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[Federal Register: October 7, 2008 (Volume 73, Number 195)]
[Rules and Regulations]
[Page 58771-58830]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr07oc08-21]
[[Page 58771]]
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Part III
Department of Energy
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10 CFR Part 431
Energy Conservation Program for Commercial and Industrial Equipment:
Packaged Terminal Air Conditioner and Packaged Terminal Heat Pump
Energy Conservation Standards; Final Rule
[[Page 58772]]
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DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number: EERE-2007-BT-STD-0012]
RIN 1904-AB44
Energy Conservation Program for Commercial and Industrial
Equipment: Packaged Terminal Air Conditioner and Packaged Terminal Heat
Pump Energy Conservation Standards
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: The Department of Energy (DOE) has determined that its
adoption of amended energy conservation standards for commercial
standard size packaged terminal air conditioners (PTACs) and packaged
terminal heat pumps (PTHPs), at efficiency levels more stringent than
those in American Society of Heating, Refrigerating, and Air-
Conditioning Engineers (ASHRAE)/Illuminating Engineering Society of
North America (IESNA) Standard 90.1-1999, is supported by clear and
convincing evidence that such standards would result in significant
additional conservation of energy and are technologically feasible and
economically justified. On this basis, DOE is today amending the
existing energy conservation standards for these types of equipment. In
addition, DOE has determined that its adoption of amended energy
conservation standards more stringent than the efficiency levels
specified by ASHRAE Standard 90.1-1999 for non-standard size PTACs and
PTHPs is not supported by clear and convincing evidence, thus, DOE is
adopting the efficiency levels in ASHRAE Standard 90.1-1999 for non-
standard size PTACs and PTHPs in today's final rule.
DATES: The effective date of this rule is November 6, 2008. The
standards established in today's final rule will be applicable starting
October 8, 2012 for standard size PTACs and PTHPs. The standards
established in today's final rule will be applicable starting October
7, 2010 for non-standard size PTACs and PTHPs.
ADDRESSES: For access to the docket to read background documents, the
technical support document, transcripts of the public meetings in this
proceeding, or comments received, visit the U.S. Department of Energy,
Resource Room of the Building Technologies Program, 950 L'Enfant Plaza,
SW., 6th Floor, Washington, DC 20024, (202) 586-2945, between 9 a.m.
and 4 p.m., Monday through Friday, except Federal holidays. For more
information about visiting the Resource Room, please call Ms. Brenda
Edwards at (202) 586-2945. (Note: DOE's Freedom of Information Reading
Room no longer houses rulemaking materials.) You may also obtain copies
of the final rule notice in this proceeding, related documents (e.g.,
the notice of proposed rulemaking and technical support document DOE
used to reassess whether to adopt certain efficiency levels in ASHRAE
Standard 90.1), draft analyses, public meeting materials, and related
test procedure documents from the Office of Energy Efficiency and
Renewable Energy's Web site at http://www.eere.energy.gov/buildings/
appliance_standards/commercial/packaged_ac_hp.html.
FOR FURTHER INFORMATION CONTACT: Wes Anderson, Project Manager, Energy
Conservation Standards for Packaged Terminal Air Conditioners and
Packaged Terminal Heat Pumps, U.S. Department of Energy, Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue, SW., Washington, DC 20585-0121. Phone: (202)
586-7335. E-mail: Wes.Anderson@ee.doe.gov.
Francine Pinto, Esq., or Michael Kido, Esq., U.S. Department of
Energy, Office of General Counsel, GC-72, 1000 Independence Avenue,
SW., Washington, DC 20585. Phone: (202) 586-9507. E-mail:
Francine.Pinto@hq.doe.gov or Michael.Kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Summary of the Final Rule and Its Benefits
A. The Standard Levels
B. Current Federal Standards for Packaged Terminal Air
Conditioners and Packaged Terminal Heat Pumps
C. Benefits to Customers of Packaged Terminal Air Conditioners
and Packaged Terminal Heat Pumps
D. Impact on Manufacturers
E. National Benefits
F. Other Considerations
G. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Packaged Terminal
Equipment
III. General Discussion
A. Test Procedures
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
D. Economic Justification
1. Economic Impact on Commercial Consumers and Manufacturers
2. Life-Cycle Costs
3. Energy Savings
4. Lessening of Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
IV. Analysis Methodology and Discussion of Comments on Analysis
Methodology
A. Market and Technology Assessment
1. Equipment Classes--Generally
2. Comments
B. Screening Analysis
1. Scroll Compressors
2. ECM Motors
3. Fan Motors
4. Micro-Channel Heat Exchangers
5. Thermal Expansion Valves
C. Engineering Analysis
1. Material Prices for the Cost Model
2. Impacts of the Refrigerant Phaseout on PTAC and PTHP
Equipment Performance
3. Manufacturer Production Cost Increases With R-410A
D. Energy Use Characterization
E. Life-Cycle Cost Analysis
1. Equipment Prices
2. Installation Costs
3. Annual Energy Use
4. Electricity Prices
5. Maintenance Costs
6. Repair Costs
7. Equipment Lifetime
8. Discount Rate
F. National Impact Analysis--National Energy Savings and Net
Present Value Analysis
1. Shipments Analysis
2. Base Case and Standards Case Forecasted Distribution of
Efficiencies
G. Manufacturer Impact Analysis
1. GRIM Input Updates
2. Cumulative Regulatory Burden
3. Employment Impacts
H. Employment Impact Analysis
I. Utility Impact Analysis
J. Environmental Analysis
K. Other Comments
1. Burdens on Small, Non-Standard Size PTAC and PTHP
Manufacturers
2. PTAC and PTHP Labeling
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Significance of Energy Savings
C. Economic Justification
1. Economic Impact on Commercial Consumers
2. Economic Impact on Manufacturers
3. National Net Present Value and Net National Employment
4. Impact on Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
D. Conclusion
1. Standard Size PTACs and PTHPs
2. Non-Standard Size PTACs and PTHPs
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
1. Reasons for the Final Rule
2. Objectives of, and Legal Basis for, the Rule
3. Description and Estimated Number of Small Entities Regulated
[[Page 58773]]
4. Description and Estimate of Compliance Requirements
5. Significant Issues Raised by Public Comments
6. Steps DOE Has Taken To Minimize the Economic Impact on Small,
Non-Standard Size PTAC and PTHP Manufacturers
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act
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 of 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act of 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
M. Congressional Notification
VII. Approval of the Office of the Secretary
I. Summary of the Final Rule and Its Benefits
A. The Standard Levels
The Energy Policy and Conservation Act, as amended (EPCA), (42
U.S.C. 6291, et seq.), establishes mandatory energy conservation
standards for certain commercial equipment covered by the American
Society of Heating, Refrigerating, and Air-Conditioning Engineers
(ASHRAE) and the Illuminating Engineering Society of North America
(IESNA) Standard 90.1, including packaged terminal air conditioners
(PTACs) and packaged terminal heat pumps (PTHPs) (collectively referred
to as ``packaged terminal equipment''). EPCA states that the Department
of Energy (DOE) may prescribe amended standards for this equipment that
exceed the stringency of efficiency levels contained in amendments to
ASHRAE Standard 90.1, only if DOE determines by rule that any such
standard ``would result in significant additional conservation of
energy and is technologically feasible and economically justified.''
(42 U.S.C. 6313(a)(6)(A)(ii)(II)) This determination must be
``supported by clear and convincing evidence.'' Id. If DOE is unable to
find that clear and convincing evidence exists that a more stringent
efficiency level than the efficiency level contained in ASHRAE Standard
90.1 would result in a significant additional energy savings and is
technologically feasible and economically justified, then EPCA states
DOE must establish an amended uniform national standard for the product
at the minimum level specified in the amended ASHRAE/IES Standard 90.1.
(42 U.S.C. 6313(a)(6)(A)(ii)(I)) The standards in today's final rule,
which apply to all packaged terminal equipment, satisfy these
requirements and will achieve the maximum improvements in energy
efficiency that are technologically feasible and economically
justified. (See 42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(A).)
Table I.1 shows the amended energy conservation standards that DOE
is adopting today. These amended energy conservation standards will
apply to standard size PTACs and PTHPs manufactured for sale in the
United States, or imported to the United States, on or after October 8,
2012 and non-standard size PTACs and PTHPs manufactured for sale in the
United States, or imported to the United States, on or after October 7,
2010.
Table I.1--Amended Energy Conservation Standards for PTACs and PTHPs
------------------------------------------------------------------------
Equipment class
--------------------------------------------------------
Cooling
capacity Energy
(British conservation
Equipment Category thermal units standards *
per hour [Btu/
h])
------------------------------------------------------------------------
PTAC................. Standard Size <7,000......... EER = 11.7
**.
7,000-15,000... EER = 13.8-
(0.300 x Cap
[dagger][dagge
r])
>15,000........ EER = 9.3
--------------------------------------------------
Non-Standard <7,000......... EER = 9.4
Size [dagger].
7,000-15,000... EER = 10.9 -
(0.213 x Cap
[dagger][dagge
r])
>15,000........ EER = 7.7
------------------------------------------------------------------------
PTHP................. Standard Size <7,000......... EER = 11.9
**.
COP = 3.3
7,000-15,000... EER = 14.0 -
(0.300 x Cap
[dagger][dagge
r])
COP = 3.7 -
(0.052 x Cap
[dagger][dagge
r])
>15,000........ EER = 9.5
COP = 2.9
--------------------------------------------------
Non-Standard <7,000......... EER = 9.3
Size [dagger].
COP = 2.7
7,000-15,000... EER = 10.8 -
(0.213 x Cap
[dagger][dagge
r])
COP = 2.9 -
(0.026 x Cap
[dagger][dagge
r])
>15,000........ EER = 7.6
COP = 2.5
------------------------------------------------------------------------
* For equipment rated according to the DOE test procedure (Air-
Conditioning and Refrigeration Institute [ARI] Standard 310/380-2004),
all energy efficiency ratio (EER) values must be rated at 95 [deg]F
outdoor dry-bulb temperature for air-cooled equipment and
evaporatively cooled equipment and at 85 [deg]F entering water
temperature for water-cooled equipment. All coefficient of performance
(COP) values must be rated at 47 [deg]F outdoor dry-bulb temperature
for air-cooled equipment.
** Standard size refers to PTAC or PTHP equipment with wall sleeve
dimensions having an external wall opening greater than or equal to 16
inches high or greater than or equal to 42 inches wide, and a cross-
sectional area greater than or equal to 670 square inches.
[dagger] Non-standard size refers to PTAC or PTHP equipment with
existing wall sleeve dimensions having an external wall opening of
less than 16 inches high or less than 42 inches wide, and a cross-
sectional area less than 670 square inches.
[dagger][dagger] Cap means cooling capacity in thousand Btu/h (kBtu/h)
at 95 [deg]F outdoor dry-bulb temperature.
DOE only presents the benefits and burdens of adopting a standard
level higher than the efficiency levels specified in ASHRAE Standard
90.1-1999. The benefits and burdens of adopting the efficiency levels
in ASHRAE Standard 90.1-1999 for non-standard size PTACs and PTHPs are
not calculated in this rulemaking because
[[Page 58774]]
DOE considers this the baseline efficiency levels even though they
represent an increase in energy efficiency when compared to the current
Federal energy conservation standards.
B. Current Federal Standards for Packaged Terminal Air Conditioners and
Packaged Terminal Heat Pumps
Table I.2 presents the minimum efficiency levels in the current
Federal energy conservation standards for PTACs and PTHPs.
Table I.2--Existing Federal Energy Conservation Standards for PTACs and PTHPs
----------------------------------------------------------------------------------------------------------------
Equipment class
-----------------------------------------------------------
Cooling capacity (Btu/ Existing Federal energy conservation standards*
Equipment h)
----------------------------------------------------------------------------------------------------------------
PTAC............................... <7,000............... EER = 8.88
7,000-15,000......... EER = 10.0 - (0.16 x Cap**)
>15,000.............. EER = 7.6
PTHP............................... <7,000............... EER = 8.88
COP = 2.7
7,000-15,000......... EER = 10.0 - (0.16 x Cap**)
COP = 1.3 + (0.16 x EER)
>15,000.............. EER = 7.6
COP = 2.5
----------------------------------------------------------------------------------------------------------------
* For equipment rated according to the ARI standards, all EER values must be rated at 95 [deg]F outdoor dry-bulb
temperature for air-cooled products and evaporatively cooled products and at 85 [deg]F entering water
temperature for water-cooled products. All COP values must be rated at 47 [deg]F outdoor dry-bulb temperature
for air-cooled products, and at 70 [deg]F entering water temperature for water-source heat pumps.
