Comment #1Amendment: Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01Page Number: 1Paragraph / Figure / Table / Note: 4.4.4.1Comment Intent: ObjectionComment Type: TechnicalComment: I support the intent of the amendment, but have three edits that improve clarity. In 4.4.4.1, state "by dividing by" rather than "by using" so that it is clear how to use the conversion factors. In the Table, change the table name to read "SEER2 and HSPF2 Conversion Factors" instead of using the forward slash, which can mean "division". The column headers could then be simplified by just stating "SEER2" and "HSPF2" rather than "SEER2/SEER", even though that header does correctly result in the conversion factor. Proposed Change: 4.4.4.1 For Heat Pumps and Air Conditioners with the more recent Manufacturer’s Equipment Performance Ratings (HSPF2 and SEER2), these ratings shall be converted to HSPF and SEER values by dividing by using the conversion factors in Table 4.4.4.1(1). If the type of equipment is not determined, the conversion shall default to the “Split System” factors. All calculations, including Equation 4.1-1a, shall use values converted to SEER and HSPF. Table 4.4.4.1(1) SEER2 and / HSPF2 Conversion Factors "SEER2/SEER" "HSPF2/HSPF"
I support the intent of the amendment, but have three edits that improve clarity.
In 4.4.4.1, state "by dividing by" rather than "by using" so that it is clear how to use the conversion factors.
In the Table, change the table name to read "SEER2 and HSPF2 Conversion Factors" instead of using the forward slash, which can mean "division".
The column headers could then be simplified by just stating "SEER2" and "HSPF2" rather than "SEER2/SEER", even though that header does correctly result in the conversion factor.
4.4.4.1
For Heat Pumps and Air Conditioners with the more recent Manufacturer’s Equipment Performance Ratings (HSPF2 and SEER2), these ratings shall be converted to HSPF and SEER values by dividing by using the conversion factors in Table 4.4.4.1(1). If the type of equipment is not determined, the conversion shall default to the “Split System” factors. All calculations, including Equation 4.1-1a, shall use values converted to SEER and HSPF.
Table 4.4.4.1(1) SEER2 and / HSPF2 Conversion Factors
"SEER2/SEER" "HSPF2/HSPF"
Comment #2Amendment: Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01Page Number: 1Paragraph / Figure / Table / Note: 4.4.4.1Comment Intent: ObjectionComment Type: TechnicalComment: First an editorial correction that these two efficiencies should be seperated with an "or" as opposed to "and" because the two are not always both included in the rating of all HVAC equipment: ie. "HSPF or SEER", "HSPF2 or SEER2". For the immediate future, HVAC manufacturers will continue to publish both HSPF or SEER rating along with the new federally required HSPF2 or SEER2 rating. The conversion factors provided in table 4.4.4.1(1) are only an estimate where not all equipment will always follow this conversion as a rule. This addendum needs to be clear that the HSPF or SEER rating, when continued to be provided by the manufacturer, should be the preferred equipment performance rating used in a HERS rating and this conversion factor should only be used when HSPF or SEER is not provided by the manufacturer. Proposed Change: For Heat Pumps and Air Conditioners with the more recent Manufacturer’s Equipment Performance Ratings (HSPF2 and or SEER2) available, and where Manufacturer’s Equipment Performance Ratings (HSPF or SEER) are not available, these HSPF2 or SEER2 ratings shall be converted to HSPF and or SEER values by dividing HSPF2 or SEER2 by the conversion factors in Table 4.4.4.1(1). If the type of equipment is not determined, the conversion shall default to the “Split System” factors. All calculations, including Equation 4.1-1a, shall use HSPF or SEER values as made available by the Manufacturer or converted to SEER and HSPF as specified above.
First an editorial correction that these two efficiencies should be seperated with an "or" as opposed to "and" because the two are not always both included in the rating of all HVAC equipment: ie. "HSPF or SEER", "HSPF2 or SEER2".
For the immediate future, HVAC manufacturers will continue to publish both HSPF or SEER rating along with the new federally required HSPF2 or SEER2 rating. The conversion factors provided in table 4.4.4.1(1) are only an estimate where not all equipment will always follow this conversion as a rule. This addendum needs to be clear that the HSPF or SEER rating, when continued to be provided by the manufacturer, should be the preferred equipment performance rating used in a HERS rating and this conversion factor should only be used when HSPF or SEER is not provided by the manufacturer.
