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The company strongly supports revising program criteria to include ductless split-system equipment, arguing ductsless units use the same testing standards as central systems, are more efficient than room air conditioners, and deliver higher installed efficiencies than test results due to reduced duct losses and better conditioned-air delivery to occupied spaces. It also states installation is straightforward and not a significant barrier.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/mitsubishi-electric-electronics-usa-inc-draft-2-partner-commitments-and-eligibility-criteria-energy-star-qualified-air-source-heat-pumps-and-central-air-conditioners/269373/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/mitsubishi-electric-electronics-usa-inc-draft-2-partner-commitments-and-eligibility-criteria-energy-star-qualified-air-source-heat-pumps-and-central-air-conditioners/269373.png","ImageObject",300,407,{"name":92,"@type":93},"Jacob","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-29","2026-09-15",true,{"@type":102,"interactionType":103,"userInteractionCount":52},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What is Mitsubishi Electric’s main position on the ENERGY STAR eligibility criteria draft?","Question",{"text":112,"@type":113},"Mitsubishi Electric strongly supports revising the criteria to permit ductless split-system equipment to be eligible for the ENERGY STAR program.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"Why does Mitsubishi Electric say ductless split systems should be included?",{"text":117,"@type":113},"The company argues ductless mini-split equipment is categorized among central air conditioning systems under ARI 210/240 and therefore should meet the same testing standards and efficiency requirements.",{"name":119,"@type":110,"acceptedAnswer":120},"How does Mitsubishi Electric explain differences between tested and delivered efficiencies?",{"text":121,"@type":113},"It states delivered efficiency of ductless units is higher than tested efficiency because ducted central systems lose energy through duct losses, while ductless systems deliver conditioned air directly to the occupied space; the test procedure does not recognize this distinction.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},269373,1790013731,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":52,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":14,"language":139,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":67,"update_tm":143,"read_time":24,"preview_page_count":4},962084931830,"https://ap-avatar.wpscdn.com/davatar_a8503ba1806abce46bf441b54a3ca4cd","Mitsubishi Electric & Electronics USA, Inc.  \nHVAC Advanced Products Division  \n3400 Lawrenceville-Suwanee Road, Suwanee, GA 30024  \nJune 30, 2005  \nRachel Schmeltz  \nENERGY STAR Program Manager  \nUnited States Environmental Protection Agency 1310 L Street, NW  \nWashington, DC 20005  \nRE: Draft 2 Partner Commitments and Eligibility Criteriafor ENERGY STAR qualified Air Source Heat Pumps and Central Air Conditioners  \nDear Ms.Schmeltz:  \nMitsubishi Electric & Electronics USA, Inc.,(MEUS) a leading provider of ductless split system air conditioners and heat pumps to residential and commercial entities in the United States, respectfully submits these comments to the US EnvironmentalProtection Agency (EPA) regarding the above matter.  \nWe strongly support EPAs initiative revising the program criteria to permit the inclusion of ductless split-system for eligibility in the ENERGY STAR program for the following reasons:  \n1. Ductless Split Systems are Subject to the Same Testing Standards as Central Air Conditioners.  \nAs EPA correctly notes, ductless mini-split equipment is categorized among central air conditioning systems according to ARI 210/240. Central air conditioning systems have long been included as ENERGY STAR eligible products. Provided that ductless systems perform according to the energy efficiency standards specified by EPA, they should not be excluded from ENERGY STAR eligibility since they are subject to the same testing conditions as central air conditioning systems and air sourced heat pumps.  \n2. Ductless Split Systems Are More Efficient Than Room Air Conditioners.  \nRelatively inefficient room air conditioners have also long been eligible for the ENERGY STAR program despite performance data demonstrating that ductless systems conserve and distribute cooling and heating on a more efficient basis. A primary reason that ductless system sales continue to grow in the US is that consumers are increasingly turning to our technology as an attractive alternative to inefficient room air conditioners.Excluding ductless split systems discourages both residential and commercial entities from considering our technology and its proven effective use of energy.  \n3. Ductless Systems Delivered Efficiencies are Higher than Tested.  \nThe installed or delivered efficiency of ductless split systems are higher than their tested efficiencies. Central systems, however, will lose efficiency due to duct loss and higher fan watts to match the needs of the duct system.Centralair conditioners and air sourced heat pumps deliver conditioned air from a centrally located air-handler through ductwork to the space to be conditioned. According to Department of Energy analysis, however, typical ducted systems lose approximately 25 to 40 percent of the heating or cooling energy through duct losses related to conduction and air leakage. Ductless products, in contrast deliver all of  \n[w](www.mehvac.com)[ww.mehvac.co](www.mehvac.com)[m](www.mehvac.com)  \nthe conditioned air to the occupied space. This distinction in energy consumption is not recognized in the test procedure. As a result, the actual efficiency of a ductless unit rated at 10 SEER, for instance, is typically equivalent to, or even higher than, the actual efficiency of aducted united rated at 12 SEER.  \n4. Installation Issues Not a Significant Factor for Ductless Split Systems.  \nDuctless split systems are installed very easily and are set-up almost like they are tested with the only installation variable being the length or the refrigerant lines.Ductless split systems insulate both refrigerant lines while for central split systems only the suction line is insulated. The plus for “installed” vs.“tested” ductless systems is that they installed systems used the system remote controller that allows the system to operate more effectively since this factory matched control is not used during testing.  \nCentral Systems are not tested as they are installed.The test room conditions are controlled t","cbCaicrUDE7E83FR","https://ap.wps.com/l/cbCaicrUDE7E83FR","pdf",50984,"English","# Comments on ENERGY STAR eligibility criteria\n## Support for including ductless split systems\n## Testing standards comparison\n## Efficiency versus room air conditioners\n## Installed efficiency and duct loss explanation\n## Installation and setup considerations","[{\"question\":\"What is Mitsubishi Electric’s main position on the ENERGY STAR eligibility criteria draft?\",\"answer\":\"Mitsubishi Electric strongly supports revising the criteria to permit ductless split-system equipment to be eligible for the ENERGY STAR program.\"},{\"question\":\"Why does Mitsubishi Electric say ductless split systems should be included?\",\"answer\":\"The company argues ductless mini-split equipment is categorized among central air conditioning systems under ARI 210/240 and therefore should meet the same testing standards and efficiency requirements.\"},{\"question\":\"How does Mitsubishi Electric explain differences between tested and delivered efficiencies?\",\"answer\":\"It states delivered efficiency of ductless units is higher than tested efficiency because ducted central systems lose energy through duct losses, while ductless systems deliver conditioned air directly to the occupied space; the test procedure does not recognize this distinction.\"}]","Mitsubishi Electric & Electronics USA, Inc. - Draft 2 Partner Commitments and Eligibility Criteria - ENERGY STAR qualified air source heat pumps and central air conditioners | PDF",1789450992]