[Federal Register Volume 75, Number 194 (Thursday, October 7, 2010)]
[Notices]
[Pages 62122-62127]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-25302]
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DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
[Case No. CAC-028]
Energy Conservation Program for Certain Industrial Equipment:
Publication of the Petition for Waiver From Daikin AC (Americas), Inc.
and Granting of the Application for Interim Waiver From the Department
of Energy Residential Central Air Conditioner and Heat Pump Test
Procedure
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver, granting of application for
interim waiver, and request for comments.
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SUMMARY: This notice announces receipt of and publishes a petition for
waiver from Daikin AC (Americas), Inc. (Daikin). The petition for
waiver (hereafter ``Daikin Petition'') requests a waiver from the U.S.
Department of Energy (DOE) test procedure applicable to residential
central air conditioners and heat pumps. The waiver request is specific
to the Daikin Altherma air-to-water heat pump with integrated domestic
water heating. Through this document, DOE: Solicits comments, data, and
information with respect to the Daikin Petition; and grants an interim
waiver to Daikin from the applicable DOE test procedure for the subject
residential central air conditioning heat pump.
DATES: DOE will accept comments, data, and information with respect to
the Daikin Petition until, but no later than November 8, 2010.
ADDRESSES: You may submit comments, identified by case number ``CAC-
028,'' by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: [email protected]. Include ``CAC-
028'' in the subject line of the message.
Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J/1000 Independence Avenue,
SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. Please
submit one signed original paper copy.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department
of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW.,
Suite 600, Washington, DC 20024. Please submit one signed original
paper copy.
Instructions: All submissions received should include the agency
name and case number for this proceeding. Submit electronic comments in
WordPerfect, Microsoft Word, Portable Document Format (PDF), or text
(American Standard Code for Information Interchange (ASCII)) file
format and avoid the use of special characters or any form of
encryption. Wherever possible, include the electronic signature of the
author. DOE does not accept telefacsimiles (faxes).
Any person submitting written comments must also send a copy of
such comments to the petitioner, pursuant to Title 10 of the Code of
Federal Regulations (10 CFR) 430.27(d). The contact information for the
petitioner is: Mr. Lee Smith, Assistant Vice President--Residential
Solutions, Daikin AC (Americas), Inc., 1645 Wallace Drive, Suite 110,
Carrollton, Texas 75006.
According to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit two copies: One copy of the document including
all the information believed to be confidential, and one copy of the
document with the information believed to be confidential deleted. DOE
will make its own determination about the confidential status of the
information and treat it according to its determination.
Docket: For access to the docket to review the background documents
relevant to this matter, you may visit the U.S. Department of Energy,
950 L'Enfant Plaza, SW., (Resource Room of the Building Technologies
Program), Washington, DC 20024; (202) 586-2945, between 9 a.m. and 4
p.m., Monday through Friday, except Federal holidays. Available
documents include the following items: (1) This notice; (2) public
comments received; (3) the petition for waiver and application for
interim waiver; and (4) prior DOE rulemakings regarding similar central
air conditioning and heat pump equipment. Please call Ms. Brenda
Edwards at the above telephone number for additional information
regarding visiting the Resource Room.
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. Telephone: (202) 586-9611. E-mail: [email protected].
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the
General Counsel, Mail Stop GC-71, Forrestal Building,
[[Page 62123]]
1000 Independence Avenue, SW., Washington, DC 20585-0103. Telephone:
(202) 586-7796. E-mail: [email protected].
SUPPLEMENTARY INFORMATION:
I. Background and Authority
Title III of the Energy Policy and Conservation Act, as amended
(``EPCA'') sets forth a variety of provisions concerning energy
efficiency. Part A of Title III provides for the ``Energy Conservation
Program for Consumer Products Other Than Automobiles.'' (42 U.S.C.
