JOHN P. SARBANES 3110 DISTRICT, MARYLAND
COMMITiff ON ENERGY AND COMMERCE



### Mr. Brad Crowell 

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www. sarbanes.house.gov 

### December 19, 2014

Assistant Secretary for Congressional and Intergovernmental Affairs U.S. Department OfEnergy 1000 Independence Avenue SW Washington, DC 20585-0001 DearMr. Crowell: 2444**R,~YBUHN** HOUSf_ 0fflCE BUILDING WASHINGTON, DC 20515 (2021225-4016 FAX: (202) 225-9219



### Enclosed, please find a copy ofcorrespondence from my constituentNorm Long. This individual has expressed some concerns about product classification for indoor horizontal doublecduct air-cooled units. I would appreciate it ifyouwould carefully review their comments and provide a response to these concerns. Should you have any questions aboutthis matter, please contact Peter Gelman ofmy staff at 202-225-4016. Thank you for your attention to this matter.

JPS/pg

600 BALTIMORE AVENUE SUITE 303 TOWSON, MD 21204

(410) 832-8890 Ft1X: (410} 832-8898 

### Sincerely, 

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(/JohnP. Sarbanes Member ofCongress

44 CALVERT S1HEET SUITE 349 ANNAPOLIS, MD 21401 {410) 295-1679 FAX: (41_0) 295-1682 PRINTED ON RECYCLED PAPER' 3901 NATIOr>JAL DF\IVE SUIT[ 220 8URTONSV1LLIO, MO 20866 (301) 421-4078 FAX: (301) 421-4079

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The Honorable John Sarbanes United States House ofRepresentatives Washington, DC 20515 Dear Mr. Sarbanes:

Havtech is an independent manufacturer's representative located in Columbia. Md. Our company provides commercial airconditioning systems. The products we offertypically consist ofapplied heating, ventilating and air conditioning systems that are specified by engineers, architects and design I build contractors to solve specific application requirements. The units are most often built-to-order and are not a commodity type ofairconditioning system. These systems are particularly well suited for renovation projects, add-on cooling, tenantfit out, retrofit and replacement situations. These units are seldom used for new construction. The units are typically utilized in the following applications: Offices Retail Spaces Fitness Centers Lobbies Restaurants Hotels Laboratories Communication Facilities Conference Rooms Bars

The DOE establishes the rules and regulations that determine the minimum efficiency levels required for air conditioning systems. Rules and regulations adopted, enacted and proposed by the DOE have created an undesirable market impact. It is also believed that the costs and impacts on business have and will continue to result in undesirable impacts for many of your constituents. DOE rules and regulations (existing and proposed) have orwill result in: 1. Unit models being withdrawn from the market 2. Unit sizes have grown which makes them more difficult to place inside the space (loss of utility). 3. Technology required to achieve higherefficiencies is not readily available to small manufacturers. 4. Some ofthe technology is not available from any US company and must be imported which is not desirable. 5. Like-for-like units are no longeravailable forcustomers that need a replacement. 6. Customers are repairing units ratherthan replacing with ·higherefficiency air conditioners.

9505 BERGER ROAD COLUMBIA, MD 211 []46 INFO@HAVTECH.COM
301 206-9225 MA!IN 301 497-9610 FAX HAVTIECH.Cl:llM7. Transportation and material handling costs are higher. 8. Installation is more oomplexdueto larger and heavier units. 9. Specifically, the 

### requirements arevery generic in nature and do not provide forthe nuancesforsomeofthe"niche• type units. In particular the current proposal (EERE2013-BT-STD-0007} istargeting an increase of 30% to some ofthe efficiency levels. Itshould be kept in mind that any improvement in the air conditioning efficiencywill help in the overall gainsfor energy consumption. Upgrading the air conditioning in an olderstructure is often the easiest and most expedientwayto improve the building energy performance. One of our vendors, United CoolAir, provides airconditioners that are unique in thatthey are located totally indoors. There are no outdoor components, such as a condensing section, for these systems. The indoor application is also very desirable for deterring theft and vandalism. These indoor modular units are installed where rooftop air conditioners and split systems are not practical or even possible. While United CoolAir has been making efforts to getsome form of relief, we feltthat it was important for you to also be aware ofthe impact in your area. This negative business impact touches on our sales agency, the engineers, contractors, tenants, building owners and ultimately the customers. All the people associated with these businesses need your support. 

### We are requesting that you help support efforts to get the DOE to create the new product classification for the indoor horizontal double-duct air-cooled units per EERE-2013-BTSTD-0007. Should there be any questions or anything that needs to be clarified please contact us. If desirable we can get you the contact details for the manufacturer. Thank you in advance for any consideration that can be made on this request.

Norm long, PE LEEDAP President
- Havtech

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