Energy Conservation Program for Certain Industrial Equipment: Publication of the Petition for Waiver From Daikin AC (Americas), Inc. and Granting of the Interim Waiver From the Department of Energy Commercial Package Air Conditioner and Heat Pump Test Procedure, 66324-66330 [E9-29795]
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66324
Federal Register / Vol. 74, No. 239 / Tuesday, December 15, 2009 / Notices
Subpart B, Appendix M can be
accurately applied to the Daikin
Altherma product class. As explained
above in the DACA’s Petition for
Waiver, the design characteristics of the
Daikin Altherma product class clearly
prevent testing the Daikin Altherma
system with the prescribed test
procedures and obtaining a
representative result of the system’s true
energy consumption characteristics.
The likelihood of DOE approving
DACA’s Petition for Waiver is supported
by the DOE’s history of approving
previous waiver requests from other
manufacturers for products that are
similar to the Daikin Altherma product
class, based on the same rationale
offered by DACA in this Petition for
Waiver.
Additionally, DACA is likely to suffer
economic hardship and competitive
disadvantage if DOE does not grant its
interim waiver request. DACA is now
preparing to introduce its Daikin
Altherma product class in a matter of
months. If we must wait for completion
of the normal waiver consideration and
issuance process, DACA will be forced
to delay the opportunity to begin
recouping through product sales its
production and marketing costs
associated with introducing the Daikin
Altherma product class into the United
States market.
DOE approval of DACA’s interim
waiver application is also supported by
sound public policy reasons. As DOE
stated in its January 7, 2008 approval of
DACA’s interim waiver for the VRV–WII
product classes:
[I]n those instances where the likely
success of the Petition for Waiver has
been demonstrated, based upon DOE
having granted a waiver for similar
products design, it is in the public
interest to have similar products tested
and rated for energy consumption on a
comparable basis.
73 Fed. Reg. at 1215. The Daikin
Altherma product class will provide
superior comfort to the end user, and
will incorporate state of the art
technology such as variable speed
compressors and a solar kit to enhance
the energy efficiency performance of the
integrated domestic hot water
production system component. The
Daikin Altherma product class will
introduce technologies that will
increase system efficiency and reduce
national energy consumption, and that
will also offer a new level of comfort
and control to end users.
DACA requests that DOE grant our
Application for Interim Waiver so we
can bring the new highly energy
efficient technology represented by the
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17:23 Dec 14, 2009
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Daikin Altherma product class to the
market as soon as possible, thereby
allowing the U.S. consumer to benefit
from our high technology and high
efficiency product.
Confidential Information
DACA makes no request to DOE for
confidential treatment of any
information contained in this Petition
for Waiver and Application for Interim
Waiver.
Conclusion
Daikin AC (Americas), Inc.
respectfully requests DOE to grant its
Petition for Waiver of the applicable test
procedure to DACA for specified models
of the Altherma system, and to grant its
Application for Interim Waiver. DOE’s
failure to issue an interim waiver from
test standards would cause significant
economic hardship to DACA by
preventing DACA from marketing these
products even though DOE has
previously granted a waiver to other
products that were offered in the market
with similar design characteristics.
We would be pleased to respond to
any questions you may have regarding
this Petition for Waiver and Application
for Interim Waiver. Please contact Lee
Smith, Director of Product of Product
Marketing at 972–245–1510 or by email
at Lee.smith@daikinac.com.
Sincerely,
Akinori Atarashi
President
Daikin AC (Americas), Inc.
1645 Wallace Drive, Suite 110
Carrollton, Texas 75006
(Submitted in triplicate)
Encls: Copy of Daikin Altherma
Brochure, Engineering Data, EN
Testing & Rating Standards
[FR Doc. E9–29785 Filed 12–14–09; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
[Case No. CAC–025]
Energy Conservation Program for
Certain Industrial Equipment:
Publication of the Petition for Waiver
From Daikin AC (Americas), Inc. and
Granting of the Interim Waiver From
the Department of Energy Commercial
Package Air Conditioner and Heat
Pump Test Procedure
AGENCY: Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver,
granting of application for interim
waiver, and request for comments.
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SUMMARY: This notice announces receipt
of and publishes a petition for waiver
from Daikin AC (Americas), Inc.
(Daikin). The petition for waiver
(hereafter ‘‘petition’’) requests a waiver
from the U.S. Department of Energy
(DOE) test procedure applicable to
commercial package air-cooled central
air conditioners and heat pumps. The
petition is specific to the Daikin variable
capacity VRV–III–C (commercial) multisplit heat pumps. Through this
document, DOE: (1) Solicits comments,
data, and information with respect to
the Daikin Petition; and (2) announces
the grant of an interim waiver to Daikin
from the applicable DOE test procedure
for the subject commercial air-cooled,
multi-split air conditioners and heat
pumps.
DATES: DOE will accept comments, data,
and information with respect to the
Daikin Petition until, but no later than
January 14, 2010.
ADDRESSES: You may submit comments,
identified by case number ‘‘CAC–025,’’
by any of the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
AS_Waiver_Requests@ee.doe.gov.
Include either the case number [CAC–
025], and/or ‘‘Daikin Petition’’ in the
subject line of the message.
• Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Program, Mailstop EE–2J/
1000 Independence Avenue, SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–2945. Please
submit one signed original paper copy.
• Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza SW., Suite 600,
Washington, DC 20024. Please submit
one signed original paper copy.
Instructions: All submissions received
must include the agency name and case
number for this proceeding. Submit
electronic comments in WordPerfect,
Microsoft Word, Portable Document
Format (PDF), or text (American
Standard Code for Information
Interchange (ASCII)) file format and
avoid the use of special characters or
any form of encryption. Wherever
possible, include the electronic
signature of the author. DOE does not
accept telefacsimiles (faxes).
Any person submitting written
comments must also send a copy of
such comments to the petitioner,
pursuant to 10 CFR 431.401(d). The
contact information for the petitioner is:
Mr. Lee Smith, Director of Product
Marketing, Daikin AC (Americas), Inc.,
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1645 Wallace Drive, Suite 110,
Carrollton, Texas 75006.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit two copies: one copy of
the document including all the
information believed to be confidential,
and one copy of the document with the
information believed to be confidential
deleted. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Docket: For access to the docket to
review the background documents
relevant to this matter, you may visit the
U.S. Department of Energy, 950 L’Enfant
Plaza SW., (Resource Room of the
Building Technologies Program),
Washington, DC, 20024; (202) 586–2945,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
Available documents include the
following items: (1) This notice; (2)
public comments received; (3) the
petition for waiver and application for
interim waiver; and (4) prior DOE
rulemakings regarding similar central
air conditioning and heat pump
equipment. Please call Ms. Brenda
Edwards at the above telephone number
for additional information regarding
visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Dr.
Michael G. Raymond, U.S. Department
of Energy, Building Technologies
Program, Mail Stop EE–2J, Forrestal
Building, 1000 Independence Avenue,
SW., Washington, DC 20585–0121.
Telephone: (202) 586–9611. E-mail:
AS_Waiver_Requests@ee.doe.gov.
Ms. Francine Pinto or Mr. Michael
Kido, U.S. Department of Energy, Office
of the General Counsel, Mail Stop GC–
72, Forrestal Building, 1000
Independence Avenue, SW.,
Washington, DC 20585–0103.
Telephone: (202) 586–7432 or (202)
586–5827, respectively. E-mail:
Francine.Pinto@hq.doe.gov or
Michael.Kido@hq.doe.gov.
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SUPPLEMENTARY INFORMATION:
I. Background and Authority
Title III of the Energy Policy and
Conservation Act (EPCA) sets forth a
variety of provisions concerning energy
efficiency, including Part A of Title III,
which establishes the ‘‘Energy
Conservation Program for Consumer
Products Other Than Automobiles.’’ (42
U.S.C. 6291–6309) Similar to the
program in Part A, Part A–1 of Title III
provides for an energy efficiency
program titled, ‘‘Certain Industrial
Equipment,’’ which includes
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commercial air conditioning equipment,
package boilers, water heaters, and other
types of commercial equipment. (42
U.S.C. 6311–6317)
Today’s notice involves commercial
equipment under Part A–1. Part A–1
specifically includes definitions (42
U.S.C. 6311), test procedures (42 U.S.C.
6314), labeling provisions (42 U.S.C.
6315), energy conservation standards
(42 U.S.C 6313), and the authority to
require information and reports from
manufacturers (42 U.S.C. 6316). With
respect to test procedures, Part A–1
authorizes the Secretary of Energy (the
Secretary) to prescribe test procedures
that are reasonably designed to produce
results which measure energy
efficiency, energy use, and estimated
annual operating costs, and that are not
unduly burdensome to conduct. (42
U.S.C. 6314(a)(2)).
For commercial package airconditioning and heating equipment,
EPCA provides that ‘‘the test procedures
shall be those generally accepted
industry testing procedures or rating
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)) Under 42 U.S.C.
6314(a)(4)(B), the statute further directs
the Secretary to amend the test
procedure for a covered commercial
product if the industry test procedure is
amended, unless the Secretary
determines, by rule and based on clear
and convincing evidence, that such a
modified test procedure does not meet
the statutory criteria set forth in 42
U.S.C. 6314(a)(2) and (3).