6291-6309). Part A includes definitions, test procedures, labeling
provisions, energy conservation standards, and the authority to require
information and reports from manufacturers. Further, Part A authorizes
the Secretary of Energy to prescribe test procedures that are
reasonably designed to produce results which measure energy efficiency,
energy use, or estimated operating costs, and that are not unduly
burdensome to conduct. (42 U.S.C. 6293(b)(3)). The test procedure for
residential central air conditioners is contained in 10 CFR part 430,
subpart B, appendix M.
The regulations set forth in 10 CFR 430.27 contain provisions that
enable a person to seek a waiver from the test procedure requirements
for covered consumer products. A waiver will be granted by the
Assistant Secretary for Energy Efficiency and Renewable Energy (the
Assistant Secretary) if it is determined that the basic model for which
the petition for waiver was submitted contains one or more design
characteristics that prevents testing of the basic model according to
the prescribed test procedures, or if the prescribed test procedures
may evaluate the basic model in a manner so unrepresentative of its
true energy consumption characteristics as to provide materially
inaccurate comparative data. 10 CFR 430.27(l). Petitioners must include
in their petition any alternate test procedures known to evaluate the
basic model in a manner representative of its energy consumption. 10
CFR 430.27(b)(1)(iii). The Assistant Secretary may grant the waiver
subject to conditions, including adherence to alternate test
procedures. 10 CFR 430.27(l). Waivers remain in effect pursuant to the
provisions of 10 CFR 430.27(m).
The waiver process also allows the Assistant Secretary to grant an
interim waiver from test procedure requirements to manufacturers that
have petitioned DOE for a waiver of such prescribed test procedures.
(10 CFR 430.27(a)(2)). An interim waiver remains in effect for a period
of 180 days or until DOE issues its determination on the petition for
waiver, whichever is sooner, and may be extended for an additionally
180 days, if necessary. (10 CFR 430.27(h)).
II. Petition for Waiver
On August 27, 2009, Daikin filed an application for interim waiver
and a petition for waiver for its Altherma products from the test
procedures at 10 CFR part 430, subpart B, appendix M, which apply to
residential central air conditioners and heat pumps. DOE granted Daikin
an interim waiver and published its petition for waiver on December 15,
2009. (74 FR 66319) DOE published a Federal Register notice granting
Daikin's waiver on June 18, 2010. (75 FR 34731) On July 29, 2010,
Daikin filed the instant petition for waiver. The basic models covered
by this petition differ from the models covered by the previous
Altherma waiver only in that these models have different capacities in
the same capacity range.
The Daikin Altherma system consists of an air-to-water heat pump
providing hydronic heating and cooling with the added ability to
provide domestic hot water functions. It operates either as a split
system with the compressor unit outside and the hydronic components in
an inside unit, or as a single package configuration where all system
components are combined in a single outdoor unit. In both the single
package and the split system configurations, the system can include a
domestic hot water supply tank that is located inside the unit.
The test method for central air conditioners and heat pumps
contained in 10 CFR subpart B, appendix M does not include any
provisions to account for the operational characteristics of an air-to-
water heat pump with an integrated domestic hot water component. The
domestic hot water portion of the Daikin Altherma system is an integral
component of the system, and it cannot operate independently. The
applicable DOE test method does not account for the Daikin Altherma
system's energy performance because the test method does not accurately
evaluate the integrated domestic hot water portion of the system, nor
does it have any provisions for air-to-water heat pumps. Daikin
proposes using the European standards that are used for testing and
rating the Altherma products in Europe. The test procedures are EN
14511 ``Air conditioners, liquid chilling packages and heat pumps with
electrically driven compressors for space heating and cooling'' and EN
15316 ``Heating systems in buildings--Methods for calculation of system
energy requirements and system efficiencies''. Daikin did not petition
for including the performance of the combined cooling and hot water
functions in the waiver.
