Date: January 9, 2015

Case: Energy Conservation Standards Rulemaking for Miscellaneous 

Consumer Refrigeration Products Preliminary Analysis Meeting

Ace-Federal Reporters, Inc.

Phone: 202-347-3700

Fax: 202-737-3638

Email: info@acefederal.com

Internet: www.acefederal.com
Energy Conservation Standards Rulemaking for Miscellaneous Consumer Refrigeration Products Preliminary Analysis Meeting

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 UNITED STATES DEPARTMENT OF ENERGY 

 ENERGY CONSERVATION STANDARDS 

 RULEMAKING FOR MISCELLANEOUS 

 CONSUMER REFRIGERATION PRODUCTS 

 PRELIMINARY ANALYSIS MEETING 

 JANUARY 9, 2015 

 FORRESTAL BUILDING, ROOM 8E-089 

 1000 INDEPENDENCE AVENUE, SW 

 WASHINGTON, DC 
Energy Conservation Standards Rulemaking for Miscellaneous Consumer Refrigeration Products Preliminary Analysis Meeting

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1 Group Members/Participants 

2

3 Doug Brookman, Public Solutions 

4 Joseph Hagerman, Department of Energy, Building 

5 Technologies Program 

6 Michael Kido, Department of Energy 

7 Prithvi S. Acharya, Navigant 

8 Nicole Buccitelli, Navigant 

9 Charles Hon, True Manufacturing Co., Inc. 

10 Stephen B. Leybourn, AHAM 

11 Jessica M. Lyman, ICF 

12 Judith Reich, Navigant 

13 Troy Watson, Navigant 

14 Detlef Westphalen, Navigant 

15 Melissa Fiffer, EPA 

16 Nathan Mouw, Whirlpool 

17 Hung-Chia Yang, Lawrence Berkeley National Laboratory 

18 Emily Marchetti, Webinar Manager, DOE 

19 Steve Rosenstock, Edison Electric Institute 

20 Scott Young, Lawrence Berkeley National Laboratory. 

21

22
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1 P R O C E E D I N G S 

2 MR. BROOKMAN: Good morning everyone 

3 welcome. This is the Energy Conservation Standards 

4 Rulemaking for Miscellaneous Consumer Refrigeration 

5 Products the preliminary analysis meeting today is 

6 January 9, 2015 here in the Forrestal Building in 

7 Washington, D.C. My name is Doug Brookman from 

8 Public Solutions in Baltimore. We are going to start 

9 this morning with welcoming remarks from Joe 

10 Hagerman. 

11 MR. HAGERMAN: This is Joe Hagerman from 

12 DOE. I just want to thank everybody for coming to, I 

13 guess, day two of the MREF test procedure and rule. 

14 This is the standard portion of the activities. I 

15 like this rule a lot, I mean we heard from ice man 

16 yesterday. Charlie told us everything about ice and 

17 today we are going to talk about standards. So we 

18 look forward to having a constructive discussion and 

19 hearing and continue to hear your thoughts on this 

20 rule so welcome and let's have a good day. 

21 MR. BROOKMAN: Thank you, we will start 

22 with introductions. Everybody can get used to 
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1 turning the microphones on and off. I will start to 

2 my immediate left, name and organizational 

3 affiliation. 

4 MR. HON: Charlie Hon, True Manufacturing. 

5 MR. MOUW: Nathan Mouw, Whirlpool 

6 Corporation. 

7 MR. LEYBOURN: Steve Leybourn with 

8 Association of Home Appliance Manufacturers. 

9 MR. ACHARYA: Prithvi Acharya with 

10 Navigant. 

11 MS. BUCCITELLI: Nicole Buccitelli with 

12 Navigant. 

13 MR. WESTPHALEN: Detlef Westphalen with 

14 Navigant. 

15 MR. WATSON: Troy Watson with Navigant. 

16 MS. REICH: Judith Reich from Navigant. 

17 MR.YOUNG: Scott Young, from Lawrence 

18 Berkeley National Laboratory. 

19 MS. YANG: Hung-Chia Yang from Lawrence 

20 Berkeley National Laboratory. 

21 MR. KIDO: Michael Kido, DOE, Office of 

22 the General Counsel. 
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1 MS. LYMAN: Jessica Lyman, ICF 

2 International, in support of the Energy Star Program. 

3 MR. BROOKMAN: Thank you. Thanks to all 

4 of you, I really appreciate you being here. Apologies 

5 for a little bit of a delayed start we had a few 

6 technical difficulties here this morning getting 

7 linked up. All of you received a packet of 

8 information I hope and this information, the Powerpoint 

9 slides will be broadcast over the net for those 

10 of you that are joining us via the web. 

11 Immediately following this overview I am 

12 going to do a brief agenda review. Immediately 

13 following this overview there is an opportunity for 

14 brief introductory remarks, kind of summary 

15 statements here at the outset about issues that might 

16 matter to you. Following that we are going to -- I 

17 have presentation material and slide content on 

18 market technology, screening, engineering analyses. 

19 Following that, markups, energy use and 

20 lifecycle and payback analyses and then moving on 

21 directly to shipments and national impact analysis, 

22 following that, manufacturing impact analysis. We 
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1 will take lunch midday, we will probably take a break 

2 mid-morningish 10:30 or so but lunch midday and 

3 whenever we get there as appropriate, following 

4 lunch, notice of proposed rulemaking analysis and the 

5 next steps and at the end of the day, whenever we 

6 arrive at that spot, closing remarks, yet another 

7 opportunity for individuals to comment about issues 

8 that matter to them. 

9 I would ask your consideration please 

10 speak one at a time, please say your name for the 

11 record each time you speak. There will be a complete 

12 transcript of this meeting made available. If you 

13 could share the air time this morning here and keep 

14 the focus here, if your cell phones are not on silent 

15 mode already, please do so, and to our participants we 

16 welcome you. 

17 The Department of Energy tries hard to 

18 make these meetings successful to all. Please turn 

19 your phone on mute, raise your hand to be recognized 

20 to speak, that's been working recently. We ought to 

21 be able to hear you in the room if you want to 

22 participate in this meeting. And an additional 
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1 reminder that even if you are participating via the 

2 web, and perhaps especially if you are participating 

3 via the web, the Department of Energy really 

4 appreciates you sending your detailed written 

5 comments surrounding your concerns. 

6 If you look at slide 6, there, you see an 

7 illustration of an issue box. These issue boxes are 

8 there, DOE puts them in the slide presentation 

9 material to call out specific issues that they hope 

10 to receive comment on so if you could be responsive 

11 to those issue boxes throughout that would be really 

12 excellent. 

13 So the way this is laid out here, now is 

14 an opportunity for anyone that wishes to, to make 

15 opening statements here -- summary statements here at 

16 the outset. I'm casting my eyes around the room and 

17 not seeing any uptake on this so now we are going to 

18 go directly to the overview regulatory history. 

19 MR. HAGERMAN: Do we want to see if there 

20 are any opening comments from anybody on the phone 

21 possibly? We can unmute the phone participants -- you 

22 just have to raise your hand. All right so we are 
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1 not seeing anybody raising their hand on the webinar 

2 so we are going to move on but as always if you have 

3 a question or comment please raise your hand and we 

4 will unmute your phone or type it in and we will get 

5 to you. 

6 It's really important that we hear your 

7 comments and your concerns. That's the nature of 

8 this whole day so I am going to quickly go over just 

9 the regulatory history here. If you could advance the 

10 next slide. 

11 I covered this a lot yesterday so I am 

12 going to try to speed through some of this today so 

13 we can get to the meat of the conversation since we 

14 are a little bit behind schedule and we have a lot of 

15 material to cover. So this is the first DOE 

16 rulemaking effort to consider energy conservation 

17 standards for what we have called miscellaneous 

18 residential refrigeration products. 

