Energy Conservation Standards 

Notice of Proposed Rulemaking on Small, Large, and Very 

Large Air-Cooled Commercial Package Air Conditioning and 

Heating Equipment

Public Meeting on

November 6, 2014

CommPkgACHP2013STD0007@ee.doe.gov
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of this 

meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar conversations.

– Webinar participants turn phone on mute; ‘raise your hand’ to be recognized 

to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Listening Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
4

Agenda

9:30 – 9:40 am Welcome, Introductions, Opening Statements

9:40 – 10:30 am Overview, Scope, Proposed Standard, Market and Technology 

Assessment, Screening Analysis

10:30 – 11:15 am Engineering Analysis

11:15 – 11:30 am Break

11:30 am – 12:00 pm Energy Use, Markup Analysis, Life-Cycle Cost and Payback Period 

Analysis

12:00 – 12:30 pm Shipments, National Impact Analysis

12:30 – 1:30 pm Lunch

1:30 – 2:00 pm Manufacturer Impact Analysis

2:00 – 2:30 pm Utility Impact Analysis, Employment Impact Analysis, 

Environmental Assessment, Regulatory Impact Analysis

2:30 – 2:45 pm Break

2:45 – 3:15 pm Proposed Standard

3:15 – 3:30 pm Closing Remarks
5

Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate 

potential energy conservation standards for commercial 

package air conditioning and heating equipment.

• Invite comment on the energy conservation standards notice of 

proposed rulemaking (NOPR) and technical support document 

(TSD), including DOE’s proposed standard levels.

• Invite participants to provide summary comments or 

statements and raise additional issues for discussion. 
6

Issue “Boxes” for Discussion

• Issue “boxes” correspond to the list of issues for which the 

Department seeks comments.

Issue Box: DOE welcomes comments, data, and information 

concerning the standards it is considering for small, large, and 

very large air-cooled commercial package air conditioning and 

heating equipment. Issues that correspond to those raised in 

DOE’s published material will be presented. Whether invited 

by an issue box or not, comments are welcome on any part of 

DOE’s analysis.

• The deadline for submitting comments is December 1, 2014.
7

Opening Remarks

Meeting participants are invited to provide opening remarks 

or statements at this time.
8

Public Meeting Topics

1 Overview; Scope; TP; Proposed Standard;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
9

Background and Current Standards

• The Energy Policy Act of 2005 (EPACT 2005), Pub. L. No. 109-58 (Aug. 8, 2005), 

amended EPCA to prescribe standards for small, large, and very large aircooled commercial package air conditioning and heating equipment (CUAC 

and CUHP).

• The American Energy Manufacturing Technical Corrections Act (AEMTCA) 

amended EPCA to require DOE to initiate a rulemaking to consider amending 

the standards for any covered equipment as to which more than 6 years has 

elapsed since the issuance of the most recent final rule establishing or 

amending a standard as of the date of AEMTCA’s enactment, December 18, 

2012. (42 U.S.C. 6313(a)(6)(C)(vi))

• AEMTCA required DOE to issue either a notice of determination that the 

current standards do not need to be amended or a NOPR containing 

proposed standards. 

• On Feb. 1, 2013, DOE published a request for information (RFI) and notice of 

document availability to solicit information to help DOE determine whether 

more stringent standards would be technologically feasible and economically 

justified for CUACs and CUHPs. 
10

EPCA Factors

EPCA directs DOE to consider seven factors when setting energy conservation 

standards. (42 U.S.C. 6313(a)(6)(B))

EPCA Factors Corresponding DOE Analyses

1. Economic impact on customers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the equipment Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers 

relevant

Environmental Assessment

Utility Impact Analysis

Employment Impact Analysis
11

Energy Conservation Standards Rulemaking Process

RFI NOPR Final 

Rule
12

Energy Efficiency Descriptor – Cooling Efficiency

• The current energy conservation standards for air-cooled CUAC and 

CUHP are based on energy efficiency ratio (EER) for cooling efficiency 

and coefficient of performance (COP) for CUHP heating efficiency. 10 CFR 

431.97(b).

• In the RFI, DOE noted that it was considering whether to replace the 

existing efficiency descriptor, EER, with a new descriptor, IEER.

• EER metric only uses the efficiency of operating at full load.

• IEER metric also factors in the efficiency of operating at part-loads of 

75%, 50%, and 25% of capacity, weighting the full- and part-load 

efficiencies with the average amount of time operating at each 

loading point.

• The usage pattern weights for the IEER metric were developed by 

analyzing equipment usage patterns of several buildings across the 

17 ASHRAE Standard 90.1–2010 climate zones. 

• The weighting factors accounted for the hours of operation where 

mechanical cooling was active. 
13

Energy Efficiency Descriptor – Cooling Efficiency

• Current DOE test procedure incorporates by reference specific sections 

of AHRI Standard 340/360–2007.

• Includes methods and procedures for testing and rating equipment 

with the IEER metric.

• ASHRAE Standard 90.1–2010 specifies two performance requirements: 

EER and IEER.

• EPCA requires that test procedures be reasonably designed to produce 

test results that measure the energy efficiency of covered equipment 

during a representative average use cycle. (42 U.S.C. 6314(a)(2)) 

• The IEER metric weights the efficiency of operating at different 

partial loads and full load based on usage patterns, which provides a 

more representative measure of annual energy use than the EER 

metric.

• DOE is proposing to amend its standards based on the IEER metric. 
14

Energy Efficiency Descriptor – Heating Efficiency

• The current standards for air-cooled CUHP heating efficiency are based 

on the COP metric.

• DOE is not aware of any test procedures that have been developed that 

measure part load performance in heating mode for air-cooled CUHP. 

• DOE is not aware of any data regarding the annual usage for CUHP 

under part-load heating conditions to determine whether part-load 

heating hours are significant or of data that would reveal usage 

patterns to help determine appropriate test conditions under partial 

loads. 

• DOE is proposing standards for the heating efficiency based on the COP 

metric.
15

The Proposed Standard

Equipment Class Heating Type Baseline TSL 1 TSL 2 TSL 3 TSL 4

Small Commercial Packaged Air 

Conditioners and Heat Pump (AirCooled)–

≥65,000 Btu/h and <135,000 

Btu/h Cooling Capacity

AC

Electric Resistance 

Heating or No Heating

11.4 IEER 12.9 IEER 14 IEER 14.8 IEER 19.9 IEER

All Other Types of 

Heating

11.2 IEER 12.7 IEER 13.8 IEER 14.6 IEER 19.7 IEER

HP

Electric Resistance 

Heating or No Heating

11.2 IEER

3.3 COP

12.2 IEER

3.3 COP

13.3 IEER

3.4 COP

14.1 IEER

3.5 COP

19.2 IEER

3.7 COP

All Other Types of 

Heating

11.0 IEER

3.3 COP

12 IEER

3.3 COP

13.1 IEER

3.4 COP

13.9 IEER

3.4 COP

19.0 IEER

3.6 COP

Large Commercial Packaged Air 

Conditioners and Heat Pump (AirCooled)–

≥135,000 Btu/h and <240,000 

Btu/h Cooling Capacity

AC

Electric Resistance 

Heating or No Heating

11.2 IEER 12.2 IEER 13.2 IEER 14.2 IEER 18.4 IEER

All Other Types of 

Heating

11.0 IEER 12.0 IEER 13.0 IEER 14.0 IEER 18.2 IEER

HP

Electric Resistance 

Heating or No Heating

10.7 IEER

3.2 COP

11.4 IEER

3.2 COP

12.4 IEER

3.3 COP

13.4 IEER

3.3 COP

17.6 IEER

3.3 COP

All Other Types of 

Heating

10.5 IEER

3.2 COP

11.2 IEER

3.2 COP

12.2 IEER

3.3 COP

13.2 IEER

3.3 COP

17.4 IEER

3.3 COP

Very Large Commercial Packaged 

Air Conditioners and Heat Pump 

(Air-Cooled)–

≥240,000 Btu/h and <760,000 

Btu/h Cooling Capacity

AC

Electric Resistance 

Heating or No Heating

10.1 IEER 11.6 IEER 12.5 IEER 13.5 IEER 15.5 IEER

All Other Types of 

Heating

9.9 IEER 11.4 IEER 12.3 IEER 13.3 IEER 15.3 IEER

HP

Electric Resistance 

Heating or No Heating

9.6 IEER

3.2 COP

10.6 IEER

3.2 COP

11.5 IEER

3.2 COP

12.5 IEER

3.2 COP

14.5 IEER

3.2 COP

All Other Types of 

Heating

9.4 IEER

3.2 COP

10.4 IEER

3.2 COP

11.3 IEER

3.2 COP

12.3 IEER

3.2 COP

14.3 IEER

3.2 COP
16

Rationale for Adopting the Proposed Standard

EPCA directs DOE to consider seven factors when setting energy conservation 

standards. (42 U.S.C. 6313(a)(6)(B))

TSL Benefits Burdens

3

• Energy savings: 11.8 quads

• Environmental savings (CO2

Savings: 1085 million metric tons)

• NPV (2013$) at a 7% discount rate: 

$16.5 billion

• Positive mean LCC savings for all 

equipment classes

• Industry Conversion Costs total $226.4 million 

over 4 years

• Up to a loss of 24.7% of industry net present 

value
17

Sample Market Plot of CUACs with Proposed Level

IEERs and TSLs for CUAC with Other Types of Heating 

Proposed Standard (TSL3)

Addendum CL (TSL1)

ASHRAE 90.1-2010 (Baseline)
18

Request for Comment

Issue 1: DOE seeks comment on the use of the IEER as the 

cooling efficiency metric and COP as the heating efficiency 

metric (for CUHP) for the proposed energy conservation 

standards, including additional data and input regarding the 

uncertainty of IEER test measurements. 
19

Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
20

Market Assessment: Equipment Classes

• The proposed energy conservation standards would apply to small, 

large, and very large, air-cooled CUAC and CUHP as defined under 

section 342(a) of EPCA. 