III. Application for Interim Waiver
In addition to its petition for waiver submitted on July 29, 2010,
Daikin submitted to DOE an application for interim waiver. DOE
determined that Daikin's application for interim waiver does not
provide sufficient market, equipment price, shipments, and other
manufacturer impact information to permit DOE to evaluate the economic
hardship Daikin might experience absent a favorable determination on
its application for interim waiver. However, DOE understands that
absent an interim waiver, Daikin's products would not otherwise be
tested and rated for energy consumption on a comparable basis with
equivalent products where DOE previously granted waivers. Furthermore,
DOE has determined that it appears likely that Daikin's Petition for
Waiver will be granted and that is desirable for public policy reasons
to grant Daikin immediate relief pending a determination on the
petition for waiver. In those instances where the likely success of the
petition for waiver has been demonstrated, based upon DOE having
granted a waiver for similar product designs, it is in the public
interest to have similar products tested and rated for energy
consumption on a comparable basis. DOE has previously granted waivers
to Carrier (55 FR 13607, April 11, 1990) and Nordyne (61 FR 11395,
March 20, 1996) for comparable heat pumps with integrated domestic
water heating. DOE granted Daikin an interim waiver and published
Daikin's petition for waiver for nearly identical Altherma products on
December 15, 2009. (74 FR 66319). DOE granted Daikin's waiver on June
18, 2010. (75 FR 34731).
Thus, DOE has determined that it is likely that Daikin's petition
for waiver will be granted for its new Altherma models. Therefore, it
is ordered that:
The Application for interim waiver filed by Daikin is hereby
granted for Daikin's Altherma heat pumps, subject to the specifications
and conditions below.
1. Daikin shall not be required to test or rate its Altherma heat
pump products on the basis of the test procedure under 10 CFR part 430
subpart B, appendix M.
2. Daikin shall be required to test and rate its Altherma heat pump
products according to the alternate test procedure
[[Page 62124]]
as set forth in section IV, ``Alternate test procedure.''
The interim waiver applies to the following basic model groups:
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Type Description U.S. model name E.U. equivalent model name
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Split Altherma.............. OD Unit (Split, 1.5-Ton or ERLQ018BAVJU.................................. ERLQ006BAV3
6kW).
OD Unit (Split, 2.0-Ton or ERLQ024BAVJU.................................. ERLQ007BAV3
7kW).
OD Unit (Split, 2.5-Ton or ERLQ030BAVJU.................................. ERLQ008BAV3
8kW).
Hydrobox.................... HB (Heating Only, BUH 3kW) EKHBH030BA3VJU................................ EKHBH008BA3V3
HB (Heating Only, BUH 6kW) EKHBH030BA6VJU................................ EKHBH008BA6V3
HB (Heat Pump, BUH 3kW)... EKHBX030BA3VJU................................ EKHBX008BA3V3
HB (Heat Pump, BUH 6kW)... EKHBX030BA6VJU................................ EKHBX008BA6V3
DHW......................... Hot Water Tank (50 Gallon EKHWS050BA3VJU................................ EKHWS200B3V3
or 200L).
Hot Water Tank (80 Gallon EKHWS080BA3VJU................................ EKHWS300B3V3
or 300L).
Options..................... Digital I/O PCB........... EKRP1HBAAU.................................... EKRP1HBAA
Solar Pump Kit............ EKSOLHWBAVJU.................................. EKSOLHAV1
Wired Room Thermostat..... EKRTWA........................................ EKRTWA
Condensate Kit............ EKHBDP........................................ EKHBDP
Type........................ Description............... U.S. Model Name............................... E.U. Equivalent Model Name
Split Altherma.............. OD Unit (Split, 1.5-Ton or ERLQ018BAVJU.................................. ERLQ006BAV3
6kW).
Hydrobox.................... OD Unit (Split, 2.0-Ton or ERLQ024BAVJU.................................. ERLQ007BAV3
7kW).
OD Unit (Split, 2.5-Ton or ERLQ030BAVJU.................................. ERLQ008BAV3
8kW).
