491 E. Princess Street • York, PA 17403 • 717

- 843

- 4311 • Fax: 717

- 854

- 4462 • www.unitedcoolair.com United CoolAir has been designing and fabricating highly flexible light commercial “niche” type air conditioning units since

1988 . This is a family

- owned and operated American business with HVAC industry ties going back long before United

CoolAir was formed. The company employs approximately 100 people and has a fabrication facility that comprises 80,000

sq. ft. and an off

- site warehouse of 20,000 sq. ft. located in York, PA.

United CoolAir commercial air conditioner units are applied systems that ar e specified by engineers, architects and

design/build contractors to solve specific application requirements. Units are built

- to

- order and are not a commodity type

of unit. We start with a basic model and add options or modify the sheet metal as needed to meet the specific application.

These units include a variety of styles, configurations and capabilities. Units are distributed through a network of

approximately 60 independent representatives throughout the US, Canada and Puerto Rico.

In order to serve o ur “niche” of the market

, a large inventory of parts and components are always kept on hand. A high

percentage of our parts are sourced from US companies, as is all of our steel. While we attempt to handle all the design

and fabrication in

- house we out

- sou rce some specialty areas, such as paint for the cabinets.

Our “niche” in the market is that we provide an all

- indoor modular system. There are many benefits to the end user for our

type of products. The modularity means that the units typically can be tak en into the structure without making building

modifications. Systems arrive fully charged with refrigerant, thus lowering the installed cost and help ing to insure a high

quality system. Additionally, United CoolAir has designed and fabricated unique one

- of

- a

- kind units for specific

applications or OEM requirements, such as cooling controls on baggage X

- ray units used at air ports.

Our systems are particularly well suited for renovation projects, add

- on cooling, tenant fit out and replacement situations.

Un ited CoolAir units are typically used for:

Offices

Restaurants

Conference Rooms

Retail Spaces

Hotels

Bars

Fitness Centers

Laboratories

Lobbies

Communication Facilities

Plus other forms of commercial spaces needing air conditioning.

I n addition to the commercial air conditioners United CoolAir also designs, fabricates and distributes portable / temporary

cooling and heating units. These units are used for hospitality tents, temporary process cooling in manufacturing, spot

cooling for computer roo ms, dehumidification for ships in dry dock, shelters for first responders , and ground support for

regional jets plus many other applications.491 E. Princess Street • York, PA 17403 • 717

- 843

- 4311 • Fax: 717

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- 4462 • www.unitedcoolair.com 

## Double

- Duct Air Conditioners

1. Have been around since mid

- 1950’s

. 2. Units can be described as a “niche” p roduct.

3. Entire system is located inside the building structure

4. Can be installed as a single package or as a split system

5. Primarily used for renovation or replacement applications.

6. Units are typically installed above drop ceilings (limited space). Competing for space in this

area with duct work, water piping, wiring, communication cables, fire systems, etc. This

application may be identified by some as being “space constrained”. However, the use of this

term is not limited solely to the singular confine of t he space the units get applied in, but also

the doorways, elevators, hallways, etc. that the units must fit through in order to get the units

into an existing building space.

7. Reference Sketch 2 for a graphic on typical application for a single package unit . Reference

Sketch 3 for a graphic on typical application for a split system.

8. Applied only as commercial units (both single phase and 3 phase).

9. Units are built

- to

- order and are not stocked in any location.

10. Air for the condenser is ducted to and from the ou tside with field supplied extended ducting

and louvers for the condenser air (inlet and outlet).

11. Description:

a. Factory made

b. Cooling Only or Heat Pump Configuration

c. Belt Drive Centrifugal Evaporator Blower

d. Belt Drive Centrifugal Condenser Blower

e. Evaporator Coil

f. Condensing Coil

g. Single or Multiple Compressor Circuits

h. Expansion Valve

12. All regulations have been defined with “outdoor units”. Outdoor units typically are configured

and constructed using direct drive propeller fans. The units do not have to operate a gainst any

static pressure. The double

- duct units typically utilize belt drive centrifugal blowers for the

condenser air movement. They must overcome the pressure drop associated with the inlet and

outlet louvers, ductwork, coil pressure drop and cabinet a ir pressure drop. Therefore, the

horsepower to move the air is substantially higher.

