Energy Conservation Program for Consumer Products: Publication of the Petition for Waiver and Granting of the Application for Interim Waiver of Samsung Air Conditioning From the DOE Residential and Commercial Package Air Conditioner and Heat Pump Test Procedures (Case No. CAC-009), 9629-9635 [05-3782]
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Federal Register / Vol. 70, No. 38 / Monday, February 28, 2005 / Notices
Dated: February 23, 2005.
Sally L. Stroup,
Assistant Secretary for Postsecondary
Education.
[FR Doc. E5–799 Filed 2–25–05; 8:45 am]
BILLING CODE 4000–01–P
DEPARTMENT OF ENERGY
Office of Energy Efficiency and
Renewable Energy
Energy Conservation Program for
Consumer Products: Publication of the
Petition for Waiver and Granting of the
Application for Interim Waiver of
Samsung Air Conditioning From the
DOE Residential and Commercial
Package Air Conditioner and Heat
Pump Test Procedures (Case No.
CAC–009)
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver,
granting of application for interim
waiver, and solicitation of comments.
AGENCY:
SUMMARY: Today’s notice publishes a
Petition for Waiver from Samsung Air
Conditioning (Samsung). The Samsung
Petition requests a waiver of the test
procedures applicable to residential and
commercial package air conditioners
and heat pumps. The Department of
Energy (DOE) is soliciting comments,
data, and information with respect to
the Petition for Waiver.
Today’s notice also grants an Interim
Waiver to Samsung from the existing
Department of Energy (DOE or
Department) test procedures applicable
to residential and commercial package
air conditioners and heat pumps.
DATES: The Department will accept
comments, data, and information with
respect to this Petition for Waiver not
later than March 30, 2005.
ADDRESSES: You may submit comments,
identified by case number CAC–009, by
any of the following methods:
• Mail: Ms. Brenda Edwards-Jones,
U.S. Department of Energy, Building
Technologies Program, Mailstop EE–2J,
1000 Independence Avenue, SW.,
Washington, DC 20585–0121.
• Telephone: (202) 586–2945. Please
submit one signed paper original.
• Hand Delivery/Courier: Ms. Brenda
Edwards-Jones, U.S. Department of
Energy, Building Technologies Program,
Room 1J–018, 1000 Independence
Avenue, SW., Washington, DC 20585.
Docket: For access to the docket to
read copies of public comments
received, this notice, and the Petition
for Waiver and Application for Interim
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Waiver, go to the U.S. Department of
Energy, Forrestal Building, Room 1J–018
(Resource Room of the Building
Technologies Program), 1000
Independence Avenue, SW.,
Washington, DC (202) 586–9127,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
Please call Ms. Brenda Edwards-Jones at
the above telephone number for
additional information regarding
visiting the Resource Room. Please note:
The Department’s Freedom of
Information Reading Room (formerly
Room 1E–190 at the Forrestal Building)
is no longer housing waiver petition
materials.
FOR FURTHER INFORMATION CONTACT: Dr.
Michael G. Raymond, U.S. Department
of Energy, Building Technologies
Program, Mail Stop EE–2J, Forrestal
Building, 1000 Independence Avenue,
SW., Washington, DC 20585–0121, (202)
586–9611; e-mail:
Michael.Raymond.ee.doe.gov; or
Francine Pinto, Esq., or Thomas
DePriest, Esq., U.S. Department of
Energy, Office of General Counsel, Mail
Stop GC–72, Forrestal Building, 1000
Independence Avenue, SW.,
Washington, DC 20585–0103, (202) 586–
9507; e-mail:
Francine.Pinto@hq.doe.gov, or
Thomas.DePriest@hq.doe.gov.
SUPPLEMENTARY INFORMATION: Title III of
the Energy Policy and Conservation Act
(EPCA) sets forth a variety of provisions
concerning energy efficiency. Part B of
Title III (42 U.S.C. 6291–6309) provides
for the ‘‘Energy Conservation Program
for Consumer Products other than
Automobiles.’’ Part C of Title III (42
U.S.C. 6311–6317) provides for an
energy efficiency program entitled
‘‘Certain Industrial Equipment,’’ which
is similar to the program in Part B, and
which includes commercial air
conditioning equipment, packaged
boilers, water heaters, and other types of
commercial equipment.
Today’s notice involves both
residential products under Part B, and
commercial equipment under Part C.
Both parts specifically provide for
definitions, test procedures, labeling
provisions, energy conservation
standards, and the authority to require
information and reports from
manufacturers. With respect to test
procedures, both parts generally
authorize the Secretary of Energy to
prescribe test procedures that are
reasonably designed to produce results
which reflect energy efficiency, energy
use and estimated annual operating
costs, and that are not unduly
burdensome to conduct. (42 U.S.C.
6293, 6314)
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9629
Samsung’s petition requests a waiver
from both the residential and
commercial test procedures for its DVM
products, which are sold for both
residential and commercial use.
As noted above, the test procedures
for residential products appear at 10
CFR Part 430, Subpart B, Appendix M.
For commercial package airconditioning and heating equipment,
EPCA provides that the test procedures
shall be those generally accepted
industry testing procedures developed
or recognized by the Air-Conditioning
and Refrigeration Institute (ARI) or by
the American Society of Heating,
Refrigerating and Air Conditioning
Engineers (ASHRAE), as referenced in
ASHRAE/IES Standard 90.1 and in
effect on June 30, 1992. (42 U.S.C.
6314(a)(4)(A)) This section also provides
for the Secretary of Energy to amend the
test procedure for a product if the
industry test procedure is amended,
unless the Secretary determines that
such a modified test procedure does not
meet the statutory criteria. (42 U.S.C.
6314(a)(4)(B)) On October 21, 2004, the
Department published a direct final
rule, effective December 20, 2004,
adopting ARI Standard 210/240–2003
for small commercial package air
conditioning and heating equipment
with capacities ≤65,000 Btu/h and ARI
Standard 340/360–2000 for small
commercial package air conditioning
and heating equipment with capacities
≥65,000 Btu/h and <135,000 Btu/h. (69
FR 61962) The capacities of Samsung’s
DVM products sold for commercial use
fall in a range covered by ARI Standard
340/360–2000. Therefore, it is the
applicable test procedure for this
commercial equipment.
The Department’s regulations contain
provisions allowing a person to seek a
waiver from the test procedure
requirements for covered consumer
products. These provisions are set forth
in 10 CFR 430.27. The Department
proposed waiver provisions for covered
commercial equipment on December 13,
1999 (64 FR 69597), as part of the
commercial furnace test procedure rule.
The waiver provisions for commercial
equipment are substantively identical to
those for covered consumer products.
The Department published a final rule
on October 21, 2004, codifying this
process in 10 CFR 431.201, effective
November 22, 2004. (69 FR 61915)
The waiver provisions allow the
Assistant Secretary for Energy Efficiency
and Renewable Energy to waive
temporarily test procedures for a
particular basic model when a petitioner
shows that the basic model contains one
or more design characteristics that
prevent testing according to the
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prescribed test procedures, or when the
prescribed test procedures may evaluate
the basic model in a manner so
unrepresentative of its true energy
consumption as to provide materially
inaccurate comparative data. (10 CFR
Sections 430.27(a)(1), 431.201(a)(1))
Waivers generally remain in effect until
final test procedure amendments
become effective, thereby resolving the
problem that is the subject of the
waiver.
The waiver process also allows the
Assistant Secretary for Energy Efficiency
and Renewable Energy (Assistant
Secretary) to grant an Interim Waiver
from test procedure requirements to
manufacturers that have petitioned DOE
for a waiver of such prescribed test
procedures. (10 CFR 430.27(a)(2),
431.201(a)(2)) An Interim Waiver
remains in effect for a period of 180
days or until DOE issues its
determination on the Petition for
Waiver, whichever is sooner, and may
be extended for an additional 180 days,
if necessary.
On October 7, 2003, Samsung filed an
Application for Interim Waiver and a
Petition for Waiver from the test
procedures applicable to residential and
commercial package air conditioning
and heating equipment. In particular,
Samsung requested a waiver from the
residential test procedures contained in
10 CFR Part 430, Subpart B, Appendix
M, and, for commercial products, a
waiver from the test procedures in ARI
210/240 (1989), and from the test
procedures contained in ARI 210/240
(1994), that the Department, at the time,
proposed to adopt. As discussed above,
for Samsung’s commercial products, the
applicable test procedure is now ARI
340/360–2000. Samsung requests a
waiver from the test procedures for the
following basic product models:
Commercial: Any product using these
outdoor units: RVMH100FAMOU,
RVMC100FAMOU, RVMC070FAMOU.