HB (Heating Only, BUH 3kW) EKHBH030BA3VJU................................ EKHBH008BA3V3
HB (Heating Only, BUH 6kW) EKHBH030BA6VJU................................ EKHBH008BA6V3
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This interim waiver is conditioned upon the presumed validity of
statements, representations, and documents provided by the petitioner.
DOE may revoke or modify this interim waiver at any time upon a
determination that the factual basis underlying the petition for waiver
is incorrect, or upon a determination that the results from the
alternate test procedure are unrepresentative of the basic models' true
energy consumption characteristics.
IV. Alternate Test Procedure
DOE is not aware of an alternate test procedure that is applicable
within the United States to test and rate the performance of air-to-
water heat pump systems that provide heating and that can also perform
domestic hot water and cooling functions such as Daikin's Altherma.
However, Daikin Europe N.V. (DENV) is currently marketing Daikin
Altherma systems in Europe, using European Standards. Daikin shall be
required to test and rate its Altherma heat pumps as DOE ordered in its
June 18, 2010, Daikin Altherma decision and order using these European
Standards as follows:
(1) Full Load Performance and Efficiency--The Daikin Altherma shall
be tested and rated according to European Standard EN 14511, ``Air
conditioners, liquid chilling packages and heat pumps with electrically
driven compressors for space heating and cooling,'' except that the
test operating and test condition tolerances in Tables 7, 13, and 15 of
the DOE test procedure in 10 CFR part 430, subpart B, Appendix M shall
apply. Daikin shall rate the Altherma full load heating and cooling
performance (not including the DHW contribution) using coefficient of
performance (COP) and energy efficiency ratio (EER).
(2) The European Standard EN 14511 applies only to testing for COP
and EER and does not supersede any DOE requirements in 10 CFR 430.24.
Daikin may make representations about the energy use of its
Altherma heat pump products for compliance, marketing, or other
purposes only to the extent that such products have been tested in
accordance with the provisions outlined above, and such representations
fairly disclose the results of such testing. Daikin may not make
representations of annual operating cost, or any parameters other than
COP and EER for the Altherma's space heating and space cooling
functions, respectively.
V. Summary and Request for Comments
Through today's notice, DOE announces receipt of the Daikin
petition for waiver from the test procedures applicable to Daikin's
Altherma heat pump products, and for the reasons articulated above, DOE
grants Daikin an interim waiver from those procedures. As part of this
notice, DOE is publishing Daikin's petition for waiver in its entirety.
The petition contains no confidential information. Furthermore, today's
notice includes an alternate test procedure that Daikin is required to
follow as a condition of its interim waiver and that DOE is considering
including in its subsequent Decision and Order. In this alternate test
procedure, DOE prescribes the European test procedure described above
to measure the full load COP and EER to characterize the Altherma's
heating and cooling performance.
DOE is interested in receiving comments on the issues addressed in
this notice. Pursuant to 10 CFR 430.27(d), any person submitting
written comments must also send a copy of such comments to the
petitioner, whose contact information is included in the section
entitled ADDRESSES section above.
Issued in Washington, DC, on September 30, 2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and Renewable Energy.
July 29, 2010
Ms. Catherine Zoi
Assistant Secretary for Energy Efficiency and Renewable Energy
U.S. Department of Energy
1000 Independence Ave., SW
Washington, DC 20585-0121
Re: Petition for Waiver of Test Procedure
Dear Assistant Secretary Zoi: Daikin AC (Americas) Inc. (DACA)
respectfully petitions the Department of Energy (DOE) pursuant to 10
C.F.R. Sec. 430.27(a)(1) (2009) for a waiver of the test procedures
applicable to central air conditioners and heat pumps, as
established in 10 C.F.R. Part 430, Subpart B, Appendix M (2009),\1\
for the Daikin Altherma system, an air to water heat pump system
that performs a hydronic heating function but can also be configured
to serve domestic hot water requirements and also cooling as
necessary. The particular systems and the specific models for which
DACA requests this waiver in the Daikin Altherma product class are
listed below in this Petition. DACA seeks a waiver from the existing
central air conditioner and central air conditioning heat
[[Page 62125]]
pump test procedure for the Daikin Altherma line of air to water
heat pumps because the integrated water-heating feature causes the
prescribed test procedures to evaluate the Daikin Altherma in a
manner that is unrepresentative of the system's true energy
consumption characteristics. We are simultaneously requesting an
interim waiver for the same systems pursuant to 10 C.F.R. Sec.
