[Federal Register: September 16, 2003 (Volume 68, Number 179)]
[Notices]
[Page 54212-54215]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr16se03-37]
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DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
Energy Conservation Program for Consumer Products: Publishing of
the Petition for Waiver of Mitsubishi Electric From the DOE Commercial
Package Air Conditioner and Heat Pump Test Procedure (Case No. CAC-008)
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of Petition for Waiver and solicitation of comments.
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SUMMARY: Today's notice publishes a ``Petition for Waiver'' from
Mitsubishi Electric and Electronics USA, Inc. (MEUS). The MEUS Petition
requests a waiver of the test procedures applicable to commercial
package air conditioners and heat pumps. The Department of Energy (DOE)
is soliciting comments, data, and information with respect to the
Petition for Waiver.
DATES: The Department will accept comments, data, and information with
respect to this Petition for Waiver on or before October 16, 2003.
ADDRESSES: Send written comments and statements to: U.S. Department of
Energy, Building Technologies Program, Case No. CAC-008, Mail Stop EE-
2J, Forrestal Building, 1000 Independence Avenue, SW, Washington, DC
20585-0121.
Copies of public comments received, this notice, and the Petition
for Waiver may be read at the Freedom of Information Reading Room (Room
1E-190) at the U.S. Department of Energy, Forrestal Building, 1000
Independence Avenue, SW, Washington, DC 20585, telephone: (202) 586-
3142, between the hours of 9 a.m. and 4 p.m., Monday through Friday,
except Federal holidays.
FOR FURTHER INFORMATION CONTACT: Dr. Michael G. Raymond, U.S.
Department of Energy, Building Technologies Program, Mail Stop EE-2J,
Forrestal Building, 1000 Independence Avenue, SW, Washington, DC 20585-
0121, (202) 586-9611; e-mail: Michael.Raymond.ee.doe.gov; or Francine
Pinto, Esq., or Thomas DePriest, Esq., U.S. Department of Energy,
Office of General Counsel, Mail Stop GC-72, Forrestal Building, 1000
Independence Avenue, SW, Washington, DC 20585-0103, (202) 586-9507; e-
mail: Francine.Pinto@hq.doe.gov, or Thomas.DePriest@hq.doe.gov.
SUPPLEMENTARY INFORMATION: Title III of the Energy Policy and
Conservation Act (EPCA) sets forth a variety of provisions concerning
energy efficiency. Part B of Title III (42 U.S.C. 6291-6309) provides
for the ``Energy Conservation Program for Consumer Products other than
Automobiles.'' Part C of Title III (42 U.S.C. 6311-6317) provides for a
program entitled ``Energy Efficiency of Industrial Equipment,'' which
is similar to the program in Part B, and which includes commercial air
conditioning equipment, packaged boilers, water heaters, and other
types of commercial equipment.
Today's notice involves commercial equipment under Part C, which
specifically provides for definitions, test procedures, labeling
provisions, energy conservation standards, and the authority to require
information and reports from manufacturers. With respect to test
procedures, Part C generally authorizes the Secretary of Energy to
prescribe test procedures that are reasonably designed to produce
results which reflect energy efficiency, energy use and estimated
annual operating costs, and that are not unduly burdensome to conduct.
(42 U.S.C. 6314)
For commercial package air-conditioning and heating equipment, EPCA
provides that the test procedures shall be those generally accepted
industry testing procedures developed or recognized by the Air-
Conditioning and Refrigeration Institute (ARI) or by the American
Society of Heating, Refrigerating and Air Conditioning Engineers
(ASHRAE), as referenced in ASHRAE/IES Standard 90.1 and in effect on
June 30, 1992. (42 U.S.C. 6314(a)(4)(A)) This section also provides for
the Secretary of Energy to amend the test procedure for a product if
the industry test procedure is amended, unless the Secretary determines
that such a modified test procedure does not meet the statutory
criteria. (42 U.S.C. 6314(a)(4)(B))
The relevant test procedure for purposes of today's notice and
referenced in the version of ASHRAE 90.1 in effect in 1992 is ARI 210/
240 (1989), ``Standard for Unitary Air-Conditioning and Air-Source Heat
Pump Equipment.'' The Air-Conditioning and Refrigeration Institute
subsequently modified the 1989 version of the test procedure. The
Department issued a Notice of Proposed Rulemaking proposing to adopt
ARI 210/240 (1994) (65 FR 48828, Aug. 9, 2000), but has not taken final
action with respect to that proposal. Thus, the currently applicable
test procedure is contained in ARI Standard 210/240 (1989).
