[Federal Register Volume 84, Number 154 (Friday, August 9, 2019)]
[Notices]
[Pages 39274-39286]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-17083]
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DEPARTMENT OF ENERGY
[Case Number 2018-004; EERE-2018-BT-WAV-0007]
Energy Conservation Program: Petition for Waiver of LG
Electronics USA, Inc. From the Department of Energy Portable Air
Conditioner Test Procedure and Notice of Grant of Interim Waiver
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver and grant of an interim waiver,
and request for comments.
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SUMMARY: This document announces receipt of and publishes a petition
for waiver from LG Electronics USA, Inc. (``LG''), which seeks an
exemption from the U.S. Department of Energy (``DOE'') test procedure
used for determining the efficiency of specified portable air
conditioner basic models. LG seeks to use an alternate test procedure
to address issues involved in testing the basic models identified in
its petition. According to LG, the current DOE test procedure for
single-duct portable air conditioners does not take into account the
benefits of portable air conditioners that use variable-speed
compressors (``variable-speed portable air conditioners''), due to
their part-load performance characteristics, and misrepresents their
actual energy consumption. LG requests use of an alternate test
procedure, under which the test unit's final combined energy efficiency
ratio (``CEER'') metric would be calculated by multiplying the unit's
measured CEER value (as measured according to the existing procedure
for a single-duct portable air conditioner) by a ``performance
adjustment factor.'' The performance adjustment factor would reflect
the performance improvement associated with avoiding
[[Page 39275]]
cycling losses as a result of implementing a variable-speed compressor,
when tested under the two rating conditions currently used for testing
dual-duct portable air conditioners. DOE grants LG an interim waiver
from DOE's portable air conditioner test procedure for the basic models
listed in the interim waiver, subject to use of the alternate test
procedure as set forth in the Interim Waiver Order. DOE solicits
comments, data, and information concerning LG's petition and its
suggested alternate test procedure to inform its final decision on LG's
waiver request.
DATES: Written comments and information are requested and will be
accepted on or before September 9, 2019.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at http://www.regulations.gov.
Alternatively, interested persons may submit comments, identified by
case number ``2018-004'', and Docket number ``EERE-2018-BT-WAV-0007,''
by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
Email: [email protected]. Include the case number
[Case No. 2018-004] in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program.
Department of Energy, Office of Energy Efficiency and Renewable Energy,
Building Technologies Office, Mailstop EE-5B, Petition for Waiver Case
No. 2018-004, 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. 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 this
process, see section V of this document.
Docket: The docket, which includes Federal Register notices,
comments, and other supporting documents/materials, is available for
review at http://www.regulations.gov. All documents in the docket are
listed in the http://www.regulations.gov index. However, some documents
listed in the index, such as those containing information that is
exempt from public disclosure, may not be publicly available.
The docket web page can be found at http://www.regulations.gov/docket?D=EERE-2018-BT-WAV-0007. The docket web page contains simple
instruction on how to access all documents, including public comments,
in the docket. See section V for information on how to submit comments
through http://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Ms. Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW,
Washington, DC 20585-0121. Email: [email protected].
Ms. Sarah Butler, U.S. Department of Energy, Office of the General
Counsel, Mail Stop GC-33, Forrestal Building, 1000 Independence Avenue
SW, Washington, DC 20585-0103. Telephone: (202) 586-1777. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
I. Background and Authority
The Energy Policy and Conservation Act of 1975, as amended
(``EPCA''),\1\ among other things, authorizes DOE to regulate the
energy efficiency of a number of consumer products and industrial
equipment. (42 U.S.C. 6291-6317) Title III, Part B \2\ of EPCA
established the Energy Conservation Program for Consumer Products Other
Than Automobiles. In addition to specifying a list of covered products
and industrial equipment, EPCA contains provisions that enable the
Secretary of Energy to classify additional types of consumer products
as covered products. (42 U.S.C. 6292(a)(20)) In a final determination
of coverage published in the Federal Register on April 18, 2016 (the
``April 2016 Final Coverage Determination''), DOE classified portable
air conditioners as covered products under EPCA. 81 FR 22514. The test
procedure for portable air conditioners is contained in the Code of
Federal Regulations (``CFR'') at 10 CFR part 430, subpart B, appendix
CC (``appendix CC'').
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\1\ All references to EPCA in this document refer to the statute
as amended through America's Water Infrastructure Act of 2018,
Public Law 115-270 (October 23, 2018).
\2\ For editorial reasons, upon codification in the U.S. Code,
Part B was re-designated Part A.
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Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures
DOE is required to follow when prescribing or amending test procedures
for covered products. EPCA requires that any test procedures prescribed
or amended under this section must be reasonably designed to produce
test results which reflect energy efficiency, energy use or estimated
annual operating cost of a covered product during a representative
average use cycle or period of use and requires that test procedures
not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3))
Under 10 CFR 430.27, any interested person may submit a petition
for waiver from DOE's test procedure requirements. DOE will grant a
waiver from the test procedure requirements if DOE determines either
that the basic model for which the waiver was requested contains a
design characteristic that prevents testing of the basic model
according to the prescribed test procedures, or that the prescribed
test procedures evaluate the basic model in a manner so
unrepresentative of its true energy consumption characteristics as to
provide materially inaccurate comparative data. 10 CFR 430.27(f)(2).
DOE may grant the waiver subject to conditions, including adherence to
an alternate test procedure. Id.
As soon as practicable after the granting of any waiver, DOE will
publish in the Federal Register a notice of proposed rulemaking to
amend its regulations so as to eliminate any need for the continuation
of such waiver. 10 CFR 430.27(l). As soon thereafter as practicable,
DOE will publish in the Federal Register a final rule. Id.
The waiver process also provides that DOE may grant an interim
waiver if it appears likely that the underlying petition for waiver
will be granted and/or if DOE determines that it would be desirable for
public policy reasons to grant immediate relief pending a determination
on the underlying petition for waiver. 10 CFR 430.27(e)(2). Within one
year of issuance of an interim waiver, DOE will either: (i) Publish in
the Federal Register a determination on the petition for waiver; or
(ii) publish in the Federal Register a new or amended test procedure
that addresses the issues presented in the waiver. 10 CFR 430.27(h)(1).
When DOE amends the test procedure to address the issues presented
in a waiver, the waiver will automatically terminate on the date on
which use of that test procedure is required to demonstrate compliance.
10 CFR 430.27(h)(2).
[[Page 39276]]
II. LG's Petition for Waiver and Petition for Interim Waiver
On May 15, 2018, LG filed a petition for waiver and a petition for
interim waiver from the test procedure for portable air conditioners,
set forth in appendix CC. In the petition, LG requested relief for the
following portable air conditioner basic models: LP1419IVSM,
LP1419HVSM, LP1219IVSM, LP1019IVSM, and LP0819IVSM.\3\ LG notes that
the current DOE test procedure for portable air conditioners requires
testing dual-duct portable air conditioners under two operating
conditions, one measuring peak-load performance (i.e., at a high-
temperature outdoor operating condition) and another measuring a
reduced-load performance (i.e., at a lower outdoor temperature
operating condition). For single-duct portable air conditioners, the
test procedure requires testing at only the high-temperature outdoor
operating condition. LG asserts that the current DOE test procedure for
single-duct portable air conditioners does not take into account the
specific performance and efficiency benefits associated with single-
duct variable-speed portable air conditioners under part-load
conditions.
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\3\ LG provided these basic model numbers in its May 15, 2018
petition.
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LG stated that single-duct variable-speed portable air conditioners
constantly use frequency controls to adjust the compressor rotation
speed to maintain the desired temperature in the home without turning
the motor on and off; that the compressor responds automatically to
surrounding conditions to operate in the most efficient possible
manner; and that this results in both significant energy savings and
faster cooling compared to a portable air conditioner without a
variable-speed compressor. LG asserted that, because the DOE test
procedure does not account for the general part-load performance
benefits of single-duct variable-speed portable air conditioners or
properly account for the favorable difference in cycling losses for
single-duct variable-speed portable air conditioners resulting from use
of variable-speed technology, the results of the test procedure are not
representative of the actual energy consumption of single-duct
variable-speed portable air conditioners.
LG also requested an interim waiver from the existing DOE test
procedure. DOE will grant an interim waiver if it appears likely that
the petition for waiver will be granted, and/or if DOE determines that
it would be desirable for public policy reasons to grant immediate
relief pending a determination of the petition for waiver. See 10 CFR
430.27(e)(2).
DOE understands that, absent an interim waiver, the test procedure
does not accurately measure the energy consumption of single-duct
variable-speed portable air conditioners, and without waiver relief,
the test results would not reflect the part-load characteristics of the
basic models listed above.
