necessary and similar activities. And 

21 again, this would be an average over a period of 

22 years. 

23 We basically said that those costs were 

24 almost entirely attributable to labor expenses and we 

25 assume that those did not vary by efficiency level. 
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1 I think I’ll stop there for any comments on 

2 all of that. 

3 MR. BROOKMAN: Joanna. 

4 MS. MAUER: Joanna Mauer. Could you just 

5 explain again what – when you refer to one time 

6 baseline cost. 

7 MR. SCOTT: Yes, the RS Means says if you’re 

8 going to do a major repair on a computer room air 

9 conditioner, this is the cost of doing that. They 

10 don’t really specify what all they’re doing, but it’s 

11 a very high price, actually, it’s a substantial 

12 portion of the original installed cost. The 

13 impression you get is it’s almost a take it all out 

14 and throw it away and bring in a new room, just about. 

15 MS. MAUER: So, if the assumption that this 

16 is something that might occur once during the life of 

17 the equipment – 

18 MR. SCOTT: Right. 

19 MS. MAUER: -- and not something that is 

20 actually occurring annually? 

21 MR. SCOTT: Right. There’s an equivalent 

22 with annual, yeah. 

23 MS. MAUER: I guess my concern is 

24 annualizing the repair cost, is that the present value 

25 of the annualized repair cost is that going to be the 
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1 same as the present value of the repair cost in the 

2 actual year that it occurs? I understand there’s a 

3 lot of uncertainty in this particular case that we’re 

4 – it sounds like you’re not sure what the actual – 

5 what the cost represents, necessarily. 

6 MR. SCOTT: Right. 

7 MS. MAUER: But I think we see this in other 

8 dockets as well where, you know, I think there are 

9 cases where you’re replacing the compressor, you’re 

10 replacing something that’s really just occurring once 

11 in some future year, and so it’s just not equivalent, 

12 I think, as this. 

13 MR. SCOTT: In some rulemakings I’ve been 

14 involved with, we’ve actually had some information 

15 about how long the time period goes before you 

16 actually have a major repair, typically, and we’ve 

17 sampled from distributions. So if it’s usually between 

18 year eight and year 12, we’ll just draw from that 

19 distribution, and then annualize the result of that. 

20 Here we simply don’t know that. 

21 MS. MAUER: And I guess I don’t understand 

22 why it makes sense to annualize, you know, whether 

23 it’s a distribution between some number of years or a 

24 certain year, if you’re annualizing it, then you’re 

25 getting a higher present value, I think, than if you 
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1 actually took the present value of when the crisis 

2 would occur. 

3 MR. BROOKMAN: Dave Winiarski, try to answer 

4 this, and then Warren, to you. Dave – and use the 

5 microphone. 

6 MR. WINIARSKI: Yeah, Mike may have just 

7 been about to say this, but one thing you can think of 

8 it is if you sort of look at the repair cost and then 

9 bring back what that cost would be back to present 

10 value, you can think of I put a chunk of money away to 

11 cover that eventual occurrence, and so once it’s 

12 converted to present value, for the purpose of the LCC 

13 analysis, it’s not going to make a lot of difference, 

14 you know, whether you spread it over multiple years or 

15 it occurred in one particular year during the 

16 analysis. 

17 MS. MAUER: So you’re saying the present 

18 value – you’re doing it in such a way that the present 

19 value is equivalent, whether you’re taking the present 

20 value of a cost in a given year, or the present value 

21 of a stream of annualized costs? 

22 MR. WINIARSKI: That’s the idea. 

23 MR. BROOKMAN: Yes, Warren. 

24 MR. BEETON: And also another factor is that 

25 for compressors which would be a source of significant 
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1 portion of a repair cost, those failure rates look 

2 like a classic bathtub curve with a very tiny front 

3 end and a very tiny back end. So it’s basically a 

4 flat curve, and whether you do it for one year or for 

5 each year, doesn’t really matter. I think your 

6 analysis is good. 

7 MR. BROOKMAN: Okay. Thank you. Just a 

8 process note. We’re ahead of schedule, which is based 

9 on all of your good effort here today, and I’m going 

10 to suggest we just keep pressing on and finish this 

11 without pausing for lunch. I think we can do it, say, 

12 probably in an hour or less. 

13 MR. SCOTT: Okay, I’ll press on then. 

14 MR. BROOKMAN: Pressing on. 

15 MR. SCOTT: So discount rates. As I said 

16 before, we bring those annual costs back to the 

17 present using discount rates that represent how future 

18 monetary expenditures, or benefits, or costs for that 

19 matter are discounted to the present and indicate what 

20 value the consumer would place on the dollar of those 

21 future costs. So discount rates are going to vary 

22 with the type of customer, because different customers 

23 have different views of the future, and that’s created 

24 by the particular circumstances. It’s quite common, 

25 for example, on commercial entities to do something 
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1 called a capital asset planning model which take a 

2 weighted average of the cost of equity and debt, 

3 depending on how much equity and how much debt they’re 

4 carrying. 

5 And we’re fortunate that there is a website 

6 that actually has a source of data on individual, 

7 private companies. And we sorted through those – 

8 there’s actually several thousand, and we came up 

9 with a sample of 938 companies involved in the 

10 industries that we think are likeliest to use this 

11 kind of computer room: health care, education, 

12 finance, and services. And for those computers then – 

13 those air conditioners that were placed in a private 

14 building, then we sampled from that distribution of 

15 938 companies as a way to obtain estimates of what the 

16 discount rate might potentially be. 