** Cap means cooling capacity in kBtu/h at 95 [deg]F outdoor dry-bulb temperature.
C. Benefits to Customers of Packaged Terminal Air Conditioners and
Packaged Terminal Heat Pumps
Table I.3 presents the impacts on commercial customers of the
energy conservation standards adopted in today's final rule.
Table I.3--Impacts of New Standards for a Sample of Commercial Customers *
----------------------------------------------------------------------------------------------------------------
Total
Amended energy Total installed Life-cycle Payback
Equipment class conservation standard installed cost cost period
cost increase savings (years)
----------------------------------------------------------------------------------------------------------------
Standard Size PTAC, 9,000 Btu/h 11.1 EER.............. 1,229 $22 ($3) 13.7
Cooling Capacity.
Standard Size PTAC, 12,000 Btu/h 10.2 EER.............. 1,469 16 (2) 13.1
Cooling Capacity.
Standard Size PTHP, 9,000 Btu/h 11.3 EER.............. 1,362 40 28 4.4
Cooling Capacity.
3.2 COP
Standard Size PTHP, 12,000 Btu/h 10.4 EER.............. 1,603 38 24 4.6
Cooling Capacity.
3.0 COP
Non-Standard Size PTAC, 11,000 Btu/h 8.6 EER............... 1,570 ** N/A ** N/A ** N/A
Cooling Capacity.
Non-Standard Size PTHP, 11,000 Btu/h 8.5 EER............... 1,692 ** N/A ** N/A ** N/A
Cooling Capacity.
2.6 COP
----------------------------------------------------------------------------------------------------------------
* The values in Table I.3 represent average values and all monetary values are expressed in 2007$.
** DOE did not calculate the implications on commercial customers of non-standard equipment because DOE is
adopting the efficiency levels in ASHRAE Standard 90.1-1999 (i.e., the baseline efficiency levels).
The economic impacts on commercial consumers (i.e., the average
life-cycle cost (LCC) savings) are positive. For example, the typical,
standard size PTAC with a cooling capacity of 9,000 Btu/h that meets
the existing Federal energy conservation standards has an installed
price of $1,207 and an annual energy cost of $109 (cooling only). A
typical, standard size PTHP of the same cooling capacity that meets the
existing Federal energy conservation standards has an installed price
of $1,362 and an annual energy cost of $209. To meet the new standard,
DOE estimates that the installed price of a typical, standard size PTAC
with a cooling capacity of 9,000 Btu/h will be $1,229, an increase of
$22. This price increase will be offset by an annual energy savings of
about $3. Similarly, for a typical, standard size PTHP of the same
cooling capacity to meet the new standard, the increase in installed
price would be $40, offset by an annual energy savings of $11. Whereas
the typical, non-standard size PTAC that meets the ASHRAE Standard
90.1-1999 efficiency levels has an installed price of $1,570 and an
annual energy cost of $180.
D. Impact on Manufacturers
Using a real corporate discount rate of five-percent, DOE estimates
the net present value (NPV) of the standard size packaged terminal
equipment industry to be $427 million in 2007$ and the NPV of the non-
standard size packaged terminal equipment industry to be $30 million in
2007$. DOE expects the impact of today's standards on the industry net
present value (INPV) of manufacturers of standard size packaged
terminal equipment to be between a two-percent loss and a 14 percent
loss (-$8 million to -$61 million). Based
[[Page 58775]]
on DOE's interviews with the manufacturers of PTACs and PTHPs, DOE
expects minimal plant closings or loss of employment as a result of the
standards for both the standard size and non-standard size industries.
E. National Benefits
DOE estimates the amended energy conservation standards will save
approximately 0.032 quads (quadrillion (1015) Btu) of energy
over 30 years (2012-2042). This is equivalent to all the electricity
used annually by approximately 500 motels.\1\
---------------------------------------------------------------------------
\1\ Energy Informaton Agency. 2003 CBECS public use sample,
where specific building activity = ``motel or inn'' (PBAPLUS8=39).
Anual electricity use averages about 177,700 kWh per yer.
---------------------------------------------------------------------------
By 2042, DOE expects the energy savings from the standards to
eliminate the need for approximately one new 82-megawatt (MW) power
plant. These energy savings will result in cumulative greenhouse gas
emission reductions of approximately 1.06 million tons (Mt) of carbon
dioxide (CO2), or an amount equal to that produced by
approximately 6,700 cars every year. Additionally, the standards will
help alleviate air pollution by resulting in between approximately 90
and 2,130 tons (0.09 and 2.13 kilotons (kt)) of nitrogen oxides
(NOX) cumulative emission reductions from 2012 through 2042.
Finally, the standards will also alleviate air pollution by resulting
in between approximately 0 and 0.037 tons of mercury (Hg) cumulative
emission reductions from 2012 through 2042.
The national NPV of the standard for standard size PTACs and PTHPs
is $10 million using a seven-percent discount rate and $54 million
using a three-percent discount rate, cumulative from 2012 to 2062 in
2007$. This is the estimated total value of future savings minus the
estimated increased equipment costs, discounted to 2008.
The benefits and costs of today's final rule can also be expressed
in terms of annualized 2007$ values over the forecast period 2012
through 2042. Using a seven-percent discount rate for the annualized
cost analysis, the cost of the amended energy conservation standards
established in today's final rule for standard size PTACs and PTHPs is
$4.7 million per year in increased equipment and installation costs
while the annualized benefits are $5.7 million per year in reduced
equipment operating costs. Using a three-percent discount rate, the
cost of the amended energy conservation standards established in
today's final rule for standard size PTACs and PTHPs is $4.1 million
per year, whereas the benefits of today's amended energy conservation
standards are $6.5 million per year.
F. Other Considerations
DOE noted in the April 2008 Notice of Proposed Rulemaking (NOPR)
that PTAC and PTHP equipment manufacturers also face a mandated
refrigerant phaseout on January 1, 2010. 73 FR 18858, 18860 (April 7,
2008). R-22, the only refrigerant currently used by PTACs and PTHPs, is
a hydrochlorofluorocarbon (HCFC) refrigerant subject to the phaseout
requirement. Phaseout of this refrigerant could have a significant
impact on the manufacturing, performance, and cost of PTAC and PTHP
equipment. DOE discussed and estimated the impacts of the refrigerant
phaseout on PTAC and PTHP equipment and on the manufacturers of this
equipment in the NOPR, see generally, 73 FR 18872-74, and today's final
rule.
G. Conclusion
DOE concludes that the benefits (energy savings, commercial
customer LCC savings, positive national NPV, and emissions reductions)
to the Nation of the amended standards for standard size equipment
outweigh their costs (loss of manufacturer INPV and commercial customer
LCC increases for some users of PTACs and PTHPs). DOE believes that
these amended standards are technologically feasible, economically
justified, and will save additional significant amounts of energy as
compared to the savings that would result from adoption of the
efficiency levels for standard size PTACs and PTHPs in ASHRAE Standard
90.1-1999. DOE also believes that the standards for non-standard size
equipment (i.e., the efficiency levels in ASHRAE Standard 90.1-1999)
are technologically feasible, economically justified, and will save
significant amounts of energy compared to the current Federal energy
conservation standards. Finally, DOE concludes that today's standards
for PTACs and PTHPs are designed to achieve the maximum improvements in
energy efficiency that are technologically feasible and economically
justified. Currently, PTACs and PTHPs that meet the new standard levels
are commercially available utilizing R-22 refrigerant. DOE believes
that PTACs and PTHPs utilizing R-410A equipment at the new standard
levels will be commercially available by the effective dates of the new
standard levels.
II. Introduction
A. Authority
Title III of EPCA sets forth a variety of provisions designed to
improve energy efficiency. Part A of Title III (42 U.S.C. 6291-6309)
provides for the Energy Conservation Program for Consumer Products
Other than Automobiles. Part A-1 of Title III (42 U.S.C. 6311-6317)
establishes a similar program for ``Certain Industrial Equipment,''
including PTACs and PTHPs, the subjects of this rulemaking.\2\ DOE
publishes today's final rule pursuant to Part A-1 of Title III, which
provides for test procedures, labeling, and energy conservation
standards for PTACs and PTHPs and certain other equipment, and
authorizes DOE to require information and reports from manufacturers.
The test procedure for PTACs and PTHPs appears in title 10 Code of
Federal Regulations (CFR) section 431.96.
---------------------------------------------------------------------------
\2\ This part was originally titled Part C. However, it was
redesignated Part A-1 after Part B of Title III of EPCA was repealed
by Public Law 109-58.
---------------------------------------------------------------------------
EPCA established Federal energy conservation standards that
generally correspond to the levels in ASHRAE Standard 90.1, effective
October 24, 1992, for most types of covered equipment listed in section
342(a) of EPCA, including PTACs and PTHPs. (42 U.S.C. 6313(a)) For each
type of equipment, EPCA directs that if ASHRAE Standard 90.1 is
amended, DOE must adopt an amended standard at the new level in ASHRAE
Standard 90.1, unless clear and convincing evidence supports a
determination that adoption of a more stringent level as a national
standard would produce significant additional energy savings and be
technologically feasible and economically justified. (42 U.S.C.
6313(a)(6)(A)(ii)(II))
EPCA also provides that in deciding whether a more stringent
standard is economically justified for equipment such as PTACs and
PTHPs, DOE must, after receiving comments on the proposed standard,
determine whether the benefits of such a standard exceed its burdens by
considering the following seven factors to the greatest extent
practicable:
1. The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of products in the type (or class) compared to any increase in the
price, initial charges, or maintenance expenses for the covered
products that are likely to
[[Page 58776]]
result from the imposition of the standard;
3. The total projected amount of energy savings likely to result
directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the products
likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
6. The need for national energy conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(2)(B)(i)-(ii))
EPCA also contains an ``anti-backsliding'' provision, which
prohibits DOE from prescribing any amended energy conservation standard
that either increases the maximum allowable energy use or decreases the
minimum required energy efficiency of covered equipment. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(1)) It is a fundamental principle in EPCA's
statutory scheme that DOE cannot amend standards downward; that is, DOE
may not weaken standards that have been previously promulgated. Natural
Resources Defense Council v. Abraham, 355 F.3d 179 (2d Cir. 2004).
In addition, EPCA, as amended (42 U.S.C. 6295(o)(2)(B)(iii)),
establishes a rebuttable presumption that a standard is economically
justified if the Secretary finds that ``the additional cost to the
consumer of purchasing a product complying with an energy conservation
standard level will be less than three times the value of the energy
(and as applicable, water) savings during the first year that the
consumer will receive as a result of the standard,'' as calculated
under the test procedure in place for that standard. This approach
provides an alternative path in establishing economic justification
under the EPCA factors. (42 U.S.C. 6295(o)(2)(B)(iii)) DOE considered
this test, but believes that the criterion it applies (i.e., a limited
payback period) is not sufficient for determining economic
justification. Instead, DOE has considered a full range of impacts,
including those to the consumer, manufacturer, Nation, and environment.
Additionally, the Secretary may not prescribe an amended standard
if interested persons have established by a preponderance of the
evidence that the standard is ``likely to result in the unavailability
in the United States of any product type (or class)'' with performance
characteristics, features, sizes, capacities, and volumes that are
substantially the same as those generally available in the United
States at the time of the Secretary's finding. (42 U.S.C. 6316(a); 42
U.S.C. 6295(o)(4))
Section 325(q)(1) of EPCA directs that DOE must specify a different
standard level than that which applies generally to such type or class
of equipment for any group of products ``which have the same function
or intended use, if * * * products within such group--(A) consume a
different kind of energy from that consumed by other covered products
within such type (or class); or (B) have a capacity or other
performance-related feature which other products within such type (or
class) do not have and such feature justifies a higher or lower
standard'' than applies or will apply to the other products within that
type or class. (42 U.S.C. 6295(q)(1)(A) and (B)) In determining whether
a performance-related feature justifies such a different standard for a
group of products, DOE must consider ``such factors as the utility to
the consumer of such a feature'' and other factors DOE deems
appropriate. (42 U.S.C. 6295(q)(1)) Any rule prescribing such a
standard must include an explanation of the basis on which DOE
established such higher or lower level. (42 U.S.C. 6295(q)(2))
Federal energy efficiency requirements for commercial equipment
generally supersede State laws or regulations concerning energy
conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c);
42 U.S.C. 6316(a) and (b)) However, DOE can grant waivers of preemption
for particular State laws or regulations, in accordance with the
procedures and other provisions of section 327(d) of the Act, as
amended. (42 U.S.C. 6297(d); 42 U.S.C. 6316(b)(2)(D))
B. Background
1. Current Standards
As described in greater detail in the NOPR, 73 FR 18861-62, the
current energy conservation standards in EPCA for PTACs and PTHPs apply
to all equipment manufactured on or after January 1, 1994. (42 U.S.C.
