[Federal Register Volume 82, Number 141 (Tuesday, July 25, 2017)]
[Proposed Rules]
[Pages 34427-34449]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-15580]
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Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
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Federal Register / Vol. 82, No. 141 / Tuesday, July 25, 2017 /
Proposed Rules
[[Page 34427]]
DEPARTMENT OF ENERGY
10 CFR Parts 429 and 431
[EERE-2017-BT-TP-0018]
RIN 1904-AD93
Energy Conservation Program for Certain Commercial and Industrial
Equipment: Test Procedure for Certain Categories of Commercial Air
Conditioning and Heating Equipment
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy (DOE).
ACTION: Request for information (RFI).
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SUMMARY: In response to statutory requirements to review its test
procedures in response to any updates of the relevant industry test
procedures, as referenced in the American Society of Heating,
Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 90.1
(ASHRAE Standard 90.1), the U.S. Department of Energy (DOE) is
initiating a data collection process to consider amendments to DOE's
test procedures for commercial package air conditioning and heating
equipment with test procedure updates included in ASHRAE Standard 90.1-
2016--specifically, those evaporatively-cooled commercial unitary air
conditioners (ECUACs), water-cooled commercial unitary air conditioners
(WCUACs), and air-cooled commercial unitary air conditioners (ACUACs)
which have a rated cooling capacity greater than or equal to 65,000
Btu/h and less than 760,000 Btu/h; and all classes of computer room air
conditioners (CRACs); as well as to consider adopting a new test
procedure for dedicated outdoor air systems (DOASes), equipment covered
by ASHRAE Standard 90.1 for the first time. In response to other
statutory requirements for DOE to review its test procedures at least
once every seven years, DOE is also reviewing its test procedures for
ECUACs and WCUACs with a rated cooling capacity less than 65,000 Btu/h,
as well as all classes of variable refrigerant flow multi-split air
conditioners and heat pumps (VRF multi-split systems) but excluding
single-phase systems with a rated cooling capacity less than 65,000
Btu/h, which are covered as consumer products. To inform interested
parties and to facilitate this process, DOE has gathered data and has
identified several issues that might warrant modifications to the
currently applicable Federal test procedures, topics on which DOE is
particularly interested in receiving comment. In overview, the issues
outlined in this document mainly concern incorporation by reference of
the most recent version of the relevant industry standard(s);
efficiency metrics and calculations; clarification of test methods; and
any additional topics that may inform DOE's decisions in a future test
procedure rulemaking, including methods to reduce regulatory burden
while ensuring the procedures' accuracy. These topics (and others
identified by commenters) are ones which may be addressed in proposed
test procedure amendments in a subsequent notice of proposed rulemaking
(NOPR). DOE welcomes written comments and data from the public on any
subject related to the test procedures for this equipment, including
topics not specifically raised in this RFI.
DATES: Written comments, data, and information are requested and will
be accepted on or before August 24, 2017.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at https://www.regulations.gov. Follow
the instructions for submitting comments. Alternatively, interested
persons may submit comments, identified by docket number EERE-2017-BT-
TP-0018, by any of the following methods:
Federal eRulemaking Portal: www.regulations.gov. Follow
the instructions for submitting comments.
Email: [email protected]. Include
EERE-2017-BT-TP-0018 in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program,
U.S. Department of Energy, Building Technologies Office, Mailstop EE-
5B, Test Procedure RFI for Commercial Package Air Conditioning and
Heating Equipment, Docket No. EERE-2017-BT-TP-0018 and/or RIN 1904-
AD93, 1000 Independence Avenue SW., Washington, DC 20585-0121. If
possible, please submit all items on a compact disc (CD), in which case
it is not necessary to include printed copies.
Hand Delivery/Courier: Appliance and Equipment Standards
Program, U.S. Department of Energy, Building Technologies Office, 950
L'Enfant Plaza, SW., 6th Floor, Washington, DC 20024. Telephone: (202)
586-6636. If possible, please submit all items on a CD, in which case
it is not necessary to include printed copies.
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on the
rulemaking process, see section III of this document (Public
Participation).
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting document/materials, is
available for review at www.regulations.gov. All documents in the
docket are listed in the www.regulations.gov index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
The docket Web page can be found at: https://www.regulations.gov/docket?D=EERE-2017-BT-TP-0018. The docket Web page will contain simple
instructions on how to access all documents, including public comments,
in the docket. See section III of this document, Public Participation,
for information on how to submit comments through www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Ms. Catherine Rivest, U.S. Department
of Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW., Washington,
DC 20585-0121. Telephone: (202) 586-7335. Email:
[email protected].
Mr. Eric Stas, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585.
Telephone: (202) 586-9507. Email: [email protected].
For further information on how to submit a comment, or review other
public comments and the docket,
[[Page 34428]]
contact the Appliance and Equipment Standards Program staff at (202)
586-6636 or by email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Discussion
A. Test Procedure for Computer Room Air Conditioners
1. Scope
a. Computer Room Cooling Application
b. Configurations
2. Energy Efficiency Descriptor
a. Integrated Efficiency Metrics
b. Part-Load Operation Due to Unit Oversizing
c. Operation Modes Other Than Standard Cooling Mode
3. Industry Test Standards
a. Standard Models and Application Classes in AHRI 1360-2016
b. ASHRAE 37 and Secondary Method
c. Minimum External Static Pressure
d. Setting Indoor Airflow
e. Refrigerant Charging Instruction
B. Test Procedure for Dedicated Outdoor Air Systems
1. Definition
a. Air Intake Source and Dehumidification Capability
b. Reheat
2. Energy Efficiency Descriptors
a. Dehumidification Metric
b. Heating Metric
3. Test Method
a. Airflow
b. Liquid Flow
c. Test Conditions
d. Tolerances
e. Capacity Measurement
f. Test Set-Up
C. Test Procedure for Air-Cooled, Water-Cooled, and
Evaporatively-Cooled Equipment
1. Energy Efficiency Descriptor
2. Addressing Changes to AHRI 340/360
a. Head Pressure Controls
b. Refrigerant Charging Requirements
c. Adjustment for Different Atmospheric Pressure Conditions
d. Measurement of Condenser Air Inlet Temperature (ACUAC and
ECUAC)
e. Tolerance of Tested Indoor Airflow Relative to Rated Indoor
Airflow (ECUAC and WCUAC)
f. Vertical Separation of Indoor and Outdoor Units
g. Outdoor Entering Air Wet-Bulb Temperature (ECUAC)
h. Single-Zone Variable-Air-Volume and Multi-Zone Variable-Air-
Volume
3. Additional Test Method Issues
a. Length of Refrigerant Line Exposed to Outdoor Conditions
b. Atmospheric Pressure Measurement
c. Consistency Among Test Procedures for Small and Large ECUAC
and WCUAC Equipment Classes
d. Make-Up Water Temperature (ECUAC)
e. Secondary Measurement Method for Capacity (ECUAC)
f. Piping Evaporator Condensate to Condenser Pump (ECUAC)
g. Purge Water Settings (ECUAC)
h. Condenser Spray Pumps (ECUAC)
i. Additional Steps To Verify Proper Operation (ECUAC)
D. Test Procedure for Variable Refrigerant Flow Multi-Split Air
Conditioners and Heat Pumps
1. Energy Efficiency Descriptors
2. Representativeness and Repeatability
3. Test Method
a. Transient Testing: Oil Recovery Mode
b. Airflow Setting and Minimum External Static Pressure
c. Condenser Head Pressure Controls
d. Air Volume Rate for Non-Ducted Indoor Units
e. Secondary Test Method
f. Heat Recovery
4. Representations
a. Tested Combination
b. Determination of Represented Values
E. Other Test Procedure Topics
III. Submission of Comments
I. Authority and Background
Title III, part C \1\ of the Energy Policy and Conservation Act of
1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6311-6317, as
codified), added by Public Law 95-619, title IV, section 441(a),
established the Energy Conservation Program for Certain Industrial
Equipment, which includes provisions covering the types of commercial
heating and air conditioning equipment that are the subject of this
notice.\2\ This covered equipment includes small, large, and very large
commercial package air conditioning and heating equipment, which
specifically includes variable refrigerant flow multi-split air
conditioners and heat pumps (VRF multi-split systems),\3\ computer room
air conditioners (CRACs), dedicated outdoor air systems (DOASes),
evaporatively-cooled commercial unitary air conditioners (ECUACs) less
than 760,000 Btu/h, water-cooled commercial unitary air conditioners
(WCUACs) less than 760,000 Btu/h, and air-cooled commercial unitary air
conditioners (ACUACs) greater than or equal to 65,000 Btu/h and less
than 760,000 Btu/h, all of which are addressed in this document. (42
U.S.C. 6311(1)(B)-(D))
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\1\ For editorial reasons, upon codification in the U.S. Code,
part C was redesignated part A-1.
\2\ All references to EPCA in this document refer to the statute
as amended through the Energy Efficiency Improvement Act of 2015,
Public Law 114-11 (April 30, 2015).
\3\ Not including single-phase VRF less than 65,000 Btu/h.
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Under EPCA, the energy conservation program consists essentially of
four parts: (1) Testing, (2) labeling, (3) Federal energy conservation
standards, and (4) certification and enforcement procedures. Relevant
provisions of the Act include definitions (42 U.S.C. 6311), energy
conservation standards (42 U.S.C. 6313), test procedures (42 U.S.C.
6314), labeling provisions (42 U.S.C. 6315), and the authority to
require information and reports from manufacturers (42 U.S.C. 6316).
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (See
42 U.S.C. 6316(a) and (b); 42 U.S.C. 6297) DOE may, however, grant
waivers of Federal preemption for particular State laws or regulations,
in accordance with the procedures and other provisions of EPCA. (42
U.S.C. 6316(b)(2)(D))
The Federal testing requirements consist of test procedures that
manufacturers of covered equipment must use as the basis for: (1)
Certifying to DOE that their equipment complies with the applicable
energy conservation standards adopted pursuant to EPCA (see 42 U.S.C.
6316(b); 42 U.S.C. 6296), and (2) making representations about the
efficiency of that equipment (42 U.S.C. 6314(d)). Similarly, DOE must
use these test procedures to determine whether the equipment complies
with relevant standards promulgated under EPCA.
Under 42 U.S.C. 6314, EPCA sets forth the general criteria and
procedures DOE is required to follow when prescribing or amending test
procedures for covered equipment. EPCA requires that any prescribed or
amended test procedures must be reasonably designed to produce test
results which reflect energy efficiency, energy use or estimated annual
operating cost of a covered equipment during a representative average
use cycle or period of use and requires that the test procedure not be
unduly burdensome to conduct. (42 U.S.C. 6314(a)(2))
EPCA requires that the test procedures for commercial package air
conditioning and heating equipment be those generally accepted industry
testing procedures or rating procedures developed or recognized by the
Air-Conditioning, Heating, and Refrigeration Institute (AHRI) or by the
American Society of Heating, Refrigerating and Air-Conditioning
Engineers (ASHRAE), as referenced in ASHRAE Standard 90.1, ``Energy
Standard for Buildings Except Low-Rise Residential Buildings'' (ASHRAE
Standard 90.1), and that if such an industry test procedure is amended,
DOE must update its test procedure to be consistent with the amended
industry test procedure, unless DOE determines, by rule published in
the Federal Register and
[[Page 34429]]
supported by clear and convincing evidence, that the amended test
procedure would not meet the requirements in 42 U.S.C. 6314(a)(2) and
(3) related to representative use and test burden. (42 U.S.C.
6314(a)(4))
ASHRAE Standard 90.1 was updated on October 26, 2016,\4\ and this
update made changes to the test procedure references in ASHRAE Standard
90.1-2013 for CRACs, as well as ACUACs, ECUACs, and WCUACs with cooling
capacity >=65,000 Btu/h and <760,000 Btu/h.\5\ Additionally, ASHRAE
Standard 90.1-2016 added efficiency levels and a test procedure for
DOAS. These changes on the part of ASHRAE trigger DOE's obligation to
review these test procedures pursuant to the requirements of EPCA.
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\4\ There is no publication date printed on ASHRAE Standard
90.1-2016, but ASHRAE issued a press release on October 26, 2016,
which can be found at https://www.ashrae.org/news/2016/ashrae-ies-publish-2016-energy-efficiency-standard.
\5\ For water-source heat pumps, ASHRAE Standard 90.1-2016
included reference to a reaffirmation of the existing test
procedure, and as such, does not constitute a change requiring DOE
action.
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EPCA also requires that DOE conduct an evaluation of test
procedures at least once every seven years for each class of covered
equipment to determine if an amended test procedure would more
accurately or fully comply with the requirements in 42 U.S.C.
6314(a)(2) and (3). (42 U.S.C. 6314(a)(1)(A)) After this evaluation,
DOE must either prescribe amended test procedures or publish a notice
in the Federal Register regarding its determination not to amend test
procedures. (42 U.S.C. 6314(a)(1)(A)(i) and (ii)) In either case, if
DOE determines that a test procedure amendment is warranted, it must
publish proposed test procedures and offer the public an opportunity to
present oral and written comments on them. (42 U.S.C. 6314(b)) To amend
a test procedure, DOE must determine the extent to which the proposed
test procedure would alter the equipment's measured energy efficiency.
If DOE determines that the amended test procedure would alter the
measured efficiency of the covered equipment, DOE must amend the
applicable energy conservation standard accordingly. (42 U.S.C.
6314(a)(4)(C); 42 U.S.C. 6293(e))
Although ASHRAE Standard 90.1-2016 did not include revisions to the
test procedures for VRF equipment or ECUACs and WCUACs with cooling
capacity <65,000 Btu/h, DOE is including such equipment in this RFI
under DOE's 7-year lookback authority. The test procedures under review
in this RFI are shown in Table I.1.
Table I.1--Commercial Air Conditioning and Heating Equipment Included in the RFI
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Review test procedure
due to amendments to Last test procedure 7-Year review due (final
Equipment included in RFI industry test or (final rule) rule)
rating procedure?
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CRAC................................ Yes.................... 77 FR 28928 (May 16, May 16, 2019.
2012).
DOAS................................ Yes.................... N/A................... N/A.
ECUAC............................... Yes (>=65,000 Btu/h 77 FR 28928 (May 16, May 16, 2019.
only*). 2012).
WCUAC............................... Yes (>=65,000 Btu/h 77 FR 28928 (May 16, May 16, 2019.
only*). 2012).
ACUAC >= 65,000 Btu/h**............. Yes.................... 80 FR 79655 (Dec. 23, Dec. 23, 2022.
2015).
VRF (except single-phase <65,000 Btu/ No..................... 77 FR 28928 (May 16, May 16, 2019.
h***). 2012).
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* DOE is considering ECUAC and WCUAC with cooling capacity less than 65,000 Btu/h in this rulemaking notice
under its 7-year lookback authority.
** DOE will be considering ACUAC with cooling capacity less than 65,000 Btu/h under its 7-year lookback
authority in a separate test procedure rulemaking.
*** Single-phase VRF with rated cooling capacity less than 65,000 Btu/h are covered under DOE's consumer product
regulations for central air conditioners.
Upon completion of this proceeding, DOE expects to satisfy for all
the equipment categories listed in Table I.1, both the requirements of
EPCA pertaining to DOE action prompted by amendments to industry test
or rating procedures, as well as EPCA's 7-year review requirements. In
support of its test procedures, DOE conducts in-depth technical
analyses of publicly-available test standards and other relevant
information. DOE continually seeks data and public input to improve its
testing methodologies to more accurately reflect customer use and to
produce repeatable results. In general, DOE is requesting comment and
supporting data regarding representative and repeatable methods for
measuring the energy use of the equipment that is the subject of this
RFI. As such, DOE is interested in feedback on any aspect of the test
procedures for the identified equipment, but it is especially
interested in receiving comment and information on the specific topics
discussed below.
II. Discussion
This RFI discusses each category of equipment under consideration
in separate sections set forth below. DOE seeks input to aid in the
development of the technical and economic analyses regarding whether
amended test procedures for each category of equipment may be
warranted. Specifically, DOE is requesting comment on any opportunities
to streamline and simplify testing requirements for each category of
equipment discussed in this notice.
Additionally, DOE welcomes comments on other issues relevant to the
conduct of this rulemaking that may not specifically be identified in
this document. In particular, DOE notes that under Executive Order
13771, ``Reducing Regulation and Controlling Regulatory Costs,''
Executive Branch agencies such as DOE are directed to manage the costs
associated with the imposition of expenditures required to comply with
Federal regulations. See 82 FR 9339 (Feb. 3, 2017). Pursuant to that
Executive Order, DOE encourages the public to provide input on measures
DOE could take to lower the cost of its regulations applicable to the
commercial equipment addressed in this notice consistent with the
requirements of EPCA.
Within each section, DOE raises relevant issues regarding scope,
efficiency metric, and test method, with a focus on changes identified
by review of the updated test procedures in ASHRAE Standard 90.1-2016.
As required by statute, DOE is considering amendments to the current
test procedures (and in the case of DOAS, adoption of a new test
procedure) to be consistent with those specified in
[[Page 34430]]
ASHRAE 90.1-2016, where possible. Further, DOE requests comment on the
benefits and burdens of adopting the industry test procedures
referenced in ASHRAE 90.1-2016, without modification.