17 This equipment is also used by universities, 

18 by state and local government, and by school 

19 districts. Well, state and local government, 

20 including school districts, typically have a bond 

21 rating of some kind that they would use for capital 

22 expenditures, and we chose a mid-range municipal bond 

23 rate that applies to state and local governments and 

24 to education institutions of a ten year AA municipal 

25 bond rate. Then for the federal government, we used a 
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1 geometric average of long-term greater than ten year 

2 US government securities to try to get an idea of what 

3 the borrowing rate likely would be there. 

4 And then we sampled from the distribution. 

5 So we had some air conditioners in public buildings, 

6 some air conditioners in private buildings, and the 

7 whole thing taken together then was part of our LCC 

8 analysis. 

9 MR. BROOKMAN: Steve Rosenstock. 

10 MR. ROSENSTOCK: Steve Rosenstock, EEI. In 

11 terms of this website, did they have information on 

12 retail companies that are using these type of services 

13 for tracking sales and/or internet service providers? 

14 MR. SCOTT: They do have information on 

15 publicly traded retail companies, yeah, so your 

16 suggestion would be that we add retail to this as 

17 well? 

18 MR. ROSENSTOCK: If possible, if it doesn’t 

19 cause too much of an analytical burden. And especially 

20 on the – if there’s the large, I would say, internet 

21 service providers, if there’s information on them, 

22 that would be helpful as well. 

23 MR. SCOTT: Yeah, we have some information 

24 on internet service providers, I believe. There’s a 

25 question here as to the application, I guess, of the 
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1 equipment. There was some discussion in the team 

2 about whether, for example, server farms were part of 

3 this, and we thought they were not. But there’s some 

4 – I see some frowns in the room. Maybe I’m speaking 

5 out of turn. 

6 MR. BROOKMAN: Dave Winiarski, I see first. 

7 MR. WINIARSKI: Not a frown, however. But I 

8 think that the issue is a real one. The type of 

9 equipment that we’re talking about, the direct 

10 expansion cooling units, are obviously used in 

11 computer room closets and some small application. How 

12 that carries on to very large server farms is a big 

13 unknown for us. I think our belief is that generally 

14 once you get into large server farms you’re talking 

15 about computer room air handlers, which generally are 

16 served by chillers, rather than small DX type 

17 equipment. But certainly, we’d welcome any comments 

18 to that from manufacturers. 

19 MR. BROOKMAN: Okay. You were hoping to get 

20 this in writing, I presume, in detail. 

21 MR. WINIARSKI: Sure, to the extent that – 

22 in fact, anyone involved in the industry who has some 

23 sense as to really what type of buildings and what 

24 type of businesses use the DX type computer room air 

25 conditioners that we’re talking about here, and the 
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1 relative proportion of how they use them, would be 

2 useful to have in detail, yes. 

3 MR. BROOKMAN: Okay. 

4 MR. SCOTT: And so what we finish with here 

5 is there’s going to be a lifetime for the equipment, 

6 and there’s some literature on that. We were able to 

7 locate seven sources. There’s a range, anywhere from 

8 ten years to 25 years. Looking at that literature as 

9 a whole, it appears that an average of perhaps 15 

10 years might be an appropriate average lifetime for the 

11 equipment. Lifetime is probably not shorter than ten 

12 unless there’s some kind of a major failure, and then 

13 probably not longer than 25 years. We chose, as is 

14 commonly used procedures, to use a Weibull 

15 distribution which is a statistical distribution that 

16 characterizes activities like the survival of 

17 equipment and infrequent failure events. 

18 So that’s what went into the life-cycle cost 

19 assessment. I’ll summarize the results briefly. In 

20 general, the life-cycle cost savings that you’ll find 

21 in chapter six and in the appendices in the TSD, and 

22 also in the NOPR, tended to be pretty strongly 

23 negative above the ASHRAE level. There weren’t very 

24 many levels above the ASHRAE level in any of the 

25 equipment that had a positive life-cycle cost savings, 
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1 even given the uncertainties that we’ve been 

2 discussing here. Where the exceptions occurred, there 

3 were generally pretty good reasons for it, or some 

4 contrary evidence out of the payback periods. 

5 For example, for the smallest air-cooled 

6 units at the first two levels, we did have positive 

7 life-cycle cost savings. However, the payback periods 

8 were fairly long, and the life-cycle cost savings were 

9 not particularly large. For medium and large air10 cooled units, we did actually have payback periods 

11 that were shorter than four years, but also keep in 

12 mind some of the uncertainties we’ve been talking 

13 about here. 

14 For the smallest water-cooled and glycol15 cooled units which are derived from them in this 

16 analysis, the payback periods were negative, and 

17 ordinarily you would think that would be a good thing 

18 because it would suggest that you’re not only having 

19 operating cost savings, but you’re also having first 

20 cost savings. However, as was described this morning, 

21 we question whether the price analysis on that 

22 equipment was showing something that was truly real 

23 for that equipment. 

24 And then for the medium and large water25 cooled and glycol-cooled units, we did have some 
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1 positive LCC savings. However, the payback periods 

2 generally were greater than nine years. In fact, they 

3 were generally greater than the lifetime of the 

4 equipment by quite a substantial margin. And we had 

5 three cases where we had negative payback periods for 

6 some of the equipment with fluid economizers. And in 

7 looking at those, what was happening was that the 

8 negative payback period was not because the equipment 

9 was getting cheaper as it got more efficient, but in 

10 fact, the repair costs were beginning to dominate the 

11 electricity savings, so we were getting actually, 

12 instead of having operating cost savings, we were 

13 having operating cost costs as the equipment became 

14 more efficient. Again, the payback periods were 

15 generally longer than equipment lifetime, for the 

16 reasons I’ve just given you, the two reasons for that. 