– This category of equipment has a rated cooling capacity between 

65,000 Btu/h and 760,000 Btu/h. 

• The current equipment classes established by EPACT 2005 divide 

this equipment into twelve classes characterized by rated cooling 

capacity, equipment type (air conditioner versus heat pump), and 

heating type.

• DOE is proposing standards based on the existing equipment class 

structure.
21

Equipment Classes

Equipment Type Cooling Capacity Sub-Category Heating Type

Small Commercial 

Packaged Air-Conditioning 

and Heating Equipment 

(Air-Cooled)

≥65,000 Btu/h and 

<135,000 Btu/h

AC

Electric Resistance Heating or No Heating

All Other Types of Heating

HP

Electric Resistance Heating or No Heating

All Other Types of Heating

Large Commercial 

Packaged Air-Conditioning 

and Heating Equipment 

(Air-Cooled)

≥135,000 Btu/h and 

<240,000 Btu/h

AC

Electric Resistance Heating or No Heating

All Other Types of Heating

HP

Electric Resistance Heating or No Heating

All Other Types of Heating

Very Large Commercial 

Packaged Air-Conditioning 

and Heating Equipment 

(Air-Cooled)

≥240,000 Btu/h and 

<760,000 Btu/h

AC

Electric Resistance Heating or No Heating

All Other Types of Heating

HP

Electric Resistance Heating or No Heating

All Other Types of Heating
22

Request for Comment

Issue 3: DOE requests comments and detailed information 

regarding any design features that DOE should consider for 

establishing separate equipment classes in this rulemaking. 

DOE requests that such information provide test data 

illustrating the additional challenges faced by models having 

such design features and a discussion of the customer utility 

aspects of the design feature. In particular, DOE requests 

detailed comments regarding the definition of such 

equipment classes, and any detailed information, such as test 

data, test conditions, key component design details, as well 

as other relevant information (e.g., fan power consumption) 

that may help DOE evaluate potential alternative equipment 

class standard levels. 
23

Technology Assessment: Purpose

• Purpose

– To develop a preliminary list of technology options that could improve 

the efficiency of air-cooled CUAC and CUHP.

– This list is examined in greater detail, and inappropriate technologies 

removed, in subsequent analyses. 

• Method

– DOE identified technology options:

• Technical support documents from previous rulemakings

• Literature review and manufacturer specification sheets 

• Equipment teardowns

• Comments and input from interested parties

• The full list of technologies that DOE identified can be found in 

Chapter 3 of the TSD.
24

Commercial Rooftop Challenge - Daikin McQuay Rebel

The appliance standards program utilized the expertise gained by working with industry in 

the commercial rooftop challenge in its analysis.

“With industry-best efficiencies up to 20.6 IEER, Rebel delivers unprecedented energy 

savings of 60-70% above ASHRAE’s 90.1 efficiency standard, allowing for complete system 

payback in as little as two years.”

http://www.daikinmcquay.com/mcquaybiz/DocumentStorage/RooftopSystems/Brochures/Rebel6pg_final.pdf
25

Commercial Rooftop Challenge Cont’d - Carrier WeatherExpertTM

“As an innovator and market leader, Carrier embraced the RTU Challenge and committed to the 

energy savings initiative more broadly with its entire line of WeatherExpert models ranging from 3-

to 23-ton units reaching a high-IEER rating of 21.0, making the WeatherExpert one of the most 

efficient packaged rooftop units available.”

http://www.carrier.com/carrier/en/br/news/news-article/carrier__weatherexpert__rises_to_department_of_energy_challenge_reaching_20_8_ieer_rating.aspx
26

Screening Analysis: Purpose

• Purpose

– To determine which technology options will be considered in 

downstream analyses.

• Technology options are “screened out” if they

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to customers

– Have adverse impacts on health or safety

• Screened-Out Technologies:

– Electro-hydrodynamic enhanced heat transfer

– Alternative refrigerants

– Sub-coolers

• The screened-in design options are listed in the engineering 

section.
27

Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
28

Engineering Analysis

• In the Engineering Analysis, DOE characterizes the relationship 

between manufacturer cost and energy efficiency.

Downstream Analyses

• Life-Cycle Cost and 

Payback Period Analysis

• National Impacts 

Analysis

• Shipments Analysis

• Manufacturer Impact 

Analysis

Output: Cost – Efficiency 

Relationship

Incremental 

Manufacturing Cost

Energy Efficiency
29

Engineering Analysis: Design Options

Design Options

Condenser and evaporator fan and fan motor improvements:

• Larger fan diameters

• More efficient fan blades (e.g., air foil centrifugal evaporator fans, backward-curved centrifugal 

evaporator fans, high efficiency propeller condenser fans)

• High efficiency motors (e.g., copper rotor motor, high efficiency induction, permanent magnet, 

electronically commutated)

• Variable speed fans/motors

Larger heat exchangers

Compressor Improvements

• High efficiency compressors

• Multiple compressor staging

• Multiple-tandem or variable-capacity compressors

Thermostatic expansion valves

Electronic expansion valves

Reduced indoor fan belt loss:

• Synchronous (toothed) belt

• Direct-drive fans
30

Request for Comment

Issue 4: DOE requests comment and data regarding additional 

design options or variants of the considered design options that 

can increase the range of considered efficiency improvements, 

including design options that may not yet be found on the 

market. 
31

Engineering Analysis: Methodology

Identify Representative 

Equipment

Develop Baseline

Identify and Model 

Design Options

Calculate Costs

Generate CostEfficiency Curves







Choose representative equipment classes and capacities, based 

primarily on their high market volumes, to streamline analysis.

Establish baseline specifications for each equipment class and 

calibrate energy model. 

Identify design options for increasing equipment efficiency and 

use energy modeling to determine IEER efficiency impact. 

Conduct teardown and cost modeling analysis for 

representative equipment and design options at the efficiency 

levels identified.

Generate cost-efficiency curves, which account for full 

manufacturer production costs (MPCs).




32

Representative Equipment

• DOE first selected representative equipment classes for which to 

conduct the full engineering analysis.

• DOE analyzed three specific capacities to represent each of the 

three cooling capacity categories (small, large, and very large).

• These equipment classes and cooling capacities were selected 

based on a review of equipment offerings and information obtained 

from manufacturer interviews.

Representative Equipment Classes Representative Cooling Capacity

Small Air-Cooled CUAC, ≥65,000 Btu/h and 

<135,000 Btu/h cooling capacity, electric 

resistance heating or no heating.

90,000 Btu/h (7.5 tons)

Large Air-Cooled CUAC, ≥135,000 Btu/h and 

<240,000 Btu/h cooling capacity, electric 

resistance heating or no heating.

180,000 Btu/h (15 tons)

Very Large Air-Cooled CUAC, ≥240,000 Btu/h 

and <760,000 Btu/h cooling capacity, electric 

resistance heating or no heating.

360,000 Btu/h (30 tons)
33

Baseline Efficiency Levels

• DOE is typically obligated either to adopt the standards developed 

by ASHRAE or to adopt more stringent levels if there is clear and 

convincing evidence in support of doing so.

– ASHRAE Standard 90.1–2010 specifies minimum efficiency 

requirements using both EER and IEER. 

• DOE evaluated the relationship between EER and IEER for models 

rated at the current DOE standard levels (EER) and analyzed the 

distribution of corresponding rated IEER values.

– Lowest IEER values generally correspond with the ASHRAE Standard 

90.1–2010 minimum efficiency requirements.

• DOE proposes to use the ASHRAE Standard 90.1–2010 minimum 

IEER requirements to characterize the baseline cooling efficiency for 

each equipment class. 

• For CUHPs, DOE proposes to use the current COP standard levels to 

characterize the baseline heating efficiency for each equipment 

class.
34

Baseline Efficiency Levels

Equipment Type Heating Type Baseline 

Efficiency Level

Small Commercial 

Packaged AC and HP (AirCooled) – ≥65,000 Btu/h 

and <135,000 Btu/h 

Cooling Capacity

AC

Electric Resistance Heating or No Heating 11.4 IEER

All Other Types of Heating 11.2 IEER

HP

Electric Resistance Heating or No Heating 11.2 IEER

3.3 COP

All Other Types of Heating 11.0 IEER

3.3 COP

Large Commercial 

Packaged AC and HP (AirCooled) – ≥135,000 Btu/h 

and <240,000 Btu/h 

Cooling Capacity

AC

Electric Resistance Heating or No Heating 11.2 IEER

All Other Types of Heating 11.0 IEER

HP

Electric Resistance Heating or No Heating 10.7 IEER

3.2 COP

All Other Types of Heating 10.5 IEER

3.2 COP

Very Large Commercial 

Packaged AC and HP (AirCooled) – ≥240,000 Btu/h 

and <760,000 Btu/h 

Cooling Capacity

AC

Electric Resistance Heating or No Heating 10.1 IEER

All Other Types of Heating 9.9 IEER

HP

Electric Resistance Heating or No Heating 9.6 IEER

3.2 COP

All Other Types of Heating 9.4 IEER

3.2 COP
35

Incremental Efficiency Levels

• DOE established incremental efficiency levels (ELs) based on a 

review of industry standards and available equipment.

• EL 1 is based on the draft of addendum CL to ASHRAE Standard 

90.1–2010.

• Higher ELs for CUACs with electric resistance heating or no heating:

– Range of ELs associated with equipment listed in the AHRI certification 

database and the California Energy Commission’s (CEC) database.

– DOE evaluated the full range of capacities for the small, large, and very 

large equipment classes with a specific focus on 7.5-ton, 15-ton, and 

30-ton as the representative cooling capacities.

• Higher ELs for CUACs with all other types of heating:

– DOE adopted the same trend of heating-type IEER drop vs. electric/noheat IEER used in Draft Addendum CL: 0.2 IEER.

– DOE believes these decreases in IEER appropriately reflect the 

additional power required for furnace pressure drop. 
36

• Higher cooling ELs for CUHP equipment classes:

– DOE adopted the same trend of heat pump IEER drop vs. electric/noheat IEER used in Draft Addendum CL: ranging from 0.2 to 1.0 IEER.

