Energy Conservation Program: Test Procedures for Central Air Conditioners and Heat Pumps
Federal RegisterJun 8, 2016
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE-2009-BT-TP-0004]
RIN 1904-AB94
Energy Conservation Program: Test Procedures for Central Air Conditioners and Heat Pumps
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Final rule.
SUMMARY:
On November 9, 2015, the U.S. Department of Energy (DOE) issued a supplemental notice of proposed rulemaking (SNOPR) to amend the test procedure for central air conditioners and heat pumps. That proposed rulemaking serves as the basis for the final rule. The final rule, in addition to satisfying the agency's obligation to periodically review its test procedures for covered equipment, amends specific certification, compliance, and enforcement provisions related to this product. In the final rule DOE makes the following amendments to the current test procedure: a new basic model definition as it pertains to central air conditioners and heat pumps and revised requirements for represented values; revised alternative efficiency determination methods; termination of active waivers and interim waivers; procedures to determine off mode power consumption; changes to the test procedure that would improve test repeatability and reduce test burden; and clarifications to ambiguous sections of the test procedure intended also to improve test repeatability and reproducibility Some of these amendments also include incorporation by reference of updated industry standards.
DATES:
The effective date of this rule is July 8, 2016. The final rule changes will be mandatory for representations of efficiency starting December 5, 2016. The incorporation by reference of certain publications listed in this rule was approved by the Director of the Federal Register on July 8, 2016.
ADDRESSES:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at regulations.gov. All documents in the docket are listed in the regulations.gov index. However, some documents listed in the index, such as those containing information that is exempt from public disclosure, may not be publicly available.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/72
. This Web page will contain a link to the docket for this notice on the regulations.gov site. The regulations.gov Web page will contain simple instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Ashley Armstrong, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-6590. Email:
Ashley.Armstrong@ee.doe.gov
.
Johanna Jochum, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC, 20585-0121. Telephone: (202) 287-6307. Email:
Johanna.Jochum@hq.doe.gov
.
For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
SUPPLEMENTARY INFORMATION:
This final rule incorporates by reference into part 430 specific sections, figures, and tables in the following industry standards:
(1) ANSI/AHRI 210/240-2008 with Addenda 1 and 2, (“AHRI 210/240-2008”): 2008 Standard for Performance Rating of Unitary Air-Conditioning & Air-Source Heat Pump Equipment, ANSI approved 27 October 2011;
(2) ANSI/AHRI 1230-2010 with Addendum 2, (“AHRI 1230-2010”): 2010 Standard for Performance Rating of Variable Refrigerant Flow (VRF) Multi-Split Air-Conditioning and Heat Pump Equipment, ANSI approved August 2, 2010;
Copies of AHRI 210/240-2008 and AHRI 1230-2010 can be obtained from the Air-Conditioning, Heating, and Refrigeration Institute, 2111 Wilson Boulevard, Suite 500, Arlington, VA 22201, USA, 703-524-8800, or by going to
http://www.ahrinet.org/site/686/Standards/HVACR-Industry-Standards/Search-Standards
.
(3) ANSI/ASHRAE 23.1-2010, (“ASHRAE 23.1-2010”): Methods of Testing for Rating the Performance of Positive Displacement Refrigerant Compressors and Condensing Units that Operate at Subcritical Temperatures of the Refrigerant, ANSI approved January 28, 2010;
(4) ANSI/ASHRAE Standard 37-2009, (“ANSI/ASHRAE 37-2009”), Methods of Testing for Rating Electrically Driven Unitary Air-Conditioning and Heat Pump Equipment, ANSI approved June 25, 2009;
(5) ANSI/ASHRAE 41.1-2013, (“ANSI/ASHRAE 41.1-2013”): Standard Method for Temperature Measurement, ANSI approved January 30, 2013;
(6) ANSI/ASHRAE 41.6-2014, (“ASHRAE 41.6-2014”): Standard Method for Humidity Measurement, ANSI approved July 3, 2014;
(7) ANSI/ASHRAE 41.9-2011, (“ASHRAE 41.9-2011”): Standard Methods for Volatile-Refrigerant Mass Flow Measurements Using Calorimeters, ANSI approved February 3, 2011
(8) ANSI/ASHRAE 116-2010, (“ASHRAE 116-2010”): Methods of Testing for Rating Seasonal Efficiency of Unitary Air Conditioners and Heat Pumps, ANSI approved February 24, 2010.
(9) ANSI/ASHRAE 41.2-1987 (Reaffirmed 1992), (“ASHRAE 41.2-1987 (RA 1992)”): “Standard Methods for Laboratory Airflow Measurement”, ANSI approved October 1, 1987.
Copies of ASHRAE 23.1-2010, ANSI/ASHRAE 37-2009, ANSI/ASHRAE 41.1-2013, ASHRAE 41.6-2014, ASHRAE 41.9-2011, ASHRAE 116-2010, and ASHRAE 41.2-1987 (RA 1992) can be purchased from ASHRAE's Web site at
https://www.ashrae.org/resources—publications
.
(10) ANSI/AMCA 210-2007, ANSI/ASHRAE 51-2007, (“AMCA 210-2007”) Laboratory Methods of Testing Fans for Certified Aerodynamic Performance Rating, August 17, 2007;
Copies of AMCA 210-2007 can be purchased from AMCA's Web site at
http://www.amca.org/store/index.php
.
For a further discussion of these standards, see section IV.N.
Table of Contents
I. Authority and Background
A. Authority
B. Background
II. Summary of the Final Rule
III. Discussion
A. Definitions, Testing, Represented Values, and Compliance of Basic Models of Central Air Conditioners and Heat Pumps
1. Basic Model Definition
2. Additional Definitions
3. Determination of Represented Values
4. Compliance with Federal (National or Regional) Standards
5. Certification Reports
6. Represented Values
7. Product-Specific Enforcement Provisions
B. Alternative Efficiency Determination Methods
1. General Background
2. Terminology
3. Elimination of the Pre-Approval Requirement
4. AEDM Validation
5. AEDM Verification Testing
6. Failure to Meet Certified Represented Values
7. Action Following a Determination of Noncompliance
8. AEDM for Off Mode
C. Waiver Procedures
1. Air-to-Water Heat Pumps and Air Conditioners
2. Clarification of the Test Procedure Pertaining to Multi-Circuit Products
3. Clarification of the Test Procedure Pertaining to Multi-Blower Products
D. Measurement of Off Mode Power Consumption
1. Test Temperatures
2. Calculation and Weighting of P1 and P2
3. Time Delay Credit and Removal of Calculations for Off Mode Energy Consumption and Annual Performance Factor
4. Impacts on Product Reliability
5. Off Mode Power Consumption for Intelligent Compressor Heat Control
6. Off Mode Test Voltage for Dual-Voltage Units
7. Off Mode Test Tolerance
8. Organization of Off Mode Test Procedure
9. Certification
10. Compliance Dates
E. Test Repeatability Improvement and Test Burden Reduction
1. Indoor Fan Speed Settings for Blower Coil or Single-Package Systems
2. Air Volume Rate Adjustment for Coil-Only Systems
3. Requirements for the Refrigerant Lines and Mass Flow Meter
4. Outdoor Room Temperature Variation
5. Method of Measuring Inlet Air Temperature on the Outdoor Side
6. Requirements for the Air Sampling Device
7. Variation in Maximum Compressor Speed with Outdoor Temperature
8. Refrigerant Charging Requirements
9. Alternative Arrangement for Thermal Loss Prevention for Cyclic Tests
10. Test Unit Voltage Supply
11. Coefficient of Cyclic Degradation
12. Break-in Periods Prior to Testing
13. Industry Standards that are Incorporated by Reference
14. References to ASHRAE 116-1995 (RA 2005)
15. Additional Changes Based on AHRI 210/240-Draft
16. Damping Pressure Transducer Signals
17. Clarify Inputs for the Demand Defrost Credit Equation
18. Improving Test Consistency Associated with Indoor Unit Air Inlet Geometry
F. Clarification of Test Procedure Provisions
1. Manufacturer Consultation
2. Incorporation by Reference of AHRI 1230-2010
3. Replacement of the Informative Guidance Table for Using the Federal Test Procedure
4. Clarifying the Definition of a Mini-Split System
5. Clarifying the Definition of a Multi-Split System
6. Clarifying the Housing for Uncased Coil
7. Test Procedure Reprint
G. Additional Comments from Interested Parties
1. Wet Coil Performance
2. Barometric Pressure Correction
3. Inlet Screen
H. Compliance with other Energy Policy and Conservation Act Requirements
1. Dates
2. Measured Energy Use
3. Test Burden
4. Potential Incorporation of International Electrotechnical Commission Standard 62301 and International Electrotechnical Commission Standard 62087
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration Act of 1974
M. Congressional Notification
N. Description of Materials Incorporated by Reference
V. Approval of the Office of the Secretary
I. Authority and Background
A. Authority
Title III, Part B
1
of the Energy Policy and Conservation Act of 1975 (“EPCA” or “the Act”), Public Law 94-163 (42 U.S.C. 6291-6309, as codified) sets forth a variety of provisions designed to improve energy efficiency and established the Energy Conservation Program for Consumer Products Other Than Automobiles.
2
These products include single-phase central air conditioners and central air conditioning heat pumps
3
with rated cooling capacities less than 65,000 British thermal units per hour (Btu/h), which are the focus of this Final Rule. (42 U.S.C. 6291(1)-(2), (21) and 6292(a)(3))
1
For editorial reasons, Part B was codified as Part A in the U.S. Code.
2
All references to EPCA in this document refer to the statute as amended through the Energy Efficiency Improvement Act of 2015, Public Law 114-11 (Apr. 30, 2015).
3
Where this notice uses the term “CAC/HP”, they are in reference specifically to central air conditioners and heat pumps as defined by EPCA.
Under EPCA, DOE's energy conservation program generally consists of four parts: (1) testing; (2) labeling; (3) Federal energy conservation standards; and (4) certification and enforcement. The testing requirements consist of test procedures that manufacturers of covered products must use as the basis for: (1) certifying to DOE that their products comply with applicable energy conservation standards adopted pursuant to EPCA, and (2) making other representations about the efficiency of those products. (42 U.S.C. 6293(c); 42 U.S.C. 6295(s)) Similarly, DOE must use these test procedures to determine whether covered products comply with any relevant standards promulgated under EPCA. (42 U.S.C. 6295(s))
EPCA sets forth criteria and procedures DOE must follow when prescribing or amending test procedures for covered products. (42 U.S.C. 6293(b)(3)) EPCA provides, in relevant part, that any test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure the energy efficiency, energy use, or estimated annual operating cost of a covered product during a representative average use cycle or period of use, and shall not be unduly burdensome to conduct.
Id.
In addition, if DOE determines that a test procedure amendment is warranted, it must publish proposed test procedures and offer the public an opportunity to present oral and written comments on them. (42 U.S.C. 6293(b)(2)) Finally, in any rulemaking to amend a test procedure, DOE must determine to what extent, if any, the amended test procedure would alter the measured energy efficiency of any covered product as determined under the existing test procedure. (42 U.S.C. 6293(e)(1))
The Energy Independence and Security Act of 2007 (EISA 2007), Public Law 110-140, amended EPCA to require that, at least once every 7 years, DOE must review test procedures for all covered products and either amend the test procedures (if the Secretary determines that amended test procedures would more accurately or fully comply with the requirements of 42 U.S.C. 6293(b)(3)) or publish a notice in the
Federal Register
of any determination not to amend a test procedure. (42 U.S.C. 6293(b)(1)(A))
DOE last published a test procedure final rule for central air conditioners and heat pumps on October 22, 2007. 72 FR 59906. The existing DOE test method for central air conditioners and heat pumps adopted pursuant to that rule appears at Title 10 of the Code of Federal Regulations (CFR) Part 430, Subpart B, Appendix M (“Uniform Test Method for Measuring the Energy Consumption of Central Air Conditioners and Heat Pumps”). That
procedure establishes the currently permitted means for determining energy efficiency and annual energy consumption of these products. The amendments in this final rule will not alter the measured efficiency of central air conditioners and heat pumps.
EISA 2007 also established that the Department's test procedures for all covered products must account for standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(2)(A)) For central air conditioners and heat pumps, standby mode is incorporated into the SEER metric, while off mode power consumption is separately regulated. This final rule includes modifications relevant to the determination of both SEER (including standby mode) and off mode power consumption.
10 CFR 430.27 allows manufacturers to submit an application for an interim waiver and/or a petition for a waiver granting relief from adhering to the test procedure requirements found under 10 CFR part 430, subpart B, appendix M. For those waivers that are active, however, 10 CFR 430.27(l) requires DOE to amend its regulations so as to eliminate any need for the continuation of such waivers. To this end, this final rule amends the test procedure concerning several waivers.
B. Background
This final rule addresses proposals and comments from three separate rulemakings, two guidance documents, and two working groups: (1) proposals for off mode test procedures made in earlier notices as part of this rulemaking (Docket No. EERE-2009-BT-TP-0004); (2) proposals regarding alternative efficiency determination methods (AEDMs) (Docket No. EERE-2011-BT-TP-0024); (3) the recommendations of the regional standards enforcement Working Group (Regional Standards Enforcement Working Group) (Docket No. EERE-2011-BT-CE-0077); (4) a draft guidance document related to testing and rating split systems with blower coil units (Docket No. EERE-2014-BT-GUID-0033); (5) a draft guidance document that deals with selecting units for testing, rating, and certifying split-system combinations, including discussion of basic models and of condensing units and evaporator coils sold separately for replacement installation (Docket No. EERE-2014-BT-GUID-0032); and (6) stakeholder comments from a request for information regarding energy conservation standards as well as the recommendations of the central air conditioner and heat pump energy conservation standards Working Group (CAC/HP ECS Working Group) (Docket No. EERE-2014-BT-STD-0048).
1. Proposals for Off Mode Test Procedures
DOE's initial proposals for estimating off mode power consumption in the test procedure for central air conditioners and heat pumps were shared with the public in a notice of proposed rulemaking published in the
Federal Register
on June 2, 2010 (June 2010 NOPR; 75 FR 31224) and at a public meeting at DOE headquarters in Washington, DC, on June 11, 2010 (Public Meeting Transcript, Doc. ID. EERE-2009-BT-TP-0004-0005). Subsequently, DOE published a supplemental notice of proposed rulemaking (SNOPR) on April 1, 2011, in response to comments received on the June 2010 NOPR and due to the results of additional laboratory testing conducted by DOE. (April 2011 SNOPR) 76 FR 18105, 18127. DOE received additional comments in response to the April 2011 SNOPR and proposed an amended version of the off mode procedure that addressed those comments in a second SNOPR on October 24, 2011 (October 2011 SNOPR). 76 FR 65616. DOE received additional comments during the comment period of the October 24, 2011 SNOPR and the subsequent extended comment period. 76 FR 79135.
Between the April 2011 and October 2011 SNOPRs, DOE published a direct final rule (DFR) in the
Federal Register
on June 27, 2011, that set forth amended energy conservation standards for central air conditioners and central air conditioning heat pumps, including a new standard for off mode electrical power consumption. (June 2011 DFR) 76 FR 37408. Under the June 2011 DFR, central air conditioning and heat pump units manufactured on or after January 1, 2015, would be subject to the published standard for off mode electrical power consumption. 10 CFR 430.32(c)(6). However, DOE has issued an enforcement policy statement regarding off mode standards for central air conditioners and central air conditioning heat pumps
4
(July 2014 Enforcement Policy Statement) specifying that DOE will not assert civil penalty authority for violation of the off mode standard until 180 days following publication of a final rule establishing a test method for measuring off mode electrical power consumption.
4
Available at:
http://energy.gov/sites/prod/files/2014/07/f17/Enforcement%20Policy%20Statement%20-%20cac%20off%20mode.pdf
(Last accessed March 30, 2015.)
2. Proposals for AEDMs
DOE also pursued, in a request for information (RFI) published on April 18, 2011, (AEDM RFI) (76 FR 21673) and a NOPR published on May 31, 2012, (AEDM NOPR) (77 FR 32038) revisions to its existing alternative efficiency determination methods (AEDM) and alternative rating methods (ARM) requirements to improve the approach by which manufacturers may use modeling techniques as the basis to certify consumer products and commercial and industrial equipment covered under EPCA. DOE also published a final rule regarding AEDM requirements for commercial and industrial equipment only (Commercial Equipment AEDM FR). 78 FR 79579 (Dec. 31, 2013).