13. Outdoor type units will typically have coils that have two or three rows. A double

- duct

condenser coil may be eight (8) rows deep. This means that the pressure drop acros s the coil

alone is substantially more than the typical outdoor unit coil.

14. Since the units are ducted on the condenser side there are limitations imposed by the

structures as to the size of the duct work and louvers. Industry recommended installation

gui delines dictate the velocity of air across louvers and in ducting. These help to establish what

the coil size face area and other design parameters are to be. This size limitation affects the

heat exchanger effectiveness directly and thus the size of the c abinet.

15. The testing standards are defined for units with propeller fans and no static pressure

requirement. This means that the double

- duct units must be tested at a point where they will

never be operated.

16. The original product family encompassed thirtee n (13) models that went from 1

- ton up through

15

- tons. The requirement to achieve 13 SEER in the units forced the cabinet sizes to grow and

diminished substantially the utility of the units. The new product family contains only six (6)

models that range fr om 2

– tons up to 8

- tons. Refer to Sketch 1 for a comparison of cabinet

sizes. Outdoor condensing sections or rooftop units are not restricted by space limitations and

can grow as needed to achieve higher efficiencies.491 E. Princess Street • York, PA 17403 • 717

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### 17. The move to the higher efficiency mod els has reduced sales approximately 80 to 90%. Should

ASHRAE 90.1

- 2013 be enacted, for the single package units at the higher 14 SEER efficiency

level, an additional 45% of the sales will be lost. This loss of sales and unit utility we feel

represents spec ial hardship, inequity and unfair distribution of burdens.

18. The total sales for these type of units does not have any measurable impact on the national

energy usage.

19. Due to the elimination of capacities and with the larger cabinet sizes there are no longe r any

like

- for

- like unit replacements for the end users.

20. Since the original units are no longer available it is more likely that an end user may opt to

repair an old unit rather than replace it with a more efficient model. This defeats the purpose of

havi ng more efficient equipment available.

21. United CoolAir has pursued higher efficiency components to aid in gaining efficiency while

retaining the utility of the units.

a. Some coil technologies are not available for small manufacturers, such as microchannel

c oils. Microchannel coil selection software does not model the performance very well.

Our experience has been that multiple coil samples must be tested to achieve an

acceptable selection. As a small manufacturer

, that does not have a test lab

, this testing

becomes too expensive to justify for development of an entire product family.

Additionally, most of the microchannel coil vendors want orders at quantity levels that

far exceed our annual demand.

b. Smaller tube coils are just now becoming available from our vendors. We are looking at

this technology, but it is new for UCA and remains to be seen if it will accomplish what

needs to be achieved.

c. High efficiency motors have been used where available.

d. Currently looking at higher efficiency blowers / motor combinat ions. Unfortunately these

are not available from any US manufacturer. The lead

- time is very long to get the

blowers from Germany. The cost will add even more (several hundred dollars) to the

already bloated price for the current models.491 E. Princess Street • York, PA 17403 • 717

- 843

- 4311 • Fax: 717

- 854

- 4462 • www.unitedcoolair.com491 E. Princess Street • York, PA 17403 • 717

- 843

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- 4462 • www.unitedcoolair.com 

## Sk etch 1 Unit Size Comparison

Standard Efficiency High Efficiency

Tons Compr.

Qty H W L Cu.

Ft. Tons Compr.