430.27(a)(2) (2009).
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\1\ Detailed citations to the test procedures for which DACA is
requesting a waiver are included on page 3 of this petition.
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General Characteristics of Daikin Altherma
The Daikin Altherma system has the following characteristics and
applications:
Daikin Altherma is an air to water heat pump that
performs a space heating function and can be configured to provide
Domestic Hot Water and additionally include the provision for space
cooling.
Daikin Altherma can be installed as a two-unit split
system consisting of an outdoor compressor unit and an indoor unit
or ``Hydrobox'' containing the hydronic parts. Alternatively, the
system can be installed as a monobloc system with a single outdoor
unit combining the compressor and hydronic parts.
The split system includes R-410A refrigerant piping
between the outdoor unit and the Hydrobox, and water piping between
the indoor unit and the indoor heating appliances. The monobloc
system includes water piping between the outdoor unit and the heat
emitters/DHW tank.
Both the Daikin Altherma monobloc system and split
system can be combined with under floor heating, fan coil units, and
low temperature radiators.
Depending on the model and the conditions, a Daikin
Altherma air/water heat pump delivers between 3 and 5 kWh of usable
heat for every kWh of electricity used.
The Daikin Altherma system heat pump compressor
incorporates inverter technology, with an integrated frequency-
converter that adjusts the rotational speed of the compressor to
meet the heating or cooling demand. Therefore, the system seldom
operates at full capacity.
The domestic hot water tank includes a supplemental
electrical heating element to boost the Domestic Hot Water
temperature if necessary.
The Altherma system also can be tied into a solar
thermal collector system that supports the production of domestic
hot water.
The Hydrobox for the split system and contained in the
outdoor unit in the monobloc system both include a built-in electric
back-up heater to provide additional heating during extremely cold
weather.
Particular Basic Models for Which DACA Requests a Waiver
DACA requests a waiver from the test procedures for the
following basic model groups:
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Type Description U.S. model name E.U. equivalent model name
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Split Altherma.............. OD Unit (Split, 1.5-Ton or ERLQ018BAVJU ERLQ006BAV3
6kW).
OD Unit (Split, 2.0-Ton or ERLQ024BAVJU ERLQ007BAV3
7kW).
OD Unit (Split, 2.5-Ton or ERLQ030BAVJU ERLQ008BAV3
8kW).
Hydrobox.................... HB (Heating Only, BUH 3kW) EKHBH030BA3VJU EKHBH008BA3V3
HB (Heating Only, BUH 6kW) EKHBH030BA6VJU EKHBH008BA6V3
HB (Heat Pump, BUH 3kW)... EKHBX030BA3VJU EKHBX008BA3V3
HB (Heat Pump, BUH 6kW)... EKHBX030BA6VJU EKHBX008BA6V3
DHW......................... Hot Water Tank (50 Gallon EKHWS050BA3VJU EKHWS200B3V3
or 200L).
Hot Water Tank (80 Gallon EKHWS080BA3VJU EKHWS300B3V3
or 300L).
Options..................... Digital I/O PCB........... EKRP1HBAAU EKRP1HBAA
Solar Pump Kit............ EKSOLHWBAVJU EKSOLHAV1
Wired Room Thermostat..... EKRTWA EKRTWA
Condensate Kit............ EKHBDP EKHBDP
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Daikin Altherma System Characteristics Constituting the Grounds for
DACA's Petition
The Daikin Altherma system consists of an air to water heat pump
providing hydronic heating with the added availability to provide
domestic hot water and cooling functions that operates either as a
split system with the compressor unit outside and the hydronic
components in an inside unit, or as a monobloc configuration where
all system components are combined in a single outdoor unit. In both
the monobloc and the split system configurations, the system can
include a domestic hot water supply tank that is located inside.
