UNITED STATES OF AMERICA

+ + + + + DEPARTMENT OF ENERGY

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SMALL DUCT, HIGH VELOCITY (SDHV) STANDARDS (EE-RM/STD-02-330)

PUBLIC WORKSHOP

+ + + + + FRIDAY, DECEMBER 13, 2002

+ + + + + The workshop came to order at 9:00 a.m. in the Room 1E-245 of the Forestal Building, 1000 Independence Avenue, N.W., Washington, D.C., Dennis Clough, Facilitator, presiding. Present: Dennis Clough, Facilitator Bryan Berringer, Department of Energy Thomas DePriest, Esq., Department of Energy Michael Bowers, Esq., Department of Energy Mike Raymond, Department of Energy Maureen Murphy, Department of Energy Michael J. McCabe, Department of Energy Brian Dougherty, NIST Nii Addy, USEPA Energy Star Dan Arnold, York International Karim Amrane, Air-Conditioning & Refrigeration

Institute Donald M. Brundage, P.E., Southern Company Services,

Inc. Timothy J. Corcoran, Intertek Testing Services Brian Dougherty, NIST Ron W. Graves, Mestek, Inc. Scott Intagliata, Unico, Inc. Floyd J. Lewis, Mestek, Inc. Aristotle Marantan, Navigant Consulting

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.comPRESENT: (CONT.) Craig Messmer, Unico, Inc. James Mullen, Lennox Industries Karen B. Meyers, Rheem Manufacturing Company Mark A. Nunn, Manufactured Housing Institute Douglas F. Patterson, Aspen Manufacturing Hung M. Pham, Copeland Corporation Stefano Ratti, Navigant Consulting, Inc. Michael C. Rivest, Navigant Consulting, Inc. Gregory Rosenquist, Lawrence Berkeley National Terry Small, Vortex Lou Sullivan, Carrier Corporation Russell Tharp, The Excel Comfort Systems, Inc. Darren Warnecker, Rheem Manufacturer Richard Ziebol, American Standards

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com3 I-N-D-E-X Introductions & Welcome . . . . . . . . . . . . . 4 SDHV Standards (EE-RM/STD-02-330)

Engineering Analysis . . . . . . . . . . . 16 Life-Cycle Cost Analysis . . . . . . . . . 31 Discussion of Comments/Issues . . . . . . . . . . 39 Wrap-up and Workshop Conclusion for SDHV

Standards . . . . . . . . . . . . . . . . . 91

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 P-R-O-C-E-E-D- I -N-G-S 9:05 a.m. FACILITATOR CLOUGH: Good morning, everybody. My name is Dennis Clough. I'm with Aspen Systems. I will be facilitating today. Just to make sure you're in the right room, this is the Small Duct, High Velocity System Standards and Central Air Conditioner Test Procedure.

Very briefly, I'll go through the agenda in a little more detail. It's actually, you'll see, very simple. We're actually running today two separate workshops, one in the morning and one in the afternoon, because the topics are connected, but unrelated. Let me introduce Mike Raymond from the Department of Energy, who is going to provide us overview information.

MR. RAYMOND: Good morning. I'm Michael Raymond, Project Manager for the Central Air Conditioners here at the Department of Energy. I am presiding officer for this public workshop. Dennis Clough will facilitate and set the guidelines for conducting the workshop. Others joining me today are Bryan Berringer, Team Leader; Michael J. McCabe, Program Manager, who is not here yet; Mike Bowers and

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Tom DePriest from the Department's Office of General Counsel; and Mark Fredericks, also not here yet, from the Department's Office of Policy and International Affairs. Providing technical support for today's public hearing are Michael E. McCabe, Stefano Ratti from Navigant Consulting; Greg Rosenquist from the Lawrence Berkeley National Laboratory; Brian Dougherty and Peter Nomansky from the National Institute of Standards and Technology.

Providing administrative support for today's public hearing are Maureen Murphy, Brenda Edwards, John Sandibell and Crystal Branson, all from the Building Technologies Program.

On behalf of the Department, I would like to thank you all for taking the time to participate in this public hearing.

In the Notice of Final Rulemaking published on May 23, 2002, DOE established amended energy conservation standards for all classes of residential central air conditioners and heat pumps, except small duct high velocity systems. In that final rule, DOE created a separate product class for SDHV systems, but it deferred establishing amended standards pending completion of a new test procedure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and the analysis needed to support new standards. And in the afternoon, this workshop is also being held to consider additional revisions to DOE's test procedure for central air conditioners and heat pumps. The final rule for the comprehensive revision of the central air conditioner test procedure is expected to be published next spring. In that rule, specific issues were identified to be addressed in the new rulemaking and this workshop is part of that new rulemaking.

We have chosen the format for today's public workshop to present technical and cost information, analysis methodology, assumptions and preliminary results for public discussion and comment. Notice published in the Federal Register on October 28th announced today's rescheduled public hearing and the extension of the comment period to January 8, 2003. The Department also sent announcements by e-mail and conventional mail to organizations and individuals who might have an interest in this rulemaking. As stated in the Federal Register notice, it invited any person who has an interest in these rules or who is a representative of a group or class of persons that has an interest in these issues to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1

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request an opportunity to make an oral presentation. We also requested each person wishing to be heard to submit an advanced copy of his or her statement. Those statements received in time, we are providing attendees with copies.

The Department seeks comments today on the assumptions and methodology for the small duct, high velocity analysis and on the specific test procedure issues under consideration here, especially the issue of revised default values for the cooling mode cycle degradation coefficients and any other issues considered pertinent by the interested parties.

The agenda for today's hearing is structured to allow each participant to make a general statement limited to five minutes prior to the discussion of the specific topic. The general statement need not address these specific topics, but may cover any other issues pertinent to this rulemaking. The Department will permit other participants to comment on any general statements. The comments received here today, along with comments submitted in writing, will assist the Department in continuing its standards and test procedures rulemaking. Anyone attending this workshop who are

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submitting written comments will be added to our list for future mailings.

We post new items to our website and we announce this by sending e-mail messages to our list our attendees from previous hearings. For those of you without e-mail, it is important that you inform us and we will mail the announcements to you.

All materials relating to this rulemaking have been posted on our website. Anyone wishing these materials and who do not have access to the Internet should let us know and we will make other arrangements to provide them with electronic versions of the web materials. Before turning the meeting -- well, here's the handout package. We've got a couple of yellow sheets on top of the agenda and some general information. Comment deadline, the address to send for comments and we would prefer Word Perfect 6, 7, 8, 9 or 10, but you can also use Microsoft Word or PDF files. Please reference the docket number which is on there. I don't need to read that.

Without the required electronic signature, you must also submit a signed original paper document by mail. Telefaxes will not be accepted. Anyone

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submitting information that he or she believes to be confidential, exempt by law from public disclosure should so indicate.

In accordance with the procedures established in the CFR, the Department of Energy will make its own determination as to whether the information shall be exempt from public disclosure.

Anyone attending today or submitting written comments will be added to our mailing list for future notices. Following those yellow pages, there's a copy of the Federal Register announcement of this public hearing.

In about two weeks, the complete copy of the transcript will be available in the Freedom of Information Reading Room down the hall from here in Room 190, telephone 202/586-6020. Anyone wishing to purchase a copy of the transcript may make arrangements with the Court Reporter here today.

Next in your handout package is a list of organizations in alphabetical order from whom we received comments and statements for presentation of today's hearing. Following the list is a copy of each statement. The workshop is scheduled to adjourn today at 4 o'clock. Actually, the second portion will

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adjourn at 4 o'clock. The first portion should be over at noon, unless we finish early.

Topics which have not been completely discussed by that time can be addressed in additional written comments which are due by January 8, 2003.

Again, we appreciate the time and effort you have taken in preparing for this public hearing and we are pleased to receive your comments and opinions. Our purpose today is to listen to your views. Do you want to do the housekeeping now or do you want me to go through the slides? Okay.

We are now at the point of the public hearing set aside for more in-depth discussions. This morning we are presenting the engineering and life-cycle cost analyses for revising the small duct, high velocity air conditioners efficiency standard. This afternoon we will discuss revisions to the residential central air conditioner test procedure.

NEACA set factors for economic justification of any new or amended standard to determine whether the benefits of the standard exceed its burdens by considering the seven factors listed on this slide. 25 II For SDHV air conditioners, we have focused

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on the second factor, life-cycle cost savings to determine the standard level we would like to propose. The fourth factor, lessening of utility, is also very important here. The reason they are a niche product is that they have a utility that is not as well served by the mainstream products and we should not set a standard level that would cause a lessening of that utility. The other factors, we rely chiefly on the justification presented in the final rule in TSD. Here they are. Thank you.

The second and fourth factors that we mainly considered have an asterisk after them, the life-cycle cost savings and the lessening of utility.

DOE has identified niche products as serving applications with severe space constraints that would make it significantly more difficult for them to meet higher efficiency standards. In the January 2001, the 13 series final rule, SDHV systems which do not meet the space constraint definition were expected to meet the 13 series standard, but were given a significant efficiency boost by a modification of the test procedure.

In the May 2002, the 12 SEER final rule, the test procedure boost was gone and SDHV systems NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12

were made a separate product class with the NEACA 10 standard series retained pending further study to establish appropriate efficiency levels.

This is the definition of SDHV systems which was established in the May 2002 final rule. These are the standards established in the May 2002 final rule. The SDHV standards were not changed from the NEACA values, but were subject to amendment. The amendments which we are now discussing.

Now we are about ready to get down to business. In today's workshop, we will present the key assumptions and analysis results that will be used to establish a new standard level for SDHV systems. There are two major analysis categories, the engineering analysis and the life-cycle cost analysis.

The engineering analysis develops a relationship between consumer costs and SDHV system efficiency. The life-cycle cost estimates the economic impact on consumers over the life of the equipment, balancing the savings from higher efficiency against the added cost of more efficient equipment. Here's the schedule for this rule. We have the workshop today, a deadline for submitting comments is January 8th. We expect to publish the

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com13 1 supplemental NOPR in April 2003 and the final rule in 2 October of 2003. 3 I'll turn it back to you, Dennis. 4 FACILITATOR CLOUGH: Thanks. Before I 5 hand it over to Michael and Greg for the technical 6 presentation this morning, a couple of simple 7 k i thi

h ng ngs. ouse eep 8 All of you have the agenda in front of 9 you. Very simply, the morning and the afternoon will 10 be about an hour of technical presentation. We'll 11 take a break and then have about an hour of open 12 discussion. That's the basic format. 13 A bit more housekeeping, restrooms, out 14 the door and to the left, end of the hall. At the 15 break if any of you are looking for a snack, it's 16 actually on the ground floor on the E corridor which 17 is the one out here. So it's really directly 18 underneath us and you can get there either by the 19 elevator or from the stairs at the end of the hall or 20 the escalators out near the front door. 21 One last thing, let's go around the room 22 and have everybody introduce themselves, your name and 23 where you're from and that will be great. 24 MR. MESSMER: Craig Messmer with Unico. 25 MR. INTAGLIATA: Stewart Intagliata with 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Unico. MR. AMRANE: Karim Amrane, AirConditioning & Refrigeration Institute.