The Department's regulations contain provisions allowing a person
to seek a waiver from the test procedure requirements for covered
consumer products and electric motors. These provisions are set forth
in 10 CFR 430.27 and 10 CFR 431.29. However, there are no waiver
provisions for other covered commercial equipment. The Department
proposed waiver provisions for covered commercial equipment on December
13, 1999 (64 FR 69597), as part of the commercial furnace test
procedure rule. The Department expects to publish a final rule
codifying this process in 10 CFR 431.201. Until that time, DOE will
apply to commercial equipment the waiver provisions for consumer
products and electric motors. These waiver provisions are substantively
identical.
The waiver provisions allow the Assistant Secretary for Energy
Efficiency and Renewable Energy to waive temporarily test procedures
for a particular basic model when a petitioner shows that the basic
model contains one or more design characteristics that prevent testing
according to the prescribed test procedures, or when the prescribed
test procedures may evaluate the basic model in a manner so
unrepresentative of its true energy consumption as to provide
materially inaccurate comparative data. (10 CFR 430.27 (a)(1), 10 CFR
431.29 (a)(1)) Waivers generally remain in effect until final test
procedure amendments become effective, thereby resolving the problem
that is the subject of the waiver.
On June 13, 2003, MEUS filed a Petition for Waiver from the test
procedures applicable to commercial package air conditioning and
heating equipment. In particular, MEUS seeks a waiver from the
currently applicable test procedures contained in ARI 210/
[[Page 54213]]
240 (1989), and from the test procedures contained in ARI 210/240
(1994), that the Department has proposed to adopt.
MEUS requests a waiver from the test procedures for the following
basic product models:
CITY MULTI Variable Refrigerant Flow Zoning System R-2 Series Outdoor
Equipment:
PURY-80TMU, 80,000 Btu/h, 208/230-3-60 split-system variable-speed
heat pump
PURY-100TMU, 100,000 Btu/h, 208/230-3-60 split-system variable-
speed heat pump
CITY MULTI Variable Refrigerant Flow Zoning System Y Series Outdoor
Equipment:
PUHY-80TMU, 80,000 Btu/h, 208/230-3-60 split-system variable-speed
heat pump
PUHY-100TMU, 100,000 Btu/h, 208/230-3-60 split-system variable-
speed heat pump
PUY-80TMU, 80,000 Btu/h, 208/230-3-60 split-system variable-speed
air conditioner
PUY-100TMU, 100,000 Btu/h, 208/230-3-60 split-system variable-speed
air conditioner
CITY MULTI Variable Refrigerant Flow Zoning System Indoor Equipment
\1\:
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\1\ The * denotes engineering differences in the models.
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PCFY Series--Ceiling Suspended--PCFY-16/24/40/48***-*
PDFY Series--Ceiling Concealed Ducted--PDFY-08/10/12/16/20/24/28/
32/40/48***-*
PEFY Series--Ceiling Concealed Ducted, Low External Static
Pressure--PEFY-08/10/12***-*
PEFY Series--Ceiling Concealed Ducted, High External Static
Pressure--PEFY-16/20/24/28/32/40/48***-*
PFFY Series--Floor Standing--PFFY-08/10/12/16/20/24***-*
PKFY Series--Wall-Mounted--PKFY-08/10/12/16/20/24/32/40***-*
PLFY Series--4-Way Airflow Ceiling Cassette--PLFY-12/16/20/24/32/
40/48***-*
PLFY Series--2-Way Airflow Ceiling Cassette--PLFY-08/10/12/16/20/
24/32/40/48***-*
PMFY Series--1-Way Airflow Ceiling Cassette--PMFY-08/10/12/16***-*
MEUS seeks a waiver from the applicable test procedures because,
MEUS asserts, the current test procedures evaluate CITY MULTI VRFZ
system products in a manner so unrepresentative of their true energy
consumption characteristics as to provide materially inaccurate
comparative data. MEUS claims that the energy usage of the CITY MULTI
VRFZ systems cannot be representatively measured using the current test
procedures for the following reasons:
1. The test procedures provide for testing of the pair of indoor
and outdoor assemblies making up a typical split system, but provide no
direction about how to test CITY MULTI systems with which literally
millions of combinations of indoor units could be used with any given
outdoor assembly.