3. Regional Enforcement Standards Working Group and Guidance Documents
On June 13, 2014, DOE published a notice of intent to form a working group to negotiate enforcement of regional standards for central air conditioners and requested nominations from parties interested in serving as members of the Regional Standards Enforcement Working Group. 79 FR 33870. On July 16, 2014, the Department published a notice of membership announcing the eighteen nominees that were selected to serve as members of the Regional Standards Enforcement Working Group, in addition to two members from Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC), and one DOE representative. 79 FR 41456. The Regional Standards Enforcement Working Group identified a number of issues related to testing and certification that are being addressed in this rule. In addition, all nongovernmental participants of the Regional Standards Enforcement Working Group approved the final report contingent on upon the issuance of the final guidance on Docket No. EERE-2014-BT-GUID-0032 0032 and Docket No. EERE-2014-BT-GUID-0033 consistent with the understanding of the Regional Standards Enforcement Working Group as set forth in its recommendations. (Docket No. EERE-2011-BT-CE-0077-0070, Attachment) The amendments in this final rule supplant the August 19 and 20, 2014 draft guidance documents; DOE will not finalize the draft guidance documents and instead has provided any necessary clarity through this final rule. DOE believes the amendments are consistent with the intent of the Regional Standards Enforcement Working Group.
4. Energy Conservation Standards and Working Group
On November 5, 2014, DOE published a request for information for energy conservation standards (ECS) for central air conditioners and heat pumps (November 2014 ECS RFI). 79 FR 65603. In response, several stakeholders provided comments suggesting that DOE amend the current test procedure.
On July 14, 2015, DOE published a notice of intent to establish the central air conditioners and heat pumps working group (CAC/HP ECS Working Group) to negotiate a notice of proposed rulemaking (NOPR) for energy conservation standards. 80 FR 40938. This working group was established under ASRAC. Ultimately, the CAC/HP ECS Working Group consisted of 15 members, including one member from ASRAC and one DOE representative. On January 19, 2016, the CAC/HP ECS Working Group successfully reached consensus on amended energy conservation standards and the associated compliance date for certain product classes of central air conditioners and central air conditioning heat pumps, on limited aspects of the proposed, amended test procedure appendix M1, and also on a handful of other miscellaneous issues related to the standards rulemaking as well as to this test procedure final rule. (ASRAC Working Group Term Sheet, Docket No. EERE-2014-BT-STD-0048, No. 0076)
5. Current Rulemaking
Prior to the conclusion of the CAC/HP ECS Working Group, on November 9, 2015, DOE published a third supplemental notice of proposed rulemaking (November 2015 SNOPR) for the test procedure of central air conditioners and heat pumps. 80 FR 69278. The SNOPR responded to relevant comments from the guidance documents and rulemaking dockets discussed in this section.
This final rule addresses certain comments received in response to the November 2015 SNOPR. Some of the provisions of the SNOPR, particularly related to changes proposed for appendix M1, will be addressed in a separate notice. This final rule, along with the separate final rule addressing Appendix M1, will fulfill DOE's obligation to periodically review its test procedures under 42 U.S.C. 6293(b)(1)(A).
II. Summary of the Final Rule
This final rule clarifies aspects of DOE's test procedure for central air conditioners and heat pumps to improve the consistency and accuracy of the results generated when using that procedure. The rule primarily clarifies how to test for compliance with the current energy conservation standards. The rule also amends certain certification, compliance, and enforcement provisions. While the changes adopted in this rulemaking may impact test burden in certain cases, as discussed in section III.H.3, DOE has determined that this final rule will not change the measured energy efficiency of central air conditioners and heat pumps when compared to the current test procedure. Any proposed amendments that would change the measured energy efficiency will be addressed as part of the new appendix M1, in a separate notice, which will be used in conjunction with amended standards.
DOE revises the basic model definition, adds additional definitions for clarity, makes certain revisions to the testing requirements for determination of represented values, adds certain certification reporting requirements, revises requirements for determination of represented values, and adds product-specific enforcement provisions.
DOE updates requirements for Alternative Rating Methods (ARMs) used to determine performance metrics for central air conditioners and heat pumps based on the regulations for Alternative Efficiency Determination Methods (AEDMs) that are used to estimate performance for commercial HVAC equipment. Specifically, for central air conditioners and heat pumps, DOE makes the following amendments: (1) Revising the nomenclature regarding ARMs; (2) rescinding DOE's pre-approval of an ARM prior to use; (3) creating AEDM validation requirements; (4) revising the AEDM verification testing process; (5) specifying actions a manufacturer could take following a verification test failure; and (6) clarifying consequences to manufacturers for invalid represented values.
DOE revises the test procedure such that tests of multi-circuit products, triple-capacity northern heat pump products, and multi-blower products can be performed without the need of an interim waiver or a waiver. Existing interim waivers and waivers for these products, as applicable, regarding these products will terminate 180 days after publication of this final rule.
DOE also terminates the existing waivers for air-to-water heat pump products integrated with domestic water heating because, as discussed in section III.C.1, DOE has determined that these waivers are not valid because they do not provide a method for measurement of the efficiency metrics used to determine compliance with applicable standards.
DOE adopts test methods and calculations for off mode power that do not impact the measured energy with respect to the current energy conservation standard. Specifically, the adopted test procedure includes the following:
(1) Provision of an option to conduct the off mode tests in a temperature-controlled room rather than a psychrometric room;
(2) Elimination of ambient condition requirements for units whose off mode power consumption can be measured without control of ambient temperature;
(3) Alteration of the off mode multiplier for modulated compressors;
(4) Addition of requirements on the heating season off mode power measurement for units having a crankcase heater whose controls cycle or vary crankcase heater power over time;
(5) Clarification of test sample set-up and power measurement testing methodology and components;
(6) Addition of requirement to eliminate the time delay effect on the off mode power measurement; and
(7) Elimination of the condition where P2 is equal to zero in the off mode power consumption calculation.
In this final rule DOE also improves the repeatability/reproducibility and reduces the test burden of the test procedure. Specifically, DOE amends the following:
(1) Clarification of fan speed settings;
(2) Clarification of insulation requirements for refrigerant lines and addition of a requirement for insulating mass flow meters;
(3) Addition of a requirement to demonstrate inlet air temperature uniformity for the outdoor unit using thermocouples;
(4) Addition of a requirement that outdoor air conditions be measured using sensors measuring the air captured by the air sampling device(s) rather than the temperature sensors located in the air stream approaching the inlets;
(5) Addition of a requirement that the air sampling device and the tubing that transfers the collected air to the dry bulb temperature sensor be at least two inches from the test chamber floor, and a requirement that humidity measurements be based on dry bulb temperature measurements made at the same location as the corresponding wet bulb temperature measurements used to determine humidity;
(6) Clarification of maximum speed for variable-speed compressors;
(7) Addition of requirements that improve consistency of refrigerant charging procedures;
(8) Allowance of an alternative arrangement for cyclic tests to replace the currently-required damper in the inlet portion of the indoor air ductwork for single-package ducted units;
(9) Clarification of the proper supply voltage for testing;
(10) Revision of the determination of the coefficient of cyclic degradation (C
D
);
(11) Option for a break-in period of up to 20 hours;
(12) Update of references to industry standards where appropriate;
(13) Inclusion of information from the draft AHRI 210/240;
(14) Addition of provisions regarding damping of pressure transducer signals to avoid exceeding test operating tolerances due to high frequency fluctuations;
(15) Clarification of inputs for the demand defrost credit equation; and
(16) Improvement of test consistency associated with indoor unit air inlet geometry.
DOE also provides additional detail and specificity with respect to several provisions. Specifically, DOE adds reference to an industry standard for testing variable refrigerant flow multi-split systems; replaces the informative guidance table for using the test procedure; clarifies the definition of multi-split systems; clarifies the definition of mini-split systems, which DOE now calls multi-head mini-split systems; and clarifies the housing for uncased coils.
Lastly, DOE addresses comments received from stakeholders in response to the November 2015 SNOPR that were unrelated to any of DOE's proposals. Specifically, this includes the following:
(1) Water condensation metric;
(2) Barometric pressure correction ; and
(3) Inlet screen.
Given the difficulty of writing amendatory instructions to implement the many small changes throughout appendix M, DOE has provided a full re-print of appendix M in the regulatory text of this final rule.
DOE revises the test procedure in this final rule as reflected in the revised Appendix M to Subpart B of 10 CFR part 430 effective on July 8, 2016. The amended test procedure is mandatory for representations of efficiency as of December 5, 2016.
III. Discussion
This final rule amends the test procedure for central air conditioners and heat pumps in appendix M to subpart B of Part 430 and adds new product-specific certification and enforcement provisions in 10 CFR 429.12, 429.16, 429.70, and 429.134. The rule also amends certain definitions found in 10 CFR 430.2 and updates certain materials incorporated by reference in 10 CFR 430.3.
In response to the November 2015 SNOPR, the following 25 interested parties submitted written comments: Advanced Distributor Products LLC; Air-Conditioning, Heating, and Refrigeration Institute (AHRI); American Council for an Energy Efficient Economy (ACEEE); Appliance Standards Awareness Project (ASAP); First Co.; Goodman Global, Inc.; Heating, Air Conditioning & Refrigeration Distributors International (HARDI); Ingersoll Rand; Johnson Controls Inc. (JCI); Lennox International Inc; LG Electronics U.S.A., Inc; Mitsubishi Electric Cooling & Heating; Natural Resources Defense Council (NRDC); Nortek Global HVAC; Northwest Energy Efficiency Alliance (NEEA); Northwest Power and Conservation Council (NPCC); Pacific Gas and Electric Company (PG&E); Rheem Manufacturing Company (Rheem); San Diego Gas and Electric Company (SDG&E); Southern California Edison (SCE); Southern California Gas Company (SCG); Unico, Inc.; United Refrigeration, Inc. (URI); United Technologies Climate, Controls & Security (UTC), also known as Carrier Corporation. NEEA and NPCC submitted a joint comment. PG&E, SDG&E, SCG, and SCE, hereafter referred to as the California Investor-Owned Utilities (California IOUs), also submitted a joint comment. ACEEE, ASAP, and NRDC, hereafter referred to as the Efficiency Advocates, also submitted a joint comment.
Interested parties provided comments on a range of issues, including those DOE identified in the November 2015 SNOPR, as well as several other pertinent issues related to DOE's proposal. Commenters also offered thoughts on further opportunities to improve the clarity of the test procedure. These issues, as well as DOE's responses to them and the resulting changes to DOE's proposal, are discussed in the subsequent sections. A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.
5
5
The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to amend the test procedures for central air conditioners and heat pumps. (Docket No. EERE-2009-BT-TP-0004, which is maintained at
http://www.regulations.gov/#!docketDetail;D=EERE-2009-BT-TP-0004
). The references are arranged as follows: (commenter name, comment docket ID number, page of that document).
A. Definitions, Testing, Represented Values, and Compliance of Basic Models of Central Air Conditioners and Heat Pumps
On August 19 and 20, 2014, DOE issued two draft guidance documents regarding the test procedure for central air conditioners and heat pumps. One guidance document dealt with testing and rating split systems with blower coil indoor units (Docket No. EERE-2014-BT-GUID-0033); and the other dealt more generally with selecting units for testing, rating, and certifying split-system combinations, including discussion of basic models and of condensing units and evaporator coils sold separately for replacement installation (Docket No. EERE-2014-BT-GUID-0032). The comments in response to these draft guidance documents were discussed in the November 2015 SNOPR. DOE proposed changes to the substance of the draft guidance that reflects the comments received as well as the recommendations of the Regional Standards Enforcement Working Group (Docket No. EERE-2011-BT-CE-0077-0070, Attachment). DOE makes additional modifications in this final rule in response to comment on the November 2015 SNOPR as well as the recommendations of the CAC/HP ECS Working Group (Docket No. Docket No. EERE-2014-BT-STD-0048, No. 76). The adopted changes supplant the two draft guidance documents; DOE will not finalize the draft guidance documents and has instead provided any necessary clarity through this final rule.
1. Basic Model Definition
In the November 2015 SNOPR, DOE proposed modifying its basic model definition for central air conditioners and heat pumps. 80 FR at 69282-4 (Nov. 9, 2015). Under DOE's proposal, manufacturers could consider each individual model/combination its own basic model, or manufacturers could assign all individual models of the same single-package system or all individual combinations using the same model of outdoor unit (for outdoor unit manufacturers (OUM)) or model of indoor unit (for independent coil manufacturers (ICM)) to the same basic model. DOE proposed to further define (for both single-package units and split systems) the physical characteristics necessary to assign individual models or
combinations to the same basic model. 80 FR 69278, 69282-83 (Nov. 9, 2015).
DOE proposed that, if a manufacturer chooses to assign each individual model or combination to its own basic model, the manufacturer must test each individual model/combination—and that an AEDM could not be applied. 80 FR 69278, 69283 (Nov. 9, 2015). If manufacturers assign all individual combinations of a model of outdoor unit (for OUMs) or model of indoor unit (for ICMs) to a single basic model, DOE further proposed that each individual combination within a basic model must be certified with a rating determined for that individual combination. However, only one individual combination in each basic model would have to be tested (see section III.A.3.a), while the others may be rated using an AEDM. This option reduces testing burden but increases risk. Specifically, if any one of the combinations within a basic model fails to meet the applicable standard, then all of the combinations within the basic model fail, and the entire basic model must be taken off the market. 80 FR 69278 at 69283 (Nov. 9, 2015).
Comments on these proposals are discussed in the following sections.
a. Basic Model Framework
The Joint Advocates of ACEEE, NRDC and ASAP (“Joint Advocates”) supported the proposed changes to the definition of a basic model and related testing and certification requirements. The Joint Advocates stated that they believe that the clarified testing requirements would reduce testing burden on manufacturers. (ACEEE, NRDC and ASAP, No. 72 at p. 1) Nortek supported DOE's proposal that manufacturers would have a choice in how to assign individual models or combinations to basic models. (Nortek, No. 58 at p. 3) ADP and Lennox supported the use of the basic model as the basis for any enforcement action as discussed in Section III.A.8 (80 FR 69278, 69297 (Nov. 9, 2015)) and the proposed 10 CFR 429. (ADP, No. 59 at p. 7; Lennox, No. 61 at p. 14)
NEEA and NPCC commented that DOE's proposed approach that all combinations within the basic model are deemed noncompliant if only one of the combinations within a basic model fails does not align with the other aspects of DOE's current proposal, in which each and every combination has its own certified rating. (NEEA and NPCC, No. 64 at p. 2-3)
Carrier/UTC expressed the concern that if one combination amongst potentially hundreds of combinations rated with a given outdoor unit fails then the entire basic model will be removed from the market and claimed that it is excessively punitive. Further, Carrier/UTC recommended a provision for saving the remaining indoor combinations of the basic model such as testing the tested combination and one (or more) other random indoor combinations. Carrier/UTC stated that the de-listing of the product should be limited to the combination that failed, not the entire basic model. (Carrier/UTC, No. 62 at pp. 5-6)
NEEA and NPCC further commented that they presume that DOE's ratings guidance of August 19 and 20, 2014, would also be impacted by a requirement to rate all outdoor and indoor unit combinations and the proposal with regard to testing-derived versus AEDM-derived ratings. They asserted that the proposal would seem to require the rating of both coil-only and blower coil combinations, with the choice of either using the highest sales volume combination being tested (and all other combinations rated using an AEDM), or testing each combination as its own basic model. (NEEA and NPCC, No. 64 at p. 2-3)
In response to NEEA and NPCC, DOE disagrees that DOE cannot make a determination of compliance on a basic model basis simply because DOE permits the manufacturer to make different representations for combinations within a basic model. In response to NEAA, NPCC, and UTC/Carrier, DOE notes that it developed the proposal for the basic model framework in an effort to balance manufacturer test burden and risk. The determination of compliance with the standard is made at the basic model level, and the manufacturer may choose how to group models into basic models and whether or not to make use of an AEDM for represented values of combinations. DOE expects that the individual combinations grouped into a single basic model would have similarities that would make validation of one of the individual model/combination's represented values a strong indication of the accuracy of the represented values of the other models/combinations—if the represented values are indeed different. DOE also notes that when manufacturers use an AEDM and DOE finds an invalid rating, manufacturers can conduct re-testing to re-certify the individual model/combination, as described in section 429.70.