6313(a)(3); 10 CFR 431.97) Table I.2 details these standards.
2. History of Standards Rulemaking for Packaged Terminal Equipment
On October 29, 1999, ASHRAE adopted ASHRAE Standard 90.1-1999,
which revised the efficiency levels for various categories of
commercial equipment covered by EPCA, including PTACs and PTHPs. In
amending the ASHRAE Standard 90.1-1989 levels for packaged terminal
equipment, ASHRAE used the equipment classes contained in EPCA, which
are distinguished by equipment type (i.e., air conditioner (PTAC) or
heat pump (PTHP)) and cooling capacity. However, ASHRAE further divided
these classes by wall sleeve dimensions, because they affect the energy
efficiency of PTACs and PTHPs. Table II.1 shows the efficiency levels
in ASHRAE Standard 90.1-1999 for this equipment.
Table II.1--ASHRAE Standard 90.1-1999 Energy Efficiency Levels for PTACs
and PTHPs
------------------------------------------------------------------------
Equipment class
-------------------------------------------------------- ASHRAE standard
Cooling 90.1-1999
Equipment Category capacity (Btu/ efficiency
h) levels *
------------------------------------------------------------------------
PTAC................. Standard Size <7,000......... EER = 11.0
**.
7,000-15,000... EER = 12.5 -
(0.213 x Cap
[dagger][dagge
r])
>15,000........ EER = 9.3
--------------------------------------------------
Non-Standard <7,000......... EER = 9.4
Size [dagger].
7,000-15,000... EER = 10.9 -
(0.213 x Cap
[dagger][dagge
r])
>15,000........ EER = 7.7
------------------------------------------------------------------------
PTHP................. Standard Size <7,000......... EER = 10.8
**. COP = 3.0
7,000-15,000.. EER = 12.3 -
(0.213 x Cap
[dagger][dagge
r])
COP = 3.2 -
(0.026 x Cap
[dagger][dagge
r])
[[Page 58777]]
>15,000........ EER = 9.1
COP = 2.8
--------------------------------------------------
Non-Standard <7,000......... EER = 9.3
Size [dagger]. COP = 2.7
7,000-15,000... EER = 10.8 -
(0.213 x Cap
[dagger][dagge
r])
COP = 2.9 -
(0.026 x Cap
[dagger][dagge
r])
>15,000........ EER = 7.6
COP = 2.5
------------------------------------------------------------------------
* For equipment rated according to ARI standards, all EER values must be
rated at 95 [deg]F outdoor dry-bulb temperature for air-cooled
products and evaporatively cooled products and at 85 [deg]F entering
water temperature for water-cooled products. All COP values must be
rated at 47 [deg]F outdoor dry-bulb temperature for air-cooled
products.
** Standard size refers to PTAC or PTHP equipment with wall sleeve
dimensions greater than or equal to 16 inches high, or greater than or
equal to 42 inches wide.
[dagger] Non-standard size refers to PTAC or PTHP equipment with wall
sleeve dimensions less than 16 inches high and less than 42 inches
wide. ASHRAE Standard 90.1-1999 also includes a factory labeling
requirement for non-standard size PTAC and PTHP equipment as follows:
``MANUFACTURED FOR REPLACEMENT APPLICATIONS ONLY; NOT TO BE INSTALLED
IN NEW CONSTRUCTION PROJECTS.''
[dagger][dagger] Cap means cooling capacity in kBtu/h at 95 [deg]F
outdoor dry-bulb temperature.
After publication of ASHRAE Standard 90.1-1999, DOE analyzed many
of its equipment categories to evaluate possible consideration of more
stringent efficiency levels than those specified in the Standard. DOE
summarized this analysis in a report, Screening Analysis for EPACT-
Covered Commercial HVAC [Heating, Ventilating and Air-Conditioning] and
Water-Heating Equipment (commonly referred to as the 2000 Screening
Analysis).\3\ On January 12, 2001, DOE published a final rule adopting
the efficiency levels in ASHRAE Standard 90.1-1999 for many types of
commercial HVAC and water heating equipment, excluding packaged
terminal equipment and certain other types of equipment. 66 FR 3336.
Regarding PTACs and PTHPs, the preamble to the final rule stated that
the 2000 Screening Analysis indicated at least a reasonable possibility
of finding ``clear and convincing evidence'' that more stringent
standards ``would be technologically feasible and economically
justified and would result in significant additional conservation of
energy.'' 66 FR 3349-50. Under EPCA, these are the criteria for DOE's
adoption of standards more stringent than the efficiency levels in
ASHRAE Standard 90.1. (42 U.S.C. 6313(a)(6)(A)(ii)(II)).
---------------------------------------------------------------------------
\3\ U.S. Department of Energy, Office of Energy Efficiency and
Renewable Energy. ``Energy Conservation Program for Consumer
Products: Screening Analysis for EPACT-Covered Commercial HVAC and
Water-Heating Equipment Screening Analysis.'' April 2000. http://
www.eere.energy.gov/buildings/highperformance/pdfs/screening_
analysis_main.pdf.
---------------------------------------------------------------------------
More recently, DOE announced the availability of a technical
support document (TSD) it developed to reassess whether to adopt as
national standards certain efficiency levels that were in amendments to
ASHRAE Standard 90.1, including the levels in the 1999 amendments for
PTACs and PTHPs. 71 FR 12634 (March 13, 2006) (Notice of Availability).
According to DOE, although the revised analysis in the TSD reduced the
potential energy savings that might result from standards more
stringent than the efficiency levels specified in ASHRAE Standard 90.1-
1999 for PTACs and PTHPs, DOE was inclined to pursue standards that are
more stringent because there was a possibility that clear and
convincing evidence exists that such standards are warranted. Id. at
12638-39. DOE stated that it would explore more stringent efficiency
levels than those in ASHRAE Standard 90.1-1999 for PTACs and PTHPs
through a separate rulemaking. Id. at 12639.
DOE proposed energy conservation standards for PTACs and PTHPs in a
NOPR published on April 7, 2008. 73 FR 18858. In conjunction with the
NOPR, DOE also published on its Web site the complete TSD for the
proposed rule, which incorporated the final analyses that DOE conducted
and technical support documentation of each analysis. The NOPR TSD
included the LCC spreadsheets, the national impact analysis
spreadsheets, and the manufacturer impact analysis (MIA) spreadsheet--
all of which are available on DOE's PTAC and PTHP webpage. The proposed
standards were as follows:
Table II.2--NOPR Proposed Energy Conservation Standards for PTACs and
PTHPs
------------------------------------------------------------------------
Equipment class
-------------------------------------------------------- Proposed energy
Cooling conservation
Equipment Category capacity (Btu/ standards *
h)
------------------------------------------------------------------------
PTAC................. Standard Size <7,000......... EER = 11.4
**.
7,000-15,000... EER = 13.0-
(0.233 x Cap
[dagger][dagge
r])
>15,000........ EER = 9.5
--------------------------------------------------
Non-Standard <7,000......... EER = 10.2
Size.
7,000-15,000... EER = 11.7-
(0.213 x Cap
[dagger][dagge
r])
>15,000........ EER = 8.5
------------------------------------------------------------------------
[[Page 58778]]
PTHP................. Standard Size <7,000......... EER = 11.8
**. COP = 3.3
7,000-15,000... EER = 13.4-
(0.233 x Cap
[dagger][dagge
r])
COP = 3.7-
(0.053 x Cap
[dagger][dagge
r])
>15,000........ EER = 9.9
COP = 2.9
--------------------------------------------------
Non-Standard <7,000......... EER = 10.8
Size. COP = 3.0
7,000-15,000... EER = 12.3-
(0.213 x Cap
[dagger][dagge
r])
COP = 3.1-
(0.026 x Cap
[dagger][dagge
r])
>15,000........ EER = 9.1
COP = 2.8
------------------------------------------------------------------------
* For equipment rated according to the DOE test procedure (ARI Standard
310/380-2004), all EER values must be rated at 95 [deg]F outdoor dry-
bulb temperature for air-cooled equipment and evaporatively cooled
equipment and at 85 [deg]F entering water temperature for water-cooled
equipment. All COP values must be rated at 47 [deg]F outdoor dry-bulb
temperature for air-cooled equipment, and at 70 [deg]F entering water
temperature for water-source heat pumps.
** Standard size refers to PTAC or PTHP equipment with wall sleeve
dimensions greater than or equal to 16 inches high, or greater than or
equal to 42 inches wide.
[dagger] Non-standard size refers to PTAC or PTHP equipment with wall
sleeve dimensions less than 16 inches high and less than 42 inches
wide.
[dagger][dagger] Cap means cooling capacity in kBtu/h at 95 [deg]F
outdoor dry-bulb temperature.
The NOPR also included additional background information on the
history of this rulemaking. 73 FR 18862-63. DOE held a public meeting
in Washington, DC, on May 1, 2008, to accept oral comments on and
solicit information relevant to the proposed rule.
III. General Discussion
A. Test Procedures
Section 343(a) of EPCA, as amended, authorizes the Secretary to
amend the test procedures for PTACs and PTHPs to the latest version
generally accepted by industry or the rating procedures developed or
recognized by the ARI, or ASHRAE as referenced in ASHRAE Standard 90.1,
unless the Secretary determines by clear and convincing evidence that
the latest version of the industry test procedure does not meet
specific requirements. (See 42 U.S.C. 6314(a)(4) As the NOPR explains,
DOE has determined that its existing test procedure for PTACs and PTHPs
does not need modification. 73 FR 18863. Accordingly, DOE has not
adopted a revised test procedure for this equipment.
B. Technological Feasibility
1. General
To adopt standards for PTACs and PTHPs that are more stringent than
the efficiency levels in ASHRAE Standard 90.1 as amended, DOE must
determine, supported by clear and convincing evidence, that such
standards are technologically feasible. (42 U.S.C.
6313(a)(6)(A)(ii)(II)) DOE considers a design option to be
technologically feasible if it is in use by the respective industry or
if research has progressed to the development of a working prototype.
DOE defines technological feasibility as follows: ``Technologies
incorporated in commercially available products or in working
prototypes will be considered technologically feasible.'' 10 CFR part
430, subpart C, appendix A, section 4(a)(4)(i).
This final rule considers the same design options as those
evaluated in the NOPR. (See the final rule TSD accompanying this
notice, Chapter 4.) Based on equipment literature, the teardown
analysis, manufacturer interviews, and the equipment performance
degradations provided by AHRI during the NOPR phase of the rulemaking,
DOE considered the following design options in the final rule analysis:
(1) Higher efficiency compressors; (2) increasing the heat exchanger
area; and (3) recircuiting the heat exchanger coils. Since these three
design options are commercially available, have been used in PTAC and
PTHP equipment, and are the most common ways by which manufacturers
improve the energy efficiency of their PTACs and PTHPs, DOE has
determined that clear and convincing evidence supports the conclusion
that all of the efficiency levels evaluated in this notice are
technologically feasible. DOE further discusses the technical
feasibility of PTAC and PTHP equipment utilizing R-410A in section
IV.C. of today's notice.
2. Maximum Technologically Feasible Levels
In order to evaluate whether energy conservation standards for
PTACs and PTHPs are economically justified, DOE determines the maximum
improvement in energy efficiency or maximum reduction in energy use
that is technologically feasible. (42 U.S.C. 6316(a); 42 U.S.C.