III. Requested Alternate Test Procedure
EPCA requires that manufacturers use DOE test procedures when
making representations about the energy consumption and energy
consumption costs of covered products. (42 U.S.C. 6293(c)) Consistent
representations are important when making representations about the
energy efficiency of products, including when demonstrating compliance
with applicable DOE energy conservation standards. Pursuant to its
regulations at 10 CFR 430.27, and after consideration of public
comments on the petition, DOE may establish in a subsequent Decision
and Order an alternate test procedure for the basic models addressed by
the interim waiver.
In its petition, LG requests testing the basic models listed in its
petition according to the test procedure for portable air conditioners
prescribed by DOE in appendix CC, except that single-duct variable-
speed portable air conditioners would be tested at both the high- and
low-temperature outdoor operating conditions to measure a weighted-
average combined energy efficiency ratio (CEER). LG also suggests an
additional set of calculations to model the CEER of a theoretical
comparable single-speed portable air conditioner with and without
cycling losses.\4\ From these results, a ``performance adjustment
factor'' would be calculated, representing the performance improvement
associated with avoiding cycling losses. The performance adjustment
factor would then be multiplied by the measured CEER value for the
variable-speed portable air conditioner according to appendix CC to
determine the test unit's final rated CEER value. LG states that this
approach takes into account performance and efficiency improvements
associated with single-duct variable-speed portable air conditioners as
compared to single-duct portable air conditioners with single-speed
compressors.
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\4\ In its suggested alternate test procedure, LG included
provisions regarding dual-duct variable-speed portable air
conditioners. However, the basic models specified in LG's petition
for waiver and petition for interim waiver are single-duct models
only. As such, the alternate test procedure specified by DOE
addresses only the single-duct variable-speed portable air
conditioners listed by LG.
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IV. Grant of an Interim Waiver
DOE has reviewed the materials submitted in LG's petition. DOE has
been unable to identify or review any marketing materials, website, or
brochure for basic models LP1419IVSM, LP1419HVSM, LP1219IVSM,
LP1019IVSM, and LP0819IVSM because they currently are not available in
the U.S. market. The materials submitted support LG's assertion of the
part-load characteristics of the single-duct variable-speed portable
air conditioners and that the DOE test procedure may yield results that
are unrepresentative of their true energy consumption characteristics.
In particular, the DOE test procedure does not capture the relative
efficiency improvements due to cycling loss avoidance that can be
achieved by single-duct variable-speed portable air conditioners over a
range of operating conditions compared to single-speed portable air
conditioners. Without an alternate test procedure, the CEER values of
single-duct variable-speed portable air conditioners would suggest that
such portable air conditioners would consume at least as much energy
annually as a theoretical comparable single-speed portable air
conditioner, despite the anticipated benefits of improved performance
under part-load conditions. DOE has reviewed the alternate procedure
suggested by LG, along with additional performance modeling and
analysis performed by DOE. Based on this review it appears that the
suggested alternate test procedure will allow for the generally
accurate measurement of efficiency of the specified basic models of
single-duct variable-speed potable air conditioners, with certain
additional requirements. First, the alternate test procedure provides
compressor speed nomenclature and definitions that are derived from
those in industry standards for testing consumer central air
conditioning products with variable-speed compressors, with additional
specificity for the low compressor speed definition that ensures the
portable air conditioner provides adequate cooling capacity under
reduced loads based on the expected load at those conditions.\5\
[[Page 39277]]
Second, LG must maintain the compressor speed required for each test
condition in accordance with the instructions LG has provided to
DOE.6 7
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\5\ The compressor speed nomenclature and definition
clarifications are derived from Air-Conditioning, Heating, and
Refrigeration Institute Standard (AHRI) 210/240-2017, ``Performance
Rating of Unitary Air-conditioning & Air-source Heat Pump
Equipment'', and adapted to be applicable to portable ACs. Equation
11.60 in AHRI 210/240-2017 relates the building load to an AC's
full-load cooling capacity and outdoor temperature, and assumes
full-load operation at 98 [deg]F outdoor temperature. DOE adjusted
(i.e. normalized) this equation to reflect full-load operation at 95
[deg]F outdoor temperature, to provide consistency with the full-
load test condition for portable ACs. Using the adjusted equation
suggests that the representative cooling load at the 83 [deg]F
rating condition would be 60 percent of the full-load cooling
capacity for portable air conditioners. DOE recognizes that
variable-speed portable ACs may use compressors that vary their
speed in discrete steps and may not be able to operate at a speed
that provides exactly 60 percent cooling capacity; therefore, the
defined cooling capacity associated with the low compressor speed is
presented as a 10-percent range rather than a single value. 60
percent cooling load is the upper bound of the 10-percent range
defining the cooling capacity associated with the lower compressor
speed (i.e., the range is defined as 50 to 60 percent). This ensures
that the variable-speed portable AC is capable of matching the
representative cooling load (60 percent of the maximum) at the 83
[deg]F rating condition, while providing the performance benefits
associated with variable-speed operation. In contrast, if the 10-
percent range were to be defined as, for example, 55 to 65 percent
(with 60 percent as the midpoint), a variable-speed portable AC
could be tested at 63 percent, for example, without demonstrating
the capability to maintain variable-speed performance down to 60
percent.
\6\ Pursuant to 10 CFR 1004.11, if the manufacturer submits
information that it believes to be confidential and exempt by law
from public disclosure, the manufacturer should submit via email,
postal mail, or hand delivery 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. DOE will make its own determination about the
confidential status of the information and treat it according to its
determination.
\7\ The instructions provided by LG were marked as confidential
and, as such, the instructions will be treated as confidential. The
document is located in the docket at https://www.regulations.gov/document?D=EERE-2018-BT-WAV-0007.
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Specifically, DOE has found that the suggested alternate test
procedure will produce final CEER values for the single-duct variable-
speed portable air conditioners that will reflect the average
performance improvement associated with variable-speed compressors as
compared to theoretical comparable single-speed portable air
conditioners under the same test conditions. Consequently, it appears
likely that LG's petition for waiver will be granted. Furthermore, DOE
has determined that it is desirable for public policy reasons to grant
LG immediate relief pending a determination of the petition for waiver.
For the reasons stated, DOE has granted an interim waiver to LG for
the specified portable air conditioner basic models in LG's petition.
Therefore, DOE has issued an Order stating:
(1) LG must test the following portable air conditioner basic
models with the alternate test procedure set forth in paragraph (2):
------------------------------------------------------------------------
Brand Basic model
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LG Electronics USA, Inc................. LP1419IVSM
LG Electronics USA, Inc................. LP1419HVSM
LG Electronics USA, Inc................. LP1219IVSM
LG Electronics USA, Inc................. LP1019IVSM
LG Electronics USA, Inc................. LP0819IVSM
------------------------------------------------------------------------
(2) The alternate test procedure for the LG basic models referenced
in paragraph (1) is the test procedure for portable air conditioners
prescribed by DOE at appendix CC to subpart B of 10 CFR part 430
(Appendix CC), except: (i) Determine the combined energy efficiency
ratio (CEER) as detailed below, and (ii) calculate the estimated annual
operating cost in 10 CFR 430.23(dd)(2) as detailed below. In addition,
for each basic model listed in paragraph (1), maintain the compressor
speeds at each test condition, and set the control settings used for
the variable components, according to the instructions submitted to DOE
by LG. Upon the compliance date of any new energy conservation
standards for portable air conditioners, LG must report product
specific information pursuant to 10 CFR 429.12(b)(13) and 10 CFR
429.62(b). All other requirements of Appendix CC and DOE's regulations
remain applicable. In 10 CFR 430.23, in paragraph (dd) revise paragraph
(2) to read as follows:
(2) Determine the estimated annual operating cost for a single-duct
variable-speed portable air conditioner, expressed in dollars per year,
by multiplying the following two factors:
(i) The sum of AEC95 multiplied by 0.2, AEC83
multiplied by 0.8, and AECT as measured in accordance with
section 5.3 of appendix CC of this subpart; and
(ii) A representative average unit cost of electrical energy in
dollars per kilowatt-hour as provided by the Secretary.
(iii) Round the resulting product to the nearest dollar per year.
In Appendix CC:
Add in Section 2, Definitions:
2.11 Single-speed means a type of portable air conditioner that
cannot automatically adjust the compressor speed, based on detected
conditions.
2.12 Variable-speed means a type of portable air conditioner that
can automatically adjust the compressor speed, based on detected
conditions.