Qty H W L 

### Cu. Ft.

1 1 16 35

- 15/16 51

- 5/8 17.18 1 NLA

1.5 1 16 35

- 15/16 51

- 5/8 17.18 1 .5 NLA

2 1 22 47

- 3/8 66

- 5/16 40.21 2 1 22 56 76 

### 54.19

3 1 22 47

- 3/8 66

- 5/16 40.21 3 1 22 56 76 

### 54.19

4 1 22 47

- 3/8 66

- 5/16 40.21 4 1 25 64 86 

### 79.63

5 1 22 47

- 3/8 66

- 5/16 40.21 5 1 25 64 86 

### 79.63

4 2 27 5 5

- 3/8 71

- 3/4 62.08 4 NLA

5 2 27 55

- 3/8 71

- 3/4 62.08 5 NLA

6 2 27 55

- 3/8 71

- 3/4 62.08 6 2 32 70

- 1/2 108

- 1/2 

### 141.65

8 2 27 55

- 3/8 71

- 3/4 62.08 8 2 32 70

- 1/2 108

- 1/2 

### 141.65

10 2 29 70

- 5/8 80

- 3/4 95.71 10 NLA

12 3 29 70

- 5 /8 80

- 3/4 95.71 12 NLA

15 3 29 70

- 5/8 80

- 3/4 95.71 15 NLA



### High Efficiency

Tons Compr. Qty

1 NLA

1.5 NLA

2 1

3 1

4 1

5 1

4 NLA

5 NLA

6 2

8 2

10 NLA

12 NLA

15 NLA Standard Efficiency

Tons Compr. Qty

1 1

1.5 1

2 1

3 1

4 1

5 1

4 2

5 2

6 2

8 2

10 2

12 3

15 3 Size Diff.

Cu. Ft. %

13.98 134.8

13.98 134.8

39.42 198.0

39.42 198.0

79.57 228.2

79.57 228.2491 E. Princess Street • York, PA 17403 • 717

- 843

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- 4462 • www.unitedcoolair.com491 E. Princess Street • York, PA 17403 • 717

- 843

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- 854

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## Operating Cost Analysis

A 5

- T on single compressor air

- cooled system was selected for the analysis. This was done because there was a

5

- ton unit in the standard efficiency and also in the high efficiency product families. The 5

- ton unit also represents

a high percentage of the product family sales mix.

HVACOPCOST software was selected from the internet. This is software available to all people and companies

and therefore does not provide any bias on the part of United CoolAir. The software is designed to handle

analysis based on SEER r atings, unit tons, electric rates and cooling hours. The software provides the cooling

hours based on the city location.

Electric rates were obtained from ELECTRICCHOICE.COM. Commercial values for 2013 were selected for a

number of cities.

The comparison was made based on the current 13 SEER minimum rating and a 10 SEER rating. The 10 SEER

rating was an arbitrary selection, but it is close to what the requested energy efficiency level is . It should be noted

that this efficiency level is higher than the or iginal Standard Efficiency level unit. The operating cost software only

allows determination based on SEER levels.

A cost difference of $2,500 has been used as this is the price difference between the old Standard Efficiency

model and a High Ef ficiency mo del with an anticipated mark

- up from the Distributor to the purchaser.

A 3 year period was selected as the target payback period for the end user to re

- coup the additional cost.

Chart 1 below plots the cooling hours based on the various electric rates ag ainst the 3 year operating cost

savings. This chart illustrates that only at higher electric rates and high cooling hours is there any opportunity to

recover the added first cost.

Chart 2 below plots the selected cities against cooling hours and operating savings. Even Miami with the highest

cooling hours cannot achieve a payback in 3 years based on operating cost savings.

Table 1 tabulates the operating cost savings for the first three years. An average increase of 2% in electric rates

was used for years 2 and 3. Additional rates above the 2013 levels are also listed.