A. Test Procedure for Computer Room Air Conditioners
DOE's test procedure for CRACs, set forth at 10 CFR 431.96,
currently incorporates by reference ASHRAE 127-2007, ``Method of
Testing for Rating Computer and Data Processing Room Unitary Air
Conditioners'', (omit section 5.11), with additional provisions
indicated in 10 CFR 431.96(c) and (e). The energy efficiency metric is
sensible coefficient of performance (SCOP) for all CRAC equipment
categories. ASHRAE 90.1-2016 updated its test procedure reference for
CRACs from ASHRAE 127-2007 to AHRI 1360-2016, ``Performance Rating of
Computer and Data Processing Room Air Conditioners'', which in turn
references ASHRAE 127-2012. This update on the part of ASHRAE triggered
DOE to review its test procedure for CRACs. In addition, DOE is aware
that the ASHRAE 127 committee is working on an updated version of that
standard, and DOE may consider the updated version when it is
available.
In order to ensure that potential adoption of AHRI 1360-2016 as the
DOE test procedure for CRACs would satisfy statutory requirements, the
following sections consider issues related to the reduced scope of AHRI
1360-2016 relative to ASHRAE 127-2007, as well as updates in the
industry test standards to the test method and rating conditions. DOE
also explores other CRAC-related issues including definitions and the
efficiency metric.
1. Scope
a. Computer Room Cooling Application
The definition for ``computer room air conditioner'' in DOE's
regulations does not include physical design differences, component
characteristics, or performance features that distinguish CRACs from
other commercial package air conditioning and heating equipment (e.g.,
CUACs) used for comfort cooling.\6\ In March 2012, DOE published a
supplemental notice of proposed rulemaking (SNOPR) refining its
proposed definition of ``computer room air conditioner.'' 77 FR 16769,
16772-16773 (March 22, 2012). In response to this SNOPR, several
stakeholders commented about differences in performance features
between CRACs and CUACs. Carrier commented that CRACs are designed to
handle different load characteristics, most notably by focusing on
sensible load and not latent cooling. (EERE-2011-BT-STD-0029, Carrier,
No. 28 at p. 1) Panasonic commented that CRACs have a different
operating range and that they operate with tighter tolerances on
temperature and relative humidity than do CUACs. (EERE-2011-BT-STD-
0029, Panasonic, No. 20 at pp. 68-69) Despite these comments, DOE was
unable to determine any specific requirements on sensible load that
would consistently differentiate CRACs from CUACs and allow it to
incorporate performance characteristics into the CRAC definition.
Therefore, on May 16, 2012, DOE adopted the current definition for
``computer room air conditioner'' that distinguishes them from CUACs
based on application differences. 77 FR 28928, 28947-28948 (May 16,
2012; ``May 2012 final rule'').
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\6\ DOE defines ``computer room air conditioner'' as a basic
model of commercial package air-conditioning and heating equipment
(packaged or split) that is: used in computer rooms, data processing
rooms, or other information technology cooling applications; rated
for sensible coefficient of performance (SCOP) and tested in
accordance with 10 CFR 431.96, and is not a covered consumer product
under 42 U.S.C. 6291(1)-(2) and 6292. A computer room air
conditioner may be provided with, or have as available options, an
integrated humidifier, temperature, and/or humidity control of the
supplied air, and reheating function. 10 CFR 431.92.
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A review of 1000 CRAC models in DOE's Compliance Certification
Management System (CCMS) shows that all of these models have a sensible
heat ratio (SHR) above 80 percent. In contrast, commercial air
conditioners used for comfort cooling generally have SHRs between 65
percent and 80 percent. DOE notes that the indoor air test condition
for CUACs has a higher relative humidity than the test condition for
CRACs. Therefore, the SHR for any air conditioner will be higher when
tested using the CRAC test condition than when using the CUAC test
conditions. However, DOE is considering whether a specific SHR (e.g.,
80 percent at the test condition of CRACs) would be sufficient to
differentiate CRACs from other CUACs.
Issue CRAC-1: DOE requests comment on the extent to which models of
commercial package air conditioners are marketed and/or installed for
use in both comfort cooling and computer room cooling applications. DOE
also seeks comment on whether there are models rated for energy
efficiency ratio (EER) or seasonal energy efficiency ratio (SEER) and
not SCOP that are used for computer room cooling--if so, DOE requests
comment and data on the extent of the use of such equipment for
computer room cooling.
Issue CRAC-2: DOE seeks comment and data on whether a specific
sensible heat ratio could be selected that would effectively and
consistently distinguish CRACs from other classes of commercial package
air conditioners. DOE also seeks comment on any other design
differences or performance features that would help resolve this issue.
b. Configurations
The following sections discuss configurations of CRACs that DOE has
identified on the market and for which DOE is considering potential
modifications to its current test procedure.
i. Airflow Direction and Mounting Location
DOE's minimum efficiency standards for CRACs in 10 CFR 431.97 apply
to down-flow and up-flow units, which is terminology typically applied
to floor-mounted units. However, DOE's test procedure for CRACs in 10
CFR 431.96 is not limited to floor-mounted units. On January 15, 2015,
DOE published a final guidance document (``January 2015 Guidance
Document'') to clarify the coverage of horizontal free-discharge CRACs
under DOE's regulations for CRACs set forth in 10 CFR part 431.\7\ In
the January 2015 Guidance Document, DOE clarified that while horizontal
free-discharge CRACs are not subject to the energy conservation
standards for CRACs, the 2012 test procedure final rule did not have an
exception for any specific airflow direction (i.e., down-flow, up-flow
or horizontal-flow) or mounting type (i.e., floor-mount, ceiling-
mount).\8\ Therefore, any manufacturer making representations of the
energy consumption of CRACs (including ceiling-mounted ducted or free-
discharge units or horizontal free-discharge units and all other
equipment that meets the CRAC definition) must base these
representations on tests conducted according to the current DOE test
procedure. A manufacturer may request a test procedure waiver for a
[[Page 34431]]
basic model if it contains design features that prevent testing
according to the DOE test procedure, or such testing may generate
results that are unrepresentative of the true energy consumption of the
basic model. 10 CFR 431.401. To date, DOE has not received any such
waiver requests.
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\7\ The January 2015 Guidance document can be found as Document
Number 2 in Docket Number EERE-2014-BT-GUID-0022.
\8\ On October 7, 2015, DOE published a draft guidance document
(``October 2015 Guidance Document'') seeking comment concerning the
coverage of ceiling-mount ducted and free-discharge CRACs. (The
October 2015 Guidance document can be found as Document Number 3 in
Docket Number EERE-2014-BT-GUID-0022.) DOE has not yet finalized
this guidance with respect to ceiling-mounted ducted and free-
discharge CRACs. The draft guidance also took the position that such
CRACs were not subject to standards, but the test procedure did not
have an exception for any specific airflow direction.
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DOE notes that the scope of AHRI Standard 1360-2016 (AHRI 1360-
2016), ``2016 Standard for Performance Rating of Computer and Data
Processing Room Air Conditioners'', the test procedure referenced in
ASHRAE 90.1-2016, excludes ceiling-mounted units, only covering floor-
mounted units. As stated in the October 2015 Guidance Document, ASHRAE
127-2007 can be used to test ceiling-mounted units. DOE understands
that the ASHRAE 127 committee is considering additional provisions that
would apply specifically to ceiling-mounted equipment, but a revised
ASHRAE 127 standard is not yet available. For those CRACs not addressed
by AHRI 1360-2016, DOE may consider continuing to reference ASHRAE 127-
2007 or updating to a revised version of ASHRAE 127 when published, if
appropriate.
Issue CRAC-3: DOE requests comment on the appropriate test
procedure for ceiling-mounted CRACs, considering that AHRI 1360-2016
does not address them, and the test burden associated with any such
procedure.
ii. Three-Phase Portable Units
Several manufacturers market portable units for commercial use in
data centers and computer rooms. On June 1, 2016, under its authority
for regulating consumer products, DOE published a final rule that
established a test procedure for portable air conditioners. 81 FR
35242. In addition, DOE issued a final rule to establish energy
conservation standards for portable air conditioners. In a final
determination published on April 18, 2016, DOE established a definition
for ``portable air conditioner'' that excludes units that use three-
phase power as a means of differentiating the portable air conditioners
that are consumer products (and thus determined to be covered products)
from those that could normally not be used in residential applications.
81 FR 22514, 22519-22520. DOE identified several models of portable
units that are marketed for commercial computer room cooling
applications and use three-phase power instead of single-phase power.
This equipment does not meet DOE's definition for ``portable air
conditioner'' and is not subject to DOE's current test procedures or
standards for portable air conditioners. DOE considers any portable
unit marketed for computer room cooling that is rated with SCOP and is
not a covered consumer product under 42 U.S.C. 6291(1)-(2) and 6292 to
meet its definition of ``computer room air conditioner.'' DOE is
considering amendments to its test procedure for computer room air
conditioners to better reflect usage in the field of portable units
used for computer room cooling that are not covered consumer products,
as applicable.
Issue CRAC-4: DOE requests comments on whether any specific
provisions should be considered to address how to test portable units
used in computer room cooling applications, such as whether they are
typically ducted and, if so, what a representative minimum external
static pressure (ESP) and return air temperature would be.
iii. Single Package Non-Floor-Mounted Air Conditioners
DOE identified several manufacturers that produce single package
non-floor-mounted air conditioners (other than portable units) that are
marketed specifically for cooling computer rooms, telecommunication
rooms, and data centers. DOE identified such air conditioners designed
for both interior and exterior installation. Of the exterior-mount
units DOE identified, some meet DOE's definition for ``single package
vertical air conditioner'' (one type of single-package vertical unit
(SPVU)), while others are rooftop units. All of these identified models
appear to meet DOE's definition for computer room air conditioners.
Therefore, DOE is considering whether amendments are needed in its test
procedure for CRACs to better reflect the in-field energy use and
installation practices of single-package non-floor-mounted air
conditioners used for computer room cooling.
Issue CRAC-5: DOE seeks information on the extent to which single-
package non-floor-mounted air conditioners are used in computer room
applications.
Issue CRAC-6: DOE seeks comment on whether special test procedure
provisions should be developed for different kinds of single package
non-floor-mounted air conditioners that are used for computer room
cooling, including: (1) Whether such units are typically installed with
supply/return air ducting; and (2) whether the test set-up described in
ANSI/ASHRAE 37-2009, ``Methods of Testing for Rating Electrically
Driven Unitary Air-Conditioning and Heat Pump Equipment,'' (ASHRAE 37-
2009) is appropriate and if any additional test set-up provisions would
be needed.
Issue CRAC-7: DOE requests comment on whether there are other
configurations of commercial package air conditioners that are marketed
for computer room cooling applications and that meet DOE's definition
for CRAC, beyond floor-mounted units (i.e., up-flow, down-flow, and
horizontal discharge), ceiling-mounted units, portable units, indoor
single package units, rooftop units, and certain SPVUs.
2. Energy Efficiency Descriptor
When ASHRAE 90.1-2016 amended its energy efficiency levels, it also
updated its test procedure from ASHRAE 127-2007 to AHRI 1360-2016. AHRI
1360-2016 defines standard rating configurations and conditions and
provides additional requirements for testing CRACs, but does not
include a method of test. Instead, AHRI 1360-2016 references ASHRAE
127-2012 as the method of test. This test procedure change also updated
the ASHRAE 90.1 efficiency metric for CRACs from SCOP to net sensible
coefficient of performance (NSenCOP). DOE's current efficiency metric
for CRACs is SCOP. As compared with SCOP, the new metric NSenCOP
specifies different operating conditions for water-cooled and glycol-
cooled models and adjusts the efficiency to account for the energy use
associated with the water or glycol pump. These changes presumably
result in a more accurate representation of the energy use associated
with the equipment. Because ASHRAE 90.1 changed the metric to NSenCOP,
EPCA requires that DOE must consider updating to NSenCOP as well. For
completeness, DOE reviews other issues related to efficiency metrics
for CRACs in this section, including: (1) Integrated efficiency
metrics; (2) part-load operation due to unit oversizing; and (3)
operation modes other than standard cooling mode. If DOE ultimately
decides to change its metric from SCOP to NSenCOP, DOE would need to
develop a crosswalk analysis to translate DOE's existing standards--
which are in terms of SCOP--to the NSenCOP metric.
a. Integrated Efficiency Metrics
ASHRAE 127-2007 includes the integrated efficiency metric, adjusted
sensible coefficient of performance (ASCOP), which is calculated based
on the SCOPs at four different rating conditions (A, B, C, and D),
representing different ambient conditions, with weightings for the SCOP
at each rating condition based on the climate at a specific location.
ASHRAE 127-2012 and AHRI 1360-2016 include an updated integrated
efficiency metric, integrated net sensible coefficient of
[[Page 34432]]
performance iNSenCOP, instead of ASCOP. There are differences between
ASCOP and iNSenCOP, similar to those between SCOP and NSenCOP, but both
are weighted averages of sensible-capacity-based efficiencies measured
for operation at different ambient conditions.
The ASCOP and iNSenCOP test methods in ASHRAE 127-2007, ASHRAE 127-
2012, and AHRI 1360-2016 require units to maintain a constant sensible
cooling capacity at lower ambient temperatures. However, it is not
clear how the lower-ambient tests are to be conducted. As the ambient
temperature decreases, the maximum cooling capacity of a CRAC will
inherently increase. ASHRAE 127-2012 does not provide guidance
regarding how the unit should be controlled in order to deliver the
same amount of sensible cooling as its capacity increases for the
lower-ambient tests.
Issue CRAC-8: DOE requests comment on whether DOE should consider
adopting an integrated efficiency metric (e.g., iNSenCOP). Also if so,
DOE requests comment on how the requirement to maintain a constant
sensible cooling capacity associated with the iNSenCOP test procedure
should be implemented during testing.
b. Part-Load Operation Due to Unit Oversizing
CRACs typically operate at part-load (i.e., less than designed full
cooling capacity) in the field. Reasons for this may include, but are
not limited to, redundancy in installed units to prevent server
shutdown if a CRAC unit stops working, and server room designers
building in extra cooling capacity to accommodate additional server
racks in the future. At part-load, single-speed systems cycle on and
off to match the cooling requirement, while variable speed systems
might operate at a different speed, but both control strategies change
performance as compared to full-load operation. While the DOE test
procedure measures performance at full-load, DOE estimated in its May
2012 final rule analysis that CRAC units operate on average at a
sensible load of 65 percent of the full-load sensible capacity. (EERE-
2011-BT-STD-0029-0021, pp. 4-15, 4-16). This may indicate a difference
between DOE test procedure operating requirements and typical field
operation. Therefore, DOE is considering whether this practice of
oversizing should be factored into a CRAC efficiency metric to the
extent that it would better represent an average use cycle.
Issue CRAC-9: DOE requests information on the range of typical
field load levels for CRACs at conditions close to or at the maximum
ambient outdoor air temperature conditions specified in the DOE test
procedure for various unit capacities. DOE seeks input on typical rules
of thumb for oversizing and whether the issues of oversizing of this
equipment should be addressed in the efficiency metric.
c. Operation Modes Other Than Standard Cooling Mode
Many CRACs operate in air circulation mode. DOE understands that
redundant units are usually installed in the computer room, and some of
the redundant units can be controlled to operate in air circulation
mode for better air movement. In this mode, the direct expansion
refrigerant system is shut down, and only evaporator blowers and
controls are on. DOE is considering whether the energy consumption of
air circulation mode should be considered in the CRAC energy efficiency
metric.
Issue CRAC-10: DOE seeks comment on the conditions under which
CRACs will operate in air circulation mode (i.e., operating the indoor
fan without actively cooling) in the field, whether each CRAC switches
automatically between standard cooling mode and air circulation mode,
and if so, the time percentage that CRACs operate in such circulation
mode. DOE also seeks comment on what fan setting(s) is used for air
circulation mode and whether DOE should consider this energy use in the
CRAC efficiency metric.
3. Industry Test Standards
In its test procedure for CRACs, DOE currently incorporates by
reference ASHRAE 127-2007 (omitting section 5.11). 10 CFR 431.96. As
mentioned previously, ASHRAE published an updated version of this test
standard in 2012, ASHRAE 127-2012. ASHRAE 127-2012 includes several
modifications from ASHRAE 127-2007, which are discussed in the
following sections. DOE is aware that ASHRAE is working to update
ASHRAE 127-2012, and DOE may consider the newer version of the test
standard if it is published during the course of this rulemaking. As
discussed previously, DOE is also aware that the referenced industry
test procedure in ASHRAE Standard 90.1-2016 has changed to AHRI 1360-
2016. The scope of AHRI 1360-2016 covers only floor-mounted computer
and data processing room air conditioners, including up-flow, down-
flow, and horizontal-flow units. AHRI 1360-2016 defines standard
configurations and provides rating conditions and additional
requirements for testing CRACs, but does not include a method of test.