17 So that kind of summarizes what the outcome 

18 of the LCC analysis was, in general. 

19 MR. BROOKMAN: Okay. So comments on that, on LCC and 

20 payback period analysis. No? Okay, we’re going to 

21 move directly then to – thank you, Mike – to shipments 

22 analysis, national impact analysis, utility impact and 

23 emissions impact analyses. Alison Williams.

24 Shipments Analysis, National Impact Analysis, utility 

25 impact and emissions impact analyses 
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1 MS. WILLIAMS: Thank you. So I’m going to 

2 start with the National Impact Analysis. The purpose 

3 of this is to estimate the national energy savings for 

4 adopting standards for efficiency levels in ASHRAE 

5 Standard 90.1 2010 as well as more stringent levels. 

6 And for more stringent levels we also look at the 

7 national economic impact in terms of net present 

8 value. 

9 The first component of this is the shipments 

10 analysis. We did not have any shipments data for the 

11 United States for CRACs, so we started with historical 

12 and forecasted data for Australia as part of their 

13 rulemaking process. We use the ratio of business 

14 establishments in the U.S. and Australia to inflate 

15 Australian shipments to the U.S. market. And that 

16 inflator was about 13.2. We then extrapolated the 

17 trend that was in the Australia report to estimate 

18 future shipments out to the end of our analysis 

19 period. We disaggregated shipments into our 15 

20 product classes, first using Australia market shares 

21 for the six categories they had, and then using model 

22 availability in the U.S. to further disaggregate into 

23 all the product classes. And again in this analysis 

24 we did not distinguish between upflow and downflow 

25 units for reasons discussed previously, so there are 
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1 15 instead of 30 here. 

2 National energy savings are calculated over 

3 the standard 30 year period, beginning with the 

4 earliest compliance date which would be based on the 

5 adoption of the ASHRAE level. This would be 2012 for 

6 the small CRACs and 2013 for CRACs larger than 65 kBtu 

7 per hour. 

8 The net present value, or NPV analysis, 

9 extends later because it covers the life cycle 

10 installation and operational expenses, so it goes 

11 through 2055 or 2056 to account for all the operating 

12 cost savings, for shipments through 2041 and 2042. 

13 This assumes a 15 year product lifetime, the average 

14 of what Mike discussed earlier. 

15 Both these analyses account for a delay 

16 between when DOE can require compliance with standards 

17 if they set the level at ASHRAE, which is 2012 or 

18 2013. A more stringent level would not require 

19 compliance until 2017. 

20 We used national average customer prices, 

21 energy use, energy prices, repair and maintenance 

22 costs from the LCC analysis that Mike just discussed. 

23 Again, these inputs were based on the downflow units 

24 but assumed to represent upflow units as well. The 

25 annual time series were discounted to 2012 and we used 
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1 a constant price assumption for the default NIA 

2 forecasts. 

3 We distributed shipments into each of the 

4 efficiency levels considered, including the market 

5 baseline, ASHRAE level, and four higher efficiency 

6 levels. This was based on the model data that was 

7 discussed earlier. And the assumption for the 

8 standards case was that equipment less efficient than 

9 the standard would roll up to the standard level, but 

10 the standard would not affect shipments at the higher 

11 efficiency levels. Once a standard is in place, the 

12 new equipment enters the market at the rolled up 

13 efficiency levels, but in both the base case and the 

14 standards case, the efficiency distributions are 

15 frozen throughout time. 

16 So we have three specific issues we’re 

17 looking for comment on for the NIA. First would be 

18 whether there would be a rebound effect in computer 

19 room energy use. We’re also interested in whether 

20 shipments would change with the higher standard 

21 levels. And finally, any comments on our base case 

22 distribution or our prediction of standards case 

23 distributions. 

24 MR. BROOKMAN: Steve Rosenstock. 

25 MR. ROSENSTOCK: Steve Rosenstock, EEI. 
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1 Looking at this distribution in slide 69 for the air2 cooled CRACs I saw that you didn’t have a – you have 

3 max tech there of five percent of sales. Wherever 

4 I’ve seen the max tech in other rulemakings, it’s 

5 usually much much less than five percent, only because 

6 just the technology basically almost prototypes and 

7 not available on the marketplace, so just kind of 

8 curious, with this technology, how you estimated five 

9 percent for the max tech case? 

10 MS. WILLIAMS: So in this case, the max tech 

11 is actually a market maximum. 

12 MR. ROSENSTOCK: It’s already max? 

13 MS. WILLIAMS: Yeah, so we have a small bin 

14 at the end of it, so what we then did to get to that 

15 level was five percent. So I’m not entirely sure what 

16 the numbers are off the top of my head for all the 

17 other ones, but it is a market maximum, not any 

18 prototype or level of that sort. 

19 MR. BROOKMAN: Karim. 

20 MR. AMRANE: Karim Amrane, AHRI. I guess in 

21 looking at that chart, it doesn’t appear to be close 

22 to any other type of air conditioner. I mean if you 

23 look, for example, the residential AC or the 

24 commercial AC, you would see that the majority of the 

25 products sold in the market will be at the base case 
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1 level, and very little at the upper efficiency level. 

2 So I’m surprised to see that the 45 percent are the 

3 medium efficiency level. What about the baseline? I 

4 don’t know. It doesn’t seem right to me. 