19 As everyone knows, EPCA currently covers 

20 refrigerators, refrigerator-freezers and freezers 

21 meeting the following criteria: they use AC 

22 electricity, they are designed for use with a door, and they 
Energy Conservation Standards Rulemaking for Miscellaneous Consumer Refrigeration Products Preliminary Analysis Meeting

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1 include a compressor and condenser as an 

2 integral part of the cabinet assembly. 

3 So, also current regulations define 

4 further [that] limit [the] energy conservation standards,

5 which 

6 cover products that can meet the temperatures of 

7 below 39 degrees Fahrenheit. So if you could advance 

8 the slide. 

9 So DOE proposed coverage of these new 

10 products, miscellaneous residential refrigeration 

11 products on November 2011. We proposed the coverage 

12 for refrigeration products that do not incorporate 

13 compressors on October 2013, coverage proposal. It 

14 proposed the coverage of the following products under 

15 a single new product category, which we largely 

16 discussed yesterday in the test procedure discussion: 

17 hybrid refrigerators, refrigerator-freezers and 

18 freezers; cooled cabinets; refrigeration products 

19 that do not use vapor compression; and ice makers. 

20 So if we could advance the slide, so DOE 

21 published the test procedure NOPR and discussed it 

22 yesterday. The NOPR was published on December 16th 
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1 and the comment period again I believe that closes 

2 March 3rd, March 2nd. For this one it's February 

3 2nd, but for the test procedures, it's March 2nd, so 

4 please, we look forward to getting your comments. 

5 In the NOPR, DOE proposed product 

6 definitions for the following: hybrid refrigeration 

7 products, cooled cabinets, non-compressor 

8 refrigeration products and ice makers. And we 

9 proposed collectively to define all of these as 

10 miscellaneous refrigeration products, MREF. We 

11 should have called it small miscellaneous 

12 refrigeration products or SMREF's but we are only so 

13 funny I guess. 

14 So the next slide is the rulemaking 

15 timeline. This is the current projected timeline 

16 with the final rule publication date of summer of 

17 2016. So next slide, so today we are going to talk 

18 about the standard itself and we -- you can use this 

19 slide, it's a very good slide as our roadmap for the 

20 day and the roadmap for the standard. And this is 

21 all the preliminary analysis that we are going to 

22 talk about today. And you see in our first cut of 
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1 this preliminary analysis so we are really looking 

2 forward to hearing your comments about some of the 

3 assumptions we made or some of the findings that we 

4 have been able to produce in this preliminary 

5 analysis. 

6 So let's go to the next slide and I'll 

7 turn it over to Detlef from Navigant who is going to 

8 start to do the market, technology, screening and 

9 engineering analysis. 

10 MR. WESTPHALEN: Thanks Joe. Is this on? 

11 Am I speaking loud enough? As Joe mentioned my name 

12 is Detlef Westphalen. I'm with Navigant Consulting, 

13 I'll be presenting on the market and technology 

14 assessment, the screening analysis and the 

15 engineering analysis. 

16 This just repeats the slide that Joe 

17 showed and shows where the market and technology 

18 assessment fits in with all the other analyses. It is 

19 an up-front analysis in which DOE collects 

20 information regarding the market and the 

21 manufacturers involved and it feeds into all the 

22 other analyses. 
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1 The purpose of the market assessment as 

2 mentioned is to characterize the miscellaneous 

3 refrigeration product market and understand who the 

4 manufacturers are, determine the scope of coverage, 

5 [and] determine appropriate product classes. The method 

6 used in this part of the analysis is to essentially 

7 do research, web research, discussion with 

8 manufacturer representatives, component suppliers, 

9 obtain shipment data if available to characterize the 

10 market trends and develop appropriate product classes 

11 consistent with EPCA criteria. 

12 There is much more detail in the technical 

13 support document than we will cover in this 

14 presentation. People are encouraged to refer to that 

15 in developing their written comments after the 

16 meeting. First of all, product types, we had some 

17 discussion yesterday as part of the test procedure 

18 meeting about product types. DOE is considering 

19 energy conservation standards for these four 

20 different MREF product categories: cooled cabinets, 

21 hybrid refrigeration products, non-compressor 

22 refrigerators and ice makers. 
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1 As part of the test procedure rulemaking, 

2 DOE proposed definitions for each of these products, 

3 and, as part of the energy conservation standard 

4 rulemaking, is considering the possibility of 

5 establishing standards for setting product classes 

6 within each of these categories in order to set 

7 appropriate standards for all the different product 

8 types. 

9 First of all, we will talk a little bit 

10 about the different product types and classes that 

11 DOE is considering. First of all, cooled cabinets. A 

12 cooled cabinet is a cabinet having a source of 

13 refrigeration requiring electric energy input only 

14 and [is] capable of maintaining temperatures either no 

15 lower than 39 Fahrenheit or in a range down to 37, no 

16 lower than 37 at least as high as 60 -- and we have 

17 talked about this a bit yesterday. 

18 Essentially, these are the types of 

19 products that I refer to in the market as wine 

20 chillers or beverage centers, that kind of a product 

21 in which the compartment temperature is maintained in 

22 a warmer range, typically 45 to 65 and the test calls 
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1 for set point at 55. We talked about a lot of that 

2 yesterday. We also have non-compressor cooled 

3 cabinets. These are cooled cabinets which do not have a 

4 vapor compression style refrigeration system. The 

5 official EPCA terminology is a compressor and condenser 

6 unit as an integral part of the cabinet assembly. 

7 Overall, the cooled cabinets are distinct 

8 from refrigerators in that they cannot achieve safe 

9 food storage temperatures and it should be noted that 

10 the definition specifies electric power input but 

11 does not distinguish between AC and DC power in the 

12 definition so DC powered cooled cabinets would also 

13 be considered for coverage. 

14 Why don't I jump one slide ahead here 

15 talking about classes for cooled cabinets before I go 

16 back to the non-compressor refrigerators? At this 

17 point DOE, is considering just one class for cooled 

18 cabinets. Potential considerations for class 

19 distinction would be associated with 

20 refrigeration system type -- the compressor versus the 

21 non-compressor. DOE has not identified consumer 

22 utility differences that would justify separate 
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1 product classes for these alternative refrigeration 

2 systems so at this point is not considering that. 

3 Another potential consideration for class 

4 distinction is defrost. DOE is not considering 

5 separate classes based on defrost because nearly all 

6 of the automatic defrost cooled cabinets on the 

7 market use off-cycle defrost. There are a very few 

8 that DOE has identified that use heated defrost, which 

9 would add to the products' energy use. 

10 DOE tested one example of this type of a 

11 product that uses a resistance heater for defrost but 

12 the defrost contribution was negligible, and due to 

13 the small market size of this type of a product and 

14 its very minor contribution to energy use of the 

15 defrost, DOE is considering not setting separate 

16 classes for different defrost categories. 

17 So here we have an issue box with a request 

18 for comment on the product classes for cooled 

19 cabinets and whether the single class [approach] is

20 appropriate, 

21 and if not, what other features should be considered 

22 for class distinction. 
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1 MR. BROOKMAN: Questions and comments 

2 here? Nothing here and those of you that are online 

3 please join us if you wish. Do you want to return to 

4 the definition on 19 or do you think that we -- 

5 because we haven't covered that yet right? 

6 MR. WESTPHALEN: We'll go back to page 19 

7 that's for a different product type. 

8 MR. BROOKMAN: Oh I see gotcha. 

9 Additional thoughts here before we move on? Okay. 

10 MR. WESTPHALEN: Okay coming back to the 

11 -- 

12 MR. HAGERMAN: So this is Joe Hagerman. I 

13 apologize we are just trying to get over some of 

14 these technical issues and we are making sure that we 

15 can actually see the webinar folks and if they have a 

16 question [to ask], be able to address you, so [were] making

17 some 

18 arrangements. 