For these products, the applicable test
procedure is ARI 340/360–2000.
Residential: Any product using these
outdoor units: RVMH050CBMOU,
RVMC050CBMOU. DVM indoor units:
AVMKH020CAOU, AVMKC020CAOU,
AVMKH032CAOU, AVMKC032CAOU,
AVMKH040CAOU, AVMKC040CAOU,
AVMCH052CAOU, AVMCC052CAOU,
AVMCH072CAOU, AVMCC072CAOU,
AVMCH105CAOU, AVMCC105CAOU,
AVMBH020CAOU, AVMBC020CAOU,
AVMBH032CAOU, AVMBC032CAOU,
AVMBH040CAOU, AVMBC040CAOU,
AVMBH052CAOU, AVMBC052CAOU,
AVMBH072CAOU, AVMBC072CAOU,
AVMHH105CAOU, AVMHC105CAOU,
AVMHH128CAOU, AVMHC105CAOU,
AVMDH052CAOU, AVMDC052CAOU,
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AVMDH072CAOU, AVMDC072CAOU,
AVMWH020CAOU,
AVMWCH020CAOU,
AVMWH032CAOU, AVMWC032CAOU,
AVMWH040CAOU, AVMWC040CAOU,
AVMWH052CAOU, AVMWC052CAOU,
AVMWH072CAOU, AVMWC072CAOU.
For these products, the applicable test
procedure is the residential test
procedure contained in 10 CFR Part 430,
Subpart B, Appendix M.
Samsung seeks a waiver from the
applicable test procedures because,
Samsung asserts, the current test
procedures evaluate its DVM (Digital
Variable Multi) systems in a manner not
representative of their true energy
efficiency. Samsung claims that the
energy usage of its DVM systems cannot
be representatively measured using the
current test procedures for the following
reasons:
1. Unlike the DVM system, no product
currently for sale in the U.S. offers the
ability of a direct expansion system to
vary its capacity every 20 seconds
between 10% and 100% of the building
design load, and no existing test
procedure can provide a method for
rating at those capacity points.
2. No existing test procedure requires
calculating Integrated Part Load Values
(IPLV) in the heating mode.
3. No existing test procedure accounts
for the benefits of the DVM system’s
zoned cooling. No existing test standard
allows for the inherent benefits of
eliminating duct loss in a ductless
system.
4. No existing test procedure provides
a method for testing and rating a system
that utilizes one outdoor unit and
sixteen indoor units.
5. No existing test procedure can
provide a method for rating systems
where the type and capacity of the
indoor unit can be mixed in the same
system. The DVM system can mix
together six different indoor models
with seven different capacities, resulting
in over 1,000 combinations.
The Samsung petition requests that
DOE grant a waiver from existing test
procedures until such time as a
representative test procedure is
developed and adopted for this class of
products. Samsung intends to work with
ARI to develop appropriate test
procedures.
Samsung also requested an Interim
Waiver to allow it to work with
manufacturers of similar products and
industry organizations to develop a test
procedure that accurately reflects the
operation and energy consumption of
these types of units. An Interim Waiver
will be granted if it is determined that
the applicant will experience economic
hardship if the Application for Interim
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Waiver is denied, if it appears likely
that the Petition for Waiver will be
granted, and/or the Assistant Secretary
determines that it would be desirable for
public policy reasons to grant
immediate relief pending a
determination on the Petition for
Waiver. (10 CFR 430.27(g),
431.201(e)(3))
Samsung’s Application for Interim
Waiver does not provide sufficient
information to evaluate what, if any,
economic hardship Samsung will likely
experience if its Application for Interim
Waiver is denied. However, in those
instances where the likely success of the
Petition for Waiver has been
demonstrated, based upon DOE having
granted a waiver for a similar product
design, it is in the public interest to
have similar products tested and rated
for energy consumption on a
comparable basis. For Samsung’s
commercial DVM products, it appears
likely that the Petition for Waiver will
be granted. The Samsung DVM products
are quite similar to the Mitsubishi City
Multi products, for which DOE granted
a waiver. (69 FR 52660, August 27,
2004) The Mitsubishi waiver was
granted because Mitsubishi’s products
cannot be tested according to the
prescribed test procedures, for two
reasons: (1) Test laboratories cannot test
products with so many indoor units (up
to sixteen—the practical limit is about
five); and (2) there are 58 indoor unit
models, so for each outdoor unit, there
are well over 1,000,000 combinations,
and it is impractical to test so many
combinations.
Samsung’s commercial outdoor units
are capable of operating up to sixteen
indoor units. Samsung’s system also
allows for over 1,000 combinations of
indoor and outdoor units. The upper
limit on the number of indoor units that
are currently able to be tested is about
six. The Samsung commercial systems
(with 100k and 72k Btu/hr outdoor
units) will therefore experience the
same testing problems that prompted
DOE to grant Mitsubishi a waiver.
Samsung’s residential models, with a
50k Btu/hr outdoor unit, are capable of
operating up to seven indoor units. This
would still be difficult to test, but it is
not clear that it could not be tested.
However, although it may be possible to
test Samsung’s residential DVM
systems, it is not practical to do so. For
standard split system air conditioners
with one indoor unit, DOE’s regulations
allow use of an alternative rating
method (ARM) for generating efficiency
ratings of different combinations of
indoor and outdoor units. There is no
such ARM for systems with more than
one indoor unit, so Samsung would
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have to test every combination offered
for sale. With up to seven indoor units
of six different types, thousands of
combinations are possible, and it would
not be practical to test so many
combinations. This is the second of the
two reasons for which Mitsubishi
received a waiver; therefore, it appears
likely that Samsung’s residential DVM
products will also be granted a waiver.
Therefore, Samsung’s Application for
an Interim Waiver from the DOE test
procedure for its DVM systems is
granted. Hence, it is ordered that:
The Application for Interim Waiver
filed by Samsung is hereby granted for
any Samsung DVM product using these
outdoor units: RVMH100FAMOU,
RVMC100FAMOU, RVMC070FAM0U,
RVMC050CBM0U, and
RVMH050CBM0U. Samsung shall not
be required to test or rate these products
on the basis of the currently applicable
test procedure, which is ARI 340/360–
2000 for the first three of the above
outdoor units, which are commercial,
and the test procedures contained in 10
CFR Part 430, Subpart B, Appendix M,
for the latter two, which are residential.
This Interim Waiver is based upon the
presumed validity of statements and
allegations submitted by the company.
This Interim Waiver may be removed or
modified at any time upon a
determination that the factual basis
underlying the Application is incorrect.
The Interim Waiver shall remain in
effect for a period of 180 days or until
DOE acts on the Petition for Waiver,
whichever is sooner, and may be
extended for an additional 180-day
period, if necessary.
The Department is publishing
Samsung’s Petition for Waiver in its
entirety. The Petition contains no
confidential information. The
Department solicits comments, data,
and information with respect to the
Petition. The Department is particularly
interested in receiving comments and
views of interested parties concerning
any alternate test procedures,
modifications to test procedures, or
alternative rating methods, which the
Department could use to fairly represent
the energy efficiency of Samsung’s DVM
products. Any person submitting
written comments must also send a
copy of such comments to the
petitioner. 10 CFR 430.27(b)(1)(iv).
Issued in Washington, DC, on February 22,
2005.
David K. Garman,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
Samsung Air Conditioning
2865 Pellissier Place
Whittier CA 90601
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October 7th 2003
Mr. Michael Raymond
Office of Building Research and Standards
United States Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585–0121
Dear Mr. Raymond
I am writing this letter to you in regard to
the process for a Petition for Waiver and
application for interim waiver of test
procedures.
Samsung Air Conditioning, acting through
it’s exclusive distributors in the USA,
Quietside Corporation hereby petitions the
United States Department of Energy for a
Waiver of all Test procedures and makes
application for an interim waiver pursuant to
the provisions of 10 CFR 431.29.
To support this petition, please consider
the following submission.
1. Models Covered by the Scope of This
Petition
The Samsung DVM system products
consist of three capacities of Outdoor units,
nominally 100,000 Btu/h, 72,000 Btu/h and
50,000 Btu/h, operating on 208/230V–3Ph–
60Hz (100k & 72k units) and 208/230V–1Ph–
60Hz (50k unit).