MR. MULLEN: Jim Mullen, Lennox International.

MR. THARP: Rusty Tharp, the Excel Comfort Systems.

Corporation.

Standard. MR. SULLIVAN: Lou Sullivan, Carrier

MR. ZIEBOL: Dick Ziebol, American

MS. MEYERS : Karen Meyers, Rheem Air Conditioning.

MR. WARNECKER: Darren Warnecker, Rheem Air Conditioning.

MR. ARNOLD: Dan Arnold, York International.

MR. SACHS: Harvey Sachs, American Council for Energy Efficient America.

MR. LEWIS: Floyd Lewis, Mestek Company. MR. GRAVES: Ron Graves, Mestek. MR. McCABE: Michael E. McCabe, Navigant Consulting.

Energy.

(202) 234-4433 MR. RAYMOND: Mike Raymond, Department of



### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 15 MR. BERRINGER: Bryan Berringer, Department of Energy.

MR. BOWERS: Mike Bowers, Department of Energy, General Counsel's Office.

MR. MARANTAN: Aris Marantan, Navigant Consulting.

Consulting. MR. RATTI: Stef Ratti, Navigant

MR. NOMANSKY: Peter Nomansky from the National Institute of Standards and Technology.

MR. ROSENQUIST: Greg Rosenquist, Lawrence Berkeley National Laboratory.

MS. MURPHY: Maureen Murphy, Department of Energy. MR. DePRIEST: Tom DePriest, Department of Energy, Office of General Counsel.

MR. PHAM: Hung Pham, Copeland Corporation.

Consulting. MR. RIVEST: Mike Rivest, Navigant

MR. DOUGHERTY: Brian Dougherty, NIST. MR. CORCORAN: Timothy J. Corcoran, Intertek Testing Services.

MR. BRUNDAGE: Don Brundage, Southern 25 11 Company.

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. CARR: Brian Carr, Department of

Energy. *: Department of Energy. * Institute. FACILITATOR CLOUGH: If there is anyone on the phone, will you introduce yourself, please?

MR. SMALL: Terry Small, Vortex Products. FACILITATOR CLOUGH: Thank you very much. Let me hand it over to Mike McCabe from Navigant Consulting. A couple of things to keep in mind for the day, please, because this is being recorded, when we get into open discussion, I'd like all of you to say your name before you make your comment so that the Court Reporter can capture it accordingly.

And also, the format for this morning, Mike and Greg will be doing the presentation. I'd like you to limit your questions during and directly after the presentations, the questions that are to clarify the content that you hear. We're going to have an hour afterwards to have discussion about whether you agree or disagree with what you heard and to have something that's more substantial afterwards, but that will help us keep the presentation as clear and brief as possible. 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Thanks. MR. McCABE: Thank you, Dennis. I'd like to begin this part of the presentation by acknowledging the participation of the two SDHV manufacturers, both who are here today and also to thank my former colleagues at NIST for their review and their valued comments.

Another contributor is Joseph Peach who is a consultant to Navigant and who assisted with the calculation methodology.

As was previously mentioned, the engineering analysis develops the relationship between the system, SDHV system efficiency and its cost. The details of the engineering analysis are presented in this draft report which was posted to the DOE website and it's in the handout package. We hope that everyone has had a chance to review it.

For the presentation this morning, I'm just going to cover the highlights of the engineering analysis. SDHV manufacturers have limited means at their disposal to increase the system efficiency. Because of the small market size, we believe that it's unlikely that they can influence the design of condenser units which are paired with the SDHV blower

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 coils. So in this charge we summarize the two

options that we have looked at in detail. The first one is to pair the SDHV blower coil with a higher SEER condensing unit and the second option is to simply enlarge blower coil.

Of course, there are other options such as say a more efficient blower motor and these options are discussed in the draft engineering analysis report, but at this workshop we're just going to focus on these two options.

As stated previously, an increase in the minimum efficiency must be economically justified. One of the economic justification factors is consumer life-cycle costs. And this chart shows the steps in the engineering analysis that leads to the cost efficiency relationship. The cost efficiency relationship then is fed into the life-cycle cost analysis which will follow this presentation.

So for each of these two options, these two design options, we have to estimate two things. We have to estimate the effect of these changes on efficiency and then we have to estimate the impacts of each of these changes on cost. And we then have to combine these cost and efficiency relationships into

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a relationship which is then input into the life-cycle cost. In the next group of slides, I'll first present the efficiency, how we calculate the efficiency methodology and the assumptions and then we'll describe each, the way we estimate the costs for each of these options. And then I'll conclude by presenting this cost versus efficiency curve.

To understand how we estimate impacts of these SDHV options on efficiency, we need to provide some background on how manufacturers rate unitary equipment which consists of two distinct components, an outdoor unit and an indoor unit.

This chart presents some general information on rating split systems. Of course, the performance of the system depends on the design features of each of the components. For the air conditioning applications, the system, the outdoor unit is the condensing unit, of course, and the indoor unit is an evaporator coil.

The indoor unit might be equipped with its own blower or it might be designed for installation with a furnace in case it uses the blower coil that comes with the furnace.



### Now there are many possible combinations

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of evaporator coils and condensing units. The Department of Energy requires that the system manufacturers test -- establish by testing the performance ratings for the combination that has the highest sales volume and that is called the -- this is the matched system. For all other combinations, then manufacturers can choose an alternative rating method. This is then called the mix system.

Now DOE accepts the use of an alternative rating method developed by the National Institute of Standards and Technology, specifically for performance rating of mixed systems. This morning, we're not going to discuss the NISI method here, but the details are well known to industry and they are summarized in the draft engineering analysis report.

What we are going to discuss here is how we use the NISI method for the purposes of the small duct, high velocity rulemaking and what are the specific assumptions?

This chart shows the two key formulas and assumptions that we need to specialize the NIST rating method for SDHV systems. The formulas used in this subscript notation where the subscript M is for the matched systems and the subscript X is for the mixed or SDHV systems. The first major assumption here is HEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com21 1 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 the formula which estimates SDHV blower power. Simply

stated, SDHV blower power is related the fan efficiencies and to the work done by the blower motors on the airstreams.

For the matched indoor blower power, we've assumed the default value of .365 watts per CFM. We've assumed the blower motor efficiency is 0.45 and we assume that the mixed blower motor efficiency is 0.65. Those are the assumptions to the fan power. Second explicit formula is the formula for calculating the indoor coil factor F, Indoor coil scaling factor per F,, a parameter that relates the cooling capacities of the mixed and matched indoor coils in the NIST rating method.

We assume here that Fc varies as the square foot of the CFM ratio and the indoor coil volume ratios where coil volume is the product of the face area and the number of rows.

As we have stated in the draft engineering analysis report, the formula for F, is empirical and it's based on -- so it's based on rules of thumb. And we would like to have your comments on these assumptions. 25 11 We now need to estimate the costs

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associated with increasing the efficiency of the SDHV system by pairing with a more efficient condensing unit. We assume that SDHV manufacturers are limited in choice to available condensing units at 12 CF 13 SEER and 14 SEER efficiency levels.

12 SEER is the minimum available after 2006 and 14 SEER is the practical limit for single speed technologies that are suitable for the SDHV systems. 

### Now in the technical support document for residential central air conditioning rulemaking, DOE developed detailed cost estimates for systems manufacturers who produced 3-ton split system air conditioners which ranged in efficiency from 10 to 15 SEER. The systems cost data assumed that the standard was set at each level, each SEER value and thus the costs reflected high volume of production.

Now the TSD provided separate costs for each -- for the blower coil unit and the condenser unit. They were broken down into direct labor and materials. The TSD also had another category, a category called "other" which included indirect labor, materials, depreciation, utilities, taxes, freight, etcetera. So at the 12 SEER standard level, in the

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technical support document for the residential air conditioning, the ratio of cost, the condensing unit was 78 percent and the blower coil cost was 22 percent of the direct labor and materials costs.

This table provides the basis for estimating the price paid by consumers for a 3-ton condensing unit at efficiency levels of 12, 13 and 14 SEER, using the system cost data in the technical support document. So for each condensing unit, we added 78 percent of the other cost category to the direct labor and materials cost of the condensing unit to determine the total production cost.

For the 12 SEER unit, we assumed the same markups as in the residential central air conditioning rulemaking to arrive at the price paid by the consumer for the condensing unit. The 12 SEER condensing unit is assumed to cost the consumer $845. Manufacturing cost estimates for the condensing unit systems 13 and 14 SEER had to be adjusted upward to reflect higher production costs due to lower sales volumes.

We also assumed that manufacturers marked up the premium models to generate higher gross margin percentages than the high volume baseline efficiency models. So we adjust the production costs for the 13 and 14 SEER units by 5 and 10 percent, respectively, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to account for lower volume and added features. We also assumed the system manufacturers mark up the 13 and 14 SEER equipment differently. All the other markups, the distributors, contractors, sales taxes are independent of efficiency and are assumed to be the same as previously used.

DOE would like to receive comments on these cost estimates, how reasonable they are on the estimates on the markup assumptions.

We now need to estimate the cost for increasing the SDHV coil size. And as coil size increases, there's more materials, there's more labor that's needed and of course, so the cost increases. Because we're dealing with confidential cost information from the SDHV manufacturers, we cannot provide estimates at the level of detail that we gave for the condensing units. So all of the costs versus efficiency results we generated for the blower coils are provided at the consumer level.

Since the SDHV coil sizes arealready four or six rowdesigns, we assume that by increasing coil size we essentiallymean an increase in the face area. So as we increase the coil face area, the cabinet size must also increase, the cabinet insulation must increase and the drainage pans must also get larger.

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Pause.) Assuming that the baseline SDHV coil size, SDHV coil has a coil size of about -- by coil size we mean face areas times rows, we estimate that the consumer costs for the baseline unit is about $1200. We also assume that the cost to the consumer varies in the linear manner with coil size, over the range of 8 to 20 which is the approximate range for products that are in the marketplace today.