DOE also notes that, as stated in the November 2015 SNOPR, this final rule will supplant DOE's draft ratings guidance documents, which will not be finalized. Finally, DOE notes in response to NEEA and NPCC that the basic model framework itself does not determine whether both coil-only and blower coil combinations must be rated; this is further discussed in section III.A.3.a. Given the support for the basic model framework voiced by many of the commenters, DOE adopts the framework as proposed in the SNOPR.
b. General Definition Comments
AHRI and several manufacturers including UTC/Carrier, ADP, Lennox, Nortek, and Unico agreed generally with DOE's proposal to modify its basic model definition. (AHRI, No. 70 at p. 3; UTC/Carrier, No. 62 at p. 5-6; ADP, No. 59 at p. 7; Lennox, No. 61 at p. 14; Nortek, No. 58 at p. 3; Unico, No. 63 at p. 4) Rheem recommended that DOE adopt the industry standard definition for basic model, as defined by AHRI. (Rheem, No. 69 at p. 4) As described below, several commenters requested additional modifications to DOE's proposed definitions; these comments are discussed below, along with revisions to the proposed definitions.
c. Split Systems Manufactured by OUMs and Single-Package Systems
For split systems manufactured by OUMs and single-package systems, AHRI, Lennox, Ingersoll Rand, Rheem, and Nortek recommended the removal of “the auxiliary refrigeration system components if present (
e.g.,
expansion valve) and controls” from the proposed basic model definition. Lennox and Nortek commented that adding these components to the definition can greatly expand the number of basic models. (AHRI, No. 70 at p. 3; Lennox, No. 61 at p. 4; Ingersoll Rand, No. 65 at p. 11; Rheem, No. 69 at p. 4; Nortek, No. 58 at p. 3) Additionally, Lennox and Nortek suggested that there would not be a benefit to expanding the definition of basic model beyond the currently accepted industry practice as outlined in AHRI's certification program. (Lennox, No. 61 at p. 4; Nortek, No. 58 at p. 3) DOE understands Lennox and Nortek are referring to the concept of a “basic model group” as the term is described in the AHRI Operations Manual for Unitary Small Air-Conditioners and Air-Source Heat Pumps, in section 1.5, “Basic Model Groups (BMGs).”
After reviewing the comments, DOE acknowledges that while use of different auxiliary refrigeration system components may impact measured performance, it may not do so significantly—for example, measurements made using two different thermostatic expansion valves that both maintain the same superheat should not be different. In an effort to balance manufacturer test burden with the
regulatory needs of the program to establish an appropriate basic model definition, DOE has not included the phrase “auxiliary refrigeration system components if present (
e.g.,
suction accumulator, reversing valve, expansion valve) and controls” in the “basic model” definition for split systems manufactured by OUMs or for single-package systems. DOE notes, however, that each manufacturer is responsible for minor variations in efficiency differences resulting from such changes in design.
For the definition of a basic model for OUMs, Goodman agreed with DOE's overall direction. However, Goodman commented that DOE's proposed definition was too rigid and would not provide enough design flexibility to manufacturers. Specifically, Goodman cited the importance of the ability for a manufacturer to vary many aspects of its outdoor coils (
e.g.,
style and fin depth) and to source components, such as compressors, from multiple component manufacturers. Goodman asserted that this flexibility in design would allow manufacturers to provide combinations that optimize their product offering to consumers, while still yielding similar performance and therefore meriting classification under a single basic model. Goodman suggested revised basic model definitions for split systems manufactured by OUMs and single-package systems in which the list of parameters affecting performance (
e.g.,
compressor and outdoor coil properties) that had been proposed to define a distinct model be instead provided as guidance for the OUM to consider when deciding whether two variations of a design should have the same model number. (Goodman, No. 73 at pp. 2-3)
In response to Goodman, DOE recognizes the importance of allowing manufacturers flexibility in design. DOE agrees with Goodman that, for instance, using compressors from different compressor manufacturers in two different models should not require the manufacturer to classify these models as two separate basic models, if the models can still reasonably be described as having “essentially identical characteristics.” However, DOE believes that Goodman's suggested revised definitions, by providing guidance but no requirements, would allow widely varying characteristics under the same model of outdoor unit or single-package unit. Rather than moving to definitions that provide flexibility limited only by guidance, DOE has instead modified the definitions to allow some design flexibility, while assuring that a large departure from a given design would require that the OUM establish a new basic model. In the definitions established in this final rule for basic model for split systems manufactured by OUMs and single-package systems, DOE has removed certain requirements proposed in the November 2015 SNOPR, and added tolerances for the remaining requirements. Specifically, these modifications from the proposal include: (1) Establishing a five percent tolerance for compressor displacement, capacity, and power input; (2) removing requirements for several outdoor coil parameters; (3) adding a five percent tolerance to the face area and total fin surface area of the outdoor coil; (4) adding a ten percent tolerance on outdoor airflow, and (5) for single-package systems, allowing a ten percent tolerance on indoor airflow and a twenty percent tolerance on power input to the indoor fan motor.
In the basic model definition proposed in the November 2015 SNOPR for split systems manufactured by OUMs and single-package systems, DOE specified that all individual models or combinations in a basic model must have the same or comparably performing compressor(s) with the “same displacement rate (volume per time) and same capacity and power input when tested under the same operating conditions.” 80 FR 69278, 69341 (Nov. 9, 2015). In order to promote design flexibility, DOE is adopting less stringent requirements in the basic model definition amended in this final rule by adding a five percent tolerance to the displacement rate and capacity and power input. DOE's research suggests that comparable compressors made by different manufacturers vary by less than two percent in displacement rate and capacity and power input when tested under the same conditions. Therefore, DOE believes that a five percent tolerance allows manufacturers the option to use comparably performing compressors from different manufacturers in models without having to classify the models as separate basic models. Additionally, in the definition established in this final rule, DOE explains that the tolerances on compressor parameters refer to the values rated by the compressor manufacturer, not the performance of individual compressors.
In this final rule, DOE is adopting less stringent requirements for classifying as comparably performing outdoor coil(s) in the basic model definition for split systems manufactured by OUMs and single-package systems. To provide more flexibility to manufacturers, DOE is not adopting specifications in the basic model definitions for: Coil depth, fin style (
e.g.,
wavy, louvered), fin density (fins per inch), tube pattern, tube diameter, tube wall thickness, and tube internal enhancement. However, DOE has added a five percent tolerance to the face area and total fin surface area for outdoor coils. This tolerance on the outdoor coil areas will allow manufacturers to vary their designs while achieving similar performance, such as adding another row perpendicular to the airflow direction to the outdoor coil to compensate for using a more energy-consuming compressor.
Additionally, DOE is adding tolerances to the requirements for classifying as comparably performing outdoor fan(s) in the basic model definition for split systems manufactured by OUMs and single-package systems. DOE is adding a ten percent tolerance on outdoor fan airflow. DOE believes that this tolerance will allow manufacturers to make adjustments to the fans, such as increasing the number, diameter, or design of fan blades, without classifying comparably performing models as separate basic models.
UTC/Carrier agreed with DOE's proposal to align the basic model definition with that used by AHRI; however, they asserted that the list of additional reporting requirements is excessive and burdensome. Specifically, UTC/Carrier stated that some of these components do not affect the performance of the system, are considered proprietary, and need not be reported. Additionally, they stated that some of these minor components may change due to sourcing availability. UTC/Carrier recommended that DOE align the basic model exactly with AHRI's basic model group definition: Compressor model, outdoor coil face area, and outdoor airflow, and not require any additional data to be reported. (UTC/Carrier, No. 62 at p. 2)
For split systems manufactured by OUMs, Lennox recommended that the proposed OUM basic model definition be revised to more closely align with industry practices and recommended that the definition of outdoor coil be revised to protect business sensitive information. (Lennox, No. 61 at p. 4) Specifically, Lennox requested that the definition of outdoor coil-only include the words “same face area and depth, style.” Lennox suggested that DOE remove the remaining specification requirements for outdoor coils so that this sensitive business information could not be made available to the public and industry competitors through a FOIA request. (Lennox, No. 61 at pp. 3-4)
DOE acknowledges the importance of avoiding disclosure of proprietary or sensitive business information; however, in the November 2015 SNOPR DOE did not propose any additional certification requirements or supplemental test instruction reporting that would require disclosure of these parameters about which UTC/Carrier and Lennox cited concern. 80 FR 69278, 69338-39 (Nov. 9, 2015). Requirements for reporting are limited to those items listed in section 429.16(e), and mention of a parameter as the basis for distinguishing a model does not by itself imply that the value of that parameter must be reported in certification reports. DOE notes that it is not requiring that manufacturers report the sensitive information such as surface area or coil depth for which their basic model determinations are made.
In response to UTC/Carrier, DOE recognizes that minor components may vary in manufacturer designs based on availability from component manufacturers. However, DOE believes that the tolerances established in this final rule (as previously discussed) around most of the requirements in DOE's definition of basic model allow for variation in component models and manufacturers. DOE also believes that the requirements included in DOE's definition of basic model are necessary to ensure units are similar enough to be classified as the same basic model. DOE also notes that the definition established in this final rule includes tolerances on the compressor model ratings, outdoor coil face area, and outdoor airflow; therefore DOE's definition allows more flexibility for outdoor coil face area and outdoor airflow than does the definition of a split-system model group in the AHRI Operations Manual.
6
6
AHRI's Operations Manual for Unitary Small Air-Conditioners and Air-Source Heat Pumps (Includes Mixed-Match Coils) (Rated Below 65,000 Btu/h) Certification Program (AHRI OM 210/240—March 2015). Available at
www.ahrinet.org/App_Content/ahri/files/Certification/OM%20pdfs/USE_OM.pdf
(Last accessed March 31, 2016.)
In response to Lennox, as previously discussed, DOE has removed references to fin material, style, or density or tube thickness in the basic model definition established in this final rule, which will provide manufacturers with more flexibility in offering a varied product offering to consumers while limiting the testing burden.
d. Requirements for Independent Coil Manufacturers
Several commenters expressed concern about the impact of the proposed definition of basic model on ICM test burden. Therefore comments regarding the ICM basic model definition are addressed in the context of testing required to determine represented values in section III.A.3.d.
e. Off-Mode
Revisions to the test procedure as stated in section III.D of this final rule enable the determination of off mode power consumption, which reflects the operation of the contributing components: crankcase heater and low-voltage controls. In the November 2015 SNOPR, DOE proposed that if individual combinations that are otherwise identical are offered with multiple options for off mode related components, manufacturers at a minimum must rate the individual combination with the crankcase heater and controls which are the most consumptive. Under this proposal, if a manufacturer wished to also make representations for less consumptive off mode options for the same individual combination, the manufacturer could provide separate ratings as long as the manufacturer differentiated the individual model numbers for these ratings. These individual combinations would be within the same basic model. 80 FR 69278, 69284 (Nov. 9, 2015).
In their comments, NEEA and NPCC strongly supported DOE's proposal to require manufacturers to either rate and certify all combinations using the most consumptive off-mode power controls and systems, or to differentiate models they wish to certify with different off-mode power controls and/or systems with different model numbers, each with its own certified rating. (NEEA and NPCC, No. 64 at p. 4)
DOE received no other comments on this proposal and adopts it in this final rule.
f. Central Air Conditioner Definition
In the November 2015 SNOPR, DOE proposed to clarify that a central air conditioner or central air conditioning heat pump may consist of: A single-package unit; an outdoor unit and one or more indoor units (
e.g.,
a single-split or multi-split system); an indoor unit only (rated as a combination by an ICM with an OUM's outdoor unit); or an outdoor unit only (with no match, rated by an OUM with the coil specified in this test procedure). DOE proposed adding these specifications to the definition of central air conditioner or central air conditioning heat pump in 10 CFR 430.2. In the certification reports submitted by OUMs for split systems, DOE proposed that manufacturers must report the basic model number as well as the individual model numbers of the indoor unit(s) and the air mover where applicable. 80 FR 69278, 69284 (Nov. 9, 2015).
Lennox and ADP expressed concern that modifying the CAC/HP definition to include “an indoor unit” only may have significant unintended consequences with additional regulation now applying to indoor units. They stated that the indoor unit has no heating or cooling capability without being installed as a part of the system, that by itself, it is a component, and that the proposed definition is factually incorrect and contradicts the DOE's previous position that they do not have authority to regulate components of air conditioners. Lennox recommended DOE keep the existing definition. (Lennox, No. 61 at p. 10; ADP, No. 59 at p. 4)
DOE notes that the modification of the CAC/HP definition does not change the scope of DOE's product coverage and is in line with the current certification requirements for CAC/HP. Specifically, ICMs are currently responsible for testing and certifying models of indoor units they manufacture as part of a split-system combination. DOE received no other comment on this topic. For these reasons, DOE is adopting the CAC/HP definition as proposed.
2. Additional Definitions
In the November 2015 SNOPR, in order to specify differences in the proposed basic model definition for ICMs and OUMs, DOE proposed definitions for an ICM and an OUM. With respect to any given basic model, a manufacturer could be an ICM or an OUM. 80 FR 69278, 69284 (Nov. 9, 2015).
DOE also proposed to define variable refrigerant flow (VRF) systems that are single-phase and less than 65,000 Btu/h as a kind of multi-split central air conditioner and central air conditioning heat pump system. Id.
Additionally, DOE proposed to clarify several other definitions currently in 10 CFR 430.2 with minor wording changes and move them to 10 CFR 430, Subpart B, Appendix M. DOE also proposed to remove entirely the definitions for “condenser-evaporator coil combination” and “coil family,” as those terms no longer appear in the proposed regulations. Id.
DOE did not receive any comments on these definitions and related changes and adopts the proposals in this final rule.
a. Indoor Unit
In the November 2015 SNOPR, DOE proposed modifying the definition of indoor unit to read as follows: “indoor unit transfers heat between the refrigerant and the indoor air, and
consists of an indoor coil and casing and may include a cooling mode expansion device and/or an air moving device.” 80 FR 69278, 69284 (Nov. 9, 2015).
Goodman commented that the definition for indoor unit does not fully account for the range of indoor units sold in the market. Specifically, Goodman stated that including the casing in the proposed indoor unit definition is inconsistent with many industry offerings. Goodman also suggested a new definition for indoor unit. (Goodman, No. 73 at p. 3-5)
AHRI and Nortek proposed a definition for indoor units that does not include casing and/or an expansion device. AHRI and Nortek expressed concern that the uncased coil would no longer be within the scope of regulation, which could open the doors for a loophole in the regulation, or that manufacturers would not be able to list an uncased coil with an outdoor unit, resulting in an illegal installation. AHRI and Nortek proposed definitions for uncased coil, cased coil, and service coil. (AHRI, No. 70 at p. 8; Nortek, No. 58 at p. 3-4). Further, AHRI stated that DOE should make clear that service coils will not be rated in the future. (AHRI, No. 70 at p. 8)
UTC/Carrier commented that the exclusion of uncased coils from DOE certification represents a significant loophole as uncased coils are often installed in various new construction scenarios and should be certified. According to UTC/Carrier, DOE should further define the replacement component service coils that are used only when the current coils fail and are considered service parts and, thus, should not be certified to DOE; the treatment of uncased coils in commerce by manufacturers as service-only is problematic. (UTC/Carrier, No. 62 at p. 3)
JCI commented that, while some manufacturers use uncased service coils, others supply service coils with casings on them. In addition, JCI commented that not all uncased coils are service coils. According to JCI, there are product families of uncased coils very often sold for new construction installations, or installation of new A/C systems in the northern parts of the United States. For example, JCI noted that often in the northern United States, a new home may be constructed with only a furnace for heating and no cooling, and that cooling may be added later by installing an uncased coil into the ductwork itself. JCI commented that the uncased coil market is a vital part of the northern U.S. market, and uncased coils need to be allowed to be rated as valid matches with a basic outdoor model. (JCI, No. 66 at p. 12-13). JCI also suggested definitions for uncased coil, cased coil, service coil, and indoor unit. (JCI, No. 66 at p. 13)
The California IOUs requested that DOE allow manufacturers to rate uncased coils with outdoor condensing units. They reported that California Building Energy Efficiency Standards (Title 24) define the replacement of any component containing refrigerant to be a system alteration requiring verification of refrigerant charge and airflow through the coil. (see California Code of Regulations, Title 24, Part 1, Article 1, Section 150.2(b)(1)F) The California IOUs stated that the replacement of an indoor coil is an alteration whether the coil is cased or uncased. DOE asserted that DOE's proposal to define uncased coils as repair parts and to not require them to be part of a rated model would create a compliance problem for contractors in California because without ratings, the energy efficiency of the system with an uncased coil is not known. The California IOUs stated that in applications where the existing coil is removed from the existing case and replaced with a new coil, which is then connected to a new outdoor unit, the efficiency rating is required to meet Title 24. Therefore, the California IOUs requested that DOE allow ratings of combinations having uncased indoor coils so that compliance with Title 24 can be verified. (California IOUs, No. 67 at p. 2)
ADP and Lennox commented that they understand the intent of excluding uncased coils is to differentiate between indoor units used for legacy replacements and new installations, but believe that DOE's proposal would create a significant loophole. ADP and Lennox commented that uncased coils are used for new installations in a significant number of markets in the upper Midwest of the United States where a long tradition of skilled sheet metal workers exists. Additionally, they asserted that Canada is a predominately uncased coil market and relies on manufacturer ratings that have been certified with DOE and AHRI. Instead, ADP suggests that DOE require replacement coils not subject to certification to carry a different model number than those sold for installation as a part of new, certified systems. (ADP, No. 59 at p. 4-5; Lennox, No. 61 at p. 10)
After consideration of the comments that uncased coils may be used for new installations and that the exclusion of uncased coils from the indoor unit definition could result in a significant loophole, DOE is adopting a revised definition for an indoor unit such that it “may or may not include . . . (e) external cabinetry”. To distinguish newly installed cased and uncased coils from replacement cased and uncased coils, DOE has added a definition for service coils and explicitly excluded them in the indoor unit definition.
