UNITED STATES OF AMERICA

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DEPARTMENT OF ENERGY

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j7c- :-: r

SMALL DUCT, HIGH VELOCITY (SDHV) STANDARDS

(EE-RM/STD-02-330)

PUBLIC WORKSHOP

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FRIDAY,

DECEMBER 13, 2002

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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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EE-RM-STD-02-330 COMMENT 02JJ
PRESENT: (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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EE-RM-STD-02-330 COMMENT 02JJ
3

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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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

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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

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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

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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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EE-RM-STD-02-330 COMMENT 02JJ
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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 housekeep i ng thi ngs.

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

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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.

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MR. RAYMOND: Mike Raymond, Department of

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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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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.

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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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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

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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,

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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 are already four

or six row designs , we assume that by increasing coil

size we essentially mean 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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(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

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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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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

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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. MULLEN: Back on slide 15, Jim Mullen,

Lennox, I'm not sure I understand why you use .65 for

SDHV blower motor efficiency and .45 for the matched

blower efficiency.

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.

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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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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

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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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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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a kilowatt hour.

Maintenance costs, annual maintenance cost

of $40 a year. Lifetime, as an average value, of 18.4

years. Compressor replacement cost is a function of

SCR and you see the values there. And finally we have

a weighted average discount rate of 5.6 percent.

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

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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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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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find it.

Harvey can keep finding more systems at

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'm sorry, 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

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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

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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 (Laught 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

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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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What do you think? Give us some better data or tell

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

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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

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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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MR. SULLIVAN: If you had kept that

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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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MR. McCABE: Okay, these are the

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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question, is the proposed rating method adequate?

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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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'm happy 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.

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MR. GRAVES: This is Ron Graves with

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25 11 and rating methods as satisfying the concerns of

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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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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,

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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

8 conversat i 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

21 c hart?

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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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.

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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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disregard that part of the curve.

MR. SULLIVAN: And let me ask one more

question. What is the max rating today in the

Directory? Do you know that for any of these systems?

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

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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.

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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?

MR. ARNOLD : This is Dan Arnold with York.

I guess maybe a question for Bryan, which carries more

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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.

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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

sentence which 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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(Laughter.)

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 . Mc CABE : No.

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

22 relationship that was based on the ARI D i rectory.

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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Not having the parasitics in cooling and

you're having the additional -- you're having the

benefit in heating.

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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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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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 document for the res identi a l a i r conditioner.

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

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1 shipped for the past five years?

2 MR. GRAVES: Can we estimate it?

3 FACILITATOR CLOUGH: That is the question

4 i n my hand .

5 MR. GRAVES: Yes, we can estimate that.

6 (Laughter.)

7 FACILITATOR CLOUGH: I'm assuming there'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 boldl y.

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

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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 Craig Messmer. 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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25 11 going back to the assumption that both systems have

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89

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 partly because 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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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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COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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MR. THARP: I'm not saying, I'm not

suggesting that they have to put in a TXV. I'm just

implying that the -- I don't think the assumption is

valid that they're both going to have the same.

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

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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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

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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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

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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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.)

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

WASHINGTON, D.C. 20005-3701 www.nealrgross.com

EE-RM-STD-02-330 COMMENT 02JJ
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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.

EE-RM-STD-02-330 COMMENT 02JJ