The engineering analysis efficiency and cost relations are combined in an Excel spreadsheet which has been posted to the DOE website. The spreadsheet allows a user to change many of the assumptions used to generate the efficiency and cost relationship and to view the results.

We'd also like to request any comments on the usefulness of this spreadsheet.

The engineering analysis has to consider a range of SDHV system efficiencies. These vary from the baseline system to one that achieves the highest efficiency level that is technologically feasible. A baseline SDHV system is one that just meets the current standard and for that we assume a baseline system has a small SDHV coil and is matted with a 12 SEER condensing unit. This results in an SDHV system NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that has a 10 SEER efficiency. We assume that the MaxTech system has the largest SDHV coil currently available in the market and is mated with a 14 SEER condensing unit. The MaxTech is estimated to have an SDHV system efficiency of 13.4. This chart here shows the general shape of the minimum costs versus efficiency curve for SDHV systems. The actual points of the curve are given in Table 5 of the draft report. And the cost is the incremental equipment cost paid by the consumer to increase SDHV system efficiency from -- and it varies from the baseline to the MaxTech.

Now each point on this curve represents our best estimate of the combination of coil, size, system capacity and condensing unit efficiency that minimizes total equipment cost. The bumps in the curve represent changes to the condensing unit, so we start out with a 12 SEER and it's lower cost to increase the coil size until we hit his point and at this point we would put a higher efficiency condensing unit and drop back in coil size. And then follow this projectory. But the coil -- based on our assumptions of condensing unit costs, the least cost projectory to follow is this. Coil size hits this point and then

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boosts it here, full size again, hit a point and then go to the 14 SEER condensing unit. And this is how you get up to the MaxTech. And you can see that the equipment, the incremental cost of doing this is about $1200. The solid line here represents the mean costs - Harvey?

MR. SACHS: Harvey Sachs. Just one clarification question on Slide 22. The curve looks strictly monotonic, meaning there's no point where it dips down below an earlier point. Is that true?

MR. McCABE: Yes. What we've done is -- and if you use the spreadsheet, the spreadsheet shows how you construct -- how these curves overlap and if you were to project a 13 SEER condensing unit backwards, you would find that cost -- there's points on the curve which we haven't shown because this represents the minimal cost that we could conceive.

MR. SACHS: Thank you, sir. MR. McCABE: Okay, the solid line represents the mean values, the mean costs and the dashed lines represent the uncertainties and the variabilities in these costs.



### The details are all given on the draft

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engineering analysis report and that's on the DOE website and in your handout package.

Now -- yes? MR. MULLEN: Jim Mullen, Lennox. A question for you to make sure I'm grounded in the right place here. When you're talking about SEER in these slides, are you talking about SEER as the unit would be rated to the current test standard or to a test standard that might be proposed at a higher static? What is my baseline --

MR. McCABE: The baseline is the proposed -- the test standard for the SDHV definition, the 1.2 inch static pressure.

MR. MULLEN: Saying that a different way, would these ratings match the ratings that are in the ARI Directory now or would they match the ratings under a proposed standard that we're going to talk about this afternoon?

MR. McCABE: I can't answer that. Maybe one of our manufacturers could tell.

MR. GRAVES: Well, the current baseline is the 10 SEER, so these numbers will represent what are presently manufactured. These would match. They are the readings, yes.

MR. McCABE: Are there any other questions

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on the presentation so far? Yes? MR. ZIEBOL: Dick Ziebol, Trane. What are the assumptions for matched system indoor fan power at 14 SEER level?

MR. McCABE: The matched system indoor fan power at -- it's the same for all condensers. We assume the default.

MR. ZIEBOL: Default? MR. McCABE: Yes. MR. ZIEBOL: I think most of those reached 14 at variable speed. *

MR. McCABE: Well, we would like to get comments on how -- on these assumptions, but that is the assumption and if -- we would like to get that feedback from you. If that's not a valid assumption that the default values are probably not suitable for one of these conditions and what suggestions might be more -- might be better.

Are there -- if there are no more questions then I'd like to turn the meeting over to Greg Rosenquist who will present the life cycle cost analysis. MR. SACHS: Harvey Sachs again. I thought I understood up to that point and I'd just like to ask for clarification from Trane. The net effect of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4

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change for the SEER 14 condensing unit would be to say SEER 14 condensing unit and variable speed lower which would raise the cost of the mixed unit uses of the matched unit uses comparison and therefore lower the incremental cost for the SDHV unit?

MR. ZIEBOL: I would say primarily of the highest obtainable SEER *

MR. SACHS: I understand. MR. ZIEBOL: The relative relationship between the matched and mixed system * at the 14 level I think are probably not correct because * system. MR. SACHS: Thank you.

MR. McCABE: We're not certain that an SDHV manufacturer would match a variable, a 14 SEER condenser whose rating is based on variable speed with the fixed speed blower coil, although it's not clear to us -- MR. ZIEBOL: They operate at fixed speed. It's a single speed unit, but they use a variable speed * for some of these applications because if they have lower fan watts than default.

FACILITATOR CLOUGH: We can discuss this in some more detail if we need to in the open discussion.

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MR. McCABE: These are assumptions. MR. MULLEN: That's good. Now what was the basis for the assumptions?

MR. McCABE: Well, the assumptions are that the -- they are stated in the draft engineering analysis report and they are -- I think we'd like your comments on them, but they are assumptions.

MR. MULLEN: The comment would be I'm not sure I understand why those two efficiencies should be different. MR. McCABE: Okay.

MR. MULLEN: I'm not sure they're different type. It seems to me they're similar motor type and similar application.

MR. McCABE: The short answer is that the efficiencies from the -- the fault fan towers are fairly old based on furnaces and designs from many years ago and the assumption is that those furnaces had less -- used the older technology motors which were less efficient and .45 is the number that we are proposing as the basis for that default fan power. 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.neairgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 FACILITATOR CLOUGH: Jim, we'll have some time to discuss that. I'll make sure that I bring it back up in open discussion.

MR. ROSENQUIST: Thank you, Mike. Can you all hear me okay with the microphone, my voice? Excuse me for the scratchy voice, but a couple of days of meeting and coming on the airplane, I think I may have picked up a little something, but I'm here to talk about the life-cycle cost analysis. My name is Greg Rosenquist, Lawrence Berkeley National Laboratory. In the analysis that we conduct is basically identical to what we did for the conventional products, the ones that received the 12 SEER rating in May 2002 final rule.

And what we're doing here is we're performing his life-cycle cost calculation on a building by building basis on a representative set of residential and nonresidential buildings. The residential buildings come from the 1997 Residential Energy Consumption Survey, about 1200 buildings which we've identified. The nonresidential buildings are coming from an analysis done for the ASHRAE 90.1 standard and there we have 77 nationally representative buildings.

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 So again, we're doing the life-cycle cost calculation on a building by building basis by sampling from this building set, so we can get a distribution of life-cycle cost results.

We're using a technique called the Monte Carlo simulation where we're using an add-in called Crystal Ball to Microsoft Excel and this spreadsheet is available on DOE's website for you to work from.

In addition to doing the simulations, you can also do a sample count based on average values to get an indication of the life-cycle cost of going to increased efficiency.

A lot of you have probably seen this before. It gives an overview of all the inputs that go into the life-cycle cost calculation. On the top of the inputs for the total installed costs. Those all come from the engineering analysis, the equipment price which Mike just spoke of. There's an installation cost for the equipment and there's also a separate cost for the total installed cost of the ductwork. All those together come up with a total installed cost of the SDHV system.

On the bottom are the inputs for the operating costs, this is the energy consumption which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 34

are drawing from these representative set of buildings. That's tied to the equipment efficiency which with the electricity prices will be an annual energy expense. Then with the repair costs and maintenance costs, we go to annual operating expense, that's turned into a lifetime operating expense by using lifetimes, a lifetime discount rate and electricity price trend. So together, you get the life-cycle cost.

Now each one of these inputs for the most part are characterized with the probability distributions. So we're actually sampling not with a single -- we don't use a single point value. We're actually sampling from a distribution of values that we've characterized for each one of these inputs.

So most of the inputs that we're using in the analysis are drawn straight from the analysis that was done for the conventional products with the exception of these four. The first one being the consumer equipment prices which Mike just spoke of. The second being that we're adding this additional cost for the ductwork and that's $2,720. We're using electricity price transferred from the most recent annual outlook that's the EO 2002. And we're using repair costs that are specific to the SDHV equipment.

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 35 I just want to add too, that we do have a separate installation cost for the equipment and that's coming from the conventional product analysis.

So this summarizes all the inputs we're drawing from the conventional product analysis. The source of the information is identified in the technical support document for the conventional products and gives the specific section which the inputs are described.

What I'm providing here are the weighted average values. Again, we're using a distribution of values, but having an idea of the magnitude of the value, I think is helpful. And so going down the list, we're assuming that the percent of units used in commercial applications is 10 percent. This is actually a fixed value. This doesn't have a distribution.The equipment installation cost has a weighted average value of $1390. The baseline energy consumption, we characterize for both the residential set of buildings and the commercial. The combined value, when you weight it properly, you get just over 2300 kilowatt hours a year.

The average electricity price is 9.36 cents per kilowatt hours. The marginal is 9.11 cents

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This is the same figure that Mike presented earlier on the consumer equipment price, but with the addition of adding a total duct installed into the cost as well as the installation for the equipment price. And that's the higher cost you see there. They basically parallel each other, but again that difference is through the installed cost of the ductwork and the installation cost for the equipment. It goes up to as high as $7500 at 13.4 SEER.

So this is the first sort of results I'm showing you here and giving you example for the 10.82 SEER level and again the nature of this analysis is that it produces a distribution of results again, because we're sampling from this representative set of buildings as well as these inputs, these probability distributions that we've created for the inputs.

And here, shows you the percentage of consumers are actually benefitting from the standard increase to go from a baseline 10 SEER to a 10.82 NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODEISLAND AVE., N.W. (202) 234-4433 WASHINGTON,D.C. 20005-3701 www.nealrgross.com1

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SEER. Blue indicates those consumers who are realizing life-cycle cost reductions or life-cycle cost savings. The red indicates those consumers who are incurring a life-cycle cost increase due to the efficiency level increase.

And so the mean impact from this distribution is an LCC cost increase of $64. And only 23 percent of the sample has life-cycle cost savings. And there, you also see the range of values going out to a savings of $1600 to a cost of just over $280.

So looking at the results in this fashion certainly doesn't look like that this is a viable efficiency level for SDHV.