Indoor unit
means part of a split-system air conditioner or heat pump that includes (a) an arrangement of refrigerant-to-air heat transfer coil(s) for transfer of heat between the refrigerant and the indoor air and (b) a condensate drain pan, and may or may not include (c) sheet metal or plastic parts not part of external cabinetry to direct/route airflow over the coil(s), (d) a cooling mode expansion device, (e) external cabinetry, and (f) an integrated indoor blower (
i.e.
a device to move air including its associated motor). A separate designated air mover that may be a furnace or a modular blower (as defined in Appendix AA to the subpart) may be considered to be part of the indoor unit. A service coil is not an indoor unit.
Service coil
means an arrangement of refrigerant-to-air heat transfer coil(s) and condensate drain pan that may or may not include sheet metal or plastic parts to direct/route airflow over the coil(s), external cabinetry, and/or a cooling mode expansion device, and is sold exclusively to replace an uncased coil or cased coil that has already been placed into service and is labeled accordingly.
DOE also acknowledges the benefit of including definitions for both cased and uncased coils, and adopts the following definitions:
Cased coil
means a coil-only indoor unit with external cabinetry.
Uncased coil
means a coil-only indoor unit without external cabinetry.
In the November 2015 SNOPR, DOE proposed to specify that if the indoor unit does not ship with a cooling mode expansion device, the system should be tested using the device as specified in the installation instructions provided with the indoor unit, or if no device is specified, using a thermostatic expansion valve (TXV). 80 FR 69278, 69284 (Nov. 9, 2015).
Goodman commented that DOE should not assume the use of TXV if a metering (expansion) device is not specified by the manufacturer. Goodman commented that the majority of systems installed today use fixed orifice rather than TXV expansion devices. (Goodman, No. 73 at p. 3-5)
DOE agrees that many product offerings use fixed orifice or piston expansion devices as standard equipment and that it may be more suitable to use a fixed orifice or piston
device if there are no detailed instructions provided in installation instructions regarding selection of an expansion device. This is because a system installed in the field without such instructions may very well perform poorly if an optimized device is not selected. Because a TXV generally is likely to provide better performance over a range of operating conditions, DOE believes the use of a fixed orifice is more consistent with this potential for poor field performance. Therefore, DOE is modifying its proposal and requiring instead that a fixed orifice or piston expansion device be used if the installation instructions do not specify a metering (expansion) device.
b. Blower Coil and Coil-Only Indoor Units
In the November 2015 SNOPR, DOE proposed definitions for blower coil indoor unit and coil-only indoor unit. The motivation was to simplify the description of the test requirements by referring to blower coil units instead of units “with an indoor fan installed” and to coil-only units instead of units “without an indoor fan installed”.
Blower coil indoor unit
means the indoor unit of a split-system central air conditioner or heat pump that includes a refrigerant-to-air heat exchanger coil, may include a cooling-mode expansion device, and includes either an indoor blower housed with the coil or a separate designated air mover such as a furnace or a modular blower (as defined in Appendix AA).
Blower coil system
refers to a split system that includes one or more blower coil indoor units.
Coil-only indoor unit
means the indoor unit of a split-system central air conditioner or heat pump that includes a refrigerant-to-air heat exchanger coil and may include a cooling-mode expansion device, but does not include an indoor blower housed with the coil, and does not include a separate designated air mover such as a furnace or a modular blower (as defined in Appendix AA). A coil-only indoor unit is designed to use a separately-installed furnace or a modular blower for indoor air movement.
Coil-only system
refers to a system that includes one or more coil-only indoor units. 80 FR 69278, 69286 (Nov. 9, 2015).
ADP and UTC/Carrier agreed with the proposed definitions for blower coil and coil-only indoor units. (ADP, No. 59 at p. 6; UTC/Carrier, No. 62 at p. 3) Lennox agreed with the proposed definitions with the exceptions noted in other sections. (Lennox, No. 61 at p. 13) Unico agreed with the coil-only indoor definition, except recommended removing the word “modular” as there is no definition. Unico commented that the blower can be anywhere in the system. (Unico, No. 63 at p. 2) JCI suggested definitions for air handler, blower coil, and coil-only. (JCI, No. 66 at p. 13)
Rheem commented that the proposed definitions for blower coil and coil-only indoor units exclude the customary practice in the Northwest United States where an uncased coil is installed in a plenum for space-constrained installations. Rheem stated that under DOE's proposal, a certified rating for this system configuration would no longer be available to consumers. Rheem noted that there are building inspectors who require an AHRI or DOE certified combination including the evaporator coil for replacements. (Rheem, No. 69 at p. 5)
DOE acknowledges that by excluding indoor units without a casing, the customary practice identified by Rheem would not be included. As noted in the previous section, DOE has addressed this by expanding the indoor unit definition to include units which may or may not have external cabinetry. The blower coil and coil-only indoor unit definitions then build on this updated indoor unit definition. Further, DOE has removed, from both the blower coil and coil-only indoor unit definitions, language redundant with the indoor unit definition and is adopting amended definitions:
In response to Unico's comment regarding “modular”, the definition explicitly refers to the definition of “modular blower” in appendix AA. In response to JCI's comment requesting a definition for “air handler”, DOE feels that this is not necessary because there are few distinctions in the test procedure between test requirements for blower coil indoor units that are air handlers (as defined by JCI) and blower coil indoor units that are not. In cases where a distinction is needed, the regulatory language adequately provides the distinction, for example in section 3.13.1.d, “blower coil split systems for which a furnace or a modular blower is the dedicated air mover . . .”, which refers to blower coil split systems whose indoor units are not “air handlers”.
3. Determination of Represented Values
In the November 2015 SNOPR, DOE proposed several regulatory changes regarding the relationship between represented values and an effective enforcement plan. The changes are described in the following sections.
a. Single-Split-System Air Conditioners Rated by OUMs
DOE proposed to make changes to 10 CFR 429.16 to revise the testing and rating requirements for single-split system air conditioners. These changes were proposed to occur in two phases. In the first phase, prior to the compliance date of any amended energy conservation standards, DOE proposed only a slight change to the current requirements. Specifically, DOE proposed that for single-split system air conditioners with single speed condensing units, each model of outdoor unit must be tested with the model of coil-only indoor unit that is likely to have the largest volume of retail sales with the particular model of outdoor unit. For split-system air conditioners with other than single speed condensing units, each model of outdoor unit must also be tested with the model of coil-only indoor unit likely to have the largest sales volume unless the model of outdoor unit is sold only with model(s) of blower coil indoor units, in which case it must be tested and rated with the model of blower coil indoor unit likely to have the highest sales volume. However, any other combination may be rated through testing or use of an AEDM. Therefore, both single speed and other than single speed systems may be rated with models of both coil-only or blower coil indoor units, but if the system is sold with a model of coil-only indoor unit, it must, at a minimum, be tested in that combination. 80 FR 69278, 69285-86 (Nov. 9, 2015).
In the second phase, DOE anticipated that any amended energy conservation standards would be based on blower coil ratings. Therefore, DOE proposed that all single-split-system air conditioner basic models be tested and rated with the model of blower coil indoor unit likely to have the largest volume of retail sales with that model of outdoor unit. Manufacturers would be required to also rate all other blower coil and coil-only combinations within the basic model but would be permitted do so through testing or an AEDM. This proposed change would also be accounted for in the parallel energy conservation standards rulemaking, and would be contingent upon any proposed amended standards being based on blower coil ratings. Id.
DOE noted that these proposed testing requirements, when combined with the proposed definition for basic model, require that each basic model have at least one rating determined through testing; no basic model can be rated solely using an AEDM. Id.
DOE also proposed that in the certification report, manufacturers state whether each rating is for a coil-only or blower coil combination. 80 FR 69278, 69286 (Nov. 9, 2015).
Following publication of the November 2015 SNOPR, DOE held meetings of the CAC/HP ECS Working Group. The CAC/HP ECS Working Group recommended consensus energy conservation standards based on coil-only ratings rather than blower coil ratings, making the second phase of DOE's proposal no longer applicable. Many of the stakeholders who submitted comments on DOE's proposal were also members of the CAC/HP ECS Working Group, and as a result, their positions may have changed over the course of the negotiations. For these reasons, DOE has included the consensus recommendations of the CAC/HP ECS Working Group that pertain to DOE's proposal but has not included the comments of members of the CAC/HP ECS Working Group on the November 2015 SNOPR where the scope of the Working Group recommendation encompassed the scope of the comment.
With respect to the coil-only and blower coil requirements, ADP agreed with the proposed requirements of the first phase approach. (ADP, No. 59 at p. 5-6;)
JCI agreed with the single speed requirements in Appendix M but did not agree with DOE's proposed requirement for two-stage units or multi-stage units to be tested with a coil-only indoor unit, if any coil-only indoor units are listed with that outdoor unit. JCI recommended that there should be no change in the current regulatory text for two-stage or modulating equipment, and asserted that the spirit of the current regulation is met with blower coils remaining as the highest sales volume tested combination, even if there are limited loose coil or coil-only ratings available. (JCI, No. 66 at p. 5)
ADP had concerns that testing the highest sales volume combination (HSVC) with a blower coil in the second phase (in appendix M1) would make it more difficult for ICMs to accurately rate their products because of the added uncertainty of the indoor blower watts and airflow performance. Under the proposed second phase, with a blower coil indoor unit as HSVC, the indoor blower watt value is unknown by the ICM, forcing the ICM to estimate the watts, which introduces additional uncertainty to ICM ratings. Although ADP and Lennox recognized that ICMs could test the HSVC blower coil, they considered this to be an unreasonable testing burden on ICMs. (ADP, No. 59 at p. 5-6) ADP proposed that DOE require the reporting of indoor watt data, indoor air volume rates, and indoor air mover settings and require that they be made publicly available. (ADP, No. 59 at p. 5-6) Unico stated that it preferred that the HSVC be a coil-only indoor unit so that they would be able to properly account for the fan power when rating their products. (Unico, No. 63 at p. 2)
Lennox; the Joint Advocates of ACEEE, NRDC, and ASAP; UTC/Carrier; Goodman; and Rheem had submitted comments in regard to the two-phase proposal related to coil-only and blower coil requirements. As noted previously, these stakeholders were members of the CAC/HP ECS Working Group, and as such the comments are not included here.
JCI commented that the current language used in Appendix M denoting the HSVC match cannot be determined with exact statistics and that it actually inhibits the adoption of new and promising advancements in product design. (JCI, No. 66 at p. 4) In contrast, Unico commented that, as an indoor coil manufacturer, it believes it to be important that the outdoor unit manufacturer continue to test and rate the HSVC, as this is an integral requirement for their AEDM to maintain accuracy. (Unico, No. 63 at p. 2)
UTC/Carrier also submitted a comment related to removal of the HSVC requirement. As noted previously, UTC/Carrier was a member of the CAC/HP ECS Working Group, and as such the comment is not included here.
In the term sheet, the CAC/HP ECS Working Group recommended that DOE implement the following requirements for single-split system air conditioners and suggested some implementing regulatory text:
• Every combination distributed in commerce must be rated.
○ Every single-stage and two-stage condensing unit distributed in commerce (other than a condensing unit for a 1-to-1 mini split) must have at least 1 coil-only rating that is representative of the least efficient coil distributed in commerce with a particular condensing unit.
• Every condensing unit distributed in commerce must have at least 1 tested combination.
○ For single-stage and two-stage condensing units (other than condensing units for a 1-to-1 mini split), this must be a coil-only combination.
• All other combinations distributed in commerce for a given condensing unit may be rated based on the application of an AEDM or testing in accordance with the applicable sampling plan.
(Docket No. EERE-2014-BT-STD-0048, No. 76, Recommendation #7)
DOE notes that this recommendation is similar to DOE's Phase 1 proposal, as it is based primarily on coil-only values. In particular, single-stage and two-stage condensing units may not ever have only a blower coil represented value. The Working Group recommendation is consistent with ADP and Unico's comments requesting that the tested combination be a coil-only unit but inconsistent with JCI's request that two-stage units be tested with a blower coil. Given the preponderance of stakeholders supporting the recommendation, and the fact that multi-stage units may be tested and rated with a blower coil, DOE believes that adopting the Working Group recommendation best addresses the majority of stakeholder concerns. For these reasons, and given that there is no longer a need for a second-phase, DOE is adopting the recommendation in the term sheet, which will become effective 180 days after publication of this final rule. DOE notes that while 1-to-1 mini-splits are not expected to have a coil-only represented value, this exception does not appear explicitly in the regulatory text. DOE clarifies that since ductless mini-splits are never distributed in commerce as coil-only units, there is no coil-only value that would be representative. Therefore these units only require blower coil represented values. DOE also notes that the Working Group recommendation that every condensing unit distributed in commerce have at least one tested combination was based on the premise that manufacturers would group multiple individual combinations with a single model of outdoor unit into a basic model, as allowed in the adopted basic model definition. If manufacturers instead choose to make every individual combination (using the same model of outdoor unit) a separate basic model, each individual combination would be required to be tested. This aligns with the basic model framework discussed in section III.A.1.a.
DOE also adopts these recommendations for space-constrained split-system air conditioners given that they are subject to the same test procedure provisions and sampling plans as non-space-constrained single-split-system air conditioners.
DOE notes that both the current test procedure and the test procedure proposed in the November 2015 SNOPR requires that the test conditions used for testing coil-only units be the same as
those used for units with single-speed compressors. For example, section 3.2.1 of the current Appendix M indicates that these tests, listed in Table 4 of Appendix M as proposed, are, “. . . for a unit . . . with no indoor blower installed.” Because the regulatory approach finalized in this notice requires that two-stage condensing units have a coil-only test, DOE has removed “coil-only units” from the description of the units that must be tested using the Table 4 tests.
DOE notes that the CAC/HP ECS Working Group recommendation also removes the requirement that the tested combination be the HSVC. DOE believes the Working Group recommendation adequately addresses JCI's concern about using the highest sales volume as a tested combination, but is inconsistent with Unico's request that OUMs test and rate the HSVC. DOE will address this aspect of the recommendation in the separate notice and has not adopted it in this final rule.