5 MR. BROOKMAN: Robert. 

6 MR. WILKINS: Karim, this is Robert Wilkins, 

7 Danfoss. I was wondering the same thing and I was 

8 bouncing around in the back of my head some possible 

9 explanation. But then I thought, you know, in normal 

10 commercial office buildings, the equipment is - the 

11 buyer of the equipment is so far removed from the 

12 tenant, there’s a classic example that the buyer is 

13 buying this low cost cheap stuff because he’s so far 

14 removed from the tenant that has to pay the electric 

15 bill that he has got this inducement to buy this cheap 

16 low efficiency equipment. Likewise, in the home, new 

17 construction, for example, the builder is separated 

18 from the home owner. The home owner is typically not 

19 buying the equipment. 

20 But in this case, if I heard your arguments 

21 and your research and the work you did earlier on, 

22 this stuff is sold to the people that are operating 

23 the computer room or the laboratory or whatever, and 

24 therefore they have done all of this analysis, not 

25 only this, but even better because they’ve done it for 
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1 their own geographic location, their own utility 

2 rates, their own climate. They figured out what’s the 

3 right equipment to give them the right payback for 

4 their business. And so that could possibly be, and my 

5 hypothesis is that’s why that people are already 

6 buying the higher efficiency product. I’d welcome any 

7 feedback on my crazy hypothesis. 

8 MR. ROSENQUIST: This is Greg Rosenquist 

9 from LBL. This is strictly based on model 

10 availability. So it’s, you know, it certainly could 

11 be that reason what you just described, but really 

12 it’s just simply taking a percentage of the market in 

13 each one of these efficiency levels. It’s based 

14 strictly on model availability. 

15 MR. WILKINS: But the market availability by 

16 -- the manufacturer meets the market demand of what 

17 the consumer is specifying. They’re not producing 

18 something that a customer doesn’t want, I still think 

19 it reinforces the argument, the hypothesis. 

20 MR. BROOKMAN: Paul. 

21 MR. DOPPEL: Paul Doppel, Mitsubishi 

22 Electric. In support of what Rob was saying, another 

23 way to look at that is if you look at the dollar value 

24 of the equipment that’s in that room, and also the 

25 importance of maintaining operation, it’s easy to see 
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1 that more would be spent on the best possible cooling 

2 equipment to maintain – and, you know, a lot of places 

3 even put in double systems just to make sure that 

4 there is a backup there in case there’s an issue. 

5 MR. BROOKMAN: Okay. Additional comments 

6 here? 

7 MS. WILLIAMS: Okay. So just to sum up the 

8 NIA results, cumulatively across all the 15 product 

9 classes, ASHRAE - adoption of the efficiency levels in 

10 ASHRAE result in .01 quad of savings. Going higher 

11 would result in anywhere from .07 to .98 quads. 

12 However, the cumulative NPV savings across all product 

13 classes range from negative $2.25 billion dollars to 

14 $0.1 billion dollars. 

15 That’s all I have for the NIA. 

16 MR. BROOKMAN: Steve Rosenstock. 

17 MR. ROSENSTOCK: One quick one to follow up 

18 on what Paul said. In the analysis, and I hadn’t 

19 looked at the technical support document, what 

20 percentage of the units are considered to be pure 

21 backup and plus one units where they’re only operated 

22 if the primary unit fails? 

23 MR. BROOKMAN: Steve Winiarski. 

24 MR. WINIARSKI: This is Dave Winiarski. In 

25 the – it’s really not taken into account explicitly, 
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1 but it’s in looking at that 65 percent load factor 

2 figure, there’s a discussion in the TSD which talks 

3 about that issue and it’s kind of built in so, you 

4 know, if you purchased – if you need nine units, you 

5 purchase a tenth, or something like that, and that 

6 helps to reduce the average load factor on all pieces 

7 of equipment, but it’s not an explicit calculation, 

8 and we don’t separately analyze back up units from the 

9 remainder in the stock. 

10 MR. ROSENSTOCK: Steve Rosenstock, EEI. But 

11 again, what I think you did kind of reinforce my point 

12 is that there might be ten percent of the units, 

13 again, if it’s nine and you purchase ten, then ten 

14 percent of the units sold are purchased that are going 

15 to have minimal or no energy consumption during the 

16 year, they’re just purely backup. So that again, I 

17 don’t know what the percentage is, and then in certain 

18 computer rooms, I know they have full backup, where 

19 they buy – they need five units for that 65 percent 

20 load, they have five backup units. So it’s actually 

21 50 percent of the units that’s in that room are not 

22 being used at all. So again, I don’t know if that data 

23 is available. It might only be a ten percent, might 

24 only be a five percent, but it could have – again, 

25 it’s not explicit, but there could be an impact on 
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1 some of the savings estimated if the percentage is 

2 high. 

3 MR. BROOKMAN: Okay. Thank you. Yes. 

4 Joanna Mauer. 

5 MS. MAUER: Joanna Mauer. So just a couple 

6 of observations, I think that the previous – the table 

7 on the previous slide, I think shows that certainly 

8 significantly higher efficiency levels are certainly 

9 technically feasible and there’s – showing that 

10 there’s lot of models on the market that significantly 

11 exceed the levels in 90.1 2010, and then the – I 

12 realize that it’s going to permanate (ph) savings 

13 estimates, but range of a tenth of a quad to a quad is 

14 – I would certainly consider to be significant 

15 potential savings. 

16 Another observation is that the two product 

17 classes that make up the bulk of the energy savings 

18 potential, the medium and large air cooled air 

19 conditioners also have clearly positive net present 

20 value, both the three and seven percent discount 

21 rates, suggests to me that there are significant cost 

22 effective energy savings that could be achieved from 

23 higher efficiency levels. 