We performed this sort of analysis on all these efficiency levels out to 13.4 SEER. The blue line indicates the mean life-cycle cost for each efficiency level. And you can see that's fairly flat through 10.5 SEER and then it starts ramping rather quickly after that point.

The red line indicates the percent of consumers who are realizing LCC savings, are moving to the higher efficiency level. And even at the smallest efficiency increase that was analyzed, a minority of the consumers are realizing LCC savings. A majority are actually being negatively impacted by the

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com38 1 standards increase. 2 Now something that we did for the 3 conventional product analysis we're also doing here 4 for the small duct, high velocity product analysis. 5 And that's that we're categorizing consumers into 6 those who are insignificantly impacted and those who 7 are either significantly -- getting significant net 8 savings or significant net costs. And we're doing 9 that by using this 2 percent threshold concept, 10 meaning that 2 percent is 2 percent of the baseline 11 life-cycle cost and in this case, baseline is 10 SEER 12 and its life-cycle cost is over $9800. So the 2 13 percent value then becomes approximately plus or minus 14 $200. So any consumers who are incurring a cost 15 within $200 or savings within $200 are considered to 16 be insignificantly impacted by the standard. 17 And so what I'm showing you here is that 18 same distribution of results for 10.82 SEER, broken up 19 into the subsets of consumers. 20 In the yellow, it indicates those who are 21 insignificantly impacted. And it's a majority of the 22 consumers in this case, 78 percent. You only have a 23 small percentage who are achieving net savings of over 24 $200, 8 percent and those with net costs greater than 25 2 percent are 14 percent. So looking at the results

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in this fashion gives you a significantly different picture on the life-cycle cost impacts.

And we performed this calculation again on each one of the -- we divided up the results for each one of the efficiency levels we analyzed earlier. In going out to 13.4 -- and also going out to 13.4 SEER and what you're seeing here on the Y axis, the percent of consumers with significant LCC increases, that is greater than this 2 percent threshold value.

And so out to about 10.7 SEER, there are no consumers who are incurring a significant LCC increase. And then after that point it ramps up rather quickly so that by the time you get to 11 SEER, a majority of the consumers are incurring a significant LCC increase.

So again, this is a different take on looking at the LCC results and purely looking at those that are above and below the zero point.

So that's the end of my presentation. I guess we can get into comment discussion now.

FACILITATOR CLOUGH: Questions for Greg? Yes, Harvey.MR. SACHS: Greg, this is very elegant work and I just want to clarify one thing. Your analysis is quite sensitive to your estimates of the

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incremental costs of the condensing units after the new rule goes into effect. You've only analyzed it at 12, 13 and 14. So that how did you -- what sort of variability envelope did you put on those incremental costs? MR. ROSENQUIST: Those came from the engineering analysis.

MR. SACHS: Right. MR. ROSENQUIST: So I guess back on slide 22, we actually characterize each one of those increases in consumer price with a distribution of values as well. So -- does that answer your question?

MR. SACHS: Well -- MR. ROSENQUIST: Again, those prices are coming from the engineering analysis. We just took them. Maybe Stefano can clarify that.

MR. McCABE: Page 28, Table 4 of the draft engineering analysis report lists the distribution, gives the variables, the assumptions.

MR. SACHS: I'm sorry, will you repeat that, please?

MR. McCABE: Table 4, page 28 of the engineering analysis report, gives the make up of our uncertainty and variability, the components of it.

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air flow rate, CFM per ton varies from 400 to 425 and the type of distribution is assumed to be uniform. These are the components that lead into the chart that shows the solid line is based on the mean value and then the dashed lines represent the results of these variabilities and uncertainties.

MR. SACHS: Thank you, sir. (Pause.) FACILITATOR CLOUGH: Somebody's bag is ringing. (Laughter.)

We are way ahead of schedule so far which is a good thing. I want to ask if anybody has any statements that they'd like to make to the group as a whole about anything. The agenda allows for people to make five minute statements on the topic if they choose to for the record. This is an ideal time to do that if anyone would like to.

Harvey? MR. SACHS: I ask if anybody else would like to go first.

FACILITATOR CLOUGH: Would anyone else like to go, have anything to say? I think you'll start. 25 11 MR. SACHS: Thank you and all that 

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formality. I'd like to refer to a letter of Mark's draft, May 15 to Mr. Craig Messmer of Unico and Mr. Ron Graves at Mestek and basically we've discussed this issue among ourselves in the public interest and environmental community and we very much respect the fact that this is an niche product which will have limited applicability and frankly our major concerns are to make sure that there's an adequate firewall so that some creative genius at an alternative firm might not find a way to qualify a traditional low velocity product under this test measure. We're very comfortable with the 1.2 inch external static pressure rating condition.

We certainly would also accept an alternative if you all prefer it, one that's scaled to the unit capacity. Our letter makes some suggestions along those lines, but the real question that's the only other one on my mind to throw out to this group is whether the air flow requirements are tight enough. This gives an upper limit of 350 CFM per ton for the small diameter, high velocity product and certainly yield performance of conventional product is frequently much lower than that value, even though the test conditions require 350 and up.



### So if the manufacturing community is

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comfortable that we really have a good firewall between the small diameter, high velocity and conventional equipment, that will take care of our technical questions and at that point with reference to my question on the sensitivities, we simply want to see the highest efficiency, widely available condenser units used which looks to us like SEER 13 and we're certainly going to be quite flexible in terms of being overwhelmed by the technical analyses the contractors have done. Thank you.

FACILITATOR CLOUGH: Any comments to Harvey's statements? Yes.

MR. ZIEBOL: Dick Ziebol, Trane. Trane, I guess, would be more comfortable if the air flow limit were 300 or lower, but on the other hand we feel that the 1.2 static requirement is just overwhelming and is basically providing all the firewall that you need. FACILITATOR CLOUGH: Thank you, Dick. Additional comments? Please.

MR. MULLEN: Jim Mullen. I think we're comfortable with the 350. I hadn't thought about Harvey's comment though about field application. If there's a loophole out there, I'm sure somebody will

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1.2 inches. I suppose he'll want them all classified as small duct, high velocity.

MR. SACHS: I'm sorry, could you repeat that? I think I was insulted, but I didn't pick it up. (Laughter.)

I really didn't hear you. MR. MULLEN: I'msorry, I was just giving you a bad time, Harvey. I was just saying as you find more systems out there at 1.2 inches of static, you'll probably want more systems in this category. (Laughter.) MR. SACHS: We really are trying to that these niche systems -- this is Harvey Sachs again -- as long as these things are prescribed in such a way that there is a good f irewall , we certainly don't feel that we should be adding extreme costs to the desire of people in historically sensitive houses who have air conditioning instead of window shakers. I've been there. MR. BERRINGER: Bryan Berringer, DOE. Just a clarification, Harvey. You said something about 13 SEER at the very end. Are you suggesting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6

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that the condensing unit be based on 13 -- or are you saying overall rating for these high velocity?

MR. SACHS: Thank you, Bryan, this is Harvey Sachs again. I am not suggesting a SEER 13 requirement, but that the indoor units be evaluated, pieced together with the ductwork from the small diameter, high velocity manufacturers should be matched with a condensing unit characteristic of SEER 13 units because in our general sense has been that these are still nonmodulating compressors. They're still pretty much conventional technologies with relatively small incremental cost. You all certainly have better cost data that we, but that's been our instinct. We did not and this is the important point, want to try to push the manufacturers of this niche equipment into using modulating compressors and their condensing units and things like that.

FACILITATOR CLOUGH: Anyone else? Yes. MR. MESSMER: Craig Messmer with Unico. I just wanted to point out that the air flow requirements that basically was set to encompass existing product out there. That's where those numbers come from.



### MR. THARP: Rusty Tharp, Excel. This is

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com46 1 a quick comment. The pictures that were on the slide, 2 page 14, there are much better looking condensing 3 units out there that could have been used. 4 (Laughter.) 5 MR. MESSMER: So you found your niche. 6 (L ht ) aug er. 7 MR. THARP: In the calculations for the 8 coil factor the SC, I'm just curious as to what 9 consideration is given to differing condensities, 10 styles, two diameters, etcetera in that calculation. 11 MR. McCABE: This is Mike E. McCabe. 12 There is some earlier description of the assumptions. 13 It's given in the technical, in the engineering 14 analysis draft report, but basically the assumption is 15 that the matched coil and the mixed coil have similar 16 state of the art, they use similar state of the art 17 coil technology. In other words, the tubing is 18 rifled, the fins are lance, the fin spacing is 19 optimum, so the assumption that is implicit in that 20 relationship for coil Fc, that both the SDHV coils and 21 the matched system coils are very similar state of the 22 art technology. 23 FACILITATOR CLOUGH: Harvey? 24 MR. SACHS: Just to be very specific, only 25 300 versus 350 CFM and this will probably be the 

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subject of conversation or may be the subject of conversation this afternoon as well, the field data suggests that the average unit, as installed, is using more than 365 watts per thousand CFM and is seeing a higher external static than is on the standard test procedure. These do have implications for energy consumption and that was the source of my question.

FACILITATOR CLOUGH: Thank you. Any other

-- does anyone else have any statements that they'd like to make before we get into some open discussion?

I also want to encourage anyone in the back who would like to come up to the table and fill some of the empty chairs, you're more than welcome to do so as we move into this.

Let me actually use that comment about the F, equation as a segue to go into perhaps a discussion about that equation, holistically, and actually I'm going to come back to you, Jim. You had the comment about the blower motor efficiency differentiation. Do you want to later raise that again?

MR. MULLEN: Jim Mullen. I'm still not sure I understand why you should use two different blower motor efficiencies. I hear what you're saying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODEISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 48

about old furnaces, but my recollection the bulk of furnaces 15 years ago was just probably average life used a PSE motor as opposed to shaded coal and while PSE technology may have gotten a little bit better, I don't think it's changed by 20 points from 45. And I'm also not sure why you're comparing today's motor with years ago motor to do your analysis.

MR. McCABE: This is Mike E. McCabe. These are assumptions. Basically, our consultant proposed these efficiency ratios. I think in the engineering analysis report, we have some data that shows that could be used to justify the 65 percent efficiency for the SDHV motors.

Our consultant tells us that the default fan power goes back to furnaces 40 years ago, that this value has been in use by ARI for a very long length of time and it's never been changed. Now we have not taken on a massive research project to try to determine what is the best efficiency, so what we're doing is we're saying this is an assumption and if there were data that was, that could give us some indications of a better efficiency to use for the default fan power, we certainly could make that substitution and revise the analysis with that.