Goodman commented that DOE has not adequately accounted for the inherent variability and uncertainty existing in the psychrometric test procedures in determining that the proposed change requiring two-stage units to be tested as coil-only would not affect the certified values. Goodman commented that the test methods specified by DOE, AHRI and ASHRAE have an uncertainty for steady state testing of approximately 6-8%. Goodman also noted that ISO 16491:2012 Annex B lists several factors associated with the indoor air enthalpy method that contribute to uncertainty. Moreover, Table A.3 of ISO 16491:2012 indicates that for typical cooling capacity methods, relative expanded uncertainty might be 6.8%. Goodman commented that even at 0.05 SEER or 0.05 EER below the regional requirements, new test data would therefore either require the OUM to test additional samples or would cause a once‐compliant unit to be marked as non‐compliant for the regional standards. (Goodman, No. 73 at p. 17)
In response to Goodman's concern about this change impacting measured energy use, DOE notes that current regulations require testing with the evaporator coil that has the largest volume of retail sales with the particular model of condensing unit. DOE understands that, for two-stage units, this is typically a coil-only combination since many homeowners do not replace the furnace at the same time when they replace their split-system air conditioning system and therefore that manufacturers should represent two-stage units as coil-only combinations. At the manufacturer's discretion, the two-stage units could also be represented as blower-coil combinations. Therefore, DOE does not believe the adopted requirements for two-stage units will change the impacted energy use,
b. Split-System Heat Pumps and Space-Constrained Split-System Heat Pumps
The current requirements for split-system heat pumps in 10 CFR 429.16 require testing a condenser-evaporator coil combination with the evaporator coil likely to have the largest volume of retail sales with the particular model of condensing unit.
In the November 2015 SNOPR, DOE proposed to slightly modify the wording explaining the testing requirement for split-system heat pumps to refer to the “evaporator coil” and condensing unit” as the “indoor unit” and “outdoor unit”, as the word “outdoor unit” is more appropriate for heat pumps than “condensing unit”. DOE also proposed to apply this same test requirement to space-constrained split-system heat pumps. 80 FR 69278, 69286-87 (Nov. 9, 2015).
DOE received no comment on this proposal, and in this final rule, DOE adopts the wording modifications. However, in the separate notice regarding Appendix M1, DOE will consider additional modifications based on the recommendations of the CAC/HP ECS Working Group with regard to split-system air conditioners.
c. Multi-Split, Multi-Circuit, and Multi-Head Mini-Split Systems
The current requirements in 10 CFR 429.16(a)(2)(ii) specify that multi-split systems and mini-split systems designed for installation with more than one indoor unit be tested using a “tested combination” as defined in 10 CFR 430.2.
In the November 2015 SNOPR, DOE proposed a slight modification to the testing requirements for single-zone-multiple-coil
7
and multi-split systems and proposed to add similar requirements for testing multi-circuit systems (see section III.C.2 for more information about these systems). DOE also explained that these requirements apply to VRF systems that are single-phase and less than 65,000 Btu/h. For all multi-split, multi-circuit, and single-zone-multiple-coil split systems, DOE proposed that, at a minimum, each model of outdoor unit must be tested as part of a tested combination (as defined in the CFR) composed entirely of non-ducted indoor units. For any models of outdoor units also sold with short-ducted indoor units, DOE proposed a second “tested combination” composed entirely of short-ducted indoor units would be required to be tested. DOE also proposed that a manufacturer may rate a mixed non-ducted/short-ducted combination as the mean of the represented values for the tested non-ducted and short-ducted combinations. 80 FR 69278, 69287 (Nov. 9, 2015).
7
The November 2015 SNOPR defined a single-zone-multiple-coil split system as representing a split system that has one outdoor unit and that has two or more coil-only or blower coil indoor units connected with a single refrigeration circuit, where the indoor units operate in unison in response to a single indoor thermostat. In this final rule, DOE has adopted the term multi-head mini-split system instead.
Under the November 2015 SNOPR proposed definition of basic model, these three combinations (non-ducted, short-ducted, and mixed) would represent a single basic model. When certifying the basic model, manufacturers should report something like “* * *” for the indoor unit model number and report the test sample size as the total of all the units tested for the basic model, not just the units tested for each combination. For example, if the manufacturer tests 2 units of a non-ducted combination and two units of a short-ducted combination, and also rates a mixed combination, the manufacturer should specify “4” as the test sample size for the basic model, while providing the rating for each combination. DOE also proposed that manufacturers be allowed to test and rate specific individual combinations as separate basic models, even if they share the same model of outdoor unit. In this case, the manufacturer would provide the individual model numbers for the indoor units rather than stating a generic model, such as “* * *”.
DOE also proposed adding a requirement that, for any models of outdoor units also sold with models of small-duct, high velocity (SDHV) indoor units, a “tested combination” composed entirely of SDHV indoor units must be used for testing and rating. However, such a system would be certified as a different basic model. 80 FR 69278, 69287 (Nov. 9, 2015).
In the November 2015 SNOPR, DOE noted that multi-split systems consisting of a model of outdoor unit paired with models of non-ducted or short-ducted units should meet the energy conservation standards for split-system air conditioners or heat pumps, while systems consisting of a model of outdoor unit paired with models of SDHV indoor units should meet SDHV standards. DOE also proposed requirements for models of outdoor units that were rated and distributed in combinations that span multiple product classes to be tested and certified
as compliant with the applicable standard for each product class. Even if a manufacturer would sell a combination including models of both SDHV and other non-ducted or short-ducted indoor units, DOE proposed that the manufacturer should not provide a mixed rating for such combinations. 80 FR 69278, 69287-88 (Nov. 9, 2015).
Use of Term “Short-Ducted”
DOE received several comments regarding its use of short-ducted systems as well as requests for low-static and mid-static terminology and comments regarding conventional ducted systems. Many of these systems and ESP requirements were recommended as part of the CAC/HP ECS Working Group term sheet and will be discussed in a separate notice.
In this final rule, DOE has not adopted use of the term short-duct and instead refers only to ducted units.
Mixed Represented Values for SDHV and Other Indoor Units
Several stakeholders commented on whether they supported represented values for mixed multi-split systems including models of both SDHV and non-ducted or ducted indoor units, and if so, how they should be rated and whether the SDHV or split-system standard would be most appropriate.
Nortek commented that some manufacturers publish ratings in the AHRI Directory for SDHV and non-ducted as an average value and that it is appropriate to maintain this practice for this product as it is for the mixed (ducted and non-ducted) indoor multi-split ratings. (Nortek, No. 58 at p. 13)
Unico commented that they publish multi-split ratings for SDHV indoor units, non-ducted indoor units and a mixture of SDHV and non-ducted indoor units. The mixed rating is calculated as an average of the other two, which are based on tests. This is the same procedure used for ducted (“short-ducted”) and non-ducted indoor units. Unico requested the same consideration as all other manufacturers that have mixed (ducted and non-ducted) indoor multi-split ratings. (Unico, No. 63 at p. 3)
UTC/Carrier questioned whether there is any data available on the frequency of application of mixed SDHV and non-ducted, ducted or short duct unit systems to determine the need for a separate system rating. Lacking this data, UTC/Carrier recommended not supporting mixed multi-split system ratings for these systems. (UTC/Carrier, No. 62 at p. 4)
Goodman agreed that SDHV should not be intermixed with non‐ducted or other ducted indoor units, and that SDHV ICMs should be required to rate and certify such systems based upon the external static pressure associated with the SDHV indoor units. (Goodman, No. 73 at p. 13-14)
Unico agreed with DOE that the SDHV test standard is appropriate for testing the multi-split SDHV indoor units. However, Unico asserted that, in doing this, it is not necessary to apply a standard for the mixed indoor combinations since the ratings are based on other ratings that already meet their appropriate standard. (Unico, No. 63 at p. 3)
NEEA and NPCC supported the rating and certification of systems that are distributed in combinations that span more than one product class (such as multi-split and SDHV) and stated that these systems must be tested and rated so as to meet the standards for all product classes represented by the various available combinations. NEEA and NPCC suggested that each class rating be listed separately, in accordance with the testing and rating requirements for that class, and be so identified in the ratings documentation. (NEEA and NPCC, No. 64 at p. 4)
After reviewing the comments, DOE has determined that given that current industry practice includes mixed represented values for SDHV and other non-ducted or ducted indoor units, DOE will explicitly allow these mixed represented values based on an average of the represented values for each of the homogenous indoor systems. DOE has clarified this in 429.16. As noted in the November 2015 SNOPR, SDHV represented values must be a separate basic model. Any represented values for a mixed system including SDHV and another style of unit (non-ducted or ducted) must be in the same basic model as the SDHV model.
Ability To Test Mixed Systems
Several stakeholders commented on whether they supported having the ability to test mixed systems (
i.e.,
systems including both non-ducted and ducted indoor units) using the test procedure rather than using an average of the other tested systems.
UTC/Carrier did not support mixed system ratings nor test averaging due to consumer confusion, proliferation of ratings, and too many permutations. (UTC/Carrier, No. 62 at p. 4) The California IOUs commented that for all types of split systems, it is important to not have averaged ratings and cited as an example that, for the California Building Energy Efficiency Code (Title 24), the rating of the system being installed is needed to demonstrate compliance. For incentive programs managed by Energy Efficiency Program Administrators such as the California IOUs, calculation and tracking of energy savings require that the installed system be known and its rating is available. (California IOUs, No. 67 at p. 3)
AHRI and Nortek commented that averaging of ducted and non-ducted ratings has been a long-standing industry practice. According to AHRI and Nortek, the kind of indoor ducted unit should be identified as part of the rating so that the mixed ratings could then be based on ratings for the specific kinds of indoor units. (AHRI, No. 70 at p. 16; Nortek, No. 58 at p. 13)
In response to UTC/Carrier, DOE notes that given the test requirements to make representations for individual combinations other than the “tested combination”(as discussed later in this section), and the limited amount of permutations currently listed in the AHRI directory, proliferation of represented values is not expected. In response to the California IOUs, DOE notes that the averaged represented values are based on represented values for kinds of individual systems (
i.e.,
ducted or non-ducted). As a result, an additional averaged represented value does not take away the availability of non-averaged represented values.
AHRI and Nortek also commented that, in industry practice, multi-split ratings with mixed indoor unit types are the numerical average of the ratings for each of the homogeneous indoor systems. They stated that the most common mixture is ducted and non-ducted indoor units. They asserted that there is no test procedure that could adequately test these combinations. (AHRI, No. 70 at p. 16; Nortek, No. 58 at p. 13)
Unico did not support testing mixed multi-split systems and commented that there is no adequate test procedure. Unico commented that using a numerical average of the individual (all ducted or all non-ducted) ratings is the best method to develop a rating for a mixed multi-split system. (Unico, No. 63 at p. 3)
Rheem commented that manufacturers should be permitted to test mixed systems instead of using an average to capture the interaction of the compressor with the multiple styles of indoor units. (Rheem, No. 69 at p. 5)
NEEA and NPCC commented that, given that the rating method for mixed multi-split systems will almost invariably produce a rating that is unrelated to how they actually operate in the field, they see no value in additional testing. However, NEEA and NPCC have no objection to
manufacturers testing such systems if the manufacturers believe the ratings would be better or more reliable with additional testing. (NEEA and NPCC, No. 64 at p. 4)
DOE acknowledges that testing mixed systems could capture interactions not captured in an average; however Rheem did not provide suggestions for how to develop such a test procedure. Given that several other stakeholders believe there is not currently an adequate test procedure to do so, DOE declines to add one at this time.
Options for Averaging
Several stakeholders commented on whether they support determining represented values for mixed systems using other than a straight mean, such as a weighting by the number of non-ducted or short-ducted units.
Unico did not support weighting mixed multi-split systems. Unico commented that indoor units are made in various sizes so the number of indoor units is not indicative of the load split. In addition, Unico stated that indoor units are designed to provide a range of capacities so the load split is dependent mostly on the application rather than the indoor unit size. (Unico, No. 63 at p. 3)
NEAA and NPCC expressed ambivalence regarding the use of weighting by the number of ducted and non-ducted units in the system. They asserted that any alignment of the actual performance of such multi-zone variable capacity systems in the field and their weighted ratings would be purely accidental. (NEEA and NPCC, No. 64 at p. 4)
Given the lack of interest in weighting mixed systems, DOE will continue to allow mixed represented values only as a straight average of two individual systems represented values containing homogenous kinds of indoor units (
i.e.,
non-ducted, ducted, or SDHV) tested with the appropriate method of test in the DOE test procedure.
Determining Represented Values for Specific Individual Combinations
Several stakeholders commented on whether DOE's proposed definition in the June 2010 NOPR for “tested combination” would be appropriate for determining represented values for specific individual combinations, or whether manufacturers prefer more flexibility, such as ability to test more than 5 indoor units. See 75 FR 31223, 31231 (June 2, 2010).
UTC/Carrier commented that rating multi-split systems with more than 5 units is unnecessary, because all manufacturers offer indoor units with a nominal capacity of up to at least 12,000 BTU/hr. (UTC/Carrier, No. 62 at p. 5)
Mitsubishi commented that the original intent of the proposed “tested combination” definition was to provide variable-speed multi-split (VSMS) system manufacturers with a method to provide efficiency and capacity ratings that would be representative of all the combinations associated with a specific outdoor unit. Mitsubishi stated that DOE based the “tested combination” concept on the fact that the outdoor unit is the primary driver for efficiency and capacity and that DOE recognized that, if a manufacturer had “specific” combinations that had higher efficiencies than the “tested combination,” then the manufacturer could test and rate that “specific” combination and enter it into the AHRI VSMS Directory of Certified Products. Mitsubishi recommended that DOE continue this process because it provides the VSMS manufacturer with the best opportunity to highlight top-performing combinations. (Mitsubishi, No. 68 at p. 3)
Unico supported the proposed DOE definition of “tested combination” and stated that there is no need to rate individual combinations unless the manufacturer chooses to rate all possible combinations (for example, if a manufacturer has a limited number of indoor models). Unico commented that single-split systems (one indoor unit) using the same outdoor unit used for multi-split systems should continue to be rated individually. (Unico, No. 63 at p. 4)
NEEA and NPCC acknowledged that combinations that might fall outside the current definition of “tested combination” systems do exist and are installed on a regular basis. The testing burden would be relatively small, as only the largest-capacity systems are capable of operating with more than 5 indoor units. (NEEA and NPCC, No. 64 at p. 4)
AHRI and Nortek commented that they do not believe the tested combination approach is appropriate for rating specific individual models. (AHRI, No. 70 at p. 16; Nortek, No. 58 at p. 13)
Rheem commented that the benefits of mix match ratings for multi-split systems are the same as those provided by mix match ratings for split systems. Rheem stated that consumers expect the ratings provided by DOE to reflect the operation of the system in their home and concluded that outdoor units should be rated to the worst case scenario and manufacturers should use an AEDM to determine the other combinations of indoor and outdoor units. On the other hand, DOE notes that Rheem also commented that a configuration that represents the highest sales volume should be established for multi-split systems. (Rheem, No. 69 at p. 5)
After reviewing the comments, DOE maintains its proposal to allow manufacturers to rate individual combinations as additional basic models beyond the required tested combinations. DOE agrees with Rheem and Mitsubishi that consumers and utilities often find benefit for having represented values for a wide variety of combinations that are available for installation.
DOE also agrees with Unico that single-split systems (one indoor unit) using the same outdoor unit used for multi-split systems must continue to be rated individually.
Sample Size
Several stakeholders commented on DOE's request for information and data on manufacturing and testing variability associated with multi-split systems that would allow it to understand how a single unit may be representative of the population and what tolerances would need to be applied to represented values based on a single unit sample in order to account for variability.