On December 8, 2006, DOE published
a final rule adopting test procedures for
commercial package air-conditioning
and heating equipment, effective
January 8, 2007. 71 FR 71340. DOE
adopted ARI Standard 340/360–2004,
‘‘Performance Rating of Commercial and
Industrial Unitary Air-Conditioning and
Heat Pump Equipment,’’ for small and
large commercial package air-cooled
heat pumps with capacities ≥ 65,000
Btu/h and <760,000 British thermal
units per hour (Btu/h). Id. at 71371.
Pursuant to this rulemaking, DOE’s
regulations at 10 CFR 431.95(b)(2)
incorporate by reference ARI Standard
340/360–2004, and Table 1 to 10 CFR
431.96 directs manufacturers of
commercial package air-cooled air
conditioning and heating equipment to
use the appropriate procedure when
measuring energy efficiency of those
products. (The cooling capacities of
Daikin’s commercial VRV–III–C multi-
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split heat pump products, which are at
issue in the waiver petition filed by
Daikin, range from 6 tons (72,000 Btu/
hr) to 16 tons (192,000 Btu/hr), thereby
resulting in these products falling
within the range of ARI Standard 340/
360–2004, which covers products with
capacities greater than 65,000 Btu/hour.)
DOE’s regulations for covered
products permit a person to seek a
waiver from the test procedure
requirements for covered commercial
equipment if at least one of the
following conditions is met: (1) The
petitioner’s basic model contains one or
more design characteristics which
prevent testing according to the
prescribed test procedures; or (2) 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
431.401(a)(1). Petitioners must include
in their petition any alternate test
procedures known to the petitioner to
evaluate the basic model in a manner
representative of its energy
consumption. 10 CFR 431.401(b)(1)(iii).
The Assistant Secretary for Energy
Efficiency and Renewable Energy
(Assistant Secretary) may grant a waiver
subject to conditions, including
adherence to alternate test procedures.
10 CFR 431.401(f)(4). Waivers remain in
effect pursuant to the provisions of 10
CFR 431.401(g).
The waiver process also permits
parties submitting a petition for waiver
to file an application for interim waiver
of the applicable test procedure
requirements. 10 CFR 431.401(a)(2). The
Assistant Secretary will grant an interim
waiver request 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 431.401(e)(3). An
interim waiver remains in effect for a
period of 180 days or until DOE issues
its determination on the petition for
waiver, whichever occurs first, and it
may be extended by DOE for an
additional 180 days, if necessary. 10
CFR 431.401(e)(4).
II. Petition for Waiver
On September 9, 2009, Daikin filed a
petition for waiver from the test
procedures at 10 CFR 431.96, which are
applicable to commercial package aircooled central air conditioners and heat
pumps, and an application for interim
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Federal Register / Vol. 74, No. 239 / Tuesday, December 15, 2009 / Notices
waiver. The capacities of the Daikin
VRV–III–C multi-split heat pumps range
from 72,000 Btu/hr to 192,000 Btu/hr,
making the applicable test procedure for
Daikin’s commercial VRV–III–C multisplit heat pumps ARI Standard 340/
360–2004, which manufacturers are
directed to use pursuant to Table 1 of
10 CFR 431.96.
Daikin seeks a waiver from the
applicable test procedures under 10 CFR
431.96 on the grounds that its VRV–
III–C multi-split heat pumps contain
design characteristics that prevent
testing according to the current DOE test
procedures. Specifically, Daikin asserts
that the two primary factors that prevent
testing of its multi-split variable speed
products are the same factors stated in
the waivers that DOE granted to
Mitsubishi Electric & Electronics USA,
Inc. (Mitsubishi) for a similar line of
commercial multi-split air-conditioning
systems:
• Testing laboratories cannot test
products with so many indoor units;
and
• There are too many possible
combinations of indoor and outdoor
unit to test. 69 FR 52660 (August 27,
2004) (Mitsubishi waiver); 72 FR 17528
(April 9, 2007) (Mitsubishi waiver); 72
FR 71387 (Dec. 17, 2007) (Samsung
waiver); 72 FR 71383 (Dec. 17, 2007)
(Fujitsu waiver); 73 FR 39680 (July 10,
2008) (Daikin waiver); 74 FR 15955
(April 8, 2009) (Daikin waiver); 74 FR
16193 (April 9, 2009) (Sanyo waiver); 74
FR 16373 (April 10, 2009) (Daikin
waiver).
The VRV–III–C systems have
operational characteristics similar to
other commercial multi-split products
manufactured by Mitsubishi, Samsung,
Fujitsu and Sanyo, all of which have
already been granted waivers. The VRV–
III–C system can be connected to the
complete range of Daikin ceiling
mounted, concealed, ducted, corner,
cassette, wall-mounted and floormounted and other indoor fan coil
units. Each of these units has nine
different indoor static pressure ratings
as standard, with addition pressure
ratings available. In certain highcapacity applications, Daikin’s VRV–
III–C systems have the capability to
combine two outdoor units to create a
larger capacity system. There are over
one million combinations possible with
the DACA VRV–III–C system.
Accordingly, Daikin requested that DOE
grant a waiver from the applicable test
procedures for its VRV–III–C product
designs, until a suitable test method can
be prescribed.
III. Application for Interim Waiver
On September 9, 2009, in addition to
its petition for waiver, Daikin submitted
to DOE an application for interim
waiver. DOE determined that Daikin’s
application for interim waiver does not
provide sufficient market, equipment
price, shipments, and other
manufacturer impact information to
permit DOE to evaluate the economic
hardship Daikin might experience
absent a favorable determination on its
application for interim waiver.
However, DOE understands that absent
an interim waiver, Daikin’s products
would not otherwise be tested and rated
for energy consumption on a
comparable basis with equivalent
products where DOE previously granted
waivers. In other words, there would
not be a level playing field and thus
Daikin would be placed at a competitive
disadvantage. Furthermore, DOE has
determined that it appears likely that
Daikin’s Petition for Waiver will be
granted and that is desirable for public
policy reasons to grant Daikin
immediate relief pending a
determination on the petition for
waiver. DOE believes that it is likely
Daikin’s petition for waiver for the new
VRV–III–C multi-split models will be
granted because, as noted above, DOE
has previously granted a number of
waivers for similar product designs.1
The two principal reasons supporting
the grant of the previous waivers also
apply to Daikin’s VRV–III–C products:
(1) Test laboratories cannot test
products with so many indoor units;
and (2) it is impractical to test so many
combinations of indoor units with each
outdoor unit. In addition, DOE believes
that similar products should be tested
and rated for energy consumption on a
comparable basis. For these same
reasons, DOE also determined that it is
desirable for public policy reasons to
grant immediate relief pending a
determination on the petition for
waiver.
Therefore, it is ordered that:
The application for interim waiver
filed by Daikin is hereby granted for
Daikin’s VRV–III–C air-cooled multisplit heat pumps, subject to the
specifications and conditions below.
1. Daikin shall not be required to test
or rate its VRV–III–C commercial aircooled multi-split products on the basis
of the existing test procedure under 10
CFR 431.96, which incorporates by
reference ARI Standard 340/360–2004.
2. Daikin shall be required to test and
rate its VRV–III–C commercial aircooled multi-split products according to
the alternate test procedure as set forth
in section IV(3), ‘‘Alternate test
procedure.’’
The interim waiver applies to the
following basic model groups:
Combination
Type
Size
Model No.
8-Ton
Condensing Unit .............................................................
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2nd Stage Function Unit .................................................
Outdoor Piping Kit ...........................................................
6-Ton ......................................
8-Ton ......................................
10-Ton ....................................
Up to 16-Ton ..........................
................................................
RTSQ72PTJU ........................
RTSQ96PTJU ........................
RTSQ120PTJU ......................
BTSQ192PTJU ......................
BHFP30A56 ...........................
16-Ton
................
1
................
1
................
1
................
1
1
1
This interim waiver is conditioned
upon the presumed validity of
statements, representations, and
documents provided by the petitioner.
DOE may revoke or modify this interim
waiver at any time upon a
determination that the factual basis
underlying the petition for waiver is
incorrect, or upon a determination that
the results from the alternate test
procedure are unrepresentative of the
basic models’ true energy consumption
characteristics.
1 DOE notes that it has also previously granted
interim waivers to Fujitsu (70 FR 5980 (Feb. 4,
2005)), Samsung (70 FR 9629 (Feb. 28, 2005)),
Mitsubishi (72 FR 17533 (April 9, 2007)), and
Daikin (72 FR 35986 (July 2, 2007)), for comparable
commercial multi-split air conditioners and heat
pumps.
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Federal Register / Vol. 74, No. 239 / Tuesday, December 15, 2009 / Notices
IV. Alternate Test Procedure
Responding to two recent petitions for
waiver from Mitsubishi, DOE specified
an alternate test procedure to provide a
basis from which Mitsubishi could test
and make valid energy efficiency
representations for its R410A CITY
MULTI products, as well as for its R22
multi-split products. Alternate test
procedures related to the Mitsubishi
petitions were published in the Federal
Register on April 9, 2007. See 72 FR
17528 and 72 FR 17533. For reasons
similar to those published in these prior
notices, DOE believes that an alternate
test procedure is appropriate in this
instance.
DOE understands that existing testing
facilities have a limited ability to test
multiple indoor units simultaneously,
and the large number of possible
combinations of indoor and outdoor
units for some variable refrigerant flow
zoned systems makes it impractical for
manufacturers to test. We further note
that subsequent to the waiver that DOE
granted for Mitsubishi’s R22 multi-split
products, ARI formed a committee to
discuss the issue and to work on
developing an appropriate testing
protocol for variable refrigerant flow
systems. However, to date, no additional
test methodologies have been adopted
by the committee or submitted to DOE.