6295(p)(2)) DOE determined the maximum technologically feasible level
(``max-tech'') efficiency levels in its engineering analysis for the
NOPR. 73 FR 18863-64. (See NOPR TSD Chapter 5.) In the NOPR, DOE based
its identification of the max-tech efficiency levels on standard size
and non-standard size PTAC and PTHP equipment utilizing R-22 that is
currently available on the market. For the final rule, DOE revised the
max-tech efficiency levels for standard size and non-standard size
PTACs and PTHPs based on submitted comments, which are discussed in
section IV.C of today's notice. The max-tech efficiency levels
considered for today's final rule are based on the efficiency levels
identified in the NOPR and factor performance degradations stemming
from the switch to R-410A refrigerant.\4\ Table III.1 lists the max-
tech efficiency levels that DOE identified for this rulemaking for the
[[Page 58779]]
estimated system performance of equipment utilizing R-410A. DOE
discusses these levels further in section IV.C.
---------------------------------------------------------------------------
\4\ DOE expects the overall system efficiency of R-410A PTAC and
PTHP equipment will be lower than if that equipment used R-22, which
DOE estimated using an overall system performance degradation. This
estimate is based on data submitted by manufacturers and AHRI
pointing to a decline in performance when using R-410A refrigerant
in place of R-22 refrigerant.
Table III.1--R-410A Max-Tech Efficiency Levels (7,000-15,000 Btu/h
Equipment Classes) *
------------------------------------------------------------------------
R-410A ``Max-
Cooling Tech''
Equipment type Equipment class capacity (Btu/ efficiency
h) level **
------------------------------------------------------------------------
PTAC................. Standard Size 9,000.......... 11.5 EER
[dagger].
12,000......... 10.8 EER
--------------------------------------------------
Non-Standard 11,000......... 10.0 EER
Size
[dagger][dagge
r].
------------------------------------------------------------------------
PTHP................. Standard Size 9,000.......... 11.5 EER
[dagger]. 3.3 COP
12,000......... 10.8 EER
3.1 COP
--------------------------------------------------
Non-Standard 11,000......... 10.0 EER
Size 2.9 COP
[dagger][dagge
r].
------------------------------------------------------------------------
* As discussed in the NOPR, DOE is presenting the results for two
cooling capacities of standard size PTACs and PTHPs, 9,000 and 12,000
Btu/h, which fall within the equipment classes of PTACs and PTHPs with
cooling capacities of 7,000-15,000 Btu/h. 73 FR 18870-18871.
** For equipment rated according to the DOE test procedure, all EER
values would be rated at 95 [deg]F outdoor dry-bulb temperature for
air-cooled products and evaporatively cooled products and at 85 [deg]F
entering water temperature for water-cooled products. All COP values
must be rated at 47 [deg]F outdoor dry-bulb temperature for air-cooled
products and at 70 [deg]F entering water temperature for water-source
heat pumps.
[dagger] Standard size refers to PTAC or PTHP equipment with wall sleeve
dimensions having an external wall opening of greater than or equal to
16 inches high or greater than or equal to 42 inches wide, and having
a cross-sectional area greater than or equal to 670 square inches.
[dagger][dagger] Non-standard size refers to PTAC or PTHP equipment with
existing wall sleeve dimensions having an external wall opening of
less than 16 inches high or less than 42 inches wide, and having a
cross-sectional area less than 670 square inches.
C. Energy Savings
DOE forecasted energy savings in its national energy savings (NES)
analysis using an NES spreadsheet tool, which the NOPR discussed in
greater detail. See generally, 73 FR 18864, 18876, 18880-83, 18899.
Among the criteria that govern DOE's adoption of more stringent
standards for PTACs and PTHPs than the amended levels in ASHRAE
Standard 90.1, clear and convincing evidence must support a
determination that the standards would result in ``significant'' energy
savings. (42 U.S.C. 6313(a)(6)(A)(ii)(II)) Although EPCA does not
define ``significant,'' the U.S. Court of Appeals for the District of
Columbia indicated that Congress intended ``significant'' energy
savings to mean savings that were not ``genuinely trivial'' in Section
325 of the Act. Natural Resources Defense Council v. Herrington, 768
F.2d 1355, 1373 (D.C. Cir. 1985). DOE's estimates of the energy savings
for each of the TSLs considered for today's rule provide clear and
convincing evidence that the additional energy savings each would
achieve by exceeding the corresponding efficiency levels in ASHRAE
Standard 90.1-1999 are nontrivial. Therefore, DOE considers these
savings to be ``significant'' as required by 42 U.S.C.
6313(a)(6)(A)(ii)(II).
D. Economic Justification
As noted earlier, EPCA provides seven factors to be evaluated in
determining whether an energy conservation standard for PTACs and PTHPs
is economically justified. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)-(ii)) The following paragraphs discuss how DOE has
addressed each of those seven factors in this rulemaking.
1. Economic Impact on Commercial Consumers and Manufacturers
DOE considered the economic impact of the standards on commercial
consumers and manufacturers. For customers, DOE measures the economic
impact as the change in installed cost and life-cycle operating costs,
i.e., the LCC. (See section V.C.1 and Chapter 8 of the TSD.) DOE
investigates the impacts of amended energy conservation standards of
PTACs and PTHPs on manufacturers through the manufacturer impact
analysis (MIA). (See section V.C.2 and Chapter 13 of the TSD.) This
factor is discussed in detail in the NOPR. See generally 73 FR 18860-
61, 18864-66, 18869, 18883-87, 18893-99, 18906-07, 18910-12.
2. Life-Cycle Costs
DOE considered life-cycle costs of PTACs and PTHPs. This factor is
discussed in detail in the NOPR. See generally 73 FR 18860-61, 18865,
18876-80, 18883, 18888, 18891-93. DOE calculated the sum of the
purchase price and the operating expense--discounted over the lifetime
of the equipment--to estimate the range in LCC benefits that commercial
customers would expect to achieve due to the standards.
3. Energy Savings
Although significant additional conservation of energy is a
separate statutory requirement for imposing a more stringent energy
conservation standard than the level in the most current ASHRAE
Standard 90.1, EPCA also requires that DOE consider the total projected
energy savings that will likely result directly from the standard in
determining whether a standard is economically justified. (42 U.S.C.
6316(a); 42 U.S.C. 6295(o)(2)(B)(i)(III)) DOE used the NES spreadsheet
results in its consideration of total projected savings. 73 FR 18860-
61, 18864, 18876, 18880-83, 18899. DOE presents the energy savings at
each TSL for standard size and non-standard size PTACs and PTHPs in
section V.B of today's notice.
4. Lessening of Utility or Performance of Equipment
In selecting today's standard levels, DOE sought to avoid new
standards for PTACs and PTHPs that would lessen the utility or
performance of that equipment. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(IV)) 73 FR 18865, 18866-68, 18900. The design options
considered in the engineering analysis of this rulemaking, which
include higher efficiency compressors, increasing the heat exchanger
area, and recircuiting the heat exchanger coils, do not involve changes
in equipment design or unusual installation requirements that could
reduce the utility or performance of PTACs and PTHPs. In the NOPR, DOE
considered
[[Page 58780]]
industry concerns that one-third of the non-standard size market
subject to the more stringent standards under ASHRAE Standard 90.1-1999
definition would not be able to meet the efficiency levels specified by
ASHRAE Standard 90.1-1999 for standard size equipment due to the
physical size constraints of the wall sleeve if this equipment class
delineation was adopted. In today's final rule, DOE is adopting the
equipment class delineations specified in Addendum t to ASHRAE Standard
90.1-2007. This action should mitigate manufacturers' concerns
regarding the misclassification of non-standard equipment classes. DOE
further discusses the equipment classes it is adopting today and the
comments received from interested parties regarding equipment classes
in section IV.A of today's rulemaking.
5. Impact of Any Lessening of Competition
DOE considers any lessening of competition likely to result from
standards. As discussed in the NOPR (73 FR 18865, 18900), DOE requested
that the Attorney General transmit to the Secretary a written
determination of the impact of any lessening of competition likely to
result from the proposed standards, together with an analysis of the
nature and extent of such impact. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(V) and (B)(ii))
To assist the Attorney General in making such a determination, DOE
provided DOJ with copies of the proposed rule and the TSD for review.
(DOJ, No. 21 at p. 1-2) \5\ The Attorney General's response is
discussed in section IV.K.1, and is reprinted at the end of today's
rulemaking.
---------------------------------------------------------------------------
\5\ ``DOJ, No. 21 at pp 1-2'' refers to (1) a statement that was
submitted by the Department of Justice and is recorded in the
Resource Room of the Building Technologies Program in the docket
under ``Energy Conservation Program for Commercial and Industrial
Equipment: Packaged Terminal Air Conditioner and Packaged Terminal
Heat Pump Energy Conservation Standards,'' Docket Number EERE-2007-
BT-STD-0012, as comment number 21; and (2) a passage that appears on
pages 1 and 2 of that statement.
---------------------------------------------------------------------------
6. Need of the Nation To Conserve Energy
In considering standards for PTACs and PTHPs, the Secretary must
consider the need of the Nation to conserve energy. (42 U.S.C. 6316(a);
42 U.S.C. 6295(o)(2)(B)(i)(VI)) The Secretary recognizes that energy
conservation benefits the Nation in several important ways. The non-
monetary benefits of the standards will likely be reflected in
improvements to the security and reliability of the Nation's energy
system. Today's standards also will likely result in environmental
benefits. As discussed in the proposed rule, DOE has considered these
factors in adopting today's standards. See generally, 73 FR at 18860,
18865, 18888, 18900-02, 18912.
7. Other Factors
In determining whether a standard is economically justified, EPCA
directs the Secretary of Energy to consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6316(a); 42 U.S.C.
6295(o)(2)(B)(i)(VII)) In adopting today's standard, DOE considered (1)
the impacts of setting different amended standards for PTACs and PTHPs,
(2) the potential that amended standards could cause equipment
switching (i.e., purchase of PTACs instead of PTHPs) and the effects of
any such switching, (3) the uncertainties associated with the impending
phaseout in 2010 of R-22 refrigerant, and (4) the impact of amended
standards on the manufacture of and market for non-standard size
packaged terminal equipment (e.g., impacts on small businesses). See
generally, 73 FR at 18860, 18865-66, 18872-74, 18882, 18884-87, 18893-
98, 18902, 18911-12.
IV. Analysis Methodology and Discussion of Comments on Analysis
Methodology
DOE used several analytical tools that it developed previously and
adapted for use in this rulemaking. The first tool is a spreadsheet
that calculates LCC and payback period (PBP). The second tool
calculates national energy savings and national NPV. DOE also used the
Government Regulatory Impact Model (GRIM), among other methods, in its
MIA. Finally, DOE developed an approach using the National Energy
Modeling System (NEMS) to estimate impacts of PTAC and PTHP energy
efficiency standards on electric utilities and the environment. The
NOPR discusses each analytical tool in detail. 73 FR at 18866-89.
As a basis for this final rule, DOE has continued to use the
spreadsheets and approaches described above and in the NOPR. DOE used
the same general methodology as applied in the NOPR, but revised some
of the assumptions and inputs for the final rule in response to
comments from interested parties. The following paragraphs discuss
these revisions.
A. Market and Technology Assessment
When beginning an energy conservation standards rulemaking, DOE
develops information that provides an overall picture of the market for
the equipment concerned, including the purpose of the equipment, the
industry structure, and market characteristics. This activity includes
both quantitative and qualitative assessments based primarily on
publicly available information. DOE presented various subjects in the
market and technology assessment for this rulemaking. (See the NOPR and
Chapter 3 of the NOPR TSD.) These include equipment classes,
manufacturers, quantities and types of equipment sold and offered for
sale, retail market trends, and regulatory and nonregulatory programs.
73 FR 18866-69 and Chapter 3 of the NOPR TSD. In response to
publication of the NOPR, DOE received comments from interested parties
about the establishment of equipment classes for the rulemaking.
1. Equipment Classes--Generally
When evaluating and establishing energy conservation standards, DOE
generally divides covered equipment into equipment classes by the type
of energy used, capacity, or other performance-related features that
affect efficiency. Different energy conservation standards may apply to
different equipment classes. (42 U.S.C. 6316(a); 42 U.S.C. 6295(q))
PTACs and PTHPs can be divided into various equipment classes
categorized by physical characteristics that affect equipment
efficiency. Key characteristics that affect the energy efficiency of
the PTAC or PTHP are whether the equipment has reverse cycle heating
(i.e., air conditioner or heat pump), the cooling capacity, and the
physical dimensions of the unit.