### It's pointed out that it's an assumption.

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us -- the thing is not to -- we didn't have the

resources to conduct the massive research project going back, trying to define this number.

MR. MULLEN: Jim Mullen again. Just for the record I invite the other manufacturers to comment, but at this point for what I understand about the analysis, I'd have to disagree with using two different motor efficiencies and say they should be the same or just a few points difference, not 20 points difference.

MR. McCABE: Okay. FACILITATOR CLOUGH: Do you have a suggestion if they were to be the same, what you think would be a more appropriate percent of efficiency?

MR. MULLEN: If they're the same, I don't think it makes too much difference. It's somewhere in that 45 to 65 band.

MR. RATTI: Stefano Ratti from Navigant Consulting. Just a couple of clarification on that point. I guess here we have two layers of assumption, really. The first one is that we assume that the conventional manufacturers don't test the blower that they're going to match their condensing unit with and therefore they use the default value. But for the

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SDHV manufacturers, we assume that they actually do test their blower coil for fan power. And so the outcome is different.

So the question on the 65 percent, I guess, that's the second layer, well, if we use a new number, which is different from the default value, then what are we going to use? And the 65 percent comes from manufacturer catalogs for motors that are available today. They're mostly * capacitor motors that probably the manufacturers can talk to this point. And the efficiencies, I think, there is pretty good evidence that justifies the 65 percent.

So really the feedback that we want to have from all of you is (1) is it reasonable to use two different values at all. I mean is it true that the conventional manufacturers for the most part do not test their blower coil or the blower coil they're going to use and is it true that the SDHV manufacturers instead test the units. And the second layer is that is the 65 percent reasonable which I felt very comfortable with that number.

MR. MULLEN: Jim Mullen again. We're talking about a mix of things, where a manufacturer lists an air conditioner split system heat pump with a blower coil. The watts are actually tested for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 51

blower. For purposes of convenience where you can take a split system with just a coil and not a blower coil and list it with a thousand furnaces, we generally don't test all thousand. We just use the default value.

So while there may be some difference because of the extra parts in the furnace, require over this resistance to overcome, I'm not sure the analogy is good to say that the blower or coil is one thing and the blower coil is another thing because they're different products. They ought to be different. I'm not following that logic totally.

MR. RATTI: Stefano Ratti from Navigant Consulting. So if I understand you correctly, you're saying that basically the conventional manufacturers today, they are testing their blower coils that they're publishing in the ARI directory and therefore they should complicitly see an efficiency higher than the 45 percent that we assume here? I mean if you test a PSE motor, you will see something less than 0.365 per CFM that is the default value. Is that correct? MR. ARNOLD : This is Dan Arnold with York. I pretty much agree with what Jim has stated so far that we do test fan coils because anything with a coil NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1

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blower in the same cabinet, basically can't be separated, so it has to go through the ARI probate as a -- my knowledge, there isn't any difference in the technology of those units, but we do try and optimize the fan power in the small duct type velocity units, unless the small duct, high velocity folks are using a different technology and different motors which again to my knowledge, they're not. So in that equation, if you want to keep apples to apples, basically that number goes to one and it's really relevant what our motor efficiency is at that point. And I would say that would be closer to .65 on average; .45, but again, basically if the technology between our fan coils and the small duct, high velocity fan coils is the same, then that number goes to 1 and you just take it out of the equation and I have another comment, but I lost my train of thought.

FACILITATOR CLOUGH: I'll come back to you. MR. ARNOLD: I'll table it for a minute.

FACILITATOR CLOUGH: Okay. MR. PHAM: Hung Pham, Copeland Corporation. I thought I'd offer this. It's a little bit more technical, but I think DOE and its consultant, NIST, needs to do a little bit more

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technical analysis on this. I think the assumption is too simple. I think it needs to be broken down by mechanical and motor efficiencies. Operating a blower motor, I mean a blower wheel at different static and different speeds certainly implies different mechanical efficiencies rather than blower itself, blower wheel, I mean.

You can do the analysis by breaking it out. The second part, from what I've been familiar with, maybe some of our other people here are familiar with it also, but multi-speed tap PSE motors quite often, very strong function of speed, speed tap. Typically in the higher end like a six pole 1100 RPM, you're probably going to achieve closer to 65. I think 63, 65 is the upper end of it. Mid-tap is around 55 percent and the low tap is around 45 percent. So I certainly don't think the 45 percent, if he's referring to strictly the motor itself, that's way too low.

### And in gas furnaces and in air conditioners, it depends where you put the speed tap at. In heat pumps, manufacturers do test the blower motors. There's various data. They even split up the mechanical and motor efficiencies. But I think

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comparison, I tend to agree that if it is really the same type of blower wheel and the same type motor, they shouldn't be different.

MR. SULLIVAN: Lou Sullivan, Carrier. I agree with the previous three comments here and I think Tom has hit the nail on the head that you need to break it out. I think going back to what Jim said earlier, you're kind of -- this has kind of confused the issue of the conventional 365 versus what we do when we test with a fan coil. So I think if you hadn't have -- we're looking at this as engineers saying this doesn't make sense. But there is the difference of testing without the blower in place, versus with the blower in place.

So maybe you could accomplish the same thing without getting into the details of this as an adjustment. I have a question. What would have happened to the analysis had you assumed the same as far as the impact on the SEER? Do you have any feel for that? In other words, the 10.82, what would it look like? MR. McCABE: If we had used the blower motor efficiency?

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constant. In other words, not increased it to .65. (Pause.) MR. McCABE: It's supplied in Table 4 where we looked at the -- if you go to Table 4, the lower efficiency. This is the SDHV blower efficiency, but

FACILITATOR CLOUGH: What page are you on?

MR. McCABE: Page 28. FACILITATOR CLOUGH: Of which document? MR. McCABE: The Engineering Analysis Draft Report. There's Table 4 and the second line, I'm sorry, the third line says blower efficiency and this refers to the SDHV efficiency, but that separate effect is not considered, but the mean value was 65 percent and it assumes to vary in the triangular form from 50 to 80. This doesn't answer your question, but it does -- it is one of the assumed -- one of the assumptions that went into the spread of the curve and that certainly could be put in and treated as an individual sensitivity, just to see what does that do to the result.

MR. SULLIVAN: I think if you just did that, that may help get through the discussion quickly or could anyway.

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suggestions that we're looking for. Basically, the assumption -- there are so many condensing units. There are so many and they're all designed differently. The indoor units, the outdoor units, they're all -- every manufacturer presumably optimizes a design of his units by using different combinations of these technologies. And so to be specific, we made these assumptions. We assumed that the matched coil was a case coil and it uses the default blower motor, blower consumption and then since we needed to calculate this SDHV coil in the methodology, using fan power ratios, we had to make some assumptions on efficiencies and on air horse power. That was the second part of the fan power equation was the work done by the blower on the airstreams. And so with the high static pressure imposed on -- these fans have to -- will consume more power. But those were the assumptions made on fan efficiencies and that could be treated as another sensitivity broken out or whatever.

We're not sure - - our survey or the survey Arthur D. Little had conducted for the residential central A/C rulemaking, identified quite a large number of candidate units made by baseline system manufacturers -- baseline system manufacturers for

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baseline units. And that information suggests that most of the 12, 13 and 14 SEER condensing units use single speed technologies. So that is what led us to think that these assumptions were reasonable, that the matched systems would be based on single speed technologies and they would -- and they would not use -- they would not have their own blowers. They would use a furnace blower. They would be rated based on the default fan power until -- the key assumption, what's the efficiency of that?

That's what we'd like to get feedback on. FACILITATOR CLOUGH: Dan, you had had your hand up before?

MR. ARNOLD: Mainly what I was going to say earlier, I just want to comment on the fact that the default 365 watts per thousand CFM or .365 per CFM, because I heard that that number typically is a lower number, another variable comes in here in addition to what Hung said about which speed type you're using which affects the electrical efficiency of the blower primarily, but also, that number is not a based average in real life. But you have to be a little bit careful when you throw it around because it's easy for us to actually improve upon that number or beat that number on a small unit, say a two-ton,

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for example, where you have basically a little bit less based on constraints than if you get up to five times, for example, you're trying to keep a given cabinet size. So just as a point of information, I really want people to understand that you design a fan coil, we can generally be lower than 365 watts per thousand on a two-ton, but may be above that on a five-ton. As an average on a three-ton, it's probably not a bad number to use. But I was going to say rewrite today, which we're not doing, but I would argue for two-ton having one default; three-ton units have another default, maybe five-tons have another default. FACILITATOR CLOUGH: Harvey?

MR. SACHS: I really am addressing Bryan, I suspect or Mike, but it seems to me we could grind on this blade until we've got no knife let and I don't think the questions today are really fundamentally about the engineering details with all due credit to those who have done the work and I love listening and participating in that conversation. The real question, I think, Bryan, is if the public interest folks and the specialty manufacturers of SDHV and the mainline manufacturers agreed on something that was a SEER and a firewall in the test procedure, you guys

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would be pretty likely to accept that, wouldn't you?

MR. BERRINGER: Yes, we would if there was

consensus. MR. SACHS : Does somebody want to nail the number on the door and we if we could --

MR. BERRINGER: That was my underlying thought the whole time we're sitting here. Does it make sense even with the LCC? We had some analysis. A whole lot of benefit, even if you moved it a little bit, say 10.5, saying 10.8 is showing negative results, you know. The underlying question is does it make sense to keep it what it is or bump it. If there's some sort of agreement on what that number should be with the industry and the advocates, that would be great and we could just stop right here.

MR. SACHS: Could we perhaps then frame that on the two separate questions, first is the proposed rating method, an appropriate and adequate method? If we had agreement on that we could probably just right quickly pool the room on what numbers people would like and go on.

I really think that you're going to find this is not terribly contentious unless these guys and those guys have a big fight among themselves.

MR. BERRINGER: I'll start with the first

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today? A raise of hands based on how you feel

MR. MESSMER: I'd like to make a comment. FACILITATOR CLOUGH: A comment, please. MR. MESSMER: Craig Messmer with Unico. I did receive Harvey's letter concerning this rulemaking process and he brought up an intriguing idea on static pressure requirement. The 1.2 is really based on a three-ton system and conventional systems have a sliding scale on the static pressure where the smaller tonnage systems have a slightly less static pressure requirement and this is primarily because the fan power is a larger percentage of the total power at the small tonnage systems than they would be for the larger ones.

And I am in favor of a sliding scale where 1.2 would be at the 3 ton and we'd have a slight drop for 1.5 ton. I don't have the ARI standard right now for that sliding scale, but Karim has it.