2.13 Full compressor speed (full) means the compressor speed
specified by the manufacturer at which the unit operates at full load
testing conditions.
2.14 Low compressor speed (low) means the compressor speed
specified by the manufacturer at which the unit operates at low load
test conditions, such that the measured cooling capacity at Condition B
in Table 1 of this appendix, i.e., Capacity83, is not less
than 50 percent and not greater than 60 percent of the measured cooling
capacity with the full compressor speed at Condition A in Table 1 of
this appendix, i.e., Capacity95.
Add to the end of Section 3.1.2, Control settings:
Set the compressor speed during cooling mode testing as described
in section 4.1, as amended by this interim waiver.
Replace Section 4.1, Cooling mode with the following:
Cooling mode. Measure the indoor room cooling capacity and overall
power input in cooling mode in accordance with Section 7.1.b and 7.1.c
of ANSI/AHAM PAC-1-2015 (incorporated by reference; see Sec. 430.3),
respectively. Determine the test duration in accordance with Section
8.7 of ASHRAE Standard 37-2009 (incorporated by reference; Sec.
430.3). Apply the test conditions presented in Table 1 of this appendix
instead of the test conditions in Table 3 of ANSI/AHAM PAC-1-2015.
Measure the indoor room cooling capacity and overall power input in
accordance with ambient conditions for Test Configuration 3, Condition
A (Capacity95, P95) in Table 1 of this appendix,
with the compressor speed set to full, for the duration of cooling mode
testing, and then measure the indoor room cooling capacity and overall
power input a second time in accordance with the ambient conditions for
Test Configuration 3, Condition B (Capacity83,
P83) in Table 1 of this appendix, with the compressor speed
set to low, for the duration of cooling mode testing. Set the
compressor speed required for each test condition in accordance with
instructions provided to DOE. Note that for the purposes of this
cooling mode test procedure, evaporator inlet air is considered the
``indoor air'' of the conditioned space and condenser inlet air is
considered the ``outdoor air'' outside of the conditioned space.
[[Page 39278]]
Table 1--Evaporator (Indoor) and Condenser (Outdoor) Inlet Test Conditions
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Evaporator inlet air, [deg]F Condenser inlet air, [deg]F
([deg]C) ([deg]C)
Test configuration ---------------------------------------------------------------
Dry bulb Wet bulb Dry bulb Wet bulb
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3 (Condition A)................................. 80 (26.7) 67 (19.4) 95 (35.0) 75 (23.9)
3 (Condition B)................................. 80 (26.7) 67 (19.4) 83 (28.3) 67.5 (19.7)
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Revise Section 4.1.1, Duct Heat Transfer following ``Calculate the
total heat transferred from the surface of the condenser exhaust duct
to the indoor conditioned space while operating in cooling mode for the
outdoor test conditions in Table 1 of this appendix, as follows.'' to
read as follows:
Qduct_95 = h x Aduct x (Tduct_95-
Tei)
Qduct_83 = h x Aduct x (Tduct_83-
Tei)
Where:
Qduct_95 and Qduct_83 = the total heat
transferred from the condenser exhaust duct to the indoor
conditioned space in cooling mode, in Btu/h, when tested according
to the 95 [deg]F dry-bulb and 83 [deg]F dry-bulb outdoor test
conditions in Table 1 of this appendix, respectively.
h = convection coefficient, 3 Btu/h per square foot per [deg]F.
Aduct = surface area of the condenser exhaust duct, in
square feet.
Tduct_95 and Tduct_83 = average surface
temperature for the condenser exhaust duct, as measured during
testing according to the two outdoor test conditions in Table 1 of
this appendix, in [deg]F.
Tei = average evaporator inlet air dry-bulb temperature,
in [deg]F.
Replace Section 4.1.2, Infiltration Air Heat Transfer with the
following:
Infiltration Air Heat Transfer. Calculate the heat contribution
from infiltration air for both cooling mode outdoor test conditions, as
described in this section. Calculate the dry air mass flow rate of
infiltration air according to the following equations:
[GRAPHIC] [TIFF OMITTED] TN09AU19.091
Where:
m95 and m83 = dry air mass flow rate of
infiltration air, as calculated based on testing according to the
test conditions in Table 1 of this appendix, in lb/m.
Vco_95 and Vco_83 = average volumetric flow
rate of the condenser outlet air during cooling mode testing at the
95 [deg]F and 83 [deg]F dry-bulb outdoor conditions, respectively,
in cubic feet per minute (cfm), as determined in section 4.1 of this
appendix.
Vci_95, and Vci_83 = average volumetric flow
rate of the condenser inlet air during cooling mode testing at the
95 [deg]F and 83 [deg]F dry-bulb outdoor conditions, respectively,
in cfm, as determined in section 4.1 of this appendix.
[rho]co_95 and [rho]co_83 = average density of
the condenser outlet air during cooling mode testing at the 95
[deg]F and 83 [deg]F dry-bulb outdoor conditions, respectively, in
pounds mass per cubic foot (lbm/ft\3\), as determined in
section 4.1 of this appendix.
[rho]ci_95, and [rho]ci_83 = average density
of the condenser inlet air during cooling mode testing at the 95
[deg]F and 83 [deg]F dry-bulb outdoor conditions, respectively, in
lbm/ft\3\, as determined in section 4.1 of this appendix.
[omega]co_95 and [omega]co_83 = average
humidity ratio of condenser outlet air during cooling mode testing
at the 95 [deg]F and 83 [deg]F dry-bulb outdoor conditions,
respectively, in pounds mass of water vapor per pounds mass of dry
air (lbw/lbda), as determined in section 4.1
of this appendix.
[omega]ci_95 and [omega]ci_83 = average
humidity ratio of condenser inlet air during cooling mode testing at
the 95 [deg]F and 83 [deg]F dry-bulb outdoor conditions,
respectively, in lbw/lbda, as determined in
section 4.1 of this appendix.
Replace Section 5.1, Adjusted Cooling Capacity with the following:
Adjusted Cooling Capacity. Calculate the adjusted cooling
capacities for portable air conditioners, ACC95 and
ACC83, expressed in Btu/h, according to the following
equations.
ACC83 = Capacity95-Qduct_95-
Qinfiltration_95
ACC83 = Capacity83-Qduct_83-
Qinfiltration_83
Where:
Capacity95 and Capacity83 = cooling capacity
measured in section 4.1 of this appendix.
Qduct_95 and Qduct_83 = duct heat transfer
while operating in cooling mode, calculated in section 4.1.1 of this
appendix.
Qinfiltration_95 and Qinfiltration_83 = total
infiltration air heat transfer in cooling mode, calculated in
section 4.1.2 of this appendix
Replace Section 5.3, Annual Energy Consumption with the following:
Annual Energy Consumption. Calculate the annual energy consumption
in each operating mode, AECm, expressed in kilowatt-hours
per year (kWh/year). Use the following annual hours of operation for
each mode:
------------------------------------------------------------------------
Annual
Operating mode operating
hours
------------------------------------------------------------------------
Cooling Mode, Dual-Duct 95 [deg]F \1\................... 750
Cooling Mode, Dual-Duct 83 [deg]F \1\................... 750
Off-Cycle............................................... 880
Inactive or Off......................................... 1,355
------------------------------------------------------------------------
\1\ These operating mode hours are for the purposes of calculating
annual energy consumption under different ambient conditions and are
not a division of the total cooling mode operating hours. The total
cooling mode operating hours are 750 hours.
AECm = Pm x tm x 0.001
Where:
AECm = annual energy consumption in each mode, in kWh/
year.
Pm = average power in each mode, in watts.
m represents the operating mode (``95'' and ``83'' cooling mode at
the 95 [deg]F and 83 [deg]F dry-bulb outdoor conditions,
respectively, ``oc'' off-cycle, and ``ia'' inactive or ``om'' off
mode).
tm = number of annual operating time in each mode, in
hours.
0.001 kWh/Wh = conversion factor from watt-hours to kilowatt-hours.
\Total annual energy consumption in all modes except cooling, is
calculated according to:
[[Page 39279]]
[GRAPHIC] [TIFF OMITTED] TN09AU19.092
Where:
AECT = total annual energy consumption attributed to all
modes except cooling, in kWh/year;
AECm = total annual energy consumption in each mode, in
kWh/year.
m represents the operating modes included in AECT (``oc''
off-cycle, and ``im'' inactive or ``om'' off mode).
Replace Section 5.4, Combined Energy Efficiency Ratio with the
following:
Combined Energy Efficiency Ratio. Using the annual operating hours,
as outlined in section 5.3 of this appendix, calculate the combined
energy efficiency ratio, CEERVS, expressed in Btu/Wh,
according to the following:
[GRAPHIC] [TIFF OMITTED] TN09AU19.103
Where:
CEERVS = combined energy efficiency ratio for the
variable-speed portable air conditioner, in Btu/Wh.