In the NOPR, DOE presented two alternative methods for defining
PTAC and PTHP equipment classes. 73 FR 18866-18868. DOE explained the
two alternative methods of defining the PTAC and PTHP equipment classes
consistent with the delineations provided in ASHRAE Standard 90.1-1999
or Addendum t to ASHRAE Standard 90.1-2007 in the NOPR. Id. at 18867.
ASHRAE Standard 90.1-1999 refers to wall sleeve dimensions in two
categories: ``New Construction'' and ``Replacement.'' Although ASHRAE
Standard 90.1-1999 does not describe ``New Construction,'' Table 6.21D,
footnote b of ASHRAE Standard 90.1-1999 states that ``replacement''
efficiencies apply only to units that are: (1) ``Factory labeled as
follows: Manufactured for Replacement Applications Only; Not to be
Installed in New Construction Projects''; and (2) manufactured ``with
existing wall sleeves less than 16 inches high and less than 42 inches
wide.'' Based on this
[[Page 58781]]
provision, DOE understands that the ``New Construction'' category under
ASHRAE Standard 90.1-1999 is residual, and covers all other PTAC and
PTHPs. Hence, this category consists of equipment with wall sleeve
dimensions greater than or equal to 16 inches high and greater than or
equal to 42 inches wide, or lacking the requisite label.
Addendum t to ASHRAE Standard 90.1-2007 includes a new definition
for non-standard size PTACs and PTHPs in place of the ``replacement''
delineation in ASHRAE Standard 90.1-1999. The new definition reads as
follows: ``equipment with existing sleeves having an external wall
opening of less than 16 in. high or less than 42 in. wide, and having a
cross-sectional area less than 670 in \2\.''
2. Comments
In the NOPR, DOE stated that ASHRAE must adopt AHRI's \6\
continuous maintenance proposal before DOE can officially use this
definition as the basis for DOE's standard because AHRI's proposed
definitions would effectively reclassify some equipment under ASHRAE
90.1-1999's delineations as non-standard size equipment. (42 U.S.C.
6313(a)(6)(A)(ii)) When the NOPR was published, AHRI's continuous
maintenance proposal on PTACs and PTHPs had been approved by ASHRAE as
Addendum t to ASHRAE Standard 90.1-2007. At the time of the NOPR, that
Addendum was the subject of public review by ASHRAE. DOE stated in the
NOPR that if ASHRAE were to adopt the Addendum before September 2008,
which is the deadline by which DOE must issue a final rule for this
rulemaking, DOE proposed to incorporate the modified definition
specified by that version of the ASHRAE standard in its final rule. In
the NOPR, DOE sought comment from interested parties on its proposal to
adopt Addendum t to ASHRAE Standard 90.1-2007. 73 FR 18867.
---------------------------------------------------------------------------
\6\ The Air-Conditioning and Refrigeration Institute (ARI) and
the Gas Appliance Manufacturers Association (GAMA) announced on
December 17, 2007, that their members voted to approve the merger of
the two trade associations to represent the interests of cooling,
heating, and commercial refrigeration equipment manufacturers. The
merged association became AHRI on Jan. 1, 2008.
---------------------------------------------------------------------------
AHRI commented that all standard and non-standard manufacturers who
are AHRI members support adoption of Addendum t. AHRI had not received
comments challenging the content in Addendum t during ASHRAE's formal
comment period, and ASHRAE was planning to adopt the Addendum during
the ASHRAE annual meeting in June 2008. AHRI added that manufacturers
believe that the definitions in Addendum t are needed to deter against
the reclassification of large numbers of non-standard size PTACs and
PTHPs as standard equipment, which will not be able to meet the
proposed standards. (Public Meeting Transcript, No. 12 at p. 31-32,
AHRI, No. 23 at pp. 6-7) \7\
---------------------------------------------------------------------------
\7\ A notation in the form ``ECR, Public Meeting Transcript, No.
12 at pp. 30, 37, 182'' identifies (1) an oral comment that DOE
received during the May 30, 2008, NOPR public meeting by ECR, which
was recorded in the public meeting transcript in the docket for this
rulemaking as comment number 12; and (2) a passage that appears on
page 30 of that transcript.
---------------------------------------------------------------------------
ECR, McQuay, Carrier, and Ice Air also commented that DOE should
use the delineations within Addendum t to classify non-standard
equipment. (Public Meeting Transcript (ECR and McQuay), No. 12 at p.
31; ECR, No. 15 at p. 4; Carrier, No. 16 at p. 1; Ice Air, No. 25 at p.
5) ECR also noted that if DOE used the delineations in ASHRAE Standard
90.1-1999 to define the equipment classes for PTACs and PTHPs,
approximately 50 percent of their equipment would be eliminated from
the market as a result of being reclassified into the standard size
category. (ECR, No. 15 at p. 4)
ECR commented that non-standard equipment is burdened by space
constraints that are more stringent than the constraints for standard
size PTACs and PTHPs. ECR added that the delineations within ASHRAE
Standard 90.1-1999, coupled with the proposed standards (TSL 4), would
force manufacturers to include more heat exchanger surface area within
the limited volumes of physical chassis of the equipment, to use
compressors incorporating inverter technology, and to use variable
speed motors, which would result in equipment switching. (ECR, No. 15
at p. 2)
AHRI, ECR, McQuay, Ice Air, and Cold Point also commented that non-
standard size PTACs and PTHPs meet a specific demand that exists in the
market, particularly for older buildings. These commenters stated that
if DOE adopted the delineations in ASHRAE Standard 90.1-1999, which
could further eliminate non-standard size PTACs and PTHPs from the
market, this would decrease competition and limit customer choices.
(Public Meeting Transcript, No. 12 at pp. 20 (ECR), 22 (AHRI), 38
(McQuay); AHRI, No. 23 at p. 7; ECR, No. 15 at p. 4; Ice Air, No. 25 at
p. 4; Cold Point, No. 18 at p. 2)
DOE also received comments about the potential for creating a
loophole by adopting Addendum t in the final rule. In this regard,
these commenters supported DOE's adoption of an alternative definition
for non-standard size PTACs and PTHPs.
Specifically, General Electric (GE) and the American Council for an
Energy Efficient Economy (ACEEE) recommended that DOE modify the non-
standard definitions and equipment classes to have the wall sleeve
dimension requirements set significantly below the proposed dimensions,
consistent with the non-standard size equipment currently on the
market. (Public Meeting Transcript, No. 12 at pp. 16 (GE), 33-34 (GE),
36-37 (ACEEE), 208 (ACEEE); GE, No. 8 at p. 2; GE, No. 20 at pp. 2-3)
GE asked DOE to make the difference in the wall sleeve dimensions of
standard size and non-standard size PTACs and PTHPs large enough to
prevent non-standard PTACs/PTHPs from being installed in standard size
PTAC and PTHP openings. GE used the example of a PTAC (15.75 x 41.75
inches) that GE believes could easily fit inside a standard size PTAC
wall sleeve, yet this unit would be classified as non-standard size
equipment subject to less stringent energy conservation standards.
(Public Meeting Transcript, No. 12 at pp. 16, 33-34; GE, No. 8 at p. 2)
GE stated that the wording in Addendum t might encourage the design
of new PTAC and PTHP equipment that may circumvent the intent of DOE's
regulations. (Public Meeting Transcript, No. 12 at pp. 16, 33-34; GE,
No. 8 at p. 2) As an alternative, GE suggested DOE use the wall sleeve
dimensions of the largest non-standard size PTAC and PTHP equipment
currently on the market to define non-standard size PTACs and PTHPs.
(Public Meeting Transcript, No. 12 at p. 33)
ECR, McQuay, and AHRI responded to concerns about the potential for
a loophole for less efficient standard size equipment to enter the
market if DOE adopts the delineations in Addendum t. (ECR, No. 15 at
pp. 1, 4; Public Meeting Transcript, No. 12 at pp. 20 (ECR), 22 (AHRI),
31-32 (AHRI), 38 (McQuay)) AHRI stated that the same potential loophole
exists in the delineations within ASHRAE Standard 90.1-1999 for
standard size and non-standard size PTACs and PTHPs. AHRI commented
that if manufacturers want to introduce less efficient standard size
equipment with wall sleeve dimensions just shy of the standard size
limitations, manufacturers would have introduced this type of equipment
already because this loophole has been in existence since 1999.
However, AHRI pointed out that none of the manufacturers in the PTAC
and PTHP industry have taken
[[Page 58782]]
advantage of this potential loophole. AHRI also noted that Addendum t
requires non-standard size equipment to be labeled to prevent
misapplications of less efficient non-standard equipment entering into
newly constructed projects. (AHRI, No. 23 at pp. 6-7)
ECR also commented that it does not believe that non-standard size
equipment will be used in newly constructed buildings. ECR stated that
commercial customers would not purchase non-standard equipment because
it is rated at lower efficiencies; rather, customers make purchases
based on the characteristics and needs of the installation (i.e., wall
sleeve dimensions). Placing non-standard size equipment in newly
constructed buildings does not make economic sense. (ECR, No. 15 at pp.
1, 4; Public Meeting Transcript, No. 12 at p. 20) McQuay pointed out
that non-standard equipment is needed to meet a specific demand that
exists in the market, particularly for older buildings, and that
phasing out the market would decrease competition and limit customer
choices. (Public Meeting Transcript, No. 12 at p. 38) If DOE were to
adopt the delineations within ASHRAE Standard 90.1-1999, ECR believes
building owners and commercial customers would keep their older, much
less efficient units in place longer because replacements could become
unavailable. (ECR, No. 15 at p. 1)
On June 22, 2008, ASHRAE Standard 90.1's committee voted to
officially approve the publication of Addendum t to ASHRAE Standard
90.1-2007 for PTACs and PTHPs.\8\ This action finalizes Addendum t,
which means that DOE can officially use this delineation as the basis
for amended energy conservation standards. (42 U.S.C.
6313(a)(6)(A)(ii))
---------------------------------------------------------------------------
\8\ To obtain a copy of Addendum t to ASHRAE Standard 90.1-2007,
contact the ASHRAE publications department at: orders@ashrae.org or
1-(800) 527-4723.
---------------------------------------------------------------------------
DOE divides equipment classes by the type of energy used or by
capacity or other performance-related features that affect efficiency.
Different energy conservation standards may apply to different
equipment classes. (42 U.S.C. 6295(q)) When installed, PTACs and PTHPs
are fitted into a wall sleeve. There is a wide variety of wall sleeve
sizes found in different buildings. Wall sleeve sizes are market driven
(i.e., the applications or facilities where the PTACs or PTHPs are
installed is what determines the ``market standard'' wall sleeve
dimension) and this factor requires manufacturers to offer various
PTACs and PTHPs that can fit into various wall sleeve dimensions. For
new units, the industry has standardized the wall sleeve dimension for
PTACs and PTHPs in buildings over the past 20 years to be 16 inches
high by 42 inches wide. Therefore, units that have a wall sleeve
dimension of 16 inches high by 42 inches wide are considered ``standard
size'' equipment and all other units are considered ``non-standard
size'' equipment. In contrast, the industry does not have a common wall
sleeve dimension that is typical for all older existing facilities.
These facilities, such as high-rise buildings found in large cities,
typically use non-standard size equipment. In these installations,
altering the existing wall sleeve opening to accommodate the more
efficient, standard size equipment could include extensive structural
changes to the building, which could be very costly, and is, therefore,
rarely done.
DOE believes that wall sleeve sizes are performance-related
features that affect PTAC and PTHP efficiency. Manufacturers typically
use various heat exchanger sizes in different wall sleeve size
equipment, and the size of the heat exchanger directly affects the
energy efficiency of the equipment. By examining the market data, DOE
found that non-standard size PTACs and PTHPs typically are less
efficient than standard size PTACs and PTHPs. Consequently, DOE is
adopting the delineations in Addendum t to ASHRAE Standard 90.1-2007 to
differentiate between standard size and non-standard size equipment.
DOE believes the delineations within Addendum t will help to
mitigate the impacts on manufacturers of non-standard size equipment,
and will not cause any equipment unavailability issues for commercial
customers. DOE was concerned that, absent non-standard equipment,
commercial customers could be forced to invest in costly building
modifications to convert non-standard sleeve openings to standard size
dimensions. Alternatively, customers may choose to use less efficient
through-the-wall air conditioners or maintain their older, less
efficient equipment longer in the absence of non-standard PTACs and
PTHPs.