Lennox commented that multi-split products are subject to the same type of variability as a conventional unit in areas such as compressor variation, coil performance variation, charging, airflow, expansion device, etc. Lennox did not support an allowance for OUM manufacturers of multi-split products to be rated based on a single unit test while OUM manufacturers of conventional products are required to test a minimum of two samples to meet statistical confidence levels. Lennox asserted that all OUM-manufactured products should be required to meet the same minimum test requirements. (Lennox, No. 61 at p. 14)
Mitsubishi and Rheem also recommended that the ratings be established based on the testing of at least two samples. (Mitsubishi, No. 68 at p. 3; Rheem, No. 69 at p. 6)
The California IOUs commented that, in addition to manufacturing variances, controls software creates an additional source of variability in the performance of multi-split systems. The California IOUs asserted that software drives the performance of these variable capacity units based on the input from indoor and outdoor sensors. They stated that, until DOE-vetted data is available for these controls, the use of results from a single unit test for rating is inadvisable. (California IOUs, No. 67 at p. 4)
Unico commented that a single unit test is adequate provided the manufacturer rates a system conservatively. Specifically, Unico said that a manufacturer should not be permitted to rate a product directly using the result of the single test; instead, the manufacturer can generate a rating from a single test through derating the measured performance. Unico gave the example that the rated capacity and efficiency of a system should be at least 95 percent less than the single test result. If two or more tests are conducted, then Unico suggested that the rating could be the mean value or less. (Unico, No. 63 at p. 4)
Goodman suggested that, if DOE mandates that ratings for a single given kind of air conditioner (ducted, non‐ducted or mixed) be based on two sample systems, then OUMs should be able to use AEDMs to rate some of the kinds of systems. Goodman stated that, because many multi‐split and multi‐head mini‐split systems use the same indoor products for multiple sizes (
e.g.,
a 2‐ton system may use two 1‐ton indoor units while a 3‐ton system may use three of the exact same 1‐ton indoor units), a method to use an AEDM should be developed for rating non‐tested systems. Goodman gave the example that, if one OUM chose to test two sample systems of non‐ducted indoor units, it should be able to rate ducted and mixed systems based on an AEDM. Goodman asserted that, if the OUM chose to have a single rating for all combinations of ducted indoor units, then the AEDM would obviously have to be used to rate the combination of ducted indoor units with the lowest efficiency rating. Goodman gave a contrasting example that, if another OUM chose to rate multiple different combinations of ducted indoor units, then each combination would be rated using an AEDM. (Goodman, No. 73 at p. 13)
AHRI and Nortek recommended that DOE maintain consistency with its AEDM approach used in the commercial HVAC equipment such that, at a minimum, manufacturers would test two low static units and apply the AEDM to derive ratings for the high static and mixed ratings. (AHRI, No. 70 at p. 16; Nortek, No. 58 at p. 13)
As previously noted, Rheem stated that outdoor units should be rated to the worst case scenario and manufacturers should use an AEDM to determine the other combinations of indoor and outdoor units. (Rheem, No. 69 at p. 5)
After reviewing the comments, DOE found that commenters did not provide data on manufacturing and testing variability that would support DOE moving to a single unit sample approach. In response to Goodman, AHRI, Nortek, and Rheem, DOE notes that DOE's current regulations require that represented values for a single kind of system be based on testing a sample of at least two units representative of production units. For these reasons, DOE is not moving to a single unit sample approach and also declines to require only the represented values of a single kind of system to be based on testing while allowing other kinds of systems to be represented using an AEDM, given that the adopted testing requirements do not increase test burden compared to the current regulations. DOE is allowing use of an AEDM for off-mode, as discussed in section III.B.8.
Summary
In summary, Table III.2 provides an example of allowable represented values for multi-split, multi-circuit, and multi-head mini-split systems.
Table III.2—Example Represented Values for Multi-Split Systems
Basic model
Individual model (outdoor unit)
Individual model(s) (indoor unit)
Sample size
Ducted rep. value
Non-ducted rep. value
Mix rep. value (D/ND)
SDHV rep. value
Mix rep. Value (SDHV/D)
Mix rep. value (SDHV/ND)
ABC
ABC
***
4
14
15
14.5
ABC-ND1
ABC
2-A123; 3-JH746
2
17
ABC-SDHV
ABC
***
6
11.5
12.75
13.25
d. Basic Models Rated by ICMs
In the November 2015 SNOPR, DOE proposed to require ICMs to test and provide certified ratings for each model of indoor unit (
i.e.,
basic model) with the least-efficient model of outdoor unit with which it will be paired, where the least-efficient model of outdoor unit is the outdoor unit in the lowest-SEER combination as certified by the OUM. If more than one model of outdoor unit (with which the ICM wishes to rate the model of indoor unit) has the same lowest-SEER rating, the ICM may select one for testing purposes. ICMs must rate all other individual combinations of the same model of indoor unit, but may determine those ratings through testing or use of an AEDM. 80 FR 69278, 69288 (Nov. 9, 2015).
AHRI, ADP, Lennox, Mortex, and First Co. commented that DOE's proposed changes to the definition of “basic model” with respect to ICMs, along with the proposed requirement to test at least one combination within each basic model, presents a significant testing burden to ICMs. (First Co., No. 56 at p. 1; AHRI, No. 70 at p. 3; ADP, No. 59 at p. 1; Lennox, No. 61 at p. 4) In order to avoid this burden, AHRI, ADP, Lennox, and Mortex recommended DOE adopt and define the term “Similarity Group,” a group of ICM basic models within a defined range of coil geometries, with performance substantiated by the same validation test, and require testing of a Similar Group rather than testing of each basic model. The range of coil geometries within a Similarity Group would be defined by: face area within ± 1 square feet (
e.g.
2-4, 4-6, etc.), fin material (
e.g.
aluminum, copper), fin style (
e.g.
wavy, louvered), fin density within ± 1 fin per inch (
e.g.
10-12, 13-15, etc.), number of rows, tube pattern (
e.g.
1 × 0.625, 1 × 0.75, etc.), tube size (
e.g.
outer diameter for round tube, channel characteristic size for microchannel), and tube internal enhancement (
e.g.
smooth or enhanced). (AHRI, No. 70 at p. 5; ADP, No. 59 at p. 2-3; Mortex, No. 71 at p. 4-6; Lennox, No. 61 at p. 5) AHRI, ADP, Mortex, and Lennox noted that in the proposed framework, Similarity Groups may span AC and HP operations as well as coil-only and blower coil combinations. (AHRI, No. 70 at p. 6; ADP, No. 59 at p. 3; Mortex, No. 71 at p. 6; Lennox, No. 61 at p. 6)
However, the commenters noted that the proposed Similarity Group concept would not replace the concept or definition of an ICM basic model. Instead, a Similarity Group would be a group of basic models for defining AEDM validation test requirements, and the ICM basic model would still be used for other aspects of the certification and enforcement scheme as noted in the SNOPR. (AHRI, No. 70 at p. 7; ADP, No. 59 at p. 4; Mortex, No. 71 at p. 7; Lennox, No. 61 at p. 7)
With regard to DOE's proposed definition of basic model for ICMs, Lennox requested that tube wall thickness not be required as part of a certification report as to protect business sensitive design information. (Lennox, No. 61 at p. 3)
UTC/Carrier, Rheem, and the Joint Advocates of ACEEE, NRDC, and ASAP supported DOE's proposal for ICMs to test each model of indoor unit with the lowest-SEER model of outdoor unit that is certified as a part of a basic model by an OUM. (UTC/Carrier, No. 62 at p. 6; Rheem, No. 69 at p. 6; ACEEE, NRDC, ASAP, No. 72 at p. 2) UTC/Carrier appreciated leveling the playing field closing this loophole advantage for ICMs. (UTC/Carrier, No. 62 at p. 6)
On the other hand, AHRI, ADP, Lennox, and Mortex commented that testing is necessary to validate product performance and each ICM's AEDM, but that the requirement to test every basic model presents an excessive burden on ICMs. (AHRI, No. 70 at p. 3; ADP, No. 59 at p. 1; Mortex, No. 71 at p. 3; Lennox, No. 61 at p. 4) First Co. also commented that the result of DOE's proposal is excessive testing. (First Co., No. 56 at p. 1)
AHRI analyzed data from the AHRI Directory of Certified Product Performance, considering air conditioning, heat pump, coil-only and air handler ratings, but omitting due to time limitations air flow, external static pressure and power input. The results indicated that each ICM has between 287 and 604 basic models for which they would have to bear the cost of testing, which AHRI estimated would increase several-fold if accounting for the additional parameters. AHRI stated that it used an estimate of testing costs for one system at an independent lab of $7,400 for AC and $10,000 for HP because many ICMs do not have their own labs. Therefore, by AHRI's calculations, the ICM with the smallest number of basic models from their analysis would be required to perform 574 tests for an estimated $5,740,000 in testing costs. In addition, a test takes approximately one day, so 574 tests would take approximately two years to complete. (AHRI, No. 70 at p. 4-5)
For these reasons, AHRI, ADP, Mortex, and Lennox recommended that DOE require all ICM ratings to be based on an AEDM, where the ICM would test and rate at least one combination of an outdoor unit with the lowest SEER that complies with standard per Similarity Group. They also recommended that the ICM perform at least one full-system test per Similarity Group, or if the ICM was rating HP combinations, the ICM test one-third of the Similarity Groups with HP systems in both heating and cooling modes; and certify all combinations before they are distributed in commerce. (AHRI, No. 70 at p. 5-6; ADP, No. 59 at p. 2-3; Mortex, No. 71 at p. 4-6; Lennox, No. 61 at p. 5) AHRI, ADP, Mortex, and Lennox noted that applying this scheme to the AHRI Directory results in between 26 and 64 tests for the same ICM companies analyzed above. AHRI, ADP, Mortex, and Lennox believed that their suggested method provides for an extremely high level of AEDM validation while creating a manageable testing burden on ICMs. (AHRI, No. 70 at p. 6; ADP, No. 59 at p. 3-4; Mortex, No. 71 at p. 6; Lennox, No. 61 at p. 6-7)
First Co. and Unico also supported AHRI's approach. First Co. commented that the use of a Similarity Group would be a more realistic and workable approach that would enable ICMs to reduce testing for comparably performing indoor coils and to validate performance for the group by the same test. (First Co., No. 56 at p. 1) Unico recommended that DOE require the OUM to have at least two tests for each basic model (the outdoor unit) and the ICM to have at least one test from each Similarity Group in order to validate the AEDM. Unico also noted that the ICM testing requirements would increase significantly compared to what they are today even under AHRI's suggestion. (Unico, No. 63 at p. 4-5)
After reviewing the comments, DOE agrees with the manufacturers that its proposed definition of basic model with respect to ICMs, combined with the proposed testing requirements, may result in a significant test burden for ICMs. In order to balance the burden of testing with the risk of enforcement action, DOE is adopting aspects of the suggested “Similarity Group” as a replacement to its proposed definition of basic model. Hence, the basic model definition for ICMs established in this final rule includes all individual combinations having comparably performing indoor coil(s) [plus or minus one square foot face area, plus or minus one fin per inch fin density, and the same fin material, tube material, number of tube rows, tube pattern, and tube size].
DOE also agrees that manufacturers should test one combination per what the AHRI and manufacturer calls “Similarity Group”, and what DOE will call a basic model for ICMs. However, DOE does not agree that testing should only serve to validate AEDMs. In order to accurately rate these non-engineered-to-order products by capturing the variability in the manufacturing processes, all combinations required to be tested must be tested according to the sampling plan in 429.16, which generally requires a sample of at least two units of the basic model. DOE notes that AHRI's calculation of burden assumes that ICMs have not been testing under current regulations, which is not consistent with existing DOE regulations. In addition, by changing the proposed definition of basic model to align with the similarity group proposal, DOE has significantly reduced the proposed test burden on ICMs.
DOE notes that because basic models do not span product classes, unlike in the stakeholders' proposal, each Similarity Group is limited to either air conditioners or heat pumps; however, in response to the stakeholders' request that only one-third of Similarity Groups need be tested in both cooling and heating mode, DOE is not requiring testing for basic models of heat pumps as long as an equivalent basic model of air conditioner has been tested.
DOE also notes that while off-mode power consumption requirements apply to ICMs, the represented values for off-mode may be based on the results of testing by the OUM according to the requirements in 429.16.
In response to Lennox's request to remove tube wall thickness from the definition of basic model, DOE notes that the Similarity Group requirements DOE is adopting in its basic model definition for ICMs do not include tube wall thickness; in addition, as noted in section III.A.1.c, DOE did not propose that manufacturers report this information regardless of its inclusion in this definition.
e. Single-Package Systems
In the current regulations, 10 CFR 429.16(a)(2)(i) states that each single-package system must have a sample of sufficient size tested in accordance with the applicable provisions of Subpart B. In the November 2015 SNOPR, DOE proposed that the lowest SEER individual model within each basic model must be tested. DOE expected that in most cases, each single-package system would represent its own basic model. However, based on the definition of basic model in section III.A.1, this may not always be the case. DOE noted that regardless, AEDMs do not apply to single-package systems—manufacturers may either test and rate each individual single-package system or, if multiple individual models are assigned to the same basic model per the proposed requirements in the basic model definition, test only the lowest SEER individual model within the basic model and use that to determine the
rating for the basic model. 80 FR 69278, 69288 (Nov. 9, 2015).
DOE also proposed to specify this same requirement for space-constrained single-package air conditioners and heat pumps. 80 FR 69278, 69288 (Nov. 9, 2015).
DOE requested comment on the likelihood of multiple individual models of single-package units meeting the requirements proposed in the basic model definition to be assigned to the same basic model. DOE also requested comment on whether, if manufacturers are able to assign multiple individual models to a single basic model, manufacturers would want to use an AEDM to rate other individual models within the same basic model other than the lowest SEER individual model.
In response, Lennox commented that the use of basic models that meet the defined requirements should not be restricted to split-system products because allowing groupings in a basic model may allow the use of AEDMs for single-package products to reduce testing burden. (Lennox, No. 61 at p. 14) UTC/Carrier supported that different options would be assigned to [individual models within] the same basic model and supported the ability to have unique ratings for units with different options without additional testing. (UTC/Carrier, No. 62 at p. 6-7)
JCI stated that it, in general, would prefer to test single-package units, especially the single-phase models. For 3-phase (commercial) products, JCI would opt to utilize an AEDM. (JCI, No. 66 at p. 15)
Rheem disagreed that manufacturers should not be allowed to use AEDM to rate packaged units; Rheem would want to use an AEDM to rate other individual models within the basic model for packaged units. (Rheem, No. 69 at p. 3, 6-7)
In response to these comments, DOE is modifying the regulations to permit the use of AEDMs for models of single-package units in cases where multiple individual models are assigned to the same basic model. The lowest SEER individual model in the basic model still will be required to be tested. DOE believes that the lowest SEER model will typically be similar to the highest sales volume model.
f. Replacement Coils
In the November 2015 SNOPR, DOE noted that its proposed definition of “indoor unit” refers to the box rather than just a coil. Accordingly, legacy indoor coil replacements and uncased coils would not meet the definition of indoor unit of a central air conditioner or heat pump. Hence, they would not need to be tested or certified as meeting the standard. 80 FR 69278, 69289 (Nov. 9, 2015).
DOE received several comments in response to this proposal. These comments have been addressed as part of DOE's definition of “indoor unit,” discussed in section III.A.2.
g. Outdoor Units With No Match
For split-system central air conditioners and heat pumps, current DOE regulations require that manufacturers test the condensing unit and “the evaporator coil that is likely to have the largest volume of retail sales with the particular model of condensing unit” (commonly referred to as the highest sales volume combination or HSVC). 10 CFR 4429.16(a)(2)(ii). Effective January 1, 2010, the U.S. Environmental Protection Agency (EPA) banned the sale and distribution of those central air conditioning systems and heat pump systems that are designed to use HCFC-22 refrigerant. 74 FR 66450 (Dec. 15, 2009). EPA's rulemaking included an exception for the manufacture and importation of replacement components, as long as those components are not pre-charged with HCFC-22.
Id.
at 66459-60.
Because complete HCFC-22 systems can no longer be distributed, manufacturers inquired how to test and rate individual components. Because the EPA prohibits distribution of new HCFC-22 condensing unit and coil combinations (
i.e.,
complete systems), there is no such thing as a HSVC, and hence, testing and determination of represented values of new HCFC-22 combinations cannot be conducted using the existing test procedure.
Accordingly, DOE proposed a test procedure that may be used for determining represented values and certifying the compliance of these outdoor units. DOE proposed to specify coil characteristics to be used when testing models of outdoor units that do not have a HSVC. Specifically, these requirements included limitations on indoor coil tube geometries and dimensions and coil fin surface area. In the November 2015 SNOPR, DOE proposed to require the normalized gross indoor fin surface (NGIFS) calculated for the indoor unit used for the test to be no more than 1.15. 80 FR 69278, 69289 (Nov. 9, 2015). NGIFS is the fin surface area divided by the unit's capacity. By imposing a limit on this value, the size of the indoor coil would be consistent with older model designs that would likely be installed in the field and that do not include a common design approach for improving efficiency,
i.e.
use of larger coils. Attaining a given efficiency level when testing a combination having a lower-NGIFS indoor unit requires use of a more efficient outdoor unit to compensate. These outdoor unit models must meet applicable Federal standards when tested with the specified indoor units.