Instead, AHRI 1360-2016 references ASHRAE 127-2012 to conduct the test.
Consequently, DOE will consider adopting both industry test standards.
In the following sections, DOE discusses specific test procedure-
related issues and questions regarding ASHRAE 127-2012 and AHRI 1360-
2016.
a. Standard Models and Application Classes in AHRI 1360-2016
Indoor floor-mounted CRACs can be installed in different
configurations, which vary by direction of airflow and connections
(e.g., raised floor plenum, ducted, free air). Instead of specifying
test conditions for all possible combinations, AHRI 1360-2016 includes
the concept of ``standard models'' that characterize common
configurations and specify standard rating conditions (e.g., external
static pressure, return air temperature) for each style of indoor
floor-mounted CRAC. Table C.1 of Appendix C of AHRI 1360-2016 defines
four different standard models: (1) Down-flow (with raised floor plenum
discharge and free air return); (2) horizontal-flow (with free air
discharge and free air return); (3) up-flow ducted (with ducted
discharge and free air return); and (4) up-flow non-ducted (with free
air discharge and free air return). AHRI 1360-2016 also specifies which
of the four standard model test set-ups and standard rating conditions
apply for down-flow, horizontal-flow, and up-flow CRACs. For example,
down-flow units are tested with a raised floor plenum discharge and a
free air return.
DOE notes that for up-flow CRACs, AHRI 1360-2016 includes two
standard models with associated standard rating conditions, one for
ducted discharge connections and one for free air discharge. However,
connection variations are characteristics of installations. A given up-
flow unit could be installed either with or without a duct. DOE's
research has not revealed that up-flow CRACs have physical
characteristics that clearly distinguish them as ducted or non-ducted
models. Hence, it is not clear which of the AHRI 1360-2016 up-flow
standard model requirements would be used for testing.
Issue CRAC-11: DOE requests comment on what equipment
characteristics can be used to determine whether up-flow CRACs should
be tested as ducted or non-ducted models. DOE also requests comments on
whether up-flow units can be sold for both up-flow ducted and up-flow
non-ducted applications and whether such
[[Page 34433]]
models are currently tested using both ducted and non-ducted standard
rating conditions.
DOE also notes that, in addition to the four standard models of
floor-mounted CRACs, Table C.1 of AHRI 1360-2016 also includes many
additional combinations of connections, referred to as application
configurations, but does not provide standard rating conditions for
these configurations.
Issue CRAC-12: DOE requests confirmation that, although floor-
mounted CRACs may be sold to be installed in multiple configurations,
all models are capable of being tested as one of the four standard
models identified in Table C.1 of AHRI 1360-2016.
AHRI 1360-2016 does not include standard models or standard rating
conditions for ceiling-mount or non-floor mount CRACs. The current DOE
test procedure, which incorporates by reference ASHRAE 127-2007,
specifies different test operating conditions (e.g., different external
static pressure) than AHRI 1360-2016.
Issue CRAC-13: DOE requests comment on whether the test
requirements of ASHRAE 127-2007 are representative of average use
cycles for ceiling-mount and other non-floor-mounted CRACs. If not, DOE
requests comment on which, if any, of the test requirements of AHRI
1360-2016 would more appropriately represent average use cycles for
such CRACs.
b. ASHRAE 37 and Secondary Method
ASHRAE 127-2007 references ANSI/ASHRAE 37-2005, ``Methods of
Testing for Rating Unitary Air-Conditioning and Heat Pump Equipment''
(ASHRAE 37-2005), while 127-2012 and AHRI 1360-2016 reference the
updated version, ASHRAE 37-2009. ASHRAE 37-2005 and the updated ASHRAE
37-2009 describe test methods for measuring cooling capacity, heating
capacity, and electrical energy use of air conditioners and heat pumps.
However, it is not clear whether the industry test standards for CRACs
reference specific provisions or all of the provisions of ASHRAE 37-
2005 or ASHRAE 37-2009.\9\ No alternate methods for determining cooling
capacity are included in ASHRAE 127 or AHRI 1360. Therefore, DOE
expects that manufacturers do use the test methods of ASHRAE 37-2005 or
ASHRAE 37-2009 to determine cooling capacity, sensible cooling
capacity, and electric energy use of CRACs. DOE is considering updating
the DOE test procedure to clarify that the test method is based on
ASHRAE 37-2009, except as modified or adjusted by ASHRAE 127-2012 or
AHRI 1360-2016.
---------------------------------------------------------------------------
\9\ For example, in ASHRAE 127-2007, the reference to ASHRAE 37-
2005 is located under a subsection 5.1.4.5.2 titled, ``Raised Floor
Plenum Systems'' which is located under section 5.1.4.5 titled
``External Resistance, Ducted Connected, Floor Plenum and Free Air
Discharge.''
---------------------------------------------------------------------------
Issue CRAC-14: DOE seeks comment on whether the test method of
ASHRAE 37-2009 is appropriate for measuring capacity, sensible
capacity, and electric energy use for all configurations of CRACs
(including configurations for which DOE does not currently prescribe
energy conservation standards).
Table 2b in section 8 of ASHRAE 37-2009 includes test operating
tolerances (maximum allowable observed range) and condition tolerances
(maximum variation of the average from a specified test condition) for
several parameters, including air and fluid temperatures, in order to
reduce the uncertainty of the measurement of cooling capacity, heating
capacity, and/or energy use of air conditioners or heat pumps. However,
this section of ASHRAE 37-2009 is not explicitly referenced by the CRAC
industry test standards. Section 5.1 of ASHRAE 127-2007 and section
5.2.1 of ASHRAE 127-2012 only include an operation tolerance for the
room temperature, and no versions of ASHRAE 127 or AHRI 1360 include
any other tolerances. DOE considers the tolerances of Table 2b of
ASHRAE 37-2009 to be relevant for CRACs and important to reduce
variability of key CRAC performance measurements.
Issue CRAC-15: DOE requests comment on whether any operating or
condition tolerances included in Table 2b in section 8 of ASHRAE 37-
2009 are not appropriate for CRACs. If any are not appropriate, DOE
requests an explanation as to why and suggestions on how the tolerances
should be changed.
Section 7.2.1 of ASHRAE 37-2009 requires that when testing
equipment with a total cooling capacity less than 135,000 Btu/h,
simultaneous capacity tests using the indoor air enthalpy method and
one other applicable method must be conducted. Specifically, these
other test methods include the outdoor air enthalpy method, the
compressor calibration method, the refrigerant enthalpy method, and the
outdoor liquid coil method. Table 1 in section 7 of ASHRAE 37-2009
specifies which of these test methods are applicable for each equipment
configuration and method of heat rejection in cooling mode. Section
10.1.2 of ASHRAE 37-2009 requires that the total cooling capacity
calculated from the two simultaneously conducted methods agree within
6.0 percent.
For CRACs with cooling capacity less than 135,000 Btu/h, DOE is
considering whether its test procedure should require a secondary test
method and how agreement between the primary and secondary methods
should be evaluated. DOE is also considering whether the primary and
secondary tests should be based on total cooling capacity or sensible
cooling capacity. Basing these tests on sensible cooling capacity may
be more appropriate because it is the basis of the CRAC efficiency
metric in both ASHRAE Standard 90.1 and the current Federal standard.
Issue CRAC-16: DOE seeks comment on whether a secondary test is
appropriate for testing CRACs, for what range of cooling capacity such
a requirement should apply for CRACs, how the requirement should be
applied (given that most secondary test methods measure total rather
than sensible capacity), and what level of agreement (in percent)
should be required. DOE is also interested in detailed information on
whether there would be a significant additional test burden resulting
from a secondary test--and if so, the nature and extent of that burden.
Many CRACs have compressors housed in their indoor units. ASHRAE
37-2009 specifies modification of the indoor enthalpy method as
depicted in its Figure 3, Calorimeter air enthalpy test method
arrangement, for capturing the impact of compressor heat on the
capacity measurement. However, none of the industry test standards
explicitly call for using this test set-up for CRAC indoor units to
take into consideration the cooling capacity reduction associated with
compressor heat.
Issue CRAC-17: DOE requests comment on whether it is appropriate to
incorporate the impact of compressor heat in sensible capacity
measurements for CRACs with compressors housed in their indoor units.
DOE requests that the comments provide an explanation as to why it is
or is not appropriate, and whether the answer depends on the specific
CRAC configuration.
c. Minimum External Static Pressure
ASHRAE 127-2007, ASHRAE 127-2012, and AHRI 1360-2016 all contain
different minimum external static pressure (ESP) levels and categories,
as indicated in Table II.1. In ASHRAE 127-2012, the minimum ESP levels
are the same as for ASHRAE 127-2007, but ASHRAE 127-2012 defines
``ducted systems'' as ``air conditioners intended to be connected to
supply and/or return ductwork'' instead of ``to supply and return
ductwork,'' as specified in ASHRAE 127-2007.
[[Page 34434]]
Table II.1--External Static Pressure Requirements
------------------------------------------------------------------------
Minimum ESP
Test standard CRAC Category (in. w.c.)
------------------------------------------------------------------------
ASHRAE 127-2007 and ASHRAE 127- Ducted: ..............
2012. Net Sensible Capacity < 0.8
20 kW. 1.0
Net Sensible Capacity
>= 20 kW.
Free Discharge......... 0.0
AHRI 1360-2016................. Up-flow Ducted:
Net Sensible Capacity 0.3
<65 kBtu/h.
Net Sensible Capacity 0.4
>=65 kBtu/h and <240
kBtu/h.
Net Sensible Capacity 0.5
>=240 kBtu/h and <769
kBtu/h.
Horizontal and Up-flow 0.0
Non-ducted.
Down-flow.............. 0.2
------------------------------------------------------------------------
DOE is considering the test procedures and the ESP levels of AHRI
1360-2016, but seeks input on the significant difference in the ESP
values of the different test standards. Additionally, AHRI 1360-2016
does not include minimum ESP requirements for ceiling-mounted units.
AHRI-1360-2016 also made very significant changes to the ESPs for up-
flow ducted and down-flow configurations compared to ASHRAE 127-2012.
DOE received no data or information from ASHRAE indicating the
rationale for the changes or why lower static pressures are more
representative of field performance. Thus, DOE is particularly
interested in any information regarding the static pressures that are
likely representative of all CRACs.
Issue CRAC-18: DOE requests comment on whether the ESP levels
required by AHRI 1360-2016 are representative of field operation for
floor-mounted CRACs.
Issue CRAC-19: DOE requests information on whether the ESP levels
required by ASHRAE 127-2012 are representative of field operation for
ceiling-mounted CRACs and for other non-floor-mounted CRAC
configurations, and if not, what a representative minimum ESP would be.
DOE's review of CRAC installation manuals suggests that some up-
flow units are installed with a plenum box that redirects the airflow
from the upwards direction to the front or rear.
Issue CRAC-20: DOE requests comment on the percentage of up-flow
CRAC installations in which a plenum box that redirects air from the
upward direction to the front or rear would be attached, and whether
non-ducted units are tested with or without this plenum.
DOE identified several models of air-cooled CRACs that have an
indoor condenser and, therefore, may require ducting of condenser air.
Neither AHRI 1360-2016 nor ASHRAE 127-2013 address the possibility of
condenser ducting, and accordingly, would call for testing such CRACs
like others in free-inlet and free-discharge mode. However, this might
not be representative of field operation. The condenser fan for a CRAC
with a ducted condenser has to overcome the additional pressure drop of
the ducts; thus, imposing a minimum ESP requirement for testing may
better reflect field operating conditions than testing the unit with
free air inlet and discharge. However, this could require attaching an
apparatus to allow adjustment of ESP, which would add to test burden.
Alternatively, if a well-defined air duct set-up for indoor condensers
could be developed (e.g., specific length and cross-sectional
dimensions for the inlet and/or outlet air duct), a standardized
airflow resistance could be imposed without requiring a similar
connection and adjustment of the airflow and measurement apparatus as
used for measurement of indoor airflow, which could significantly
reduce test burden.
Issue CRAC-21: DOE seeks comment on how to set up the condenser air
flow when testing CRACs manufactured with condenser air inlet and
outlet connections and high-static condenser fans, which indicate that
such units can be installed indoors with the condenser air ducted to
and from the outdoors. Additionally, DOE requests comment on whether
some CRACs can be installed with or without condenser ducting, and if
so, how often these units are typically installed with condenser
ducting. DOE also seeks comment on whether certain CRAC configurations
are more likely to be installed with condenser ducting.
d. Setting Indoor Airflow
DOE currently requires manufacturers to certify the indoor airflow
for CRACs. However, DOE's test procedure and industry test standards do
not impose tolerances on achieving the certified airflow and/or the
minimum ESP during testing. The performance of any air conditioner can
be significantly affected by operation with indoor airflow that is very
different from the intended airflow.
For ACUACs with capacity >=65,000 Btu/h, DOE established a
requirement that the full-load indoor airflow rate must be within
3 percent of the certified airflow. 80 FR 79655, 79671
(Dec. 23, 2015; ``December 2015 CUAC TP final rule''). Tolerance for
ESP in this test is -0.00/+0.05 in. w.c. In contrast, for consumer
central air conditioners and heat pumps (CAC/HPs), the method for
setting indoor air volume rate for ducted units without variable-speed
constant-air-volume-rate indoor fans is a multi-step process that
addresses the discrete-step fan speed control of these units. In this
method, (a) the air volume rate during testing may not be higher than
the certified air volume rate, but may be 10 percent less, and (b) the
ESP during testing may not be lower than the minimum specified ESP, but
may be higher than the minimum if this is required to avoid having the
air volume rate overshoot its certified value. 81 FR 36992, 37026 (June
8, 2016; ``June 2016 CAC TP final rule'').
Issue CRAC-22: DOE seeks information on how certified airflow is
achieved in laboratory testing of CRACs, both with indoor blowers that
are continuously variable and for indoor blowers that are adjustable in
discrete steps. DOE also seeks comments on whether the tolerances for
setting airflow of commercial CUACs or of CAC/HPs are appropriate for
CRACs, and what tolerances would be appropriate for airflow and ESP.
e. Refrigerant Charging Instruction
Neither the ASHRAE nor the AHRI testing standards for CRACs include
specific instructions for refrigerant charging. The June 2016 CAC TP
final rule provides a comprehensive approach for charging intended to
improve test reproducibility. The approach indicates which set of
installation instructions to use for charging, explains what to do if
there are no instructions, indicates that target values of parameters
are the centers of the ranges allowed by installation
[[Page 34435]]
instructions, and specifies tolerances for the measured values. 81 FR
36992, 37030-37031. An approach that details methods such as these
could improve the CRAC test method.
Issue CRAC-23: DOE requests comments on what refrigerant charging
requirements should be considered to establish reproducible test
results for CRACs, and whether the approach developed for CAC/HP
products may be appropriate. Also, DOE seeks comments on the typical
operating conditions at which the unit is charged in the field and/or
what conditions should be used to set refrigerant charge for testing
purposes.
Issue CRAC-24: DOE requests comments on any other issues related to
the adoption of AHRI 1360-2016 as the test procedure for CRACs.
B. Test Procedure for Dedicated Outdoor Air Systems
DOASes appear to meet the EPCA definition for ``commercial package
air conditioning and heating equipment,'' \10\ and could be considered
as a category of that covered equipment. (42 U.S.C. 6311(8)(A))
However, DOE has tentatively concluded that if DOASes are a category of
``commercial package air conditioning and heating equipment,'' there
are no existing DOE test procedures or energy conservation standards
for that category of commercial package air conditioning and heating
equipment. Specifically, DOE does not believe that DOAS are among the
commercial ``central air conditioners and central air conditioning heat
pumps'' for which EPCA originally established standards (42 U.S.C.
6313(a)(1)-(2), (7)-(9)), and for which the current test procedure and
standards are codified in Table 1 to 10 CFR 431.96 and Tables 1-4 of 10
CFR 431.97 (as air conditioners and heat pumps).
---------------------------------------------------------------------------
\10\ Under the statute, ``commercial package air conditioning
and heating equipment'' means air-cooled, water-cooled,
evaporatively-cooled, or water-source (not including ground-water-
source) electrically operated, unitary central air conditioners and
central air conditioning heat pumps for commercial application.
---------------------------------------------------------------------------
Neither EPCA nor DOE defines commercial ``central air conditioners
and central air conditioning heat pumps.'' DOASes operate similarly to
commercial central air conditioners and central air conditioning heat
pumps, in that they provide space conditioning using a refrigeration
cycle consisting of a compressor, condenser, expansion valve, and
evaporator. However, DOASes are designed to provide 100 percent outdoor
air to the conditioned space, while outdoor air makes up only a small
portion of the total airflow for typical commercial air conditioners,
usually less than 50 percent. When operating in humid conditions, the
dehumidification load is a much larger percentage of total cooling load
for a DOAS than for a typical commercial air conditioner. Additionally,
compared to a typical commercial air conditioner, the amount of total
cooling (both sensible and latent) is much greater per pound of air for
a DOAS at design conditions (i.e., the warmest/most humid expected
summer conditions), and a DOAS is designed to accommodate greater
variation in entering air temperature and humidity. DOASes are
typically installed in addition to a primary cooling system (e.g.,
CUAC, VRF, chilled water system, water-source heat pumps)--the DOAS
conditions the outdoor ventilation air, while the primary system
provides cooling to balance building shell and interior loads and solar
heat gain. DOE is considering whether there is a need for definitions
of ``commercial central air conditioners and central air conditioning
heat pumps'' and ``dedicated outdoor air systems'' to clarify this
distinction. If DOE determines this necessary, it would do so through a
future rulemaking proceeding.