2. The test procedures call for testing ``matched assemblies, ''
but CITY MULTI systems are designed to be used in zoning systems where
the capacity of the indoor units does not match the capacity of the
outdoor unit.
3. The test procedures do not accommodate infinite variability in
compressor speed.
4. The test procedures do not account for the capability of
simultaneous heating and cooling.
The MEUS petition requests that DOE grant a waiver from existing
test procedures until such time as a representative test procedure is
developed and adopted for this class of products. MEUS intends to work
with ARI to develop appropriate test procedures.
The Department is publishing the MEUS ``Petition for Waiver'' in
its entirety. The Petition contains no confidential information. The
Department solicits comments, data, and information with respect to the
Petition. The Department is particularly interested in receiving
comments and views of interested parties concerning any alternate test
procedures, or modifications to test procedures, that the Department
could use to fairly represent the energy efficiency of MEUS' CITY MULTI
products. Any person submitting written comments must also send a copy
of such comments to the petitioner. 10 CFR 430.27(b)(1)(iv).
Issued in Washington, DC, on September 9, 2003.
David K. Garman,
Assistant Secretary, Energy Efficiency and Renewable Energy.
Mitsubishi Electric & Electronics USA, Inc.
HVAC Advanced Products Division, 4505-A Newpoint Place,
Lawrenceville, GA 30043, Phone: 678-376-2900, Fax: 678-376-3540 or
800-889-9904.
Mr. David K. Garman, Assistant Secretary for Energy Efficiency and
Renewable Energy, U.S. Department of Energy, 1000 Independence Ave,
SW., Washington, DC 20585-0121.
June 13, 2003.
Re: Petition for Waiver of Test Procedure.
Dear Assistant Secretary Garman: Mitsubishi Electric & Electronics
USA, Inc. (MEUS) respectfully submits this petition to the
Department of Energy (DOE) for a waiver of the test procedures
applicable to commercial package air conditioners and heat pumps, as
established in ARI 210/240 (1989), for MEUS's CITY MULTI Variable
Refrigerant Flow Zoning System products.\2\
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\2\ As of this petition, DOE has not codified procedures
concerning waiver of test procedures for commercial package air
conditioners and heat pumps. However, we assume that DOE will employ
the same procedures it uses for processing requests for waivers of
other test procedures. See 10 CFR 430.27 (2002) (procedures for
waiver from test procedures for consumer products) and 10 CFR 431.29
(2002) (procedures for waiver from test procedures for electric
motors). While there are no final regulations for commercial package
air conditioners and heat pumps, in a 1999 Notice of Proposed
Rulemaking, DOE proposed procedures and standards for granting
waivers and interim waivers from test procedures for commercial
package air conditioners and heat pumps, in a 1999 Notice of
Proposed Rulemaking, DOE proposed procedures and standards for
granting waivers and interim waivers from test procedures for
commercial heating and air conditioning equipment. These proposed
procedures are similar to those codified for other products. In
particular, DOE proposed to grant waivers where the prescribed test
procedures evaluate the basic model ``in a manner so
unrepresentative of its true energy consumption characteristics as
to provide materially inaccurate comparative data.'' 64 FR 69598
(Dec. 13, 1999) (to be codified at 10 CFR 431.601).
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Background--CITY MULTI Variable Refrigerant Flow Zoning Systems
MEUS's line of CITY MULTI Variable Refrigerant Flow Zoning
(VRFZ) System products, offered by the HVAC Advanced Products
Division of MEUS, combines advanced technologies to provide a new
approach to comfort conditioning. CITY MULTI VRFZ systems are
complete, commercial zoning systems that save energy through the
effective use of variable refrigerant control and distribution,
zoning diversity, and system intelligence.