ACC95 and ACC83 = adjusted cooling capacity,
tested at the 95 [deg]F and 83 [deg]F dry-bulb outdoor conditions in
Table 1 of this appendix, in Btu/h, calculated in section 5.1 of
this appendix.
AEC95 and AEC83 = annual energy consumption
for the two cooling mode test conditions in Table 1 of this
appendix, in kWh/year, calculated in section 5.3 of this appendix.
AECT = total annual energy consumption attributed to all
modes except cooling, in kWh/year, calculated in section 5.3 of this
appendix.
750 = number of cooling mode hours per year
0.001 kWh/Wh = conversion factor for watt-hours to kilowatt-hours.
0.2 = weighting factor for the Condition A test.
0.8 = weighting factor for the Condition B test.
Add after Section 5.4, Combined Energy Efficiency Ratio:
5.5 Adjustment of the Combined Energy Efficiency Ratio. Adjust the
combined energy efficiency ratio as follows.
5.5.1 Theoretical Comparable Single-Speed Portable Air Conditioner
Cooling Capacity and Power at the Lower Outdoor Test Condition.
Calculate the cooling capacity and cooling capacity with cycling
losses, expressed in British thermal units per hour (Btu/h), and
electrical power input, expressed in watts, for a theoretical
comparable single-speed portable air conditioner at the 83 [deg]F dry-
bulb outdoor conditions (Condition B in Table 1 of this appendix). A
theoretical comparable single-speed portable air conditioner has the
same cooling capacity and electrical power input, with no cycling
losses, as the single-duct variable-speed portable air conditioner
under test at Condition A in Table 1 of this appendix.
Capacity83_SS = Capacity95
Capacity83_SS_CLF = Capacity95 x CLF
P83_SS = P95
Where:
Capacity83_SS = theoretical comparable single-speed
portable air conditioner cooling capacity, in Btu/h, calculated for
Condition B in Table 1 of this appendix.
Capacity83_SS_CLF = theoretical comparable single-speed
portable air conditioner cooling capacity with cycling losses, in
Btu/h, calculated for Condition B in Table 1 of this appendix.
Capacity95 = cooling capacity, in Btu/h, determined in
section 4.1 of this appendix for Condition A in Table 1 of this
appendix.
P83_SS = theoretical comparable single-speed portable air
conditioner electrical power input, in watts, calculated for
Condition B in Table 1 of this appendix.
P95 = electrical power input, in watts, determined in
section 4.1 of this appendix for Condition A in Table 1 of this
appendix.
CLF = cycling loss factor for Condition B in Table 1 of this
appendix, 0.875.
5.5.2 Duct Heat Transfer for a Theoretical Comparable Single-Speed
Portable Air Conditioner at the Lower Outdoor Test Condition. Calculate
the condenser exhaust duct heat transfer to the conditioned space for a
theoretical comparable single-speed portable air conditioner at the 83
[deg]F dry-bulb outdoor conditions (Condition B in Table 1 of this
appendix), as follows:
Qduct_83_SS = h x Aduct x (Tduct_95-
Tei)
Where:
Qduct_83_SS = total heat transferred from the ducts to
the indoor conditioned space in cooling mode, in Btu/h, for a
theoretical comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix.
h = convection coefficient, 3 Btu/h per square foot per [deg]F.
Aduct = surface area of the condenser exhaust duct, in
square feet, as calculated in section 4.1.1 of this appendix.
Tduct_95 = average surface temperature for the condenser
exhaust duct, as measured during testing at Condition A in Table 1
of this appendix, in [deg]F.
Tei = average evaporator inlet air dry-bulb temperature,
in [deg]F.
5.5.3 Infiltration Air Heat Transfer for a Theoretical Comparable
Single-Speed Portable Air Conditioner at the Lower Outdoor Test
Condition. Calculate the heat contribution from infiltration air for a
theoretical comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix, as described in this section.
Calculate the dry air mass flow rate of infiltration air according to
the following equations:
[GRAPHIC] [TIFF OMITTED] TN09AU19.093
Where:
m83_SS = dry air mass flow rate of infiltration air for a
theoretical comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix, in lb/m.
Vco_95 = actual average volumetric flow rate of the
condenser outlet air during cooling mode testing at Condition A in
Table 1 of this appendix, in cubic feet per minute (cfm), as
determined in section 4.1 of this appendix.
[rho]co_95 = actual average density of the condenser
outlet air during cooling mode
[[Page 39280]]
testing at Condition A in Table 1 of this appendix, in
lbm/ft\3\, as determined in section 4.1 of this appendix.
[omega]co_95= average humidity ratio of condenser outlet
air during cooling mode testing at Condition A in Table 1 of this
appendix, in pounds mass of water vapor per pounds mass of dry air
(lbw/lbda), as determined in section 4.1 of
this appendix.
Calculate the sensible component of infiltration air heat
contribution for a theoretical comparable single-speed portable air
conditioner at Condition B in Table 1 of this appendix as follows:
Qs_83_SS = m83_SS x 60 x [(0.24 x
(Tia_83 - Tindoor)) + (0.444 x
([omega]ia_83 x Tia_83 - [omega]indoor
x Tindoor))]
Where:
Qs_83_SS = sensible heat added to the room by
infiltration air for a theoretical comparable single-speed portable
air conditioner, at Condition B in Table 1 of this appendix, in Btu/
h.
0.24 Btu/lbm - [deg]F = specific heat of dry air.
0.444 Btu/lbm - [deg]F = specific heat of water vapor.
Tindoor = indoor chamber dry-bulb temperature, 80 [deg]F.
Tia_95 and Tia_83 = infiltration air dry-bulb
temperatures for Condition A and Condition B in Table 1 of this
appendix, 95 [deg]F and 83 [deg]F, respectively.
[omega]ia_95 and [omega]ia_83 = humidity
ratios of the infiltration air at Condition A and Condition B in
Table 1 of this appendix, 0.0141 and 0.01086 lbw/
lbda, respectively.
[omega]indoor = humidity ratio of the indoor chamber air,
0.0112 lbw/lbda.
60 = conversion factor from minutes to hours.
m83_SS as previously defined in this section.
Calculate the latent component of infiltration air heat
contribution for a theoretical comparable single-speed portable air
conditioner at Condition B in Table 1 of this appendix as follows:
Ql_83_SS = m83_SS x 60 x 1061 x
([omega]ia_83-0.0112)
Where:
Ql_83_SS = latent heat added to the room by infiltration
air for a theoretical comparable single-speed portable air
conditioner, at Condition B in Table 1 of this appendix, in Btu/h.
1061 Btu/lbm = latent heat of vaporization for water
vapor.
0.0112 lbw/lbda = humidity ratio of the indoor
chamber air.
60 = conversion factor from minutes to hours.
m83_SS, [omega]ia_95, and
[omega]ia_83 as previously defined in this section.
The total heat contribution of the infiltration air for a
theoretical comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix is the sum of the sensible and
latent heat calculated above in this section:
Qinfiltration_83_SS = Qs_83_SS +
Ql_83_SS
Where:
Qinfiltration_83_SS = total infiltration air heat in
cooling mode for a theoretical comparable single-speed portable air
conditioner at Condition B in Table 1 of this appendix, in Btu/h.
Qs_83_SS, Ql_83_SS as previously defined.
5.5.4 Adjusted Cooling Capacity for a Theoretical Comparable
Single-Speed Portable Air Conditioner at the Lower Outdoor Test
Condition. Calculate the adjusted cooling capacity for a theoretical
comparable single-speed portable air conditioner at Condition B in
Table 1 of this appendix with and without cycling losses,
ACC83_SS and ACC83_SS_CLF, respectively,
expressed in Btu/h, according to the following equations:
ACC83_SS = Capacity83_SS - Qduct_83_SS
- Qinfiltration_83_SS
ACC83_SS_CLF = Capacity83_SS_CLF -
Qduct_83_SS - Qinfiltration_83_SS
Where:
ACC83_SS and ACC83_SS_CLF = adjusted cooling
capacity for a theoretical comparable single-speed portable air
conditioner at Condition B in Table 1 of this appendix without and
with cycling losses, respectively, in Btu/h.
Capacity83_SS and Capacity83_SS_CLF =
theoretical comparable single-speed portable air conditioner cooling
capacity without and with cycling losses, respectively, in Btu/h, at
Condition B in Table 1 of this appendix, calculated in section 5.5.1
of this appendix.