General Comments
AHRI, URI, Nortek, HARDI, Goodman, UTC/Carrier, Rheem, and JCI submitted comments against adding the test procedure provisions for outdoor units with no match. (AHRI, No. 70 at p. 2; United Refrigeration, Inc., No. 60 at p. 3-4; Nortek, No. 58 at p. 2; HARDI, No. 57 at p. 2; Goodman, No. 73 at p. 17-18; UTC/Carrier, No. 62 at p. 22-23; Rheem, No. 69 at p. 3; JCI, No. 66 at p. 5)
Nortek and UTC/Carrier expressed concern that offering a test procedure for units with no match could potentially open up a larger loophole than what DOE is attempting to fix with this proposal. (Nortek, No. 58 at p. 2; UTC/Carrier, No. 62 at p. 23) Similarly, Nortek and HARDI noted that there have been no instances of a company trying to sell an outdoor unit without match that failed to meet existing standards. (Nortek, No. 58 at p. 2; HARDI No. 57 at p.1)
Conversely, Lennox, NEEA, NPCC, and the Joint Advocates of ACEEE, NRDC and ASAP concurred with DOE's proposal to require testing and rating of dry-ship units. (Lennox, No. 61 at p. 2; NEEA and NPCC, No. 64 at p. 3; ACEEE, NRDC and ASAP, No. 72 at p. 2)
DOE acknowledges these comments and responds to particular concerns about its proposal in subsequent sections.
URI commented that the Department's proposal not only would ban the manufacture of new replacement units, it also would impose significant cost burdens on manufacturers and distributors of replacement HCFC-22 components. URI suggested that under DOE's proposal, replacement unit manufacturers that tested and certified HCFC-22 products in good faith reliance of the various test procedure guidance documents issued by the Department would be unable to advertise or sell these units. URI requested that DOE evaluate the impacts of replacing rather than repairing and maintaining an HCFC-22 unit, particularly on those consumers who live on a fixed income, and that DOE assess whether, as a practical matter, this test procedure amendment would adversely impact the availability of replacement components for the installed base of HCFC-22 units.
(United Refrigeration, Inc., No. 60 at p. 8-9)
In response to URI, DOE's approach in developing the test procedure requirements for outdoor units with no match is based on the concept that the test should produce results that measure energy efficiency during a representative average use cycle. (42 U.S.C. 6293 (b)(3)) Further, the test procedure addresses the fact that these units have no match. Unmatched outdoor units are primarily used as a low-cost alternative to replacement of an entire legacy system when the outdoor unit is no longer operational. Specifically, in such installations, only the outdoor unit would be replaced, rather than both the outdoor unit and indoor unit. In addition, such units would be installed using HCFC-22, which is no longer legal for use in new systems.
DOE developed this amended test procedure with the goal of ensuring that the unmatched outdoor unit should be compliant when tested with an indoor unit that is representative of indoor units in the field with which the outdoor unit could be paired. DOE's goal was to provide a method of test, consistent with the current standards, that meets the statutory requirement of measuring a representative average use cycle. Hence, the indoor unit specifications are intended to represent among the lesser-efficient units that could be paired with a given outdoor unit with no match. DOE believes this approach is consistent with the requirement that the represented value for a basic model reflect the performance of the poorest-performing model that is part of the basic model.
In response to URI's comments regarding evaluation of cost burdens and impacts of the test procedure change, DOE notes that its energy conservation standard rulemakings have already evaluated the costs and benefits of specific efficiency levels for central air conditioners and heat pumps. This test procedure provides a mechanism of assessing the performance of unmatched outdoor units, which can then be used to provide a reasonable level of assurance that all field-match combinations of the new, unmatched outdoor units will achieve the established efficiency levels. DOE is now adopting the November 2015 SNOPR approach for testing and determining represented values for unmatched outdoor units based on stakeholder comment.
Goodman had concerns about unforeseen and unintended consequences when moving forward with alternate refrigerants at some date in the future, especially as the requirements for applying air conditioners and heat pumps with these likely A2L refrigerants is unknown. Goodman stated that it expects that, with currently known alternate refrigerants, there may be a need for certain low‐income and elderly consumers to have cost-effective replacement air conditioners. Goodman also noted that it has apprehensions that providing a test procedure provides a path for HCFC‐22 “dry ship” products to continue in the marketplace. (Goodman, No. 73 at p. 18)
DOE responds that it cannot set test procedure requirements based on speculation about the potential cost impact of future refrigerant changes on air-conditioning product costs. In response to the second comment, DOE points out the suggestion of commenters that DOE's proposal will limit sales of these units—URI for example indicated that the test procedure will effectively end the manufacturer of such components (URI, No. 60 at p. 2). While DOE does not agree with this assessment, DOE also does not believe that the approach will increase manufacturer of such units.
DOE Authority
In its comments, JCI stated that it was not certain that DOE has the authority under EPCA to create a test procedure to allow for units with no match. (JCI, No. 66 at p. 6)
URI commented that the DOE's November 2015 SNOPR test procedure, if finalized, would violate EPCA, as amended, as well as the Administrative Procedure Act. URI asserted that DOE had proposed a restriction on representations for already manufactured and certified units and that the proposal would invalidate the expectation-backed investments of manufacturers and distributors, constituting a violation of the Fifth Amendment to the U.S. Constitution. URI characterized DOE's proposal as an effective ban on condensing units using HCFC-22 that also would impose significant cost burdens on consumers. (United Refrigeration, Inc., No. 60 at p. 2, 3-5)
URI also commented that a test procedure change for replacement HCFC-22 systems is not needed, and that DOE has not articulated a valid basis for its proposal, as required by EPCA. URI argued that DOE's proposed test procedure change for replacement HCFC-22 systems would violate the Administrative Procedure Act, which requires an agency to “examine the relevant data and articulate a satisfactory explanation for its action including a `rational connection between the facts found and the choice made.'” 5 U.S.C. 553,
Motor Vehicle Manufacturers Ass'n
v.
State Farm Mutual Automobile Insurance Co.,
463 U.S. 29 (1983)). URI said that the DOE did not only fail to explain why the change to the test procedure for replacement units is necessary, but also failed to acknowledge the de facto ban it is proposing for such units. URI argued that DOE does not have the authority to impose a ban on replacement units and asserted that, even assuming that DOE has the authority to impose such a ban, that EPCA prohibits the Department from implementing such an action through a test procedure amendment. (United Refrigeration, Inc., No. 60 at p. 5)
URI also argued that DOE could not circumvent the prohibition against retroactive effect by belatedly “clarifying” that HCFC-22 condensing components are basic models in and of themselves, even assuming that the EPCA would allow such a comprehensive revision of the “basic model” via test procedure rulemaking. (United Refrigeration, Inc., No. 60 at p. 9)
Contrary to URI's assertions, DOE is not, in this rule, imposing a de facto ban on condensing units using HCFC-22. DOE is amending a test procedure and, in accordance with the applicable provisions of EPCA, is ensuring that the test procedure is reasonably designed to measure the energy efficiency and energy use of unmatched outdoor units in a manner that is comparable to that of other complete systems. DOE clearly articulated the basis for its proposal and has explained again here the need for a test procedure applicable to unmatched outdoor units. Regarding the amended definition of basic model in today's rule, DOE is not proposing that the definition, as amended, be applied retroactively.
Test Procedure Details Including Specification of Indoor Unit
Stakeholders provided a range of comments regarding whether the proposed details of the test for outdoor units with no match are suitable.
Nortek, Ingersoll Rand, and Goodman questioned how DOE determined the proposed value for NGIFS and that the default coefficient of cyclic degradation should be used for these units, and requested that DOE provide supporting evidence. (Nortek, No. 58 at p. 2; Ingersoll Rand, No. 65 at p. 12; Goodman, No. 73 at p. 18)
URI commented that it is simply impossible for any HCFC-22 replacement component to meet the 13
SEER standard using the amended test procedure, stating that the proposed coil size limitation makes no sense as such coils were used in HCFC-22 units rated to 10 SEER. URI also asserted that the proposed coefficient of cyclic degradation improperly excludes units that use thermostatic expansion valves, rather than orifice tubes, to control the flow of refrigerants, thus penalizing the efficiency rating approximately 6% (for example, a 13 SEER unit with a thermostatic expansion valve would instead rate at 12.2 SEER). (United Refrigeration, Inc., No. 60 at p. 2, 7)
Goodman noted that by specifically choosing the 1.15 maximum NGIFS (especially without deference to the type of fin used), DOE is choosing indoor coils that are smaller, but not smallest, in size. Goodman commented that based on the information it has, the value of 1.15 would favor one manufacturer, which has all of its “no‐match” units rated with indoor coils having less than 1.15 NGIFS, while at least two manufacturers have zero “no‐match” units rated with indoor coils having less than 1.15 NGIFS. Goodman commented that DOE should not ignore fin surface type in the NGIFS calculation, and that if DOE's intent is intent is to specify an indoor coil size such that it is virtually impossible for an OUM to have an outdoor unit with no match that can achieve 13 or 14 SEER as a system, then DOE should choose an NGIFS in the range of 0.90 or less using the proposed NGIFS formula. (Goodman, No. 73 at p. 18-19)
JCI commented for a 10 SEER product, the value of NGIFS of 1.15 is too small. The NGIFS of 10 SEER products made by JCI was 1.25, and these products will have been out of production for 10 years by the time this SNPOR is effective. JCI said that, at this point, when an outdoor unit fails, approximately 40% to 50% would be 13 SEER plus equipment. A reasonable NGIFS for 13 SEER equipment would be 1.30, which is the average for JCI's 13 SEER HCFC-22 product when the EPA ban on new produced equipment shipped with HCFC-22 took effect in 2010: averaging the 10 SEER and 13 SEER values leaves a value of 1.28. JCI believes this value to be a more representative value for NGIFS and recommends DOE adopt it. (JCI, No. 66 at p. 5-6)
Ingersoll Rand provided data on the 61 HCFC-22 systems that they had on the market before HCFC-22 was phased out. For the HSVCs of these 61 models, the NGIFS ranged from 0.9784 to 1.9082 with a mean of 1.2692 and a standard deviation of 0.2215. Ingersoll Rand recommended a value of 1.75 for the final rule. (Ingersoll Rand, No. 65 at p. 12)
JCI commented that modern heat exchanger technology such as that found in microchannel heat exchangers significantly reduces the refrigerant charge and thus reduces the cycling losses, resulting consistently in degradation coefficient values under 0.10 with piston metering (expansion) devices, or non-bleed TXVs. JCI recommended that rather than requiring use of the default degradation coefficient value, DOE should specify the type of expansion device it believes would be used in the legacy indoor units, which in most instances would be a piston or fixed orifice construction. (JCI, No. 66 at p. 6)
As mentioned above, DOE's approach in developing the test procedure requirements for outdoor units with no match is based on the concept that the test should produce results which measure energy efficiency during a representative average use cycle (see 42 U.S.C. 6293(b)(3)) while also ensuring that they will generally meet the standard. By their nature, however, neither the manufacturer nor DOE knows exactly what the paired system will be. DOE evaluated indoor unit specifications representing units across the spectrum that would likely be paired with the “no match” units. To ensure compliance, DOE proposed indoor unit specifications that it believed to be representative of a less efficient unit that could be paired with the given outdoor unit with no match.
In developing its proposal, DOE developed the indoor unit specifications (1.15 NGIFS and coefficient of cyclic degradation equal to the default) through reverse engineering 13 SEER split-system blower coil air conditioners designed to use HCFC-22. The 1.15 value is representative of the indoor units associated with the evaluated systems. All of these units had single-capacity compressors, and the indoor units had PSC fan motors. Although the NGIFS for these units ranged from 1.0 to 1.7, almost identical to the range of the data provided by Ingersoll Rand, DOE does not feel that establishing an NGIFS range is a valid approach, since this would be equivalent to setting the limit equal to the highest end of the range. In any case, both of these datasets are at odds with URI's claim that the 1.15 NGIFS makes attaining 13 SEER impossible. Regarding JCI's claim that the value is too small, the selected value is for an indoor unit that was part of an HCFC-22 unit rated at 13 SEER, hence it is certainly representative of the indoor units that may be installed in the field. In fact, DOE's selection of 1.15 did not consider the 10 SEER units whose indoor units are still in the field as well. In addition, the actual performance of the non-replaced legacy indoor units, represented in terms of NGIFS, generally will be significantly degraded. Degradation of indoor unit performance can be caused by numerous factors, including foulants coating external coil surfaces, caustic environments attacking fin material and/or fin/tube contact, inadequate air flow, and degraded oil fouling the internal tube surfaces. Consistent with the use of unmatched outdoor units for such system repairs as a low-cost alternative, it is questionable whether installation consistently addresses optimization of the system for operation at the diminished efficiency potential of the degraded legacy indoor unit. Consequently it is expected that laboratory testing of new models of unmatched outdoor units significantly overestimates the efficiency of these units when paired with old legacy indoor units in the field. The proposed maximum NGIFS of the indoor unit to be used in such a test is in the range of the values for legacy indoor units, but, because of the non-optimum field conditions, choosing a value that is an average or median for such legacy indoor units is not representative. Based on all of these considerations, DOE has decided to lower the required NGIFS for the test to 1.0. This level acknowledges degradation of indoor unit performance over time, questions regarding optimization of the indoor/outdoor unit match and of the installation, and that the range of indoor units in the field would also include 10 SEER units. This value is representative of the 13 SEER systems of both DOE's and Ingersoll Rand's datasets. DOE notes that the comments have not shown that this value is unrepresentative of the potential indoor unit pairings of no-match outdoor units. Furthermore, given that DOE believes this value is representative and that an NGIFS range is not a valid approach, DOE does not believe there is a need for AEDM for these units.
DOE understands that the type of fin surface has an impact on coil performance, as Goodman pointed out in its comment. Most of the fins of the evaporator coils of DOE's dataset were enhanced, having lanced or louvered surfaces, so DOE's assessment has considered the possibility that the fin surfaces would be enhanced. DOE believes that selecting the NGIFS limit based on enhanced-fin information is appropriate because any manufacturer conducting such a test would do so using an indoor unit that has enhanced
fins, which would provide an advantage to the manufacturers.
DOE notes JCI's comment that when an outdoor unit fails, 40% to 50% of the indoor units would have been rated 13 SEER or higher. This suggests that at least half would have been rated lower than 13 SEER. JCI also suggested that NGIFS might be 0.05 lower for a 10 SEER indoor unit than for 13 SEER. The Ingersoll Rand comment indicates that the NGIFS of their HCFC-22 models on the market prior to the refrigerant's phase-out was as low as 0.9784. Since the 13 SEER standard took effect in 2006, DOE presumes that these units all had a SEER value no lower than 13.
DOE agrees with JCI that advanced heat exchanger technology might improve system efficiency. In particular, microchannel heat exchangers may reduce refrigerant charge sufficiently to reduce degradation of performance associated with unit cycling. However, DOE is not convinced that the expansion devices, be they thermostatic expansion valves, pistons, or fixed-orifice devices, of all legacy indoor units are replaced with orifices optimized for the new paired combination using the intended refrigerant. DOE agrees that a degradation coefficient less than the default value may be achievable in a laboratory test while using a fixed orifice device, but is not convinced that this will consistently be achieved with field-paired combinations. JCI did not comment on the consistency of the replacement of the expansion devices in unmatched outdoor unit installations, so DOE cannot determine how many such installations include expansion devices that are optimized for the outdoor/indoor unit combination. It is reasonable to expect that numerous such installations do not involve installation of an optimized expansion device, since unmatched outdoor units are sold as a low-cost alternative to purchase of an entirely new system, and use of the existing expansion device would also reduce cost. Further, DOE notes that reduction of the cyclic degradation coefficient, as proposed in the November 2015 SNOPR, was based on the observation that most modern systems achieve degradation coefficients well below 0.2. DOE did not intend to assign this same value as the default for outdoor units without a match. Based on the same arguments regarding lack of optimization of the expansion devices, DOE does not believe it is appropriate to adopt the new-test default of 0.2 for these units and therefore is retaining the current degradation coefficient for them at 0.25.