The operating cost savings when going from a 10 SEER model to a 13 SEER model do not provide enough

savings based on current electric rates and cooling hours. The added cost (approximately $2500 for a 5

- ton

model) for the higher efficiency cannot be justified based on operating savings.491 E. Princess Street • York, PA 17403 • 717

- 843

- 4311 • Fax: 717

- 854

- 4462 • www.unitedcoolair.com 

### Chart 1

– Cooling Hours vs. 3

- Year Operating Savings491 E. Princess Street • York, PA 17403 • 717

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- 4311 • Fax: 717

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- 4462 • www.unitedcoolair.com 

### Chart 2

– Cooling Hours vs. Operating Savings491 E. Princess Street • York, PA 17403 • 717

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- 4462 • www.unitedcoolair.com Orig. SEER 10

Hours New SEE R 13

Location Cents / KWH Yr 1 Yr 2 Yr 3 Total

1320 11 $249 $254 $259 $762

Washington, DC 12 $271 $276 $282 $829

13 $295 $301 $307 $903

14 $317 $323 $330 $970

15 $339 $346 $353 $1,037

2127 9 $329 $336 $342 $1,007

Charleston, SC 10 $364 $3 71 $379 $1,114

11 $401 $409 $417 $1,227

12 $437 $446 $455 $1,337

13 $474 $483 $493 $1,451

1089 15 $280 $286 $291 $857

New York, NY 16 $298 $304 $310 $912

17 $318 $324 $331 $973

18 $336 $343 $350 $1,028

19 $354 $361 $368 $1,083

683 7 $82 $84 $85 $251

Chicago, IL 8 $94 $96 $98 $288

9 $106 $108 $110 $324

10 $117 $119 $122 $358

11 $129 $132 $134 $395

1215 8 $166 $169 $173 $508

St. Louis, MO 9 $187 $191 $195 $572

10 $208 $212 $216 $637

11 $229 $234 $238 $701

12 $250 $255 $260 $765

2209 7 $265 $270 $276 $811

Houston, TX 8 $303 $309 $315 $927

9 $341 $348 $355 $1,044

10 $378 $386 $393 $1,157

11 $417 $425 $434 $1,276

282 7 $33 $34 $34 $101

Seattle, WA 8 $38 $39 $40 $116

9 $43 $44 $45 $132

10 $48 $49 $50 $147

11 $53 $54 $55 $162

379 8 $52 $53 $54 $159

Portland, OR 9 $59 $60 $61 $181

10 $65 $66 $68 $199

11 $71 $72 $74 $217

12 $78 $80 $81 $239

1530 14 $367 $374 $382 $1,123

Los Angeles, CA 15 $393 $401 $409 $1,203

16 $420 $428 $437 $1,285

17 $446 $455 $464 $1,365

18 $472 $481 $491 $1,445

2141 9 $330 $337 $343 $1,010

Phoenix, AZ 10 $367 $374 $382 $1,123

11 $404 $412 $420 $1,236

12 $441 $450 $459 $1,350

13 $477 $487 $496 $1,460

3931 9 $607 $61 9 $632 $1,858

Miami, FL 10 $674 $687 $701 $2,063

11 $741 $756 $771 $2,268

12 $808 $824 $841 $2,473

13 $876 $894 $911 $2,681

Average Electric P rice Increase 2% (Years 2 & 3) 

### Table 1

– Summation of Operating Cost Savings491 E. Princess Street • York, PA 17403 • 717

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## Impacts of Higher Efficiency Levels on Double

- Duct Air Conditioners

A. The cabinet sizes have grown substantially (Ref. Sketch 1). This means that the units, defined by capacity size,

can no longer fit into the same space. The tabulation associate d with Sketch 1 shows that the cabinets have

grown from 134% to 228% of the comparable unit capacities of the Standard Efficiency models. The 6 & 8 ton

cabinets are more than double the older cabinet size and exceed the old 15 ton cabinet size.

B. Like

- for

- li ke units can no longer be provided due to the larger cabinet sizes.

C. Capacity sizes have been lost : 1, 1

- 1/2, 10, 12 and 15

- ton models.

D. End users are more likely to repair a unit, rather than replacing with a more efficient system. The desire for energy

sav ings will not be achieved.