The test method for central air conditioners and heat pumps
contained in 10 C.F.R. Part 430, Subpart B, Appendix M does not
include any provision to account for the operation characteristics
of an Air to Water heat pump of the function and energy consumption
characteristics of a domestic hot water component that is integrated
into an air to water heat pump system. The domestic hot water tank
portion of the Daikin Altherma system is a regular element of the
complete system, and it cannot operate independent of the rest of
the system. Therefore, the currently applicable test method does not
accurately account for the Daikin Altherma system's energy
performance because the test method does not accurately evaluate the
integrated domestic hot water portion of the system.
Daikin Altherma products share the design characteristics and
basic features of three other products for which DOE has previously
granted waivers. One product was Carrier's Hydrotech system, \2\ and
the other product was Nordyne's Powermiser system.\3\ The Carrier
and Nordyne systems that previously received waivers from DOE were
both air source heat pump systems providing both heating and cooling
functions. Both of these systems also included a domestic hot water
supply tank as an integral part of the system. More recently, DOE
granted an interim waiver for another series of Altherma models,
which share the same design features as the equipment covered by
this waiver petition, but which have different capacities.\4\ The
same energy consumption calculation constraints apply equally to all
of these products.
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\2\ 55 Fed. Reg. 13,607 (April 11, 1990).
\3\ 61 Fed. Reg. 11,395 (March 20, 1996).
\4\ 74 Fed. Reg. 66,319 (December 19, 2009).
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DOE stated the following in its March 20, 1996 approval notice
issuing the Nordyne: ``DOE agrees [with Nordyne] that, using the
current central air conditioning test procedure, the company cannot
account for the energy savings associated with integrated water
heating.'' 61 Fed. Reg. at 11,396.
Based on this conclusion, the DOE granted the Nordyne Powermiser
system waiver petition (Id.), and based on a similar analysis DOE
granted the Carrier Hydrotech system waiver petition. (55 Fed. Reg.
at 13,607).
Based on the same rationale, the DOE granted Daikin's previous
Altherma interim waiver request (74 Fed. Reg. at 66,320).
The rationale for DACA's Petition for a waiver from testing
standards for the Daikin Altherma system is identical to Daikin's
previous Altherma Petition, and is virtually identical to the basis
for the other manufacturers' previous requests for waivers noted
above. DACA requests that DOE apply the same rationale to DACA's
Petition for waiver for the Daikin Altherma system that DOE used to
grant the previous Daikin Altherma interim waiver petition, and the
Carrier and Nordyne waiver petitions for their similar systems.
Specific Testing Requirements Sought To Be Waived
The test procedures from which DACA is requesting a waiver are
contained in 10 C.F.R. Part 430, Subpart B, Appendix M, which is
incorporated by reference into 10 C.F.R. Sec. 430.23(m), and which
is applicable to central air conditioner and heat pump equipment
with a capacity of <65,000 Btu/hr.
Detailed Discussion of Need for Requested Waiver
Although the capacity of the Daikin Altherma product class is
within the scope of 10 C.F.R. Part 430, Subpart B, Appendix M, the
design characteristics of the Daikin
[[Page 62126]]
Altherma product class prevent testing of the system according to
the prescribed test procedures in a manner that represents the
system's true energy consumption characteristics. Specifically,
application of the existing prescribed test method does not define
Air to Water Heat Pump operating characteristics and also cannot
account for energy savings associated with the system's integrated
water heating.
The absence of a waiver from the required testing procedure will
restrict the availability to consumers in the United States of the
Daikin Altherma system's energy savings benefits that result from
integrating domestic hot water production into the system.