19 MR. BROOKMAN: Okay back to Detlef. 

20 MR. WESTPHALEN: So we had no webinar 

21 questions on page 20 request for comment. 

22 MS. MARCHETTI: Joanna Mauer says we 
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1 support a single product class for cooled cabinets. 

2 MR. WESTPHALEN: Okay now back to page 19 

3 I think that's where I'm at. So this is about 

4 non-compressor refrigerators. The definition that was 

5 proposed that we discussed yesterday, this is a 

6 cabinet that has a source of refrigeration that does 

7 not include a compressor and condenser unit, and 

8 requires electric energy input only, and is capable of 

9 maintaining compartment temperatures of above 32 and 

10 below 39. The known non-compressor refrigerated 

11 products known to DOE used either thermoelectric or 

12 absorption refrigeration -- and this is just a picture 

13 of the thermoelectric unit in this slide. 

14 So now maybe we skip to page 21, which 

15 discusses classes for non-compressor refrigerators. 

16 So DOE has not identified consumer utility 

17 differences that would justify separate classes for 

18 the different refrigeration technology i.e. 

19 thermoelectric versus absorption. Limited data that DOE 

20 has available at this point suggests that the 

21 energy characteristics of these technologies are 

22 similar. 
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1 DOE has not identified non-compressor 

2 refrigerator products that use resistance heaters for 

3 defrost or that have manual defrost. Hence, DOE is not 

4 considering separate classes for different defrost 

5 approaches for non-compressor refrigerators, hence, 

6 DOE is at this point considering just one product 

7 class for non-compressor refrigerators. 

8 Next slide -- absorption refrigerators, 

9 DOE's collected data indicate that only 0.2% of 

10 homes use absorption refrigerators. According to 

11 DOE's research, roughly 2/3rds of the absorption 

12 refrigerator stock is found in hotels. All the models 

13 designed for hotels generally appear to be 

14 indistinguishable from residential models and I know 

15 we talked a little bit yesterday about the potential 

16 that some of these units may have commercial 

17 certifications UL or NSF which potentially carry with 

18 them some feature differences which may be important 

19 to consider. 

20 DOE -- as [part of its] preliminary analysis DOE,

21 has 

22 tentatively concluded that all of the refrigerators 
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1 that are used in hotels are otherwise 

2 indistinguishable in terms of utilities and features. 

3 So at this point I think it's probably appropriate to 

4 request comment on the classes for non-compressor 

5 refrigerators. 

6 MR. BROOKMAN: Okay comments on the 

7 classes as portrayed here? 

8 MR. WESTPHALEN: I think we skipped ahead 

9 in the slides. 

10 MR. BROOKMAN: Yeah. Whether it's now or 

11 in your written comments it's useful to tell the 

12 Department whether you think they are on the right 

13 track with this stuff. Okay nothing additional here. 

14 MR. WESTPHALEN: Okay next slide. So one 

15 thing in addition to note about non-compressor 

16 refrigerators and DOE testing, the non-compressor 

17 refrigerator is tested typically, or unable to achieve 

18 the target storage temperature of 39 Fahrenheit or 

19 below when tested in ambient test condition of 90 

20 Fahrenheit, so DOE has a request for comment here asking 

21 whether any non-compressor refrigerators exist and 

22 maintain storage temperatures of 39 Fahrenheit or 
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1 below in a 90 Fahrenheit ambient and, if not, are the 

2 technologies capable or are there potential 

3 alternative non-compressor technologies theoretically 

4 capable of maintaining these component temperatures? 

5 MR. BROOKMAN: Charlie? 

6 MR. HON: Absorption technology can be 

7 done that way. It is done that way with alternate 

8 fuel systems such as when you see a cabin in the 

9 woods with a propane tank behind it, absorption 

10 refrigeration can maintain that and actually maintain 

11 freezer temperatures but it's a very seldom used 

12 technology with electricity. 

13 MR. BROOKMAN: You don't see many of these 

14 units meeting the 37 degree threshold, okay Mr. Kido? 

15 MR. KIDO: Just to clarify Charlie, are 

16 you saying that it's not possible for these 

17 electrically-run, non-compressor refrigerators to meet 

18 those lower temperatures or it's just not that 

19 common? 

20 MR. HON: Let me say two things. Number one 

21 is there is extensive research being done at several 

22 universities right now on thermoelectrics and some 
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1 of the preliminary data shows that they are by 

2 stacking the plates heat cool, heat cool multiples. 

3 They are getting much better ability to get down to 

4 the lower temperatures. It is not a commercially 

5 available product at this time but I have seen the 

6 research that shows that they can do it. 

7 So we can definitely -- it could be into 

8 the refrigerator range, freezer range rate I don't 

9 know. 

10 The second thing is absorption systems if 

11 you put a larger heating element in it you can get 

12 more out of it. You have to get a good delta T's 

13 different than what they are running right now by 

14 keeping the heating element small they reduce energy 

15 consumption and then you have a limited cycle. 

16 MR. BROOKMAN: Identify yourself for the 

17 record. 

18 MR. HON: Charlie Hon. 

19 MR. BROOKMAN: Do we have additional 

20 comments here? Thank you Charlie that was helpful. 

21 Additional comments here on non-compressor 

22 refrigerators? 
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1 Okay we are going to move on. 

2 MR. WESTPHALEN: Next slide. And now we 

3 move on to hybrid refrigeration products. These are 

4 products proposed that include hybrid refrigerators, 

5 hybrid refrigerator-freezers, and hybrid freezers. 

6 These are products for which at least half of the 

7 volume includes one or more compartments, a warm 

8 compartment that either does not get below 39 

9 Fahrenheit or if it gets below 39 it gets down only 

10 to 37 and has a wide range up to at least 60. 

11 The test procedure notice proposed 

12 definitions for the various types of hybrids -- 

13 hybrid all refrigerators, hybrid refrigerators, 

14 hybrid refrigerator-freezers, hybrid freezers and 

15 hybrid non-compressor refrigerators. It should be 

16 noted here that a product with cellar compartments 

17 comprising less than half of the refrigerated 

18 volume would not be hybrid and would instead be 

19 considered to be a refrigerator-freezer or a freezer 

20 subject to the existing standards. 

21 Next slide -- so DOE is considering 

22 product classes for hybrid refrigeration products 
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1 that parallel the classes that are in existence for 

2 the refrigerators, refrigerator-freezers and 

3 freezers. The sub-bullets under the first bullet 

4 here show some of the characteristics that 

5 distinguish these classes, the size of the unit, the 

6 compartment types and orientation, the freezer 

7 compartment temperature range, defrost type, whether 

8 the unit has through the door ice service, and whether 

9 the unit is built in. 

10 And in determining the class of a hybrid 

11 product, the class would be assigned looking at the 

12 product as if the warm compartment, the cellar 

13 compartment, were not present. So next slide, the 

14 next slide lists the four different categories of 

15 hybrid products according to this paradigm for 

16 assigning classes the DOE is aware of based on market 

17 research. These include two standard sized, built-in 

18 variants, built-in hybrid all refrigerator and a 

19 built-in hybrid freezer with an internal ice maker, 

20 and also two compact products -- compact hybrid all 

21 refrigerator with manual defrost and compact hybrid 

22 refrigerator with automatic defrost. 
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1 And the first column in this table 

2 indicates the potential designation -- product class 

3 designation and you can see that these parallel the 

4 designations of the conventional refrigerator, 

5 refrigerator-freezer, and freezer with an additional 

6 "H" in the front. 

7 At this point we have a request for 

8 comment, specifically are there currently hybrid 

9 refrigeration products on the market for which there 

10 is no clear selection of the appropriate class based 

11 on the approach discussed using the existing 

12 structure, sorry, "classes" for conventional 

13 refrigerators or refrigerator-freezers and freezers. 