Qduct_83_SS = total heat transferred from the ducts to
the indoor conditioned space in cooling mode for a theoretical
comparable single-speed portable air conditioner at Condition B in
Table 1 of this appendix, in Btu/h, calculated in section 5.5.2 of
this appendix.
Qinfiltration_83_SS = total infiltration air heat in
cooling mode for a theoretical comparable single-speed portable air
conditioner at Condition B in Table 1 of this appendix, in Btu/h,
calculated in section 5.5.3 of this appendix.
5.5.5 Annual Energy Consumption in Cooling Mode for a Theoretical
Comparable Single-Speed Portable Air Conditioner at the Lower Outdoor
Test Condition. Calculate the annual energy consumption in cooling mode
for a theoretical comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix, expressed in kWh/year,
according to the following equations:
AEC83_SS = P83_SS x 750 x 0.001
Where:
AEC83_SS = annual energy consumption for a theoretical
comparable single-speed portable air conditioner in cooling mode at
Condition B in Table 1 of this appendix, in kWh/year.
P83_SS = theoretical comparable single-speed portable air
conditioner electrical power input at Condition B in Table 1 of this
appendix, in watts, calculated in section 5.5.1 of this appendix.
750 = number of cooling mode hours per year.
0.001 kWh/Wh = conversion factor from watt-hours to kilowatt-hours.
5.5.6 Combined Energy Efficiency Ratio for a Theoretical Comparable
Single-Speed Portable Air Conditioner. Calculate the combined energy
efficiency ratio for a theoretical comparable single-speed portable air
conditioner without and with cycling losses considered,
CEERSS and CEERSS_CLF, respectively, expressed in
Btu/Wh, according to the following equations:
[GRAPHIC] [TIFF OMITTED] TN09AU19.094
[GRAPHIC] [TIFF OMITTED] TN09AU19.095
Where:
CEERSS and CEERSS_CLF = combined energy
efficiency ratio for a theoretical
[[Page 39281]]
comparable single-speed portable air conditioner without and with
cycling losses considered, respectively, in Btu/Wh.
ACC95 = adjusted cooling capacity, tested for the single-
duct variable-speed portable air conditioner at Condition A in Table
1 of this appendix, in Btu/h, calculated in section 5.1 of this
appendix.
ACC83_SS and ACC83_SS_CLF = adjusted cooling
capacity for a theoretical comparable single-speed portable air
conditioner at Condition B in Table 1 of this appendix without and
with cycling losses, respectively, in Btu/h, calculated in section
5.5.4 of this appendix.
AEC95 = annual energy consumption for the sample unit at
Condition A in Table 1 of this appendix, in kWh/year, calculated in
section 5.3 of this appendix.
AEC83_SS = annual energy consumption for a theoretical
comparable single-speed portable air conditioner in cooling mode at
Condition B in Table 1 of this appendix, in kWh/year, calculated in
section 5.5.5 of this appendix.
AECT = total annual energy consumption attributed to all
modes except cooling for the sample unit, in kWh/year, calculated in
section 5.3 of this appendix.
750 and 0.001 as defined previously in this section.
0.2 = weighting factor for the Condition A test.
0.8 = weighting factor for the Condition B test.
5.5.7 Single-Duct Variable-Speed Portable Air Conditioner
Performance Adjustment Factor. Calculate the single-duct variable-speed
portable air conditioner performance adjustment factor, Fp,
according to the following equation:
[GRAPHIC] [TIFF OMITTED] TN09AU19.096
Where:
CEERSS and CEERSS_CLF = combined energy
efficiency ratio for a theoretical comparable single-speed portable
air conditioner without and with cycling losses considered,
respectively, in Btu/Wh, calculated in section 5.5.6 of this
appendix.
5.5.8 Single-Duct Variable-Speed Portable Air Conditioner Combined
Energy Efficiency Ratio. Calculate the final combined energy efficiency
ratio, CEER, expressed in Btu/Wh, according to the following equation:
CEER = CEERVS x (1 + Fp)
Where:
CEER = combined energy efficiency ratio for the sample unit, in Btu/
Wh.
CEERVS = combined energy efficiency ratio initially
determined for the sample unit, in Btu/Wh, calculated in section 5.4
of this appendix.
Fp = single-duct variable-speed portable air conditioner
performance adjustment factor, determined in section 5.5.7 of this
appendix.''
(3) Representations. LG may not make representations about the
energy efficiency of the basic models listed in paragraph (1) for
compliance, marketing, or other purposes unless the basic model has
been tested in accordance with the provisions in this alternate test
procedure and such representations fairly disclose the results of such
testing.
(4) This interim waiver shall remain in effect according to the
provisions of 10 CFR 430.27.
(5) This interim waiver is issued to LG on the condition that the
statements, representations, and information provided by LG are valid.
DOE may revoke or modify this waiver at any time if it determines the
factual basis underlying the petition for waiver is incorrect, or the
results from the alternate test procedure are unrepresentative of a
basic model's true energy consumption characteristics. 10 CFR
430.27(k)(1). Likewise, LG may request that DOE rescind or modify the
interim waiver if LG discovers an error in the information provided to
DOE as part of its petition, determines that the interim waiver is no
longer needed, or for other appropriate reasons. 10 CFR 430.27(k)(2).
(6) LG remains obligated to fulfill any certification requirements
set forth at 10 CFR part 429.
DOE makes decisions on waivers and interim waivers for only those
basic models specifically set out in the petition, not future models
that may be manufactured by the petitioner. LG may submit a new or
amended petition for waiver and request for grant of interim waiver, as
appropriate, for additional basic models of portable air conditioners.
Alternatively, if appropriate, LG may request that DOE extend the scope
of a waiver or an interim waiver to include additional basic models
employing the same technology as the basic models set forth in the
original petition consistent with 10 CFR 430.27(g).
V. Request for Comments
DOE is publishing LG's petition for waiver in its entirety,
pursuant to 10 CFR 430.27(b)(1)(iv).\8\ The petition includes a
suggested alternate test procedure, as specified in the petition and
summarized in section IV of this document, to determine the efficiency
of LG's specified portable air conditioners. DOE may consider including
the alternate procedure specified in the Interim Waiver Order, and
restated in section IV of this document, in a subsequent Decision and
Order.
---------------------------------------------------------------------------
\8\ The petition did not identify any of the information
contained therein as confidential business information.
---------------------------------------------------------------------------
DOE invites all interested parties to submit in writing by
September 9, 2019, comments and information on all aspects of the
petition, including the alternate test procedure. Pursuant to 10 CFR
430.27(d), any person submitting written comments to DOE must also send
a copy of such comments to the petitioner. The contact information for
the petitioner is Scott Blake Harris, Harris, Wiltshire & Grannis LLP,
1919 M Street NW, Eighth Floor, Washington, DC 20036.
Submitting comments via http://www.regulations.gov. The http://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 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
include it in the comment or in any documents attached to your comment.
Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
comment. Persons viewing comments will see only first and last names,
organization names, correspondence containing comments, and any
documents submitted with the comments.
Do not submit to http://www.regulations.gov information for which
disclosure is restricted by statute,
[[Page 39282]]
such as trade secrets and commercial or financial information
(hereinafter referred to as Confidential Business Information
(``CBI'')). Comments submitted through http://www.regulations.gov
cannot be claimed as CBI. Comments received through the website will
waive any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section.
DOE processes submissions made through http://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
several weeks. Please keep the comment tracking number that http://www.regulations.gov provides after you have successfully uploaded your
comment.
Submitting comments via email, hand delivery, or mail. Comments and
documents submitted via email, hand delivery, or mail also will be
posted to http://www.regulations.gov. If you do not want your personal
contact information to be publicly viewable, do not include it in your
comment or any accompanying documents. Instead, provide your contact
information on a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery, please provide all items on a CD, if feasible. It is not
necessary to submit printed copies. No facsimiles (faxes) will be
accepted.
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 written in English, free of any defects or viruses, and are not
secured. Documents should not contain special characters or any form of
encryption and, if possible, they should carry the 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
into one or more PDFs. This reduces comment processing and posting
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 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).
Signed in Washington, DC, on July 30, 2019.
Alexander N. Fitzsimmons,
Acting Deputy Assistant Secretary for Energy Efficiency, Energy
Efficiency and Renewable Energy.