Therefore, as discussed below, as a
condition for granting this interim
waiver to Daikin, DOE is including an
alternate test procedure similar to those
granted to Mitsubishi for its R22 and
R410A products. DOE plans to consider
the same alternate test procedure in the
context of the subsequent Decision and
Order pertaining to Daikin’s petition for
waiver. Utilization of this alternate test
procedure will allow Daikin to test and
make energy efficiency representations
for its VRV–III–C products. More
broadly, DOE has applied a similar
alternate test procedure to other waivers
for similar residential and commercial
central air conditioners and heat pumps.
Such cases include petitions for waiver
involving multi-split products
manufactured by Mitsubishi (72 FR
17528, April 9, 2007); Samsung (72 FR
71387, Dec. 17, 2007); Fujitsu (72 FR
71383, Dec. 17, 2007); Daikin (73 FR
39680, July 10, 2008); Daikin (74 FR
15955, April 8, 2009); Sanyo (74 FR
16193, April 9, 2009); and Daikin (74 FR
16373, April 10, 2009).
The alternate test procedure
developed in conjunction with the
Mitsubishi waiver permits Daikin to
designate a ‘‘tested combination’’ for
each model of outdoor unit. The indoor
units designated as part of the tested
combination must meet specific
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requirements. For example, the tested
combination must have from two to
eight indoor units so that it can be
tested in available test facilities. (The
‘‘tested combination’’ was originally
defined to consist of one outdoor unit
matched with between 2 and 5 indoor
units. The maximum number of indoor
units in a tested combination is
increased in this instance from 5 to 8 to
account for the fact that these largercapacity products can accommodate a
greater number of indoor units.) The
tested combination must be tested
according to the applicable DOE test
procedure, as modified by the
provisions of the alternate test
procedure as set forth below. The
alternate test procedure also allows
manufacturers of such products to make
valid and consistent representations of
energy efficiency for their airconditioning and heat pump products.
In the present case, DOE is modifying
the alternate test procedure taken from
the above-referenced waiver granted to
Mitsubishi for its R410A and R22 CITY
MULTI products to revise the definition
of a ‘‘tested combination.’’ The ‘‘tested
combination’’ was originally defined to
consist of one outdoor unit matched
with between 2 and 5 indoor units. The
maximum number of indoor units in a
tested combination is here increased
from 5 to 8 to account for the fact that
these larger-capacity products (>150,000
Btu/h) can accommodate a greater
number of indoor units. DOE plans to
consider inclusion of the following
waiver language in the Decision and
Order for Daikin’s VRV–III–C
commercial multi-split air-cooled heat
pump models:
(1) The ‘‘Petition for Waiver’’ filed by
Daikin Electronics, Inc. is hereby
granted as set forth in the paragraphs
below.
(2) Daikin shall not be required to test
or rate its VRV–III–C variable capacity
multi-split heat pump products listed
above in section III, on the basis of the
existing test procedures, but shall be
required to test and rate such products
according to the alternate test procedure
as set forth in paragraph (3).
(3) Alternate test procedure.
(A) Daikin shall be required to test the
products listed in section III above
according to the test procedures for
central air conditioners and heat pumps
prescribed by DOE at 10 CFR 431.96,
except that Daikin shall test a ‘‘tested
combination’’ selected in accordance
with the provisions of subparagraph (B)
of this paragraph. For every other
system combination using the same
outdoor unit as the tested combination,
Daikin shall make representations
concerning the VRV–III–C products
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66327
covered in this waiver according to the
provisions of subparagraph (C) below.
(B) Tested combination. The term
‘‘tested combination’’ means a sample
basic model comprised of units that are
production units, or are representative
of production units, of the basic model
being tested. For the purposes of this
waiver, the tested combination shall
have the following features:
(1) The basic model of a variable
refrigerant flow system used as a tested
combination shall consist of one
outdoor unit, with one or more
compressors, that is matched with
between 2 and 8 indoor units; for multisplit systems, each of these indoor units
shall be designed for individual
operation.
(2) The indoor units shall—
(i) Represent the highest sales model
family or another indoor model family
if the highest sales model family does
not provide sufficient capacity (see ii);
(ii) Together, have a nominal cooling
capacity that is between 95% and 105%
of the nominal cooling capacity of the
outdoor unit;
(iii) Not, individually, have a nominal
cooling capacity that is greater than
50% of the nominal cooling capacity of
the outdoor unit;
(iv) Operate at fan speeds that are
consistent with the manufacturer’s
specifications; and
(v) Be subject to the same minimum
external static pressure requirement
while being configurable to produce the
same static pressure at the exit of each
outlet plenum when manifolded as per
section 2.4.1 of 10 CFR Part 430, subpart
B, appendix M.
(C) Representations. In making
representations about the energy
efficiency of its VRV–III–C variable
capacity air-cooled multi-split heat
pump products, for compliance,
marketing, or other purposes, Daikin
must fairly disclose the results of testing
under the DOE test procedure, doing so
in a manner consistent with the
provisions outlined below:
(1) For VRV–III–C combinations
tested in accordance with this alternate
test procedure, Daikin may make
representations based on these test
results.
(2) For VRV–III–C combinations that
are not tested, Daikin may make
representations based on the testing
results for the tested combination at the
same energy efficiency level as the
tested combination with the same
outdoor unit and which is consistent
with either of the two following
methods:
(i) Representation of non-tested
combinations according to an
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1000 Independence Ave, SW.,
Washington, DC 20585–0121
Alternative Rating Method (ARM)
approved by DOE; or
(ii) Representation of non-tested
combinations at the same energy
efficiency level as the tested
combination with the same outdoor
unit.
Re: Petition for Waiver of Test
Procedure
V. Summary and Request for Comments
Through today’s notice, DOE
announces receipt of the Daikin petition
for waiver from the test procedures
applicable to Daikin’s VRV–III–C
commercial multi-split heat pump
products, and for the reasons articulated
above, DOE grants Daikin an interim
waiver from those procedures. As part
of this notice, DOE is publishing
Daikin’s petition for waiver in its
entirety. The petition contains no
confidential information. Furthermore,
today’s notice includes an alternate test
procedure that Daikin is required to
follow as a condition of its interim
waiver and that DOE is considering
including in its subsequent Decision
and Order. In this alternate test
procedure, DOE is defining a ‘‘tested
combination’’ which Daikin could use
in lieu of testing all retail combinations
of its VRV–III–C multi-split heat pump
products.
DOE is interested in receiving
comments on the issues addressed in
this notice. Pursuant to 10 CFR
431.401(d), any person submitting
written comments must also send a
copy of such comments to the
petitioner, whose contact information is
included in the section entitled
ADDRESSES section above.
Issued in Washington, DC, on December 8,
2009.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
September 9, 2009.
Ms. Catherine Zoi
Assistant Secretary for Energy Efficiency
and Renewable Energy
U.S. Department of Energy
Dear Assistant Secretary Zoi:
Daikin AC (Americas) Inc. (DACA)
respectfully petitions the Department of
Energy (DOE) pursuant to 10 CFR
§ 431.401(a)(1) (2009) for a waiver of the
test procedures applicable to central air
conditioners and heat pumps, as
established in 10 C.F.R. § 431.96 (2009)
and ARI Standard 340/360–20041, for
the Daikin VRV–III–C system (also
called Cold Climate VRV), an air source
heat pump system that incorporates a
unique second stage refrigeration cycle
to deliver improved heating
performance and efficiency at lower
ambient conditions. The specific models
for which DACA requests this waiver in
the Daikin VRV–III–C product class are
listed below in this Petition. DACA
seeks a waiver from the existing central
air conditioner and central air
conditioning heat pump test procedure
for the Daikin VRV–III–C line of heat
pumps because the basic models
contain design criteria that prevent
testing of the basic models according to
the prescribed test procedures. We are
simultaneously requesting an interim
waiver for the same systems pursuant to
10 CFR § 431.401(a)(2) (2009).
General Characteristics of DACA’s
VRV–III–C Products
The Daikin VRV–III–C system has the
following characteristics and
applications:
• The VRV–III–C operates as a heat
pump system only (as an 8-ton or a 16ton system).
• The VRV–III–C is an inverter
controlled heat pump system that can
provide year round heating in very low
outdoor temperatures. In low ambient
conditions, the VRV–III–C offers 30%
more heating capacity than a standard
Daikin VRV–III heat pump.
• The VRV–III–C can provide cooling
in ambient temperatures down to 23 °F.
• The VRV–III–C includes a
proprietary 2-stage refrigeration cycle
technology to ensure improved heating
effect.
• The VRV–III–C delivers nominal
(rated) heating capacity at 5 °F (¥15 °C)
(rated condition is 47 °F).
• The VRV–III–C delivers 87% of
nominal (rated) heating capacity at ¥4
°F (¥20 °C), and the system delivers
75% of nominal (rated) heating capacity
at ¥13 °F (¥25 °C).
• The VRV–III–C provides an
enhanced heating ‘‘warm up’’ function.
• The VRV–III–C minimizes heating
downtime from defrost operation.
• The VRV–III–C system eliminates
the need to use supplemental
‘‘resistance type’’ strip heating elements.
• The VRV–III–C system heat pump
compressor’s inverter technology
includes an integrated frequencyconverter that adjusts the rotational
speed of the compressor to meet the
heating or cooling demand. Therefore,
the system seldom operates at full
capacity.