CITY MULTI VRFZ systems have the capability of connecting a
single outdoor unit to up to 16 indoor units, giving these systems
tremendous installation flexibility with over a million potential
system combinations. The operating characteristics of a VRFZ system
allow each indoor unit to have a different set temperature and a
different mode of operation (i.e., on/off/heat/cool/fan), allowing
great flexibility of operation. The variable speed compressor and
the system controls direct refrigerant flow throughout the system to
precisely match the performance of the system to the load of the
conditioned areas. The compressor is capable of reducing its
operating capacity to as little as 16% of its rated capacity. The
outdoor fan motor also has a variable speed drive to properly match
the outdoor coil to indoor loads. Zone diversity enables VRFZ
systems to have a total connected indoor unit capacity of up to 150%
of the capacity of the outdoor unit. The CITY MULTI R2 Series, the
first member of this MEUS product family to be introduced into the
U.S. market, is capable of simultaneously providing cooling to one
or more zones while heating other zones using advanced heat recovery
methods.
[[Page 54214]]
Test Procedures From Which Waiver Is Requested
MEUS seeks a waiver from the test procedures applicable, for
purposes of the Energy Policy and Conservation Act (EPCA), to
commercial package air conditioning and heating equipment. In
particular, MEUS seeks a waiver from the currently applicable test
procedures provided in ARI 210/240 (1989), and from the test
procedures provided in ARI 2140/240 (1994) that the Department has
proposed to adopt.
Section 343(a)(4)(A) of EPCA provides that the test procedures
for purposes of EPCA shall be those generally accepted procedures
referenced in ASHRAE/IES Standard 90.1 and in effect on June 30,
1992. Section 343(a)(4)(B) of EPCA provides for the Secretary to
amend the test procedure for a product if the industry test
procedure is modified, unless the Secretary determines that such a
modified test procedure does not meet the statutory criteria.
The ARI test procedures referenced in the version of ASHRAE 90.1
in effect in 1992 are ARI 210/240 (1989). ARI has subsequently
modified the 1989 version of the test procedures several times. The
Department issued a Notice of Proposed Rulemaking proposing to adopt
ARI 210/240 (1994),\3\ but has not taken final action with respect
to that proposal. Thus, the currently applicable test procedures for
EPCA purposes are contained in ARI Standard 210/240 (1989).
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\3\ 65 FR 48828 (Aug. 9, 2000).
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While the proposal to adopt ARI 210/240 (1994) has not been
finalized as of the filing of this petition, we understand that it
is under active consideration. Therefore, we request waiver from the
applicable test procedures, including ARI 210/240 (1989) or ARI 210/
240 (1994) if adopted, so as to avoid the need to request another
waiver if the 1994 version is adopted by the Department.
Basic Models for Which Waiver Is Requested
MEUS requests a waiver from the test procedures for the
following basic product models:
CITY MULTI Variable Refrigerant Flow Zoning System R-2 Series
Outdoor Equipment:
--PURY-80TMU, 80,000 Btu/h, 208/230-3-60 split-system variable-
speed heat pump
--PURY-100TMU, 100,000 Btu/h, 208/230-3-60 split-system
variable-speed heat pump
CITY MULTI Variable Refrigerant Flow Zoning System Y Series Outdoor
Equipment:
--PUHY-80TMU, 80,000 Btu/h, 208/230-3-60 split-system variable-
speed heat pump
--PUHY-100TMU, 100,000 Btu/h, 208/230-3-60 split-system
variable-speed heat pump
--PUY-80TMU, 80,000 Btu/h, 208/230-3-60 split-system variable-
speed air conditioner
--PUY-100TMU, 100,000 Btu/h, 208/230-3-60 split-system variable-
speed air conditioner
CITY MULTI Variable Refrigerant Flow Zoning System Indoor
Equipment:\4\
---------------------------------------------------------------------------
\4\ The * denotes engineering differences in the models.