– DOE believes these decreases in IEER are representative of the 

efficiency differences that occur due to losses from the reversing valve 

and coil circuitry required in heat pumps for both heating and cooling 

operation.

• Maximum-available ELs rely on the performance of recently 

introduced models. 

– DOE evaluated available equipment literature and energy use 

information on these maximum-available efficiency models.

– Conducted energy modeling to determine the feasibility of achieving 

these efficiency levels.

Incremental Efficiency Levels
37

• For CUHP equipment classes heating efficiency levels, the 

correlations between COP and EER were used to justify DOE’s prior 

final rule adopting ASHRAE 90.1 levels.

• Because this method was generally accepted by industry and 

interested parties, DOE considered a similar approach for proposing 

heating efficiency levels based on the variation of COP with IEER. 

– DOE evaluated AHRI and CEC data for air-cooled CUHP units with 

electric resistance heat or no heat to analyze the relationship between 

COP and both IEER and EER. 

– The correlations between COP and IEER using linear regressions are no 

less strong than the correlations between COP and EER for each 

capacity range. 

– DOE observed only a small variation in COP from baseline to max-tech.

Incremental Efficiency Levels
38

• DOE is proposing to use the functions relating COP to IEER based on 

AHRI and CEC data to establish COP efficiency levels. 

– For each CUHP equipment class, DOE selected COP levels 

corresponding to each incremental IEER level. 

– Details of this analysis are presented in Chapter 5 of the TSD.

Incremental Efficiency Levels
39

Incremental Efficiency Levels

Equipment Type Heating Type

Efficiency Levels

Baseline EL1 EL2 EL3 EL4 (max 

tech)

Small Commercial 

Packaged AC and 

HP (Air-Cooled) –

≥65,000 Btu/h and 

<135,000 Btu/h 

Cooling Capacity

AC

Electric Resistance 

Heating or No Heating 11.4 IEER 12.9 IEER 14 IEER 14.8 IEER 19.9 IEER

All Other Types of 

Heating 11.2 IEER 12.7 IEER 13.8 IEER 14.6 IEER 19.7 IEER

HP

Electric Resistance 

Heating or No Heating

11.2 IEER

3.3 COP

12.2 IEER

3.3 COP

13.3 IEER

3.4 COP

14.1 IEER

3.5 COP

19.2 IEER

3.7 COP

All Other Types of 

Heating

11.0 IEER

3.3 COP

12 IEER

3.3 COP

13.1 IEER

3.4 COP

13.9 IEER

3.4 COP

19.0 IEER

3.6 COP

Large Commercial 

Packaged AC and 

HP (Air-Cooled) – 

≥135,000 Btu/h and 

<240,000 Btu/h 

Cooling Capacity

AC

Electric Resistance 

Heating or No Heating 11.2 IEER 12.2 IEER 13.2 IEER 14.2 IEER 18.4 IEER

All Other Types of 

Heating 11.0 IEER 12.0 IEER 13.0 IEER 14.0 IEER 18.2 IEER

HP

Electric Resistance 

Heating or No Heating

10.7 IEER

3.2 COP

11.4 IEER

3.2 COP

12.4 IEER

3.3 COP

13.4 IEER

3.3 COP

17.6 IEER

3.3 COP

All Other Types of 

Heating

10.5 IEER

3.2 COP

11.2 IEER

3.2 COP

12.2 IEER

3.3 COP

13.2 IEER

3.3 COP

17.4 IEER

3.3 COP
40

Incremental Efficiency Levels

Equipment Type Heating Type

Efficiency Levels

Baseline EL1 EL2 EL3 EL4 (max 

tech)

Very Large 

Commercial 

Packaged AC and 

HP (Air-Cooled) –

≥240,000 Btu/h and 

<760,000 Btu/h 

Cooling Capacity

AC

Electric Resistance 

Heating or No Heating 10.1 IEER 11.6 IEER 12.5 IEER 13.5 IEER 15.5 IEER

All Other Types of 

Heating 9.9 IEER 11.4 IEER 12.3 IEER 13.3 IEER 15.3 IEER

HP

Electric Resistance 

Heating or No Heating

9.6 IEER

3.2 COP

10.6 IEER

3.2 COP

11.5 IEER

3.2 COP

12.5 IEER

3.2 COP

14.5 IEER

3.2 COP

All Other Types of 

Heating

9.4 IEER

3.2 COP

10.4 IEER

3.2 COP

11.3 IEER

3.2 COP

12.3 IEER

3.2 COP

14.3 IEER

3.2 COP
41

Request for Comment

Issue 5: DOE requests comment on the incremental and maxtech ELs identified for the analyses, including whether the ELs 

identified by DOE can be achieved using the technologies 

screened-in during the screening analysis, and whether higher 

efficiencies are achievable using technologies that were 

screened-in during the screening analysis. 
42

Equipment Testing, Teardown, and Energy Modeling

• DOE selected 8 representative test units for the engineering 

analysis:

– Conducted testing according to the IEER test method specified in AHRI 

Standard 340/360–2007 at a third party laboratory.

– Conducted physical reverse-engineering teardowns on each test unit 

to develop a manufacturing cost model and to evaluate key design 

features (e.g., heat exchangers, compressors, fans/fan motors, control 

strategies, etc.)

• Supplemented these data by conducting virtual teardowns using 

catalog specifications on models spanning the full range of 

capacities from all manufacturers to verify cost-efficiency estimates.

• Used information from test results and equipment teardowns to 

conduct energy modeling for CUACs.
43

Energy Modeling

• DOE used the modeling tools developed by the Center for 

Environmental Energy Engineering from the University of Maryland 

at College Park to calculate cooling capacity and compressor power 

consumption at different operating conditions.

• The tools include a detailed heat exchanger modeling program 

(CoilDesigner) and a refrigeration cycle modeling program (VapCyc). 

– The refrigeration cycle model integrates the heat exchanger and compressor 

models to construct a refrigeration cycle model.

• Power consumption of fans and controls based on power 

measurements and information available in product literature. 

• Energy Modeling Validation:

– Applied the key design features identified during physical equipment 

teardowns.

– Generated detailed performance data (e.g. capacity and EER) for one test unit 

in each capacity range class (small, large, and very large) and validated them 

against the results obtained from laboratory testing at each IEER capacity level 

or with the published performance data. 

– Modeled performance data was within 5% of the tested value for each test 

unit.
44

Energy Modeling

• DOE expanded the modeling tasks with various system design 

options and identified the key design features required for 7.5-ton, 

15-ton, and 30-ton air-cooled CUAC units with electric resistance 

heating or no heating to achieve each efficiency level. 

– In some cases the models were developed to represent designs of 

specific equipment models that are available for sale or that were 

tested and reverse-engineered.

– In other cases, the models represented modifications of these designs 

based on consideration of alternative design options, but still 

consistent in general with equipment available on the market.

• DOE used the model to generate energy use profiles for air-cooled 

CUACs to serve as inputs for the energy use analysis.

– Included wattage inputs for key components (i.e., compressor, indoor 

and outdoor fan motors, and controls) at each operating load level 

measured for the IEER test method, for each efficiency level.
45

Energy Modeling

• DOE used these design features developed by the energy modeling 

to determine the incremental manufacturing costs for each 

efficiency level for 7.5-ton, 15-ton and 30-ton air-cooled CUAC 

units.

Issue 6: DOE requests comments, information, and data that 

would inform adjustment of energy modeling input and/or 

results that would allow more accurate representation of the 

energy use impacts of design options using the modeling tools 

developed by the Center for Environmental Energy Engineering 

from the University of Maryland College Park.
46

Manufacturing Cost Model

Manufacturing cost models were developed by DOE as part of the reverseengineering approach.

Raw 

Materials

Finished 

Materials

Purchased 

Parts

Physical 

Teardown

Selection of 

Units

Fabrication 

Processes

Bill of Materials

Assembly 

Processes

Manufacturing 

Cost

• Bills of material were generated during 

the equipment teardown analysis and 

entered into the cost model.

• Cost model generated manufacturing, 

material, labor, and overhead costs.

• Physical teardown analysis conducted 

with representative equipment.

• Manufacturer interviews conducted to 

further refine the analytical inputs and 

the results generated by the cost 

model.
47

Manufacturing Cost Model

Structure/Classification of Manufacturing Costs

Full Manufacturer Selling 

Price (MSP)

Non-Production Cost **

Selling General & 

Admin. R & D Interest

Full Manufacturing Production Cost (MPC)*

Direct Labor Direct 

Material Overhead

Indirect labor

Indirect material

Maintenance

Depreciation

Taxes

Insurance related 

to assets

Market research

Advertising

POS promotion

Sales person 

compensation & 

travel

Logistics

- Warehousing

- Delivery

- Record keeping

Costs of 

service & 

staff units

General 

corporate 

costs –

comp., etc.

Costs 

associated with 

efforts to find 

new or 

improved 

equipment or 

production 

processes

Costs of 

borrowing 

funds

* Tax Reform Act of 1986 essentially requires companies to measure cost of goods sold as the full production cost of the goods sold.

** In a company’s income statement, many of these costs are reported as a lump sum, under SG&A expenses. 
48

Manufacturer Interviews

• DOE requested interviews with CUAC and CUHP manufacturers to 

develop a deeper understanding of the various combinations of 

technologies used to increase equipment efficiency, and their 

associated manufacturing costs.

– DOE conducted interviews with 7 CUAC and CUHP manufacturers.

• As part of the interviews, DOE sought feedback on the proposed 

efficiency levels, design options, inputs for the energy and 

manufacturing cost models, and resulting manufacturing costs 

generated from the reverse-engineering analyses.

• DOE also sought to better understand the impact that the proposed 

standard levels would have on manufacturers businesses (e.g., the 

size and nature of capital expenditures).

• DOE refined its analysis based on all data and feedback provided to 

date.
49

Cost-Efficiency Results

• Based on these analyses, DOE generated cost-efficiency results for 

each cooling capacity range. 