These units are available in both Cooling
only and Heat Pump models (72k is Cooling
only) and these outdoor units can be matched
with six different types of indoor unit—
Built in Duct
Low Silhouette Duct
High Static Pressure Duct
4 Way Ceiling Cassette
1 Way Ceiling Cassette
High Wall Mount unit
These indoor units are available in
capacities from 7,000 Btu/h to 44,000 Btu/h
depending on the model type.
Appendix 1: Full model list and description
of items covered by petition
2. Inherent Characteristics of the Samsung
DVM System
The Samsung DVM system is a Commercial
and Residential multi split, multi zoned
variable refrigerant flow system that will
provide either heating or cooling to the
building as dictated by the individual zone
temperature.
The 100k & 72k Outdoor units are capable
of operating up to 16 indoor units, and the
50,000 Btu/h Outdoor unit is capable of
operating up to 7 indoor units
All of the indoor units are capable of
operating independently, with their own
temperature and fan speed setting. Based on
those controls the outdoor unit will then
determine the cooling or heating capacity
delivered into the zones. The outdoor unit
uses the following inputs to determine the
capacity required by the zone—
Set Temperature (User selectable)
Room temperature (Measured in the return
air of the unit)
Refrigerant temperature at the Evaporator
Inlet
Refrigerant temperature at the Evaporator
Outlet
Outdoor ambient temperature
The Samsung DVM system cannot provide
simultaneous Heating and Cooling functions
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9631
into the zones, however it will operate to
satisfy the building demands in the following
manner—
First unit calling for operation
Majority rules for the building
All other zone requirements
The Outdoor and Indoor units
communicate the control information listed
above every 20 seconds to calculate the
indoor capacity required for the next 20
seconds of operation, allowing the unit to
correctly assess the load characteristics of the
building and adjust the capacity output
accordingly.
The method for controlling the capacity is
to vary the quantity of refrigerant flowing
through the entire system at any given time.
The compressor(s) used in the Samsung
DVM system are manufactured by Copeland
in Sidney OH, and are a ‘‘Digital Scroll’’ type.
This revolutionary compressor allows the
system capacity to be varied from 10% to
100% depending on the indoor load. This is
accomplished by allowing the fixed and
orbiting scrolls inside the compressor to
separate during unloaded periods, which
stops refrigerant flow through the compressor
and operates the compressor motor in an
unloaded fashion, which greatly reduces the
power consumed by the compressor,
The outdoor unit also uses variable speed
condenser fan motor(s) which can alter
condenser airflow to exactly suit the outdoor
air temperature and building load to ensure
the unit operates in the most efficient manner
possible.
The Indoor units all utilize an Electronic
Expansion Valve (EEV) which operates over
a 480 step range from fully closed to fully
open. This extensive range allows precise
monitoring of the refrigerant quantity
entering the evaporator coil and hence the
cooling or heating capacity of the unit.
This type of product will almost always
operate below the 100% capacity threshold
(part load versus full load operation), and
due to the enhanced capacity control range
of the DVM system it can operate at 10%
capacity if the building load has reduced to
that point.
This type of operation is very similar to the
Water Chilling units as detailed in ARI
standard 550/590.
3. Waiver Requirements
Samsung/Quietside seeks a waiver of all
current test standards until a test standard
can be developed and adopted that will
provide the HVAC market in the United
States (US) with a fair and accurate
assessment of the DVM system energy
consumption and efficiency levels.
The current test procedures in place may
evaluate the DVM system in a manner that
is not representative of the true energy
efficiency of the DVM system and provide
inaccurate ratings which would be used to
compare the DVM system with other forms
of Air Conditioning/Heat Pumps in the
market.
Due to the constant variation of the system
capacity it is patently inaccurate to rate the
unit at its full load capacity or at any other
fixed point of capacity when the unit
capacity is constantly varying between 10%
and 100% of the capacity.
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Any test method utilized to rate these types
of full variable refrigerant flow units should
be indicative of the ability of these units to
operate at 10%, 20%, 30% * * * 100% as
this is the true operation of the unit in the
field.
During 2002 a committee was formed by
ARI to discuss alternate test methods for this
type of multi split variable refrigerant flow
unit, however to this date no additional test
methodology has been adopted by the
committee. As the Department is aware the
timeframe for drafting and approving such a
standard may be months or even years. The
International Standards Organization have
been currently working on a standard of their
own for several years at this point in time.
Due to the lack of an approved standard at
this present time, the energy savings
provided by the DVM System would not be
accurately represented should it be tested
under the current standards. This inaccurate
representation will have a negative impact
upon the sales of both the Samsung DVM
system and other Variable Refrigerant
Volume systems. This will not only greatly
affect the business revenue of Quietside and
Samsung, but it will prevent the country
from realizing energy savings, particularly in
the area of peak load usage reduction.
To summarize, the test waiver for the DVM
system is requested for the following reasons:
A. No product currently for sale in the
USA offers the ability of a direct expansion
system to vary its capacity every 20 seconds
between 10% and 100% of the building
design load, and no existing test standard can
provide a method for providing ratings at
those capacity points.
B. No existing test standard allows for IPLV
to be calculated in the Heating mode.
C. No existing test standard provides for
the benefits of diversity due to the inherent
ability of the DVM System to provide zoned
cooling. Also no existing test standard
provides for credit for negating duct loss
from the nonducted units available with this
system.
D. No existing test standard provides a
method to test and rate a system that utilizes
one outdoor unit and 16 indoor units.
E. No existing test standard can provide a
method for rating systems where the type and
capacity of indoor unit can be used. The
DVM system can mix 6 different indoor
models in up to 7 different capacities. For
example a 100,000 Btu/h system can use 2 x
11,000 Btu/h units of different models, 2 x
13,000 Btu/h units of additional models, 2 x
24,000 Btu/h models from additional models
and still not be at 100% capacity load. The
total number of unit combinations available
is over 1,000, not including the ability to over
or under size the indoor capacity with regard
to the outdoor unit capacity.
4. Similar Equipment Currently Offered for
Sale in the U.S.
Sanyo
Mitsubishi Comfort Systems
Mitsubishi Electric U.S.
The above companies currently offer
similar systems for sale in the United States,
these systems offer similar advantages and
energy savings inherent to all Variable
Refrigerant Flow units, however no other
manufacturer utilizes the ‘‘Digital Scroll’’
technology and the capacity range of the
DVM system.
Mitsubishi Electric U.S. currently has a test
waiver proposal in front of the Department
that has been published for comment in the
Federal Register.
5. Reasons for Granting a Test Waiver to the
DVM System
The Samsung DVM System is currently
offered for sale in the U.S. marketplace,
however the lack of an existing or proposed
test standard has resulted in the unit having
to be provided with Energy Guide labels
detailing a 10 SEER, the lowest possible
rating. The true SEER of the DVM system
would be a minimum of 50% higher.
This failure to correctly rate the energy
efficiency of the unit also does not allow the
performance of the DVM system to be
certified by the ARI (no applicable test
standard or test availability), which causes a
misconception of the efficiency level of the
DVM system and provides wholly inaccurate
data to the U.S. consumer.
These types of Variable Refrigerant Flow
products are very well established in the
Asian and European markets, based on the
high levels of efficiency and comfort
provided to the end user. U.S. consumers
should not be excluded from these benefits
due to the lack of an applicable test standard,
and should not be beholden to inaccurate
data that will heavily disadvantage the DVM
system or any other Variable Refrigerant
Flow system in a very competitive
marketplace.
Independent testing of the DVM system
against conventional Air conditioning
systems shows an average of over 30%
reduction on energy consumption, not even
including the reduction in peak load
operating consumption.
Samsung test data, showing EER values
(Watt for Watt) shows almost a full EER point
increase over VAV and compressor control
units, and a similar increase over an Inverter
Variable Refrigerant Flow system. This test
data is included in Appendix 2.
The disadvantage of the lack of an
applicable test standard will not only impact
the potential sales of the DVM system, but
also result in economic losses not only for
Samsung and Quietside but also for the
Copeland Corporation who have spent
considerable time and resources in
developing the ‘‘Digital Scroll’’ compressors.
Samsung/Quietside formally urges the
Department to grant an interim waiver from
existing test standards and allow Quietside to
work in conjunction with the other
manufacturers of Variable Refrigerant Flow
products and the various organizations
involved in our industry to formulate a test
standard that accurately reflects the
operation and energy consumption of these
types of units.