ASHRAE 90.1-2016 created separate equipment classes for DOAS units
and set minimum efficiency levels using the integrated seasonal
moisture removal efficiency (ISMRE) metric for all DOAS classes and the
integrated seasonal coefficient of performance (ISCOP) metric for air-
source heat pump and water-source heat pump DOAS classes. Both metrics
are measured in accordance with AHRI Standard 920-2015, ``Performance
Rating of DX-Dedicated Outdoor Air System Units'' (AHRI 920-2015). AHRI
920-2015 references ASHRAE Standard 198-2013, ``Method of Test for
Rating DX-Dedicated Outdoor Air Systems for Moisture Removal Capacity
and Moisture Removal Efficiency'' (ASHRAE 198-2013), as the method of
test for DOAS units.
DOE must adopt the industry standard designated by ASHRAE 90.1
unless it is not consistent with EPCA requirements. Accordingly, DOE is
considering the test methods of AHRI 920-2015 and ASHRAE 198-2013, but
may consider modifications of these test methods if necessary to
fulfill the EPCA requirements. In the following sections, DOE reviews
potential definitions and efficiency metrics for DOAS, as well as
questions regarding the test method in the industry standards.
1. Definition
As stated previously, DOE is considering how to define ``dedicated
outdoor air system.'' Both AHRI 920-2015 and ASHRAE 198-2013 include
definitions for DOAS. DOE may adopt one of these definitions, but it
may also adjust the definition to assure that it is clear and complete.
The following sections address different aspects of the definitions
provided in the industry test standards.
a. Air Intake Source and Dehumidification Capability
Both AHRI 920-2015 and ASHRAE 198-2013 define a DOAS as a product
that dehumidifies 100-percent outdoor air to a low dew point. However,
section 6.6 of ASHRAE 198-2013 provides requirements for dampers not
used for introducing outdoor air, suggesting that some DOAS units take
in some percentage of return air. Accordingly, DOE has identified
models from multiple manufacturers that are advertised as DOASes, but
which incorporate a damper-controlled return air inlet that allows
return air to be mixed with outdoor air.
CUACs also often incorporate a damper to mix return air and outdoor
air. Additionally, CUACs also can dehumidify 100-percent outdoor air,
although generally not to a dew point as low as DOASes. Hence, DOE is
concerned that the dehumidification capability and/or the range of
percentage of return air flow may have to be quantified to distinguish
DOASes and CUACs.
Issue DOAS-1: DOE requests information on the range of the maximum
percentage of return air intake relative to total air flow of DOAS
models in order to determine whether the maximum return air percentage
is an important DOAS distinguishing feature.
Issue DOAS-2: DOE requests comment on the differences in
dehumidification capabilities of CUACs and DOASes when operating with
100-percent outdoor air. Specifically, DOE seeks comment on whether a
difference can be quantified to be a clear differentiating feature of
DOASes--for example, can a specific dew point criterion for a given set
of outdoor air conditions be established that can be achieved by any
DOAS, but that no conventional CUAC can achieve?
b. Reheat
DOE is interested in determining how the ability to reheat
dehumidified air should be incorporated into the definition of a DOAS.
The AHRI 920-2015 definition requires that a DOAS
[[Page 34436]]
include reheat ``capable of controlling the supply dry-bulb temperature
of the dehumidified air to the designed supply air temperature,''
whereas the ASHRAE 198-2013 definition indicates only that DOASes may
have this functionality. The ASHRAE 198-2013 definition indicates that
the DOAS might also have a supplemental heat system ``for use when
outdoor air requires heating beyond the capability of the refrigeration
system and/or other heat transfer apparatus.'' Supplemental heating is
also mentioned in the note below the AHRI 920-2015 definition.
Issue DOAS-3: DOE requests comment on whether and how reheating
functionality should be included in the DOAS definition. If reheat
should be required for a unit to be considered a DOAS, DOE requests
comment on whether a minimum reheat capacity should be specified in the
definition. DOE also requests information to clarify the difference
between a reheat system and a supplementary heat system in a DOAS--for
example, if reheat is required for a DOAS, can it be a supplementary
reheat system (i.e., one that uses a heat source other than warm
refrigerant or heat recovered from the return air)?
2. Energy Efficiency Descriptors
a. Dehumidification Metric
ISMRE is a seasonal efficiency metric calculated based on moisture
removal efficiency (MRE) at four different dehumidification rating
conditions. The weighted values are derived from bin hour data (i.e.,
temperature/humidity data for a selection of representative cities
indicating the number of hours of occurrence of each ``bin''
representing a defined range of temperature and humidity) to represent
seasonal operation. MRE is calculated as moisture removal capacity
(MRC) divided by the total energy input, as described in ASHRAE 198-
2013 section 10.6.
DOE is seeking clarification on the calculation procedure for
ISMRE. ASHRAE 198-2013 indicates measuring MRE twice for each test
condition, once with reheat on and once with reheat off. AHRI 920-2015
does not specify which of these values of MRE is used in the
calculation of ISMRE. AHRI 920-2015 section 6.1.3.1 calls for a
supplemental heat penalty if the supply air temperature is less than 70
[deg]F, but the incorporation of this penalty into the MRE equation is
not clearly described. It is also not clear whether the ASHRAE 198-2013
test method considers this penalty. Finally, the equation for the
supplemental heat penalty in AHRI 920-2015 appears to be missing the
supply air volume flow rate as a factor.
Issue DOAS-4: DOE requests information to clarify the calculation
procedure for ISMRE. Specifically, DOE requests input on which
dehumidification test MRE should be used (and why), how and when the
supplementary heat penalty is applied, and the basis for the
supplementary heat equation.
While the primary functions of DOASes are to provide ventilation
and to dehumidify the outdoor air, the units also provide sensible
cooling to the supplied air stream. However, the sensible cooling
provided by the unit is not accounted for as part of the MRE or ISMRE
efficiency metric. DOE is aware that the total sensible cooling
provided may be significantly less than the latent cooling associated
with removal of moisture--for example, conditions C and D of Tables 2
and 3 of AHRI 1360-2016 specify inlet air conditions already cooler
than the target 70 [deg]F supply temperature--but sensible cooling may
be important enough to consider for the warmer test conditions.
Issue DOAS-5: DOE requests comment on whether the DOAS efficiency
metric should also account for sensible cooling provided for
ventilation air during the cooling/dehumidification season.
The ISMRE metric is based on testing at four different operating
conditions, involving specification of both dry bulb and wet bulb
outdoor temperature. A weighted average of the MRE measurements
determined for the four conditions is calculated to obtain ISMRE. DOE
test procedures must provide a measurement that is representative of an
average use cycle for the tested equipment. (42 U.S.C. 6314(a)(2))
Among the considerations that might be relevant in defining the test
conditions and weighting factors is the fact that ventilation air must
be delivered to occupied spaces during occupied hours, which would put
more emphasis on daytime hours for development of the metric.
Issue DOAS-6: DOE seeks information about analysis of climate data
relevant to the development of the ISMRE test conditions and weighting
factors in order to confirm that the metric provides a measurement that
is representative of an average use cycle for DOAS equipment.
b. Heating Metric
ISCOP is a seasonal energy efficiency descriptor calculated as the
weighted average of heating COP determined for two different heating
rating conditions. DOE test procedures must provide a measurement that
is representative of an average use cycle for the tested equipment. (42
U.S.C. 6314(a)(2)) Section 6.4 of AHRI 920-2015 indicates that the
weighting factors for the COPs are derived from bin hour data to
represent a full year of operation.
Issue DOAS-7: DOE seeks information about analysis of climate data
relevant to the development of the ISCOP test conditions and weighting
factors in order to allow confirmation that the metric provides a
measurement that is representative of an average use cycle for DOAS
heat pump equipment.
``Integrated seasonal coefficient of performance,'' as defined in
AHRI 920-2015, is an energy efficiency metric for water-source heat
pumps. However, DOE notes that ASHRAE 90.1-2016 includes ISCOP minimum
efficiency levels for air-source heat pumps (heating mode) in Table
6.8.1-16 in addition to water-source heat pumps. ASHRAE 198-2013
section 10.9 claims that its equations for calculating COP are for
water-source heat pumps, although the COP definition in ASHRAE 198-2013
does not exclude air-source heat pumps, and the equations should apply
equally well for air-source heat pumps. Finally, DOE notes that tests
conducted at 35 [deg]F dry bulb temperature for consumer central air
conditioning heat pumps (which are air-source) consider the impacts of
defrosting of the outdoor coil in the energy use measurement (see
section 3.9 of 10 CFR part 430, subpart B, appendix M), while defrost
is not discussed at all in ASHRAE 198-2013. Defrost has a real impact
on efficiency because of energy use associated with defrost and because
a system cannot continue to provide heating during defrost operation,
thereby reducing time-averaged capacity. Hence, consideration of
defrost could provide a more field-representative measurement of
performance.
Issue DOAS-8: DOE seeks input on the calculation procedure for the
COP of air-source heat pump DOASes, including whether testing for test
condition E of AHRI 920-2015 Table 2 (35 [deg]F dry bulb/29 [deg]F wet
bulb) should consider energy use associated with defrost.
The COP equation of ASHRAE 198-2013 section 10.9 uses the term
qhp to represent the heating capacity in the COP
calculation. This term does not appear in the nomenclature section, but
the subscript ``hp'' suggests that this includes only heat provided by
the heat pumping function of the DOAS unit. However, the equation
defining qhp is based on supply air temperature, suggesting
that any of the possible
[[Page 34437]]
additional methods for providing heat (e.g., supplemental heat, heat
recovery) may contribute to qhp and thereby boost COP by
increasing the numerator of the COP equation. The COP equation includes
only electric power input in the denominator and does not include
energy use that might be associated with fuel-fired supplemental heat.
In addition, the supplemental heat penalty of AHRI 920-2015 section
6.1.3.1, which the section states applies to the heating test
conditions as well as the dehumidification test conditions, seems to
penalize the COP calculation excessively, because it does not indicate
that the additional heating should be added to the qhp of
the COP equation.
Issue DOAS-9: DOE seeks input on the calculation for COP and how
the supplemental heat penalty is included. DOE also seeks input on how
the heating capacity and power/fuel consumption of various supplemental
heating sources are accounted for as part of the COP equation and how
DOAS manufacturers incorporate the impacts of these sources in their
ISCOP calculations.
3. Test Method
a. Airflow
i. Supply Airflow
Section 5.2.2 of AHRI 920-2015 specifies instructions regarding
supply airflow rate. Section 5.2.2.1 of that industry standard requires
either use of the supply airflow that occurs at the minimum external
static pressure of Table 4 or a manufacturer-specified lower leaving
airflow rate that occurs with higher external static pressure. Section
5.2.2.3 of that industry standard further requires that the
manufacturer specify a single airflow for all tests. However, many DOAS
systems can operate over a range of airflow rates, and DOE expects that
their indoor fans can be set up with a range of speeds to accommodate
the airflow range and the variation in duct length in field
installations. Further, some DOAS systems are employed for demand
ventilation use, for which reduced airflow will likely be required for
a significant portion of the unit's use. Such systems also are likely
to have variable-speed indoor fans, whose speed settings for the test
may also have to be defined clearly. The performance of the DOAS may
vary significantly from the low end to the high end of the rated
installation airflow range. DOE is concerned that the selected airflow
rate may not provide a representative indication of field use, and that
there may not be sufficient clarity regarding how to set up for testing
a unit with multiple indoor fan speed options.
Issue DOAS-10: DOE requests input on the appropriate selection of
the supply airflow rate for testing units that can operate with a range
of airflow rates. DOE requests information regarding how manufacturers
select the airflow rate for testing and any data demonstrating the
variation of DOAS unit performance over a range of installed airflow
rates.
Issue DOAS-11: DOE requests comment on whether it would be
appropriate to develop a test that includes part-load (reduced
ventilation air) test points to quantify the efficiency benefit of
demand-controlled ventilation for DOASes that are capable of operating
with this control.
ii. Return Airflow
For testing DOAS units with energy recovery,\11\ Tables 2 and 3 in
AHRI 920-2015 provide return airflow temperature conditions and
indicate that they apply to units with energy recovery at balanced
airflow (i.e., tested with supply airflow equal to exhaust airflow). It
is unclear what airflow streams should be balanced, how to determine if
they are balanced, and within what tolerances they should be balanced.
DOE is considering clarifying the return airflow set-up procedures.
---------------------------------------------------------------------------
\11\ DOAS units with energy recovery take in and discharge
exhaust air, using a device such as an energy recovery wheel that
can transfer heat and moisture from the exhaust air to the outdoor
air, thereby preconditioning the outdoor air and reducing the load
required to cool, dehumidify, or heat the air to the desired supply
conditions.
---------------------------------------------------------------------------
Issue DOAS-12: DOE requests comment regarding how manufacturers who
have tested heat recovery DOAS set up return airflow for testing DOAS
units with energy recovery as prescribed by the AHRI 920-2015 test
standard. Further, DOE requests comment on whether balanced airflow is
representative of field installation, and what ESP levels should be set
up for the return airflow.
iii. Exhaust Air Transfer Ratio
Exhaust air transfer ratio (EATR) is an indicator of the amount of
air that leaks from the return air side of the energy recovery wheel to
the supply air side. Such leakage could increase the apparent
dehumidification provided by a DOAS unit because the return air is less
humid than the outdoor air into which the return air could leak--thus,
high leakage could boost the ISMRE rating without providing any real
benefit. However, DOE recognizes that such leakage may be low enough in
most energy recovery wheels that the EATR measurement would represent
an unnecessary addition to test burden.
Issue DOAS-13: DOE seeks comments on whether EATR should be
included in DOE's test procedure for DOAS, and, if so, how it should be
used in determining DOAS ratings. DOE requests information on the range
of return air leakage typical for energy recovery wheels used in
DOASes.
b. Liquid Flow
i. Water Flow Rate for Water-Source DOASes
Neither AHRI 920-2015 nor ASHRAE 198-2013 provides requirements for
outlet water temperature or water flow rate for water-cooled units.
Instead, AHRI 920-2015 specifies a standard rating test water entering
temperature in Table 2 and requires in section 6.1.4.3 that the
manufacturer specify a water flow rate, unless it is controlled
automatically by the device. However, ANSI/AHRI 340/360-2007 with
addenda 1 and 2, ``Standard for Performance Rating of Commercial and
Industrial Unitary Air-Conditioning and Heat Pump Equipment'' (AHRI
340/360-2007) and ANSI/AHRI 210/240-2008 with addenda 1 and 2,
``Standard for Performance Rating of Unitary Air-Conditioning & Air-
Source Heat Pump Equipment'' (AHRI 210/240-2008), which cover
performance rating for water-cooled commercial air-conditioning
equipment, employ a different method. Both of these standards specify
water inlet and outlet temperatures for the standard rating conditions,
rather than relying on manufacturers to determine water flow rate.
Further, both standards specify that the full-load water flow rate
determined for the standard rating conditions should also be used for
IEER part-load rating conditions. DOE believes that these approaches to
testing reflect the typical design temperature differential for cooling
towers serving water-cooled equipment, and a very common approach for
control of condenser water pumps, and hence it is not clear why the
same approach would not be adopted for water-cooled DOAS.
Issue DOAS-14: DOE requests information on how condenser water flow
rates are set in the field and how they are controlled at part load.
DOE also requests comment on whether the provisions of section 6.1.4.3
of AHRI 920-2015 provide sufficient guidance regarding how to set up
water flow for DOASes with automatic water flow control systems.
[[Page 34438]]
ii. Energy Consumption of Pumps and Fans for Water-Source Condensers
AHRI 920-2015 offers Equation 1 for calculating the total pump
effect (PE), an estimate of the energy consumption of non-integral
water pumps (i.e., pumps that are not part of the DOAS unit and whose
power consumption would, therefore, not already be part of the measured
power). Section 6.1.3 of AHRI 920-2015 implies that this calculation
applies solely to water pumps serving refrigerant-to-liquid heat
recovery devices--no indication is given whether the equation also
applies for pumps serving water-source or water-cooled condensers--
although it is possible that the term ``refrigerant-to-liquid heat
recovery device'' refers to the condenser of a water-source heat pump
DOAS. Further, neither AHRI 920-2015 nor ASHRAE 198-2013 mention
accounting for the energy consumption of heat recovery fans for water
loops or water-cooled condensers. In contrast, AHRI 340/360-2007, which
is used for rating water-cooled CUACs, provides in section 6.1 a power
consumption allowance for both the cooling tower fan and the
circulating water pump.