• The VRV–III–C system can be
linked to the complete range of Daikin
Ceiling-Mounted, Concealed, Ducted,
Corner, Cassette, Wall-Mounted, FloorMounted and other indoor fan coil
units, providing the same connection
flexibility as Daikin’s standard VRV
systems. The amount of piping, and the
number, diversity and range of indoor
units that can be connected to the VRV–
III–C is comparable to the Daikin VRV–
II, VRV–II–S and VRV–III systems for
which DOE has previously issued
waivers.
Particular Basic Models for Which
DACA Requests a Waiver
DACA requests a waiver from the test
procedures for the following basic
model groups:
Combination
Type
Size
Model Number
8-Ton
Condensing Unit ..........................................................
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2nd Stage Function Unit .............................................
Outdoor Piping Kit .......................................................
6-Ton ...............................
8-Ton ...............................
10-Ton .............................
Up to 16-Ton ...................
..........................................
RTSQ72PTJU ..................
RTSQ96PTJU ..................
RTSQ120PTJU ................
BTSQ192PTJU ................
BHFP30A56 .....................
1 Detailed citations to the test procedures for
which DACA is requesting a waiver are included on
page 3 of this petition.
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16-Ton
........................
1
........................
1
........................
1
........................
1
1
1
Federal Register / Vol. 74, No. 239 / Tuesday, December 15, 2009 / Notices
VRV–III–C System Characteristics
Constituting the Grounds for DACA’s
Petition
sroberts on DSKD5P82C1PROD with NOTICES
The Daikin VRV–III–C system consists
of a heat pump that comprises a newly
designed outdoor unit and ‘‘function
unit’’ featuring two-stage compression
technology. This design feature gives
the VRV–III–C its outstanding
performance characteristics by creating
the higher pressures necessary for
efficient system operation under low
ambient conditions.
The Daikin VRV–III–C system can be
connected to the complete range of
Daikin Ceiling Mounted, Concealed,
Ducted, Corner, Cassette, Wall-Mounted
and Floor-Mounted and other indoor fan
coil units. Each of these units has nine
different indoor static pressure ratings
as standard, with addition pressure
ratings available. There are over one
million combinations possible with the
DACA VRV–III–C product offerings. It is
completely impractical for testing
laboratories to test a product such as the
VRV–III–C with multiple indoor units
because of the huge number of potential
system configurations.
The test method for central air
conditioners and heat pumps contained
in 10 C.F.R. § 431.96, Subpart B,
Appendix M does not account for the
extremely large number of potential
system configurations possible with the
VRV–III–C system. Therefore, the
currently applicable test method cannot
accurately account for the Daikin VRV–
III–C system’s energy performance
across the range of possible system
configurations.
DACA’s VRV–III products share many
of the design characteristics and features
of similar equipment for which DOE has
already approved either interim waivers
or waivers, including DACA’s VRV,
VRV–S and VRV–III product lines, and
Mitsubishi Electric and Electronics
USA, Inc.’s (MEUS) CITY MULTI and
S&L product classes.2 The same testing
constraints and limitations apply to all
of these products.
The rationale for DACA’s Petition for
a waiver from testing standards for the
Daikin VRV–III–C system is virtually
identical to basis for the other
manufacturers’ previous requests for
waivers noted above. DACA requests
2 DOE granted DACA an interim waiver for its
VRV and VRV–S product lines in a letter dated
August 14, 2006, and DOE renewed this interim
waiver on July 2, 2007 (72 Fed. Reg. 35,986). DOE
granted MEUS a waiver for its CITY MULTI VRFZ
class of products. 69 Fed. Reg. 52,660 (August 27,
2004). DOE granted DACA a waiver for its VRV–III
product lines on April 8, 2009 (74 Fed. Reg. 15,955).
DOE has recently granted MEUS an interim waiver
for its S&L Class multi-split heat pumps and heat
recovery systems.
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that DOE apply the same rationale to
DACA’s Petition for waiver for the
Daikin VRV–III–C system that DOE used
to grant the previous waiver petitions
for their similar systems.
Specific Testing Requirements Sought
to be Waived
The test procedures from which
DACA is requesting a waiver are
contained in 10 C.F.R. § 431.96(b), Table
1, which incorporates ARI Standard
340/360–2004 by reference into 10
C.F.R. Part 431, and which is applicable
to central air conditioner and heat pump
equipment with a capacity of >65,000
Btu/hr.
Discussion of Need for Requested
Waiver
Although the capacity of the Daikin
VRV–III–C product class is within the
scope of 10 C.F.R. Part § 431.96, the
design characteristics of the Daikin
VRV–III–C product class prevent testing
of the system according to the
prescribed test procedures in a manner
that represents the system’s true energy
consumption characteristics.
Specifically, application of the existing
prescribed test method cannot account
for the large number of possible
combinations of indoor and outdoor
units that would be subject to testing.
Also, it is impossible for testing
laboratories to test products with such
a large number of possible
combinations.
The absence of a waiver from the
required testing procedure will restrict
the availability to consumers in the
United States of the Daikin VRV–III–C
system’s energy savings benefits that
result from integrating domestic hot
water production into the system.
Manufacturers of Other Basic Models
Incorporating Similar Design
Characteristics
DACA is aware of the following
manufacturer that produces a basic
model incorporating similar design
characteristics to the VRV–III–C in the
United States market:
• Mitsubishi Electric & Electronics
USA, Inc.3
Alternative Test Procedure
DACA proposes that DOE apply the
same alternate test procedure to the
covered VRV–III–C products as DOE
applied to DACA’s VRV–III products in
the waiver that DOE granted for those
products on April 8, 2009 (74 Fed. Reg.
15,955). The alternate test method
3 MEUS’s Hyper Heating VRF system has similar
design characteristics to the VRV–III–C system,
offering year-round heating in low ambient
temperatures.
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66329
appears in Section 3 of the VRV–III
waiver. 74 Fed. Reg. at 15,958.
Application for Interim Waiver
DACA also hereby applies pursuant to
10 C.F.R. § 431.401(a)(2) for an interim
waiver of the applicable test procedure
requirements for the Daikin VRV–III–C
product class models listed above. The
basis for DACA’s Application for
Interim Waiver follows.
DACA is likely to succeed in its
Petition for Waiver because there is no
reasonable argument that the test
method contained in 10 C.F.R. § 431.96
can be accurately applied to the Daikin
VRV–III–C product class. As explained
above in the DACA’s Petition for
Waiver, the design characteristics of the
Daikin VRV–III–C product class clearly
prevent testing the Daikin VRV–III–C
system with the prescribed test
procedures because of the large number
of possible system combinations and the
limitations of existing testing facilities.
The likelihood of DOE approving
DACA’s Petition for Waiver is supported
by the DOE’s history of approving
previous waiver requests from other
manufacturers for products that are
similar to the Daikin VRV–III–C product
class, based on the same rationale
offered by DACA in this Petition for
Waiver.
Additionally, DACA is likely to suffer
economic hardship and competitive
disadvantage if DOE does not grant its
interim waiver request. DACA is now
preparing to introduce its Daikin VRV–
III–C product class in a matter of
months. If we must wait for completion
of the normal waiver consideration and
issuance process, DACA will be forced
to delay the opportunity to begin
recouping through product sales its
production and marketing costs
associated with introducing the Daikin
VRV–III–C product class into the United
States market.
DOE approval of DACA’s interim
waiver application is also supported by
sound public policy reasons. As DOE
stated in its January 7, 2008 approval of
DACA’s interim waiver for the VRV–WII
product classes:
[I]n those instances where the likely
success of the Petition for Waiver has
been demonstrated, based upon DOE
having granted a waiver for similar
products design, it is in the public
interest to have similar products tested
and rated for energy consumption on a
comparable basis.
73 Fed. Reg. at 1215. The Daikin
VRV–III–C product class will provide
superior comfort to the end user, and
will incorporate state of the art
technology such as an advanced inverter
drive and two-stage compression that
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enable the system to provide year round
heating in very low ambient
temperatures. The Daikin VRV–III–C
product class will introduce
technologies that will increase system
efficiency and reduce national energy
consumption, and that will also offer a
new level of comfort and control to end
users.
DACA requests that DOE grant our
Application for Interim Waiver so we
can bring the new highly energy
efficient technology represented by the
Daikin VRV–III–C product class to the
market as soon as possible, thereby
allowing the U.S. consumer to benefit
from our high technology and high
efficiency product.
Confidential Information
sroberts on DSKD5P82C1PROD with NOTICES
DACA makes no request to DOE for
confidential treatment of any
information contained in this Petition
for Waiver and Application for Interim
Waiver.
• Conclusion
Daikin AC (Americas), Inc.
Corporation respectfully requests DOE
to grant its Petition for Waiver of the
applicable test procedure to DACA for
specified models of the VRV–III–C
system, and to grant its Application for
Interim Waiver. DOE’s failure to issue
an interim waiver from test standards
would cause significant economic
hardship to DACA by preventing DACA
from marketing these products even
though DOE has previously granted
waivers to other products that were
offered in the market with similar
design characteristics.
We would be pleased to respond to
any questions you may have regarding
this Petition for Waiver and Application
for Interim Waiver. Please contact Lee
Smith, Director of Product Marketing at
972–245–1510 or by email at
Lee.smith@daikinac.com.
Sincerely,
Akinori Atarashi,
President
Daikin AC (Americas), Inc.