14 Additionally, DOE requests comment on 

15 whether there should be separate product classes 

16 allowed for built-in hybrid refrigeration products. 

17 MR. BROOKMAN: So are there products on 

18 the market for which there is no clear selection that 

19 corresponds to the appropriate to the listed classes? 

20 We don't know? Hmmm. 

21 MR. WESTPHALEN: I should say that DOE 

22 would also be interested in comments on whether there 
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1 are additional hybrid products out there on the 

2 market that would not be captured by these four 

3 variants listed in the table above. 

4 MR. BROOKMAN: Well what's happening in 

5 this marketplace maybe someone can say is there wild 

6 variation going on? All kinds of different 

7 configurations or are these configurations fairly 

8 standard since they relate to food safety and you 

9 know, what's happening with this marketplace do we 

10 know? I guess we don't know, Charlie? 

11 MR. HON: Charlie Hon, True Manufacturing. 

12 The big issue in most of these hybrid type units is 

13 the wine coolers with variable different temperatures 

14 allowed, whether it be for red wine, white wine or 

15 segregations thereof and the category is growing 

16 quickly but there's not a lot of major new 

17 technologies coming in -- just the same issues whether 

18 it be beer, wine, white, red. 

19 MR. BROOKMAN: Okay, do you want to prompt 

20 any other questions Detlef before we move on? 

21 MR. WESTPHALEN: No, I think that 

22 certainly more comments here would be helpful. 
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1 MR. BROOKMAN: I'd be curious here if 

2 anybody wants to respond to the question about 

3 built-in hybrid refrigeration products there should 

4 be a separate product class for them. Okay then, I 

5

6 26 

7

8 guess we are going to move on. 

9 MR. WESTPHALEN: Next, we will talk about 

10 ice makers. Yesterday, we talked about the definition 

11 proposed in the test procedure for ice makers -- a 

12 consumer product designed to automatically produce 

13 and harvest ice but excluding any type that achieved 

14 certification under NCNSF12 2012. Such a product may 

15 also include a means of storing ice, dispensing ice 

16 or storing and dispensing ice. 

17 And it just should be noted that 

18 refrigerators, refrigerator-freezers and hybrid 

19 refrigeration products and the like would be excluded 

20 from the definition of an ice maker. 

21 Next slide -- product classes for ice makers. 

22 These are distinguished by their ice storage 
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1 temperature and the water connections. First of all, 

2 cooled storage ice makers, these are ice makers that 

3 maintain the ice storage bin temperatures below 32 

4 Fahrenheit and typically produce crescent shaped ice 

5 similar to the ice produced by the automatic ice 

6 makers in refrigerator-freezers. 

7 All of the products DOE is aware of that 

8 would fit into this category use chilled air both to 

9 cool the mold and freeze the ice and also to keep the 

10 ice storage area cold. I know yesterday we talked 

11 about some other potential variants where there might 

12 be two sources of cooling, one for the ice production 

13 and one for the bin but DOE is not aware of any 

14 products at the moment that fit that category. 

15 The second category class here is the 

16 uncooled storage ice makers. These are ice makers 

17 that do not maintain ice storage bin temperature 

18 below 32 Fahrenheit. They have a refrigeration 

19 system that directly cools the mold, if you will, that 

20 forms the ice. Typically, they run water over the 

21 surface of the mold and the ice gradually forms and 

22 the water trickles down into a sump and is circulated 
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1 and a portion of that water is then drained at the 

2 end of the process. Hence, they use more water than is 

3 actually converted into ice, maybe 1/3 to 2/3's more 

4 than the ice quantity. 

5 These ice makers require drain connection 

6 to remove the melt water that collects in the bin and 

7 also the water that is removed as part of the ice 

8 making process. 

9 A third class that DOE is considering is 

10 portable ice makers. These are ice makers that do 

11 not require a connection to a household water supply 

12 for operation and they are operable using one or more 

13 onboard reservoirs that must be manually supplied 

14 with water. They are generally small, 

15 countertop-type products and the known products have 

16 uncooled storage and that doesn't mean that they fall 

17 into the uncooled storage ice maker class. You will 

18 remember from yesterday that there's a definition for 

19 uncooled storage ice maker and these portable ice 

20 makers that DOE is aware of are all uncooled storage 

21 ice makers and hence, portions of the ice making test 

22 procedure that was proposed that are associated with 
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1 uncooled storage features would be followed in 

2 testing these units. 

3 So next slide -- actually at this point 

4 why don't we stop before heading into the technology 

5 assessment and perhaps request comment on the ice 

6 maker classes? 

7 MR. BROOKMAN: We received some comments 

8 yesterday on ice makers, additional comment here 

9 Nate? 

10 MR. MOUW: Yeah and first if I might pose 

11 a question. I see on the definition of ice maker it 

12 says the proposed definition says such a product may 

13 also include a means for storing ice but yet the 

14 product classes don't contemplate a non-stored or an 

15 ice maker that does not store ice. What -- I guess 

16 help me put those two together. 

17 MR. WESTPHALEN: Well, the definition of 

18 ice maker is part of the test procedure and so DOE is 

19 not aware of any ice makers that do not store ice as 

20 well; however, the coverage and the definitions would 

21 apply to those if they did come on the market. The 

22 energy conservation standards and the analysis that 
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1 DOE has conducted has only considered those that 

2 actually do store ice at this time. 

3 MR. MOUW: Okay, thank you Detlef and then 

4 a comment again on yesterday I believe that was 

5 brought up in the test procedure rulemaking distinction -- 

6 even within an uncooled storage ice maker, about two 

7 different technologies for ice which produce a 

8 different utility for the consumer. One being a -- I 

9 think the word we used yesterday, there's probably 

10 various words, but a cascading type which removes 

11 minerals and produces a very clear ice for the 

12 consumer and that's what consumers often are looking 

13 for as well as removing the mineral content from the 

14 water. 

15 A different one, and honestly, I'm not 

16 familiar with the market in this regard, but it's 

17 certainly possible for somebody to produce an 

18 uncooled storage ice maker that does not have a 

19 cascading type and does not have the mineral 

20 reduction utility that consumers expect often times. 

21 So perhaps from a class perspective -- again I don't 

22 know the market in this area but it is possible to 
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1 have those two different types of ice makers with two 

2 very different utilities, even inside one of 

3 those product classes. 

4 You know our consumers do expect -- some 

5 consumers do expect clear ice, which again, is a very 

6 different utility and a different energy consumption 

7 to create clear ice than it does to pour ice in a 

8 trough so it would be water in a trough and let it 

9 freeze so there's a -- the comment is then to 

10 summarize there's probably opportunity or a need to 

11 separate those two. 

12 MR. BROOKMAN: Okay thank you. Charlie 

13 Hon? 

14 MR. HON: Charlie Hon, True Manufacturing. 

15 You mentioned that you had not seen any units which 

16 were basically cooled storage areas with, shall we say, 

17 crescent mooned ice. 

18 MR. WESTPHALEN: Correct. 

19 MR. HON: I have seen those, they are not 

20 very popular because usually it's a high-end market 

21 with a low-end product, but there is one on the 

22 market which produces -- it has a refrigeration coil 
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1 inside the block which heats up and then uses a hot 

2 gas by-pass to release the ice and push it back out 

3 and then -- but the block itself actually is still 

4 always cold. It helps maintain the chill in the 

5 cabinet so you don't lose your ice as fast. 

6 So they don't just eject ice when they 

7 need just cooling. If the ice bin is full, it doesn't 

8 start ejecting ice but it is still refrigerating so 

9 it can be done that way. 