Should the Department have any
comments or questions regarding this
petition please do not hesitate to contact the
undersigned.
Yours truly,
John Miles
Director of Engineering and Technical
Support
Appendix 1 : Full Model List Samsung DVM
System Products
Appendix 2 : Samsung performed Tests
detailing Energy Efficiency versus
Delivered Capacity for the DVM System
I hereby certify that copies of this petition
and application for Interim Waiver of test
standards have been mailed to the following
companies who are known to market similar
Variable Refrigerant Flow products
Mitsubishi Electric US
4505–A Newpoint Place
Lawrenceville GA 30043
Attn: William Rau, President, HVAC
Advanced Products Division
Sanyo
1165 Allgood Road, Suite #22
Marietta, GA 30062
Attn: Tetsushi Yamashita, Engineering
Manager, HVAC
Mitsubishi Heavy Industries Climate Control
Inc
3030 E. Victoria Street
Rancho Dominguez CA 90221
Attn: Caesar Ceballos, Technical Support
Manager
APPENDIX 1.—SAMSUNG DVM SYSTEM PRODUCTS AND CAPACITIES
Btu/h cooling/
heating
2003 Model
Description
RVMH100FAMOU ...................................
RVMC100FAMOU ...................................
RVMH050CBMOU ...................................
RVMC050CBMOU ...................................
RVMC070FAMOU ...................................
AVMKH020CAOU ....................................
AVMKC020CAOU ....................................
AVMKH032CAOU ....................................
AVMKC032CAOU ....................................
AVMKH040CAOU ....................................
Condensing Unit Heat Pump .....................................................................................
Condensing Unit Cooling Only ..................................................................................
Condensing Unit Heat Pump .....................................................................................
Condensing Unit Cooling Only ..................................................................................
Condensing Unit Cooling Only ..................................................................................
1–Way Ceiling Cassette Heat Pump .........................................................................
1–Way Ceiling Cassette Cooling Only ......................................................................
1–Way Ceiling Cassette Heat Pump .........................................................................
1–Way Ceiling Cassette Cooling Only ......................................................................
1–Way Ceiling Cassette Heat Pump .........................................................................
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95,500/107,500
50,000/55,000
50,000/55,000
76,000/85,000
7,000/7,500
7,000/7,500
11,000/12,000
11,000
13,500/14,500
Federal Register / Vol. 70, No. 38 / Monday, February 28, 2005 / Notices
9633
APPENDIX 1.—SAMSUNG DVM SYSTEM PRODUCTS AND CAPACITIES—Continued
Btu/h cooling/
heating
2003 Model
Description
AVMKC04OCAOU ...................................
AVMCH052CAOU ...................................
AVMCC052CAOU ...................................
AVMCH072CAOU ...................................
AVMCC072CAOU ...................................
AVMCH105CAOU ...................................
AVMCC105CAOU ...................................
AVMBH020CAOU ....................................
AVMBC020CAOU ....................................
AVMBH032CAOU ....................................
AVMBC032CAOU ....................................
AVMBH040CAOU ....................................
AVMBC040CAOU ....................................
AVMBH052CAOU ....................................
AVMBC052CAOU ....................................
AVMBH072CAOU ....................................
AVMBC072CAOU ....................................
AVMHH105CAOU ...................................
AVMHC105CAOU ...................................
AVMHH128CAOU ...................................
AVMHC128CAOU ...................................
AVMDH052CAOU ...................................
AVMDC052CAOU ...................................
AVMDH072CAOU ...................................
AVMDC072CAOU ...................................
AVMWH020CAOU ...................................
AVMWC020CAOU ...................................
AVMWH032CAOU ...................................
AVMWC032CAOU ...................................
AVMWH040CAOU ...................................
AVMWC040CAOU ...................................
AVMWH052CAOU ...................................
AVMWC052CAOU ...................................
AVMWH072CAOU ...................................
AVMWC072CAOU ...................................
1–Way Ceiling Cassette Cooling Only ......................................................................
4–Way Ceiling Cassette Heat Pump .........................................................................
4–Way Ceiling Cassette Cooling Only ......................................................................
4–Way Ceiling Cassette Heat Pump .........................................................................
4–Way Ceiling Cassette Cooling Only ......................................................................
4–Way Ceiling Cassette Heat Pump .........................................................................
4–Way Ceiling Cassette Cooling Only ......................................................................
Built-In Duct Heat Pump ............................................................................................
Built-In Duct Cooling Only .........................................................................................
Built-In Duct Heat Pump ............................................................................................
Built-In Duct Cooling Only .........................................................................................
Built-In Duct Heat Pump ............................................................................................
Built-In Duct Cooling Only .........................................................................................
Built-In Duct Heat Pump ............................................................................................
Built-In Duct Cooling Only .........................................................................................
Built-In Duct Heat Pump ............................................................................................
Built-In Duct Cooling Only .........................................................................................
HSP Duct Heat Pump ...............................................................................................
HSP Duct Cooling Only .............................................................................................
HSP Duct Heat Pump ...............................................................................................
HSP Duct Cooling Only .............................................................................................
Low Silhouette Duct Heat Pump ...............................................................................
Low Silhouette Cooling Only .....................................................................................
Low Silhouette Duct Heat Pump ...............................................................................
Low Silhouette Cooling Only .....................................................................................
High Wall Mount Heat Pump .....................................................................................
High Wall Mount Cooling Only ..................................................................................
High Wall Mount Heat Pump .....................................................................................
High Wall Mount Cooling Only ..................................................................................
High Wall Mount Heat Pump .....................................................................................
High Wall Mount Cooling Only ..................................................................................
High Wall Mount Heat Pump .....................................................................................
High Wall Mount Cooling Only ..................................................................................
High Wall Mount Heat Pump .....................................................................................
High Wall Mount Cooling Only ..................................................................................
BILLING CODE 6450–01–P
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13,500
18,000/19,000
18,000
24,000/26,000
24,000
36,000/39,000
36,000
7,000/7,500
7,000
11,000/12,000
11,000
13,500/14,500
13,500
18,000/19,000
18,000
24,000/26,000
24,000
36,000/39,000
36,000
44,000/47,000
44,000
18,000/19,000
18,000
24,000/26,000
24,000
7,000/7,500
7,000
11,000/12,000
11,000
13,500/14,500
13,500
18,000/19,000
18,000
24,000/26,000
24,000
VerDate jul<14>2003
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9634
Federal Register / Vol. 70, No. 38 / Monday, February 28, 2005 / Notices
[FR Doc. 05–3782 Filed 2–25–05; 8:45 am]
BILLING CODE 6450–01–C
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Docket Nos. EL00–95–125 and EL00–98–
112]
Online service, please e-mail
FERCOnlineSupport@ferc.gov, or call
(866) 208–3676 (toll free). For TTY, call
(202) 502–8659.
Comment Date: 5 p.m. eastern time on
March 4, 2005.
Linda Mitry,
Deputy Secretary.
[FR Doc. E5–787 Filed 2–25–05; 8:45 am]
BILLING CODE 6717–01–P
San Diego Gas & Electric Company,
Complainants v. Sellers of Energy and
Ancillary Services Into Markets
Operated by the California
Independent System Operator and the
California Power Exchange,
Respondents; Investigation of
Practices of the California Independent
System Operator and the California
Power Exchange; Notice of
Compliance Filing
February 18, 2005.
On February 11, 2005, the City of
Pasadena (Pasadena) submitted its
emissions calculations in compliance
with the Commission’s Order issued
November 23, 2004, in Docket Nos.
EL00–95–100 and EL00–98–088, 109
FERC ¶ 61,218.
Any person desiring to intervene or to
protest this filing must file in
accordance with Rules 211 and 214 of
the Commission’s Rules of Practice and
Procedure (18 CFR 385.211, 385.214).
Protests will be considered by the
Commission in determining the
appropriate action to be taken, but will
not serve to make protestants parties to
the proceeding. Any person wishing to
become a party must file a notice of
intervention or motion to intervene, as
appropriate. Such notices, motions, or
protests must be filed on or before the
comment date. Anyone filing a motion
to intervene or protest must serve a copy
of that document on the Applicant and
all the parties in this proceeding.
The Commission encourages
electronic submission of protests and
interventions in lieu of paper using the
‘‘eFiling’’ link at https://www.ferc.gov.
Persons unable to file electronically
should submit an original and 14 copies
of the protest or intervention to the
Federal Energy Regulatory Commission,
888 First Street, NE., Washington, DC
20426.