24 MS. WILLIAMS: I think it was Adam went into 

25 before some of the - a lot of this analysis was a lot 
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1 of uncertainties, so although some of the results 

2 might suggest you could go higher in some cases, we 

3 did not feel we had clear and convincing - or DOE did 

4 not feel they had clear and convincing evidence 

5 because of some of the reasons we suggested earlier. 

6 MR. BROOKMAN: Dave Winiarski. 

7 MR. WINIARSKI: Dave Winiarski, Pacific 

8 Northwest National Lab. One point I would like to 

9 emphasize and hopefully we get some feedback from the 

10 industry on was that in the analysis of the air-cooled 

11 products, we specifically did not incorporate air12 cooled economizers in helping to reduce the load on 

13 the equipment. We have very little data on how often 

14 or frequent they might be used with this class of 

15 equipment, but obviously, that would reduce the loads 

16 and to some extent the life-cycle cost savings and the 

17 national energy savings potential. So to the extent 

18 that anyone could provide information like that, it 

19 would be useful for the analysis. 

20 MR. BROOKMAN: Okay. Karim. 

21 MR. AMRANE: Karim Amrane, AHRI. I guess 

22 question to David. But I believe that 90.1 has a 

23 requirement on the economizer for data centers and 

24 have you looked at that? 

25 MR. WINIARSKI: Yeah, actually I looked at 
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1 that in a fair amount of detail. The issue is that 

2 90.1 does have requirements for economizers, but it 

3 has a tremendous amount of exceptions for those 

4 requirements. You have to basically, I think that the 

5 way that the exceptions are written, they’re really 

6 looking at requiring economizers in systems that use 

7 large air handlers and water-cooled buildings, and 

8 that for this class of equipment, because of the way 

9 90.1 was written, it appears that the requirements for 

10 economizers that would be required for comfort cooling 

11 applications don’t apply, necessarily, to those for 

12 computer room applications. 

13 MR. BROOKMAN: Additional comments or 

14 questions. 

15 MS. WILLIAMS: Okay. So moving on to the 

16 downstream analyses. DOE conducted a utility impact 

17 analysis to assess the impacts on the domestic energy 

18 supplies from the standard. This was done using NEMS19 BT, which is a variation of NEMS used by EIA for their 

20 Annual Energy Outlook, and this model assesses the 

21 impacts from standards as deviations from the AEO 

22 reference case, and as a result - avoided capacity 

23 forecasts. 

24 DOE also assesses the emissions from the 

25 power plants and the implications that standards have 
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1 for this. This comes out of the same NEMS-BT model. 

2 DOE looks at carbon dioxide, sulfur dioxide, nitrogen 

3 oxides and mercury. I should note that NEMS-BT does 

4 not show any measurable impact on SO2 because of the 

5 clean air amendments that cap SO2 emissions. There 

6 are also some nitrogen oxide caps that limits what 

7 NEMS-BT shows for those. 

8 MR. BROOKMAN: Yes, Steve Rosenstock. 

9 MR. ROSENSTOCK: Steve Rosenstock, EEI. On 

10 this one, just again, I don’t know how DOE is going to 

11 incorporate it, but there are – EPA did announce a 

12 standard on mercury for power plants that are going 

13 to go into effect, as I recall, within the next three 

14 to four years, which is basically near the beginning 

15 or right before the beginning of certain standards are 

16 going to take effect, and in terms of carbon dioxide, 

17 EPA is on track to put out rules on emissions caps for 

18 power plants, so at that point I’m just kind of 

19 curious when these rules are announced and put in 

20 place, is DOE going to use the same rationale for CO2 

21 and mercury as it does for NOX and sulfur dioxide? 

22 MS. WILLIAMS: So generally, DOE will 

23 include, when NEMS is updated, it will include some of 

24 the newer rules, especially if there’s a transport 

25 rule that deals with NOX. I think that wasn’t taken 
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1 into account in AEO 2011, so when AEO 2012 comes out 

2 it will take that into account, and we will redo the 

3 analysis, so whenever the future rules come out that 

4 affect this, NEMS will be updated, and at that point, 

5 DOE will be able to take those into account in these 

6 analyses. 

7 MR. ROSENSTOCK: Again, thank you. Steve 

8 Rosenstock, EEI. So you’ll take the same approach in 

9 terms of the economic numbers assigned to these 

10 emissions? 

11 MS. WILLIAMS: So in terms of the 

12 monetization, not sure if I can answer that question, 

13 so I’ll move on to this very quickly. Currently DOE 

14 monetizes CO2 using the values for the social cost of 

15 carbon developed during interagency process. So as 

16 the interagency group revises those values, DOE will 

17 take those new values into account. And similarly, 

18 the values for NOX that DOE has been using. Does 

19 anyone else have more – 

20 MR. BROOKMAN: Greg Rosenquist. 

21 MR. ROSENQUIST: Yeah, it’s whenever the 

22 interagency agreement gets updated, then DOE uses 

23 those numbers to monetize carbon, so and since it’s 

24 developed through this interagency process – 

25 MR. ROSENSTOCK: Right. Steve Rosenstock. 
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1 Yeah, I understand that, but the way DOE approaches 

2 it, once there’s a cap like there is with sulfur 

3 dioxide, DOE says there’s no impact on the upstream 

4 emission from the downstream efficiency standard. So 

5 you’re going to take that – I assume you’re going to 

6 take that approach with CO2, correct? 

7 MS. ARMSTRONG: I think the best thing to 

8 say is if the rules got – if rules come into effect, 

9 we would deal with it at that time. 

10 MR. ROSENSTOCK: Well, again, Steve 

11 Rosenstock. I appreciate that, thank you very much, 

12 but again, the reason I ask that, you’re talking about 

13 a 30 year period – 

14 MS. ARMSTRONG: No, I understand. 

15 MR. ROSENSTOCK: -- and within five years of 

16 that 30 year period, the cap will be in place. 