10 MR. WESTPHALEN: Okay, it might be 

11 beneficial to get some details like product detail so 

12 that we -- 

13 MR. HON: I'll see if I can find it. I 

14 remembered it as shell. 

15 MR. BROOKMAN: Steve Rosenstock? 

16 MR. ROSENSTOCK: Steve Rosenstock, Edison 

17 Electric Institute. If you discussed this before, 

18 please forgive me, my delay was unavoidable. You 

19 proposed an ice maker definition and the first words 

20 are consumer product designed to . . . . . my 

21 question is -- aren't the vast overwhelming majority 

22 of ice makers used in commercial and/or industrial 
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1 settings? I don't know if there are ice makers 

2 specifically marketed to the residential market but 

3 I'm just saying in terms of the actual marketplace in 

4 the United States, aren't, I'll say, 90+ % of them used 

5 in commercial, maybe in some industrial settings? 

6 MR. WESTPHALEN: I can't say that I have 

7 the numbers off the top of my head but there is a 

8 considerable residential market and so that's what 

9 this rulemaking is. 

10 MR. ROSENSTOCK: And Steve Rosenstock, 

11 EEI. I'll say the commercial market? I'm sorry 

12 commercial -- I know there's automatic ice makers but 

13 then you have these tub ice makers that aren't, you 

14 know, automatic and commercial, is that not part of 

15 this coverage? 

16 MR. WESTPHALEN: Well commercial ice 

17 makers would be covered under, you know, the automatic 

18 commercial ice maker standard. I'm not sure what 

19 the question was. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

21 I mean I'm looking at the diagram here and I'm just -- 

22 I'm used to the big commercial ice makers and then I 
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1 see the small -- we have one in our office, it's just 

2 a small, I'll say a small cabinet ice maker, is that 

3 -- I'll say that small cabinet ice maker that's in 

4 office buildings is that already covered under the 

5 automatic commercial ice maker? Because I don't know, 

6 again, I don't know the capacity or the production 

7 rate of those. 

8 MR. WESTPHALEN: Well the commercial ice 

9 makers are covered down to 50 pounds per day ice 

10 production rate so depending on ice production rate 

11 it may or may not be covered already. 

12 MR. BROOKMAN: Okay Charlie Hon? 

13 MR. HON: This is Charlie Hon. In this 

14 same vein this isn't the type that has achieved 

15 certification under ANSI/NSF12 but not everybody gets 

16 that. Not everybody gets residential certified 

17 NSF12, some people just market product without that 

18 to the residential market. 

19 MR. BROOKMAN: So that definition should 

20 be modified to not include the ANSI/NSF stuff? 

21 MR. HON: I think we are building another 

22 exclusion if we do it that way because if they don't 
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1 choose to go for NSF12 then therefore they are not 

2 regulated. 

3 MR. WESTPHALEN: Well, the exclusion goes 

4 the other way, the way the definition is worded if 

5 they did certify it then they would not be covered 

6 under the residential. 

7 MR. HON: But, again, we end up with the 

8 same discussion we had yesterday. 

9 MR. WESTPHALEN: Exactly. 

10 MR. HON: Using it as an exclusion, so it 

11 could be either way. 

12 MR. WESTPHALEN: Right. 

13 MR. BROOKMAN: Okay. Charlie help us with 

14 this. If that's removed is the current definition 

15 robust? Does it provide adequate coverage? 

16 MR. HON: I think you capture both ends of 

17 the possible realm yes. 

18 MR. BROOKMAN: Okay, thank you. 

19 Additional comments on this section here before we 

20 move on? Okay let's move on. 

21 MR. WESTPHALEN: Okay, now we move into the 

22 technology assessment. The purpose of the technology 
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1 assessment, I think you are going ahead on the slides 

2 here, is to characterize the technology status of 

3 current products and to develop a preliminary list of 

4 technology options that could be used to improve 

5 efficiency. And to do this, DOE conducted a literature 

6 review that [included] manufacturer brochures and spec sheets

7

8 for commercially available equipment, looked at 

9 comments and input from stakeholders and conducted 

10 testing and reverse engineering of products that are 

11 available on the market. 

12 Again, a whole lot of the detail is 

13 provided in chapter three. The next few slides list 

14 a lot of the technologies that are described in a 

15 little bit more detail in chapter three. Next slide, 

16 this first page lists technologies associated with 

17 the refrigeration system and then the next slide 

18 lists technologies associated with the cabinet. 

19 And some of these technologies are 

20 applicable to more than one of the different product 

21 types addressed in the rulemaking and others are 

22 specific to a particular product type. For instance, 
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1 the glass doors would not be applicable for ice 

2 makers. 

3 Before we take a comment on the technology 

4 assessment, we might as well consider all of the 

5 technology- and design option-related questions after 

6 we have discussed the screening so if you advance the 

7 slide we are now getting into the screening analysis 

8 -- next slide -- in which the technologies that 

9 [DOE] preliminarily identified would be screened according 

10 to these 4 screening criteria. 

11 First, technologies are screened that are 

12 not technologically feasible; they are also screened 

13 if they are not practical to manufacture or install a 

14 service, have adverse impacts on product utility or 

15 availability to consumers or have adverse impacts on 

16 health or safety. And again, this is described in 

17 more detail in the TSD. 

18 The next slide lists the technologies that 

19 were screened out from the preliminary analysis and 

20 I'm not going to read all of these in detail but I 

21 think the next slide then reiterates the point I made 

22 earlier that the technologies listed might be 
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1 suitable to one of the product types and not another. 

2 And at this point, I think we should probably request 

3 comment on any of the technology and design option 

4 related issues such as first of all are there any 

5 technologies that should be considered in the 

6 analysis that are not listed yet or are there any 

7 that were listed that were not screened out that 

8 should be screened out? 

9 MR. BROOKMAN: So these design options are 

10 important and those listed on slide 35 technology 

11 options were not considered for analysis for 

12 non-compressor refrigerators. We don't have a 

13 comment box here but we would be -- it would be 

14 useful to get any additional comments on these 

15 technologies that were screened out or intended to be 

16 screened in and Emily can we unmute the phones? 

17 MS. MARCHETTI: Joanna Mauer has one. 

18 MR. BROOKMAN: Because we are suspicious 

19 that the technology is not working correctly here 

20 this morning so we are going to unmute the phones for 

21 everyone and then see if anyone who wants to 

22 contribute can get into the conversation. Joanna 
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1 Maurer Emily says you have a comment? 

2 MS. MAUER: Can you hear me? 

3 MR. BROOKMAN: Yes, you are good. 

4 MS. MAUER: I was just wondering 

5 regarding the cooled cabinets, Detlef, could you say 

6 anything about what kind of lighting technology is 

7 typically found in cooled cabinets today and/or 

8 typical wattages? 

9 MR. WESTPHALEN: Well, that varies. A lot 

10 of the cooled cabinets are moving to LED lighting, 

11 some of them may still use incandescent lighting. 

12 MS. MAUER: Okay. 

13 MR. WESTPHALEN: So it could be as low as 

14 you know a handful of watts, 3 to 5, it could be more 

15 like 20. 

16 MR. BROOKMAN: Okay Charlie Hon. 

17 MR. HON: Charlie Hon, True. There are 

18 also fluorescent lamps involved as well. 

19 MR. BROOKMAN: Okay. 

20 MS. MAUER: Thank you. 

21 MR. BROOKMAN: Additional thoughts on this 

22 segment? 
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1 MR. MOUW: This is Nate Mouw from 

2 Whirlpool. If I could just pose a question on slide 

3 34 which talks about technology which was screened 

4 out, it's not clear. Is this a list for cooled 

5 cabinets, hybrid refrigerators, ice makers, is it all 

6 of the above or is it specific to a product? 

7 MR. WESTPHALEN: It's more or less all of 

8 the above although clearly some of these wouldn't 

9 apply to all of the categories. 