Manufacturers of Other Basic Models Incorporating Similar Design
Characteristics
DACA is aware of no other manufacturers that currently produce
products incorporating similar design characteristics to the Daikin
Altherma system in the United States market.\5\
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\5\ DACA believes that Carrier is no longer marketing its
Hydrotech system for which DOE previously granted a waiver, and DACA
believes that Nordyne is no longer marketing its Powermiser system
for which DOE also previously granted a waiver.
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Alternative Test Procedures
To our knowledge, there is no alternative test procedure that is
applicable within the United States to test accurately and to rate
the performance of air to water heat pump systems that provide both
heating and that can also serve domestic hot water and cooling
functions such as Daikin Altherma. However, DACA's sister division,
Daikin Europe N.V. (DENV) is currently marketing Daikin Altherma
systems in Europe. To address the local EU requirements regarding
testing and rating of the Daikin Altherma system, DENV has
approached the matter in two ways as follows:
Full Load Performance and Efficiency:
Daikin Altherma is tested and rated to EN14511
Annual Performance and Efficiency:
Daikin Altherma is rated to EN15316
Standard EN14511, Air conditioners, liquid chilling packages and
heat pumps with electrically driven compressors for space heating
and cooling, is an internationally recognized standard that is used
throughout Europe.
Standard EN14511 is published in 4 sections and clearly defines
Terms and Conditions (-1), Test Conditions (-2), Test Methods (-3)
and Requirements (-4). The overall scope of the standard is stated
in EN14511-1:2004(E), Section 1, Scope, which states that the
standard:
Specifies the terms and definitions for the rating and performance
of air and water cooled air conditioners, liquid chilling packages,
air-to-air, water-to-air, air-to-water and water-to-water heat pumps
with electrically driven compressors when used for space heating
and/or cooling. This European Standard does not specifically apply
to heat pumps for sanitary hot water, although certain definitions
can be applied to these.
Standard EN14511, which is attached, provides the full criteria
to establish full load performance ratings for Air to Water Heat
Pump Systems.
Standard EN15316, Heating systems in buildings--Method for
calculation of system energy requirements and system efficiencies,
is an internationally recognized standard that is also used
throughout Europe.
The portion of the standard that is relevant to Daikin Altherma
is Standard EN15316-4-2, which is attached. A brief conceptual
summary of Standard EN15316-4-2 follows:
The Scope of Standard EN15316-1 (Section 1) states that this
standard ``specifies the structure for calculation of energy use for
space heating systems and domestic hot water systems in buildings.''
The standard's calculation method enables the energy analysis of the
various sub-systems of the heating system, ``including control
(emission, distribution, storage, generation), through determination
of the system energy losses and the system performance factors. This
performance analysis permits the comparison between sub-systems and
makes it possible to monitor the impact of each sub-system on the
energy performance of the building.'' Id.
Under Section 4.2 of the Standard EN15316-1, the calculation
period is established to evaluate the annual energy use of the space
heating and domestic hot water system.
Pursuant to Section 4.3 of the Standard, the calculation methods
in the standard determine operating conditions, such as heat demand
and water temperatures, and energy performance for given operating
conditions, including system thermal losses and recoverable losses.
The full attached Standard EN15316-4-2 provides the full energy
calculation method used under the standard for seasonal performance
of space heating and an integrated domestic hot water system. No
methodology exists for determining the seasonal performance of space
cooling and an integrated domestic hot water system, as the air to
water heat pump systems are primarily focused as being a ``heating''
solution. Cooling is deemed as an added optional benefit.
DACA aims to utilize the performance and efficiency
characteristics of the Daikin Altherma system as tested and
determined by the EN testing and rating standards, as an alternate
rating method for Daikin Altherma in lieu of an applicable U.S.
testing and rating standard being available at this time. This
utilization specifically means that DACA would promote the following
characteristics:
Full Load Heating Capacity and COP
(Per EN Std 14511--Test Conditions and Methods defined in
section 2 and section 3 of std 14511 respectively).