– Incremental manufacturing costs are expected to be equivalent for 

each of the equipment classes within a given cooling capacity range 

(e.g., the analysis for electric resistance/no heating AC units would 

apply to the other heating and/or HP units of the capacity range).

• Small Commercial Packaged AC and HP (Air-Cooled):

Efficiency Level

Incremental Costs ($2013)

MPC Shipping

Baseline - -

EL 1 $115.93 $0

EL 2 $583.47 $0

EL 3 $788.88 $0

EL 4 (Max-Tech) $1,277.04 $102.86
50

Cost-Efficiency Results

• Large Commercial Packaged AC and HP (Air-Cooled):

• Very Large Commercial Packaged AC and HP (Air-Cooled):

Efficiency Level

Incremental Costs ($2013)

MPC Shipping

Baseline - -

EL 1 $419.16 $0

EL 2 $792.76 $192.86

EL 3 $1,236.98 $192.86

EL 4 (Max-Tech) $1,554.26 $192.86

Efficiency Level

Incremental Costs ($2013)

MPC Shipping

Baseline - -

EL 1 $542.65 $0

EL 2 $1,296.41 $0

EL 3 $1,834.67 $0

EL 4 (Max-Tech) $2,753.32 $444.00
51

Request for Comment

Issue 7: Input and data on the estimated incremental 

manufacturing costs, including the extrapolation of incremental 

costs for equipment classes not fully analyzed, in particular for 

heat pump equipment classes.
52

Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
53

Energy Use Analysis

Purpose

• Determine annual energy use (UEC) of CUACs at the considered 

efficiency levels to find annual energy costs and savings.

• Annual energy costs are inputs to Life-Cycle Cost and Payback Period 

Analysis.

Method

• Utilized building simulation analysis results from prior DOE analysis of 

CUAC energy efficiency standards (2004).

• CUAC cooling and ventilation energy use derived by applying detailed 

equipment performance data to the simulated hourly time series of 

cooling load and fan operation.

• Created a generalized building sample to capture the energy use of 

CUACs in buildings since 1996.
54

Energy Use Analysis: Modeling of CUAC equipment

• Utilized building simulation analysis results from prior DOE 

analysis of CUAC energy efficiency standards (2004)

– Simulations performed on buildings from Energy Information 

Administration (EIA) Commercial Building Energy Consumption Survey 

(CBECS), 1995.

– 1033 buildings utilizing package rooftop air conditioners were modeled.

– Simulations provided “8760-hour” cooling load and fan operating hour 

profiles for air-conditioning and ventilation for CUACs at various EER 

levels.

– The 11 EER CUAC simulations were used to represent equipment 

performance for the baseline IEER levels: 7-5-ton: 11.4 IEER; 15-ton: 11.2 

IEER 30-ton: 10.1 IEER.

– The 11 EER simulations were chosen as they most closely represented 

equipment performance at current standard levels.
55

Energy Use Analysis: Modeling of CUAC equipment

• DOE derived CUAC cooling and ventilation energy use by 

applying detailed equipment performance data to the 

simulated hourly time series of cooling load and fan operation

– AHRI 340/360 defines the required performance data and rating conditions to 

define the test procedure energy use for 7.5-ton, 15-ton, and 30-ton CUACs

– Outdoor rating conditions are 95, 81.5, 68, and 65 °F

– For each of the 1033 buildings, the outdoor temperature was obtained from the 

TMY2 (Typical Meteorological Year) weather file used in the original simulations

– The temperature data were adjusted to account for changes between TMY2 

(1995) and the more recent TMY3 edition (2008)
56

Energy Use Analysis: Modeling of CUAC equipment

• Energy use calculations are based on equations for the net capacity (BTU/hr), 

compressor power (W), condenser fan power (W), indoor fan power (W) and 

control power (W) at each IEER level.

• The net capacity and compressor power are linear functions of the exterior 

dry-bulb temperature.

• Indoor fan power is also a function of dry-bulb temperature for higher 

temperature conditions.

• The engineering analysis provides these fields for the baseline and each 

efficiency level at the rating conditions.

• DOE used linear interpolation to develop more general equations as a 

function of outdoor dry bulb temperature. 

• The linear equations, and the TMY2 temperature time series for each 

simulated building, were used to determine the energy consumption of each 

component for each hour of the year.
57

Energy Use Analysis: Results of Modeling CUAC equipment

• Summing up hourly component power use over “8760-hour” load profile 

provides annual use for the baseline and each efficiency level for each building 

in the set of the 1033 building sample.

1000

10000

100000

1000000

10000000

Building Energy Use for Cooling (kWh/yr)

Building ID (from highest to lowest energy use)

Baseline

EL 1

EL 2

EL 3

EL 4

1000

10000

100000

1000000

10000000

Building Fan Energy Use (kWh/yr)

Building ID (from highest to lowest energy use)

Baseline

EL 1

EL 2

EL 3

EL 4

15-ton CUAC cooling energy use 15-ton CUAC fan energy use

• For 15-ton CUAC equipment:

– Baseline: Weighted-average cooling energy use = 15,005 kWh/yr; fan energy use = 11,955 kWh/yr.

– EL 2: Weighted-average cooling energy savings = 7,845 kWh/yr; fan energy savings = 6,645 kWh/yr. 
58

Energy Use Analysis: Generalized Building Sample

• DOE developed a generalized building sample to define the population of 

buildings that use CUAC equipment in 2014.

• The generalized building sample serves as the customer sample that is 

provided to the Life-Cycle Cost (LCC) and Payback Period (PBP) analysis.

• The generalized building sample is an estimate of the total commercial 

building floor space that uses CUAC as a function of four characteristics: 

building activity, size, vintage, and location.

• These characteristics are the primary source of variability in cooling energy 

use and operating costs.

• The floor space estimate is used to define the relative weights of each 

generalized building in the customer sample.

– For example, if large offices in region 1, vintage 1981-1999 are 3.5% of total floor 

space, then generalized buildings of this type constitute 3.5% of the customer 

sample.

• The results from the simulation data for the individual buildings in the 

sample of 1033 were averaged to create load profiles for each generalized 

building.
59

Energy Use Analysis: Generalized Building Sample

• The region in which the building is located affects both the cooling loads and the 

price of electricity. 

• The building activity affects building schedules and occupancy, which in turn 

influence the cooling and internal loads. 

• The building size influences the price of electricity because larger facilities tend to 

have lower marginal prices. 

• The building vintage influences shell characteristics that can affect cooling loads. 

– The energy use for building vintages after 2004 was adjusted using scaling factors for 

cooling loads taken from the Annual Energy Outlook commercial demand module
60

Energy Use Analysis: Results

• Cooling and Fan energy use were developed for the CUAC units for each 

generalized building in the sample; weighted averages shown below:

Region EL IEER

Cooling Fan Total Cooling Fan Total Cooling Fan Total

kWh/ton kWh/ton kWh/ton kWh/sq.ft. kWh/sq.ft. kWh/sq.ft. kWh/unit kWh/unit kWh/unit

U.S. Base 11.2 1,000 523 1,523 2.7 1.4 4.2 15,005 7,845 22,850

U.S. 1 12.2 919 477 1,396 2.5 1.3 3.8 13,785 7,151 20,936

U.S. 2 13.2 797 443 1,240 2.2 1.2 3.4 11,955 6,645 18,600

U.S. 3 14.2 881 222 1,102 2.4 0.6 3.0 13,212 3,324 16,536

U.S. 4 18.4 594 231 825 1.6 0.6 2.3 8,916 3,463 12,379

Warm Base 11.2 1,186 512 1,698 3.5 1.5 5.1 17,784 7,679 25,463

Warm 1 12.2 1,093 467 1,559 3.3 1.4 4.7 16,389 6,999 23,389

Warm 2 13.2 960 434 1,394 2.9 1.3 4.2 14,402 6,511 20,914

Warm 3 14.2 1,034 223 1,257 3.1 0.7 3.8 15,514 3,346 18,860

Warm 4 18.4 731 242 972 2.2 0.7 2.9 10,960 3,624 14,584

Cool Base 11.2 848 532 1,380 2.1 1.3 3.5 12,718 7,982 20,700

Cool 1 12.2 776 485 1,261 2.0 1.2 3.2 11,643 7,276 18,918

Cool 2 13.2 663 450 1,113 1.7 1.1 2.8 9,941 6,755 16,696

Cool 3 14.2 755 220 975 1.9 0.6 2.5 11,318 3,306 14,624

Cool 4 18.4 482 222 704 1.2 0.6 1.8 7,234 3,331 10,565

15-ton CUAC Average Cooling and Fan Energy Use 
61

Request for Comment

Issue 9: DOE requests comments on the use of a ‘‘generalized 

building sample’’ to characterize the energy consumption of 

CUAC equipment in the commercial building stock. Specifically, 

whether there are any data or information that could improve 

the method for translating the results from the 1,033 simulated 

buildings to the generalized building sample.
62

Markups Analysis

Purpose

• Determine customer prices based on manufacturer’s selling price for 

baseline and higher efficiency equipment

• Characterize CUAC and CUHP distribution channels

Method

• Analyze company direct costs, expenses, and profits

– Manufacturers: 2006-2011 SEC 10-K Reports

– Wholesalers: HARDI 2012 Profit Report

– Mechanical Contractors: ACCA 1995 Financial Analysis for the HVACR Contracting Industry 

and U.S. Census Bureau, 2007 Plumbing, Heating, and Air-Conditioning Contractors 

– General Contractors: U.S. Census Bureau, 2007 Commercial and Institutional Building 

Construction

– Sales Taxes: The Sales Tax Clearinghouse

Manufacturer National Account Consumer

Wholesaler

Small 

Mechanical 

Contractor General 

Contractor

Consumer

Manufacturer

Large

Mechanical 

Contractor General 

Contractor

Consumer

Manufacturer National Account Consumer

Wholesaler

Small 

Mechanical 

Contractor Consumer

Manufacturer

Large

Mechanical 

Contractor

Consumer

New Construction Replacements
63

Markups Analysis Markups Analysis: Markup Types

• Baseline Markups

– Relate the MSP of baseline equipment to the customer purchase 

price.