Before the
United States Department of Energy
Washington, DC 20585
In the Matter of: Energy Efficiency Program: Test Procedure for
Portable Air Conditioners
Petition of LG Electronics, Inc. for Waiver and Application for Interim
Waiver of Test Procedure for Portable Air Conditioners
LG Electronics, Inc. (LG) respectfully submits this Petition for
Waiver and Application for Interim Waiver \1\ from DOE's test procedure
for portable air conditioners (PACs). LG seeks a waiver because the
current test procedure for PACs does not accurately measure the energy
consumption of single-duct PACs with variable speed compressors (VSCs).
LG requests expedited treatment of the Petition and Application.
---------------------------------------------------------------------------
\1\ See 10 CFR 430.27 (petitions for waiver and interim waiver).
---------------------------------------------------------------------------
LG is a manufacturer of PACs and other products sold worldwide,
including in the United States. LG's United States affiliate is LG
Electronics USA, Inc., with headquarters at 1000 Sylvan Avenue,
Englewood Cliffs, NJ 07632 (tel. 201-816-2000).
I. Basic Models for Which a Waiver Is Requested
The basic models for which a waiver is requested are set forth in
the Appendix. They are single-duct PACs distributed in commerce under
the LG brand name.
II. Need for the Requested Waiver
The LG PACs with VSC technology are advanced, energy efficient
products. A VSC (inverter compressor) uses frequency controls
constantly to adjust the compressor's rotation speed to maintain the
desired temperature in the home without turning the motor on and off.
The compressor responds automatically to surrounding conditions to
operate in the most efficient possible manner. This results in both
dramatic energy savings and faster cooling compared to products without
VSCs. PACs with VSCs also have a higher/lower operating range (10 Hz to
120 Hz) than those without VSC.\2\
---------------------------------------------------------------------------
\2\ To the best of LG's knowledge, LG is the only manufacturer
of PAC basic models distributed in commerce in the United States to
incorporate design characteristic(s) similar to those found in the
basic models that are the subject of this petition, namely, PAC VSC
technology.
---------------------------------------------------------------------------
Unfortunately, while the current DOE test procedure for dual-duct
PACs provides that they be tested in two conditions, the test procedure
provides for testing only with full-load performance for single-duct
PACs.\3\ Thus, the PAC test procedure as applied to single-duct PACs
does not take into account the benefits of VSC, with its part-load
performance characteristics. This is also unlike the DOE test procedure
for central air conditioners, which provides for testing with part-load
performance for VSCs. Additionally, the PAC test procedure as applied
to single-duct PACs does not properly account for the favorable
difference in cycling losses resulting
[[Page 39283]]
from use of VSC technology. This technology limits the inefficiencies
associated performance degradation from cycling losses. Cycling losses
are avoided when the unit modulates its speed to meet a partial load
rather than cycles on and off.
---------------------------------------------------------------------------
\3\ 10 CFR Pt. 430, Subpart B, App. CC, Sec. 4.1, Tbl.1.
---------------------------------------------------------------------------
DOE has recognized this serious shortcoming in the context of its
test procedure for room air conditioners (RACs).\4\ It has stated that
the RAC test procedure ``does not measure the benefits of technologies
that improve part-load performance.'' \5\
---------------------------------------------------------------------------
\4\ Id. App. F.
\5\ 80 FR 34843, 34848 (June 18, 2015).
The current room AC test procedure measures only the full-load
performance at outdoor ambient conditions of 95 [deg]F dry-bulb and
75 [deg]F wet-bulb. Therefore, technologies that improve part-load
performance, such as multiple-speed compressors and variable-opening
expansion devices, will not improve the rated performance of a room
AC under the current test procedure.\6\
---------------------------------------------------------------------------
\6\ Id.
Indeed, DOE has correctly stressed that, ``[i]n contrast, central ACs
and heat pumps are rated'' using ``multiple rating points at different
conditions.'' \7\ DOE has said it intends to investigate potential
revision of the test procedure ``to account for any benefits of
technologies that improve part-load performance.'' \8\ DOE is currently
considering a waiver request by LG for RACs with VSCs.
---------------------------------------------------------------------------
\7\ Id.
\8\ Id.
---------------------------------------------------------------------------
These considerations apply to single-duct PACs as well as dual-duct
PACs and RACs. At the moment, however, the DOE test procedure for PACs
as applied to single-duct PACs does not include any provision to
account for the benefits of the part-load performance of VSCs or
properly account for the favorable difference in cycling losses
resulting from use of VSC technology. Therefore, the test procedure
evaluates the LG models with VSCs in a manner that misrepresents their
actual energy consumption. LG urges that a waiver be granted, for the
basic models in the Appendix, that will allow use of the alternate test
procedure discussed below. The alternate test procedure is designed to
take into account the energy savings characteristics of VSCs, properly
account for the favorable difference in cycling losses, and yield
results more representative of the actual energy consumption of these
products than the current DOE test procedure. And the rules provide
that DOE ``will grant a waiver from the test procedure requirements''
in these circumstances.\9\ The waiver should continue until DOE adopts
an applicable amended test procedure.
---------------------------------------------------------------------------
\9\ 10 CFR 430.27(f)(2).
---------------------------------------------------------------------------
III. Proposed Alternate Test Procedure
LG proposes the following alternate test procedure to evaluate the
performance of the basic models listed in the Appendix. The alternate
test procedure is the same as the existing test procedure for PACs
except that it takes into account VSC part-load characteristics for
single-duct PACs. It does so by providing for tests at multiple load
conditions. Specifically:
LG shall be required to test the performance of the basic models
listed in the Appendix hereto according to the test procedure for
portable air conditioners in 10 CFR part 430, subpart B, Appendix CC,
except as follows:
Add new Section 2.10 to Appendix CC as follows:
``2.10 Single-speed means a type of portable air conditioner that
does not automatically adjust either the compressor or fan speed, or
both, based on the detected outdoor conditions.''
Add new Section 2.12 to Appendix CC as follows:
``2.12 Variable-speed means a type of portable air conditioner that
can automatically adjust compressor and fan speed, only compressor
speed, or only fan speed, based on the detected outdoor conditions.''
Add the following at the end of Section 3.1.2 of Appendix CC:
``For a variable-speed portable air conditioner, the compressor
speed shall be set during cooling mode testing as described in section
4.1 of this appendix.''
Add the following at the end of Section 4.1 of Appendix CC:
``For a single-duct or dual-duct variable-speed portable air
conditioner, measure the indoor room cooling capacity and overall power
input in accordance with ambient conditions for Test Configuration 3,
Condition A (Capacity95, P95) with the compressor
speed set to maximum, and then measure the indoor room cooling capacity
and overall power input a second time in accordance with the ambient
conditions for Test Configuration 3, Condition B
(Capacity83, P83) with the compressor speed set
to minimum, for the duration of cooling mode testing.''
Add in Section 4.1.1, Duct Heat Transfer following ``Calculate the
total heat transferred from the surface of the duct(s) to the indoor
conditioned space while operating in cooling mode for the outdoor test
conditions in Table 1 of this appendix, as follows.'':
``Variable-speed portable air conditioners shall use the dual-duct
portable air conditioner calculations.''
Add in Section 4.1.2, Infiltration Air Heat Transfer after
``Calculate the heat contribution from infiltration air for single-duct
and dual-duct portable air conditioners for both cooling mode outdoor
test conditions, as described in this section.:
``Variable-speed portable air conditioners shall use the dual-duct
portable air conditioner calculations, except that the condenser inlet
terms shall not be included for single-duct variable-speed portable air
conditioners.''
Add in Section 4.1.2, Infiltration Air Heat Transfer after
``Calculate the dry air mass flow rate of infiltration air according to
the following equations.'':
``For single-duct portable air conditioners:''
Add in Section 5.1, Adjusted Cooling Capacity after ``Calculate the
adjusted cooling capacities for portable air conditioners,
ACC95 and ACC83, expressed in Btu/h, according to
the following equations.'':
``Variable-speed portable air conditioners shall use the dual-duct
portable air conditioner calculations.''
Add in Section 5.3, Annual Energy Consumption after ``Calculate the
annual energy consumption in each operating mode, AECm,
expressed in kilowatt-hours per year (kWh/year).'':
``Variable-speed portable air conditioners shall use the dual-duct
portable air conditioner annual operating hours and calculations.''
Add in Section 5.4, Combined Energy Efficiency Ratio after
``expressed in Btu/Wh,'':
``which shall be the combined energy efficiency ratio reported in
Sec. 429.62(b)(2) for single-speed portable air conditioners,''
Add the following after ``according to the following:'' in Section
5.4 of Appendix CC:
``Variable-speed portable air conditioners shall use the dual-duct
portable air conditioner calculation.''