17 MS. ARMSTRONG: Sure. We understand, but 

18 the rules have to be promulgated first. 

19 MR. ROSENSTOCK: They are being promulgated. 

20 MS. ARMSTRONG: I understand. 

21 MR. ROSENSTOCK: And they’re finalized, but 

22 they – 

23 MS. ARMSTRONG: We would need finalized 

24 before we can speculate. 

25 MR. ROSENSTOCK: You can’t use a sensitivity 
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1 case where – 

2 MS. ARMSTRONG: You can suggest that we 

3 should. 

4 MR. ROSENSTOCK: Okay. Thank you. 

5 MR. BROOKMAN: Okay. Thank you. That last 

6 set of comments from Ashley. Okay. So yes? 

7 MS. WILLIAMS: That’s all. 

8 MR. BROOKMAN: That’s all with that. So 

9 Ashley Armstrong to talk about certification, 

10 compliance, and enforcement. 

11 Certification, compliance, and enforcement 

12 MS. ARMSTRONG: Okay. I only have one 

13 slide. I want to generally explain how our savings 

14 plans work for certification, and I understand that 

15 we were just earlier – some of the potential issues 

16 or concerns with the time, but I do want to make you 

17 aware because there are already on the books, and 

18 they have been adopted for ASHRAE equipment and ... or 

as the certification ... come in December 31st 19 of this 

20 year for products that either have to be in 

21 compliance with standards, manufacturers are required 

22 to use these sampling plans in absence of DOE 

23 revising them and going through that process again. 

24 So we’re not going to – you test the minimum units of 

25 the basic model, that minimum number is no less than 
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1 ten. Unless DOE promulgates some other alternative 

2 to testing, like I said, ... type rule that we’re 

3 working on now, you can test more than two units to 

4 our discussion, the actual sample of the basic model, 

5 but you’re required to test no less than two. You 

6 determine which federal standards apply, depending on 

7 the product, the references are there. And you 

8 calculate your mean and it’s two or more, you 

9 calculate your mean of your sample. You determine 

10 your rating values. This has to do with the 

11 distribution of your confidence limit or a lower 

12 confidence limit depending on if it’s an efficiency 

13 standard or if it’s a consumption standard, and then 

14 you actually generate your certification rating. And 

15 what you can do is you can always rate more 

16 conservatively, but you can’t do the overrate. This 

17 will give you the maximum number you can rate at. 

18 So it’s not as simple as just running the 

19 test once, that’s the number that’s on that you 

20 certify that that’s the number that you make 

21 representations of. I just wanted to make that 

22 clear. It’s really, as I stated earlier, DOE is more 

23 than willing to work with both industry as well as 

24 AHRI to address some of the concerns, but I did want 

25 to go over quickly just these are required for some 
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1 of the equipment we talked about today. It’s not 

2 subject to existing standards. We’re going through 

3 the process of adding it to – proposing to add it to 

4 the program. You won’t be required to certify, DOE 

5 will address any certification requirements in a 

6 later rule, but you wouldn’t be required to certify. 

7 A total compliance with standards is 

8 required, so it will be some time down the road, 

9 however if you do make some representations about 

10 equipment’s efficiency, you do have to do it with our 

11 test procedures as well as our sampling plans. 

12 MR. BROOKMAN: Karim. 

13 MR. AMRANE: Karim Amrane, AHRI. What 

14 you’re saying here, does it apply to VRFs as well as 

15 data centers, computer rooms, or what are the 

16 products you are talking about here? 

17 MS. ARMSTRONG: It will apply to VRFs and 

18 data centers in terms of testing. But they will not 

19 be required to certify compliance with the standards 

20 until the compliance date of the actual standard DOE 

21 adopts. So if they make representations earlier than 

22 that, whether in the product literature, in marketing 

23 tools, in a certified directory, they need to do it 

24 following these steps, but, you know, they don’t have 

25 to do it until the compliance date. And at the 
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1 moment we don’t have certification requirements on 

2 the books for those types of equipment because just 

3 in the process of adjusting them in our program. 

4 Okay? 

5 All right, I’m going to turn it back over to 

6 you. 

7 MR. BROOKMAN: Frank Stanonik. Find a 

8 microphone, Frank. 

9 MR. STANONIK: Frank Stanonik, AHRI. 

10 Ashley, you just made me think of something and I 

11 want to make sure that we’ve got it right. There’s 

12 some other things in this NOPR about just updating 

13 test methods, without any associated change in the 

14 level. And at least in some cases, the determination 

15 has been made that using the new test procedures 

16 doesn’t change anything. 

17 I’m assuming, and I’m looking for 

18 verification, that in those cases that in effect, 

19 this updating of the test procedure does not put any 

20 other obligation on the manufacturer to do retests. 

21 MS. ARMSTRONG: So we will explicitly 

22 address that, but unless the rating is going to 

23 change, that is correct. 

24 MR. STANONIK: Okay. Thanks. 

25 MR. BROOKMAN: Okay, go on. 
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1 MR. BEETON: I just have a question or maybe 

2 a comment, or a combination about the tolerance 

3 issue. You know, as a component manufacturer of 

4 compressors, we have lived with the ARI tolerance 

5 system, plus or minus five percent on the equipment, 

6 which can mean a tighter tolerance on the components, 

7 of course, and it’s a very extensive management 

8 process at our company to stay within those 

9 tolerances. Now all of a sudden I’m hearing today 

10 for the very first time that because you’re now going 

11 to have an independent verification method that is 

12 going to be separate from ARI’s that we may be 

13 subject to something different, which we don’t know. 