1645 Wallace Drive
Suite 110
Carrollton, Texas 75006
(Submitted in triplicate)
Encls.
cc:
Mitsubishi Electric & Electronics USA, Inc
4300 Lawrenceville-Suwanee Road
Suwanee, GA 30024
Attn: William Rau, Senior Vice President and
General Manager
[FR Doc. E9–29795 Filed 12–14–09; 8:45 am]
BILLING CODE 6450–01–P
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DEPARTMENT OF ENERGY
[Case No. CAC–021]
Energy Conservation Program for
Commercial Equipment: Decision and
Order Granting a Waiver to LG
Electronics, Inc. (LG) From the
Department of Energy Commercial
Package Air Conditioner and Heat
Pump Test Procedures
AGENCY: Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Decision and Order.
SUMMARY: This notice publishes the U.S.
Department of Energy’s (DOE) Decision
and Order in Case No. CAC–021, which
grants a waiver to LG from the existing
DOE test procedure applicable to
commercial package central air
conditioners and heat pumps. The
waiver is specific to the LG variable
speed and variable refrigerant volume
Multi V (commercial) multi-split heat
pumps and heat recovery systems. As a
condition of this waiver, LG must test
and rate its Multi V multi-split products
according to the alternate test procedure
set forth in this notice.
DATES: This Decision and Order is
effective December 15, 2009.
FOR FURTHER INFORMATION CONTACT: Dr.
Michael G. Raymond, U.S. Department
of Energy, Building Technologies
Program, Mailstop EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–9611. E-mail:
Michael.Raymond@ee.doe.gov.
Francine Pinto or Michael Kido, U.S.
Department of Energy, Office of the
General Counsel, Mail Stop GC–72,
1000 Independence Avenue, SW.,
Washington, DC 20585–0103.
Telephone: (202) 586–9507. E-mail:
Francine.Pinto@hq.doe.gov or
Michael.Kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION: In
accordance with 10 CFR 431.401(f)(4),
DOE gives notice of the issuance of its
Decision and Order as set forth below.
In this Decision and Order, DOE grants
LG a Waiver from the existing DOE
commercial package air conditioner and
heat pump test procedures for its Multi
V multi-split products, subject to a
condition requiring LG to test and rate
the specified models from its Multi V
multi-split product line pursuant to the
alternate test procedure provided in this
notice. The current test procedure is the
Air-Conditioning and Refrigeration
Institute (ARI) Standard 340/360–2004,
‘‘Performance Rating of Commercial and
Industrial Unitary Air-Conditioning and
Heat Pump Equipment’’ (incorporated
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by reference at 10 CFR 431.95(b)(2)).
Further, today’s decision requires that
LG may not make any representations
concerning the energy efficiency of
these products unless such product has
been tested consistent with the
provisions and restrictions in the
alternate test procedure set forth in the
Decision and Order below, and such
representations fairly disclose the
results of such testing. (42 U.S.C.
6314(d)) Distributors, retailers, and
private labelers are held to the same
standard when making representations
regarding the energy efficiency of these
products. (42 U.S.C. 6293(c)).
Issued in Washington, DC, on December 8,
2009.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
Decision and Order
In the Matter of: LG Electronics, Inc.
(LG) (Case No. CAC–021).
Background
Title III of the Energy Policy and
Conservation Act (EPCA) sets forth a
variety of provisions concerning energy
efficiency, including Part A of Title III
which establishes the ‘‘Energy
Conservation Program for Consumer
Products Other Than Automobiles.’’ (42
U.S.C. 6291–6309) Similar to the
program in Part A, Part A–1 of Title III
provides for an energy efficiency
program titled, ‘‘Certain Industrial
Equipment,’’ which includes large and
small commercial air conditioning
equipment, package boilers, storage
water heaters, and other types of
commercial equipment. (42 U.S.C.
6311–6317).
Today’s notice involves commercial
equipment under Part A–1. The statute
specifically includes definitions, test
procedures, labeling provisions, energy
conservation standards, and provides
the Secretary of Energy (the Secretary)
with the authority to require
information and reports from
manufacturers. 42 U.S.C. 6311–6317.
With respect to test procedures, the
statute generally authorizes the
Secretary to prescribe test procedures
that are reasonably designed to produce
test results which reflect energy
efficiency, energy use, and estimated
annual operating costs, and that are not
unduly burdensome to conduct. (42
U.S.C. 6314(a)(2)).
For commercial package airconditioning and heating equipment,
EPCA provides that ‘‘the test procedures
shall be those generally accepted
industry testing procedures or rating
procedures developed or recognized by
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Agencies
[Federal Register Volume 74, Number 239 (Tuesday, December 15, 2009)]
[Notices]
[Pages 66324-66330]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-29795]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
[Case No. CAC-025]
Energy Conservation Program for Certain Industrial Equipment:
Publication of the Petition for Waiver From Daikin AC (Americas), Inc.
and Granting of the Interim Waiver From the Department of Energy
Commercial Package Air Conditioner and Heat Pump Test Procedure
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver, granting of application for
interim waiver, and request for comments.
-----------------------------------------------------------------------
SUMMARY: This notice announces receipt of and publishes a petition for
waiver from Daikin AC (Americas), Inc. (Daikin). The petition for
waiver (hereafter ``petition'') requests a waiver from the U.S.
Department of Energy (DOE) test procedure applicable to commercial
package air-cooled central air conditioners and heat pumps. The
petition is specific to the Daikin variable capacity VRV-III-C
(commercial) multi-split heat pumps. Through this document, DOE: (1)
Solicits comments, data, and information with respect to the Daikin
Petition; and (2) announces the grant of an interim waiver to Daikin
from the applicable DOE test procedure for the subject commercial air-
cooled, multi-split air conditioners and heat pumps.
DATES: DOE will accept comments, data, and information with respect to
the Daikin Petition until, but no later than January 14, 2010.
ADDRESSES: You may submit comments, identified by case number ``CAC-
025,'' by any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: AS_Waiver_Requests@ee.doe.gov. Include either
the case number [CAC-025], and/or ``Daikin Petition'' in the subject
line of the message.
Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J/1000 Independence Avenue,
SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. Please
submit one signed original paper copy.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department
of Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Please submit one signed original paper
copy.
Instructions: All submissions received must include the agency name
and case number for this proceeding. Submit electronic comments in
WordPerfect, Microsoft Word, Portable Document Format (PDF), or text
(American Standard Code for Information Interchange (ASCII)) file
format and avoid the use of special characters or any form of
encryption. Wherever possible, include the electronic signature of the
author. DOE does not accept telefacsimiles (faxes).
Any person submitting written comments must also send a copy of
such comments to the petitioner, pursuant to 10 CFR 431.401(d). The
contact information for the petitioner is: Mr. Lee Smith, Director of
Product Marketing, Daikin AC (Americas), Inc.,
[[Page 66325]]
1645 Wallace Drive, Suite 110, Carrollton, Texas 75006.
According to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit two copies: one copy of the document including
all the information believed to be confidential, and one copy of the
document with the information believed to be confidential deleted. DOE
will make its own determination about the confidential status of the
information and treat it according to its determination.
Docket: For access to the docket to review the background documents
relevant to this matter, you may visit the U.S. Department of Energy,
950 L'Enfant Plaza SW., (Resource Room of the Building Technologies
Program), Washington, DC, 20024; (202) 586-2945, between 9 a.m. and 4
p.m., Monday through Friday, except Federal holidays. Available
documents include the following items: (1) This notice; (2) public
comments received; (3) the petition for waiver and application for
interim waiver; and (4) prior DOE rulemakings regarding similar central
air conditioning and heat pump equipment. Please call Ms. Brenda
Edwards at the above telephone number for additional information
regarding visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Dr. Michael G. Raymond, U.S.
Department of Energy, Building Technologies Program, Mail Stop EE-2J,
Forrestal Building, 1000 Independence Avenue, SW., Washington, DC
20585-0121. Telephone: (202) 586-9611. E-mail: AS_Waiver_Requests@ee.doe.gov.
Ms. Francine Pinto or Mr. Michael Kido, U.S. Department of Energy,
Office of the General Counsel, Mail Stop GC-72, Forrestal Building,
1000 Independence Avenue, SW., Washington, DC 20585-0103. Telephone:
(202) 586-7432 or (202) 586-5827, respectively. E-mail:
Francine.Pinto@hq.doe.gov or Michael.Kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Background and Authority
Title III of the Energy Policy and Conservation Act (EPCA) sets
forth a variety of provisions concerning energy efficiency, including
Part A of Title III, which establishes the ``Energy Conservation
Program for Consumer Products Other Than Automobiles.'' (42 U.S.C.
6291-6309) Similar to the program in Part A, Part A-1 of Title III
provides for an energy efficiency program titled, ``Certain Industrial
Equipment,'' which includes commercial air conditioning equipment,
package boilers, water heaters, and other types of commercial
equipment. (42 U.S.C. 6311-6317)
Today's notice involves commercial equipment under Part A-1. Part
A-1 specifically includes definitions (42 U.S.C. 6311), test procedures
(42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315), energy
conservation standards (42 U.S.C 6313), and the authority to require
information and reports from manufacturers (42 U.S.C. 6316). With
respect to test procedures, Part A-1 authorizes the Secretary of Energy
(the Secretary) to prescribe test procedures that are reasonably
designed to produce results which measure energy efficiency, energy
use, and estimated annual operating costs, and that are not unduly
burdensome to conduct. (42 U.S.C. 6314(a)(2)).
For commercial package air-conditioning and heating equipment, EPCA
provides that ``the test procedures shall be those generally accepted
industry testing procedures or rating 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)) Under 42 U.S.C.