---------------------------------------------------------------------------
--PCFY Series--Ceiling Suspended--PCFY-16/24/40/48***-*
--PDFY Series--Ceiling Concealed Ducted--PDFY-08/10/12/16/20/24/
28/32/40/48***-*
--PEFY Series--Ceiling Concealed Ducted, Low External Static
Pressure--PEFY-08/10/12***-*
--PEFY Series--Ceiling Concealed Ducted, High External Static
Pressure--PEFY-16/20/24/28/32/40/48***-*
--PFFY Series--Floor Standing--PFFY-08/10/12/16/20/24***-*
--PKFY Series--Wall-Mounted--PKFY-08/10/12/16/20/24/32/40***-*
--PLFY Series--4-Way Airflow Ceiling Cassette--PLFY-12/16/20/24/
32/40/48***-*
--PLFY Series--2-Way Airflow Ceiling Cassette--PLFY-08/10/12/16/
20/24/32/40/48***-*
--PMFY Series--1-Way Airflow Ceiling Cassette--PMFY-08/10/12/
16***-*
Need for Waiver of the Test Procedure
MEUS seeks a waiver from the applicable test procedures because
the current test procedures evaluate CITY MULTI VRFZ System products
``in a manner so unrepresentative of its true energy consumption
characteristics as to provide materially inaccurate comparative
data.''\5\ The energy usage of the CITY MULTI VRFZ Systems cannot be
representatively measured using the current test procedures for
several reasons discussed below.
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\5\ See 10 CFR 430.27 (2003) (standard for granting waiver from
test procedures for consumer products) and 10 CFR 431.29 (2002)
(standard for granting waiver from test procedures for electric
motors.)
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1. The test procedure provides for testing of the pair of indoor
and outdoor assemblies making up a typical split system, but
provides no direction about how to test CITY MULTI systems with
which literally millions of combinations of indoor units could be
used with any given outdoor assembly.
The ARI test procedures do not provide for separate testing of
indoor and outdoor components of split systems. Rather, they provide
for the indoor and outdoor elements to be tested together. In
particular, the test procedure provides that ``the requirements of
rating outlined in this standard are based upon the use of matched
assemblies.'' ARI Standard 210/240 3.2 (1989).\6\ Virtually all of
the systems covered by this test procedure have one outdoor unit
matched to one indoor coil,\7\ so the test procedure's direction to
test ``matched assemblies'' can be straightforwardly applied. With
CITY MULTI VRFZ Systems, however, there is no standard configuration
of outdoor and indoor units that can be tested together as
representative. The products are intended to be used in zoning
systems, and each outdoor unit can be connected with up to 16
separate indoor units in a zoned system. Moreover, MEUS offers 58
indoor unit models. Each of these indoor unit models is designed to
be used with up to 15 other indoor units, which need not be the same
models, in combination with a single outdoor unit. Thus, for each of
the CITY MULTI VRFZ outdoor coils, there are well over 1,000,000
combinations of indoor coils that can be matched up in a system
configuration.
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\6\ The same language appears in ARI Standard 210/240 3.2
(1994).
\7\ An analysis of commercial products from 65,000 Btu/h to
240,000 Btu/h covered by ARI Standard 210/240 and listed in the ARI
Unitary Large Equipment (ULE) directory was conducted by MEUS. For
the products in the Split System Heat Pump (HRCU-A-CB) category, 172
of 173 (over 99%) of the systems listed have one indoor coil, and
the other system has two indoor coils. For the products in the
Condensing Unit Coil and Blower (RCU-A-CB) category, 649 of 653
(over 99%) of the listed systems have one indoor coil and the other
four systems have two indoor coils. None of the listed products in
these categories have more than 2 indoor coils. By contrast, the
City Multi VRFZ systems will have typically 4 to 8 indoor coils, can
be configured with as many as 16 indoor coils.
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The current test procedure provides no direction for determining
what combination or combinations of outdoor and indoor units should
be tested in these circumstances. It is not practical to test each
possible combination. The test procedure provides no mechanism for
sampling component combinations.\8\ Thus, the test procedure does
not contemplate, and cannot practicably be applied to, the CITY
MULTI VRFZ systems consisting of multiple assemblies that are
intended to be used in a very large number of different
combinations.