Add the following after Section 5.4 of Appendix CC:
``5.5 Adjustment of the Combined Energy Efficiency Ratio for
Variable-Speed Portable Air Conditioners. Adjust the combined energy
efficiency ratio for variable-speed portable air conditioners as
follows, which shall be the combined energy efficiency ratio reported
in Sec. 429.62(b)(2) for variable-speed portable air conditioners.
5.5.1 Comparable Single-Speed Portable Air Conditioner Cooling
Capacity and Power at the Lower Outdoor Test Condition. Calculate the
[[Page 39284]]
cooling capacity and cooling capacity with cycling losses, expressed in
British thermal units per hour (Btu/h), and electrical power input,
expressed in watts, for a comparable single-speed portable air
conditioner at the 83 [deg]F dry-bulb outdoor conditions (Condition B
in Table 1 of this appendix).
For a single-duct variable-speed portable air conditioner:
Capacity83_SS = Capacity95
Capacity83_SS_CLF = Capacity95 x CLF
P83_SS = P95
For a dual-duct variable-speed portable air conditioner:
Capacity83_SS = Capacity95 x (1 + (Mc
x (T95-T83)))
Capacity83_SS_CLF = [Capacity95 x (1 +
(Mc x (T95-T83)))] x CLF
P83_SS = P95 x (1-(Mp x
(T95-T83)))
Where:
Capacity83_SS = comparable single-speed portable air
conditioner cooling capacity, in Btu/h, calculated for Condition B
in Table 1.
Capacity83_SS_CLF = comparable single-speed portable air
conditioner cooling capacity with cycling losses, in Btu/h,
calculated for Condition B in Table 1.
Capacity95 = variable-speed portable air conditioner
cooling capacity, in Btu/h, determined in section 4.1 of this
appendix for Condition A in Table 1.
P83_SS = comparable single-speed portable air conditioner
electrical power input, in watts, calculated for Condition B in
Table 1.
P95 = variable-speed portable air conditioner electrical
power input, in watts, determined in section 4.1 of this appendix
for Condition A in Table 1.
Mc = adjustment factor to determine the increased cooling
capacity at lower outdoor test conditions, 0.0099.
Mp = adjustment factor to determine the reduced
electrical power input at lower outdoor test conditions, 0.0076.
T95 = outdoor dry-bulb temperature for Condition A in
Table 1, 95 [deg]F.
T83 = outdoor dry-bulb temperature for Condition B in
Table 1, 83 [deg]F.
CLF = cycling loss factor for Condition B, 0.875.
5.5.2 Duct Heat Transfer for a Comparable Single-Speed Portable Air
Conditioner at the Lower Outdoor Test Condition. Calculate the
condenser exhaust duct and condenser inlet duct heat transfer to the
conditioned space for a comparable single-speed portable air
conditioner at the 83 [deg]F dry-bulb outdoor conditions (Condition B
in Table 1 of this appendix).
For a single-duct variable-speed portable air conditioner:
Qduct_83_SS = h x Aduct_exhaust x
(Tduct_95_exhaust-Tei)
For a dual-duct variable-speed portable air conditioner:
Qduct_95_inlet = h x Aduct_inlet x
(Tduct_95_inlet-Tei)
Qduct_95_exhaust = h x Aduct_exhaust x
(Tduct_95_exhaust-Tei)
Qduct_83_SS = MD x Qduct_95_inlet +
Qduct_95_exhaust
Where:
Qduct_95_inlet and Qduct_95_exhaust = the heat
transferred from the variable-speed portable air conditioner
condenser inlet duct and condenser exhaust duct to the indoor
conditioned space in cooling mode, in Btu/h, at the 95 [deg]F dry-
bulb outdoor test conditions in Table 1 of this appendix,
respectively.
Qduct_83_SS = total heat transferred from the ducts to
the indoor conditioned space in cooling mode, in Btu/h, for a
comparable single-speed portable air conditioner at the 83 [deg]F
dry-bulb outdoor test conditions in Table 1 of this appendix.
h = convection coefficient, 3 Btu/h per square foot per [deg]F.
Aduct_inlet and Aduct_exhaust = surface area
of the variable-speed portable air conditioner condenser inlet and
condenser exhaust ducts, respectively, in square feet, as calculated
in section 4.1.1 of this appendix.
Tduct_95_inlet and Tduct_95_exhaust = average
surface temperature for the variable-speed portable air conditioner
condenser inlet and exhaust ducts, respectively, as measured during
testing according to the 95 [deg]F outdoor test condition (Condition
A in Table 1 of this appendix), in [deg]F.
Tei = variable-speed portable air conditioner average
evaporator inlet air dry-bulb temperature, in [deg]F.
MD = adjustment factor to determine the comparable
single-speed portable air conditioner inlet condenser duct heat
transfer at the lower outdoor test condition, 0.241.
5.5.3 Infiltration Air Heat Transfer for a Comparable Single-Speed
Portable Air Conditioner at the Lower Outdoor Test Condition. Calculate
the heat contribution from infiltration air for a comparable single-
speed portable air conditioner at Condition B in Table 1 of this
appendix, as described in this section. Calculate the dry air mass flow
rate of infiltration air according to the following equations:
For a single-duct variable-speed portable air conditioner:
[GRAPHIC] [TIFF OMITTED] TN09AU19.097
For a dual-duct variable-speed portable air conditioner:
[GRAPHIC] [TIFF OMITTED] TN09AU19.098
Where:
m83_SS = dry air mass flow rate of infiltration air for a
comparable single-speed portable air conditioner at the 83 [deg]F
dry-bulb outdoor conditions (Condition B in Table 1 of this
appendix), in lb/m.
Vco_95 = average volumetric flow rate of the condenser
outlet air during cooling mode testing for the variable-speed
portable conditioner at the 95 [deg]F dry-bulb outdoor conditions,
in cubic feet per minute (cfm).
[rho]ci_95 and [rho]ci_83 = average density of
the condenser inlet air during cooling mode testing for the
variable-speed portable air conditioner at the 95 [deg]F and 83
[deg]F dry-bulb outdoor conditions, respectively, in lbm/
ft\3\.
[omega]co_95, and [omega]co_83 = average
humidity ratio of condenser outlet air during cooling mode testing
for the variable-speed portable air conditioner at the 95 [deg]F and
83 [deg]F dry-bulb outdoor conditions, respectively, in pounds mass
of water vapor per pounds mass of dry air (lbw/
lbda).
Calculate the sensible component of infiltration air heat
contribution for a comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix as follows:
Qs_83_SS = m83_SS x 60 x [(cp\da x
(Tia_83 - Tindoor)) + (cp\wv x
([omega]ia_83 x Tia_83 - [omega]indoor x
Tindoor))]
Where:
Qs_83_SS = sensible heat added to the room by
infiltration air for a comparable single-speed portable air
conditioner, at
[[Page 39285]]
the 83 [deg]F dry-bulb outdoor condition in Table 1 of this
appendix, in Btu/h.
m83_SS = dry air mass flow rate of infiltration air for a
comparable single-speed portable air conditioner, at the 83 [deg]F
dry-bulb outdoor condition in Table 1 of this appendix, in lb/m.
cp_da = specific heat of dry air, 0.24 Btu/lbm
- [deg]F.
cp_wv = specific heat of water vapor, 0.444 Btu/
lbm - [deg]F.
Tindoor = indoor chamber dry-bulb temperature, 80 [deg]F.
Tia_95 and Tia_83 = infiltration air dry-bulb
temperatures for the two test conditions in Table 1 of this
appendix, 95 [deg]F and 83 [deg]F, respectively.
[omega]ia_95 and [omega]ia_83 = humidity
ratios of the 95 [deg]F and 83 [deg]F dry-bulb infiltration air,
0.0141 and 0.01086 lbw/lbda, respectively.
[omega]indoor = humidity ratio of the indoor chamber air,
0.0112 lbw/lbda.
60 = conversion factor from minutes to hours.
Calculate the latent component of infiltration air heat
contribution for a comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix as follows:
Ql\83\SS = m83\SS x 60 x Hfg x ([omega]ia_83 - [omega]
indoor)
Where:
Ql_83_SS = latent heat added to the room by infiltration
air for a comparable single-speed portable air conditioner, at the
83 [deg]F dry-bulb outdoor condition in Table 1 of this appendix, in
Btu/h.
m83_SS = dry air mass flow rate of infiltration air for a
comparable single-speed portable air conditioner, at the 83 [deg]F
dry-bulb outdoor condition in Table 1 of this appendix, in lb/m.
Hfg. = latent heat of vaporization for water vapor, 1061
Btu/lbm.