6314(a)(4)(B), the statute further directs the Secretary to amend the
test procedure for a covered commercial product if the industry test
procedure is amended, unless the Secretary determines, by rule and
based on clear and convincing evidence, that such a modified test
procedure does not meet the statutory criteria set forth in 42 U.S.C.
6314(a)(2) and (3).
On December 8, 2006, DOE published a final rule adopting test
procedures for commercial package air-conditioning and heating
equipment, effective January 8, 2007. 71 FR 71340. DOE adopted ARI
Standard 340/360-2004, ``Performance Rating of Commercial and
Industrial Unitary Air-Conditioning and Heat Pump Equipment,'' for
small and large commercial package air-cooled heat pumps with
capacities >= 65,000 Btu/h and <760,000 British thermal units per hour
(Btu/h). Id. at 71371. Pursuant to this rulemaking, DOE's regulations
at 10 CFR 431.95(b)(2) incorporate by reference ARI Standard 340/360-
2004, and Table 1 to 10 CFR 431.96 directs manufacturers of commercial
package air-cooled air conditioning and heating equipment to use the
appropriate procedure when measuring energy efficiency of those
products. (The cooling capacities of Daikin's commercial VRV-III-C
multi-split heat pump products, which are at issue in the waiver
petition filed by Daikin, range from 6 tons (72,000 Btu/hr) to 16 tons
(192,000 Btu/hr), thereby resulting in these products falling within
the range of ARI Standard 340/360-2004, which covers products with
capacities greater than 65,000 Btu/hour.)
DOE's regulations for covered products permit a person to seek a
waiver from the test procedure requirements for covered commercial
equipment if at least one of the following conditions is met: (1) The
petitioner's basic model contains one or more design characteristics
which prevent testing according to the prescribed test procedures; or
(2) 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 431.401(a)(1).
Petitioners must include in their petition any alternate test
procedures known to the petitioner to evaluate the basic model in a
manner representative of its energy consumption. 10 CFR
431.401(b)(1)(iii). The Assistant Secretary for Energy Efficiency and
Renewable Energy (Assistant Secretary) may grant a waiver subject to
conditions, including adherence to alternate test procedures. 10 CFR
431.401(f)(4). Waivers remain in effect pursuant to the provisions of
10 CFR 431.401(g).
The waiver process also permits parties submitting a petition for
waiver to file an application for interim waiver of the applicable test
procedure requirements. 10 CFR 431.401(a)(2). The Assistant Secretary
will grant an interim waiver request 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
431.401(e)(3). An interim waiver remains in effect for a period of 180
days or until DOE issues its determination on the petition for waiver,
whichever occurs first, and it may be extended by DOE for an additional
180 days, if necessary. 10 CFR 431.401(e)(4).
II. Petition for Waiver
On September 9, 2009, Daikin filed a petition for waiver from the
test procedures at 10 CFR 431.96, which are applicable to commercial
package air-cooled central air conditioners and heat pumps, and an
application for interim
[[Page 66326]]
waiver. The capacities of the Daikin VRV-III-C multi-split heat pumps
range from 72,000 Btu/hr to 192,000 Btu/hr, making the applicable test
procedure for Daikin's commercial VRV-III-C multi-split heat pumps ARI
Standard 340/360-2004, which manufacturers are directed to use pursuant
to Table 1 of 10 CFR 431.96.
Daikin seeks a waiver from the applicable test procedures under 10
CFR 431.96 on the grounds that its VRV- III-C multi-split heat pumps
contain design characteristics that prevent testing according to the
current DOE test procedures. Specifically, Daikin asserts that the two
primary factors that prevent testing of its multi-split variable speed
products are the same factors stated in the waivers that DOE granted to
Mitsubishi Electric & Electronics USA, Inc. (Mitsubishi) for a similar
line of commercial multi-split air-conditioning systems:
Testing laboratories cannot test products with so many
indoor units; and
There are too many possible combinations of indoor and
outdoor unit to test. 69 FR 52660 (August 27, 2004) (Mitsubishi
waiver); 72 FR 17528 (April 9, 2007) (Mitsubishi waiver); 72 FR 71387
(Dec. 17, 2007) (Samsung waiver); 72 FR 71383 (Dec. 17, 2007) (Fujitsu
waiver); 73 FR 39680 (July 10, 2008) (Daikin waiver); 74 FR 15955
(April 8, 2009) (Daikin waiver); 74 FR 16193 (April 9, 2009) (Sanyo
waiver); 74 FR 16373 (April 10, 2009) (Daikin waiver).
The VRV-III-C systems have operational characteristics similar to
other commercial multi-split products manufactured by Mitsubishi,
Samsung, Fujitsu and Sanyo, all of which have already been granted
waivers. The VRV-III-C system can be connected to the complete range of
Daikin ceiling mounted, concealed, ducted, corner, cassette, wall-
mounted and floor-mounted and other indoor fan coil units. Each of
these units has nine different indoor static pressure ratings as
standard, with addition pressure ratings available. In certain high-
capacity applications, Daikin's VRV- III-C systems have the capability
to combine two outdoor units to create a larger capacity system. There
are over one million combinations possible with the DACA VRV-III-C
system. Accordingly, Daikin requested that DOE grant a waiver from the
applicable test procedures for its VRV-III-C product designs, until a
suitable test method can be prescribed.
III. Application for Interim Waiver
On September 9, 2009, in addition to its petition for waiver,
Daikin submitted to DOE an application for interim waiver. DOE
determined that Daikin's application for interim waiver does not
provide sufficient market, equipment price, shipments, and other
manufacturer impact information to permit DOE to evaluate the economic
hardship Daikin might experience absent a favorable determination on
its application for interim waiver. However, DOE understands that
absent an interim waiver, Daikin's products would not otherwise be
tested and rated for energy consumption on a comparable basis with
equivalent products where DOE previously granted waivers. In other
words, there would not be a level playing field and thus Daikin would
be placed at a competitive disadvantage. Furthermore, DOE has
determined that it appears likely that Daikin's Petition for Waiver
will be granted and that is desirable for public policy reasons to
grant Daikin immediate relief pending a determination on the petition
for waiver. DOE believes that it is likely Daikin's petition for waiver
for the new VRV-III-C multi-split models will be granted because, as
noted above, DOE has previously granted a number of waivers for similar
product designs.\1\ The two principal reasons supporting the grant of
the previous waivers also apply to Daikin's VRV-III-C products: (1)
Test laboratories cannot test products with so many indoor units; and
(2) it is impractical to test so many combinations of indoor units with
each outdoor unit. In addition, DOE believes that similar products
should be tested and rated for energy consumption on a comparable
basis. For these same reasons, DOE also determined that it is desirable
for public policy reasons to grant immediate relief pending a
determination on the petition for waiver.
---------------------------------------------------------------------------
\1\ DOE notes that it has also previously granted interim
waivers to Fujitsu (70 FR 5980 (Feb. 4, 2005)), Samsung (70 FR 9629
(Feb. 28, 2005)), Mitsubishi (72 FR 17533 (April 9, 2007)), and
Daikin (72 FR 35986 (July 2, 2007)), for comparable commercial
multi-split air conditioners and heat pumps.
---------------------------------------------------------------------------
Therefore, it is ordered that:
The application for interim waiver filed by Daikin is hereby
granted for Daikin's VRV-III-C air-cooled multi-split heat pumps,
subject to the specifications and conditions below.
1. Daikin shall not be required to test or rate its VRV-III-C
commercial air-cooled multi-split products on the basis of the existing
test procedure under 10 CFR 431.96, which incorporates by reference ARI
Standard 340/360-2004.
2. Daikin shall be required to test and rate its VRV-III-C
commercial air-cooled multi-split products according to the alternate
test procedure as set forth in section IV(3), ``Alternate test
procedure.''
The interim waiver applies to the following basic model groups:
----------------------------------------------------------------------------------------------------------------
Combination
Type Size Model No. ---------------------
8-Ton 16-Ton
----------------------------------------------------------------------------------------------------------------
Condensing Unit....................... 6-Ton................... RTSQ72PTJU.............. ......... 1
8-Ton................... RTSQ96PTJU.............. 1 .........
10-Ton.................. RTSQ120PTJU............. ......... 1
2nd Stage Function Unit............... Up to 16-Ton............ BTSQ192PTJU............. 1 1
Outdoor Piping Kit.................... ........................ BHFP30A56............... ......... 1
----------------------------------------------------------------------------------------------------------------
This interim waiver is conditioned upon the presumed validity of
statements, representations, and documents provided by the petitioner.
DOE may revoke or modify this interim waiver at any time upon a
determination that the factual basis underlying the petition for waiver
is incorrect, or upon a determination that the results from the
alternate test procedure are unrepresentative of the basic models' true
energy consumption characteristics.
[[Page 66327]]
IV. Alternate Test Procedure
Responding to two recent petitions for waiver from Mitsubishi, DOE
specified an alternate test procedure to provide a basis from which
Mitsubishi could test and make valid energy efficiency representations
for its R410A CITY MULTI products, as well as for its R22 multi-split
products. Alternate test procedures related to the Mitsubishi petitions
were published in the Federal Register on April 9, 2007. See 72 FR
17528 and 72 FR 17533. For reasons similar to those published in these
prior notices, DOE believes that an alternate test procedure is
appropriate in this instance.
DOE understands that existing testing facilities have a limited
ability to test multiple indoor units simultaneously, and the large
number of possible combinations of indoor and outdoor units for some
variable refrigerant flow zoned systems makes it impractical for
manufacturers to test. We further note that subsequent to the waiver
that DOE granted for Mitsubishi's R22 multi-split products, ARI formed
a committee to discuss the issue and to work on developing an
appropriate testing protocol for variable refrigerant flow systems.