I think adding one inch to whatever the conventional has is probably valid. I think that gives us 1.2 at the 3 ton. That's all I had.

MR. AMRANE: Karim Amrane, ACRI. Currently, the ARI standard 210-240 does not address

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that type of velocity system, the one with two static

pressures. So as an industry, ARI would have to immediately go back and revise the standard so it would be something that we have to do right away. I guess the sliding scale might be something that --

MR. SACHS: For those who don't have my letter, this is Harvey Sachs again, Craig has actually suggested an ARI 210-240 level plus one inch static. My letter originally proposed .9 inches. I'm certainly quite happy with the 1 inch as being an even better differentiated and firewall, so I'mhappy to accept that.MR. MESSMER: Karim, can you tell us about the 3-ton static pressure is?

MR. AMRANE: Point 15. MR. MESSMER: Point 15? Okay, thank you. I think one inch would be acceptable for us.

FACILITATOR CLOUGH: Comments from the other manufacturers in the room?

Agreement? Disagreement? Comments. MR. SACHS: So I'm hearing a consensus of a test and rating method that would have the size specific ARI 210240 products, low pressure products, plus one inch external at each size class.

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today, later on, what the thing is going to be. I mean yes, we are revising the standard and it will be discussed within the recommendation of ARI.

MR. SACHS: Thank you, Karim, for that clarification. What's important to me is I'm not hearing any of your members who are here saying this is stupid. FACILITATOR CLOUGH: Harvey, you had a second questions also that you thought was fundamental.MR. SACHS: Well, this is the firewall issue and I'm hearing that you all feel that a 1-inch plus is a reasonable approach and the second half of my question was whether there should be an upper bound on the allowable airflow.

Craig has told us that it's -- they propose a 350 CFM per ton based on an available product and if the manufacturers with their experience don't feel that offers a problem in terms of some dirty person who is not here trying to slide by a conventional product as being a small diameter, higher velocity, then I have no problem with it. I think this is something that is among the manufacturers in terms of a level playing field.

(202) 234-4433 MR. GRAVES: This is Ron Graves with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com63 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I'm hearing, Bryan, agreement on the test 25 11 and rating methods as satisfying the concerns of

(202) 234-4433 Mestek. The 350 CFM per rated ton would be pretty much the maximum. With anything above that you're going to end up * because of the * being required.

MR. SACHS: How do the SDHV manufacturers be impacted if that requirement were set at a maximum air flow of 300 CFM per ton? I understand there's one product listed now that's higher. I mean is this a major restriction on your ability to serve customer needs? MR. GRAVES: I believe so, yes.

MR. MESSMER: It certainly is restrictive, more restrictive than what we have. I believe the highest rated per ton is 325 of all the match ups currently available; 350, a little bit of leeway that we had proposed earlier and there hadn't been any objections to that.

MR. SACHS: I'm just interested in a level playing field and a good firewall and if you all are comfortable, I have no objection.

MR. AMRANE: This definition as proposed by ARI, we're fine with the definition.

MR. SACHS: But you're not accepting it. Thank you.



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everybody at the table with the modification that Craig suggested.

FACILITATOR CLOUGH: Yes, Jim? MR. MULLEN: Jim Mullen. Back to Harvey's point, I don't think anybody is trying to impede the proceeding, but I think since everybody is this engaged in it, we've got this level of manpower working on it, we need to make sure we all understand the details of it before anybody totally consents or not consent.I think I'm still not quite sure I understand exactly what we're talking about in terms of procedure, test procedure.

I need to go back and ask, how are the systems rated for ARI 210 today? What static are they running at? MR. MESSMER: This is Craig Messmer. Let me start off by saying that the SDHV systems, the fans that are designed for this type of system are not suitable for running at low static pressures. Therefore, currently, when we rate them under the ARI program, they operate at significantly higher static pressures during that test. We have all of our units, except for one, as 1.5 inches of static pressure at the rated air flows. The smallest unit that we have

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less than that, but it's close to one inch and that's 1.5 ton. Right now, the way the rule, the definition is written, most of our units would apply. Not all of them. We would have to redesign some of them. We're not using, making use of the current conventional static pressure requirement to lower our fan wattage in some way.

I'm pretty sure Space Pack is doing the same thing. MR. GRAVES: This is Ron Graves with Mestek. One of the things I was going to bring up about the test procedure was the method of test. Presently, in the procedure there's -- you can test it through a psychometric* chamber or Calorometer which you would typically not run into any problems at achieving your static pressure, but if they use a closed loop system, depending upon how much return air static, that closed loop system would have, you may not ever achieve your external static pressure. But the total pressure across the box would be. Typically, we design around for a tenth of an inch on the return and 1.2 on the supply.

FACILITATOR CLOUGH: Any more comments on 

### 25 11 this topic?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MULLEN: I just have one more

question. FACILITATOR CLOUGH: Please, go ahead.

MR. MULLEN: In the analysis that was done, since these are all SEER levels, what assumption is made about the *?

MR. McCABE: The assumption is that the matched system and the mixed systems * are the same. And that's an implicit assumption in the NIST rating method. MR. THARP: Rusty Tharp. Also, as noted in here is that they both assume both systems have *?

MR. McCABE: Yes. That's correct. FACILITATOR CLOUGH: Anything else? This is feeling like a good time for us to take about a 15 minute break and if everybody can try and be back here at about 10 minutes of, so we can get started, that will give us some time for a little further discussion before lunch.

Thank you. (Off the record.) FACILITATOR CLOUGH: One of the topics that was suggested for us to talk about briefly is actually about the SEER level itself which is currently at 10 and to have a brief discussion about, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com67 1 based on the information that's been seen and the 2 procedures associated with it, if anyone has any 3 comments about their thoughts on whether or not the 4 number should stay where it is or if it should be 5 raised to another level such as 25. 6 (Laughter.) 7 Would anyone like to start off this i 8 conversat on? 9 MR. SULLIVAN: Lou Sullivan, Carrier. I 10 guess more of a question. Going back to page 22, the 11 graph there, I'm just curious if anyone compared that 12 graph with some of the ratings that are currently in 13 the ARI Directory? 14 FACILITATOR CLOUGH: And your question is 15 was there a comparison done to -- 16 MR. SULLIVAN: To current equipment today. 17 FACILITATOR CLOUGH: Any comments? 18 MR. SULLIVAN: In other words, we produced 19 12, 13 and 14 SEER equipment today that's rated by 20 these gentlemen, so how would that compare to this

h 21 art?

c 22 MR. GRAVES: This is Ron Graves. We 23 presently already match all of our systems with the 12 24 SEER condensing unit just to achieve the current level 25 of 10.

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 68 MR. SULLIVAN: I guess to be more specific, I'm looking at this chart and I'm taking away that the max at 12 SEER can get is an 11. I'm looking at the max comparison. Maybe that's where I'm confusing people.

MR. McCABE: The question is how does this compare with ARI data?

MR. SULLIVAN: Yes, today. In other words, for a conventional 12 system, would I find, if I looked at the directory today, the highest rating of an 11 of one of these high velocities or would I find something that says 11.5 in the directory? I'm just looking for a check on this graph with reality.

MR. McCABE: Let me, if we started out at the baseline system, the one that just meets the 10 SEER, there is a number of very specific assumptions regarding the matched system and the matched system is rated at 12 SEER, it's 3-ton and the assumptions about the coil size, what we call coil size, the face area times rows that we use in this F. ratio and the CFM per ton. So all of those assumptions, they're explicit for this curve.

So if -- I believe the face area times rows of the matched system are 12, it would be say a 2-row coil at 6 square feet is 400 CFM per ton. 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69 Now if you go and look at the host of 12 SEER matched systems in the ARI Directory, you will find a very large variation of indoor unit matched system coil on the coil size. Some manufacturers use large indoor coils and they use lower, this lower outdoor coils or less efficient compressors. Other manufacturers will use a smaller indoor coil and a better condensing unit.

And so the SDH results are very sensitive to that and it all is embodied in the F., ratio. So we have looked at the data. We haven't presented this, but any given SDHV system of a given model and compared it with 20 or so conventional units. Each condensing unit is normally rated at the same, 12 SEER 3-ton and when we take the data, the coil size and put that into our methodology, we have a fairly large scatter in the results of the SDHV capacity and the efficiency. So what this curve represents is an assumption that the matched coil size is 12 and that assumption is fixed throughout this curve.

If you have a matched system that has a coil size of say 8, a small indoor coil, the efficiency boost is much greater. If the matched system is based on a very large indoor coil, then the

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efficiency is lower. But this is implicit in here is that that description of the baseline system and those characteristics of the matched coil.

FACILITATOR CLOUGH: Yes. Can you come up to the microphone, please?

MR. RATTI: A quick answer would be yes. I you look at the ARI Directory today, you, d see a lot of the SDHV systems are matched with 12 SEER condensing units and they're mostly between 10 and 11.

I'm not sure if you can say that the maximum efficiency that you can get with a 12 is close to 11 because that's not what the graph says anyway. The only thing it says is that as you go up to 11, then it's more cost effective to go to a 13 than try to do anything with the blower coil, but the answer to your question is basically yes.

MR. SULLIVAN: I guess it's these vertical lines that -- really it's the Maxtech that you talked earlier. I was assuming that was -- inferring I guess on the other vertical lines, the 12 and the 13 that that was the typical range there.

MR. RATTI: No, not necessarily. You could go above -- there is an overlapping there between the 12 and the 13, but then the 12 turns out that it's more costly than the 13, so you just

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MR. McCABE: I think Space Pack has a 12 SEER rating. And there's another issue here though is that the purpose of the -- the ARI rating or certification in the ARI Directory is for certification purposes and not necessarily for the engineering type of analyses we're presenting here. So we have looked at the Directory data for both of the SDHV manufacturers and we have discussions with the manufacturers on their philosophies for how they round the numbers to present the data and because of the concerns over certification. So it's really -- we have looked at ARI data and we see this very big spread of performance ratings and basically the SDHV because of the characteristics, the CFM per ton, primarily and the static pressure, there's a hit. You're going to get -- there's a capacity hit. This SDHV system is the capacity is going to be less than that of the nominal capacity of the matched system condenser and the SEER value is going to be less and then the degree of that hit on both capacity and efficiency depends to a large extent on the

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characteristics of the matched indoor coil and it's embodied in F, ratio.

MR. SULLIVAN: Okay, thank you. FACILITATOR CLOUGH: Let me bring us back to the original question of the SEER and the 10. Again, I'll ask the question, based on the information that you see today, does anyone have any comments or suggestions as to what should be considered with that number? The comment is that it should remain at 10, that it should be moved up to another number and if so, do you have any comments?