Although DOE acknowledges GE's and ACEEE's concern about the
potential loophole in the definition, DOE believes that the effects of
this loophole will be reduced due to the labeling requirements
specified in Addendum t. DOE is not adopting the labeling requirement
set forth in Addendum t, but believes that non-standard manufacturers
will still be required to use this labeling through some of their State
building code regulations, which require the use of such labels on PTAC
and PTHP equipment. DOE believes ASHRAE's labeling requirement will
deter less efficient equipment from entering into newly constructed
buildings.
Additionally, DOE agrees with AHRI's assertion that if
manufacturers wanted to introduce less standard size equipment with
wall sleeve dimensions just shy of the standard size limitations they
could have done this in today's market. DOE believes the market forces
surrounding the standardized sleeve size have deterred standard size
manufacturers from producing this type of equipment because of the
unique non-standard size industry and the cost implications of
producing customized equipment. Further, DOE believes these market
forces will continue to deter standard size manufacturers from taking
advantage of this potential loophole after the adoption of the
delineations in Addendum t to ASHRAE Standard 90.1-2007.
In today's final rule, DOE incorporates the following definitions
of standard size and non-standard size PTACs and PTHPs as presented in
Addendum t to ASHRAE Standard 90.1-2007:
Standard size refers to a PTAC or a PTHP with wall sleeve
dimensions having an external wall opening of greater than or equal to
16 inches high or greater than or equal to 42 inches wide, and having a
cross-sectional area greater than or equal to 670 square inches.
Non-standard size refers to a PTAC or a PTHP with existing
wall sleeve dimensions having an external wall opening of less than 16
inches high or less than 42 inches wide, and having a cross-sectional
area less than 670 square inches.
DOE added these two definitions of standard size and non-standard
size to be codified at 10 CFR 431.2. Consistent with the definitions,
DOE has defined the equipment classes for today's final rule for PTACs
and PTHPs (as shown in Table IV.1).
[[Page 58783]]
Table IV.1--Equipment Classes for PTACs and PTHPs if ASHRAE Adopts Addendum to ASHRAE Standard 90.1-2007
----------------------------------------------------------------------------------------------------------------
Equipment class
-----------------------------------------------------------------------------------------------------------------
Equipment Category Cooling capacity (Btu/h)
----------------------------------------------------------------------------------------------------------------
PTAC..................................... Standard Size *............ <7,000
7,000-15,000
>15,000
----------------------------------------------------------------------
Non-Standard Size **....... <7,000
7,000-15,000
>15,000
----------------------------------------------------------------------------------------------------------------
PTHP..................................... Standard Size *............ <7,000
7,000-15,000
>15,000
----------------------------------------------------------------------
Non-Standard Size **....... <7,000
7,000-15,000
>15,000
----------------------------------------------------------------------------------------------------------------
* Standard size refers to PTAC or PTHP equipment with wall sleevedimensions having an external wall opening of
greater than or equal to 16 inches high or greater than or equal to 42 inches wide, and having a cross-
sectional area greater than or equal to 670 square inches.
** Non-standard size refers to PTAC or PTHP equipment with existing wall sleeve dimensions having an external
wall opening of less than 16 inches high or less than 42 inches wide, and having a cross-sectional area less
than 670 square inches.
B. Screening Analysis
The purpose of the screening analysis is to evaluate the
technologies that improve equipment efficiency, to determine which
technologies to consider further, and which to screen out. In
developing the screening analysis for the NOPR, DOE consulted with a
range of parties, including industry, technical experts, and others to
develop a list of technologies for consideration. DOE then applied the
four screening criteria to determine which technologies are unsuitable
for further consideration in the rulemaking (10 CFR part 430, subpart
C, appendix A4.(a)(4) and 5.(b)). DOE presented its results of the
screening analysis in the NOPR and in Chapter 4 of the NOPR TSD. In
response to the NOPR, DOE received one comment about the technology
options that it considered in the screening analysis.
ACEEE commented that DOE should not have screened out some of the
technology options. Instead, DOE should have further considered these
options in the engineering analysis. (Public Meeting Transcript, No. 12
at pp. 49-52, 64-65) ACEEE stated that DOE neglected to examine other
types of compressors (such as scroll compressors), electronically
commutated motor (ECM) fans, clutched fan motors, micro-channel heat
exchangers, and thermostatic expansion valves (TXVs). According to
ACEEE, the compressor choices for PTACs should not be different from
those used for residential refrigerators because the loads are similar.
ACEEE added that micro-channel heat exchangers allegedly cost less to
implement, require less refrigerant and space, and have been used in
air conditioning applications within automobiles. (Public Meeting
Transcript, No. 12 at pp. 50-51)
1. Scroll Compressors
As presented in Chapter 4 of the NOPR TSD, scroll compressors are
an alternative to rotary compressors in air-conditioning applications.
Scroll compressors are more efficient than rotary compressors at higher
cooling capacities than are typically found in packaged terminal
equipment. Whereas rotary compressors use a rotating motion to compress
refrigerant gases, scroll compressors use two nutating spirals--one
fixed and the other rotating. Although scroll compressors can be more
efficient than rotary compressors, they typically are more expensive,
heavier, and larger than rotary compressors of the same cooling
capacities.
After reviewing publicly available equipment literature and
specifications for scroll compressors currently available on the
market, DOE determined that manufacturers typically produce scroll
compressors with cooling capacities of approximately 20,000 Btu/h or
higher, and that the majority of equipment using scroll compressors is
typically rated at capacities higher than 40,000 Btu/h. Manufacturers
also produce scroll compressors with housings larger than those used
for compressors found in PTACs and PTHPs. DOE found that scroll
compressors are typically built to be 16 inches or higher in height and
that capacity ratings do not impact scroll compressor heights
significantly. For example, DOE found that the height of a scroll
compressor only decreases by approximately 1.5 inches when capacity
decreases from 80,000 to 20,000 Btu/h. However, significant
improvements in efficiency, when compared to rotary compressors, are
generally achieved with higher capacity models. DOE's market review
also found that scroll compressors weigh more than PTAC and PTHP
compressors. Scroll compressors typically weigh 50 pounds or more,
compared with the 25 to 30 pounds for a PTAC/PTHP rotary compressor
found in PTACs and PTHPs.
Ultimately, DOE screened out scroll compressors as a viable design
option. As stated in the NOPR and subsequently confirmed by DOE using
updated data, manufacturers do not produce scroll compressors for PTAC
and PTHP applications, making it unlikely that this technology option
could be readily applied to these products. DOE also screened out
scroll compressors because their manufacturers have yet to produce a
full line of scroll compressors that meet the size limitations,
capacity requirements, and voltage requirements of packaged terminal
equipment. The size limitation is particularly problematic when given
the installation limitations of the sleeve sizes for PTACs and PTHPs.
2. ECM Motors
As presented in Chapter 4 of the NOPR TSD, there are multiple types
of electric fan motors that manufacturers
[[Page 58784]]
can choose from to blow air over the condenser and evaporator coils.
Since the PTAC and PTHP industries have a relatively small number of
annual shipments, manufacturers typically have to choose their motors
from existing motor lines, rather than having motors customized for
their specific needs. The type of motor and its power rating are
typically indicative of its efficiency. For example, shaded pole motors
are generally the lowest efficiency motors that are available,
particularly at very low power levels. By contrast, the electronically
commutated motors (ECM) or brushless permanent magnet motors (BPMs) are
typically the most efficient motors for the low power levels.
DOE determined that the PTAC and PTHP industries have not adopted
ECMs or similar high efficiency motors due to size and weight
constraints. The size limitation is particularly problematic when given
the installation limitations of the sleeve sizes for PTACs and PTHPs,
particularly for non-standard PTACs. Ultimately, DOE screened out high
efficiency motors as a viable design option. As stated in the NOPR and
subsequently confirmed by DOE using updated data and through
discussions with industry experts, DOE found high efficiency motors are
not available in the full ranges of sizes needed for the PTAC and PTHP
industries making it unlikely that this technology option could be
readily applied to these products. DOE believes that, given these
circumstances, it would not be practical to manufacture, install, and
service this technology on the scale necessary to serve the relevant
market at the time of the effective date of an amended standard.
3. Fan Motors
ACEEE commented on clutched fan motors, but DOE did not consider
this technology. Although the automotive industry uses clutched fans to
engage and disengage a vehicle's cooling fan from the belt driven by
the engine, using a clutched fan would not provide appreciable benefits
within the energy efficiency context. In theory, these devices would
work with PTACs and PTHPs to reduce the load on a single fan motor used
to drive both the evaporator and the condenser fan blades when the
refrigerating system is not operating by disengaging the condenser fan.
In this way, power input could be reduced during times when only the
indoor blower is running to recirculate air, or when electric
resistance heating is being provided. However, the measure of energy
use for PTACs in cooling mode is based on full cooling operation, in
which both the indoor blower and the condenser fan must operate. Hence,
including a clutched condenser fan would not provide measurable energy
efficiency benefits.
4. Micro-Channel Heat Exchangers
As presented in Chapter 4 of the NOPR TSD, micro-channel heat
exchangers have a rectangular aluminum cross-section containing several
small channels through which refrigerant passes. Aluminum fins with a
corrugated shape are brazed at a 90-degree angle between the
rectangular tubes. Micro-channel heat exchanger designs provide more
heat transfer per volume of heat exchanger core and can provide more
heat transfer per unit of face area. In addition, these designs have
lower airside pressure drop than similarly performing conventional
coils, which reduces the fan power requirement. The small size and
lower airside pressure drop that results from micro-channel heat
exchangers provide opportunities to reduce the size and weight of the
heat exchanger. This explains the frequent use of micro-channel heat
exchangers in automobile air-conditioning systems, where their small
size and high performance allow car designers to minimize air
resistance by lowering the leading edge of the car.
As stated in the NOPR TSD, DOE screened out micro-channel heat
exchangers from the engineering analysis. 73 FR 18869-70. Through
review of publicly available literature, product specifications, and
discussions with manufacturers, DOE determined that micro-channel heat
exchangers have inherent problems with performance and condensate
removal when installed in PTAC equipment. In particular, manufacturers
observed that the smaller airflow passages between plate fins are
subject to clogging in installations where debris is present, which can
affect both the heat exchanger and fan motor performance. Additionally,
for PTACs and PTHPs operating in cooling mode, condensate buildup on
the evaporator of the installation may result in icing, which is harder
to remove from small horizontal micro-channel heat exchanger passages
than from the vertical fins found in the currently used tube and fin
heat exchangers.
For the reasons stated above, manufacturers have chosen not to
install micro-channel heat exchangers in PTAC and PTHP designs. DOE
determined that this technology has not yet penetrated the PTAC and
PTHP industry and that design challenges still exist. At this time, DOE
believes microchannel heat exchangers are technologically infeasible in
PTAC and PTHP applications. DOE understands that manufacturers are
conducting research into the use of micro-channel heat exchangers in
their PTACs and PTHP design at this time. However, DOE does not have
definite knowledge of whether their research efforts will be
successful, of when mirco-channel heat exchangers could appear in
either prototypes or equipment designs, and what the cost implications
would be and the contribution to system performance would be. Because
this technology is in the research stage for the PTAC industry, it is
also not possible to assess whether it will have any adverse impacts on
equipment utility to customers or equipment availability, or on
customer health or safety.
5. Thermal Expansion Valves
Regarding ACEEE's comments about TXVs, DOE did not consider this
technology for PTACs or PTHPs. TXVs are expansion devices that meter
the flow of refrigerant from the condenser to the evaporator at a rate
equivalent to the amount of refrigerant being boiled off in the
evaporator. For example, when the evaporator is exposed to high
temperatures, the TXV will open to allow faster flow of refrigerant to
match the higher boiling rate caused by higher temperatures.
Alternatively, for lower temperatures, the TXV will reduce the flow
rate to match the lower boiling rate caused by cooler temperatures.
Typically, TXVs are installed in central air conditioning applications
where equipment is rated with the seasonal energy efficiency ratio
(SEER) metric and testing occurs at various operating conditions and
temperatures. In contrast, PTACs and PTHPs are measured using the EER
metric, with testing occurring at a constant temperature of 95 degrees
F. Therefore, the energy efficiency benefits of a TXV will not affect
the EER rating of a PTAC because the orifice of the TXV and the flow of
refrigerant would remain constant during testing. Therefore, DOE does
not consider TXVs to be a technology for improving the EER of PTACs and
PTHPs.