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\8\ Any modification of test procedures to provide for testing
of a sample of configurations would need to assure that the test
results produced would fairly represent energy used in other
component combinations used by customers.
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2. The test procedure calls for testing ``matched assemblies,''
but CITY MULTI systems are designed to be used in zoning systems
where the capacity of the indoor units does not match capacity of
the outdoor unit.
Indoor and outdoor coils in split systems are typically
balanced, that is, the capacity of the outdoor coil is equivalent to
the capacity of the indoor coil. The test procedure's application to
``matched assemblies'' contemplates such a balance between indoor
and outdoor coil capacity. With the CITY MULTI VRFZ Systems,
however, the sum of the capacity of the indoor units connected into
the system can be as much as 150% of the capacity of the outdoor
coil. Such unbalanced combinations of CITY MULTI indoor and outdoor
units are permitted by the zoning characteristics of the system, the
use of electronic expansion valves to precisely control refrigerant
flow to each indoor coil, and the system intelligence for overall
system control. The test procedure designed for matched assemblies
does not contemplate or address testing for substantially unbalanced
zoning systems such as the CITY MULTI.\9\
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\9\ Note that the ARI test procedure is also ambiguous about how
to determine the capacity of such unbalanced VRFZ systems.
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3. The current test procedure does not accommodate infinite
variability in compressor speed.
The compressors in typical commercial package air conditioners
and heat pumps are on/off systems, with the compressor
[[Page 54215]]
operating only at one speed. Thus, the test procedure's baseline
test is conducted at full load. The test procedure includes a crude
mechanism designed to measure energy use in the cooling mode at
specified part-loads. ARI 210/240 5.2 (1989) provides that
``[s]ystems which are capable of capacity reduction shall be rated
at 100% and at each step of capacity reduction provided by the
refrigeration system(s) as published by the manufacturer. These
rating points shall be used to calculate the [integrated part load
value, or] IPLV.''\10\ The CITY MULTI VRFZ Systems, by contrast,
have variable frequency inverter driven scroll compressors, and
therefore have nearly infinite steps of capacity. For this reason,
the test procedure's ``step'' analysis of capacity reduction cannot
be practicably applied to the CITY MULTI VRFZ compressors.
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\10\ The same language appears in ARI 210/240 5.2 (1994).
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In addition, the existing test standards do not provide a test
method for integrated part load value during heating operation of
heat pumps. The CITY MULTI heat pump products' part load capability
in heating mode is not accounted for in any way in the test
procedure.
In order to provide accurate data for product comparisons by
consumers, it is critical that the efficiency rating of a system be
derived at its normal operating state. While other system
compressors run at full load as their normal state, the CITY MULTI
VRFZ Systems run at part load as their normal state. EER
measurements at full load are not representative of typical customer
usage of the CITY MULTI product. Thus, the problems with the IPLV
methodology described above are particularly problematic with
respect to the CITY MULTI VRFZ Systems.
4. The current test procedure does not account for the
capability of simultaneous heating and cooling.
The CITY MULTI VRFZ R2 products are the only 2-pipe simultaneous
heating and cooling systems available in the United States at the
current time. These simultaneous heating and cooling systems achieve
significant energy efficiency because they transfer heat recovered
from one zone and discharge it into another zone needing heat. The
test procedures in ARI 210/240 5.2 (1989) and ARI 210/240 5.2 (1994)
do not include any mechanism for testing a multi-split heat pump
that can operate with one or more indoor coils cooling while one or
more other indoor units are heating.
For all of these reasons, the existing test procedures evaluate
the CITY MULTI VRFZ products ``in a manner so unrepresentative of
its true energy consumption characteristics as to provide materially
inaccurate comparative data.''\11\ Thus, this petition for waiver
should be granted.
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\11\ 10 CFR 431.29 (2002)(a)(1) (standard for granting waiver
from test procedures for electric motors). See also 10 CFR
430.27(a)(1) (2002) (standard for granting waiver from test
procedures for consumer products).