– Indicate a customer price that covers the wholesaler’s expenses plus 

profit.

• Incremental Markups

– Relate the increase in MSP of more efficient equipment to the 

increase in customer purchase price. 

– Cover only expenses that vary with MSP, in this case, expenses that 

increase due to an efficiency standard.

• DOE applies baseline markups to the MSP of the baseline level, and 

the incremental markups to the incremental difference in MSP at

each level above the baseline.
64

Markups Analysis: Distribution Channels

Distribution Channel Share of Market

New Construction, Small Mechanical Contractor 10.0%

New Construction, Large Mechanical Contractor 6.5%

New Construction, National Account 3.5%

Replacement, Small Mechanical Contractor 40.0%

Replacement, Large Mechanical Contractor 26.0%

Replacement, National Account 14.0%

The CUAC and CUHP market has six primary distribution channels
65

Markups Analysis Markups Analysis: Overall Markups

Distribution Channel

Replacement New Construction

Baseline Incremental Baseline Incremental

Manufacturer* 1.34 1.34 1.34 1.34

Wholesaler 1.36 1.10 1.36 1.10

Mechanical Contractor (large/small) 1.38 / 1.58 1.10 / 1.26 1.30 / 1.50 1.04 / 1.20

General Contractor -- -- 1.31 1.20

Sales Tax 1.07 1.07 -- --

Overall (large/small contractor) 2.68 / 3.08 1.75 / 2.00 3.10 / 3.58 1.84 / 2.12

National Account** 1.96 1.42 2.20 1.50

* Markup is for large equipment class (135-240 kBtu/h); markup varies by 

equipment class (lower for small and higher for very large)

**National account markup is one-half of that of the overall markup for the 

corresponding distribution channel
66

Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
67

Life-Cycle Cost (LCC) and Payback Period (PBP) Analysis

Purpose

• Provide an economic evaluation from the consumer’s perspective.

• Life-Cycle Cost (LCC) is the total consumer cost over the life of the 

equipment. 

• Payback Period (PBP) is the time required to recover the increased 

purchase price of more energy-efficient equipment through reduced 

operating costs.

Method

• Use consumer samples developed in the energy use analysis.

• Determine total installed costs for each efficiency level (EL).

• Determine first-year and equipment lifetime operating costs.

• Calculate PBP by dividing average increase in installed cost by average 

decrease in first-year operating cost.

• Calculate LCC by adding installed cost and lifetime operating costs.

• Calculate LCC savings by subtracting LCC of each EL from LCC of the EL 

that customer would purchase in the absence of a new standard.
68

• Consumer samples were based on the generalized building sample 

developed in the energy use analysis for each of the three CUAC 

equipment classes.

• Each consumer has a unique energy use and energy price.

• Other inputs (e.g. discount rates and lifetimes) are characterized by 

probability distributions.

• Monte Carlo sampling was used to create a consumer list with 

variable values for these inputs.

LCC and PBP Analysis: Consumer Sample
69

LCC and PBP Analysis: Total Installed Cost

• Total Installed Cost is the sum of equipment price and installation 

cost.

• Equipment price provided by Markups Analysis.

• Constant real prices used to project CUAC and CUHP equipment 

prices.

- Producer Price Index (PPI) series for “unitary air-conditioners, except heat 

pumps” spanning 1978 to 2013 was analyzed to forecast future 

equipment prices; no discernable long-term declining trend.

• Installation costs represent the labor and materials necessary to 

install the equipment

• Costs based on RS Means.

• Installation costs are assumed to increase proportionally with 

equipment weight, which increases with efficiency level. Therefore 

installation costs are assumed to vary by efficiency level.
70

• Annual energy savings provided by Energy Use Analysis.

• Electric utility tariff data used to develop average and marginal electricity prices.

– Average electricity prices and marginal energy and demand prices developed for nine 

Census Divisions and California.

– Baseline energy bill determined by multiplying energy consumption by average price.

– Energy bill savings determined by multiplying energy savings by marginal energy price 

and demand reduction by demand price.

• DOE used Annual Energy Outlook (AEO) 2013 for projections of future average 

energy prices for each census division.

LCC and PBP Analysis: Annual Energy Cost

Region

Average Electricity

Price ¢/kwh

Marginal Demand

Price $/kW

Marginal Consumption

Price ¢/kwh

annual summer winter annual summer winter annual summer winter

New England 14.91 15.56 14.22 12.14 13.96 10.85 9.64 9.75 9.47

Mid-Atlantic 15.27 15.92 14.59 12.69 13.77 11.87 9.27 9.58 9.00

East North Central 12.36 12.59 12.00 12.54 13.25 12.00 6.28 6.36 6.18

West North Central 7.80 8.30 7.41 5.55 6.33 4.98 5.53 5.86 5.28

South Atlantic 10.16 10.10 10.12 7.94 8.17 7.79 7.03 7.00 7.02

East South Central 8.46 8.11 8.73 6.90 7.25 6.67 5.72 5.58 5.80

West South Central 7.65 8.25 6.97 3.92 4.38 3.57 5.87 6.44 5.20

Mountain 10.35 10.35 10.25 7.87 8.04 7.72 7.12 7.12 7.11

Pacific – WA,OR 6.93 7.01 6.84 2.59 2.59 2.58 5.51 5.50 5.51

Pacific – CA 16.41 17.50 15.28 6.80 9.36 4.49 12.15 12.35 11.77

US Average 11.17 11.52 10.75 8.33 9.11 7.71 7.34 7.53 7.12
71

• Maintenance costs represent the labor and materials necessary to 

maintain the equipment

– Costs based on RS Means.

– Maintenance costs do not increase with efficiency of the equipment.

• Repair costs are associated with repairing or replacing components that 

have failed.

– Routine repairs were included in maintenance costs.

– One-time cost for major repair (for compressor replacement) included 

as part of the repair vs. replacement decision in the Shipments 

Analysis.

LCC and PBP Analysis: Maintenance and Repair Costs
72

Request for Comment

Issue 10: DOE requests comments on the use of RS Means cost 

data to develop maintenance, repair, and installation costs for 

CUAC and CUHP equipment. If not appropriate, DOE requests 

information and data that can be used to estimate these costs.
73

• ASHRAE database served as source of information for CUAC 

equipment lifetime.

– Included 215 packaged rooftop units listed as in service, with a median 

age of 16 years.

– Five units that had been replaced had a median age of 22 years. 

– Data suggest that median lifetime is longer than 15 years.

• Shipments Model calibration yielded equipment lifetimes based on 

a Weibull probability distribution.

– CUAC: median value = 18.7 years.

– CUHP: median value = 15.4 years.

LCC and PBP Analysis: CUAC and CUHP Equipment Lifetime
74

Request for Comment

Issue 11: DOE requests comments, information and data on the 

equipment lifetimes developed for CUAC and CUHP equipment. 

Specifically, any information that would indicate whether the 

retirement functions yielding median lifetimes of 18.7 years and 

15.4 years for CUAC and CUHP equipment, respectively, are 

reasonable.
75

• Used to convert streams of annual operating expenses to the year of 

purchase (i.e., 2019). 

• Estimated as the weighted average cost of capital using capital asset 

pricing model (CAPM). 

• Damodaran Online is a source of information about company debt and 

equity financing.

– Financial cost of any debt incurred to purchase equipment

– Opportunity cost of any equity to purchase equipment

• Discount rates were estimated for the types of firms on whose premise a 

CUAC or CUHP is located.

– Sectors for which discount rates were developed: Retail, Property Owners, 

Medical Services, Lodging, Food Service, Offices, Industrial, and Public

– Weighed-average real discount rate = 4.66%

LCC and PBP Analysis: Discount Rates
76

• LCC and PBP analysis typically analyzes standard levels relative to a baseline efficiency level.

– Not all consumers purchase products at baseline levels.

• Base case efficiency distributions define the percentage of products being purchased at various 

efficiency levels.

– Consumers already purchasing products at efficiencies greater than or equal to a prospective standard 

level are not impacted by the standard. 

– Allows more accurate estimation of consumer impacts.

• EER market share data from 1999-2001 were used as a basis for the base case distribution. 

– EERs were mapped into IEERs using the same method as the Engineering Analysis.

• Historical IEER market shares and the Shipments model were used to estimate base case 

efficiency in the year of compliance (2019). 

LCC and PBP Analysis: Energy Efficiency in the Base Case

Small CUAC: ≥65,000 Btu/h 

and < 135,000 Btu/h

Large CUAC: ≥135,000 Btu/h 

and < 240,000 Btu/h

Very Large CUAC: ≥240,000 

Btu/h and < 760,000 Btu/h

IEER Market Share IEER Market Share IEER Market Share

11.4 61% 11.2 78% 10.1 63%

12.9 39% 12.2 20% 11.6 24%

14.0 0% 13.2 2% 12.5 7%

14.8 1% 14.2 0% 13.5 4%

19.9 0% 18.4 0% 15.5 1%
77

Request for Comment

Issue 12: DOE requests comments, information and data on the 

base case efficiency distributions of CUAC equipment. Given 

that historical market share efficiency data from 1999–2001 

were used to inform a consumer choice model in the shipments 

analysis to develop estimated base case efficiency distributions 

in the compliance year (2019), DOE seeks more recent historical 

market share efficiency data that would be useful for validating 

the estimated base case efficiency distributions.
78

LCC and PBP Analysis: Results 

Efficiency 

Level IEER

Average Costs 2013$ Simple Payback 

Period

years

Total Installed 

Cost

First Year

Operating Cost

Lifetime 

Operating Cost Life-Cycle Cost

Baseline 11.2 13,212 $2,703 33,014 46,226 -

1 12.2 14,078 $2,508 30,622 44,700 4.4 

2 13.2 15,695 $2,266 27,641 43,336 5.7 

3 14.2 16,548 $2,101 25,597 42,145 5.5 

4 18.4 17,748 $1,690 20,563 38,311 4.5 

Efficiency 

Level IEER

LCC Savings

Average Savings

2013$

Percent of Consumers with 

Net Cost

1 12.2 1,189 1%

2 13.2 2,528 4%

3 14.2 3,713 4%

4 18.4 7,541 2%

15-ton CUAC LCC and PBP Results
79

Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
80

Purpose

• To estimate CUAC and CUHP shipments over the 30-year analysis period 

(2019-2048).