10 MR. MOUW: Okay, but this is intended to 

11 include everything including ice makers? 

12 MR. WESTPHALEN: Yeah, and I think the TSD 

13 might be a little bit more specific in terms of is it 

14 screened out for one type or another but I think most 

15 of them are if they are screened out they are 

16 screened out. 

17 MR. MOUW: Okay, thank you. 

18 MR. BROOKMAN: We're about to move on, 

19 additional comments on this segment? Okay, we are 

20 going to move on. 

21 MR. WESTPHALEN: Okay, next slide. So now 

22 we will be talking about the engineering analysis and 
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1 essentially the engineering analysis develops the 

2 relationship between different efficiency levels and 

3 the costs required to attain those levels. The 

4 methods used for this analysis differed for the 

5 different product types. For the cooled cabinets and 

6 non-compressor refrigerators, DOE used a combined 

7 efficiency-level, design-option and reverse8 engineering approach where DOE evaluated certain 

9 products that are available on the market and 

10 determined, based on testing, their efficiency level. 

11 DOE also conducted energy use analysis to 

12 establish an energy model using the test data to 

13 validate that energy model. DOE also used that 

14 energy model to extend the analysis to efficiency 

15 levels that weren't specifically represented by 

16 products on the market and then DOE used reverse 

17 engineering to understand both the parameters that 

18 affect the energy use as inputs to the energy 

19 modeling and also parameters regarding the 

20 construction and fabrication that we used as inputs 

21 to a manufacturing cost model that then we used to 

22 develop the process of the different approaches for 
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1 achieving different efficiency levels. 

2 For ice makers, DOE used an efficiency 

3 level approach where DOE selected different models 

4 that were available on the market, conducted tests to 

5 understand their efficiency level, and then conducted 

6 reverse engineering that fed into manufacturing cost 

7 analysis to determine the different costs associated 

8 with achieving those different levels. 

9 For hybrid refrigeration products, we get 

10 into the approach used for this in quite a bit more 

11 detail later. DOE's considering the 2014 Energy 

12 Conservation Standard values as you have got the 

13 numerical values to assign for the standards for the 

14 hybrid refrigeration products. 

15 Again, the TSD provides more detail on all 

16 of these analyses. The analysis that I talked about 

17 a moment ago focuses on development of the 

18 manufacturing manufacturer production costs, what 

19 does it cost the manufacturer to make the product at 

20 a given efficiency level. Ultimately, for the 

21 downstream analysis, what's important is what is the 

22 selling price and, obviously, there is a difference 
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1 between what it costs to manufacture to make a 

2 product and what they are selling the product at and 

3 it's associated with the manufacturer markup. 

4 The next slide talks about the methodology 

5 for developing the manufacturer markups. Those 

6 markups are listed for the different product types. 

7 At the top of the slide, we have 1.26 for hybrids and 

8 vapor compression cooled cabinets, 1.22 for 

9 non-compressor cooled cabinets and refrigerators and 

10 1.23 for ice makers. And these markups were developed 

11 based on review of publicly available data such as 

12 SEC 10-K reports. 

13 So, next slide -- so the methodology for 

14 the engineering analysis for cooled cabinets and 

15 non-compressor refrigerators discussed this at a top 

16 level. On one of the previous slides was a combined 

17 efficiency-level design-option reverse-engineering 

18 approach. DOE conducted tests of products at 

19 different efficiency levels using the proposed test 

20 procedure. Reverse engineering allowed us to 

21 understand some of the parameters that affect the 

22 energy use, how the different components operate and 
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1 also to develop a bill of materials for the manufacturing 

2 cost model. 

3 Energy analysis was conducted with 

4 calibrating to the test data and/or ratings to 

5 evaluate the efficiency improvements associated with 

6 specific groups of design options and the energy 

7 model allowed us to evaluate efficiency levels that 

8 were not specifically represented by the products on 

9 the market. 

10 Manufacturing cost models were assembled 

11 using component cost data based on multiple 

12 information sources and also reverse engineering. 

13 DOE developed cost efficiency curves for the 

14 non-compressor refrigerators, one curve for 

15 non-compressor refrigerators and two curves for the 

16 cooled cabinets -- one for 2 cubic foot 

17 representative volume and one for a 6 cubic foot 

18 representative volume. 

19 So for the cooled cabinets the efficiency 

20 levels considered are listed on the table. Baseline 

21 efficiency level was defined by the least efficient 

22 unit that was identified on the market. EL4 
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1 represents what we call a CEC equivalent level of 

2 energy use, this is associated with the CEC standard 

3 for automatic defrost wine chillers, multiplied by a 

4 factor of .65. Essentially, that converts to .85 factor 

5 used in the CEC test procedure to the .55 factor that 

6 is proposed in -- that we discussed yesterday for the 

7 DOE test procedure. 

8 DOE chose to compare the other efficiency 

9 levels to EL4 so you see the efficiency level 

10 percentages are represented as a percent of the CEC 

11 equivalent energy consumption and it's called "CEC 

12 equivalent" because it's not really the CEC value, its 

13 CEC equivalent. Note that the lower efficiency 

14 levels lower than EL4 we used only for the 2-cubic 

15 foot analysis to represent the thermoelectric 

16 cooled cabinets. We did not find any 

17 thermoelectric-cooled cabinets on the market in the 6 cubic 

18 foot range. 

19 Next slide -- 

20 MR. HAGERMAN: I have a question about 

21 doing that there -- so your note says EL level 0 through 3 

22 use only the 2-foot, 2-cubic foot analysis 
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1 represented for cooled and electric cabinets, right? 

2 Does that mean that you found -- did you find any 

3 thermoelectric-cooled cabinets at 2 feet, 2 cubic 

4 feet that were at the levels above 3? Did you find 

5 any at 4 or 5? It's a little bit misleading here, I 

6 think, one could read that rule differently. 

7 MR. WESTPHALEN: I would have to say that 

8 there were not any that we evaluated and 

9 investigated. That's not to say that there aren't 

10 any on the market in a 2-cubic foot size. 

11 MR. HAGERMAN: And then also at levels of 

12 0 through 3 did you find any 0 to 3 units that had 

13 traditional compressors? 

14 MR. WESTPHALEN: No, and this goes back to 

15 the discussion we had yesterday that the California 

16 and Canadian standards essentially represent a North 

17 American standard and there is good clarity that 

18 vapor compression products are subject to that and so 

19 we are not aware of any units -- and I think Charlie was 

20 mentioning the real potential that there are some 

21 products that are on the market sold in the U.S. 

22 outside of California that do not meet those 
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1 standards so, again, I would be interested in hearing 

2 more about that. 

3 MR. BROOKMAN: Steve Rosenstock? 

4 MR. ROSENSTOCK: Steve Rosenstock, Edison 

5 Electric Institute. For the thermoelectric-cooled 

6 cabinets, what's the range of sizes just out of 

7 curiosity on the marketplace? 

8 MR. WESTPHALEN: Roughly, at a low end of 

9 l/2 a cubic foot, not much higher than 2-cubic foot. 

10 MR. ROSENSTOCK: So, and 2 cubic feet 

11 represents, I'll say, the majority of thermoelectric 

12 sold in the U.S., would you say? 

13 MR. WESTPHALEN: We don't have shipment 

14 data that would really say where the -- you know, the 

15 average point is in terms of size. 

16 MR. ROSENSTOCK: Okay, because it seems 

17 like you are using that going forward as a 

18 representative unit for the rest of the analysis and 

19 I just wanted to know in terms of -- for the 

20 thermoelectric area to the 2-cubic footage, I'll say your 

21 default size for the rest of the analysis. 