This filing is accessible on-line at
https://www.ferc.gov, using the
‘‘eLibrary’’ link and is available for
review in the Commission’s Public
Reference Room in Washington, DC.
There is an ‘‘eSubscription’’ link on the
Web site that enables subscribers to
receive e-mail notification when a
document is added to a subscribed
docket(s). For assistance with any FERC
VerDate jul<14>2003
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9635
3. Idaho Power Company
[Docket No. ER97–1481–007]
Take notice that on February 17, 2005,
Idaho Power (IPC) submitted an
amendment to its January 19, 2005,
filing regarding IPC’s revised generation
market power screen analysis.
Comment Date: 5 p.m. eastern time on
February 25, 2005.
4. PacifiCorp PPM Energy, Inc.
[Docket No. ER97–2801–005 and ER03–478–
004]
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Docket No. EC05–20–000, et al.]
PPL Sundance Energy, LLC, et al.;
Electric Rate and Corporate Filings
February 18, 2005.
The following filings have been made
with the Commission. The filings are
listed in ascending order within each
docket classification.
Take notice that on February 14, 2005,
PacifiCorp and PPM Energy, Inc.
tendered for filing an updated market
power analysis.
Comment Date: 5 p.m. eastern time on
March 4, 2005.
5. Pacific Gas and Electric Company
[Docket No. ER03–1091–007]
[Docket No. EC05–20–000]
Take notice that on February 11, 2005,
PPL Sundance Energy, LLC (PPL
Sundance), PPL Energy Plus, LLC and
Arizona Public Service Company (APS)
(collectively, Applicants) filed with the
Federal Energy Regulatory Commission
a response to a deficiency letter issued
on January 28, 2005, by Jamie L. Simler,
Director, Division of Tariffs and Market
Development—West, in connection with
a section 203 application filed for
authorization to acquire a 450 megawatt
generating facility owned by PPL
Sundance. Applicants request
confidential treatment of certain
supporting data contained in the filing.
Comment Date: 5 p.m. eastern time on
March 2, 2005.
Take notice that on February 11, 2005,
Pacific Gas and Electric Company
(PG&E) tendered for filing an
amendment to its December 30, 2004,
compliance filing regarding a Generator
Special Facilities Agreement and
Generator Interconnection Agreement
between PG&E and Duke Energy Morro
Bay LLC (Duke Morro Bay).
PG&E states that copies of this filing
have been served upon Duke Morro Bay,
the California Independent System
Operator Corporation and the California
Public Utilities Commission.
Comment Date: 5 p.m. eastern time on
March 4, 2005.
6. The Detroit Edison Company
1. PPL Sundance Energy, LLC, PPL
Energy Plus, LLC, Arizona Public
Service Company
[Docket Nos. ER04–14–006 and EL04–29–
006]
2. Duke Power, a Division of Duke
Power Corporation
Take notice that on February 11, 2005,
The Detroit Edison Company (Detroit
Edison) filed an amendment to its
Ancillary Services Tariff, First Revised
Volume No. 5, filed on December 2,
2004 to repaginate the tariff sheets in
compliance with Order No. 614.
Comment Date: 5 p.m. eastern time on
March 4, 2005.
[Docket Nos. ER96–110–013 and EL05–4–
000]
7. California Independent System
Operator Corporation
Take notice that on February 14, 2005,
Duke Power, a division of Duke Energy
Corporation (Duke Power) submitted a
filing in compliance with the
Commission’s order issued December
15, 2004, in Docket No. ER96–110–010,
et al., 109 FERC ¶ 61,270.
Duke Power states that copies of the
filing were served on parties on the
official service list in the abovecaptioned proceed as well as its State
commissions.
Comment Date: 5 p.m. eastern time on
March 4, 2005.
PO 00000
Frm 00028
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[Docket No. ER05–277–001]
Take notice that on February 14, 2005,
the California Independent System
Operator Corporation (ISO) submitted a
filing in compliance with the
Commission’s order issued January 28,
2005, in Docket No. ER05–277–000, 110
FERC ¶ 61,082.
The ISO states that the filing has been
served on all parties on the official
service list for this proceeding. In
addition, the ISO states that it has
posting the filing on the ISO home page.
E:\FR\FM\28FEN1.SGM
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]]>Agencies
[Federal Register Volume 70, Number 38 (Monday, February 28, 2005)]
[Notices]
[Pages 9629-9635]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 05-3782]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
Energy Conservation Program for Consumer Products: Publication of
the Petition for Waiver and Granting of the Application for Interim
Waiver of Samsung Air Conditioning From the DOE Residential and
Commercial Package Air Conditioner and Heat Pump Test Procedures (Case
No. CAC-009)
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver, granting of application for
interim waiver, and solicitation of comments.
-----------------------------------------------------------------------
SUMMARY: Today's notice publishes a Petition for Waiver from Samsung
Air Conditioning (Samsung). The Samsung Petition requests a waiver of
the test procedures applicable to residential and commercial package
air conditioners and heat pumps. The Department of Energy (DOE) is
soliciting comments, data, and information with respect to the Petition
for Waiver.
Today's notice also grants an Interim Waiver to Samsung from the
existing Department of Energy (DOE or Department) test procedures
applicable to residential and commercial package air conditioners and
heat pumps.
DATES: The Department will accept comments, data, and information with
respect to this Petition for Waiver not later than March 30, 2005.
ADDRESSES: You may submit comments, identified by case number CAC-009,
by any of the following methods:
Mail: Ms. Brenda Edwards-Jones, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC 20585-0121.
Telephone: (202) 586-2945. Please submit one signed paper
original.
Hand Delivery/Courier: Ms. Brenda Edwards-Jones, U.S.
Department of Energy, Building Technologies Program, Room 1J-018, 1000
Independence Avenue, SW., Washington, DC 20585.
Docket: For access to the docket to read copies of public comments
received, this notice, and the Petition for Waiver and Application for
Interim Waiver, go to the U.S. Department of Energy, Forrestal
Building, Room 1J-018 (Resource Room of the Building Technologies
Program), 1000 Independence Avenue, SW., Washington, DC (202) 586-9127,
between 9 a.m. and 4 p.m., Monday through Friday, except Federal
holidays. Please call Ms. Brenda Edwards-Jones at the above telephone
number for additional information regarding visiting the Resource Room.
Please note: The Department's Freedom of Information Reading Room
(formerly Room 1E-190 at the Forrestal Building) is no longer housing
waiver petition materials.
FOR FURTHER INFORMATION CONTACT: Dr. Michael G. Raymond, U.S.
Department of Energy, Building Technologies Program, Mail Stop EE-2J,
Forrestal Building, 1000 Independence Avenue, SW., Washington, DC
20585-0121, (202) 586-9611; e-mail: Michael.Raymond.ee.doe.gov; or
Francine Pinto, Esq., or Thomas DePriest, Esq., U.S. Department of
Energy, Office of General Counsel, Mail Stop GC-72, Forrestal Building,
1000 Independence Avenue, SW., Washington, DC 20585-0103, (202) 586-
9507; e-mail: Francine.Pinto@hq.doe.gov, or Thomas.DePriest@hq.doe.gov.
SUPPLEMENTARY INFORMATION: Title III of the Energy Policy and
Conservation Act (EPCA) sets forth a variety of provisions concerning
energy efficiency. Part B of Title III (42 U.S.C. 6291-6309) provides
for the ``Energy Conservation Program for Consumer Products other than
Automobiles.'' Part C of Title III (42 U.S.C. 6311-6317) provides for
an energy efficiency program entitled ``Certain Industrial Equipment,''
which is similar to the program in Part B, and which includes
commercial air conditioning equipment, packaged boilers, water heaters,
and other types of commercial equipment.
Today's notice involves both residential products under Part B, and
commercial equipment under Part C. Both parts specifically provide for
definitions, test procedures, labeling provisions, energy conservation
standards, and the authority to require information and reports from
manufacturers. With respect to test procedures, both parts generally
authorize the Secretary of Energy to prescribe test procedures that are
reasonably designed to produce results which reflect energy efficiency,
energy use and estimated annual operating costs, and that are not
unduly burdensome to conduct. (42 U.S.C. 6293, 6314)
Samsung's petition requests a waiver from both the residential and
commercial test procedures for its DVM products, which are sold for
both residential and commercial use.
As noted above, the test procedures for residential products appear
at 10 CFR Part 430, Subpart B, Appendix M.