Issue DOAS-15: DOE requests confirmation that the ``refrigerant-to-
liquid heat recovery device'' cited in section 6.1.3 of AHRI 920-2015
is intended to include heat exchangers used for rejection of
refrigerant circuit heat during the dehumidification cycle, and comment
on whether Equation 1 of this section for estimating the energy usage
of water pumps is appropriate for DOASes with water-cooled condensers.
Issue DOAS-16: DOE requests comment on accounting for the energy
consumption for heat-rejection fans employed in water-cooled or water-
loop DOASes.
iii. Energy Consumption for the Chiller System for Liquid-Cooled DOAS
Using Chilled Water for Condenser Cooling
One of the options for testing water-cooled DOAS is to provide
condenser cooling water at 45 [deg]F, replicating operation in which
condenser cooling is provided by a chilled water system. When operating
in this fashion, the chilled water system must expend additional energy
to maintain the 45 [deg]F supply water condition--it is not clear that
this energy is considered in the ISMRE metric. Without this energy use
contribution, the ratings for such equipment would appear to be have an
unfair advantage in comparison to the ratings for DOAS rated using
cooling tower water. The minimum efficiency levels in ASHRAE 90.1-2016
for both equipment classes certainly do reflect this advantage, with
the ISMRE levels being 4.9 for water-cooled DOAS using cooling tower
water and 6.0 for those using chilled water. Although the 6.0 ISMRE
level for chilled-water-cooled operation appears to be much more
efficient, it does not include the energy use associated with the
chiller system required to deliver the chilled water at the specified
45 [deg]F.
Issue DOAS-17: DOE requests comment on whether energy contributions
should be considered for the chiller system of a water-cooled DOAS that
is rated for use with chilled water for condenser cooling. If so, DOE
requests comment on the appropriate representative value for the
chiller system energy contribution.
c. Test Conditions
i. Supply Air Conditions
AHRI 920-2015 includes a requirement of minimum supply air
temperature of 70.0 [deg]F for all standard rating conditions and a
maximum dew-point temperature of 55.0 [deg]F for standard rating
conditions for dehumidification. ASHRAE 198-2013 requires a supply air
temperature of 75.2 [deg]F or as close to this value as the controls
will allow during testing.
Issue DOAS-18: DOE requests comment or clarification related to the
difference in target supply air temperature requirements between AHRI
920-2015 and ASHRAE 198-2013. DOE requests comments as to the
appropriate supply air temperature for use in the DOE test procedure
for DOAS.
ii. Cooling Tower and Closed-Loop Water-Source Differences
The water entering temperature test conditions in AHRI 920-2015
Table 2 for testing water-cooled DOAS differ from the water-source heat
pump inlet temperature conditions specified in Table 3 for water-source
heat pump DOAS tested using the ``water source'' test conditions.
Water-source water loops generally provide heat rejection using cooling
towers. Hence, it is unclear that there is much value in having
incremental differences for the dehumidification test conditions for
these types of equipment.
Issue DOAS-19: DOE requests comment on the need for different
dehumidification test conditions for a water-cooled DOAS as compared to
a water-source heat pump DOAS using the closed water loop test
conditions.
iii. Water-Cooled Condensing and Ground-Source Equipment
Tables 2 and 3 in AHRI 920-2015 include two categories for water-
cooled DOASes and three categories for heat pump DOASes. The test
standard specifies a different set of inlet water/fluid temperatures
for each category. The different categories and their associated rating
conditions could require some DOASes to be tested separately as
different basic models. For example, water-cooled DOASes that can be
operated with either chilled water or condenser water would have to be
tested and rated in both configurations. Similarly, ASHRAE 90.1-2016
includes three rating subcategories for water-source heat pump DOASes--
ground-source, closed loop; ground-water-source; and water-source. The
EPCA definition for ``commercial package air conditioning and heating
equipment'' does not include ground-water-source products (42 U.S.C.
6311(8)(A)), but ground-source and water-source heat pumps would be
covered by DOE with two different rating conditions. DOE is considering
whether such dual rating and certification is appropriate.
Issue DOAS-20: DOE requests comment on whether condenser cooling by
cooling tower water versus chilled water demarcates two distinct
equipment categories, or whether a single piece of equipment could
operate in both applications. Likewise, DOE requests comments on
whether ground-source closed-loop DOASes represent equipment that is
distinct from water-source models. For each of these pairs of
categories, if they do only represent different test conditions for the
same equipment, DOE requests input on whether testing and rating
equipment for two applications is preferable, or whether a single set
of test conditions and rating would be sufficient.
Section 2 of ASHRAE 198-2013 specifically excludes DOASes with
water coils that are supplied by a chiller located outside of the unit.
However, AHRI 920-2015 Table 2 includes operating conditions for which
a water-cooled condenser is supplied with chilled water, and ASHRAE
90.1-2016 established standard levels for DOASes that operate with
chilled water as the condenser cooling fluid.
Issue DOAS-21: DOE seeks confirmation that the ASHRAE 198-2013
chiller exclusion applies to cooling coils rather than condenser coils.
d. Tolerances
Rating test tolerances for DOASes are listed in Table 1 of ASHRAE
198-2013. This table specifies tolerances for
[[Page 34439]]
airflow rate and outdoor and return air dry-bulb and wet-bulb
temperatures, but does not list any tolerances for supply airflow
temperature. However, tolerances for supply temperature are included in
other relevant test procedures, such as in Table 2b of ASHRAE 37-2009.
DOE is considering adding operating tolerances for supply airflow dry-
bulb and wet-bulb temperatures to the test procedure.
In addition, the operating and condition tolerances listed for
airflow rate are 5 percent in Table 1 of ASHRAE 198-2013, which is
looser than the airflow rate tolerance adopted for CUACs. In fact, DOE
proposed to apply 5 percent condition tolerance on cooling
full-load indoor airflow rate for CUACs (see 80 FR 46870, 46873 (August
6, 2015; ``August 2015 CUAC TP NOPR'')), but received several comments
suggesting that a 5-percent tolerance would result in too much
variation in the measurement of EER and cooling capacity. Therefore,
DOE adopted a 3-percent tolerance in the December 2015 CUAC TP final
rule, as suggested by stakeholder comments. 80 FR 79655, 79659-79660
(Dec. 23, 2015). DOE has concerns that the 5-percent condition
tolerance on airflow in ASHRAE 198-2013 may result in too much test
variability for DOASes.
Issue DOAS-22: DOE requests comment on whether to adopt the
operating condition tolerances for supply air temperature listed in
Table 2b of ASHRAE 37-2009 for DOAS testing. DOE also seeks input
regarding whether a 5-percent airflow tolerance is acceptable. Further,
DOE requests any information or data regarding tolerances for any other
test operating parameters. Specifically, DOE requests comment on
whether there are any parameters whose tolerances should be tightened
or relaxed to ensure limited variation and high certainty for the ISMRE
and ISCOP results with appropriate test burden.
e. Capacity Measurement
The air enthalpy method, as specified in section 6.1 of ASHRAE 198-
2013, is the only capacity measurement method required in the test
procedure. There is no mention of a secondary test method for capacity
measurement verification in AHRI 920-2015 or ASHRAE 198-2013. In
contrast, secondary capacity measurements are generally required for
testing of air conditioners with capacity less than 135,000 Btu/h (see,
e.g., ASHRAE 37-2009 section 7.2.1). Measurement of air conditioning
capacity is based on the measurements of air flow rate, temperature,
and humidity, which can have an uncertainty range associated with them
that makes use of a secondary method to check the primary method
worthwhile to ensure accuracy. DOE is considering whether secondary
measurements should be required for DOAS testing in order to ensure
accuracy of measurements. Section 7 of ASHRAE 37-2009 describes several
different test methods applicable to testing of unitary air-
conditioning and heat pump equipment. The cooling condensate method may
be particularly relevant as a secondary test method for measuring the
dehumidification performance of a DOAS.
Issue DOAS-23: DOE requests comment on the need for a secondary
test method requirement for DOAS testing. DOE seeks input regarding
potentially applicable secondary test methods for the dehumidification
and heating tests, and whether a secondary test method requirement and/
or the secondary method allowed by the test procedure should depend on
cooling (or dehumidification) capacity or airflow rate. DOE is also
interested in detailed information on the test burden that would be
associated with a secondary test method.
f. Test Set-Up
Figures 1 and 2 of ASHRAE 198-2013 show the typical test set-up for
DOASes with and without energy recovery. The figures show airflow and
condition measuring devices at both the inlet and the outlet of each
airstream, but it is not clear in the test standard that both airflow
measurement devices are required. DOE notes that typically only one
airflow measuring device, which measures airflow downstream of the
unit, is installed in air-conditioner and heat pump testing. ASHRAE
198-2013 provides no description of the use of two sets of airflow
measurements per airstream, for example, for a tolerance check of the
airflow calculation or determination of leakage between air streams
when testing a DOAS with energy recovery.
Issue DOAS-24: DOE requests comments on whether it is beneficial or
necessary to use two airflow measuring devices per airstream when
testing DOAS equipment.
Section 6.6 of ASHRAE 198-2013, which deals with Unit Preparation,
describes that any energy recovery devices that include a purge or
other function that transfers air from supply or exhaust shall be
disabled to set at zero position.
Issue DOAS-25: DOE seeks additional information on the purge
function mentioned in section 6.6 of ASHRAE 198-2013. Specifically, are
all purge devices adjustable to zero purge, and is it always clear how
to set them to zero purge? Also, DOE requests feedback on whether it is
appropriate to set purge to zero or whether it would be more
appropriate to set purge to its highest setting or to some standard
setting?
Issue DOAS-26: DOE requests any additional comments related to the
adoption of AHRI 920-2015 as the test procedure for DOAS.
C. Test Procedure for Air-Cooled, Water-Cooled, and Evaporatively-
Cooled Equipment
DOE's test procedures for ACUACs, ECUACs, and WCUACs are codified
at 10 CFR 431.96. Table 1 at 10 CFR 431.96 incorporates by reference
AHRI 340/360-2007 for WCUACs and ECUACs with cooling capacity >=65,000
Btu/h, excluding section 6.3. For ACUACs with cooling capacity >=65,000
Btu/h, Table 1 refers to appendix A to subpart F of part 431, which
references sections 3, 4, and 6 of AHRI 340/360-2007, excluding section
6.3. Paragraphs (c) and (e) of 10 CFR 431.96 and appendix A to subpart
F of part 431 contain additional test procedure provisions for WCUACs/
ECUACs and ACUACs, respectively. ASHRAE 90.1-2016 updated its test
procedure reference for this equipment to AHRI 340/360-2015,
``Performance Rating of Commercial and Industrial Unitary Air-
conditioning and Heat Pump Equipment'' (AHRI 340/360-2015), which has
triggered the requirement for DOE to review its test procedures for
this equipment.
At 10 CFR 431.95 and Table 1 of 10 CFR 431.96, DOE incorporates by
reference AHRI 210/240-2008 for testing of ACUACs, WCUACs, and ECUACs
with cooling capacity <65,000 Btu/h, excluding section 6.5. While
ASHRAE 90.1-2016 did not update its test procedure reference for this
equipment, AHRI has made public a draft update of AHRI 210/240 (AHRI
210/240-2015-Draft) that was submitted to the docket for the test
procedure for CAC/HPs on August 14, 2015 (Docket No. EERE-2009-BT-TP-
0004). For this reason, and to comply with the statutory requirement to
review test procedures at least once every seven years (42 U.S.C.
6314(a)(1)(A)), DOE is reviewing its test procedures for ECUACs and
WCUACs with cooling capacity less than 65,000 Btu/h in this RFI. DOE
will consider ACUACs with a cooling capacity less than 65,000 Btu/h in
a separate RFI.
The following sections explore aligning the ECUAC and WCUAC metric
with that of ACUAC, review updates in AHRI 340/360-2015 to determine if
adopting that industry standard would meet EPCA requirements, and
explore
[[Page 34440]]
additional test procedure issues related to the subject equipment.
1. Energy Efficiency Descriptor
DOE's current energy efficiency descriptor for ECUACs and WCUACs is
the energy efficiency ratio (EER). 10 CFR 431.96. The EER metric only
captures performance at a single set of rating conditions with
equipment operating at full-load, and it is calculated by dividing the
full-load cooling capacity by the equipment power input. In contrast,
DOE adopted integrated energy efficiency ratio (IEER) as an energy
efficiency metric for ACUACs in the December 2015 CUAC TP final rule.
80 FR 79655 (Dec. 23, 2015). ASHRAE 90.1-2016 also provides minimum
efficiency IEER levels (in addition to EER levels) for ECUACs and
WCUACs.
AHRI 340/360-2007 includes a method for testing and calculating
IEER for ECUACs and WCUACs. IEER is an energy efficiency descriptor
that is calculated from test results at four sets of conditions
including a full-load test at standard rating conditions and three
part-load tests at different outdoor conditions for ECUACs and
different entering water temperatures for WCUACs. IEER utilizes
adjustment factors to account for cycling losses, when applicable, at
part-load conditions. IEER also includes continuous indoor fan
operation, during times when the compressor would be cycling to meet
the required load, to account for fan operation during ventilation
mode. After the measured efficiencies at the four test conditions are
adjusted for cycling losses and continuous fan use, if applicable, the
results are multiplied by weighting factors and added together to
determine the IEER. The weighting factors used are as follows: 0.020
for the full-load test, 0.617 for the 75-percent load test, 0.238 for
the 50-percent load test, and 0.125 for the 25-percent load test.
Issue CUAC-1: DOE seeks comment or data on whether the IEER part-
load conditions and IEER weighting factors are representative of the
operation of field-installed ECUACs and WCUACs. DOE also seeks comment
or data regarding the typical cycling losses of field-installed ECUACs
and WCUACs.
The Appliance Standards and Rulemaking Federal Advisory Committee
(ASRAC) Commercial and Industrial Fans and Blowers Working Group
developed recommendations regarding the energy conservation standards,
test procedures, and efficiency metrics for commercial and industrial
fans and blowers in a term sheet (Docket No. EERE-2013-BT-STD-0006-
0179), which was the culmination of a negotiated rulemaking involving
that equipment. As part of this term sheet, Recommendation #3 discussed
the need for DOE's test procedures and related efficiency metrics to
properly account for the energy consumption of fans embedded in
regulated commercial air-conditioning equipment.
In addition, the working group agreed that in the next round of
test procedure rulemakings, DOE should consider revising efficiency
metrics that include energy use of supply and condenser fans to include
the energy consumption during all relevant operating modes (e.g.,
auxiliary heating mode, ventilation mode, and part-load operation). The
working group included ACUACs, ECUACs, and WCUACs in its list of
regulated equipment for which fan energy use should be considered.
(Docket No. EERE-2013-BT-STD-0006-0179 at pp. 3-4, 16)
Consequently, DOE is considering what changes to its ACUAC, ECUAC,
and WCUAC test procedures may more accurately represent fan energy use
in field applications. DOE is aware that field-installed fan energy use
will vary based on the use of the fan for ancillary functions (e.g.,
economizers, ventilation, filtration, and auxiliary heat). In order to
properly account for fan energy use, DOE is requesting information on
how frequently field installations use the supply fan of the CUAC for
various ancillary functions.
Issue CUAC-2: DOE requests information, including any available
data, on how frequently CUAC supply fans are operated when there is no
demand for heating or cooling (i.e., for fresh air ventilation or air
circulation/filtration), and what the typical operating schedules or
duty cycles are for this function. Additionally, DOE requests data or
information regarding how frequently and what forms of primary and
auxiliary heating are installed with CUACs and whether their operation
is dependent on the supply fan of the CUAC. DOE requests data or
information regarding how frequently the systems are used with
economizers, how the economizers are integrated with the systems, and
what control logic is typically used on the economizers. DOE also seeks
comment and information regarding the use of the indoor supply fan of
CUACs for any ancillary functions not mentioned above. Please
differentiate by ACUAC, ECUAC, or WCUAC, as necessary.
Another factor that influences fan energy use is the external
static pressure that is required to overcome the air distribution
system pressure drop. Both AHRI 210/240-2008 and AHRI 340/360-2007
specify minimum external static pressures for testing based on the
rated unit capacity of ECUACs and WCUACs. DOE is interested in ensuring
that the external static pressures in the test procedures are
representative of those experienced in field installations. In the
December 2015 CUAC TP final rule, DOE summarized stakeholder comments
regarding the possibility that external static pressures as measured in
the field may be higher than those found in the industry test
standards. 80 FR 79655, 79664 (Dec. 23, 2015). Based on this
information, DOE is examining the external static pressures specified
in the test procedures for ECUACs and WCUACs.
Issue CUAC-3: DOE requests comment or data regarding the typical
external static pressures in field installations of ECUACs and WCUACs
and whether these field-installed external static pressures typically
vary with capacity. DOE also seeks comment regarding whether the field
applications of ECUACs and WCUACs are different from ACUACs with
regards to the typical ducting installed on the system.