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It is not surprising that the existing test procedures do not
address the issues listed above, because VRFZ systems like the CITY
MULTI were not in distribution in the U.S. when the Energy Policy
Act was enacted in 1992, or when the industry standards and test
procedures incorporated by reference in the Energy Policy Act were
developed.
Without a waiver of the test procedure, MEUS is at a competitive
disadvantage in the market. Utilities, customers, and State and
local governments expect MEUS to provide energy efficiency ratings
that will enable the comparison of HVAC products, the determination
of building code compliance, and the calculation of energy savings.
The current test procedure, however, cannot be meaningfully applied
to CITY MULTI VRFZ systems, for the reasons described above.
Moreover, if there is an applicable test procedure for a covered
product, section 343(d)(1) of EPCA prohibits a manufacturer from
making representations about the energy consumption of the equipment
unless the equipment has been tested in accordance with such test
procedure and the representation fairly discloses the results of the
testing. Therefore, MEUS is handicapped in its ability to provide
information on energy consumption to its customers. This is
particularly counterproductive for the CITY MULTI VRFZ systems
because these systems are specifically designed to deliver energy
savings for customers.
No Known Alternative Test Procedures
There are no alternative test procedures known to MEUS that
could evaluate these products in a representative manner.\12\
---------------------------------------------------------------------------
\12\ Although ARI 210/240 has been modified several times since
1989 (the most recent version being ARI 210/240 (2003)), even these
revised test procedures do not address the problems identified
above.
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Similar Products
To the best of our knowledge, VRFZ products are also offered in
the United States by Samsung Electronics Company, Ltd., Sanyo Fisher
(USA) Corp., and Mitsubishi Heavy Industries Climate Control, Inc.
Each of the manufacturers has incorporated a different technology to
achieve variable refrigerant flow. None of these manufacturers offer
a product comparable to the CITY MULTI VRFZ R2 products that offer
simultaneous heating and cooling with a 2-pipe system.
We believe that a test procedure could be developed to address
appropriately variable refrigerant flow zoning systems, part-load
performance by variable speed compressors, and simultaneous heating
and cooling operations. Given the differences in technology used by
manufacturers of other VRFZ systems, however, it is uncertain
whether a test procedure developed for the CITY MULTI VRFZ systems
would also appropriately apply to these other manufacturers'
products.
Conclusion
MEUS seeks a waiver of current test procedures established in
ARI 210/240 (1989). Such a waiver is necessary because the current
prescribed test procedures produce materially inaccurate and
unrepresentative data for regulatory and consumer information
purposes.
MEUS respectfully asks the Department of Energy to grant a
waiver from existing test standards until such time as a
representative test procedure is developed and adopted for this
class of products. MEUS expects to work with ARI through the process
of developing appropriate test procedures.
If we can provide further information, or if it would be helpful
to discuss any of these matters further, please contact Paul Doppel,
Brand Manager, at (678) 376-2923.
Sincerely,
William Rau
President, HVAC Advanced Products Division
Mitsubishi Electric & Electronics USA, Inc.
4505-A Newpoint Place
Lawrenceville, GA 30043
Certificate
I hereby certify that I have this day served the foregoing
document upon the following companies known to Mitsubishi Electric &
Electronics USA, Inc. to currently market systems in the United
States which appear to be similar to the CITY MULTI VRFZ System
design:
Samsung Air Conditioning
Samsung Electronics Company, LTD.
2865 Pellissier Pl.
Whittier, CA 90601
Attn: John Miles, Director, Engineering & Technical Support
Sanyo Fisher (USA) Corp.
1165 Allgood Road
Suite 22
Marietta, GA 30062
Attn: Tetsushi Yamashita, Engineering Manager, HVAC
Mitsubishi Heavy Industries Climate Control, Inc.
3030 E. Victoria Street
Racho Dominguez, CA 90221
Attn: Mario B. Santos, Assistant Manager, Service Engineer
Dated this 13th day of June 2003.
William Rau
President, HVAC Advanced Products Division
Mitsubishi Electric & Electronics USA, Inc.
4505-A Newpoint Place
Lawrenceville, GA 30043
[FR Doc. 03-23567 Filed 9-15-03; 8:45 am]
BILLING CODE 6450-01-P