For commercial package air-conditioning and heating equipment, EPCA
provides that the test procedures shall be those generally accepted
industry testing procedures developed or recognized by the Air-
Conditioning and Refrigeration Institute (ARI) or by the American
Society of Heating, Refrigerating and Air Conditioning Engineers
(ASHRAE), as referenced in ASHRAE/IES Standard 90.1 and in effect on
June 30, 1992. (42 U.S.C. 6314(a)(4)(A)) This section also provides for
the Secretary of Energy to amend the test procedure for a product if
the industry test procedure is amended, unless the Secretary determines
that such a modified test procedure does not meet the statutory
criteria. (42 U.S.C. 6314(a)(4)(B)) On October 21, 2004, the Department
published a direct final rule, effective December 20, 2004, adopting
ARI Standard 210/240-2003 for small commercial package air conditioning
and heating equipment with capacities <=65,000 Btu/h and ARI Standard
340/360-2000 for small commercial package air conditioning and heating
equipment with capacities >=65,000 Btu/h and <135,000 Btu/h. (69 FR
61962) The capacities of Samsung's DVM products sold for commercial use
fall in a range covered by ARI Standard 340/360-2000. Therefore, it is
the applicable test procedure for this commercial equipment.
The Department's regulations contain provisions allowing a person
to seek a waiver from the test procedure requirements for covered
consumer products. These provisions are set forth in 10 CFR 430.27. The
Department proposed waiver provisions for covered commercial equipment
on December 13, 1999 (64 FR 69597), as part of the commercial furnace
test procedure rule. The waiver provisions for commercial equipment are
substantively identical to those for covered consumer products. The
Department published a final rule on October 21, 2004, codifying this
process in 10 CFR 431.201, effective November 22, 2004. (69 FR 61915)
The waiver provisions allow the Assistant Secretary for Energy
Efficiency and Renewable Energy to waive temporarily test procedures
for a particular basic model when a petitioner shows that the basic
model contains one or more design characteristics that prevent testing
according to the
[[Page 9630]]
prescribed test procedures, or when the prescribed test procedures may
evaluate the basic model in a manner so unrepresentative of its true
energy consumption as to provide materially inaccurate comparative
data. (10 CFR Sections 430.27(a)(1), 431.201(a)(1)) Waivers generally
remain in effect until final test procedure amendments become
effective, thereby resolving the problem that is the subject of the
waiver.
The waiver process also allows the Assistant Secretary for Energy
Efficiency and Renewable Energy (Assistant Secretary) to grant an
Interim Waiver from test procedure requirements to manufacturers that
have petitioned DOE for a waiver of such prescribed test procedures.
(10 CFR 430.27(a)(2), 431.201(a)(2)) An Interim Waiver remains in
effect for a period of 180 days or until DOE issues its determination
on the Petition for Waiver, whichever is sooner, and may be extended
for an additional 180 days, if necessary.
On October 7, 2003, Samsung filed an Application for Interim Waiver
and a Petition for Waiver from the test procedures applicable to
residential and commercial package air conditioning and heating
equipment. In particular, Samsung requested a waiver from the
residential test procedures contained in 10 CFR Part 430, Subpart B,
Appendix M, and, for commercial products, a waiver from the test
procedures in ARI 210/240 (1989), and from the test procedures
contained in ARI 210/240 (1994), that the Department, at the time,
proposed to adopt. As discussed above, for Samsung's commercial
products, the applicable test procedure is now ARI 340/360-2000.
Samsung requests a waiver from the test procedures for the following
basic product models:
Commercial: Any product using these outdoor units: RVMH100FAMOU,
RVMC100FAMOU, RVMC070FAMOU. For these products, the applicable test
procedure is ARI 340/360-2000.
Residential: Any product using these outdoor units: RVMH050CBMOU,
RVMC050CBMOU. DVM indoor units: AVMKH020CAOU, AVMKC020CAOU,
AVMKH032CAOU, AVMKC032CAOU, AVMKH040CAOU, AVMKC040CAOU, AVMCH052CAOU,
AVMCC052CAOU, AVMCH072CAOU, AVMCC072CAOU, AVMCH105CAOU, AVMCC105CAOU,
AVMBH020CAOU, AVMBC020CAOU, AVMBH032CAOU, AVMBC032CAOU, AVMBH040CAOU,
AVMBC040CAOU, AVMBH052CAOU, AVMBC052CAOU, AVMBH072CAOU, AVMBC072CAOU,
AVMHH105CAOU, AVMHC105CAOU, AVMHH128CAOU, AVMHC105CAOU, AVMDH052CAOU,
AVMDC052CAOU, AVMDH072CAOU, AVMDC072CAOU, AVMWH020CAOU, AVMWCH020CAOU,
AVMWH032CAOU, AVMWC032CAOU, AVMWH040CAOU, AVMWC040CAOU, AVMWH052CAOU,
AVMWC052CAOU, AVMWH072CAOU, AVMWC072CAOU. For these products, the
applicable test procedure is the residential test procedure contained
in 10 CFR Part 430, Subpart B, Appendix M.
Samsung seeks a waiver from the applicable test procedures because,
Samsung asserts, the current test procedures evaluate its DVM (Digital
Variable Multi) systems in a manner not representative of their true
energy efficiency. Samsung claims that the energy usage of its DVM
systems cannot be representatively measured using the current test
procedures for the following reasons:
1. Unlike the DVM system, no product currently for sale in the U.S.
offers the ability of a direct expansion system to vary its capacity
every 20 seconds between 10% and 100% of the building design load, and
no existing test procedure can provide a method for rating at those
capacity points.
2. No existing test procedure requires calculating Integrated Part
Load Values (IPLV) in the heating mode.
3. No existing test procedure accounts for the benefits of the DVM
system's zoned cooling. No existing test standard allows for the
inherent benefits of eliminating duct loss in a ductless system.
4. No existing test procedure provides a method for testing and
rating a system that utilizes one outdoor unit and sixteen indoor
units.
5. No existing test procedure can provide a method for rating
systems where the type and capacity of the indoor unit can be mixed in
the same system. The DVM system can mix together six different indoor
models with seven different capacities, resulting in over 1,000
combinations.
The Samsung petition requests that DOE grant a waiver from existing
test procedures until such time as a representative test procedure is
developed and adopted for this class of products. Samsung intends to
work with ARI to develop appropriate test procedures.
Samsung also requested an Interim Waiver to allow it to work with
manufacturers of similar products and industry organizations to develop
a test procedure that accurately reflects the operation and energy
consumption of these types of units. An Interim Waiver will be granted
if it is determined that the applicant will experience economic
hardship if the Application for Interim Waiver is denied, if it appears
likely that the Petition for Waiver will be granted, and/or the
Assistant Secretary determines that it would be desirable for public
policy reasons to grant immediate relief pending a determination on the
Petition for Waiver. (10 CFR 430.27(g), 431.201(e)(3))
Samsung's Application for Interim Waiver does not provide
sufficient information to evaluate what, if any, economic hardship
Samsung will likely experience if its Application for Interim Waiver is
denied. However, in those instances where the likely success of the
Petition for Waiver has been demonstrated, based upon DOE having
granted a waiver for a similar product design, it is in the public
interest to have similar products tested and rated for energy
consumption on a comparable basis. For Samsung's commercial DVM
products, it appears likely that the Petition for Waiver will be
granted. The Samsung DVM products are quite similar to the Mitsubishi
City Multi products, for which DOE granted a waiver. (69 FR 52660,
August 27, 2004) The Mitsubishi waiver was granted because Mitsubishi's
products cannot be tested according to the prescribed test procedures,
for two reasons: (1) Test laboratories cannot test products with so
many indoor units (up to sixteen--the practical limit is about five);
and (2) there are 58 indoor unit models, so for each outdoor unit,
there are well over 1,000,000 combinations, and it is impractical to
test so many combinations.
Samsung's commercial outdoor units are capable of operating up to
sixteen indoor units. Samsung's system also allows for over 1,000
combinations of indoor and outdoor units. The upper limit on the number
of indoor units that are currently able to be tested is about six. The
Samsung commercial systems (with 100k and 72k Btu/hr outdoor units)
will therefore experience the same testing problems that prompted DOE
to grant Mitsubishi a waiver.
Samsung's residential models, with a 50k Btu/hr outdoor unit, are
capable of operating up to seven indoor units. This would still be
difficult to test, but it is not clear that it could not be tested.