Full Load Cooling Capacity and EER
(Per EN Std 14511--Test Conditions and Methods defined in
section 2 and section 3 of std 14511 respectively).
Seasonal Performance Factor (SPF)
(Per EN15316-4-2--Full energy calculation method is defined).
No representation will be made to any Seasonal Performance
Factor for the cooling operation.
Application for Interim Waiver
DACA also hereby applies pursuant to 10 C.F.R. Sec.
430.27(a)(2) for an interim waiver of the applicable test procedure
requirements for the Daikin Altherma product class models listed
above. The basis for DACA's Application for Interim Waiver follows.
DACA is likely to succeed in its Petition for Waiver because
there is no reasonable argument that the test method contained in 10
C.F.R. Part 430, Subpart B, Appendix M can be accurately applied to
the Daikin Altherma product class. As explained above in the DACA's
Petition for Waiver, the design characteristics of the Daikin
Altherma product class clearly prevent testing the Daikin Altherma
system with the prescribed test procedures and obtaining a
representative result of the system's true energy consumption
characteristics.
The likelihood of DOE approving DACA's Petition for Waiver is
supported by the DOE's history of approving previous waiver requests
from other manufacturers for products that are similar to the Daikin
Altherma product class, based on the same rationale offered by DACA
in this Petition for Waiver.
Additionally, DACA is likely to suffer economic hardship and
competitive disadvantage if DOE does not grant its interim waiver
request. DACA is now preparing to introduce its Daikin Altherma
product class in a matter of months. If we must wait for completion
of the normal waiver consideration and issuance process, DACA will
be forced to delay the opportunity to begin recouping through
product sales its production and marketing costs associated with
introducing the Daikin Altherma product class into the United States
market.
DOE approval of DACA's interim waiver application is also
supported by sound public policy reasons. As DOE stated in its
January 7, 2008 approval of DACA's interim waiver for the VRV-WII
product classes:
[I]n those instances where the likely success of the Petition
for Waiver has been demonstrated, based upon DOE having granted a
waiver for similar products design, it is in the public interest to
have similar products tested and rated for energy consumption on a
comparable basis.
73 Fed. Reg. at 1215. The Daikin Altherma product class will provide
superior comfort to the end user, and will incorporate state of the
art technology such as variable speed compressors and a solar kit to
enhance the energy efficiency performance of the integrated domestic
hot water production system component. The Daikin Altherma product
class will introduce technologies that will increase system
efficiency and reduce national energy consumption, and that will
also offer a new level of comfort and control to end users.
DACA requests that DOE grant our Application for Interim Waiver
so we can bring the new highly energy efficient technology
represented by the Daikin Altherma product class to the market as
soon as possible, thereby allowing the U.S. consumer to benefit from
our high technology and high efficiency product.
[[Page 62127]]
Confidential Information
DACA makes no request to DOE for confidential treatment of any
information contained in this Petition for Waiver and Application
for Interim Waiver.
Conclusion
Daikin AC (Americas), Inc. respectfully requests DOE to grant
its Petition for Waiver of the applicable test procedure to DACA for
specified models of the Altherma system, and to grant its
Application for Interim Waiver. DOE's failure to issue an interim
waiver from test standards would cause significant economic hardship
to DACA by preventing DACA from marketing these products even though
DOE has previously granted a waiver to other products that were
offered in the market with similar design characteristics.
We would be pleased to respond to any questions you may have
regarding this Petition for Waiver and Application for Interim
Waiver. Please contact me at 972-245-1510 or by email at:
[email protected].
Sincerely,
Lee Smith
Assistant Vice President--Residential Solutions
Daikin AC (Americas), Inc.
1645 Wallace Drive, Suite 110
Carrollton, Texas 75006
(Submitted in triplicate)
Encls: Copy of Daikin Altherma Brochure, Engineering Data, EN
Testing & Rating Standards
[FR Doc. 2010-25302 Filed 10-6-10; 8:45 am]
BILLING CODE 6450-01-P