JOHN P. SARBANES 

3110 DISTRICT, MARYLAND 

COMMITiff ON 

ENERGY AND COMMERCE 

Mr. Brad Crowell 

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December 19, 2014 

Assistant Secretary for Congressional and Intergovernmental Affairs 

U.S. Department Of Energy 

1000 Independence Avenue SW 

Washington, DC 20585-0001 

Dear Mr. Crowell: 

2444 R,~YBUHN HOUSf_ 0fflCE BUILDING 

WASHINGTON, DC 20515 

(2021225-4016 

FAX: (202) 225-9219 

Enclosed, please find a copy of correspondence from my constituent Norm Long. 

This individual has expressed some concerns about product classification for indoor 

horizontal doublecduct air-cooled units. I would appreciate it if you would carefully review their 

comments and provide a response to these concerns. 

Should you have any questions about this matter, please contact Peter Gelman of my 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, 

d.-L p ...(l_.q. 

(/John P. Sarbanes 

Member of Congress 

44 CALVERT S1HEET 

SUITE 349 

ANNAPOLIS, MD 21401 

{410) 295-1679 

FAX: (41_0) 295-1682 

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3901 NATIOr>JAL DF\IVE 

SUIT[ 220 

8URTONSV1LLIO, MO 20866 

(301) 421-4078 

FAX: (301) 421-4079 
t:}HAVTECH lNNCIVAT~VIE 501!.UTIC>N:O~ IEXCEP1Pl'O!NtA!L SEIRVU:::£. 

The Honorable John Sarbanes 

United States House of Representatives 

Washington, DC 20515 

Dear Mr. Sarbanes: 

Havtech is an independent manufacturer's representative located in Columbia. Md. Our 

company provides commercial air conditioning systems. 

The products we offer typically consist of applied 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 of air conditioning system. These systems are particularly well suited for 

renovation projects, add-on cooling, tenant fit 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 or will 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 higher efficiencies is not readily available to small 

manufacturers. 

4. Some of the technology is not available from any US company and must be imported 

which is not desirable. 

5. Like-for-like units are no longer available for customers that need a replacement. 

6. Customers are repairing units rather than replacing with ·higher efficiency air 

conditioners. 

9505 BERGER ROAD COLUMBIA, MD 211 []46 

INFO@HAVTECH.COM 

301 206-9225 MA!IN 

301 497-9610 FAX 

HAVTIECH.Cl:llM 
7. Transportation and material handling costs are higher. 

8. Installation is more oomplex due to larger and heavier units. 

9. Specifically, the requirements are very generic in nature and do not provide for the 

nuances for some of the "niche• type units. In particular the current proposal (EERE2013-BT-STD-0007} is targeting an increase of 30% to some of the efficiency levels. 

It should be kept in mind that any improvement in the air conditioning efficiency will help in the 

overall gains for energy consumption. Upgrading the air conditioning in an older structure is 

often the easiest and most expedient way to improve the building energy performance. 

One of our vendors, United CoolAir, provides air conditioners that are unique in that they 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 roof top air conditioners and split systems are 

not practical or even possible. 

While United CoolAir has been making efforts to get some form of relief, we felt that it was 

important for you to also be aware of the 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 

LEED AP 

President - Havtech 
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OFFICIAL BUSINESS 

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Mr. Brad Crowell 

U.S. Department Of Energy 

1000 Independence Avenue SW 

Washington, DC 20585-0001 

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