E. Unit prices have increased substantially. A 5

- ton unit now costs approximately $2,500 more.

F. Operating cost savings for a 10 SEER unit versus a 13 SEER unit cannot re

- coup the increased unit cost in 3

years or less. In some areas of the U.S. the operating cost savings may not be re

- couped during the life time of

the equipment.

G. Sales of the double

- duct units have dropped substantially.

H. The ASHRAE 90.1

- 2013 standard will erode more sales because of the higher efficiency levels. The r equirement

for the single package units to achieve 14 SEER, for units < 65 MBH, will eliminate another 45% of the market.

I. United CoolAir is aware of one manufacturer that stopped producing these units several years ago because they

could not engineer units to achieve the higher efficiency levels.

J. A high majority of the impact on double

- duct air conditioners falls on small businesses.

K. Technology to achieve the higher efficiency levels will raise the cost substantially more. Some technology means

going outsid e the U.S. for components.491 E. Princess Street • York, PA 17403 • 717

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- 4462 • www.unitedcoolair.com 

## Standard vs. Burdens

The following is a summary of “litmus test” questions that are to be analyzed to determine if a standard is justified.

Comments listed are relative to the energy efficienc y requirements only for horizontal double

- duct type air conditioners

.

(I) The economic impact of the standard on the manufacturers and on the consumers of the products subject to such

standard

a. Manufacturing costs have been raised and thus the end price to the consumer.

b. Costs, relative to high production volume units, went up proportionately more for the same efficiency level

achievement.

c. Sales and revenues for the small manufacturers have been substantially reduced.

d. The cost for compliance for small manufactu rers must be spread out across a s ubstantially less unit

volume (less than a hundred units) compared to high volume (thousands of units) type units.

(II) The savings in operating costs throughout the estimated average life of the product in the type (or class)

compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the products

which are likely to result from the imposition of the standard

a. The increase d cost cannot be recovered in a reasonable period of time (3 years ) based on current electric

rates from around the country and the amount of cooling hours.

b. In many locations the recovery of the higher costs may take 10 to 15 years or more on a unit with a

projected lifetime of 15 years. It must be noted that due to the nature of commercial unit applications, a

unit lifetime may actually be before any recovery of the energy cost savings is achieved.

(III) The total projected amount of energy savings likely to result directly from the imposition of the standard

a. The estimated to tal market of the horizontal double

- duct type air conditioners represents approximately

< 0.01% of the total air conditioner market.

b. The increased efficiency level for these units does not have any measurable impact on the national

electrical energy con sumption.

(IV) Any lessening of the utility or the performance of the products likely to result from the imposition of the standard

a. The size of the equipment has grown substantially due to the higher efficiency requirements and the

available technology to achi eve the efficiency. (See sketch 1)

b. The larger size means that the units cannot fit into the same space where they once did.

c. Like

- for

- like replacement is not possible in many situations.

d. The renovation and replacement market, which is where a high majority of these units are applied, have

more stringent / restrictive application parameters versus new construction.

e. The larger sizes of units above 8

- ton are no longer available. The smaller 1 and 1

- 1/2 ton models are also

no longer available.

f. A categorization of “space constrained” should be considered. These units when placed above a drop

ceiling are competing for space with duct work, water piping, electrical services, communication cabling,

fire sprinkler systems, etc. Additionally, getting the units into th e space is also an additional parameter

under space constrained considerations.

(V) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to

result from the imposition of the standard

a. United CoolAir is aw are of one manufacturer that stopped producing the horizontal double

- duct units

because of the higher energy efficiency requirements.

b. The increased cost of these units versus other types of equipment, that is not as well suited to the

application, reduces the competitive nature of business.491 E. Princess Street • York, PA 17403 • 717

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c. No major manufacturer makes these types of products so the entire customer base is dependent upon

small manufacturers to fulfill the needs.

d. Small manufacturers do not have their own test facilities. As a result, they are limited as to what testing

they can get accomplished based on available resources versus what the major suppliers can accomplish

using their in

- house testing capabilities and resources.

