Federal Register - March 29, 2021
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Source: Federal Register
Federal Register / Vol. 86, No. 58 / Monday, March 29, 2021 / Rules and Regulations into a single metric may limit a consumers ability to recognize the mode-specific performance and compare performance with room ACs that only provide cooling, and may lead to a reduction in cooling mode efficiency. 85 FR 35700, 35726 Jun. 11, 2020.
AHAM supported DOEs proposal, noting that there are insufficient data to support developing a test to measure heating mode as current data suggest it is not a significant operating mode for room ACs. AHAM stated that national, statistically significant consumer use data must be used to justify changes in order to satisfy the requirements of the Data Quality Act. In urging DOE to adopt AHAM RAC12020 formerly AHAM RAC12019, which does not include a heating mode test, AHAM
further agreed with DOEs proposal.
AHAM, Public Meeting Transcript, No.
12 at pp. 910; AHAM, No. 13 at pp. 2, 7
For the reasons discussed, and in the June 2020 NOPR, DOE is not establishing a heating mode test procedure for room ACs in appendix F.
3. Off-Cycle Mode Single-speed room ACs typically operate with a compressor on-off control strategy, where the compressor runs until the room temperature drops below a consumer-determined setpoint, then ceases to operate i.e., the unit operates in off-cycle mode 39 until the room temperature rises above the setpoint, at which time the compressor starts again.
The points at which the compressor stops and restarts depend on the setpoint temperature defined by the user and the deadband 40 programmed by the manufacturer. During the period in which the compressor remains off i.e., off-cycle mode, the fan may operate in different ways depending on manufacturer implementation: 1 The fan ceases operation entirely; 2 the fan continues to operate for a short period of time after the setpoint is reached and then stops until the compressor is reactivated; 3 the fan continues to operate continuously for a short period of time, after which it cycles on and off periodically until the compressor is reactivated; or 4 the fan continues to 39 Off-cycle mode is distinct from off mode, in which a room AC not only ceases compressor and fan operation but also may remain in that state for an indefinite time, not subject to restart by thermostat or temperature sensor signal.
40 The term deadband refers to the range of ambient air temperatures around the setpoint for which the compressor remains off, and above which cooling mode is triggered on.
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operate continuously until the compressor is reactivated.41
In the June 2020 NOPR, DOE did not propose a definition or test procedure for off-cycle mode. 85 FR 35700, 35728
Jun. 11, 2020 Through investigative testing, DOE found that average power use in off-cycle mode was relatively low i.e., approximately 10 percent or less compared to the average power used in cooling mode. Id. Thus, DOE initally determined that the additional 2-hour test burden that would be required to establish a test procedure for off-cycle mode would outweigh the benefits of measuring off-cycle mode power for room ACs. Id.
AHAM agreed with DOEs proposal, commenting that EPCA requires test procedures to measure only a representative average use cycle/period of use, not every possible mode. AHAM
further commented that the cooling cycle continues to be the most representative average use cycle for this purpose, with no data on the prevalence of consumer use of off-cycle mode.
AHAM, No. 13 at p. 7
The California IOUs, the Joint Commenters, and NEAA disagreed with DOEs proposal, stating the exclusion of off-cycle mode testing would result in non-representative efficiency ratings.
California IOUs, No. 14 at pp. 45; Joint Commenters, No. 15 at p. 3; NEAA, No.
16 at pp. 34 The California IOUs commented that ENERGY STAR finds off-cycle power consumption sufficiently important to require qualifying room ACs to enable Energy Saver Mode ESM by default when the unit is switched on. The California IOUs expressed concern that assuming all room ACs typically operate in ESM
may be unwarranted. California IOUs, No. 14 at pp. 45 The Joint Commenters commented that room AC
units with continuous fan operation can consume close to 240 kilowatt-hours per year of energy in off-cycle mode alone, pointing to its prevalence and importance in testing. Joint Commenters, No. 15 at p. 3 NEAA
stated that, while more data are needed on the number of hours spent in offcycle and recirculation mode, these modes have the potential to account for a significant percentage of annual energy use. For example, NEAA
commented that if a unit in the 6,000
7,900 Btu/h capacity range spent 25
percent of the amount of time in the offcycle mode than it does in compressor mode i.e., 187.5 hours, DOE estimates 750 compressor hours per year on 41 Unlike air circulation mode, off-cycle mode is not user-initiated and only occurs when the ambient temperature has satisfied the setpoint.
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average, the off-cycle mode would account for 9 percent of annual energy use for an average continuous operation fan. NEAA further commented that if this same room AC spent the same number of hours in off-cycle hours as in compressor mode, the off-cycle mode would account for 37 percent of its annual energy use. NEAA, No. 16 at pp.
34 The California IOUs, the Joint Commenters, and NEAA urged DOE to capture off-cycle mode power consumption, including fan operation, to provide a better representation of actual efficiency in the field and more accurate information to consumers.
California IOUs, No. 14 at pp. 45; Joint Commenters, No. 15 at p. 3; NEAA, No.
16 at pp. 34 The California IOUs specifically requested that DOE
investigate consumer use of ESM
compared to always-on fan operation modes, and determine the proportion of operating hours where the fan runs with the compressor off in order to accurately determine average power consumption during off-cycle mode and to include that power consumption in the test procedure. The California IOUs also requested that DOE create a definition for off-cycle mode. California IOUs, No. 14 at pp. 45
EPCA requires that the test procedures be reasonably designed to produce test results which measure the energy efficiency of room air conditioners during a representative average use cycle or period of use and not be unduly burdensome to conduct.
42 U.S.C. 6293b2 EPCA does not require the test procedure to evaluate every mode of operation. DOE notes that there are insufficient available data on the amount of time room ACs spend in off-cycle mode to support a conclusion that a test procedure capturing such operation would be representative of an average use cycle. Furthermore, as discussed in the June 2020 NOPR, DOE
found that energy consumption in offcycle mode was relatively low, approximately 10 percent or less, of the power used during cooling mode. 85 FR
35700, 35728 Jun. 11, 2020. While DOE understands that units with continuous fan modes during off-cycle mode may consume a higher percentage of energy relative to cooling mode, the units in DOEs test sample that operated the fan continuously during off-cycle mode were older models which are no longer in production and are not likely prevalent on the market.
Because of the lack of data regarding operation in off-cycle, DOE is not adopting test procedures to address this mode.
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