22 MR. WESTPHALEN: The 2-cubic foot 
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1 represents the size where there is overlap between 

2 vapor compression and thermoelectric. We get into 

3 some discussion later as to how small can you go with 

4 vapor compression, right, and certainly, you are 

5 alluding to a question of how high can you go with 

6 thermoelectric, but we did the analysis at the 2- 

7 cubic foot mark. 

8 MR. ROSENSTOCK: Thank you. 

9 MR. WESTPHALEN: Okay, next slide here 

10 shows the cost efficiency curves for two different 

11 sizes, the red for the 2-cubic foot and the blue plot 

12 for the 6-cubic foot and you can see that, clearly, the 

13 units started at a much better efficiency level for blue 

14 because thermoelectric technology was not 

15 considered and then they go up to fairly consistent 

16 levels at the top with a little bit higher costs for 

17 the 2-cubic foot due to conversion required 

18 to vapor compression in order to get 

19 to the EL4 level. Next slide -- 

20 MR. HON: This is Charlie Hon. Could we 

21 go back to the previous slide please? I'm seeing 

22 some units that don't cost anything to manufacture up 
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1 there. This is very uncomfortable for me. 

2 MR. WESTPHALEN: Yeah, I should say these 

3 are incremental costs and so that there would be -- 

4 yeah, there should be some, if you were showing actual 

5 costs, obviously the lines would be above zero, okay. 

6 MR. HON: So basically you have a 

7 theoretical baseline and then all incremental 

8 increases above that? 

9 MR. HAGERMAN: Exactly, so let's just be 

10 clear with that. So, your Y-axis there reads "MSP" should 

11 read "incremental MSP." 

12 MR. WESTPHALEN: That's correct. 

13 MR. LEYBOURN: This is Steve Leybourn. On 

14 the -- I guess the previous slide the factor of .65 

15 should that be .85? 

16 MR. WESTPHALEN: Well, that is, the 

17 .65 is equal to .55 divided by .85. 

18 MR. LEYBOURN: Thanks okay. 

19 MR. WESTPHALEN: So page 45 is that 44? 

20 No, I think you went too far, 43, addresses this 

21 question regarding the size range for the different 

22 technologies, specifically, the vapor compression 
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1 products. There may be limited availability of 

2 compressors with low enough capacity that there may 

3 be a practical lower limit and volume of cooled 

4 cabinets, and like a half cubic foot vapor compression 

5 may not be practical and so even if the compressor -- 

6 the system is designed to provide low duty cycle, you 

7 know, it would be anticipated that a certain amount of 

8 space would be required for the heat exchangers 

9 potentially and that and [at] a half cubic foot size 

10 potentially, there may not be 

11 space for that without having a heat exchanger extend 

12 off the back, so DOE requests comments and additional 

13 data on whether vapor compression is infeasible for 

14 cooled cabinets below a certain size and what would 

15 that physical size be? 

16 MR. BROOKMAN: No comments here? Okay. 

17 MR. WESTPHALEN: Next slide -- now we 

18 move on to the analysis for thermoelectric-cooled 

19 cabinets. The table here shows some of the test data 

20 obtained for thermoelectric-cooled cabinets and you 

21 can see that an interesting trend with regard to 

22 volume here you can see the, and this is in part in 
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1 response to Joe's question about the smallest volume 

2 unit does meet the CEC equivalent level. However, the 

3 units near 2 do not by a wide margin. 

4 And so we have a request for comment here, 

5 are there additional data available on the 

6 relationship between volume and efficiency in 

7 thermoelectric refrigeration products? 

8 MR. BROOKMAN: Steve Rosenstock? 

9 MR. ROSENSTOCK: Steve Rosenstock. Yeah, I 

10 just did some quick calculations. I just did, you 

11 know, the energy per kind of cubic feet and the first 

12 one is 222 kilowatt hours per cubic foot per year. 

13 The second one is in the middle 1.08 as 406 but then 

14 you get to the big one it is down to 293 so I don't 

15 know what that really means, it doesn't seem like 

16 there's any sort of trend between size and 

17 efficiency. 

18 Again on a per cubic foot of storage 

19 spaces. It goes 222, 406, 293 per cubic foot based 

20 on my calculations so I don't know if there is a 

21 relationship. 

22 MR. WESTPHALEN: Right, there are 3 data 
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1 points here. 

2 MR. ROSENSTOCK: Right. 

3 MR. WESTPHALEN: And still a request for 

4 additional data. 

5 MR. ROSENSTOCK: Right, but again, just 

6 looking at this table, Steve Rosenstock, EEI, just 

7 looking at this table it doesn't seem like there is a 

8 clear trend just based on these data points. I have 

9 no idea if there is a relationship between volume 

10 increasing or decreasing energy efficiency. 

11 MR. HAGERMAN: This is Joe Hagerman, DOE. 

12 I don't think this also tells you enough data to even 

13 make an assumption like you are because it doesn't 

14 tell you module size, it doesn't tell you 

15 installation of the -- of a lot of stuff. 

16 MR. ROSENSTOCK: Correct, I know these are 

17 like typical units -- again, I'm looking at the table 

18 that is being presented and I don't know if the 

19 technical support document had a lot more data in 

20 terms of some of those terms of a range, you know any 

21 sort of a range you know based on size but, you know, 

22 if there is a scatter plot maybe that would help but 
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1 if you can based on these I'm not sure, I can't tell. 

2 MR. WESTPHALEN: Yeah, the TSD does not 

3 have more information. There really isn't much 

4 publicly-available information using any kind of 

5 test procedure for these units, the cooled cabinets. 

6 Some of them, I believe, are listed on the CEC data 

7 base and/or Canada's data base, but very few. 

8 MR. BROOKMAN: That's what I was wondering 

9

10 53 

11

12 about the CEC especially -- do you suspect there's data 

13 out there that you haven't uncovered yet, Detlef? 

14 MR. WESTPHALEN: Well, I suspect that 

15 these units are a low-cost commodity product where 

16 you know the people that might be importing them may 

17 or may not be focusing a lot on certifying or 

18 reporting energy use. 

19 MR. BROOKMAN: So what would be the 

20 source of that data, if any? 

21 MR. WESTPHALEN: Potentially, the 

22 manufacturers that are involved or the importers that 
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1 are involved. 

2 MR. BROOKMAN: I was wondering if AHAM or 

3 someone like that has that kind of information. 

4 MR. LEYBOURN: I'll check. 

5 MR. BROOKMAN: Thanks Steve. 

6 MR. LEYBOURN: Ask. 

7 MR. BROOKMAN: Okay, thank you, Charlie? 

8 MR. HON: The problem 

9 that we faced when we have looked at these units and 

10 didn't choose to produce them is that just the 

11 configuration of your volume dictates your efficiency 

12 somewhat. The closer you are to the plate, the 

13 cooler that works. So if you have a large flat plate 

14 versus a true cube, you would get much more 

15 efficiency off the large flat plate with a very 

16 shallow distance away probably because there is no 

17 natural system to convect the cooler air around, it's 

18 just the plate is cool and that's all there is. 

19 MR. HAGERMAN: This is Joe Hagerman, I 

20 just don't want anybody to expect when you dive into 

21 the TSD that you are going to get a discourse on 

22 thermoelectric-cooling for refrigeration, right, 
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1 because that's not what we do here, it's not a 

2 research document like that. 

3 MR. BROOKMAN: But that comment was 

4 useful, that's descriptive, that's like kind of 

5 understandable I guess. So any additional thoughts, 

6 comments or sources for data as listed here in the 

7 issue box? Okay. 

8 MR. WESTPHALEN: All right, next slide. 

9 One of the design options considered in the analysis 

10 for cooled cabinets was the vacuum insulated panels. 

11 DOE based its modeling of vacuum insulated panel 

12 technology in cooled cabinets based on information 

13 obtained during the 2011 refrigeration product 

14 rulemaking. Most of that information pertained to 

15 cooler compartment temperatures [rather] than cooled cabinets

16

17 and so DOE requests information, are there any data 

18 available that would give some kind of indication as 

19 to the performance of vacuum insulated panels in 

20 these products. 