However, although it may be possible to test Samsung's residential DVM
systems, it is not practical to do so. For standard split system air
conditioners with one indoor unit, DOE's regulations allow use of an
alternative rating method (ARM) for generating efficiency ratings of
different combinations of indoor and outdoor units. There is no such
ARM for systems with more than one indoor unit, so Samsung would
[[Page 9631]]
have to test every combination offered for sale. With up to seven
indoor units of six different types, thousands of combinations are
possible, and it would not be practical to test so many combinations.
This is the second of the two reasons for which Mitsubishi received a
waiver; therefore, it appears likely that Samsung's residential DVM
products will also be granted a waiver.
Therefore, Samsung's Application for an Interim Waiver from the DOE
test procedure for its DVM systems is granted. Hence, it is ordered
that:
The Application for Interim Waiver filed by Samsung is hereby
granted for any Samsung DVM product using these outdoor units:
RVMH100FAMOU, RVMC100FAMOU, RVMC070FAM0U, RVMC050CBM0U, and
RVMH050CBM0U. Samsung shall not be required to test or rate these
products on the basis of the currently applicable test procedure, which
is ARI 340/360-2000 for the first three of the above outdoor units,
which are commercial, and the test procedures contained in 10 CFR Part
430, Subpart B, Appendix M, for the latter two, which are residential.
This Interim Waiver is based upon the presumed validity of
statements and allegations submitted by the company. This Interim
Waiver may be removed or modified at any time upon a determination that
the factual basis underlying the Application is incorrect.
The Interim Waiver shall remain in effect for a period of 180 days
or until DOE acts on the Petition for Waiver, whichever is sooner, and
may be extended for an additional 180-day period, if necessary.
The Department is publishing Samsung's Petition for Waiver in its
entirety. The Petition contains no confidential information. The
Department solicits comments, data, and information with respect to the
Petition. The Department is particularly interested in receiving
comments and views of interested parties concerning any alternate test
procedures, modifications to test procedures, or alternative rating
methods, which the Department could use to fairly represent the energy
efficiency of Samsung's DVM products. Any person submitting written
comments must also send a copy of such comments to the petitioner. 10
CFR 430.27(b)(1)(iv).
Issued in Washington, DC, on February 22, 2005.
David K. Garman,
Assistant Secretary, Energy Efficiency and Renewable Energy.
Samsung Air Conditioning
2865 Pellissier Place
Whittier CA 90601
October 7th 2003
Mr. Michael Raymond
Office of Building Research and Standards
United States Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585-0121
Dear Mr. Raymond
I am writing this letter to you in regard to the process for a
Petition for Waiver and application for interim waiver of test
procedures.
Samsung Air Conditioning, acting through it's exclusive
distributors in the USA, Quietside Corporation hereby petitions the
United States Department of Energy for a Waiver of all Test
procedures and makes application for an interim waiver pursuant to
the provisions of 10 CFR 431.29.
To support this petition, please consider the following
submission.
1. Models Covered by the Scope of This Petition
The Samsung DVM system products consist of three capacities of
Outdoor units, nominally 100,000 Btu/h, 72,000 Btu/h and 50,000 Btu/
h, operating on 208/230V-3Ph-60Hz (100k & 72k units) and 208/230V-
1Ph-60Hz (50k unit).
These units are available in both Cooling only and Heat Pump
models (72k is Cooling only) and these outdoor units can be matched
with six different types of indoor unit--
Built in Duct
Low Silhouette Duct
High Static Pressure Duct
4 Way Ceiling Cassette
1 Way Ceiling Cassette
High Wall Mount unit
These indoor units are available in capacities from 7,000 Btu/h
to 44,000 Btu/h depending on the model type.
Appendix 1: Full model list and description of items covered by
petition
2. Inherent Characteristics of the Samsung DVM System
The Samsung DVM system is a Commercial and Residential multi
split, multi zoned variable refrigerant flow system that will
provide either heating or cooling to the building as dictated by the
individual zone temperature.
The 100k & 72k Outdoor units are capable of operating up to 16
indoor units, and the 50,000 Btu/h Outdoor unit is capable of
operating up to 7 indoor units
All of the indoor units are capable of operating independently,
with their own temperature and fan speed setting. Based on those
controls the outdoor unit will then determine the cooling or heating
capacity delivered into the zones. The outdoor unit uses the
following inputs to determine the capacity required by the zone--
Set Temperature (User selectable)
Room temperature (Measured in the return air of the unit)
Refrigerant temperature at the Evaporator Inlet
Refrigerant temperature at the Evaporator Outlet
Outdoor ambient temperature
The Samsung DVM system cannot provide simultaneous Heating and
Cooling functions into the zones, however it will operate to satisfy
the building demands in the following manner--
First unit calling for operation
Majority rules for the building
All other zone requirements
The Outdoor and Indoor units communicate the control information
listed above every 20 seconds to calculate the indoor capacity
required for the next 20 seconds of operation, allowing the unit to
correctly assess the load characteristics of the building and adjust
the capacity output accordingly.
The method for controlling the capacity is to vary the quantity
of refrigerant flowing through the entire system at any given time.
The compressor(s) used in the Samsung DVM system are
manufactured by Copeland in Sidney OH, and are a ``Digital Scroll''
type. This revolutionary compressor allows the system capacity to be
varied from 10% to 100% depending on the indoor load. This is
accomplished by allowing the fixed and orbiting scrolls inside the
compressor to separate during unloaded periods, which stops
refrigerant flow through the compressor and operates the compressor
motor in an unloaded fashion, which greatly reduces the power
consumed by the compressor,
The outdoor unit also uses variable speed condenser fan motor(s)
which can alter condenser airflow to exactly suit the outdoor air
temperature and building load to ensure the unit operates in the
most efficient manner possible.
The Indoor units all utilize an Electronic Expansion Valve (EEV)
which operates over a 480 step range from fully closed to fully
open. This extensive range allows precise monitoring of the
refrigerant quantity entering the evaporator coil and hence the
cooling or heating capacity of the unit.
This type of product will almost always operate below the 100%
capacity threshold (part load versus full load operation), and due
to the enhanced capacity control range of the DVM system it can
operate at 10% capacity if the building load has reduced to that
point.
This type of operation is very similar to the Water Chilling
units as detailed in ARI standard 550/590.
3. Waiver Requirements
Samsung/Quietside seeks a waiver of all current test standards
until a test standard can be developed and adopted that will provide
the HVAC market in the United States (US) with a fair and accurate
assessment of the DVM system energy consumption and efficiency
levels.
The current test procedures in place may evaluate the DVM system
in a manner that is not representative of the true energy efficiency
of the DVM system and provide inaccurate ratings which would be used
to compare the DVM system with other forms of Air Conditioning/Heat
Pumps in the market.
Due to the constant variation of the system capacity it is
patently inaccurate to rate the unit at its full load capacity or at
any other fixed point of capacity when the unit capacity is
constantly varying between 10% and 100% of the capacity.
[[Page 9632]]
Any test method utilized to rate these types of full variable
refrigerant flow units should be indicative of the ability of these
units to operate at 10%, 20%, 30% * * * 100% as this is the true
operation of the unit in the field.
During 2002 a committee was formed by ARI to discuss alternate
test methods for this type of multi split variable refrigerant flow
unit, however to this date no additional test methodology has been
adopted by the committee. As the Department is aware the timeframe
for drafting and approving such a standard may be months or even
years. The International Standards Organization have been currently
working on a standard of their own for several years at this point
in time.
Due to the lack of an approved standard at this present time,
the energy savings provided by the DVM System would not be
accurately represented should it be tested under the current
standards. This inaccurate representation will have a negative
impact upon the sales of both the Samsung DVM system and other
Variable Refrigerant Volume systems. This will not only greatly
affect the business revenue of Quietside and Samsung, but it will
prevent the country from realizing energy savings, particularly in
the area of peak load usage reduction.
To summarize, the test waiver for the DVM system is requested
for the following reasons:
A. No product currently for sale in the USA offers the ability
of a direct expansion system to vary its capacity every 20 seconds
between 10% and 100% of the building design load, and no existing
test standard can provide a method for providing ratings at those
capacity points.
B. No existing test standard allows for IPLV to be calculated in
the Heating mode.
C. No existing test standard provides for the benefits of
diversity due to the inherent ability of the DVM System to provide
zoned cooling. Also no existing test standard provides for credit
for negating duct loss from the nonducted units available with this
system.