• Shipments are inputs to National Impact Analysis and Manufacturer 

Impact Analysis.

Method

• Develop an equipment stock accounting model which tracks shipments 

for replacements, new construction, and existing buildings that do not 

already utilize the equipment.

• Deduce a historical repair rate from comparing the model’s estimate of 

historical shipments to actual shipments.

• Use historical equipment price and repair cost data to estimate how 

repair rates change as a function of efficiency.

Shipments Analysis
81

Shipments Analysis: Overview

• The goal of the shipments model is to estimate the annual shipments of 

covered equipment in the reference case and for each EL

– Shipments drop under the standards case due to increased equipment price

– Lower shipments imply more people are repairing equipment that fails

• Each equipment class is modeled separately using the same approach

• Total Shipments in each year, S = SN + SE + SR

– SN = new installations in new buildings

– SE = new installations in existing buildings (that did not previously use the equipment)

– SR = replacement installations in existing buildings

• Equipment stock U is the number of units in all buildings

– Function of age (a) and the analysis year (y) with

U(y, a=0) = S(y)

• Total equipment stock is related to total commercial building floor space 

through a market saturation parameter (m) which may vary with time

– Total commercial floor space that may use the covered equipment is partitioned across 

the six equipment classes

– Time-dependent market saturation follows an S-curve
82

Shipments Analysis: Modeling Approach

• SN : new installations in new buildings 

– Equal to market saturation parameter (m) x new construction floor space

– Floor space projections taken from the AEO (2013)

• SE : new installations in existing buildings

– Equal to the change in market saturation parameter (m) x existing floor space

– Existing floor space projections taken from AEO (2013)

• SR : replacement installations in existing buildings

– Depends on the equipment stock model

– Other inputs include a survival function (probability that a unit of age a will break 

down), and an econometric model for the repair-replace decision

– Econometric model depends on the total installed cost (TIC), operating and maintenance 

costs (OM), and repair costs (RC) 

– These costs vary by EL, changing the proportion of units repaired and the shipments

• The shipments model also includes a disaggregation of total shipments 

into efficiency bins

– Based on a second econometric model
83

Shipments Model: Inputs

• Model is calibrated to historical shipments

– Data submitted by ARI (1980-2001) for the 2005 rule; includes efficiency information for 1999-2001 only

– Economic census for 1969-1979 and 2002-2010 (no efficiency information)

• Floor-space projections obtained from AEO 2013

• Market saturations estimates are based on CBECS 1992, 1995 and 1999

– CBECS 2003 has no equipment data for shopping malls

– CBECS 2012 not available

– Significant source of uncertainty

• Equipment price, operating and maintenance costs

– Historical values developed from price indices and previous rule

– LCC provides values for the starting year of the analysis period (2019)

– Future operating costs estimated using AEO electricity price trends

– No price trend on equipment cost

• Repair costs (compressor replacement) obtained from RS Means

– Assumed to be proportional to equipment cost at each EL

– Significant source of uncertainty

• Lifetime/Survival function

– Use a Weibull distribution to estimate the probability of survival as a function of age

– CUAC: median = 18.7 years

– CUHP: median = 15.4 years
84

Shipments Model: Equipment Stock Model

• Assume we know the stock U(y,a); what happens in year y+1?

– Unit survives and ages to a+1

– Unit breaks and is not repaired => new unit is shipped (add 1 to SR)

– Unit breaks and is repaired

• Number of units that break = (stock of age a)*(probability of failure at age a)

• Average historic repair rate r is calculated by running shipments model assuming no 

repairs and comparing to data

• Starting with the first year of the 

standard (2019) the repair probability 

changes

• Use a logit model to estimate the 

probability of repair as a function of 

costs

• Key variable is the difference between 

the cost of repair and the cost of a 

new unit

• Model doesn’t include the difference 

in operating costs

• For very large equipment all units are 

repaired once then replaced
85

Shipments Model: Projected Base Case Shipments
86

Shipments Model: Base Case and Standards Cases

Note: In the figure, EL2 is overlain by EL3.
87

Shipments Model: Repairs vs Replacements
88

Request for Comment

Issue 13: DOE requests comments and information relating to 

the inputs to the shipments model, particularly updated 

shipments, repair costs and equipment mechanical lifetimes. 

Variation in repair costs as a function of equipment first cost and 

age would be especially useful.

DOE also requests comment on its approach to estimating the 

repair rate.
89

Shipments Model: Efficiency Distributions

• Use a consumer choice model to segregate each year’s shipments by efficiency

• The model uses the logit form, with the product utility equal to the sum of the total 

installed cost (TIC) plus the first year’s operating and maintenance cost (OM)

• W = α*TIC + β*OM

• The parameters α and β describe the relative sensitivity of purchasers to first cost vs. 

operating costs

• These parameters are estimated by calibrating the model to historic data on 

efficiency distributions

• DOE‘s model results show that, based on available data, purchasers are relatively 

insensitive to operating costs

• Thus, the model predicts that most purchases are first cost driven

• Within the shipments model, these results are equivalent to a “roll-up” scenario, 

where nearly everyone purchases the least-cost compliant unit at each EL

• This also results in a flat population-average efficiency trend over the analysis period
90

Request for Comment

Issue 14: DOE requests comments and data regarding the 

mechanical lifetime of equipment (time to first failure), and the 

lifetime of repaired equipment (to the next repair), and how 

these vary with the age of the equipment. This information will 

allow DOE to refine its shipments model and repair rate 

estimates.

Issue 15: DOE requests comments or data on the repair rate for 

very large CUACs and CUHPs (≥240,000 Btu/h and <760,000 

Btu/h). For this equipment, the shipments analysis assumed that 

all failing equipment is repaired once, and replaced the second 

time it fails.
91

Purpose

• Determine the projected national energy savings and customer national 

net present value.

Method

• Develop annual series of national energy and economic impacts.

• Use the shipments model to estimate the total stock of CUACs and 

CUHPs in service each year. 

• Aggregate the costs and energy use per unit in any given year.

• Report estimates for economic impact as change in consumer National 

Net Present Value (NPV) (in constant year dollars).

• Account for the time-value of money through defined discount rates.

National Impact Analysis
92

Shipments 

Model

National 

Energy 

Savings

National

Economic

Impacts

LCC 

Analysis 

Results and 

Other Inputs

National 

Energy Savings 

(Quads)

National 

Net Present Value 

(NPV)

(2013 US $, billion)

• National energy savings calculated for equipment shipped over the period 

from 2019 - 2048 (30 years of shipments).

• NPV calculated for equipment shipped over the period from 2019 - 2048 (30 

years of shipments).

National Impact Analysis: Process
93

National Impact Analysis: National Energy Savings Flow Diagram
94

National Impact Analysis: Consumer NPV Flow Diagram
95

Input Description

Total Installed Cost CUAC: Weighted-average per unit values as a function of efficiency level taken from the LCC 

analysis. 

CUHP: Baseline costs developed in Engineering Analysis and incremental costs for increased 

efficiency estimated to be the same as CUAC; installation costs same as CUAC.

Repair and 

Maintenance Costs

Maintenance costs taken from the LCC analysis; do not vary as a function of efficiency level;

estimated to be the same for CUHP as for CUAC.

Repair costs estimated based on RS Means; estimated to vary with efficiency; estimated to 

be the same for CUHP and CUAC. 

Annual Energy Use CUAC: Annual weighted-average per unit values as a function of efficiency level taken from 

LCC analysis.

CUHP: Cooling-side energy use same as CUAC; heating-side energy use taken from buildings 

using CUHPs in CBECS 2003; correlated COP and IEER based on AHRI database to 

obtain energy use as a function of efficiency level.

Base-Case Efficiencies Shipments-weighted efficiencies determined for the compliance year. Based on base-case 

efficiency distribution from LCC analysis. 

Standards-Case 

Projected Efficiencies

Projected by the Shipments Model.

Energy Prices Projected energy prices from EIA AEO 2013 forecasts (to 2040) and extrapolation to 2078.

Full Fuel Cycle Multiplier to convert site energy to full-fuel cycle energy.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A-4.

Present Year Future expenses are discounted to the year 2014.