However, to date, no additional test methodologies have been adopted by
the committee or submitted to DOE.
Therefore, as discussed below, as a condition for granting this
interim waiver to Daikin, DOE is including an alternate test procedure
similar to those granted to Mitsubishi for its R22 and R410A products.
DOE plans to consider the same alternate test procedure in the context
of the subsequent Decision and Order pertaining to Daikin's petition
for waiver. Utilization of this alternate test procedure will allow
Daikin to test and make energy efficiency representations for its VRV-
III-C products. More broadly, DOE has applied a similar alternate test
procedure to other waivers for similar residential and commercial
central air conditioners and heat pumps. Such cases include petitions
for waiver involving multi-split products manufactured by Mitsubishi
(72 FR 17528, April 9, 2007); Samsung (72 FR 71387, Dec. 17, 2007);
Fujitsu (72 FR 71383, Dec. 17, 2007); Daikin (73 FR 39680, July 10,
2008); Daikin (74 FR 15955, April 8, 2009); Sanyo (74 FR 16193, April
9, 2009); and Daikin (74 FR 16373, April 10, 2009).
The alternate test procedure developed in conjunction with the
Mitsubishi waiver permits Daikin to designate a ``tested combination''
for each model of outdoor unit. The indoor units designated as part of
the tested combination must meet specific requirements. For example,
the tested combination must have from two to eight indoor units so that
it can be tested in available test facilities. (The ``tested
combination'' was originally defined to consist of one outdoor unit
matched with between 2 and 5 indoor units. The maximum number of indoor
units in a tested combination is increased in this instance from 5 to 8
to account for the fact that these larger-capacity products can
accommodate a greater number of indoor units.) The tested combination
must be tested according to the applicable DOE test procedure, as
modified by the provisions of the alternate test procedure as set forth
below. The alternate test procedure also allows manufacturers of such
products to make valid and consistent representations of energy
efficiency for their air-conditioning and heat pump products.
In the present case, DOE is modifying the alternate test procedure
taken from the above-referenced waiver granted to Mitsubishi for its
R410A and R22 CITY MULTI products to revise the definition of a
``tested combination.'' The ``tested combination'' was originally
defined to consist of one outdoor unit matched with between 2 and 5
indoor units. The maximum number of indoor units in a tested
combination is here increased from 5 to 8 to account for the fact that
these larger-capacity products (>150,000 Btu/h) can accommodate a
greater number of indoor units. DOE plans to consider inclusion of the
following waiver language in the Decision and Order for Daikin's VRV-
III-C commercial multi-split air-cooled heat pump models:
(1) The ``Petition for Waiver'' filed by Daikin Electronics, Inc.
is hereby granted as set forth in the paragraphs below.
(2) Daikin shall not be required to test or rate its VRV-III-C
variable capacity multi-split heat pump products listed above in
section III, on the basis of the existing test procedures, but shall be
required to test and rate such products according to the alternate test
procedure as set forth in paragraph (3).
(3) Alternate test procedure.
(A) Daikin shall be required to test the products listed in section
III above according to the test procedures for central air conditioners
and heat pumps prescribed by DOE at 10 CFR 431.96, except that Daikin
shall test a ``tested combination'' selected in accordance with the
provisions of subparagraph (B) of this paragraph. For every other
system combination using the same outdoor unit as the tested
combination, Daikin shall make representations concerning the VRV-III-C
products covered in this waiver according to the provisions of
subparagraph (C) below.
(B) Tested combination. The term ``tested combination'' means a
sample basic model comprised of units that are production units, or are
representative of production units, of the basic model being tested.
For the purposes of this waiver, the tested combination shall have the
following features:
(1) The basic model of a variable refrigerant flow system used as a
tested combination shall consist of one outdoor unit, with one or more
compressors, that is matched with between 2 and 8 indoor units; for
multi-split systems, each of these indoor units shall be designed for
individual operation.
(2) The indoor units shall--
(i) Represent the highest sales model family or another indoor
model family if the highest sales model family does not provide
sufficient capacity (see ii);
(ii) Together, have a nominal cooling capacity that is between 95%
and 105% of the nominal cooling capacity of the outdoor unit;
(iii) Not, individually, have a nominal cooling capacity that is
greater than 50% of the nominal cooling capacity of the outdoor unit;
(iv) Operate at fan speeds that are consistent with the
manufacturer's specifications; and
(v) Be subject to the same minimum external static pressure
requirement while being configurable to produce the same static
pressure at the exit of each outlet plenum when manifolded as per
section 2.4.1 of 10 CFR Part 430, subpart B, appendix M.
(C) Representations. In making representations about the energy
efficiency of its VRV-III-C variable capacity air-cooled multi-split
heat pump products, for compliance, marketing, or other purposes,
Daikin must fairly disclose the results of testing under the DOE test
procedure, doing so in a manner consistent with the provisions outlined
below:
(1) For VRV-III-C combinations tested in accordance with this
alternate test procedure, Daikin may make representations based on
these test results.
(2) For VRV-III-C combinations that are not tested, Daikin may make
representations based on the testing results for the tested combination
at the same energy efficiency level as the tested combination with the
same outdoor unit and which is consistent with either of the two
following methods:
(i) Representation of non-tested combinations according to an
[[Page 66328]]
Alternative Rating Method (ARM) approved by DOE; or
(ii) Representation of non-tested combinations at the same energy
efficiency level as the tested combination with the same outdoor unit.
V. Summary and Request for Comments
Through today's notice, DOE announces receipt of the Daikin
petition for waiver from the test procedures applicable to Daikin's
VRV-III-C commercial multi-split heat pump products, and for the
reasons articulated above, DOE grants Daikin an interim waiver from
those procedures. As part of this notice, DOE is publishing Daikin's
petition for waiver in its entirety. The petition contains no
confidential information. Furthermore, today's notice includes an
alternate test procedure that Daikin is required to follow as a
condition of its interim waiver and that DOE is considering including
in its subsequent Decision and Order. In this alternate test procedure,
DOE is defining a ``tested combination'' which Daikin could use in lieu
of testing all retail combinations of its VRV-III-C multi-split heat
pump products.
DOE is interested in receiving comments on the issues addressed in
this notice. Pursuant to 10 CFR 431.401(d), any person submitting
written comments must also send a copy of such comments to the
petitioner, whose contact information is included in the section
entitled ADDRESSES section above.
Issued in Washington, DC, on December 8, 2009.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and Renewable Energy.
September 9, 2009.
Ms. Catherine Zoi
Assistant Secretary for Energy Efficiency and Renewable Energy
U.S. Department of Energy
1000 Independence Ave, SW.,
Washington, DC 20585-0121
Re: Petition for Waiver of Test Procedure
Dear Assistant Secretary Zoi:
Daikin AC (Americas) Inc. (DACA) respectfully petitions the
Department of Energy (DOE) pursuant to 10 CFR Sec. 431.401(a)(1)
(2009) for a waiver of the test procedures applicable to central air
conditioners and heat pumps, as established in 10 C.F.R. Sec. 431.96
(2009) and ARI Standard 340/360-20041, for the Daikin VRV-III-C system
(also called Cold Climate VRV), an air source heat pump system that
incorporates a unique second stage refrigeration cycle to deliver
improved heating performance and efficiency at lower ambient
conditions. The specific models for which DACA requests this waiver in
the Daikin VRV-III-C product class are listed below in this Petition.
DACA seeks a waiver from the existing central air conditioner and
central air conditioning heat pump test procedure for the Daikin VRV-
III-C line of heat pumps because the basic models contain design
criteria that prevent testing of the basic models according to the
prescribed test procedures. We are simultaneously requesting an interim
waiver for the same systems pursuant to 10 CFR Sec. 431.401(a)(2)
(2009).
---------------------------------------------------------------------------
\1\ Detailed citations to the test procedures for which DACA is
requesting a waiver are included on page 3 of this petition.
---------------------------------------------------------------------------
General Characteristics of DACA's VRV-III-C Products
The Daikin VRV-III-C system has the following characteristics and
applications:
The VRV-III-C operates as a heat pump system only (as an
8-ton or a 16-ton system).
The VRV-III-C is an inverter controlled heat pump system
that can provide year round heating in very low outdoor temperatures.
In low ambient conditions, the VRV-III-C offers 30% more heating
capacity than a standard Daikin VRV-III heat pump.
The VRV-III-C can provide cooling in ambient temperatures
down to 23 [deg]F.
The VRV-III-C includes a proprietary 2-stage refrigeration
cycle technology to ensure improved heating effect.
The VRV-III-C delivers nominal (rated) heating capacity at
5 [deg]F (-15 [deg]C) (rated condition is 47 [deg]F).
The VRV-III-C delivers 87% of nominal (rated) heating
capacity at -4 [deg]F (-20 [deg]C), and the system delivers 75% of
nominal (rated) heating capacity at -13 [deg]F (-25 [deg]C).
The VRV-III-C provides an enhanced heating ``warm up''
function.
The VRV-III-C minimizes heating downtime from defrost
operation.
The VRV-III-C system eliminates the need to use
supplemental ``resistance type'' strip heating elements.
The VRV-III-C system heat pump compressor's inverter
technology includes an integrated frequency-converter that adjusts the
rotational speed of the compressor to meet the heating or cooling
demand. Therefore, the system seldom operates at full capacity.