D. No existing test standard provides a method to test and rate
a system that utilizes one outdoor unit and 16 indoor units.
E. No existing test standard can provide a method for rating
systems where the type and capacity of indoor unit can be used. The
DVM system can mix 6 different indoor models in up to 7 different
capacities. For example a 100,000 Btu/h system can use 2 x 11,000
Btu/h units of different models, 2 x 13,000 Btu/h units of
additional models, 2 x 24,000 Btu/h models from additional models
and still not be at 100% capacity load. The total number of unit
combinations available is over 1,000, not including the ability to
over or under size the indoor capacity with regard to the outdoor
unit capacity.
4. Similar Equipment Currently Offered for Sale in the U.S.
Sanyo
Mitsubishi Comfort Systems
Mitsubishi Electric U.S.
The above companies currently offer similar systems for sale in
the United States, these systems offer similar advantages and energy
savings inherent to all Variable Refrigerant Flow units, however no
other manufacturer utilizes the ``Digital Scroll'' technology and
the capacity range of the DVM system.
Mitsubishi Electric U.S. currently has a test waiver proposal in
front of the Department that has been published for comment in the
Federal Register.
5. Reasons for Granting a Test Waiver to the DVM System
The Samsung DVM System is currently offered for sale in the U.S.
marketplace, however the lack of an existing or proposed test
standard has resulted in the unit having to be provided with Energy
Guide labels detailing a 10 SEER, the lowest possible rating. The
true SEER of the DVM system would be a minimum of 50% higher.
This failure to correctly rate the energy efficiency of the unit
also does not allow the performance of the DVM system to be
certified by the ARI (no applicable test standard or test
availability), which causes a misconception of the efficiency level
of the DVM system and provides wholly inaccurate data to the U.S.
consumer.
These types of Variable Refrigerant Flow products are very well
established in the Asian and European markets, based on the high
levels of efficiency and comfort provided to the end user. U.S.
consumers should not be excluded from these benefits due to the lack
of an applicable test standard, and should not be beholden to
inaccurate data that will heavily disadvantage the DVM system or any
other Variable Refrigerant Flow system in a very competitive
marketplace.
Independent testing of the DVM system against conventional Air
conditioning systems shows an average of over 30% reduction on
energy consumption, not even including the reduction in peak load
operating consumption.
Samsung test data, showing EER values (Watt for Watt) shows
almost a full EER point increase over VAV and compressor control
units, and a similar increase over an Inverter Variable Refrigerant
Flow system. This test data is included in Appendix 2.
The disadvantage of the lack of an applicable test standard will
not only impact the potential sales of the DVM system, but also
result in economic losses not only for Samsung and Quietside but
also for the Copeland Corporation who have spent considerable time
and resources in developing the ``Digital Scroll'' compressors.
Samsung/Quietside formally urges the Department to grant an
interim waiver from existing test standards and allow Quietside to
work in conjunction with the other manufacturers of Variable
Refrigerant Flow products and the various organizations involved in
our industry to formulate a test standard that accurately reflects
the operation and energy consumption of these types of units.
Should the Department have any comments or questions regarding
this petition please do not hesitate to contact the undersigned.
Yours truly,
John Miles
Director of Engineering and Technical Support
Appendix 1 : Full Model List Samsung DVM System Products
Appendix 2 : Samsung performed Tests detailing Energy Efficiency
versus Delivered Capacity for the DVM System
I hereby certify that copies of this petition and application
for Interim Waiver of test standards have been mailed to the
following companies who are known to market similar Variable
Refrigerant Flow products
Mitsubishi Electric US
4505-A Newpoint Place
Lawrenceville GA 30043
Attn: William Rau, President, HVAC Advanced Products Division
Sanyo
1165 Allgood Road, Suite 22
Marietta, GA 30062
Attn: Tetsushi Yamashita, Engineering Manager, HVAC
Mitsubishi Heavy Industries Climate Control Inc
3030 E. Victoria Street
Rancho Dominguez CA 90221
Attn: Caesar Ceballos, Technical Support Manager
Appendix 1.--Samsung DVM System Products and Capacities
------------------------------------------------------------------------
Btu/h cooling/
2003 Model Description heating
------------------------------------------------------------------------
RVMH100FAMOU.................. Condensing Unit Heat 95,500/107,500
Pump.
RVMC100FAMOU.................. Condensing Unit 95,500/107,500
Cooling Only.
RVMH050CBMOU.................. Condensing Unit Heat 50,000/55,000
Pump.
RVMC050CBMOU.................. Condensing Unit 50,000/55,000
Cooling Only.
RVMC070FAMOU.................. Condensing Unit 76,000/85,000
Cooling Only.
AVMKH020CAOU.................. 1-Way Ceiling Cassette 7,000/7,500
Heat Pump.
AVMKC020CAOU.................. 1-Way Ceiling Cassette 7,000/7,500
Cooling Only.
AVMKH032CAOU.................. 1-Way Ceiling Cassette 11,000/12,000
Heat Pump.
AVMKC032CAOU.................. 1-Way Ceiling Cassette 11,000
Cooling Only.
AVMKH040CAOU.................. 1-Way Ceiling Cassette 13,500/14,500
Heat Pump.
[[Page 9633]]
AVMKC04OCAOU.................. 1-Way Ceiling Cassette 13,500
Cooling Only.
AVMCH052CAOU.................. 4-Way Ceiling Cassette 18,000/19,000
Heat Pump.
AVMCC052CAOU.................. 4-Way Ceiling Cassette 18,000
Cooling Only.
AVMCH072CAOU.................. 4-Way Ceiling Cassette 24,000/26,000
Heat Pump.
AVMCC072CAOU.................. 4-Way Ceiling Cassette 24,000
Cooling Only.
AVMCH105CAOU.................. 4-Way Ceiling Cassette 36,000/39,000
Heat Pump.
AVMCC105CAOU.................. 4-Way Ceiling Cassette 36,000
Cooling Only.
AVMBH020CAOU.................. Built-In Duct Heat 7,000/7,500
Pump.
AVMBC020CAOU.................. Built-In Duct Cooling 7,000
Only.
AVMBH032CAOU.................. Built-In Duct Heat 11,000/12,000
Pump.
AVMBC032CAOU.................. Built-In Duct Cooling 11,000
Only.
AVMBH040CAOU.................. Built-In Duct Heat 13,500/14,500
Pump.
AVMBC040CAOU.................. Built-In Duct Cooling 13,500
Only.
AVMBH052CAOU.................. Built-In Duct Heat 18,000/19,000
Pump.
AVMBC052CAOU.................. Built-In Duct Cooling 18,000
Only.
AVMBH072CAOU.................. Built-In Duct Heat 24,000/26,000
Pump.
AVMBC072CAOU.................. Built-In Duct Cooling 24,000
Only.
AVMHH105CAOU.................. HSP Duct Heat Pump.... 36,000/39,000
AVMHC105CAOU.................. HSP Duct Cooling Only. 36,000
AVMHH128CAOU.................. HSP Duct Heat Pump.... 44,000/47,000
AVMHC128CAOU.................. HSP Duct Cooling Only. 44,000
AVMDH052CAOU.................. Low Silhouette Duct 18,000/19,000
Heat Pump.
AVMDC052CAOU.................. Low Silhouette Cooling 18,000
Only.
AVMDH072CAOU.................. Low Silhouette Duct 24,000/26,000
Heat Pump.
AVMDC072CAOU.................. Low Silhouette Cooling 24,000
Only.
AVMWH020CAOU.................. High Wall Mount Heat 7,000/7,500
Pump.
AVMWC020CAOU.................. High Wall Mount 7,000
Cooling Only.
AVMWH032CAOU.................. High Wall Mount Heat 11,000/12,000
Pump.
AVMWC032CAOU.................. High Wall Mount 11,000
Cooling Only.
AVMWH040CAOU.................. High Wall Mount Heat 13,500/14,500
Pump.
AVMWC040CAOU.................. High Wall Mount 13,500
Cooling Only.
AVMWH052CAOU.................. High Wall Mount Heat 18,000/19,000
Pump.
AVMWC052CAOU.................. High Wall Mount 18,000
Cooling Only.
AVMWH072CAOU.................. High Wall Mount Heat 24,000/26,000
Pump.
AVMWC072CAOU.................. High Wall Mount 24,000
Cooling Only.
------------------------------------------------------------------------
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[FR Doc. 05-3782 Filed 2-25-05; 8:45 am]
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