For Heat Pumps and Air Conditioners with the more recent Manufacturer’s Equipment Performance Ratings (HSPF2 and or SEER2) available, and where Manufacturer’s Equipment Performance Ratings (HSPF or SEER) are not available, these HSPF2 or SEER2 ratings shall be converted to HSPF and or SEER values by dividing HSPF2 or SEER2 by the conversion factors in Table 4.4.4.1(1). If the type of equipment is not determined, the conversion shall default to the “Split System” factors. All calculations, including Equation 4.1-1a, shall use HSPF or SEER values as made available by the Manufacturer or converted to SEER and HSPF as specified above.
Comment #3Amendment: Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: 4.4.4.1(1)Comment Intent: ObjectionComment Type: TechnicalComment: How were these conversion factors actually derived? The published standards provide sufficient information to develop conversions, but this does not appear to be what was done. Standards-dereived conversions differ from what is proposed here. None of the draft conversions include an intercept, only slopes. While the slope for HSPF2 is correct, those for SEER2 are not. The standards also make no allowance for equipment type variations in the definition of these units.
How were these conversion factors actually derived? The published standards provide sufficient information to develop conversions, but this does not appear to be what was done. Standards-dereived conversions differ from what is proposed here. None of the draft conversions include an intercept, only slopes. While the slope for HSPF2 is correct, those for SEER2 are not. The standards also make no allowance for equipment type variations in the definition of these units.
Comment #4Amendment: Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 4.4.4.1(1) SEER2/HSPF2 Conversion FactorsComment Intent: ObjectionComment Type: TechnicalComment: No objection to the overall intent of the conversion factors, however the proposed system names and conversion factors are not aligned with the system names and conversion factors provided by CEE and EPA. For example: Assumption: Split System = Ductless, Related values: SEER2 and HSPF2 conversion factors are different Assumption: Split System = Most Ducted (most of the time), Related values: HSPF2 is not aligned Assumption: Packaged = Single Package, Related values: SEER2 is not aligned A consistent approach will be beneficial for efficiency programs utilizing RESNET Standards to have alignment with CEE/EPA Conversion factors Table 1 M to M1 Appendix Crosswalk SEER2 EER2 HSPF2 Ducted 0.95 0.95 0.91 Ductless 1.00 1.00 0.95 Packaged 0.95 0.95 0.84
No objection to the overall intent of the conversion factors, however the proposed system names and conversion factors are not aligned with the system names and conversion factors provided by CEE and EPA. For example:
Assumption: Split System = Ductless, Related values: SEER2 and HSPF2 conversion factors are different
Assumption: Split System = Most Ducted (most of the time), Related values: HSPF2 is not aligned
Assumption: Packaged = Single Package, Related values: SEER2 is not aligned
A consistent approach will be beneficial for efficiency programs utilizing RESNET Standards to have alignment with CEE/EPA Conversion factors
Comment #5Amendment: Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 4.4.4.1(1)Comment Intent: ObjectionComment Type: TechnicalComment: No objection to the overall intent of the conversion factors, however the proposed system names and conversion factors are not aligned with the system names and conversion factors provided by CEE and EPA. For example: Assumption: Split System = Ductless, Related values: SEER2 and HSPF2 conversion factors are different Assumption: Split System = Most Ducted (most of the time), Related values: HSPF2 is not aligned Assumption: Packaged = Single Package, Related values: SEER2 is not aligned A consistent approach will be beneficial for efficiency programs utilizing RESNET Standards to have alignment with CEE/EPA Conversion factors Proposed Change: See attachment
Assumption: Split System = Ductless, Related values: SEER2 and HSPF2 conversion factors are different Assumption: Split System = Most Ducted (most of the time), Related values: HSPF2 is not aligned Assumption: Packaged = Single Package, Related values: SEER2 is not aligned
See attachment
Comment #6Amendment: Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 4.4.4.1(1)Comment Intent: ObjectionComment Type: TechnicalComment: No objection to the overall intent of the conversion factors, however the proposed system names and conversion factors are not aligned with the system names and conversion factors provided by CEE and EPA. For example: Assumption: Split System = Ductless, Related values: SEER2 and HSPF2 conversion factors are different Assumption: Split System = Most Ducted (most of the time), Related values: HSPF2 is not aligned Assumption: Packaged = Single Package, Related values: SEER2 is not aligned A consistent approach will be beneficial for efficiency programs utilizing RESNET Standards to have alignment with CEE/EPA Conversion factors Proposed Change: See attachment
Return to Proposed MINHERS Addendum 71, SEER2/HSPF2 Conversions, Draft PDS-01