(VI) The need for national energy conservation

a. See (III) above

(VII) Other fac tors the Secretary considers relevant

a. Cabinet size limits, condenser coil size requirements and the use of a centrifugal blower on the

condenser air side represent the key items that differentiate these units from other air conditioners and

what makes it d ifficult to achieve parity of efficiency.

b. Need to consider that due to the loss of specific capacities and the inability to get replacement units into

the same space, repairs are more likely to result rather than a replacement with a unit that is more

effi cient.

c. Small manufacturers typically do not have the access to newer technology required to make the units

more efficient at a reasonable price. Thusly, the small manufacturers are more dependent upon vendors

to be able to provide the components required t o achieve the performance levels.

d. Some of the newer technologies, such as one type of heat exchanger, require more testing of more units

due to the lack of accurate computer performance modeling. As noted above

, the small manufacturers

have fewer testing r esources available and the costs would go up even more for outsourced testing.

e. One of the newer technologies required to achieve the higher efficiency levels and keep the unit size

small, is not currently available from any US manufacturers.

f. Vendors that p rovide a key component to the small manufacturers could not justify the new technology

until 2014.

g. Commercial units are typically used more (higher run hours) during the year than residential models.

Therefore, there is less of a seasonality consideration. Having a rating standard for these types of units

as an EER target instead of the SEER type target would lessen the amount of testing required for the

small manufacturers.

h. Standards have been developed or created based on the high volume type units that a re configured with

outdoor propeller air movement for the condenser / condensing section. The indoor condenser /

condensing sections must use a centrifugal blower to handle the increased pressure drop of the coil

configuration , louvers and duct losses asso ciated with this type of product. This difference in technology

has not been taken into account when establishing “one size fits all” efficiency levels.

i. All the existing test standards for the industry are based on the outdoor propeller technology. This fo rces

the centrifugal technology type units into being tested at a point where they were not designed to operate.

j. Max

- Tech refers to the maximum technology that can be employed to achieve the highest energy

efficiency. The actual level of efficiency is belo w the max

- tech level. It is our belief that for the horizontal

double

- duct units the max

- tech level where the unit size and character changes and utility is lost, is less

than 11 EER. We would propose an EER level of 10 be set for the horizontal double

- duc t systems (single

phase and three phase).

k. Some might argue that this would represent back sliding for efficiency. Our position on this is that the

rules and standards have all been written around an “outdoor” unit. A single all inclusive rule does not and

cannot encompass all the unit types. Since these units are located indoors, a separate product category

should have been created to support this product type. Efforts are under way to get the testing standards

updated to include these types of units.

l. Simi lar type units currently exist as vertical, floor mounted, ducted condenser, style configurations in the

SPVAC Product Classification with Energy Efficiency Levels of 9.0 EER (< 65 MBH), 8.9 EER ( ≥ 65 MBH

and < 135 MBH) and 8.6 EER (≥ 135 MBH and < 240 MBH). ASHRAE 90.1

- 2013 has proposed raising

the efficiency level of these units to 10 EER for all capacities.491 E. Princess Street • York, PA 17403 • 717

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## Request for Double

- Duct Air

- Cooled Air Conditioners

A. Exempt the double

- duct units until:

a. The applicable industry standards are changed to include the ducted condensing sections.

b. The verbiage in all the Federal rules and regulations is changed from describing systems solely with or as

“outdoor units”

.

c. Establish a new product class

– “Ho rizontal Double

- Duct Air

- Cooled”:

1. Capacity range should cover all units < 180 MBH.

2. Product class should include both single phase and three phase units.

3. Units are horizontal indoor configuration only.

4. Efficiency level should be the same for the single pac kage and the split systems.

5. Set the efficiency level at 10 EER for all sizes and electrical power source.

B. Target 1/1/2016 to have the above accomplished.