In a notice published on June 11, 2020, the U.S. Department of Energy ("DOE" or the "Department") proposed amendments to its room air conditioner ("RAC") test procedure.[1] The proposed amendments would add new testing provisions for variable-speed RACs and incorporate the latest versions of industry standards currently referenced in the test procedure.

The proposed amendments to the RAC test procedure stem from recent test procedure waivers granted to manufacturers of variable-speed RACs. Since RACs were historically designed with single-speed compressors, the test procedure does not yet account for the increased efficiencies of variable-speed RACs. Indeed, while single-speed compressors typically cycle "on" and "off" continuously to match the cooling load of the space, variable-speed RACs utilize an inverted compressor that can reduce its speed to match the cooling load of the space. Because the current test procedure measures the performance of RACs while operating under a full cooling load, it neither accounts for the inefficiencies created by compressor cycling nor the increased efficiency of variable-speed compressors.

To account for this change in technology, DOE is proposing to amend the test procedure to measure energy efficiency over a range of four test conditions and compressor speeds, including (1) full speed at 95°, (2) full speed at 92°F, (3) intermediate speed at 87°F, and (4) low speed at 82°F. For comparative purposes, DOE is proposing that a "performance adjustment factor" ("PAF") - the calculated percent improvement of the weighted-average Combined Energy Efficiency Radio (CEER) of the variable-speed system versus that of a theoretical, comparable single-speed RAC - be applied to the CEER value obtained from testing a variable-speed unit at full compressor speed under 95°F conditions. This factor would account for the increased efficiency of these units, allowing for direct, consumer comparison with single-speed RAC CEER values.

In addition, the Department is proposing to update references to two industry standards in Appendix F. Specifically, DOE is proposing to update the references to the ANSI/AHAM RAC-1 standard to reflect the cooling mode-specific subsections of the most recent ANSI/AHAM RAC-1-2015 standard, as well as the provisions that address measuring electrical power input in cooling mode. Similarly, the proposed amendments would also incorporate the updated ANSI/ASHRAE Standard 16-2016 for cooling mode temperature conditions, methods, and calculations.

Finally, although DOE acknowledged the increasing presence of connected RACs that provide additional - and energy consuming - capabilities, such as alerts and messages, remote control, and demand response ("DR"), the Department declined to include amendments addressing connected RACs in this rulemaking. In declining to propose amendments, the Department cited the lack of market penetration and energy consumption and usage data on connected capabilities. The Department is, however, proposing to clarify that network enabled RACs be tested with network settings disabled.

Comments on the proposal will be accepted until August 10, 2020. In the meantime, DOE plans to hold a public webinar on July 8, 2020 to discuss its proposal. For any questions on this proposed rule or energy efficiency requirements in general, please contact us.

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[1] Energy Conservation Program: Test Procedure for Room Air Conditioners, 85 Fed. Reg. 35,700 (June 11, 2020)