Is there any type of additional analysis that may need to be done before that decision is made? Any comments?

MR. McCABE: Let me comment. I think the normal process that DOE would want to go through is that this a workshop where we're presenting preliminary results. These results are very contingent on these assumptions. So having had the chance to vet these assumptions and listen to what the interested parties have to say, we can then go back and redo the analysis and then come out and propose a standard, redo the -- and do the engineering analysis with revisions that make sense. And then the normal process would be for us to -- for the Department to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON,D.C. 20005-3701 www.nealrgross.com1

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propose a standard. And then that proposed standard would then be subject to public hearings and commentary and what have you and then based on that, the comments from that, then the final rule is issued.

FACILITATOR CLOUGH: Harvey? MR. SACHS: With all due respect to all the Mike McCabes of the world, the reason I asked the question of Bryan is to see whether resources for all concerned might be conserved if the manufacturers of SDHV product and my community and the manufacturers of mainstream products reach a consensus, I believe we can move on from that by signalling to DOE that there is a consensus among those who feel involved in this thing and that would allow DOE to free up some resources for working on other regulatory matters.

My question was basically whether there is a substantial disagreement between the manufacturers of this specialty or niche product class and the other manufacturers, all of whom are represented by ARI, whether there's something that they would like that we would find acceptable as well, given that there's so little national energy savings at stake here.

FACILITATOR CLOUGH: Bryan? MR. BERRINGER: Yes, I would just follow up and pretty much agree with what Harvey is saying. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 74

If there's -- as part of the process improvement rule, if there's a consensus agreement the Department would definitely consider that. We might not reach it today and it might be done something offline here, but - and obviously, Mike E. McCabe is correct, but typically this is, as we all know, a special case too where we're setting there and we broke this off a major rulemaking, just to address this particular niche product and issue. So this is a special case and again, if there was consensus document submitted to us as a comment, by say January 8th, then we would consider that. The next step would likely, we still would probably propose a supplemental NOPR. We could put that comment in there, do it and then we do a follow-up and we can still do a final rule, but obviously, the Department would highly consider it, any type of consensus type agreement for consideration.

So -- and the point was that Dennis was bringing up is there any suggestions today that would go in the public record or do you want to -- do you feel that there's something that could be done offline or in a comment period?

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weight in the end is it to have a small duct, high velocity standard that's basically equivalent to a 12 SEER conventional systems standard or is it more to go based on the life-cycle cost analysis and that methodology? Is there one that carries more weight than the other in your final judgment?

MR. BERRINGER: Bryan Derringer. One of the things that is in the criteria and legislation that Mike Bowers continues to point out is that there is significantly energy savings to the nation. So that's an issue that we have to look at too. And what Harvey has brought up is in his points are are there any loopholes that we think, as far as these definitions that somehow, somebody would then -- that would become the major -- it would become a larger market share. If somebody could find some way of now making conventional units and this is more high velocity. That's a concern.

If we feel comfortable that's not going to happen and we know that based on what we feel the shipments are now are very low compared to the overall industry, then there's not going to be real -- we haven't cranked the numbers, but I don't see that there's going to be any significant, if any, energy savings no matter what, how far we inch it up. It's

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going to very little compared to that. So again, we want to make sure that we broke this off in the main rulemaking to address this special product.

So if everybody feels comfortable and can agree these are what definitions need to be, and this is what the level should be and it's in a joint comment, that would definitely -- that carries a lot of weight as far as the Department is concerned, as far as moving forward with the decision.

MR. AMRANE: Karim Amrane, ARI. As far as ARI, I think it's premature to have this kind of discussion today, but we can certainly explore this in-house and you could submit comments on this.

MR. BERRINGER: There's some, I guess, overall questions that we've gone through the analysis. I think there's been some comments throughout the day on some of the assumptions with fan power. I guess I'd just ask if we would just step through this list to see if anybody has additional comments today on this where again you can also submit written comments to this.

So I think we've discussed pretty much the fan power and linked already this morning as far as the numbers and if those motor efficiencies should be the same or if it should be taken out of the equation. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODEISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 77 MR. SACHS: Excuse me, Bryan, I can't quite read that slide number.

MR. BERRINGER: It's 33. MR. SACHS: I didn't quite go far enough back. Thank you.

Bryan, one little other thing if we could before we segue to this slide, the letter to which I've referred has three points of what our community would like to see. We've addressed two of them. We accept the rationale for the separate niche category and meaningful -- the second one was meaningful test procedures as a f irewall . I just want to read the one sentencewhich is our last point. "As an alternative to a rulemaking that would consumer disproportionate resources, we will accept the minimum SEER that allows the use of efficient condensers widely available in the market today." It does not make particular suggestion, but I'm trying to tell you all and our colleagues at ARI that we're running from a fight on this one.

to --

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Thank you. FACILITATOR CLOUGH: Bryan, do you want me

MR. BERRINGER: Why don't we just



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basically maybe introduce them and see if anybody does have any comments.

FACILITATOR CLOUGH: Okay. I'll just walk through them very quickly. This is an opportunity for open comment on these. Any more comments on the fan power, the equation with regards to fan power on this point? We had some discussion on this already.

The entire equation for F, itself? Baseline SDHV system? Also known as Table 1. The options that are located in Section 2.4 and just for my clarification, Mike McCabe, this Section 2.4 is with regards to the report?

MR. McCABE: Correct. FACILITATOR CLOUGH: Okay, thank you. MR. McCABE: It begins on page 19 of the draft engineering analysis.

FACILITATOR CLOUGH: Page 19, if anyone needs the reference. Anything else regarding design options within that section?

We're moving. The assumptions with regard to Max tech. We have had a little bit of discussion on that today.

Heat pumps relation to A/C in Section 219 and Mike McCabe, 2.9 starts on which page?

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1 touched on this. 2 FACILITATOR CLOUGH: Okay. 3 MR. McCABE: In the residential central 4 air conditioning analysis, we assumed there was a 5 relationship established between heat pumps and air 6 conditioner, between SEERS and HSPFs. We propose a 7 correlation and we are

-- because there are SDHV heat 8 pumps, the question is is this relationship that was 9 proposed for conventional residential equipment still 10 valid for SDHV application? 11 MR. AMRANE: Karim Amrane. ARI. Have you 12 done any analysis? 13 MR M CABE N . : o. c 14 MR. AMRANE: Have you looked -- 15 MR. McCABE: No, the analysis

-- there's been no 16 analysis on heat pumps. 17 It was not

-- as a resource conserving, we 18 did not analyze the heat pumps. 19 MR. AMRANE: I recall last time what you 20 did you looked at the Directory and basically -- 21 MR. McCABE: Correct. That is the i 22 rectory.

relationship that was based on the ARI D 23 MR. AMRANE: It shouldn't be too hard to 24 do the same thing for smaller categories. 25 MR. McCABE: Well, we could have done the 

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spreadsheet analysis and a cost efficiency curve. The thing is that --- in other words, repeat for the heat pumps what we did for the air conditioners. Because of the limited size of the heat pump market, we thought that this would be a more appropriate approach would be to adopt rather than do any additional analysis on the heat pumps.

What's on the table is that relationship that was developed for the air conditioners. Is it reasonable to use that for the SDHV heat pump. That's the equation that's on page 29.

FACILITATOR CLOUGH: Karim, do you have any follow-up at this point?

MR. AMRANE: I guess what I was suggesting is not to redo the analysis, but to do this correlation just for smaller systems.

MR. McCABE: I see, okay. MR. SACHS: I'm not as versed in the details as I probably ought to be, but it occurs to me that whereas the conventional equipment almost uniformly has the fan motor within the conditioned airstream, that's not always the case for this niche product class and that would impact the correlations if you have some product on the market which has its motor outside the airstream. 

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MR. McCABE: I think the assumptions here are that were made was that all of the fan heat ends up in the air stream so it subtracts, the system capacity is reduced by that fan power. All the fan energy -- MR. SACHS: I believe that's not strictly true from my conversation with the manufacturer, but again, if ARI and its membership reaches a consensus on these points, we will not stand in the way. Or I can't imagine there are conditions under which it would matter to us.

FACILITATOR CLOUGH: Let me move us on into the cost methodology. The three points here, derivation of the condensing unit costs that are in Section 2.6.2 which is also on which page of the report? MR. McCABE: 24.

FACILITATOR CLOUGH: Page 24. Any comments on that?

The manufacturer's markup. My recollection of the table was that varied based on the SEER.

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 82 MR. McCABE: Correct, that's Table 2 on page 25. I'm sorry, no, I take that back. That's the outdoor unit. Table 3, page 26.

FACILITATOR CLOUGH: Okay. Comments, thoughts, suggestions?

Installation costs in Section 2.10. MR. McCABE: That's on page 30, just a brief paragraph.

FACILITATOR CLOUGH: There was also the discussion of the spreadsheet. Is there an example of that or is that only available on line?

MR. McCABE: We don't have a graphic of it. FACILITATOR CLOUGH: Okay. That will most likely need to wait until people actually get the opportunity to see it.

MR. McCABE: It is posted on the DOE website to allow people to make changes in the assumptions if they want to. They can -- there's a number of different options, but it is the basis that we used for determining the cost efficiency relationship that goes into the life-cycle cost analysis. FACILITATOR CLOUGH: Comments on that? I 25 II have three more here which are not on the overhead.

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com83 1 One of the questions for discussion was is the 2 manufacturer's impact analysis for central air 3 conditioning also suitable for the SDHV? 4 MR. McCABE: I'd like to lead that 5 discussion. This is Mike E. by taking some 6 information gleaned from the technical support 7 ti l i diti t f th id d a r con oner. ocumen or e res en a 8 In Chapter 8 of the TSD included a 9 discussion of small niche manufacturers and Section 10 8.5.2 of that TSD chapter discusses low volume or 11 niche manufacturer subgroup. And in that, they 12 divided that into two groups, two subgroups within the 13 subgroup. Indoor coil manufacturers who were 14 interviewed, expressed no major concerns over the 15 impact of standards on their business, whereas -- I'm 16 paraphrasing this, but the other subgroup were niche 17 product manufacturers who have the space constrain 18 products and they seem to fall into both the low 19 volume classification and into the space constrained. 20 So there are concerns because of the space constraints 21 on their products, in other words the products can't 22 -- they just can grow arbitrarily in size. 23 Another item was that there was - - because 24 of the unique factors for each of these low volume 25 manufacturers, no GRIM analysis was performed. The

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GRIM analysis is the very detailed analysis that projects costs at the manufacturing level investment costs and cash flow projections and it's a rather lengthy analysis.