C. Engineering Analysis
The purpose of the engineering analysis is to establish the
relationship between the cost and efficiency of PTACs and PTHPs and to
show the manufacturing costs required to achieve that increased
efficiency level. As detailed in the NOPR, DOE's engineering analysis
for PTACs and PTHPs estimated the baseline manufacturer cost, as well
as the incremental cost for equipment at
[[Page 58785]]
efficiency levels above the baseline. 73 FR 18870-74. DOE presented its
engineering analysis in the NOPR, which included a discussion on the
approach, the equipment classes analyzed, the cost model, the baseline
equipment, the alternative refrigerant analysis, the cost efficiency
results, and mappings of the EER and COP values. In response to DOE's
presentation of the engineering analysis in the NOPR, DOE received
comments on the following topics: Standard size equipment performance
in systems using R-410A refrigerant, max-tech efficiency levels
analyzed for standard size equipment, energy-efficiency equations for
standard size equipment, max-tech efficiency levels analyzed for non-
standard size equipment, energy-efficiency for non-standard size
equipment, compressor availability, and the manufacturer production
cost increases with the introduction and use of R-410A. DOE discusses
each of these topics and the updates to the cost model for the final
rule in the subsections below.
1. Material Prices for the Cost Model
In the NOPR analyses, DOE used five-year average material prices
from years 2002 through 2006. 73 FR 18871. For the final rule, DOE
updated the five-year averages to include material price data from 2007
and 2008. DOE uses a five-year span to normalize the fluctuating prices
experienced in the commodities market to screen out temporary dips or
spikes. DOE believes a five-year span is the longest span that would
still provide appropriate weighting to current prices experienced in
the market.
DOE basis for its belief relies on updated commodity pricing data,
which point to continued increases. For example, the 5-year time period
ending in mid-2008 has higher commodity indices than a 5-year ending in
mid-2006 by 10 percent, 28 percent, and 45 percent for All Commodities,
Steel, and Copper, respectively.\9\ Considering the significant amount
of steel and copper in each PTAC or PTHP, incorporating commodity
prices that reflect 5-year average prices as close to the current
conditions best reflect the market conditions. DOE believes it is
appropriate to use prices from 2007 and 2008 in the data span because
it more closely represents current PTAC and PTHP material prices and
manufacturing conditions. DOE calculated a new five-year average
materials price for cold rolled steel, aluminized steel, galvanized
steel, painted cold rolled steel, and stainless steel. DOE used the
U.S. Department of Labor's Bureau of Labor Statistics (BLS) Producer
Price Indices (PPIs) for various materials from 2004 to 2008 to
calculate new averages, which incorporate the changes within each
material industry and inflation. Finally, DOE adjusted all averages to
2007$ using the gross-domestic-product implicit-price deflator.
---------------------------------------------------------------------------
\9\ Bureau of Labor Statistics (BLS) for Copper (WPU102502),
Cold Rolled Steel (WPU101707), and All Commodities (WPU00000000) as
tracked in the Producer Price Index (PPI) database of the BLS. To
download the data or to discover how it is gathered, please see
http://www.bls.gov.
---------------------------------------------------------------------------
As was the case for the NOPR, DOE developed a material-price-
sensitivity analysis. DOE used the annual average price for each of the
raw materials from 2008 to calculate the current manufacturing product
costs (MPCs). DOE expressed the material price sensitivity results in
2007$. The results for the material-price-sensitivity analysis are
presented in Chapter 5 of the final rule TSD.
2. Impacts of the Refrigerant Phaseout on PTAC and PTHP Equipment
Performance
a. Standard Size Equipment Performance in Systems Using R-410A
Refrigerant
GE commented that R-410A refrigerant has been in use for years by
the air conditioning industry. Even though GE believes switching to R-
410A refrigerant in PTAC and PTHP equipment will have a negative impact
on system efficiency, GE believes the difference can be made up with a
combination of higher efficiency compressors, motors, as well as
increases in heat exchanger size. GE stated that manufacturers have
been aware of the future requirements and should be far along with
developments and designs to meet both amended energy conservation
standards and R-410A requirements. GE also pointed out that one
manufacturer has produced an R-410A PTHP that exceeds the proposed
energy conservation standard level in the NOPR (i.e., 11.5 EER for
standard equipment) and is currently available on the market. (GE, No.
20 at pp. 2-3; Public Meeting Transcript, No. 12 at pp. 17-18, 66) GE
noted that it is finishing the design and test phase for several models
and is confident that it can manufacture standard size R-410A PTACs and
PTHPs at TSL 4 efficiency levels (i.e., the proposed energy
conservation standards for PTHPs in the NOPR). GE added that achieving
an efficiency level that is 10 percent higher than the proposed
standard for a potential ENERGY STAR category is also possible with
existing technology. (GE, No. 20 at p. 3; Public Meeting Transcript,
No. 12 at p. 66)
In addition to comments from manufacturers of standard size PTACs
and PTHPs, DOE also received confidential performance test data that
characterizes the equipment performance degradations in standard size
PTACs and PTHPs using R-410A refrigerant. The confidential data DOE
received regarding standard size equipment performance suggests the
performance degradation can vary greatly depending upon the cooling
capacity of the equipment. DOE further addresses comments from
interested parties and its analysis of the variation in standard size
equipment performance with changes in cooling capacity in DOE's
discussion of the energy-efficiency equations, below.
DOE reviewed the data submitted by manufacturers and comments from
interested parties and found, in general, the system performance
degradations for PTAC and PTHP equipment with R-410A, as described in
the NOPR, were in the middle of the range of the submitted data. For
today's final rule, DOE used the same system performance degradations
for PTAC and PTHP equipment with R-410A refrigerants as described in
the NOPR. 73 FR 18873. Because standard size PTAC and PTHP equipment
utilizing R-22 refrigerants exists at efficiency levels well above the
efficiency levels in ASHRAE Standard 90.1-1999, DOE believes that
manufacturers will be able to produce equipment utilizing R-410A at
efficiency levels specified by ASHRAE Standard 90.1-1999 and higher
efficiency levels in 2012. As GE noted, one standard size manufacturer
is already producing R-410A equipment at efficiency levels above ASHRAE
Standard 90.1-1999 efficiency levels. Lastly, the comments submitted by
GE establishes that PTAC and PTHP prototypes utilizing R-410A
refrigerant have been developed and will be able to meet the proposed
efficiency levels, i.e., TSL 4, for standard size PTACs and PTHPs.
As DOE reviewed the data submitted by interested parties, DOE
generally found larger performance degradations at higher cooling
capacities for standard size equipment. As a PTAC or PTHP increases in
capacity, manufacturers typically increase the surface area or add a
row to the heat exchanger in order to increase unit capacity. Even at
larger cooling capacities, manufacturers have to maintain the same
physical box sleeve, leaving little space for additional efficiency
modifications (e.g., adding heat exchanger area). DOE considered the
effects of the R-410A refrigerant
[[Page 58786]]
phaseout on the entire range of cooling capacities as part of the
generation of the energy-efficiency equations that translates the
results for the representative cooling capacities to the entire cooling
capacity range. See section IV.C.2.c for additional details on how DOE
extended the results for the representative cooling capacities to the
full range of cooling capacities for standard size PTACs and PTHPs.
b. ``Max-Tech'' Efficiency Levels Analyzed for Standard Size Equipment
AHRI and the People's Republic of China, through its WTO/TBT
National Notification and Enquiry Center (PRC), commented that the max-
tech levels are inaccurate because they are based on R-22 refrigerant
and there is no equipment in the 2008 AHRI Directory of Certified
Product Performance (AHRI Certified Directory) \10\ operating with R-
410A refrigerant. AHRI and the PRC also commented about the difficulty
in reaching the max-tech efficiency levels with R-410A refrigerant and
assert that attaining those efficiency levels is not possible at this
time. (Public Meeting Transcript, No. 12 at pp. 168-169; PRC, No. 17 at
p. 3)
---------------------------------------------------------------------------
\10\ The Air-Conditioning, Heating and Refrigerating Institute,
Directory of Certified Product Performance for Packaged Terminal Air
Conditioners and Packaged Terminal Heat Pumps. 2008. <http://
www.ahridirectory.org/ahriDirectory/pages/home.aspx.
---------------------------------------------------------------------------
DOE agrees that with the prohibition on R-22 refrigerant, and the
expected use of R-410A refrigerant as the most likely alternative,
system performance will decline. The max-tech efficiency level should
be based on the most likely refrigerant, which is R-410A. Accordingly,
DOE revised the max-tech efficiency levels for standard size PTACs and
PTHPs in the final rule analysis. DOE applied the system performance
degradations described in the NOPR to the AHRI certified market data
for standard size equipment. (See graphs in Chapter 5 of the final rule
TSD.) DOE used the modified market data to estimate the max-tech
efficiency levels corresponding to current models utilizing R-410A and
has identified these efficiency levels in section III.B for the
representative cooling capacities. DOE estimates that these performance
degradations will fall within five to eight percent depending on
cooling capacity when compared to an R-22 baseline.
c. Energy-Efficiency Equations for Standard Size Equipment
In response to the NOPR, DOE also received a comment on its
approach for calculating the energy efficiency equations for standard
size PTACs and PTHPs. Carrier commented that the engineering
extrapolations might not provide an accurate view of the max-tech
efficiency levels for larger size equipment. In particular, Carrier
commented that the PTAC efficiency levels proposed in the NOPR are
achievable, but the PTHP proposed efficiency levels in the NOPR may be
unachievable in equipment with a cooling capacity of 12 kBtu/h and
above. (Carrier, No. 16 at p. 2)
DOE further considered the effects of R-410A on system performance
for larger cooling capacities in the engineering analysis. DOE found
that as a standard size PTAC or PTHP increases in capacity,
manufacturers typically increase the coil surface area or add a coil
row to the heat exchanger in order to increase unit capacity.
Manufacturers of standard size PTACs and PTHPs maintain the same
physical box sleeve (i.e., 42 inches by 16 inches) across all models
regardless of cooling capacity. This sleeve size is an established
common sleeve size that allows standardization across the industry.
This common sleeve size allows end-users to simply slide replacement
units into existing wall sleeve openings. However, the standard size
wall sleeve imposes a limitation on the total volume available into
which all components must fit. Manufacturers add heat exchanger coil
area or coil volume to either increase the cooling capacity or to
obtain higher efficiencies. This fixed volume limits the size of the
box into which the unit's components must fit. In turn, this fixed
volume limits the size of heat exchangers and other components that can
be used to increase efficiency and there are accompanying decreases in
thermodynamic returns when making such changes. Thus, higher capacity
units often have lower energy efficiency potentials due to the size
constraints of the box sleeve.
In order to consider the effects of the refrigerant phaseout on
larger capacity units, DOE reviewed the market data for standard size
equipment in the AHRI Certified Directory. DOE applied the efficiency
degradations distinguished by cooling capacity ranges estimated in the
engineering analysis to each of the models in the AHRI Certified
Directory. DOE used these data to estimate the overall system
performance of the models in the AHRI Certified Directory utilizing R-
410A refrigerant. From these data, DOE plotted each TSL it considered
as part of the final rule to see if there were models in the full range
of cooling capacity with estimated performance utilizing R-410A
refrigerant that would meet the TSL being considered.