Another issue related to fan energy is the default fan power for
ACUACs, ECUACs, and WCUACs with a coil-only configuration (i.e.,
without an integral supply fan). Current test procedures for ACUACs,
ECUACs, and WCUACs specify that indoor fan power of 365 Watts (W) per
1000 standard cubic feet per minute (scfm) be added to power input for
coil-only units and that the corresponding heat addition be subtracted
from measured cooling. This value has been used to account for the fan
energy use associated with coil-only units for many years, and more-
efficient motors and fans may be in use for which the current 365 W/
1000 scfm fan power value is not representative. It is also possible
that the value is not consistent with field-typical external static
pressures.
Issue CUAC-4: DOE seeks comment or data on the prevalence of
ACUACs, ECUACs, and WCUACs that are sold in coil-only configurations
(i.e., neither with an integral supply fan, nor with a designated air
mover such as a furnace or modular blower).
Issue CUAC-5: DOE seeks comment or data on the typical efficiency
or typical power use and flow of fans used with coil-only ACUACs,
WCUACs, and ECUACs in field installations.
2. Addressing Changes to AHRI 340/360
As noted previously, ASHRAE 90.1-2016 updated its reference from
AHRI 340/360-2007 to AHRI 340/360-2015. The updated AHRI 340/360-2015
includes significant changes from AHRI 340/360-2007 for ACUACs, ECUACs,
[[Page 34441]]
and WCUACs, and DOE seeks comment on those changes as discussed in this
section. Several changes are relevant to all three categories of
equipment, while other changes are only relevant to one or two of the
equipment categories. Table II.2 illustrates to which equipment
category each change is relevant. In some cases, a change may not be
relevant to ACUACs because the change has already been adopted in the
December 2015 CUAC TP final rule.
Table II.2--AHRI 340/360-2015 Changes
----------------------------------------------------------------------------------------------------------------
Topic ACUAC ECUAC WCUAC
----------------------------------------------------------------------------------------------------------------
Head Pressure Controls....................................... X X X
Refrigerant Charging Requirements............................ X X X
Adjustment for Different Atmospheric Pressure Conditions..... X X X
Measurement of Condenser Air Inlet Temperature............... X X ...............
Tolerance of Tested Airflow Relative to Rated Airflow........ ............... X X
Vertical Separation of Indoor and Outdoor Units.............. X X X
Outdoor Entering Air Wet-Bulb Temperature.................... ............... X ...............
Single-Zone Variable-Air-Volume and Multi-Zone Variable-Air- X X X
Volume......................................................
----------------------------------------------------------------------------------------------------------------
a. Head Pressure Controls
Condenser head pressure controls regulate the flow of refrigerant
through the condenser and/or adjust operation of condenser fans to
prevent condenser pressures from dropping too low during low-ambient
operation. When employed, these controls ensure that the refrigerant
pressure is high enough to maintain adequate flow through refrigerant
expansion devices such as thermostatic expansion valves. AHRI 340/360-
2007 provides minimal guidance on head pressure controls, only
mentioning in note 2 of Table 6 that the condenser airflow should be
adjusted as required by the unit controls for head pressure control.
AHRI 340/360-2015 states that any head pressure controls shall be left
at the manufacturer's settings and operated in automatic mode, but
that, if this results in unstable operation exceeding the tolerances of
ASHRAE 37-2009, the time-averaged head pressure control test described
in section F7 of appendix F of AHRI 340/360-2015 shall be used. This
test requires measuring performance using two one-hour test periods,
first after approaching the target ambient condition from warmer
temperatures, and once after approaching from lower temperatures.
During these tests, the looser tolerance requirements from Table 2b of
ASHRAE 37-2009 for the ``heat portion'' of the heat with defrost test
must be met. This issue was reviewed by DOE for ACUACs in the December
2015 CUAC TP final rule. In that final rule, DOE clarified that head
pressure controls must be active during the test, but DOE did not adopt
the time-averaged head pressure control test specified in AHRI 340/360-
2015, indicating that AHRI 340/360-2015 was a draft document at the
time and that DOE would reconsider adoption of the provisions for
testing units with head pressure control later. 80 FR 79655, 79660
(Dec. 23, 2015).
Issue CUAC-6: DOE seeks information and data regarding testing of
CUACs with head pressure control that would require the special test
provisions described in AHRI 340/360-2015. Specifically, can such units
be tested in compliance with the relaxed stability requirements of
these test provisions? Do the test results accurately represent field
use? Is the test burden associated with these tests appropriate?
b. Refrigerant Charging Requirements
AHRI 340/360-2007 does not provide any specific guidance on setting
the refrigerant charge of a unit.
The DOE test procedures for ACUACs, ECUACs, and WCUACs state that
if the manufacturer specifies a range of superheat, sub-cooling, and/or
refrigerant pressures in the installation or operation manual, any
value within that range may be used to determine refrigerant charge,
unless the manufacturer clearly specifies a rating value in its
installation or operation manual, in which case the specified value
shall be used. 10 CFR 431.96(e)(1); section (5)(i) of appendix A to
subpart F of part 431.
AHRI 340/360-2015 states that equipment shall be charged with
refrigerant at standard rating conditions (or conditions specified by
the manufacturer in the installation instructions) in accordance with
the manufacturer's installation instructions or label applied to the
equipment. In contrast with the DOE test procedure, the industry test
standard calls for the use of the average of ranges of sub-cooling or
superheat specified in installation manuals.
As discussed in section II.A.3.e, the June 2016 CAC TP final rule
provides a comprehensive approach for charging that improves test
reproducibility. The approach indicates which set of installation
instructions to use for charging, explains what to do if there are no
instructions, indicates that target values of parameters are the
centers of the ranges allowed by installation instructions, and
specifies tolerances for the measured values. 81 FR 36992, 37030-37031.
These methods could be considered as an example for the CUAC test
method.
Issue CUAC-7: DOE seeks comment on whether it would be appropriate
to adopt an approach for charging requirements for commercial CUACs
similar or identical to the approach adopted in the June 2016 CAC TP
final rule for residential products. DOE seeks comments regarding which
parts of the approach should or should not be adopted, and for what
reasons they might or might not be suitable for application to CUACs.
DOE is also interested in receiving data that demonstrate how sensitive
the performance of ACUACs, ECUACs, and WCUACs is relative to changes in
the various charge indicators used for different charging methods,
specifically the method based on sub-cooling.
c. Adjustment for Different Atmospheric Pressure Conditions
In order to address potential differences in measured results
conducted at different atmospheric pressure conditions, AHRI 340/360-
2015 introduced an adjustment for indoor supply fan power and
corresponding fan heat. This adjusts the fan power based on the
barometric pressure at the test site, multiplying the measured supply
fan power by the square of the ratio of the measured air density
(density of air at measured supply air temperature and humidity and
measured atmospheric pressure) to the density of the supply air if it
were at standard pressure (14.696 pounds per square inch).
Consequently, the cooling capacity and efficiency are also impacted by
this correction.
The outdoor air mass flow rate and fan power will also vary with
[[Page 34442]]
atmospheric pressure; however, the outdoor fan speed is typically not
adjustable, because most outdoor fans have single-speed direct-drive
motors, and no rated outdoor air flow rate in scfm is set during the
test for the majority of CUACs. To address the potential impact of
barometric pressure on the outdoor fan air flow, AHRI 340/360-2015
imposed a minimum atmospheric pressure of 13.7 pounds per square inch
absolute (psia) for testing equipment.
Issue CUAC-8: DOE requests test data that validate the supply fan
power correction used in AHRI 340/360-2015. DOE is also interested in
comments on whether the minimum atmospheric pressure of 13.7 psia will
prevent any existing laboratories from testing equipment, and what
burden, if any, is imposed by such a requirement. DOE also seeks any
available test data showing the impact that variations in atmospheric
pressure have on the performance (i.e., capacity and component power
use) of ACUACs, ECUACs, and WCUACs.
d. Measurement of Condenser Air Inlet Temperature (ACUAC and ECUAC)
A number of requirements have been added in Appendix C of AHRI 340/
360-2015 to help ensure accurate and reproducible measurement of the
condenser air inlet temperature. These requirements include
specifications on the acceptable number, geometry, placement, and
construction details of air sampling trees; specifications on the
required accuracy of dry bulb, wet bulb, and thermopile measurement
devices; requirements on the set-up and number of aspirating
psychrometers; and criteria for assessing acceptable air distribution
and control of air temperature.
Issue CUAC-9: DOE requests comment on whether any manufacturers
have evaluated the condenser inlet air uniformity using the criteria in
Appendix C of AHRI 340/360-2015 for ACUACs and ECUACs and if so,
whether any alterations to the laboratory or test set-up were necessary
to meet those requirements. Also, DOE requests comment on whether the
requirements of Appendix C are sufficient to ensure reproducibility of
results and/or any test data that demonstrate sufficient
reproducibility.
Due to the different heat exchange process of ECUAC condensers when
compared to ACUACs, ECUACs may have lower condenser airflow and in
turn, smaller openings for the condenser inlet air when compared to
ACUACs of similar capacity. Consequently, the air sampler tree and
thermopile requirements in AHRI 340/360-2015 may not be appropriate for
ECUACs.
Issue CUAC-10: DOE requests comments and data on the sizes of the
smallest and largest openings for condenser inlet air on the sides of
ECUACs. DOE seeks comment on whether the air sampler tree requirements
in Appendix C of AHRI 340/360-2015, specifically the requirement of 10
to 20 branch tubes, and the thermopile requirement of having 16
thermocouples per air sampler tree, are feasible for all ECUACs. DOE
also seeks information regarding any alternative methods or
measurements for determining condenser inlet air uniformity that may be
more suitable for ECUACs.
Issue CUAC-11: DOE requests comments and data regarding whether a
method of measuring and specifications for uniformity of the outdoor
inlet wet bulb temperature would benefit test reproducibility for
ECUACs.
e. Tolerance of Tested Indoor Airflow Relative to Rated Indoor Airflow
(ECUAC and WCUAC)
AHRI 340/360-2007 does not provide any tolerance on the tested
indoor airflow relative to the rated airflow of the unit under test.
AHRI 340/360-2015 has added a 3-percent tolerance for the tested
airflow relative to the rated airflow (i.e., the tested airflow is
permitted to be 3 percent higher or 3 percent lower than the rated
airflow). DOE adopted a 3 percent tolerance on indoor airflow for
testing ACUACs in the December 2015 CUAC TP final rule to limit
variation in EER and cooling capacity, based on test data and feedback
provided by industry commenters. 80 FR 79655, 79659-79660 (Dec. 23,
2015).
Issue CUAC-12: DOE seeks comment or data showing whether variations
in indoor airflow impact the measured efficiency or capacity of ECUACs
and WCUACs more or less than ACUACs and whether the 3-percent tolerance
provided in AHRI 340/360-2015 (and adopted for ACUACs in DOE's
regulations) is appropriate for these other equipment categories.
f. Vertical Separation of Indoor and Outdoor Units
AHRI 340/360-2007 does not limit the vertical separation of indoor
and outdoor units when testing split systems. However, AHRI 340/360-
2015 adds a requirement that the maximum allowable vertical separation
of the indoor and outdoor units be 10 feet, presumably because
separation greater than 10 feet can adversely affect measured
performance. If test facilities use indoor and outdoor environmental
chambers that are stacked vertically, the limitation on vertical
separation may make it impractical or impossible to test split systems.
Issue CUAC-13: DOE seeks comment regarding whether a maximum of 10
feet of vertical separation of indoor and outdoor units would limit the
ability of existing facilities to test split-system ACUACs, ECUACs, or
WCUACs. DOE also seeks comment on the impact that vertical separation
of split systems has on efficiency and capacity.
g. Outdoor Entering Air Wet-Bulb Temperature (ECUAC)
AHRI 340/360-2007 provides the same outdoor entering air conditions
(i.e., 95.0 [deg]F dry bulb and 75.0 14; [deg]F wet bulb) for the
standard rating condition (Table 3 of AHRI 340/360-2007) and the 100-
percent-capacity test point used to calculate IEER (Table 6 of AHRI
340/360-2007) for ECUACs. While the outdoor entering air dry-bulb
temperature is unchanged in AHRI 340/360-2015, the outdoor entering air
wet-bulb temperature for the 100-percent-capacity test point used to
calculate IEER was changed from 75.0 [deg]F to 74.5 [deg]F (Table 6 of
AHRI 340/360-2015). This change suggests that two full-load tests may
be required: One at the standard rating conditions for measuring the
rated capacity and EER, and another at the 100-percent-capacity test
point for the IEER test. Table 6 of AHRI 340/360-2015 also lists only
entering air wet-bulb temperatures for ECUACs, with no corresponding
dry-bulb temperatures.
Issue CUAC-14: DOE seeks comment regarding the slightly different
air wet-bulb test conditions of AHRI 340/360-2015 for standard rating
conditions as compared with the 100-percent-capacity test point for the
IEER test, and whether the requirement should be 75.0 [deg]F for both
purposes.
Issue CUAC-15: DOE seeks comment on whether the air-cooled entering
air dry-bulb temperatures in Table 6 of AHRI 340/360-2015 apply to
evaporatively-cooled units. If any manufacturers have developed IEER
ratings for ECUACs using AHRI 340/360-2015, DOE requests information
about what outdoor entering air dry-bulb temperatures were used during
the 100-percent and part-load tests.
h. Single-Zone Variable-Air-Volume and Multi-Zone Variable-Air-Volume
AHRI 340/360-2015 established different approaches for setting
indoor air flow for the part-load test conditions for single-zone
variable-air-volume (SZVAV) and multi-zone variable-air-
[[Page 34443]]
volume (MZVAV) systems (see section 6.1.3.3). The test standard defines
MZVAV as units ``designed to vary the indoor air volume and
refrigeration capacity/staging at a controlled discharge air
temperature and static pressure as a means of providing space
temperature control to independent multiple spaces with independent
thermostats.'' (AHRI 340/360-2015 section 3.14) It defines SZVAV as
units with a ``control system designed to vary the indoor air volume
and refrigeration capacity/staging as a means to provide zone control
to a single or common zones, controlled by a single space thermostat
input.'' The SZVAV definition further explains that, ``the capacity, as
well as the supply air flow shall be controlled either through
modulation, discrete steps or combinations of modulation and step
control based on the defined control logic.'' (AHRI 340/360-2015
section 3.25)
Part of the focus of each definition is the number of zones and
number of thermostats involved in a system served by a given variable-
air-volume unit. However, the zones served and thermostats connected
are part of the installation of a unit and not inherent attributes of a
unit's characteristics. Another part of the definition addresses the
variation of indoor air flow and capacity. For MZVAV, the air flow and
capacity can be varied to provide a controlled discharge temperature
and a controlled static pressure, which suggests, but does not clearly
state, that such units have variable-capacity compressors, and that
their indoor fan controls allow fully variable control of fan speed. In
contrast, the SZVAV definition seems to allow modulation, steps, or a
combination of steps and modulation for both fan and compressor
capacity control. Based on these definitions, it seems that a unit with
a variable-capacity compressor system and a variable-speed fan could
meet both definitions. Also, it would appear that any unit with a
variable-capacity compressor system that has SZVAV characteristics
could be converted to a MZVAV system by changing the indoor fan motor
controller or perhaps simply changing its settings.
Issue CUAC-16: DOE requests comment on whether a CUAC model that
could be both SZVAV and MZVAV should be tested both ways, representing
two separate basic models. If tested as one basic model, DOE requests
information regarding how to determine which of the two test methods
would apply. How frequently would such a model be installed in the
field as a SZVAV as opposed to a MZVAV? DOE also requests comment on
whether status as a proportionally controlled unit (see AHRI 340/360-
2015 section 3.20) would be considered to be the appropriate indication
of whether a CUAC can be used as a MZVAV unit, or whether some other
characteristics regarding variable capacity control would have to be
satisfied. Finally, for models that can be both SZVAV and MZVAV, how
much do the efficiency ratings for the two configurations differ?
3. Additional Test Method Issues
In this section, DOE explores several additional issues related to
the test procedures for CUACs. Most issues are relevant to only ECUACs,
but a few are also relevant to WCUACs and/or ACUACs, as shown in Table
II.3.
Table II.3--Additional CUAC Test Method Issues
----------------------------------------------------------------------------------------------------------------
Topic ACUAC ECUAC WCUAC
----------------------------------------------------------------------------------------------------------------
Length of Refrigerant Line Exposed to Outdoor Conditions..... X X X
Atmospheric Pressure Measurement............................. X X X
Consistency Among Test Procedures for Small and Large ............... X X
Equipment...................................................
Make-up Water Temperature.................................... ............... X ...............
Secondary Measurement Method for Capacity.................... ............... X ...............
Piping Evaporator Condensate to Condenser Pump............... ............... X ...............
Purge Water Settings......................................... ............... X ...............
Condenser Spray Pumps........................................ ............... X ...............
Additional Steps to Verify Proper Operation.................. ............... X ...............
----------------------------------------------------------------------------------------------------------------
a. Length of Refrigerant Line Exposed to Outdoor Conditions
AHRI 340/360-2007, AHRI 340/360-2015, AHRI 210/240-2008, and AHRI
210/240-2015-Draft all require at least 25 feet of interconnecting
refrigerant line when testing split-systems. However, both versions of
AHRI 340/360 require that at least 5 feet of the interconnecting
refrigerant line must be exposed to outdoor test chamber conditions,
while both versions of AHRI 210/240 require at least 10 feet be so
exposed. DOE has estimated an upper bound of the capacity loss to be
approximately 1 percent of the capacity of the unit for 10 feet of
refrigerant line located in the outdoor chamber and approximately 0.5
percent for 5 feet.