14 You haven’t disclosed it. 

15 MS. ARMSTRONG: So let me clarify it. One 

16 is – I said nothing today about an independent 

17 verification program. DOE does have the discretion 

18 to test at any time, should it want to, or should it 

19 have a reason to. It doesn’t mean that -- DOE 

20 doesn’t have a formalized verification program up and 

21 running right now. The second part is these are 

22 actually sampling plans for certification testing, 

23 and certification testing is something a manufacturer 

24 does before it actually certifies the efficiency of 

25 their product. They are not new. They’ve been 
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1 adopted since 2006, the CFR since 2006. There is 

2 nothing new about these. 

3 MR. BROOKMAN: Warren, go ahead. 

4 MR. BEETON: But, we’re going to be subject 

5 to different tolerance requirements as a consequence 

6 of what the rulemaking today than we have been in the 

7 past, is that not correct? 

8 MS. ARMSTRONG: So it’s going to depend on 

9 the – I guess the ultimate answer is yes, there will 

10 be definitely, and they’re based upon the 

11 distribution of the two units you test. It’s not a 

12 straight out plus or minus five percent. It could be 

13 pretty close to that, but if you have high 

14 variability, then the ... could be less. 

15 MR. BEETON: So are you saying that based on 

16 a test of a model, a model, which could be two units, 

17 you’re going to decide what the variation – allowable 

18 variation is for that model based on the test of two 

19 units? 

20 MS. ARMSTRONG: The tolerances already have 

21 variation built in them. They’re based on an upper 

22 and lower confidence limit. It’s going to supposedly 

23 reflect – it’s going to tell you what your rating can 

24 be. It’s not for determining the compliance with the 

25 standard. 
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1 MR. BEETON: Oh, okay. 

2 MS. ARMSTRONG: It’s not for enforcement 

3 purposes. It’s just going to tell you what your 

4 rating can be. 

5 MR. BEETON: Okay. 

6 MS. ARMSTRONG: The plus or minus five 

7 percent that they run in the verification program, we 

8 have an enforcement tolerance which is different than 

9 these. And that’s how they were determined – 

10 MR. BEETON: Then my comment has to do with 

11 that. And it has to do – I just want to repeat our 

12 concern, not as an equipment manufacturer, but as a 

13 component manufacturer that this is a very huge issue 

14 for us to see a change which we don’t know you’re 

15 going to specify. You just said today that the 

16 information is not available, right. 

17 MS. ARMSTRONG: It’s been on the books in 

18 CFR since 2006. I can show you. I can come over 

19 there and show you exactly where you can find it. 

20 MR. BEETON: Okay. But we, you know, Karim 

21 mentioned that ARI is opposed to this. As a 

22 component manufacturer, we’re very much concerned 

23 about this issue. That’s my comment. 

24 MR. AMRANE: Karim Amrane, AHRI. The fact 

25 that it’s in CFR 2006 doesn’t mean it’s correct, 
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1 though. 

2 MS. ARMSTRONG: And I can relate to that. 

3 MR. AMRANE: So that is why, if DOE is ... is 

4 five percent for the test procedure, for the HR 

5 standard, I think DOE has, at the same time, has to ... 

6 that to make sure that this other confidence thing ... 

7 We cannot – as an industry, we will not accept ... five 

8 percent, without DOE looking as well at that part of 

9 the – 

10 MS. ARMSTRONG: That’s fair, and DOE will 

11 work with you. DOE has never had the five percent in 

12 its regs. So, I mean at this point, we will work 

13 with you to work with this, but the five percent has 

14 never been in our regs. 

15 MR. BROOKMAN: Okay. Final comments on the 

16 sampling plans and these specifics that are listed 

17 here. Okay. I think we’ve covered everything that’s 

18 in the agenda to be covered. Now there’s another 

19 opportunity for anybody that wishes to do so to make 

20 additional comments here as we move towards closing. 

21 And you can see the Department here specifically 

22 invites comment on some issues listed. Yes. 

23 Closing Remarks 

24 MR. STANONIK: Frank Stanonik, AHRI. Just a 

25 question, trying to assimilate all this information. 
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1 In the case of the computer room air conditioners, 

2 you shipment data from Australia because that’s all 

3 you could find. So first question is, does Australia 

4 have efficiency requirements for commercial room air 

5 conditioners? 

6 MR. BROOKMAN: Alison. Alison, you’ve got 

7 to find the microphone, please. 

8 MS. WILLIAMS: (off mic) Yes. 

9 MR. STANONIK: Okay. Are those efficiency 

10 requirements different than what I’ll call a comfort 

11 air conditioner? 

12 MR. BROOKMAN: So the first question 

13 Alison’s going to answer now, once she pushes her 

14 green button. Yes, thank you. 

15 MS. WILLIAMS: Alison Williams, LBNL. Yes, 

16 Australia regulates computer room air conditioners. 

17 They call them close control air conditioners. 

18 MR. STANONIK: Is the efficiency requirement 

19 different in Australia than for a comfort air 

20 conditioner? 

21 MS. WILLIAMS: I – 

22 MR. WINIARSKI: I think that they may have a 

23 different metric, and therefore they would have a 

24 different standard than a – 

25 MR. STANONIK: Probably the most important 
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1 question. Does Australia in some way regulate what 

2 can be used in a computer room? 