For TSL A, which is the amended standard level for standard size
PTACs and PTHPs, DOE adjusted the slope of the energy-efficiency
equation from the revised slopes calculated in the NOPR for TSLs 1
through 7. This adjustment was based on manufacturer comment and DOE
data pointing to the reduced opportunities for achieving greater
efficiencies for larger capacity PTAC and PTHP equipment. By revising
the slope in this manner, DOE could create and ultimately, adopt, a
standard level that is more stringent for lower cooling capacities,
where manufacturers have additional physical space to add efficiency
improvements, but is less stringent for higher cooling capacities,
where manufacturers are physically constrained by the physical
dimensions of the box sleeve and less able to introduce efficiency
improvements. See Chapter 9 of the final rule TSD for additional
details and graphic demonstrations of the energy-efficiency equations
for each TSL, including today's amended energy conservation standard
for standard size PTACs and PTHPs.
d. Efficiency Levels Analyzed for Non-Standard Size Equipment
In the NOPR, DOE explicitly analyzed one cooling capacity of non-
standard equipment (i.e., 11,000 Btu/h). Based upon this cooling
capacity, DOE demonstrated a typical design option pathway a
manufacturer could use to increase the efficiency of its non-standard
PTAC and PTHP equipment. To account for the potential loss of system
efficiency as a result of the R-22 refrigerant phaseout, DOE applied an
overall system degradation of 6.8 percent, which effectively shifted
the cost-efficiency curve to the left (in the direction of decreasing
efficiency for the same cost). Thus, for any given efficiency level,
the MPC increase will be greater when R-410A refrigerants are used. By
degrading expected system performance, DOE accounts for the shift in
the baseline performance that a system converted to R-410A use
typically exhibits. Using the design option pathway described in the
engineering analysis, the maximum efficiency level analyzed is 10.0 EER
for non-standard equipment with a cooling capacity of 11,000 Btu/h
using R-410A.
e. Energy-Efficiency Equations for Non-Standard Size Equipment
In response to the NOPR, DOE received several comments on its
approach for calculating the energy-efficiency equations for non-
standard
[[Page 58787]]
size PTACs and PTHPs. Specifically, DOE retained the ASHRAE Standard
90.1-1999 slope from the energy-efficiency equation, which
characterizes the relationship between EER and cooling capacity for
non-standard PTACs and PTHPs in the NOPR. 73 FR 18890-91.
ECR and AHRI commented that they are particularly concerned about
reaching the efficiency levels for the larger capacity, non-standard
size equipment. (AHRI, No. 23 at pp. 4-5; Public Meeting Transcript
(ECR), No. 12 at p. 170) ECR specifically commented that it is
concerned about the methodology DOE used to develop the energy-
efficiency equations for non-standard equipment. (ECR, No. 15 at p. 2)
ECR and Ice Air commented that the proposed energy conservation
standard for non-standard PTHPs is too high for all capacities
considering the system performance degradations from switching to R-
410A refrigerant. (Public Meeting Transcript, No. 12 at pp. 56-60; Ice
Air, No. 25 at p. 2)
DOE further considered the effects of R-410A on system performance
in the engineering analysis for larger cooling capacities of non-
standard PTACs and PTHPs. As explained above, DOE found that as a non-
standard size PTAC or PTHP increases in capacity, manufacturers
typically increase the coil surface area or add a coil row to the heat
exchanger in order to increase unit capacity. The fixed volume of the
box sleeve imposes a physical limit on the size of heat exchangers and
other unit components that can be used to increase efficiency. Thus,
higher capacity units often have lower energy efficiency potential due
to the size constraints of the box.
In order to consider the effects on larger capacity units, DOE
reviewed the market data for non-standard size equipment in
manufacturer equipment catalogs. DOE applied the efficiency
degradations distinguished by cooling capacity ranges estimated in the
engineering analysis to each of the non-standard models offered for
sale and described in manufacturer equipment catalogs. DOE used this
data to estimate the overall system performance of the models on the
market utilizing R-410A refrigerant. DOE was able to plot each of the
TSLs it considered as part of the final rule (i.e., TSL 1 through 5) to
see if there were models in the full range of cooling capacities with
estimated performance utilizing R-410A refrigerant that would meet the
TSL being considered. These plots demonstrated the specific cooling
capacities where the TSL or amended standard would be eliminating all
of the models from the market using the estimated R-410A performance.
See Chapter 9 of the final rule TSD for additional details and graphic
demonstrations of the energy-efficiency equations for each TSL,
including today's amended energy conservation standard for non-standard
size PTACs and PTHPs.
DOE further considered the effects of the refrigerant phaseout on
larger cooling capacities when weighing the benefits and the burdens
for non-standard equipment. See section V.D for additional information.
f. Compressor Availability
AHRI, Carrier, Ice Air, ECR, and Goodman stated that the true
impact on PTAC and PTHP equipment efficiency levels cannot currently be
assessed because the lack of available components across the range of
equipment capacities prevents comprehensive equipment testing. These
manufacturers also stated that R-410A compressors are not available in
all required capacities and voltages. Further, compressor manufacturers
have not committed to improving compressor performance of rotary
compressors. (Public Meeting Transcript (ECR), No. 12 at p. 68-69;
Public Meeting Transcript (Goodman), No. 12 at p. 174; AHRI, No. 23 at
p. 4; Carrier, No. 16 at p. 5; Ice Air, No. 25 at pp. 1-2)
As DOE presented in the NOPR, DOE found the availability of R-410A
compressors in a wide range of efficiencies and voltages remains
uncertain. Several compressor manufacturers make R-22 PTAC and PTHP
compressors of different capacities, voltages, and efficiencies for
standard and non-standard equipment. As the market transitions to the
use of R-410A, manufacturers may only develop and offer one line of
compressors for PTACs and PTHPs. In engineering interviews conducted
for the NOPR, compressor manufacturers commented on the uncertainties
surrounding R-410A compressors and their performance characteristics
when compared to R-22 compressors. 73 FR 18874. DOE noted in the NOPR
that compressor manufacturers stated in interviews that they expect to
offer R-410A compressors at only one efficiency level in the initial
stages of the R-22 refrigerant phaseout, which could further reduce
compressor options for PTAC and PTHP manufacturers. Id.
In response to comments and the uncertainty surrounding compressor
options for manufacturers, DOE gave particular attention to the PTAC
and PTHP efficiency levels that cannot be met with current technologies
and practices with R-410A in weighing the benefits and burdens of the
various TSLs. However, DOE notes that GE stated its working prototypes
have experienced significantly less performance degradation due to R-
410A conversion than was modeled in the engineering analysis. (GE, No.
20 at p. 2) Based on manufacturer feedback during interviews and
historic precedent in other air-conditioning markets where similar
refrigerant transitions have taken place, DOE acknowledges that the R-
410A compressors available for use in PTAC and PTHP equipment could be
less efficient than similar compressors that use R-22 refrigerant at
the time of the R-22 phaseout. Even though DOE received comments during
engineering interviews stating compressor manufacturers may only offer
one rotary compressor line when the refrigerant phaseout occurs, DOE
believes compressor manufacturers will continue their development
efforts and eventually offer compressors in the full range of cooling
capacities, voltages, and efficiencies as they do today. Similar market
transformations have occurred in other industries and while the initial
set of compressors were less efficient, the markets eventually matured
to offer manufacturers a variety of compressors. See Chapter 5 of the
TSD for additional information. In addition, DOE believes the amended
energy conservation standards being adopted in today's final rule will
aid the PTAC and PTHP industry and provide compressor manufacturers
with target efficiencies for which they can concentrate their research
and development efforts.
3. Manufacturer Production Cost Increases With R-410A
Goodman stated that DOE's estimate of a two percent manufacturing
cost increase for converting standard size PTAC and PTHP equipment to
utilize R-410A refrigerant is too low. (Public Meeting Transcript, No.
12 at pp. 46-47, 74)
Goodman misstates DOE's estimate. DOE did not use a two percent
cost increase. To derive the baseline MPCs for the R-410A PTACs and
PTHPs used in the NOPR, DOE estimated the R-410A refrigerant pricing,
R-410A compressor pricing, as well as other design changes necessary to
accommodate the alternative refrigerant, and incorporated them into the
same cost model used for the R-22 engineering analysis. Based on
technical journals and manufacturer interviews, DOE increased the tube
wall thicknesses of all heat exchangers by 25 percent to
[[Page 58788]]
account for the higher pressures associated with R-410A refrigerant.
DOE also used a refrigerant price for R-410A based upon cost estimates
from refrigerant suppliers and engineering interviews with
manufacturers. During engineering interviews, PTAC and PTHP equipment
and component manufacturers stated that compressor prices would
increase between 10 percent and 20 percent from current R-22 compressor
prices. To incorporate manufacturers' comments, DOE estimated that
compressor costs would increase by 15 percent. Using the above
estimates, DOE calculated the baseline manufacturer selling price
(MSPs) \11\ of R-410 standard size equipment to be at least 10 percent
more than its' R-22 counterpart, on average. See Chapter 5 of the final
rule TSD for additional details of the R-410A analysis and results. See
TSD, Chapter 5, Section 5.8 (detailing representative capacities of
standard size equipment using R-410A).
---------------------------------------------------------------------------
\11\ This is the price at which the manufacturer can recover
both production and non-production costs and earns a profit.
---------------------------------------------------------------------------
Accordingly, DOE believes Goodman's statement mischaracterizes the
estimated manufacturing cost increases in the NOPR. DOE has continued
to use the same methodology as presented in the NOPR to develop the R-
410A manufacturer production costs for both standard size and non-
standard size equipment. After DOE revised the cost model in response
to comments from interested parties, DOE calculated the baseline MSPs
to be at least 15 percent more than its R-22 counterpart, on average,
for standard size PTAC and PTHP equipment. Additional details and
results can be found in section 5.8 of Chapter 5 of the final rule TSD.
D. Energy Use Characterization
The building energy use characterization analysis assessed the
energy savings potential of PTAC and PTHP equipment at different
efficiency levels. The analysis estimates the energy use of PTACs and
PTHPs at specified energy efficiency levels through energy use
simulations for key commercial building types across a range of climate
zones. The energy simulations yielded hourly estimates of building
energy consumption, including lighting, plug loads, and air-
conditioning and heating equipment. The analysis extracted the annual
energy consumption of the PTACs and PTHPs for use in subsequent
analyses, including the LCC, PBP, and NES.
DOE did not consider a rebound effect in the final rule analysis
when determining the reduction in energy consumption of PTAC and PTHP
equipment due to increased efficiency. The rebound effect occurs when a
piece of equipment is made more efficient such that the operating costs
come down to a point that either the use of the product increases or
the market increases, resulting in lower than expected energy savings.
Because the user of the equipment (e.g., the customer in a hotel room)
does not pay the utility bill, DOE assumed that increasing the
efficiency of the equipment will not affect the usage or market for the
equipment and, as a result, no rebound effect would occur. DOE
requested comment on this assumption in the NOPR. 73 FR 18876. The
commenters all agreed that there would be no rebound effect for PTACs
and PTHPs. (Public Meeting Transcript (ECR), No. 12 at p. 138, GE, No.
8 at p. 2, Carrier, No. 16 at p. 2) Based on the above, DOE did not
incorporate a rebound effect into the final rule analysis.
E. Life-Cycle Cost Analysis
For each efficiency level analyzed, the LCC analysis requires input
data for the total installed cost of the equipment, its operating cost,
and the discount rate. Table IV.2 summarizes the inputs and key
assumptions used to calculate the customer economic impacts of all
energy efficiency levels analyzed in this rulemaking. DOE also
calculated the PBP of the TSLs relative to a baseline efficiency level.
The PBP measures the amount of time it takes the commercial customer to
recover the assumed higher purchase expense of more energy efficient
equipment through lower operating costs. Similar to the LCC, the PBP is
based on the total installed cost and operating expenses, and is
calculated as a range of payback periods depending on the probability
distributions of the two key inputs (i.e., the supply chain markups and
where the unit is likely to be shipped). Unlike its calculation of the
LCC, DOE's calculation of the PBP considered only the first year's
operating expenses. Because the PBP does not account for changes in
operating expense over time or the time value of money, it is also
referred to as a simple payback period. Aside from the installation
cost, the primary change for the final rule analysis affecting PBP is
the electricity price forecasted for 2012 based on the 2007 EIA State
energy price data and the AEO2008 electricity price forecasts. Chapter
8 of the TSD discusses the PBP calculation in more detail.
Table IV.2--Final Rule Inputs and Key Assumptions Used in the LCC and
PBP Analyses
------------------------------------------------------------------------
Changes for final
Inputs NOPR description rule
------------------------------------------------------------------------
Overall
------------------------------------------------------------------------
LCC Reporting............... All cost inputs and Updated cost inputs
LCC analysis and and LCC reporting
reporting done in to 2007 dollars
2006 dollars (2007$).
(2006$).
------------------------------------------------------------------------
Affecting Total Installed Cost
------------------------------------------------------------------------
Equipment Price............. Derived by All MSPs updated to
multiplying MSP 2007. Updated
(from the wholesaler markup
engineering to use 2007
analysis) by industry (Heating,
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