National Impact Analysis: Inputs
96

National Impact Analysis: Trial Standard Levels

TSL Formulation Criteria

1 Each equipment class moves up one efficiency level from the current baseline

2 Each equipment class moves up two efficiency levels from the current baseline

3 Each equipment class moves up three efficiency levels from the current 

baseline

4 Maximum technologically feasible level, maximum NPV and maximum NES. 

Each equipment class moves up four efficiency levels from the current baseline
97

National Impact Analysis: Trial Standard Levels

Equipment Class Efficiency Level

Small Commercial Packaged Air Conditioners ≥65,000 

Btu/h and <135,000 Btu/h Cooling Capacity 1 2 3 4

Large Commercial Packaged Air Conditioners ≥135,000 

Btu/h and <240,000 Btu/h Cooling Capacity 1 2 3 4

Very Large Commercial Packaged Air Conditioners

≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 1 2 3 4

Small Commercial Packaged Heat Pumps

≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity 1 2 3 4

Large Commercial Packaged Heat Pumps

≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity 1 2 3 4

Very Large Commercial Packaged Heat Pumps ≥240,000 

Btu/h and <760,000 Btu/h Cooling Capacity 1 2 3 4
98

National Impact Analysis: National Energy Savings Results

Equipment Class quads

Small Commercial Packaged Air Conditioners ≥65,000 

Btu/h and <135,000 Btu/h Cooling Capacity 1.2 4.3 5.5 8.4

Large Commercial Packaged Air Conditioners ≥135,000 

Btu/h and <240,000 Btu/h Cooling Capacity 0.8 1.8 2.6 3.8

Very Large Commercial Packaged Air Conditioners

≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 0.8 1.6 2.7 3.5

Small Commercial Packaged Heat Pumps

≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity 0.1 0.5 0.7 1.0

Large Commercial Packaged Heat Pumps

≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.0 0.1 0.1 0.2

Very Large Commercial Packaged Heat Pumps ≥240,000 

Btu/h and <760,000 Btu/h Cooling Capacity 0.0 0.1 0.1 0.2

TOTAL 3.0 8.4 11.8 17.1

Cumulative Full Fuel Cycle National Energy Savings
99

National Impact Analysis: Consumer NPV

Equipment Class Billion 2013$

Small Commercial Packaged Air Conditioners ≥65,000 

Btu/h and <135,000 Btu/h Cooling Capacity 6.9 20.7 26 36.2

Large Commercial Packaged Air Conditioners ≥135,000 

Btu/h and <240,000 Btu/h Cooling Capacity 3 6.8 9.7 15.6

Very Large Commercial Packaged Air Conditioners

≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 3.4 6.4 11 13.5

Small Commercial Packaged Heat Pumps

≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity 0.8 2.3 3.1 4.2

Large Commercial Packaged Heat Pumps

≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.2 0.3 0.5 0.8

Very Large Commercial Packaged Heat Pumps ≥240,000 

Btu/h and <760,000 Btu/h Cooling Capacity 0.2 0.3 0.6 0.7

TOTAL 14.4 36.9 50.8 71.0

National Net Present Value at 3% real discount rate 
100

National Impact Analysis: Consumer NPV

Equipment Class Billion 2013$

Small Commercial Packaged Air Conditioners ≥65,000 

Btu/h and <135,000 Btu/h Cooling Capacity 2.5 7.1 9 11.8

Large Commercial Packaged Air Conditioners ≥135,000 

Btu/h and <240,000 Btu/h Cooling Capacity 0.9 2 2.9 4.8

Very Large Commercial Packaged Air Conditioners

≥240,000 Btu/h and <760,000 Btu/h Cooling Capacity 1 1.8 3.3 3.9

Small Commercial Packaged Heat Pumps

≥65,000 Btu/h and <135,000 Btu/h Cooling Capacity 0.3 0.8 1.1 1.5

Large Commercial Packaged Heat Pumps

≥135,000 Btu/h and <240,000 Btu/h Cooling Capacity 0.1 0.1 0.2 0.3

Very Large Commercial Packaged Heat Pumps ≥240,000 

Btu/h and <760,000 Btu/h Cooling Capacity 0.1 0.1 0.2 0.2

TOTAL 4.8 11.9 16.5 22.5

National Net Present Value at 7% real discount rate 
101

Request for Comment

Issue 16: DOE requests comments on its decision to not include 

a rebound effect for more efficient CUAC and CUHP.

Issue 21: DOE analyzed the effects of potential standards on 

equipment purchased over a 30-year period, and it undertook a 

sensitivity analysis using 9 years rather than 30 years of product 

shipments. The choice of a 30-year period of shipments is 

consistent with the DOE analysis for other products and 

commercial equipment. The choice of a 9-year period is a proxy 

for the timeline in EPCA for the review of certain energy

conservation standards and potential revision of, and 

compliance with, such amended standards. DOE is seeking input 

on ways to refine the analytical timeline.
102

Public Meeting Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening;

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
103

Purpose: 

• Assess the impacts of potential energy conservation standards on 

manufacturers.

• Identify and estimate impacts on manufacturer subgroups that may be more 

severely affected than the industry as a whole.

• Examine the direct employment, product competition, manufacturing 

capacity, and cumulative regulatory impacts on the industry.

Methodology:

• Analyze industry cash flow and industry net present value (INPV) through use 

of the Government Regulatory Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop subgroup 

analyses, and address qualitative issues.

Manufacturer Impact Analysis
104

• Certification and testing

– Definition of basic model

– Implementation of AEDMs

– Cost of IEER testing

• Impact of standard on repair rates

– Increase in prices will lead more customers to choose to repair older 

units

– Impacts on industry profitability as well as energy savings

• Alignment with industry standards

– ASHRAE

Key Issues
105

• Phase 1

– DOE creates an industry profile to characterize the market and identify 

important issues that require further investigation.

• Phase 2

– DOE prepares an industry cash flow model and an interview 

questionnaire to guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards 

both quantitatively (using the GRIM) and qualitatively (impacts on 

employment, competition, manufacturing capacity, and regulatory 

burden).

Manufacturer Impact Analysis
106

Industry Cash Flow Model

• Upstream Inputs

– Market and Technology Assessment (MTA) Industry Profile 

– Engineering MPCs

– Shipments

• MIA Inputs

– Markup Scenarios

– Conversion Costs

Manufacturer Impact Analysis
107

Markup Scenarios

– Preservation of Gross Margin Percentage

– Preservation of Operating Profit

Manufacturer Impact Analysis

High-Volume Product Classes

Pres. Of Gross Margin 

Scenario

Pres. Of Operating 

Profit Scenario 

(TSL 3)

Small Commercial Packaged Air-Conditioners 1.30 1.27

Small Packaged Heat Pumps 1.30 1.28

Large Commercial Packaged Air-Conditioners 1.34 1.31

Large Commercial Packaged Heat Pumps 1.34 1.36

Very Large Commercial Packaged Air-Conditioners 1.41 1.37

Very Large Commercial Packaged Heat Pumps 1.41 1.37
108

Industry Conversion Costs total $226.4 M over 4 years at TSL 3

Manufacturer Impact Analysis

Product Conversion Cost Capital Conversion Cost Industry Total

TSL 1 $38.7 $14.9 $53.6

TSL 2 $58.5 $39.2 $97.7

TSL 3 $120.9 $105.5 $226.4

TSL 4 $210.9 $113.3 $324.2
109

Manufacturer Impact Analysis

Base Case TSL 1 TSL 2 TSL 3 TSL 4

INPV 

($M) 1,260.9 

1,187.0 

to 

1,249.5 

1,015.6 

to 

1,208.0 

949.3 

to 

1,172.4 

822.8 

to 

1,142.7 

Change in INPV

($M) - 

(73.9) 

to 

(11.5) 

(245.3) 

to 

(52.9) 

(311.6) 

to 

(88.6) 

(438.2) 

to 

(118.1) 

Change in INPV

(%) - 

(5.9) 

to 

(0.9) 

(19.5) 

to 

(4.2) 

(24.7) 

to 

(7.0) 

(34.8)

to 

(9.4) 

Conversion Costs

($M) 12.7 53.7 97.8 226.4 324.3 

INPV Results

Summary of TSL 3

• Expected INPV change in the range of -24.7% to -7.0%

• Expected conversion costs total $226.4M for the industry
110

Small Business Impacts

• 3 small manufacturers identified

• Small manufacturers could have differential impacts relative to larger competitors due 

to the following:

– Product conversion and certification costs tend to be fixed and do not scale with 

sales volume

– Small manufacturers have fewer engineering and testing resources

– Small manufacturers lack purchasing power for critical components

• Comparison of Conversion Costs

Manufacturer Impact Analysis

TSL 3 Average Large 

Manufacturer

Average Small

Manufacturer *

Conversion Costs

as a % of Annual Revenue 19% 49%

*DOE assumed small manufacturers account for 5% of industry revenue
111

Request for Comment

Issues 22-24: DOE seeks comment on the number of small 

manufacturers; on the potential impacts of new energy 

conservation standard on those small manufacturers; and 

on the severity of those impacts.

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
112

Purpose

• To evaluate the economic impacts of standards on customer subgroups 

who may be disproportionately impacted compared with the general user 

population.

Method

• DOE identified small businesses in six building types from the building 

sample: assembly, small education, food services, small office, retail, and 

warehouses.

– The small business subgroup represents approximately 80% of floor space in 

the building sample.

• DOE applied a small company discount rate premium in the LCC and PBP 

analysis instead of the sector average discount rates.

Results

• LCC and PBP results were not appreciably different than for the 

general population.

LCC Subgroup Analysis
113

Emissions Impact Analysis

Purpose

• To estimate the emissions reductions resulting from amended energy 

conservation standards. 

– Includes estimating considers full-fuel-cycle emissions; both power plant emissions and 

“upstream” emissions.

– Includes fugitive methane emissions.

Method

• National Impact Analysis provides an annual time-series of energy savings over 

the analysis period.

• Energy Information Administration’s National Energy Modeling System (NEMS) 

is modified to represent the impacts of amended standards (modified code is 

known as NEMS-BT).

Results

TSL 1 TSL 2 TSL 3 TSL 4

CO2 (million metric tons) 271 770 1085 1565

SO2 (thousand tons) 727 2083 2934 4243

NOX (thousand tons) 252 725 1021 1477

Hg (tons) 0.89 2.53 3.57 5.16

N2O (thousand tons) 3.8 11 15.5 22.4

CH4 (thousand tons) 772 2181 3072 4427
114

Emissions Monetization

• DOE used the most current Social Cost of Carbon (SCC) values developed 

by interagency process.

– SCC is intended to be a monetary measure of the incremental damage resulting from 

greenhouse gas (GHG) emissions, including, but not limited to, agricultural productivity 

loss, human health effects, property damage from rising sea levels, and changes in the 

ecosystem.

• The most recent (2013) U.S. government interagency estimates of the SCC 

for emissions in 2015, per metric ton avoided (in 2013$): 

– $12.0 (average value from distribution with a 5% discount rate)

– $40.5 (average value from distribution with a 3% discount rate)

– $62.4 (average value from distribution with a 2.5% discount rate)

– $119 (95th-percentile value from distribution with a 3% discount rate) 

• The SCC in constant dollars increases over time.