3 MR. WINIARSKI: I don’t believe so. 

4 MR. STANONIK: And the reason I was asking 

5 again, realizing you’re using the best tools you can, 

6 we’ve heard here that in fact, depending, let’s say, 

7 on what’s going on in that computer room and what’s 

8 required in terms of let’s say precision or 

9 reliability, you could use comfort air conditioner in 

10 some computer rooms, in some other rooms you might 

11 use a computer room air conditioner. And what I was 

12 trying to establish was if the situation was 

13 different in Australia, for example, if in Australia 

14 they said every computer room had to have a unit 

15 listed for that use, then your proportioning won’t 

16 work, okay, because in fact we are a different market 

17 condition. But if appears we don’t know that. 

18 MR. WINIARSKI: Yeah, I was going to say I 

19 have no first hand knowledge of them, but I believe 

20 that their basic process is similar to our process 

21 where it’s regulated as a manufactured component, but 

22 I have no idea what’s in their codes and standards 

23 for the buildings themselves. My suspicions is that 

24 they would have no restraint, that you could use a 

25 standard comfort air conditioner. 
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1 MR. STANONIK: One last question about the 

2 analysis you’ve been doing. And I, for one, we’ve 

3 heard a lot about, again, depending on whether the 

4 computer room equipment is being used for, there is a 

5 higher demand for reliability and a much lower 

6 tolerance for air conditioning unit failure, and all 

7 that factors into the computer room air conditioner 

8 equipment cost, installation, maintenance, all that 

9 stuff. Have you tried to kind of work that into the 

10 analysis that in fact there’s just a different – the 

11 precision not only relates to maintaining a very 

12 tighter band of cooling or temperature, but in fact a 

13 very different tolerance for either equipment 

14 breakdown or reliability? 

15 MR. WINIARSKI: Yeah, our analysis doesn’t 

16 do that explicitly by any means. To the extent that 

17 that’s reflected in the cost of units, so that may 

18 be, but our analysis doesn’t incorporate it. 

19 MR. BROOKMAN: Steve Rosenstock. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEI. In 

21 terms of just the general kind of final comments. I 

22 appreciate what all the work that DOE has done in 

23 adopting the ASHRAE levels. I think it will help in 

24 terms of just again, reinforcing energy savings. I 

25 work on ASHRAE quite a lot and ASHRAE has really 
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1 worked very hard to look at everything in terms of 

2 the improving efficiency in commercial buildings, so 

3 I think where you’ve adopted ... levels, I think it 

4 kind of supports a lot of the details that ASHRAE 

5 does because they have to be cost effective, and I 

6 think it will really help efficiency for all 

7 commercial buildings and the federal government 

8 buildings. Thank you. 

9 MR. BROOKMAN: Joanna. 

10 MS. MAUER: Joanna Mauer. I just wanted to 

11 reiterate that we – the concern with the levels that 

12 DOE adopts for computer room air conditioners end up 

13 being weaker than the current California standards, 

14 but also we’d be concerned if the levels are 

15 significantly lower than the levels for other 

16 commercial package air conditioners, because there’s 

17 not a technical basis for that, so we encourage DOE 

18 to look at those things. 

19 MR. BROOKMAN: Thank you. So you can see 

20 these are closing remarks. Additional comments and 

21 issues that you wish to raise. Paul. 

22 MR. DOPPEL: Paul Doppel, Mitsubishi 

23 Electric. I’d also like to thank DOE for the efforts 

24 to the ASHRAE new products into the CFR. This is a 

25 last step for VRF products to be sort of fully 
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1 integrated into the industry, and so we view this as 

2 an important step. And want to recommend that DOE 

3 works closely with AHRI on the test standard. Any 

4 concerns that you have with that, to see if there’s 

5 something that we can work out to be sure that DOE 

6 feels that the standard is representative of all 

7 other standards in the industry, and there’s a way to 

8 test these very complex systems with manufacturer 

9 representatives present, because it is essential for 

10 that to take place. 

11 And also we recommend that the operations 

12 manuals that AHRI be included in any materials that 

13 are incorporated for reference by DOE. 

14 MR. BROOKMAN: Okay. Other closing 

15 comments. I see none, so the Department always hands 

16 out an evaluation form at the end of these meetings, 

17 so I’m going to pass these around, and on my part, I 

18 thank you. We had a very productive meeting. And 

19 I’ll turn it back to Mohammed Khan. 

20 MR. KHAN: Mohammed Khan, DOE. Just want to 

21 again express appreciation for all the input that we 

22 received today. It’s been a wide scope of input, a 

23 lot of concerns that we heard regarding the test 

24 standards, the test procedure concerns as well. 

25 And at this point here, I just want to 
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1 reiterate the importance of comments, written 

2 comments, and again here’s how you would do it, and 

again, the deadline is April 2nd 3 , and if at all 

4 possible, I would like to request that you get your 

5 comments in earlier than that. Generally we say the 

6 comments come in right about that date and of course 

7 we have to analyze and go through the comments and 

8 incorporate them into the final rule, which we need 

9 to turn around very shortly after that anyway. So 

10 again, if you could get it in sooner, that would be 

11 better. 

12 So, with that, I just want to say thank you 

13 very much for a very productive day. 

14 (Whereupon, at 1:00 p.m., the meeting in the 

15 above captioned matter was adjourned.) 

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 REPORTER'S CERTIFICATE

 This is to certify that the attached proceedings 

before: 

U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS 

FOR CERTAIN COMMERCIAL AIR CONDITIONING, 

HEATING AND WATER HEATING EQUIPMENT, i.e., 

CERTAIN EQUIPMENT IN ASHRAE STANDARD 90.1.2010 

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law Judge 

or the Agency. 

 Further, I am neither counsel for or related to any 

party to the above proceedings. 

 

Debra Derr 

 Official Reporter 

Dated: February 21, 2012