Waiver Process and Change in the Measurement
Nortek, Goodman, and HARDI commented that manufacturers who would like to sell a condensing unit with no match should request a waiver from DOE. (Nortek, No. 58 at p. 2; Goodman, No. 73 at p. 18; HARDI, No. 57 at p. 2)
URI commented that the notice is silent on how the proposed coil limitation or NGIFS will improve the measured energy efficiency of replacement HCFC-22 condensing units and that DOE's view that these units should have been tested pursuant to a waiver doesn't make sense in light of guidance DOE issued in 2010, 2012, and 2014 . URI separately indicated that DOE has not clarified whether the test procedure change will alter the measurement and/or whether the standard would have to be adjusted as required by EPCA. (United Refrigeration, Inc., No. 60 at p. 6)
In response to Nortek, Goodman, and HARDI, DOE notes that the waiver process is a step towards establishing new procedure provisions in the CFR that address the test procedure issues raised by the waiver. In this case, as mentioned by some commenters, at the time of publication of the November 2015 SNOPR, there had been no petitions for waivers for outdoor units with no match. Test procedure waivers are not a long-term solution, however. DOE's regulations require DOE to amend its test procedure to address an issue raised through the waiver process. Therefore, even though DOE has not received any petitions for waivers for outdoor units with no match, DOE has long recognized the difficulty of reconciling the current test procedure language with the reality that manufacturers have no highest sales volume combination due to EPA regulations and proposed a test method to eliminate the regulatory incongruity between EPA's and DOE's regulations. DOE is finalizing a test procedure to eliminate the issue.
In response to URI, DOE acknowledges that its guidance document indicated that an individual condensing unit must meet the current Federal standard when paired with the appropriate other new part to make a system when tested in accordance with the DOE test procedure and sampling plan. However, as noted in the November 2015 SNOPR, generally when a model cannot be tested in accordance with the DOE test procedure, manufacturers must submit a petition for a test procedure waiver for DOE to assign an alternative test method. Nothing in the guidance documents indicated that this would not have been the case for these units.
In response to URI's comment suggesting that measured energy use must improve under a waiver procedure, DOE notes that a test procedure waiver is not intended to impact measured energy efficiency. Instead, a test procedure waiver provides a manufacturer with an alternative method of test that will yield results comparable to the test procedure in the DOE regulations. Test procedures are not a mechanism to impact the efficiency of a product, which is why DOE has carefully evaluated the characteristics of a paired system so as to avoid impacting measured efficiency relative to the current test procedure.
Transition From Coverage Under the Guidance Documents
URI commented that the test procedure would effectively end the manufacture of such components six months after the revised test procedure goes into effect. URI contended that it also would be prohibited from selling or distributing its existing inventory of properly certified and rated HCFC-22 replacement condensing units six months after the effective date because the notice makes clear that “any representations, including compliance certifications,” about the energy cost and efficiency of replacement condensing units must be based on the revised test procedure. (United Refrigeration, Inc., No. 60 at p. 2)
URI submitted that DOE should clarify in the preamble and regulatory text of a final test procedure that the restriction on representations does not apply to HCFC-22 condensing units that were manufactured and certified pursuant to the preceding DOE guidance. (United Refrigeration, Inc., No. 60 at p. 2)
In a letter to the Secretary of Energy, Lennox requested DOE to promptly issue guidance to prevent the entry of newly designed 14 SEER HCFC-22 dry-charge products into the southern and southwestern regions that do not meet the requirements of the DOE test procedure. Lennox commented that DOE action on these issues is particularly critical by early 2016, as manufacturers ramp up production for the 2016 summer air-conditioning sales season in that timeframe. (Lennox, No. 61 at p. 2)
Lennox requested DOE include mechanisms in the final rule to facilitate a quick and orderly market transition from legacy dry-shipped outdoor split-system central air conditioners and heat pumps certified to DOE as compliant
that are not rated in accordance with the test procedure final rule by requiring manufacturers to discontinue all non-compliant ratings 180 days after the final rule's publication. (Lennox, No. 61 at p. 2-3)
JCI recommended that no later than February 1, 2016, DOE should issue enforcement guidance stating that DOE will not seek civil penalties or injunctive relief for the distribution in commerce of a dry charged HCFC-22 unit (unit with no match), or for the labeling requirements of that unit, if the unit is manufactured prior to a date that is 30 days after the date of publication of the enforcement guidance. (JCI, No. 66 at p. 7)
On December 16, 2015, DOE issued an enforcement policy stating that it would begin investigating the methods manufacturers were using to rate split-system central air conditioners that do not have a highest sales volume combination. Those investigations are ongoing. DOE also stated that it would seek civil penalties for violations related to units manufactured on or after February 1, 2016, that had not been tested and properly certified as compliant with the applicable standards. As DOE indicated in the policy statement, DOE will continue to use its discretion in determining whether or to what extent penalties are appropriate, including an evaluation of a manufacturer's good faith efforts to comply with the regulations. DOE notes that this test procedure final rule does not have retroactive application; however, the units at issue have been subject to the energy conservation standards and certification requirements since 2006.
DOE also notes that following the close of the comment period for the November 2015 SNOPR, on December 1, 2015, an ex parte meeting occurred between AHRI, manufacturers, and DOE regarding outdoor units with no match. Representatives from Nortek, Mitsubishi, Carrier, Lennox, Trane, Rheem, JCI, ADM, Goodman, and Allied Air attended. During this meeting, the attendees requested that DOE require that ratings of existing dry R-22 units must be discontinued 180 days after the date of the publication of the amended test procedure in the
Federal Register
. (Docket No. EERE-2009-BT-TP-0004-0074) This recommendation indicates that existing ratings for outdoor units with no match are invalid and supports the need for a test procedure as finalized in this notice. DOE is implementing this recommendation consistent with EPCA, as discussed in section III.H.1.
4. Compliance With Federal (National or Regional) Standards
In the November 2015 SNOPR, DOE proposed to add requirements to the relevant provisions of section 430.32 that the least-efficient combination within each basic model must comply with the regional SEER and EER standards. 80 FR 69278, 69290 (Nov. 9, 2015). In addition, as noted in section III.A.1, DOE proposed that if any individual combination within a basic model fails to meet the standard, the entire basic model (
i.e.,
model of outdoor unit) must be removed from the market. In order to clarify the limitations on sales of models of outdoor units across regions with different standards, DOE proposed to add a limitation in section 429.16 that any model of outdoor unit that is certified in a combination that does not meet all regional standards cannot also be certified in a combination that meets the regional standard(s). Further,
Basic model
Individual model # (outdoor unit)
Individual model # (indoor unit)
Certified rep. value (SEER/EER)
Permitted?
AB12
ABC**#**-***
SO123
14.5/12.0
NO.
AB12
ABC**#**-***
SW123
15.0/12.8
AB12
ABC**#**-***
N123
13.9/11.7
CD13
CDESO**-*#*
SO123
14.5/12.0
YES.
CD13
CDESW**-*#*
SW123
15.0/12.8
CD13
CDEN***-*#*
N123
13.9/11.7
EF12
EFCS**#**-***
SO123
14.5/12.2
YES.
EF12
EFCS**#**-***
SW123
14.6/12.4
EF12
EFCN**#**-***
N123
13.9/11.7
DOE proposed to require that outdoor unit model numbers cannot span regions unless the model of outdoor unit is compliant with all standards in all possible combinations. If a model of outdoor unit is certified below a regional standard, then, under DOE's proposal, it must have a unique individual model number for distribution in each region. 80 FR at 69290 (Nov. 9, 2015).
For example:
The Joint Advocates of ACEEE, NRDC and ASAP commented that the approach proposed by DOE is workable and provides clear requirements for OUM rating systems. The Joint Advocates also commented that requiring a specific model number for outdoor units that are certified only in combinations that meet regional standard(s), and therefore permitted to be installed in those regions, will aid enforcement. The Joint Advocates also commented that DOE should clarify the requirements for ICMs, specifically how DOE would treat an ICM that attempts to certify a combination with a rating below 14 SEER using an outdoor unit model that otherwise meets 14 SEER in all combinations certified by the OUM. (ACEEE, NRDC and ASAP, No. 72 at p. 3)
Based on this comment, DOE adopts the limitation as proposed, with wording modifications for clarity. DOE has not added a limitation on ICMs certifying a combination below an OUM represented value, given that such a value would reflect the performance the consumer would experience. DOE has not modified 430.32 in this rulemaking and will instead do so in the regional standards enforcement rulemaking.
5. Certification Reports
To maximize test repeatability and reproducibility for assessment and enforcement testing, DOE proposed a number of amendments to the certification reporting requirements. 80 FR 69278, 69290 (Nov. 9, 2015).
Among these requirements, DOE proposed to clarify what basic model number and individual model numbers must be reported for central air conditioners and heat pumps. 80 FR 69278, 69290-91 (Nov. 9, 2015). DOE proposed to require the reporting of the sensible heat ratio (SHR) value calculated based on full-load cooling test conditions at the outdoor ambient conditions: 82 °F dry bulb and 65 °F wet bulb. 80 FR at 69326 (Nov. 9, 2015). Finally, DOE also proposed to require certain product-specific information at 10 CFR 429.16(c)(4) that would not be
displayed in DOE's public database. 80 FR at 69291 (Nov. 9, 2015).
NEEA and NPCC supported DOE's proposals for certification reports, specifically noting the importance that all combinations of individual model numbers within a basic model group can be identified and to identify the outdoor and indoor mini-split and multi-split system units that are rated as combinations. (NEEA and NPCC, No. 64 at p. 3) DOE adopts this provision in the final rule.
Regarding the basic model provision, AHRI commented that ICMs should be required to identify in the certification report the Similarity Group to which each indoor unit belongs. (AHRI, No. 70 at p. 5-6) DOE notes that it has adopted the Similarity Group structure recommended by AHRI as the basis for the basic model for ICMs. Hence, identification of the Similarity Group is not necessary.
The California IOUs commented that the proposal to require reporting of SHR is a good precedent for providing other data from tests and requested that results also be reported for all the tests that are the inputs to calculation of SEER and HSPF, as well as the results of the AHRI maximum operational conditions test.
8
(California IOUs, No. 67 at p. 4) On the other hand, AHRI, Lennox, ADP, UTC/Carrier, JCI, Goodman, and Nortek believe that SHR should not be reported as part of a certification report. (AHRI, No. 70 at p. 10; Lennox, No. 61 at p. 9; ADP, No. 59 at p. 7; UTC/Carrier, No. 62 at p. 8; JCI, No. 66 at p. 15-16; Goodman, No. 73 at p. 14; Nortek, No. 58 at p. 7) JCI noted that the publication of SHR should be left to the manufacturer as part of their technical literature, and UTC/Carrier noted that that information is already provided in the manufacturer's product data. (JCI, No. 66 at p. 12; UTC/Carrier, No. 62 at p. 7) AHRI, Lennox, ADP, Goodman, Nortek, and Rheem commented that the requirement to add reporting of SHR adds an excessive burden. (AHRI, No. 70 at p. 10; Lennox, No. 61 at p. 9; ADP, No. 59 at p. 7; Goodman, No. 73 at p. 14; Nortek, No. 58 at p. 7: Rheem, No. 69 at p. 8) ADP further commented that adding a requirement for SHR is significant for those OUM and ICM ratings developed by AEDMs, as manufacturers may not have this capability in their current AEDM. (ADP, No. 59 at p. 7) JCI further commented that the agreement made between AHRI members and advocates (presumably referring to the agreement in advance of the 2011 Direct Final Rule) was intended to encourage manufacturers to list SHR in manufacturer technical literature, not to make it a certified value. (JCI, No. 66 at p. 15-16)
8
This test is conducted with 115 °F air entering the outdoor coil, see AHRI 210/240-2008, Table 13.
After reviewing these comments, DOE agrees that the joint proposal from stakeholders that served as the basis for the 2011 Direct Final Rule regarding central air conditioners stated that manufacturers would make the SHR at 82 °F (at the rated airflow) available in in manufacturer technical literature and Web sites but that the SHR would not be verified or certified by AHRI. The parties agreed that DOE did not need to take regulatory action to implement this information sharing. (Docket No. EERE-2011-BT-STD-0011, No. 16 at p. 7) DOE did not account for this agreement in the November 2015 SNOPR, and in response to stakeholder comment within this docket, proposed to require reporting of SHR. However, given the existing stakeholder agreement that underlay the 2011 Direct Final Rule, DOE is not adopting the proposed requirement to certify SHR.
AHRI, ADP, Lennox, UTC/Carrier, Ingersoll Rand, JCI, Nortek, Rheem, Goodman, and Mitsubishi did not support the additional reporting requirements proposed by DOE and commented that they are a significant burden on manufacturers. (AHRI, No. 70 at p. 13-15; ADP, No. 59 at p. 7; Lennox, No. 61 at p. 14-15; UTC/Carrier, No. 62 at p. 7; Ingersoll Rand, No. 65 at p. 12; JCI, No. 66 at p. 15; Nortek, No. 58 at p. 11; Rheem, No. 69 at p. 7; Goodman, No. 73 at p. 14, 19; Mitsubishi, No. 68 at p. 2-3) AHRI, Lennox, UTC/Carrier, Nortek, JCI, Rheem, Goodman, and Mitsubishi also commented that some of the required data is proprietary and puts the manufacturer at risk. (AHRI, No. 70 at p. 13-15; Lennox, No. 61 at p. 14-15; UTC/Carrier, No. 62 at p. 7; Nortek, No. 58 at p. 11; JCI, No. 66 at p. 12; Rheem, No. 69 at p. 7; Goodman, No. 73 at p. 14, 19; Mitsubishi, No. 68 at p. 2) JCI and Mitsubishi expressed concern that confidential information could be revealed in a FOIA request. (JCI, No. 66 at p. 12; Mitsubishi, No. 68 at p. 2)
AHRI and Lennox each provided a list of information that they support DOE requiring. (AHRI, No. 70 at p. 13-14; Lennox, No. 61 at p. 14-15) Unico agreed in its comments with AHRI's position on the reporting burden associated with the certification reporting requirements. (Unico, No. 63 at p. 6) Nortek commented that it supports DOE requiring information that is already being submitted to AHRI for purposes of certification. (Nortek, No. 58 at p. 10-11) Mitsubishi commented that manufacturers should not be required to provide any physical information that is not needed to test the system. (Mitsubishi, No. 68 at p. 3) JCI commented that the only additional reporting information that should be added to the certification report is the off mode standby metric, and that no other unregulated items should be added. (JCI, No. 66 at p. 12)
Some stakeholders listed specific information that DOE should not require manufacturers to report. AHRI, Rheem, and JCI commented that DOE should not require manufacturers to report the orientation of a product's indoor coils and that, rather than reporting the process for manually entering the defrost cycle to DOE, manufacturers should describe that process in the product instructions. (AHRI, No. 70 at p. 13; Rheem, No. 69 at p. 7-8; JCI, No. 66 at p. 12) AHRI commented that for variable speed products, compressor frequency set points are proprietary to the manufacturer and therefore should not be reported to DOE. (AHRI, No. 70 at p. 15) Rheem commented that variable speed heat pump minimum and maximum speed blocks are proprietary and therefore should not be reported. (Rheem, No. 69 at p. 7-8) Goodman commented that their product nameplates do not explicitly state nominal capacity, nor do the majority of their competitors' products. Goodman recommended that the manufacturer provide the specific model numbers of the indoor unit tested rather than nominal capacity of each indoor unit. (Goodman, No. 73 at p. 6) Goodman also suggested that, instead of requiring manufacturers to solely report the general type of expansion device, DOE should require that manufacturers submit the same information (for fixed orifices, the orifice inside dimension (I.D.) and length; or, for expansion valves, the part number or model number) manufacturers currently submit to AHRI for each individual combination of a split‐system air conditioner or split‐system heat pump. (Goodman, No. 73 at p. 3-5)
Rheem commented that the addition of the requirement to certify airflow and C
D
is a significant certification burden on manufacturers. Rheem noted that the documentation of the values measured during the test of a single sample cannot be applied to a second test, and that the averages of multiple measured values are even less applicable. Rheem stated that the certification of C
D
requires that manufacturers provide a conservative value that would be applied to multiple test samples. Rheem suggested that the certification of a product should be based on actual product performance, as the use of a certified value of C
D
would
increase the variability of the test procedure and require more conservative ratings and redesign of minimum efficiency equipment. (Rheem, No. 69 at p. 7)
After reviewing the stakeholders' comments, DOE maintains that the certification reporting requirements proposed in the November 2015 SNOPR, except for SHR as previously discussed, are necessary for DOE to be able to conduct testing. None of the commenters indicated how DOE could properly conduct testing without the requested information. In the November 2015 NOPR, DOE proposed that this information would not be made available on the DOE public Web site. While the information may be subject to Freedom of Information Act (FOIA), DOE will seek to protect this information to the extent legally permissible.
For these reasons, DOE has adopted these requirements in the final rule, with minor modifications as discussed in relevant sections. In response to Goodman, DOE notes that the model numbers of indoor units are required in addition to nominal capacity, which is needed to verify appropriate unit selection used for certification testing.
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