Issue CUAC-17: DOE seeks comment or data regarding the typical
length of refrigerant line that is exposed to outdoor conditions on
split-system ACUAC, ECUAC or WCUAC installations and whether this
length varies depending on the capacity of the unit. DOE also seeks
comment or data on any measurements or calculations that have been made
of the losses associated with refrigerant lines located in the outdoor
chamber and whether the impact is larger or smaller than DOE's estimate
of approximately 1 percent of capacity per 10 feet of refrigerant line
located in the outdoor chamber.
b. Atmospheric Pressure Measurement
The accuracy of atmospheric pressure measurements required by
section 5.2.2 of ASHRAE 37-2009 (which is referenced by AHRI 340/360-
2015) is 2.5 percent. This level of uncertainty can result
in error when calculating the indoor entering and leaving air
enthalpies and resulting cooling capacity. Under certain circumstances,
atmospheric pressure measurements at the extremes of this tolerance
result in capacity measurement errors of 1-2 percent.
Issue CUAC-18: DOE seeks comment on the typical accuracy of the
atmospheric pressure sensors used by existing test laboratories.
c. Consistency Among Test Procedures for Small and Large ECUAC and
WCUAC Equipment Classes
The current test procedure and referenced industry standard for
ECUACs and WCUACs that have cooling capacities less than 65,000 Btu/h
(AHRI 210/240-2008) reference the same test method (ASHRAE 37-2005) and
contain the same efficiency metrics as those for units with capacities
greater than or equal to 65,000 Btu/h (AHRI 340/360-2007). However,
there are some differences that have been identified in this section.
DOE is considering whether the
[[Page 34444]]
consistency of test procedures could be improved by referencing a
single industry standard for all cooling capacities of ECUACs and
WCUACs. The updated industry standard for rating units with a capacity
greater than or equal to 65,000 Btu/h (AHRI 340/360-2015) has
significant changes that affect the testing of ECUACs and WCUACs.
However, the industry standard for rating units with a cooling capacity
less than 65,000 Btu/h is in the process of being updated and could
potentially be finalized with better consistency with AHRI 340/360 for
testing of this equipment.
Issue CUAC-19: DOE requests comment on whether there are
differences between ECUACs and WCUACs that have cooling capacities less
than 65,000 Btu/h and those that have cooling capacities greater than
or equal to 65,000 Btu/h that justify the incorporation by reference of
different industry test standards for the different cooling capacity
ranges. If not, DOE seeks feedback on whether referencing a single
industry standard for units of all cooling capacities would be
beneficial and/or whether there could or should be better consistency
between the test standards for testing of this equipment. Specifically,
DOE requests comment on whether there are actual differences in field
installations and field use of this equipment and on the extent to
which these differences impact performance.
d. Make-Up Water Temperature (ECUAC)
Neither AHRI 340/360-2007 nor AHRI 340/360-2015 provide any
requirements on the make-up water temperature for the standard rating
condition or for the part-load IEER tests. Make-up water must be
supplied to the sump of an ECUAC to replenish the evaporated water (or
to spray nozzles for models without sumps). AHRI 210/240-2008 and AHRI
210/240-2015-Draft specify 85.0[emsp14][deg]F for the full-load
standard rating condition and 77.0[emsp14][deg]F for the part-load
tests. Cooler makeup water temperature could increase measured cooling
capacity and vice versa, causing variation in measurements if specific
temperatures are not required.
Issue CUAC-20: DOE seeks comment or data regarding the impact that
the make-up water temperature has on the unit performance. DOE also
seeks comment or data on whether the make-up water temperatures,
including the temperatures for part-load conditions, specified in AHRI
210/240-2008 and AHRI 210/240-2015-Draft are representative of
conditions experienced by field-installed ECUACs of all cooling
capacities.
e. Secondary Measurement Method for Capacity (ECUAC)
ASHRAE 37-2009 requires the indoor air enthalpy method plus an
additional secondary method for calculating the test equipment capacity
for all units with less than 135,000 Btu/h rated capacity. The test
standard lists applicable test methods in Table 1, but this table does
not indicate that the outdoor air enthalpy method is applicable for any
configuration of evaporatively-cooled equipment. Therefore, the
secondary method for ECUACs is limited to use of the refrigerant
enthalpy method or compressor calibration method for split systems and
only the compressor calibration method for single-package equipment.
DOE recognizes that the refrigerant enthalpy method and compressor
calibration method can, in some circumstances, add burden to the
testing procedure, so DOE examined the potential use of the outdoor air
enthalpy method as a secondary method for ECUACs. During testing, DOE
observed that the part-load test conditions produce an environment
where condensation is likely in the outdoor unit supply duct, because
the outdoor air dry bulb temperature cooling the duct walls can be
lower than the dew point of the warm moist air leaving the outdoor
unit. This condensation would be unaccounted for by the outdoor air
enthalpy method, resulting in a calculated capacity less than the
actual capacity. To consider another approach, DOE notes that it
modified the CAC/HP test method to require a secondary capacity
measurement only for full-load operation for cooling and heating,
rather than for all tests in a January 5, 2017 final rule. 82 FR 1426,
1441. While this change was for central air conditioners and heat
pumps, limiting the secondary method test to a single set of
conditions, such as the full-load cooling (and heating, if applicable)
test conditions, would eliminate or reduce the potential for
condensation in the outdoor supply duct when testing ECUACs.
Issue CUAC-21: DOE seeks comment or test data on the difficulty of
getting a match of primary and secondary capacity measurements when
testing ECUACs with rated capacities less than 135,000 Btu/h and
whether the difficulty level is higher, lower, or the same when testing
the unit at full-load conditions as compared to part-load conditions.
DOE also seeks comment and data on how often the primary capacity
measurement results in an exceeded allowable percent difference between
the primary and secondary capacity measurements.
Issue CUAC-22: DOE seeks comment on whether single-package ECUACs
with a rated cooling capacity less than 135,000 Btu/h are currently
sold.
Issue CUAC-23: DOE seeks comment on whether manufacturers would see
a benefit in allowing the outdoor air enthalpy method as a secondary
capacity measurement for ECUACs. If so, DOE is interested in feedback
on methods to mitigate the risk of condensation in the outdoor unit
supply duct and the outdoor supply wet-bulb sample station. DOE also
asks if other alternative approaches could be considered for mitigating
the potential test burden associated with the secondary test methods
that ASHRAE 37-2009 specifies for evaporatively-cooled equipment.
f. Piping Evaporator Condensate to Condenser Pump (ECUAC)
Some split-system ECUACs provide the option for piping evaporator
condensate to the condenser sump. This reduces the make-up water use of
the unit and may provide some performance improvement. Neither DOE's
current test procedures nor the industry ECUAC test standards address
this potential variation, which could result in differences in test
results depending on whether this feature was employed in a test.
Issue CUAC-24: DOE seeks comment on whether ECUACs that allow
piping of evaporator condensate to the condenser sump present any
complications (e.g., maintaining proper slope in the piping from the
evaporator to the outdoor unit and test repeatability issues) when
testing in a laboratory. DOE also seeks comment or data indicating what
kind of impact piping the evaporator condensate to the condenser sump
has on the efficiency and/or capacity of ECUACs.
g. Purge Water Settings (ECUAC)
Some ECUACs require the sump water to be continuously or
periodically purged in order to reduce mineral and scale build-up on
the condenser heat exchanger. AHRI 340/360-2015 provides guidance to
set up and configure the unit per the manufacturer's installation
instructions, which would include setting the purge rate if specified.
Issue CUAC-25: DOE seeks comment on how the purge water rate should
be set for laboratory testing if the manufacturer's installation
instructions do not contain information on this topic.
[[Page 34445]]
h. Condenser Spray Pumps (ECUAC)
The rate that water is sprayed on the condenser coil may have an
impact on the performance of an ECUAC. For units with sumps, this rate
may be affected by the pump set-up, and, for units without sumps, the
incoming water pressure may have an impact. Neither DOE's current test
procedures nor the industry ECUAC test standards address these
potential variations.
Issue CUAC-26: DOE requests comment on whether the pump flow can be
adjusted on any ECUACs on the market that have circulation pumps. DOE
also requests comment on whether ECUACs without a sump exist and, if
so, whether there are requirements on the incoming water pressure to
ensure proper operation of the spray nozzles. DOE also requests
comments and/or data regarding the sensitivity of performance test
results to these adjustments.
i. Additional Steps To Verify Proper Operation (ECUAC)
Some ECUACs may use spray nozzles with very small diameter openings
that may become easily clogged, thereby reducing the effectiveness of
the heat exchanger.
Issue CUAC-27: DOE requests comment on whether there are any
additional steps that should be taken to verify proper operation of
ECUACs during testing, such as ensuring nozzles are not blocked.
Issue CUAC-28: DOE requests comment on any additional issues
associated with adopting AHRI 340/360-2015 for ACUACs, ECUACs, and
WCUACs.
D. Test Procedure for Variable Refrigerant Flow Multi-Split Air
Conditioners and Heat Pumps
DOE's commercial equipment regulations include test procedures and
energy conservation standards that apply to air-cooled VRF multi-split
air conditioners, air-cooled VRF multi-split heat pumps, and water-
source VRF multi-split heat pumps, all with cooling capacity less than
760,000 Btu/h, except air-cooled, single-phase VRF multi-split air
conditioners and heat pumps with cooling capacity less than 65,000 Btu/
h (which are covered by DOE's consumer product regulations for central
air conditioners \12\). 10 CFR 431.96 and 431.97.
---------------------------------------------------------------------------
\12\ See 10 CFR 430.32(c) and Appendix M and M1 to Subpart B of
Part 430.
---------------------------------------------------------------------------
DOE's test procedure for (commercial) VRF multi-split systems is
codified at 10 CFR 431.96 and was established in the May 2012 final
rule. 77 FR 28928 (May 16, 2012). DOE's current regulations require
that manufacturers test VRF multi-split systems using AHRI 1230-2010
with addendum 1, except for sections 5.1.2 and 6.6. DOE's current test
procedure also requires that manufacturers adhere to certain additional
requirements listed in 10 CFR 431.96(c)-(f). Although ASHRAE 90.1-2016
did not update its test procedure reference for VRF (AHRI 1230-2010
with addendum 1), DOE is reviewing its test procedure in response to
the seven-year-lookback statutory review requirement (see 42 U.S.C.
6314(a)(1)(A)), and in advance of its review of energy conservation
standards for VRF in response to changes in ASHRAE 90.1-2016.
As part of its seven-year-lookback review, DOE is examining updated
industry test standards, including Addendum 2 to AHRI 1230-2010
(approved June 2014) and a draft version of AHRI 1230 provided by AHRI
for the docket that will supersede AHRI 1230-2010 (with Addendum 1 and
2) once published (``AHRI 1230-Draft,'' No. 1). DOE reviewed the AHRI
1230-Draft and discusses in the following sections specific issues
regarding the draft and other items related to the VRF test procedure.
1. Energy Efficiency Descriptors
DOE currently prescribes energy conservation standards for air-
cooled VRF multi-split systems with cooling capacity greater than or
equal to 65,000 Btu/h and water-source VRF multi-split systems in terms
of the EER metric for cooling-mode operation and in terms of the
coefficient of performance (COP) metric for heating-mode operation.\13\
DOE is considering whether to add or replace the existing cooling-mode
efficiency descriptor (i.e., EER) with a new cooling-mode energy-
efficiency descriptor that better captures part-load performance, such
as IEER.
---------------------------------------------------------------------------
\13\ DOE also prescribes energy conservation standards for
three-phase air-cooled VRF multi-split systems with cooling capacity
less than 65,000 Btu/h in terms of the SEER metric for cooling-mode
operation and in terms of the heating seasonal performance factor
(HSPF) metric for heating-mode operation.
---------------------------------------------------------------------------
IEER factors in the efficiency of operating at part-load conditions
of 75-percent, 50-percent, and 25-percent of capacity, as well as the
efficiency at full-load. The IEER metric provides a more representative
measure of energy consumption in actual operation by weighting the
full-load and part-load efficiencies with the average amount of time
equipment spends operating at each load point. ASHRAE 90.1 has
specified an IEER metric for commercial air conditioning and heat pump
equipment since the 2008 Supplement to Standard 90.1-2007, effective
January 1, 2010.14 15 ASHRAE Standard 90.1-2013 included
minimum efficiency levels for both the EER and IEER of air-cooled VRF
multi-split systems and for the EER of water-source VRF multi-split
systems. ASHRAE Standard 90.1-2016 added IEER levels for water-source
VRF multi-split systems, including units with cooling capacity less
than 65,000 Btu/h. DOE notes that in addition to ASHRAE 90.1, both the
ENERGY STAR and Consortium for Energy Efficiency (CEE) programs use the
IEER metric for VRF systems.16 17
---------------------------------------------------------------------------
\14\ ASHRAE Standard 90.1 first specified a part-load
performance metric in the 2007 edition, which used integrated part
load value (IPLV).
\15\ ASHRAE, ASHRAE Addenda (2008 Supplement) (Available at:
http://www.ashrae.org/File%20Library/docLib/Public/20090317_90_1_2007_supplement.pdf).
\16\ ENERGY STAR Program Requirements, Product Specifications
for Light Commercial HVAC (Available at: https://www.energystar.gov/sites/default/files/specs//private/LC_HVAC_V2.2.pdf).
\17\ Consortium for Energy Efficiency, CEE Commercial Unitary AC
and HP Specification (Available at: http://www.cee1.org/files/CEE_CommHVAC_UnitarySpec2012.pdf).
---------------------------------------------------------------------------
On January 15, 2016, DOE published a direct final rule for energy
conservation standards for small, large, and very large air-cooled
commercial package air conditioners and heat pumps (CUACs and CUHPs),
which amended the energy conservation standards for CUACs and CUHPs and
changed the cooling efficiency metric from EER to IEER. 81 FR 2420.
Except possibly for ventilation, VRF multi-split systems serve the same
primary functions as CUACs and CUHPs (i.e., space heating and cooling
commercial buildings) and are used in a similarly wide range of
climatic conditions.
Because the vast majority of cooling and heating loads do not
demand operation at full-load, the full-season metric IEER may capture
the efficiency of VRF multi-split systems operating in the field more
realistically than does the full-load metric EER. DOE believes that the
publication of IEER ratings for most units on the market (as in AHRI's
Directory of Certified Product Performance for VRF multi-split
systems), as well as the inclusion of minimum efficiency levels and
test procedures for IEER of VRF multi-split systems in ASHRAE Standard
90.1-2016 and AHRI 1230-2010, respectively, demonstrate that IEER is an
industry-accepted metric for measuring efficiency of VRF multi-split
systems. For these reasons, DOE is considering replacing the current
EER metric for VRF multi-split systems with
[[Page 34446]]
the full-season IEER metric, or adding IEER in addition to EER. DOE's
ultimate decision will be impacted by the separate energy conservation
standards rulemaking considering the efficiency levels for VRF in
ASHRAE 90.1-2016.
Issue VRF-1: DOE requests comment on issues DOE should consider
regarding potentially using IEER as an efficiency metric for energy
conservation standards for air-cooled VRF multi-split systems with a
cooling capacity greater than or equal to 65,000 Btu/h and all water-
source VRF multi-split systems, so as to capture efficiency in part-
load operation.
2. Representativeness and Repeatability
Operation of VRF multi-split systems is inherently variable, and
DOE notes that the control systems of VRF multi-split systems can be
significantly more sophisticated than control systems in other
commercial HVAC systems. In order to achieve steady-state operation, it
is generally necessary for a manufacturer's representative that is
knowledgeable about the control system to be present during testing in
order to override the typical dynamic control and to set each
individual component at a fixed position or speed. It may be possible
to achieve ``full-load'' capacity and/or part-load operation in
different ways, all of which may be consistent with the test procedure
and manufacturer's installation instructions.
Issue VRF-2: DOE seeks comment on the settings required to be
reported in order for third-party laboratories to reproduce unit
performance in a rating test.
Section 6.3.4 of AHRI 1230-Draft requires that for air-cooled VRF
multi-split systems with a cooling capacity less than 65,000 Btu/h, at
least one indoor unit must be turned off for tests conducted at minimum
compressor speed. DOE also established a similar requirement for CACs
in the June 2016 CAC TP final rule. 81 FR 36992, 37038 (June 8, 2016).
However, AHRI 1230-Draft does not include a corresponding requirement
for equipment with a cooling capacity greater than or equal to 65,000
Btu/h or for water-source VRF multi-split systems. This requirement for
equipment less than 65,000 Btu/h considers the wide range of loads that
can occur in the field. However, DOE expects that load diversity would
also be an issue for larger-capacity VRF multi-split systems used in
commercial applications.