The VRV-III-C system can be linked to the complete range
of Daikin Ceiling-Mounted, Concealed, Ducted, Corner, Cassette, Wall-
Mounted, Floor-Mounted and other indoor fan coil units, providing the
same connection flexibility as Daikin's standard VRV systems. The
amount of piping, and the number, diversity and range of indoor units
that can be connected to the VRV-III-C is comparable to the Daikin VRV-
II, VRV-II-S and VRV-III systems for which DOE has previously issued
waivers.
Particular Basic Models for Which DACA Requests a Waiver
DACA requests a waiver from the test procedures for the following basic
model groups:
----------------------------------------------------------------------------------------------------------------
Combination
Type Size Model Number -------------------------------
8-Ton 16-Ton
----------------------------------------------------------------------------------------------------------------
Condensing Unit................... 6-Ton................ RTSQ72PTJU........... .............. 1
8-Ton................ RTSQ96PTJU........... 1 ..............
10-Ton............... RTSQ120PTJU.......... .............. 1
2nd Stage Function Unit........... Up to 16-Ton......... BTSQ192PTJU.......... 1 1
Outdoor Piping Kit................ ..................... BHFP30A56............ .............. 1
----------------------------------------------------------------------------------------------------------------
[[Page 66329]]
VRV-III-C System Characteristics Constituting the Grounds for DACA's
Petition
The Daikin VRV-III-C system consists of a heat pump that comprises
a newly designed outdoor unit and ``function unit'' featuring two-stage
compression technology. This design feature gives the VRV-III-C its
outstanding performance characteristics by creating the higher
pressures necessary for efficient system operation under low ambient
conditions.
The Daikin VRV-III-C system can be connected to the complete range
of Daikin Ceiling Mounted, Concealed, Ducted, Corner, Cassette, Wall-
Mounted and Floor-Mounted and other indoor fan coil units. Each of
these units has nine different indoor static pressure ratings as
standard, with addition pressure ratings available. There are over one
million combinations possible with the DACA VRV-III-C product
offerings. It is completely impractical for testing laboratories to
test a product such as the VRV-III-C with multiple indoor units because
of the huge number of potential system configurations.
The test method for central air conditioners and heat pumps
contained in 10 C.F.R. Sec. 431.96, Subpart B, Appendix M does not
account for the extremely large number of potential system
configurations possible with the VRV-III-C system. Therefore, the
currently applicable test method cannot accurately account for the
Daikin VRV-III-C system's energy performance across the range of
possible system configurations.
DACA's VRV-III products share many of the design characteristics
and features of similar equipment for which DOE has already approved
either interim waivers or waivers, including DACA's VRV, VRV-S and VRV-
III product lines, and Mitsubishi Electric and Electronics USA, Inc.'s
(MEUS) CITY MULTI and S&L product classes.\2\ The same testing
constraints and limitations apply to all of these products.
---------------------------------------------------------------------------
\2\ DOE granted DACA an interim waiver for its VRV and VRV-S
product lines in a letter dated August 14, 2006, and DOE renewed
this interim waiver on July 2, 2007 (72 Fed. Reg. 35,986). DOE
granted MEUS a waiver for its CITY MULTI VRFZ class of products. 69
Fed. Reg. 52,660 (August 27, 2004). DOE granted DACA a waiver for
its VRV-III product lines on April 8, 2009 (74 Fed. Reg. 15,955).
DOE has recently granted MEUS an interim waiver for its S&L Class
multi-split heat pumps and heat recovery systems.
---------------------------------------------------------------------------
The rationale for DACA's Petition for a waiver from testing
standards for the Daikin VRV-III-C system is virtually identical to
basis for the other manufacturers' previous requests for waivers noted
above. DACA requests that DOE apply the same rationale to DACA's
Petition for waiver for the Daikin VRV-III-C system that DOE used to
grant the previous waiver petitions for their similar systems.
Specific Testing Requirements Sought to be Waived
The test procedures from which DACA is requesting a waiver are
contained in 10 C.F.R. Sec. 431.96(b), Table 1, which incorporates ARI
Standard 340/360-2004 by reference into 10 C.F.R. Part 431, and which
is applicable to central air conditioner and heat pump equipment with a
capacity of >65,000 Btu/hr.
Discussion of Need for Requested Waiver
Although the capacity of the Daikin VRV-III-C product class is
within the scope of 10 C.F.R. Part Sec. 431.96, the design
characteristics of the Daikin VRV-III-C product class prevent testing
of the system according to the prescribed test procedures in a manner
that represents the system's true energy consumption characteristics.
Specifically, application of the existing prescribed test method cannot
account for the large number of possible combinations of indoor and
outdoor units that would be subject to testing. Also, it is impossible
for testing laboratories to test products with such a large number of
possible combinations.
The absence of a waiver from the required testing procedure will
restrict the availability to consumers in the United States of the
Daikin VRV-III-C system's energy savings benefits that result from
integrating domestic hot water production into the system.
Manufacturers of Other Basic Models Incorporating Similar Design
Characteristics
DACA is aware of the following manufacturer that produces a basic
model incorporating similar design characteristics to the VRV-III-C in
the United States market:
Mitsubishi Electric & Electronics USA, Inc.\3\
---------------------------------------------------------------------------
\3\ MEUS's Hyper Heating VRF system has similar design
characteristics to the VRV-III-C system, offering year-round heating
in low ambient temperatures.
---------------------------------------------------------------------------
Alternative Test Procedure
DACA proposes that DOE apply the same alternate test procedure to
the covered VRV-III-C products as DOE applied to DACA's VRV-III
products in the waiver that DOE granted for those products on April 8,
2009 (74 Fed. Reg. 15,955). The alternate test method appears in
Section 3 of the VRV-III waiver. 74 Fed. Reg. at 15,958.
Application for Interim Waiver
DACA also hereby applies pursuant to 10 C.F.R. Sec. 431.401(a)(2)
for an interim waiver of the applicable test procedure requirements for
the Daikin VRV-III-C product class models listed above. The basis for
DACA's Application for Interim Waiver follows.
DACA is likely to succeed in its Petition for Waiver because there
is no reasonable argument that the test method contained in 10 C.F.R.
Sec. 431.96 can be accurately applied to the Daikin VRV-III-C product
class. As explained above in the DACA's Petition for Waiver, the design
characteristics of the Daikin VRV-III-C product class clearly prevent
testing the Daikin VRV-III-C system with the prescribed test procedures
because of the large number of possible system combinations and the
limitations of existing testing facilities.
The likelihood of DOE approving DACA's Petition for Waiver is
supported by the DOE's history of approving previous waiver requests
from other manufacturers for products that are similar to the Daikin
VRV-III-C product class, based on the same rationale offered by DACA in
this Petition for Waiver.
Additionally, DACA is likely to suffer economic hardship and
competitive disadvantage if DOE does not grant its interim waiver
request. DACA is now preparing to introduce its Daikin VRV-III-C
product class in a matter of months. If we must wait for completion of
the normal waiver consideration and issuance process, DACA will be
forced to delay the opportunity to begin recouping through product
sales its production and marketing costs associated with introducing
the Daikin VRV-III-C product class into the United States market.
DOE approval of DACA's interim waiver application is also supported
by sound public policy reasons. As DOE stated in its January 7, 2008
approval of DACA's interim waiver for the VRV-WII product classes:
[I]n those instances where the likely success of the Petition for
Waiver has been demonstrated, based upon DOE having granted a waiver
for similar products design, it is in the public interest to have
similar products tested and rated for energy consumption on a
comparable basis.
73 Fed. Reg. at 1215. The Daikin VRV-III-C product class will
provide superior comfort to the end user, and will incorporate state of
the art technology such as an advanced inverter drive and two-stage
compression that
[[Page 66330]]
enable the system to provide year round heating in very low ambient
temperatures. The Daikin VRV-III-C product class will introduce
technologies that will increase system efficiency and reduce national
energy consumption, and that will also offer a new level of comfort and
control to end users.
DACA requests that DOE grant our Application for Interim Waiver so
we can bring the new highly energy efficient technology represented by
the Daikin VRV-III-C product class to the market as soon as possible,
thereby allowing the U.S. consumer to benefit from our high technology
and high efficiency product.
Confidential Information
DACA makes no request to DOE for confidential treatment of any
information contained in this Petition for Waiver and Application for
Interim Waiver.
Conclusion
Daikin AC (Americas), Inc. Corporation respectfully requests DOE to
grant its Petition for Waiver of the applicable test procedure to DACA
for specified models of the VRV-III-C system, and to grant its
Application for Interim Waiver. DOE's failure to issue an interim
waiver from test standards would cause significant economic hardship to
DACA by preventing DACA from marketing these products even though DOE
has previously granted waivers to other products that were offered in
the market with similar design characteristics.
We would be pleased to respond to any questions you may have
regarding this Petition for Waiver and Application for Interim Waiver.
Please contact Lee Smith, Director of Product Marketing at 972-245-1510
or by email at Lee.smith@daikinac.com.
Sincerely,
Akinori Atarashi,
President
Daikin AC (Americas), Inc.
1645 Wallace Drive
Suite 110
Carrollton, Texas 75006
(Submitted in triplicate)
Encls.
cc:
Mitsubishi Electric & Electronics USA, Inc
4300 Lawrenceville-Suwanee Road
Suwanee, GA 30024
Attn: William Rau, Senior Vice President and General Manager
[FR Doc. E9-29795 Filed 12-14-09; 8:45 am]
BILLING CODE 6450-01-P