Federal Register - March 29, 2021
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Fuente: Federal Register
Federal Register / Vol. 86, No. 58 / Monday, March 29, 2021 / Rules and Regulations materials was equivalent to a 2742
square inch hole in the wall, and an improved installation has the potential to reduce this leakage by 6585 percent.
The Joint Commenters commented that, in the preliminary 202006 Technical Support Document TSD, DOE
explained that because DOEs investigative testing was conducted with no pressure difference between the rooms, the tests were not able to measure the real-world impacts of infiltration.35 The Joint Commenters asserted that the test procedure does not capture potentially significant inefficiencies in typical installations.
The Joint Commenters encouraged DOE
to investigate how the test procedure could capture the effects of real-world installations of room AC units, which would provide an incentive to manufacturers to offer improved installation materials such that leakage is reduced. The Joint Commenters further stated that, in addition to saving energy, reducing leakage would also improve cooling performance by reducing the amount of hot air entering from outdoors, which ultimately would improve consumer comfort. Joint Commenters, No. 15 at pp. 56
DOE is not aware of an industryaccepted method to evaluate heat losses to the outdoors during the room AC
representative use cycle or during times when the room AC is installed but not operating, or of any data quantifying the magnitude of these losses.
DOE has preliminarily investigated applying a pressure difference between the indoor and outdoor chambers during the standard appendix F test procedure, as the Joint Commenters suggested.
While it was possible to create a pressure difference between the rooms, temperature and humidity within the chamber did not stabilize and the resulting test data did not meet the tolerance requirements from ASHRAE
162016 required in appendix F.
Furthermore, for some larger-capacity units, it was difficult for the chamber to maintain the pressure difference throughout the rating test period given the air flow interaction between the unit operation and the chamber reconditioning equipment. It is therefore unclear how the influence of infiltration air could be measured within the DOE
test procedure for room ACs, given the difficulties associated with testing using a fixed pressure difference between the indoor and outdoor test chambers.
35 202006
Technical Support Document: Energy Efficiency Program For Consumer Products And Commercial And Industrial Equipment: Room Air Conditioners EERE2014BTSTD00590013.
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Therefore, as proposed, DOE is not requiring in this final rule installation of louvered room ACs with the manufacturer-provided installation materials, including side curtains, and instead is requiring the partition wall be sealed to the unit during testing, as specified in Section 6.1.1.4 of ANSI/
ASHRAE Standard 162016.
Accordingly, as discussed above, DOE is not adopting a test to evaluate, or a constant representative adjustment factor to account for, heat losses to the outdoors during the room AC
representative use cycle or during times when the room AC is installed but not operating and is not adopting a test requiring a pressure differential between the indoor and outdoor chambers at this time.
d. Test Conditions Multiple Test Conditions In the June 2020 NOPR, DOE did not propose additional cooling mode test conditions for single-speed room ACs because a test procedure that measures performance at both peak temperature conditions and a less extreme temperature would require a new overall weighted metric, room AC
performance has historically been based on peak performance under elevated outdoor temperature conditions and peak performance would not be clearly portrayed by a weighted metric, and information about variable-speed room ACs is too limited to justify the expected substantial increase in test burden, utility impacts, and consumer confusion associated with measuring performance at reduced outdoor temperature test conditions for all room ACs. 85 FR 35700, 35723 Jun. 11, 2020.
AHAM agreed with maintaining a single test condition for single-speed room ACs. AHAM, Public Meeting Transcript, No. 12 at pp. 5053 ASAP, the California IOUs, and NEAA stated that testing only at the 95 F outdoor test condition may not provide an accurate relative ranking of different single-speed room AC units as they are likely to have varying efficiency and performance at lower temperature conditions. ASAP, Public Meeting Transcript, No. 12 at pp.
1112; California IOUs, Public Meeting Transcript, No. 12 at pp. 3033 NEAA
suggested that single-speed room AC
units be given the option to test at multiple test conditions to allow better single-speed options to demonstrate improved performance, while not requiring all products to retest. NEAA, No. 16 at p. 3
The California IOUs encouraged DOE
to amend the room AC test procedure to
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improve representativeness and facilitate product comparison with air conditioners tested under appendix M1
to 10 CFR part 430. The California IOUs stated that DOEs proposal to create a part-load test for room ACs with variable-speed compressors recognizes that testing single-speed room ACs only at full capacity is unrepresentative of an average-use cycle. The California IOUs stated that, in their experience, using different test procedures and energy consumption calculations for equipment that provides the same consumer utility, in this case, space conditioning, has the potential to create market distortions.
The California IOUs further stated that the rest of the air conditioning industry has moved towards testing at part load, and recommended that DOE consider a consistent approach for room ACs.36 To minimize market confusion, the California IOUs suggested that the room AC test procedure should be as similar as possible for the test procedure for central air conditioners and heat pumps, including measuring part-load performance for room ACs, as defined for central air conditioners and heat pumps in appendix M1 to 10 CFR part 430. The California IOUs stated that aligning test procedures and energy efficiency metrics for room ACs with a cooling capacity greater than or equal to 9,000 Btu/h and central air conditioners and heat pumps would enhance consumers ability to choose the product that best fits their needs. The California IOUs further stated that, because many room AC manufacturers also make products that fall under appendix M1 to 10 CFR part 430 and are familiar with the test procedure, the transition to a test procedure for room ACs aligned with appendix M1 would be relatively easy. California IOUs, No. 14 at pp. 1
3
While certain single-speed room ACs may perform differently under reduced outdoor temperature test conditions, requiring two or more tests for every single-speed room AC, either by testing at multiple test conditions or aligning the room AC test procedure with appendix M1, would at least double the test burden on manufacturers of singlespeed room ACs that represent the vast majority of the market. A voluntary reduced outdoor temperature test would require a revision of the test procedure and the CEER metric to account for a multiple-condition single-speed room AC test. Such an option may be 36 Based on the context of the California IOUs comment, it is understood that the California IOUs are referring to how appendix M1 accounts for operation at reduced cooling loads and not loadbased testing as discussed above.
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