• DOE also monetizes the NOx emissions reductions resulting from amended 

standards. 

– Estimates of monetary value range from $476 to $4,893 per short ton. 

– DOE calculated monetary benefits using a medium value of $2,684 per short ton.
115

Emissions Monetization: Results

Full Fuel Cycle Emissions Reduction Benefits (million 2013$)

TSL 1 TSL 2 TSL 3 TSL 4

CO2 1,564 to 24,219 4,350 to 68,057 6,127 to 95,856 8,794 to 137,933

NOx 3 % discount rate 267 753 1,060 1,527

NOx 7 % discount rate 89 243 343 490
116

Request for Comment

Issue 18: DOE requests comment on the application of the new 

SCC values used to determine the social benefits of CO2 

emissions reductions over the rulemaking analysis period. In 

particular, the agency solicits comment on its derivation of SCC 

values after 2050, where the agency applied the average annual 

growth rate of the SCC estimates in 2040–2050 associated with 

each of the four sets of values. 
117

Utility Impact Analysis

Purpose

• To estimate the changes in electric installed capacity and generation that 

result from amended energy conservation standards.

Method 

• National Impact Analysis provides an annual time-series of energy savings 

over the analysis period.

• Energy Information Administration’s National Energy Modeling System 

(NEMS) is modified to represent the impacts of amended standards 

(modified code is known as NEMS-BT).

Output

• Reductions in total electricity generation.

• Reductions in primary fuel (e.g. coal, natural gas) consumption.

• Changes to the mix of electricity generation by fuel type.

• Changes to total installed capacity.
118

Employment Impact Analysis

Purpose

• To estimate the national net impact on jobs as a consequence of 

amended energy conservation standards, including indirect employment 

impacts.

Method 

• Uses the ImSET (Impact of Sector Energy Technologies) model for the 

evaluation of indirect employment impacts; direct employment impacts 

to the commercial air conditioning industry are developed in the 

Manufacturer Impact Analysis.

• The changes in national equipment and energy expenditures are taken 

from the National Impact Analysis and entered as inputs into ImSET.

Results

• Net labor market impacts are negligible over time due to the small 

magnitude of the short-term effects.
119

Regulatory Impact Analysis

Purpose

• To investigate the national impacts of non-regulatory alternatives to 

mandatory amended energy conservation standards.

Method

• DOE modified the NIA spreadsheet to analyze the following nonregulatory alternatives and their impact on purchase price and energy 

use.

Output

• National Energy Savings and Net Present Value for the non-regulatory 

alternatives.

• No new regulatory action • Manufacturer tax credits

• Customer rebates • Voluntary efficiency targets

• Customer tax credits • Bulk government procurement

Details of the Analysis can be found in chapter 18 of the TSD.
120

Closing Remarks
121

How to Submit Written Comments

• In all correspondence, please refer to the CUAC/CUHP rulemaking by:

– Small, Large, and Very Large Air-Cooled Commercial Package Air 

Conditioning and Heating Equipment Energy Conservation Standards 

Rulemaking,

– Docket Number EE-2013-BT-STD-0007, and

– Regulatory Identification Number (RIN) 1904-AC95.

• Email: CommPkgACHP2013STD0007@ee.doe.gov

• Comment period closes: December 1, 2014, 11:59 PM EST

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945
122

Supporting Material
123

Technology Options Identified for Market & Technology 

Assessment
124

Technology Assessment: Technologies Identified

Technology Options

Heat transfer improvements:

• Electro-hydrodynamic enhancement

Alternative refrigerants

Condenser and evaporator fan and fan motor improvements:

• Larger fan diameters

• More efficient fan blades (e.g., air foil centrifugal evaporator fans, backward-curved centrifugal 

evaporator fans, high efficiency propeller condenser fans)

• High efficiency motors (e.g., copper rotor motor, high efficiency induction, permanent magnet, 

electronically commutated)

• Variable speed fans/motors

Larger heat exchangers
125

Technology Assessment: Technologies Identified 

Technology Options (cont.)

Compressor Improvements

• High efficiency compressors

• Multiple compressor staging

• Multiple-tandem or variable-capacity compressors

Thermostatic expansion valves

Electronic expansion valves

Sub-coolers

Reduced indoor fan belt loss:

• Synchronous (toothed) belt

• Direct-drive fans
126

Determination of Incremental Heating Efficiency Levels for 

CUHP
127

COP Efficiency Levels for CUHP

• Relationship between EER and COP for small CUHP, ≥65,000 Btu/h 

and <135,000 Btu/h cooling capacity, electric heat/no heating 

equipment class.
128

COP Efficiency Levels for CUHP

• Relationship between EER and COP for large CUHP, ≥135,000 Btu/h 

and <240,000 Btu/h cooling capacity, electric heat/no heating 

equipment class.
129

COP Efficiency Levels for CUHP

• Relationship between EER and COP for very large CUHP, ≥240,000 

Btu/h and <760,000 Btu/h cooling capacity, electric heat/no heating 

equipment class.
130

COP Efficiency Levels for CUHP

• Relationship between IEER and COP for small CUHP, ≥65,000 Btu/h 

and <135,000 Btu/h cooling capacity, electric heat/no heating 

equipment class.
131

COP Efficiency Levels for CUHP

• Relationship between IEER and COP for large CUHP, ≥135,000 Btu/h 

and <240,000 Btu/h cooling capacity, electric heat/no heating 

equipment class.
132

COP Efficiency Levels for CUHP

• Relationship between IEER and COP for very large CUHP, ≥240,000 

Btu/h and <760,000 Btu/h cooling capacity, electric heat/no heating 

equipment class.
133

Design Options and Energy Modeling Results for Analyzed 

Equipment Categories
134

Design Options for Incremental Efficiency Levels

• Design options for 7.5-Ton CUAC units

• Design options for 15-ton CUAC units

ID 

Airflow

OD 

Airflow

# Basis IEER Ref. 

Circuit

# of 

Comp. Type Stage Capacity ratio Speed Type

Face 

area 

[ft^2]

Fin 

pitch Rows Stage Type

Fin 

pitch

Face 

area 

[ft^2]

Row Stage

Baseline Modeling 11.4 1 circuit 1 Scroll 1 100 Fixed Tube-fin 7.2 15 3 1 Tube-fin 17 16.6 2 1

EL1 Teardown / 

Testing 12.9 1 circuit 1 Scroll 1 100 Fixed Tube-fin 8.9 15 3 1 Tube-fin 17 20.5 2 1

EL2 Teardown / 

Testing 14.0 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 11.1 15 4 1 Tube-fin 17 25.1 2 1

EL3 Modeling 14.8 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 11.1 15 4 VS Tube-fin 17 25.1 2 2

EL4

Modeling with

Published 

Manuf. Data

19.9 1 circuit 2 Scroll 3 64/36 Fixed Tube-fin 17.5 15 4 VS Tube-fin 18 36.1 2 3

Efficiency Level Compressor Indoor Heat Exchanger Outdoor Heat Exchanger

ID 

Airflow

OD 

Airflow

# Basis IEER Ref. 

Circuit

# of 

Comp. Type Stage Capacity ratio Speed Type

Face 

area 

[ft^2]

Fin 

pitch Rows Stage Type

Fin 

pitch

Face 

area 

[ft^2]

Row Stage

Baseline Modeling 11.2 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 16.2 15 3 1 Tube-fin 21 26.6 2 1

EL1 Modeling 12.2 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 24.5 15 3 1 Tube-fin 21 40.4 2 1

EL2 Testing 13.2 2 circuits 2 Scroll 2 50/50 Fixed Tube-fin 22.0 15 4 1 Tube-fin 17 42.8 2 1

EL3 Modeling 14.2 2 circuits 2 Scroll 2 55/45 Fixed Tube-fin 22.0 15 4 VS Tube-fin 17 42.8 2 2

EL4

Modeling with

Published 

Manuf. Data

18.4 1 circuit 2 Scroll 3 64/36 Fixed Tube-fin 26.4 15 4 VS Tube-fin 18 59.2 2 3

Efficiency Level Compressor Indoor Heat Exchanger Outdoor Heat Exchanger
135

Design Options for Incremental Efficiency Levels

• Design options for 30-Ton CUAC units

ID 

Airflow

OD 

Airflow

# Basis IEER Ref. 

Circuit

# of 

Comp. Type Stage Capacity ratio Speed Type

Face 

area 

[ft^2]

Fin 

pitch Rows Stage Type

Fin 

pitch

Face 

area 

[ft^2]

Row Stage

Baseline Modeling 10.1 2 circuits 4 Scroll 2 25/25/

25/25/ Fixed Tube-fin 21.9 15 4 1 Microchannel 23 23.0 1 1

EL1 Modeling 11.6 2 circuits 4 Scroll 2 25/25/

25/25/ Fixed Tube-fin 31.3 15 4 1 Microchannel 23 32.9 1 2

EL2 Modeling 12.5 2 circuits 4 Scroll 2 25/25/

25/25/ Fixed Tube-fin 31.3 15 4 1 Microchannel 23 46.1 1 2

EL3 Modeling 13.5 2 circuits 4 Scroll 4 25/25/

25/25/ Fixed Tube-fin 31.3 15 4 VS Microchannel 23 46.1 1 2

EL4

Modeling with

Published 

Manuf. Data

15.5 2 circuits 4 Scroll 4 25/25/

25/25/ Fixed Tube-fin 31.6 15 4 VS Microchannel 23 68.4 1 4

Efficiency Level Compressor Indoor Heat Exchanger Outdoor Heat Exchanger
136

Design Option Energy Modeling Results

• Detailed energy modeling performance data for 7.5-ton incremental 

efficiency levels at different loading conditions.
137

• Detailed energy modeling performance data for 15-ton incremental 

efficiency levels at different loading conditions.

Design Option Energy Modeling Results
138

• Detailed energy modeling performance data for 30-ton incremental 

efficiency levels at different loading conditions.

Design Option Energy Modeling Results