[omega]ia_95 and [omega]ia_83 = humidity
ratios of the 95 [deg]F and 83 [deg]F dry-bulb infiltration air,
0.0141 and 0.01086 lbw/lbda, respectively.
[omega]indoor = humidity ratio of the indoor chamber air,
0.0112 lbw/lbda.60 = conversion factor from
minutes to hours.
The total heat contribution of the infiltration air for a
comparable single-speed portable air conditioner at Condition B in
Table 1 of this appendix is the sum of the sensible and latent heat
calculated above in this section:
Qinfiltration_83_SS = Qs_83_SS +
Ql_83_SS
Where:
Qinfiltration_83_SS = total infiltration air heat in
cooling mode for a comparable single-speed portable air conditioner
at the 83 [deg]F dry-bulb outdoor condition in Table 1 of this
appendix, in Btu/h.
Qs_83_SS = sensible heat added to the room by
infiltration air for a comparable single-speed portable air
conditioner, at the 83 [deg]F dry-bulb outdoor condition in Table 1
of this appendix, in Btu/h.
Ql_83_SS = latent heat added to the room by infiltration
air for a comparable single-speed portable air conditioner, at the
83 [deg]F dry-bulb outdoor condition in Table 1 of this appendix, in
Btu/h.
5.5.4 Adjusted Cooling Capacity for a Comparable Single-Speed
Portable Air Conditioner at the Lower Outdoor Test Condition. Calculate
the adjusted cooling capacity for a comparable single-speed portable
air conditioner at Condition B in Table 1 of this appendix with and
without cycling losses, ACC83_SS and
ACC83_SS_CLF, respectively, expressed in Btu/h, according to
the following equations.
ACC83_SS = Capacity83_SS - Qduct_83_SS
- Qinfiltration_83_SS
ACC83_SS_CLF = Capacity83_SS_CLF -
Qduct_83_SS - Qinfiltration_83_SS
Where:
ACC83_SS and ACC83_SS_CLF = adjusted cooling
capacity for a comparable single-speed portable air conditioner at
Condition B in Table 1 of this appendix without and with cycling
losses, respectively, in Btu/h.
Capacity83_SS and Capacity83_SS_CLF =
comparable single-speed portable air conditioner cooling capacity
without and with cycling losses, respectively, in Btu/h, at
Condition B in Table 1, calculated in section 5.5.1 of this
appendix.
Qduct_83_SS = total heat transferred from the ducts to
the indoor conditioned space in cooling mode for a comparable
single-speed portable air conditioner at the 83 [deg]F dry-bulb
outdoor test condition, in Btu/h, calculated in section 5.5.2 of
this appendix.
Qinfiltration_83_SS = total infiltration air heat in
cooling mode for a comparable single-speed portable air conditioner
at the 83 [deg]F dry-bulb outdoor condition, in Btu/h, calculated in
section 5.5.3 of this appendix.
5.5.5 Annual Energy Consumption in Cooling Mode for a Comparable
Single-Speed Portable Air Conditioner at the Lower Outdoor Test
Condition. Calculate the annual energy consumption in cooling mode for
a comparable single-speed portable air conditioner at Condition B in
Table 1 of this appendix, expressed in kWh/year, according to the
following equations.
AEC83_SS = P83_SS x t x k
Where:
AEC83_SS = annual energy consumption for a comparable
single-speed portable air conditioner in cooling mode at the 83
[deg]F dry-bulb outdoor condition, in kWh/year.
P83_SS = comparable single-speed portable air conditioner
electrical power input, in watts, calculated for the 83 [deg]F dry-
bulb outdoor condition in section 5.5.1.
t = number of cooling mode hours per year, 750.
k = 0.001 kWh/Wh conversion factor from watt-hours to kilowatt-
hours.
5.5.6 Combined Energy Efficiency Ratio for a Comparable Single-
Speed Portable Air Conditioner. Calculate the combined energy
efficiency ratio for a comparable single-speed portable air conditioner
without and with cycling losses considered, CEERSS and
CEERSS_CLF, respectively, expressed in Btu/Wh, according to
the following:
[GRAPHIC] [TIFF OMITTED] TN09AU19.099
Where:
CEERSS and CEERSS_CLF = combined energy
efficiency ratio for a comparable single-speed portable air
conditioner without and with cycling losses considered,
respectively, in Btu/Wh.
ACC95 = adjusted cooling capacity, tested for the
variable-speed portable air conditioner at the 95 [deg]F outdoor
condition in Table 1 of this appendix, in Btu/h, calculated in
section 5.1 of this appendix.
ACC83_SS and ACC83_SS_CLF = adjusted cooling
capacity for a comparable single-
[[Page 39286]]
speed portable air conditioner at the 83 [deg]F outdoor condition in
Table 1 of this appendix without and with cycling losses,
respectively, in Btu/h, calculated in section 5.5.4 of this
appendix.
AEC95 = annual energy consumption for the variable-speed
portable air conditioner at the 95 [deg]F outdoor conditions in
Table 1 of this appendix, in kWh/year, calculated in section 5.3 of
this appendix.
AEC83_SS = annual energy consumption for a comparable
single-speed portable air conditioner in cooling mode at the 83
[deg]F dry-bulb outdoor condition, in kWh/year, calculated in
section 5.5.5 of this appendix.
AECT = total annual energy consumption for the variable-
speed portable air conditioner attributed to all modes except
cooling, in kWh/year, calculated in section 5.3 of this appendix.
t = number of cooling mode hours per year, 750.
k = 0.001 kWh/Wh conversion factor for watt-hours to kilowatt-hours.
0.2 = weighting factor for the 95 [deg]F dry-bulb outdoor condition
test.
0.8 = weighting factor for the 83 [deg]F dry-bulb outdoor condition
test.
5.5.7 Variable-Speed Portable Air Conditioner Performance
Adjustment Factor. Calculate the variable-speed portable air
conditioner performance adjustment factor, Fp.
[GRAPHIC] [TIFF OMITTED] TN09AU19.100
Where:
Fp = variable-speed portable air conditioner performance
adjustment factor.
CEERSS and CEERSS_CLF = combined energy
efficiency ratio for a comparable single-speed portable air
conditioner without and with cycling losses considered,
respectively, in Btu/Wh.
5.5.8 Variable-Speed Portable Air Conditioner Combined Energy
Efficiency Ratio. For single-duct and dual-duct variable-speed portable
air conditioners, multiply the combined energy efficiency ratio,
CEERDD, expressed in Btu/Wh, determined in section 5.4 by (1
+ Fp) to obtain the final CEER for variable-speed portable
air conditioners.
Where:
Fp = variable-speed portable air conditioner performance
adjustment factor, determined in section 5.5.7 of this appendix.''
IV. Application for Interim Waiver
LG also hereby applies for an interim waiver of the applicable test
procedure requirements for the LG basic models set forth in the
Appendix. LG meets the criteria for an interim waiver.
LG's Petition for Waiver is likely to be granted because the test
method contained in 10 CFR part 430, subpart B, Appendix CC clearly
does not address the VSC characteristics of these LG basic models and
does not properly account for the favorable difference in cycling
losses resulting from use of VSC technology. Thus, the test procedure
does not accurately measure these models' energy consumption. Without
waiver relief, LG would be subject to requirements that are
inapplicable to these products. Additionally, LG will suffer economic
hardship and be at a competitive disadvantage if it must wait to rate
these basic models pending a determination on the petition for waiver.
DOE approval of LG's interim waiver application is also supported
by sound public policy. These LG products employ advanced technology
that increases efficiency and reduces energy consumption, while
offering a new level of affordable comfort to consumers.
V. Conclusion
LG respectfully requests that DOE grant its Petition for Waiver of
the applicable test procedure for specified basic models, and also
grant its Application for Interim Waiver.
LG requests expedited treatment of the Petition and Application.
Respectfully submitted,
Scott Harris/s/,
Richard C. Wingate,
Vice President, Compliance and General Counsel.
LG Electronics USA, Inc., 1000 Sylvan Avenue, Englewood Cliffs, NJ
07632, (201) 816 2000
Scott Blake Harris,
Stephanie Weiner,
John A. Hodges,
Harris, Wiltshire & Grannis LLP, 1919 M Street, NW, 8th Floor,
Washington, DC 20036, (202) 730-1300
Counsel to LG Electronics USA, Inc.
May 15, 2018.
Appendix
The waiver and interim waiver requested herein should apply to
testing and rating of the following basic models that are
manufactured by LG:
LP1419IVSM
LP1419HVSM
LP1219IVSM
LP1019IVSM
LP0819IVSM
[FR Doc. 2019-17083 Filed 8-8-19; 8:45 am]
BILLING CODE 6450-01-P