Issue VRF-3: DOE requests information and data on the field
operating states of indoor units of VRF multi-split systems when
operating at low compressor speeds (i.e., near 25-percent load).
Specifically, are there field data available that show operating states
of VRF multi-split systems at different load levels? Such data might
show what happens with indoor fan speeds and expansion devices of
indoor units at low load percentages, including whether any indoor fans
shut off, or whether any refrigerant flow control devices shut off
refrigerant flow, and how this might be affected by the user-accessible
control positions set for the indoor units. DOE is also interested in
whether indoor unit operation at low compressor speeds is different in
field application for VRF multi-split systems with cooling capacities
less than 65,000 Btu/h than those with capacities greater than or equal
to 65,000 Btu/h, and whether these trends follow at intermediate
compressor speeds as well. Further, DOE requests data that would show
the trends of total system capacity, total indoor air flow, and
sensible heat ratio as a function of compressor speed (e.g., percentage
of full-speed revolutions per minute) for laboratory rating tests of
typical VRF multi-split systems conducted either with one or no indoor
unit shut off at the lowest load point.
3. Test Method
a. Transient Testing: Oil Recovery Mode
AHRI 1230-Draft refers to ASHRAE 37-2009 for provisions for
transient tests, which are required when defrost interferes with
steady-state operation sufficiently frequently to prevent completion of
a steady-state test (see, for example, sections 8.8.2.5.1 and 8.8.2.5.2
of that test standard). Specific instructions are provided for how to
determine an average heating capacity for the transient test, with
different instructions depending on the number and completion of
defrost cycles. Tables 2a and 2b of ASHRAE 37-2009 specify the test
tolerances to be used when conducting a transient heating capacity
test.
VRF multi-split systems may periodically operate in an oil recovery
mode in order to return oil from the refrigeration loop to the
compressor. Section 5.1.3 of AHRI 1230-Draft requires that if a
manufacturer indicates that a VRF multi-split system is designed to
recover oil more frequently than every two hours of continuous
operation, the oil recovery mode shall be activated during testing, and
the additional power shall be included in the efficiency calculations.
However, there is no specific instruction in the AHRI 1230-Draft that
indicates how the additional power should be incorporated into the
efficiency metric. DOE expects that maintenance of steady-state
conditions may be affected during oil recovery mode and that, as a
result, some type of transient test procedure may be appropriate when
oil recovery mode happens during testing. However, AHRI 1230-Draft does
not specify use of the transient test for this case, and the ASHRAE 37-
2009 description of the transient test does not mention oil recovery.
DOE notes that VRF multi-split systems vary in the way they activate
oil recovery mode; some may initiate oil recovery mode at a set time
interval, and others may instead initiate oil recovery mode only when
the system detects that the oil level in the compressor has reached a
certain minimum level. DOE understands that unit performance may vary
with the oil level. Consequently, DOE is considering requiring all
measurements to be made within a certain time after the last oil
recovery to ensure repeatability between tests.
Issue VRF-4: DOE requests comment on the impact of oil recovery
mode, including power input and heating/cooling provided to space
during oil recovery mode. DOE also requests comment on whether any VRF
multi-split systems operate in oil recovery mode more frequently than
every two hours of continuous operation. For such systems, DOE requests
comment on whether the test method should be modified to address the
transient operation occurring during and after oil recovery, and how
this should be done. In addition, DOE requests comment on the
performance variation associated with oil level and whether all
measurements should be made within a certain time after the last oil
recovery. Lastly, DOE requests comment on how the energy use of oil
recovery mode might be addressed in the test procedure without imposing
excessive test burden.
b. Airflow Setting and Minimum External Static Pressure
DOE notes AHRI 1230-Draft contains one set of instructions for
setting the indoor air flow rates for systems with capacities less than
65,000 Btu/h (section 6.3.3.1) and another set for systems with
capacities larger than 65,000 Btu/h (section 6.4.1). It is not clear
why alternate approaches are required for different systems because the
indoor units generally do not differ by system capacity.
Issue VRF-5: DOE requests comment on whether there should be a
consistent approach for setting indoor airflow across all capacity
ranges of VRF multi-split systems.
[[Page 34447]]
c. Condenser Head Pressure Controls
Condenser head pressure controls regulate the flow of refrigerant
through the condenser and/or adjust operation of condenser fans to
prevent condenser pressures from dropping too low during low-ambient
operation. When employed, these controls ensure that the refrigerant
pressure is high enough to maintain adequate flow through refrigerant
expansion devices such as thermostatic expansion valves. In the
December 2015 CUAC test procedure final rule, DOE required that CUACs
and CUHPs equipped with head pressure controls have these controls
activated during testing. 80 FR 79655, 79660 (Dec. 23, 2015). For VRF
multi-split systems equipped with heat recovery, it is unclear whether
the head pressure would be elevated when one of the indoor units calls
for heating during cooling-based operation. It is also not clear how
the head pressure differs during cool outdoor conditions between units
with and without heat recovery function.
Issue VRF-6: DOE requests comment on the appropriateness of
requiring head pressure control activation during testing of VRF multi-
split systems. In addition, DOE requests comment on any methods to
control VRF multi-split systems during testing to ensure stable
operation with head pressure controls activated. Further, DOE requests
comment on any methods that could be added to the test procedure for
calculation of system efficiency of VRF multi-split systems if head
pressure controls prevent stable operation at low-ambient, part-load
conditions.
d. Air Volume Rate for Non-Ducted Indoor Units
DOE notes the following issues associated with testing multi-split
systems with free discharge air flow from the indoor unit (i.e.,
airflow provided directly from the indoor unit to the conditioned space
without the use of ducts). In testing, if a common duct is used for the
combined discharge airflow of multiple individual units, the airflow
for each individual unit cannot be verified. Second, even if the ESP is
set to zero--which is intended to replicate operation without ducting--
based on a measurement of downstream pressure in a discharge duct, this
does not always guarantee that flow is identical to free discharge
conditions, due to sensitivity of such in-duct pressure measurements to
the air movement in the duct. Finally, specification of unusually high
air flows for testing of free discharge in indoor units may boost
measured performance inconsistent with field operation. Section
6.3.3.1.1.3 of AHRI 1230-Draft added an upper limit on air flow per
capacity for non-ducted units for systems with capacity less than
65,000 Btu/h--the rated air volume for each indoor unit must not exceed
55 scfm per 1,000 Btu/h.\18\
---------------------------------------------------------------------------
\18\ DOE notes that test methods associated with the indoor
units of systems with capacity <65,000 Btu/h are relevant for
testing of systems with capacity >=65,000 Btu/h because the
capacities of the indoor units are comparable.
---------------------------------------------------------------------------
Issue VRF-7: DOE requests comment on how to confirm air flow for
each indoor unit individually when there is a common duct for each unit
and when there is potential deviation from free-discharge operation if
a discharge duct is connected. DOE also requests comment on whether
there should be an upper limit of air flow per capacity for non-ducted
units, such as the 55 scfm per 1,000 Btu/h limit in the AHRI 1230-
Draft.
e. Secondary Test Method
In AHRI 1230-Draft, ASHRAE 37-2009 is referenced as the test
procedure for both air-cooled and water-cooled units across all
capacities. Section 7.2.1 in ASHRAE 37-2009 requires a secondary test
method in addition to the primary method (i.e., indoor air enthalpy
method) for units having a total cooling capacity less than 135,000
Btu/h. ASHRAE 37-2009 provides multiple options for the secondary test
method. For units with a cooling capacity larger than 135,000 Btu/h,
section 7.2.2 of ASHRAE 37-2009 only requires a single method, but
provides multiple test method options.
Section 11.1.1.7 of AHRI 1230-Draft indicates the redundant
measurement verification method as an alternative to refrigerant
enthalpy method or outdoor enthalpy method when they cannot be
performed. However, the draft does not provide guidance on how to
determine whether the refrigerant enthalpy method or outdoor enthalpy
method can or cannot be performed. DOE is considering whether there are
other alternatives to the refrigerant enthalpy method or outdoor
enthalpy method (other than the duplicate measurement method), such as
the cooling condensate and indirect airflow measurement method.
Issue VRF-8: DOE requests comment on the methods generally used for
measurement of capacity when testing VRF multi-split systems and
whether the selection of methods differs between cooling and heating
tests. DOE requests comment on how to determine whether the refrigerant
enthalpy method or outdoor air enthalpy method (for units having a
total cooling capacity less than 135,000 Btu/h) can or cannot be
performed. DOE also requests comment on how to standardize the
selection of test methods for measuring the capacity of VRF multi-split
systems. Finally, DOE requests comment on whether there are issues with
achieving heat balance in part-load tests for VRF multi-split systems,
similar to those cited for variable speed CAC/HP, and if so, whether
there is sufficient assurance of proper measurement for all test points
of VRF multi-split systems if the heat balance is verified only for
full capacity.
f. Heat Recovery
VRF multi-split systems with heat recovery include a heat recovery
unit (sometimes referred to as a branch circuit controller) that
controls refrigerant flow between indoor units, allowing for
simultaneous cooling and heating operation. However, DOE believes that
VRF multi-split systems with the heat recovery capability may be able
to operate without the heat recovery unit attached, although in such
case, simultaneous heating and cooling would not be possible. It is not
clear in AHRI 1230-Draft whether VRF multi-split systems capable of
heat recovery must be tested with the heat recovery unit attached in
tests for determining EER, IEER, and COP. DOE seeks clarification on
industry practice for testing VRF multi-split systems with the heat
recovery feature because attachment of the heat recovery unit may
affect test results.
Issue VRF-9: DOE seeks comment on whether VRF multi-split systems
with the heat recovery feature can be operated without the heat
recovery unit attached, and if so, whether such systems are typically
tested for determining EER, IEER, and COP with the heat recovery unit
attached. Additionally, DOE seeks data showing the difference in test
results between having the heat recovery unit attached or not.
4. Representations
a. Tested Combination
AHRI specified requirements for tested combinations for systems
with capacities more than 65,000 Btu/h in section 6.2.2 of the AHRI
1230-Draft. The AHRI requirement specifies selecting standard 4-way
ceiling cassette indoor units with the smallest coil volume per nominal
capacity for non-ducted indoor units and selecting mid-static units for
ducted indoor units. DOE is aware that there is a range of ductless
indoor unit styles, which may have a range of efficiency
characteristics. In
[[Page 34448]]
addition, ducted systems may serve a range of external static
pressures.
A report by the Cadeo Group \19\ indicates that 4-way ceiling
cassettes are the most prevalent non-ducted indoor units. On the other
hand, while DOE notes that ducted units can be classified by the amount
of static pressure they produce as either low-static, mid-static, or
conventional-static units, DOE has no data indicating which ducted unit
style or static pressure classification is the most prevalent.
---------------------------------------------------------------------------
\19\ Cadeo Report. See docket: EERE-2017-BT-TP-0018. No. 2. The
report presents market share by VRF multi-split system equipment
class, based on confidential sales data given in interviews with
several major manufacturers of VRF multi-split equipment and DOE's
CCMS database.
---------------------------------------------------------------------------
Issue VRF-10: DOE requests comment and data on variation of system
efficiency related to indoor unit styles (both for ducted and non-
ducted indoor units). For example, for a system tested with non-ducted
units, what is the potential range of EER and/or IEER comparing the
most-efficient indoor units with the most energy-intensive indoor
units? DOE requests comment on its assumption that 4-way ceiling
cassettes are the most prevalent non-ducted indoor unit style. DOE also
requests data on the most prevalent style and static pressure
classification (low-static, mid-static, or conventional-static) of
ducted units.
b. Determination of Represented Values
DOE recognizes that non-ducted indoor units and ducted indoor units
operate at different levels of ESP and have different limitations on
ESP. The ESP affects the power consumed by the indoor fan, and,
therefore, also affects the measured efficiency of a VRF multi-split
system. DOE is considering requiring separate ratings for different ESP
levels to account for differences between ducted indoor units, non-
ducted indoor units, and possibly other distinctions in indoor units.
Issue VRF-11: DOE requests comment on how many distinctly
identifiable ESP levels are generally represented in a family of VRF
multi-split systems and what ESP levels are typical for VRF multi-split
systems. DOE also requests data that demonstrate how different ESP
levels affect measured efficiency for the system, both in terms of EER
and IEER.
Issue VRF-12: DOE requests comment on what specific topics
pertaining to the test procedure for VRF multi-split air conditioners
and heat pumps, in addition to the topics discussed previously, are not
fully or appropriately addressed in the docketed AHRI-1230-Draft.
E. Other Test Procedure Topics
In addition to the issues identified earlier in this document, DOE
welcomes comment on any other aspect of the existing test procedures
for commercial package air conditioning and heating equipment that is
the subject of this notice not already addressed by the specific areas
identified in this document. DOE particularly seeks information that
would improve the representativeness of the test procedures, as well as
information that would help DOE create a procedure that would limit
manufacturer test burden through streamlining or simplifying testing
requirements. Comments regarding repeatability and reproducibility are
also welcome.
DOE also requests feedback on any potential amendments to the
existing test procedures that could be considered to address impacts on
manufacturers, including small businesses. Regarding the Federal test
methods, DOE seeks comment on the degree to which the DOE test
procedures should consider and be harmonized with the most recent
relevant industry standards for the commercial package air conditioning
and heating equipment that is the subject of this notice, and whether
there are any changes to the Federal test methods that would provide
additional benefits to the public.
Additionally, DOE requests comment on whether the existing test
procedures limit a manufacturer's ability to provide additional
features to consumers on the commercial package air conditioning and
heating equipment that is the subject of this notice. DOE particularly
seeks information on how the test procedures could be amended to reduce
the cost of new or additional features and make it more likely that
such features are included on the equipment.
III. Submission of Comments
DOE invites all interested parties to submit in writing by August
24, 2017, comments, data, and information on matters addressed in this
notice and on other matters relevant to DOE's consideration of amended
test procedures for VRF multi-split systems, CRAC and DOAS equipment,
and water-cooled, evaporatively-cooled, and air-cooled commercial
unitary air conditioners (WCUACs, ECUACs, and ACUACs). These comments
and information will aid in the development of a test procedure NOPR
for the subject VRF multi-split systems, and CRAC, DOAS, WCUAC, ECUAC,
and ACUAC equipment, if DOE determines that amended test procedures may
be appropriate for these products.
Instructions: All submissions received must include the agency name
and docket number and/or RIN for this rulemaking. No telefacsimilies
(faxes) will be accepted.
Docket: The docket is available for review at https://www.regulations.gov, including Federal Register notices, comments, and
other supporting documents/materials. All documents in the docket are
listed in the https://www.regulations.gov index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
A link to the docket Web page can be found at: https://www.regulations.gov/docket?D=EERE-2017-BT-TP-0018. This Web page
contains a link to the docket for this notice on the https://www.regulations.gov Web site. The https://www.regulations.gov Web page
contains instructions on how to access all documents, including public
comments, in the docket.
For information on how to submit a comment, review other public
comments and the docket, or participate in the public meeting, contact
the Appliance Standards Program at (202) 586-6636 or by email:
[email protected]. DOE considers public
participation to be a very important part of the process for developing
test procedures and energy conservation standards. DOE actively
encourages the participation and interaction of the public during the
comment period at each stage of the rulemaking process. Interactions
with and between members of the public provide a balanced discussion of
the issues and assist DOE in the rulemaking process. Anyone who wishes
to be added to the DOE mailing list to receive future notices and
information about this rulemaking should contact Appliance and
Equipment Standards Program staff at (202) 586-6636 or by email at
[email protected].
Submitting comments via https://www.regulations.gov. The https://www.regulations.gov Web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to
[[Page 34449]]
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
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Do not submit to https://www.regulations.gov information for which
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through the Web site will waive any CBI claims for the information
submitted. For information on submitting CBI, see the Confidential
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DOE processes submissions made through https://www.regulations.gov
before posting. Normally, comments will be posted within a few days of
being submitted. However, if large volumes of comments are being
processed simultaneously, your comment may not be viewable for up to
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comment.
Submitting comments via email, hand delivery/courier, or postal
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or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
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Include contact information each time you submit comments, data,
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delivery/courier, please provide all items on a CD, if feasible, in
which case it is not necessary to submit printed copies.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
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electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
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time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
One copy of the document marked ``confidential'' including all the
information believed to be confidential, and one copy of the document
marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items, (2) whether and why such items are customarily treated as
confidential within the industry, (3) whether the information is
generally known by or available from other sources, (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality, (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure, (6) when such information might lose its
confidential character due to the passage of time, and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
DOE considers public participation to be a very important part of
the process for developing test procedures and energy conservation
standards. DOE actively encourages the participation and interaction of
the public during the comment period in each stage of the rulemaking
process. Interactions with and between members of the public provide a
balanced discussion of the issues and assist DOE in the rulemaking
process. Anyone who wishes to be added to the DOE mailing list to
receive future notices and information about this rulemaking should
contact Appliance and Equipment Standards Program staff at (202) 586-
6636 or via email at [email protected].
Issued in Washington, DC, on July 11, 2017.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
[FR Doc. 2017-15580 Filed 7-24-17; 8:45 am]
BILLING CODE 6450-01-P