So there is discussion on manufacturer impacts in the Chapter 8 of the Technical Support Document. And so one of our concerns it does this need to be done for this -- for the SDHV manufacturers? Would it serve as useful value?

FACILITATOR CLOUGH: Comments? Response at this time?

MR. AMRANE: Karim Amrane, ARI. I think it was properly addressed in the original STD.

FACILITATOR CLOUGH: All right. There's a question regarding the -- I'm sorry, Harvey.

MR. SACHS: Just for the record, without prejudice to the TSD, we were very uncomfortable with the comments provided by the Department of Justice in the regulatory record with respect to the small volume manufacturers. I don't think it needs further treatment at this time.

FACILITATOR CLOUGH: Okay, thank you. One more follow-up question regarding SDHV shipments and national energy savings. The question is can the SDHV manufacturers estimate the total number of units NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com85 1 shipped for the past five years? 2 MR. GRAVES: Can we estimate it? 3 FACILITATOR CLOUGH: That is the question

h i d 4 an

n my . 5 MR. GRAVES: Yes, we can estimate that. 6 (Laughter.) 7 FACILITATOR CLOUGH: I'm assumingthere's 8 a follow-up question to that also. 9 (Laughter.) 10 I'm assuming from context as to whether 11 the question is will that information also be provided 12 for some analytical use is my assumption that I make 13 boldly. 14 MR. AMRANE: Karim Amrane, ARI. As far as 15 ARI, we don't distinguish in our statistical data what 16 is small and what is not. So we don't have the data, 17 but I'm sure that the manufacturers can provide data 18 and I would be more than willing to aggregate if you 19 submit anything. 20 FACILITATOR CLOUGH: Okay. Yes, Craig? 21 MR. MESSMER: Well, since there's only two 22 member companies in this group, we're going to opt out 23 of providing exact numbers. 24 I had suggested that the best way to do 25 this is to ask each of the member companies to 

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estimate themselves what the size of the market is rather than to give exact number individuals sales are. You won't hit exact numbers, but you should get pretty close on that.

I think both Unico and Space Pack could probably estimate what we think the size of the market is, but that's as far as we're willing to go.

FACILITATOR CLOUGH: Okay. MR. SACHS: On behalf of my community which does a lot of exercises to try to estimate national energy savings, as long as we've got a good firewall and are assured that this product class is shall we say less than half a percent of air conditioner, central air conditioner shipments, we do not feel it would be fair to ask for disclosure of things that might indicate market share when there are only two manufacturers.

Some sort of a bound would make us very happy, but we don't want to see detail.

MR. McCABE: This is Mike E. McCabe. The reason for this is the economic justification factors. One of them is the national energy savings and whether it's -- what the actual number is, I think we will need to have before the final rule that some estimate of that and if we had a better number, anything is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 87

better than what we have now and I think what Craig suggests would be fine. If we could get and it went through ARI and ARI said well, this is what we think the number if. We need somewhat of a time line, if the market has changed because the shipments model basically tracks shipments over time and so we have to do some minimal analysis of national energy savings, just for the sake of completeness.

FACILITATOR CLOUGH: Okay, thanks. Let me use that as a segue into we had discussed a little bit earlier about the potential loopholes for DOE to be concerned with. Is there any other discussion on that, things that DOE should think about in order to avoid? Yes, please come to the microphone, sir.

MR. PATTERSON: Doug Patterson with Aspen Manufacturing.

With all due respect to Mr. Sachs, we've heard a lot of discussion today about firewalling and I wondered whether or not we've got enough firewall, reverse firewall to protect the OEM's *, from them battling at a reduced SEER of 11, 10.5 in the existing product lines today.

MR. McCABE: This Mike E. McCabe. I'd like to read something from the -- again from the

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Technical Support Document, the engineering analysis, Chapter 4 of the residential air conditioning, Technical Support Document. And there' s a sub -- there's a section called loopholes. And it goes on to explain that a loophole -- "any time two product classes exist with different efficiency standards, there is the potential for companies to attempt to exploit the lower standards." And then it goes on to say that "the price differential between high velocity equipment is sufficiently high, about twice that of conventional equipment at the same efficiency and capacity." Therefore, the concern about creating attractive loopholes is low for these products.

So the issue is this a reasonable assertion or conclusion, but because of the very high price cost differential that that DOE is not concerned that these are potential loopholes or that they're not attractive. MR. MESSMER: This is CraigMessmer. That was an interesting comment on only manufacturers if they produce a product without a blower. Currently, all the SDHV manufacturers do sell it with a matched blower and if you don't have the matched blower there possibly is a loophole. Unless we raise the minimum standard of power for the fan. 

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MR. AMRANE: Karim Amrane, ARI. I would like to remind the audience that ARI as an industry that proposed to DOE this SDHV system including manufacturers who stand with our position.

FACILITATOR CLOUGH: Any other comments on this? Any other overall comments on any other topic that you feel you'd like to raise at this point?

Yes sir. MR. PRAM: Hung Pham, Copeland Corporation. Again, I just wondered for clarification purposes on the design options, there was no discussion about capacity modulation either reducing compressor speed or reducing blower speed.

Is this partlybecause of the definition that it has to deliver the 1.2 inch at all conditions?

MR. GRAVES: Yes, Ron Graves, Mestek. The basic design principle of the SDHV is aspiration and in order to get that effect you have to run a higher static pressure.

MR. PHAM: Thank you. FACILITATOR CLOUGH: Any other comments? Yes, please.



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the same type of expansion, I personally don't think that is a valid assumption especially for 12 SEER because there are many 12 SEER systems out there today that are a piston or orifice type expansion device. I don't know how that would affect the calculation methods, but there's a lot of 12 SEER systems out there today that are orifice.

MR. McCABE: I don't have the information at hand, but in our TSD, going back to Chapter 4 and Appendix B of the Technical Support Document, we did -- the whole residential central air conditioning analysis was based on survey of some 68 different products and I think about 50 of them were split system air conditioners and it tracked how different manufacturers achieve different efficiencies by combinations of what's used, things like variable speed motors which use TXVs, time delay relays and so on and so forth.

And I think that and the 12 SEER did show a substantial number of those in the survey at TXVs. I can't say off the top of my head but, as I recall, as the SEER value increased, the number, the percentage of those in the survey increased the TXV, those equipped with TXV increased as the SEER value increased. So at the 12 SEER level there was a

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 substantial number of them. MR. THARP: I would not disagree. My guess, maybe 10 SEER, probably almost 100 percent orifice in conventional system manufacturers and 14 SEER, you're probably almost 100 percent TXV, but at 12 SEER, probably pretty close to 50 percent.

MR. McCABE: This is Mike E. again. The SDHV manufacturers have to take that into consideration when they rate their products. And again, this methodology, we have this vast cloud of systems, matched systems available, each one has different attributes, so the assumption, to avoid that as an additional parameter, yes. We simply made that assumption that they were matched, the TXV and the expansion device, the factors that are given in this equation were assumed to be the same for the SDHV and for the matched systems. It's an assumption.

MR. SACHS: Now, Rusty, I may be jumping to confusion and have known it to happen occasionally, but it sounds to me like you're suggesting a requirement for the air conditioner side where I think the TXV is on the evaporator that the SDHV folks might be required prescriptively to have a TXV in their product. We don't normally like prescriptive requirements, but we're not going to stand in the way.

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MR. SACHS: Harvey Sachs. We are still making the assumption that these units will have to be tested, so they have to have a condensing unit and an evaporator coil that together will give them 25 to Dennis' -- whatever SEER is adopted. We won't object.

FACILITATOR CLOUGH: Any other comments? With that, I want to hand it over to Bryan Berringer, momentarily to talk a little bit about where it goes from here. MR. BERRINGER: Thank you, Dennis, and thank you, everybody, for participating today.

Obviously, the next step would be the comment period, so we welcome anything, especially the slides specific to the equations or the assumptions used, if you would provide those to the Department which is addressed in your second yellow sheet. It has the information. There's a specific e-mail address to submit comments to and again that comment period ends January 8th, so again, we would -- and if -- again, if there was a joint proposal that was 25 11 submitted, we would gladly accept that as a comment

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and take that under consideration in this particular rulemaking. With that said, again, I thank everybody that participated today and on the phone and for those that are going to join us at test procedures -- Karim?

MR. AMRANE: One question. Do you have a time frame here as to when you expect to publish the NOPR? MR. BERRINGER: I think we had an April time frame. MR. MESSMER: Bryan, do you have any requirements on format for sending documents? You used to have Word Perfect.

MR. BERRINGER: Right, Mike Raymond mentioned that. Word Perfect, we accept that. I think 6 through 10, but we also would accept Word and PDF. What we're looking at just from the aspect is we have anything that's sent regular mail has been sterilized, so it usually takes a while to get it. And if you send a floppy disk to us it's usually melted by the time we get it, so if there's any way, I know Word, if there's a signature of PDF that's sent to us and has a signature on it, that gives us sort of a legal standing, otherwise, if it doesn't have signature, it's just a file, an electronic file, then

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we would need a follow up letter sent to us that has a signature.So basically, those three formats would be acceptable, Word Perfect, Word and PDF. And again, on the second sheet it does give the e-mail address. We do have a specific e-mail for this particular rulemaking. Any other questions? Thank you. I guess we'll have a long lunch break and those that are participating in the test procedure workshop this afternoon, we'll see you at 1 o'clock.

MR. SACHS: That raises a question whether we should carry everything with us for security reasons when we go to lunch or?

MR. BERRINGER: We can -- we will lock the doors while people are at lunch.

FACILITATOR CLOUGH: We will reconvene at 1 o'clock. My understanding is with the paper visitors' badges, you can leave and then come back in again with them. Security people will tell you what to do with it at the door.

Everybody knows where the small cafeteria is. Does everyone know where the large cafeteria is in the building? Does anyone care? Would anyone like to know? If you do, down to the ground floor again

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and instead of turning left to go to the small cafeteria, you turn right and go down the 500 yard long corridor. At the end of it you'll see an escalator, go up two flights of the escalator and the door to the cafeteria is right in front of you.

See you at 1 o'clock. (Whereupon, at 11:37 a.m., the workshop was recessed, to reconvene today, Friday, December 13, 2002 at 1:00 p.m.)

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com96 CERTIFICATE

This is to certify that the foregoing transcript in the matter of: Public Hearing

Before: Department of Energy

Date: December 13, 2002

Place: Washington, DC

represents the full and complete proceedings of the aforementioned matter, as reported and reduced to typewriting.