21 MR. HAGERMAN: Joe Hagerman, DOE. Do the 

22 manufacturers use a lot of these VIPs in your 
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1 products? 

2 MR. HON: In the small technology -- 

3 Charlie Hon. In the small technologies we are 

4 looking at them in the future but the cost is 

5 prohibitive as an insulation item and the bigger you 

6 get in large refrigeration units with very large 

7 evaporator coils or you have a really cold spot being 

8 developed in the cabinets, they are very valuable 

9 pieces because you can place them strategically 

10 around the cabinet and use them as a target 

11 insulation where you have either like right over the 

12 top of a compressor so you want to keep the heat from 

13 the compressor getting into the cabinet, you may put 

14 a VIP over the evaporator coil -- or it gets very 

15 cold and you are trying to avoid additional heat 

16 migration there you will put one, but the cost of them 

17 is fairly prohibitive and if you are a commodity 

18 product like some of these smaller units are, these 

19 thermoelectrics, I don't ever see them being 

20 viable. 

21 MR. BROOKMAN: Thank you Charlie. 

22 Additional comments here? Joanna -- Joanna Mauer you 
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1 are unmuted, please speak. 

2 MS. MAUER: Detlef, I was wondering whether 

3 you had tried contacting VIP manufacturers to get 

4 performance information? 

5 MR. WESTPHALEN: I don't think we did in 

6 order to get information for addressing this 

7 particular issue. 

8 MS. MAUER: Okay, it seems like it would be 

9 worthwhile to do that, especially because it seems 

10 like VIP technology may be changing fairly rapidly, 

11 that kind of performance and [the] cost of VIP's on the 

12 market in the 2011 time frame may be different from 

13 what's on the market today. 

14 MR. WESTPHALEN: Yes, good point. 

15 MR. BROOKMAN: Okay, thanks Joanna. 

16 MR. WESTPHALEN: Okay, move on to the next 

17 slide and this is associated with non-compressor 

18 refrigerators. As you recall during the discussion 

19 yesterday DOE is proposing that non-compressor 

20 refrigerators be tested in a 90 Fahrenheit ambient 

21 condition. DOE tested a few of these products and 

22 found that none was able to maintain a temperature 
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1 within 9 Fahrenheit of the 39 Fahrenheit 

2 standardized temperature in the test. 

3 And in the test procedure DOE proposed 

4 that the measured energy use would be based on the 

5 product's cold setting in the 90 Fahrenheit ambient 

6 because this would be most representative of the 

7 energy use essentially, the product working as hard 

8 as it could to deal with the additional thermal load 

9 that it would be expected in a refrigerator that 

10 traditionally is simulated with the 90 Fahrenheit 

11 ambient. 

12 So DOE is considering a standard 

13 adjustment factor for the standards for 

14 non-compressor refrigerators that would reduce the 

15 allowable energy use to compensate for the fact that 

16 these units in the 90 Fahrenheit ambient are not 

17 really maintaining the 39 Fahrenheit in the 

18 compartment and the standard adjustment factor here 

19 is just a linear adjustment based on the temperature 

20 difference. 

21 The next slide I think presents the 

22 request for comment on adopting this approach. 
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1 MR. BROOKMAN: Thoughts on the standard 

2 that has just been affected? Yes, Steve Rosenstock? 

3 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

4 Again I'm just kind of curious. Did the adjustment 

5 factor kind of match the numbers that you found in 

6 your test that you know the product only cooled down 

7 to 50 degrees Fahrenheit so you say, okay, when you 

8 knock it down the adjustment factor would be .784, 

9 are you finding that the energy consumption in those 

10 units was about that? You know, .784 times what -- 

11 MR. WESTPHALEN: Well, the tested products, 

12 obviously, could not maintain it. 

13 MR. ROSENSTOCK: Right. 

14 MR. WESTPHALEN: We couldn't test 39, you 

15 know, with those particular products but if we -- 

16 MR. ROSENSTOCK: Steve Rosenstock, maybe a 

17 better way to ask the question is -- is there a way 

18 to test them at the higher temperature to see if the 

19 adjustment factor is valid? 

20 MR. WESTPHALEN: Well, what I was going to 

21 say was that we did some investigation of other 

22 products with, you know, vapor compression technology 
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1 that can maintain the 39 looking at, you know, when 

2 they are tested at the warm setting might be at 45 

3 when they are tested, you know, the mid-setting might 

4 be near 39 and look at the trend and this standard 

5 adjustment based on that limited bit of research is, I 

6 guess, lenient shall we say, that generally, there 

7 would be more of an energy impact associated with 

8 bringing the temperature down to the 39 than a linear 

9 trend would suggest. 

10 MR. BROOKMAN: Any other comments on this 

11 standard adjustment factor? The comment box asks if 

12 it's appropriate and if not put what the factor 

13 should be. Do we have thoughts on that or do you 

14 think what is there is appropriate? 

15 MR. HON: This is Charlie Hon. 

16 MR. BROOKMAN: Yes? 

17 MR. HON: I'm very uncomfortable without 

18 any test data to validate any of this. This is 

19 typical modeling without verification of the model 

20 and there is a lot of problems right now with the DOE 

21 on that very topic so unless it's been validated that 

22 there is some correlation coming up with an algebraic 
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1 formula, its an algebraic formula that I don't know 

2 if [its] valid or invalid. 

3 MR. BROOKMAN: Okay, thank you, other 

4 thoughts on this? Okay, we are going to move on. 

5 MR. WESTPHALEN: Okay, moving on to more 

6 details on the non-compressor refrigerator 

7 engineering analysis. As mentioned previously the 

8 analysis is based on testing, reverse engineering and 

9 energy modeling. DOE considered design options 

10 including insulation, pipe cooling of the 

11 thermoelectric modules hot side and vacuum insulated 

12 panels. 

13 The table there identifies several 

14 efficiency levels that were considered based on the 

15 analysis and testing and the design option 

16 descriptions associated with those different levels. 

17 And the next slide then illustrates four of those 

18 different levels, the incremental cost adders 

19 associated with the different design option groups, 

20 and if there aren't any comments on this next we move 

21 into the engineering analysis for ice makers. 

22 DOE tested 2 models for each of the 3 
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1 product classes. Based on the reverse engineering 

2 feeding into manufacturing cost models, DOE 

3 calculated the incremental costs of the different 

4 designs and based on that, DOE developed one cost 

5 efficiency curve for each of the 3 ice maker product 

6 classes. 

7 DOE considered max tech levels that 

8 represent the higher efficiency units observed and 

9 tested and the next slide -- the next two slides show 

10 the curves in table form but then the third slide 

11 shows the plots representing the 3 curves. The green 

12 curve for the uncooled storage ice makers, the red 

13 curve for the cooled storage ice makers and then the 

14 blue curve for the portable ice makers and these 

15 again are incremental costs. 

16 I don't know if we want to stop here and get any 

17 comments on the ice maker analysis. 

18 MR. BROOKMAN: Charlie? 

19 MR. HON: Charlie Hon. Do you [have] any idea of 

20 the size of each of these units that you are showing 

21 here? Because the portable ice systems that I have 

22 seen in the market are traditionally a little bit 
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1 smaller than some of the bigger ones, some of the 50 

2 pound-type units. Were there any differences on 

3 sizes on these three charts because there is major 

4 differences in costs involved? 

5 MR. WESTPHALEN: Yeah, the portable units 

6 are deliverable countertop units, you know, maybe a 

7 few cubic foot total in outer dimensions, if that. 

8 The cooled storage and uncooled storage ice makers 

9 were 15-inch wide under counter units. The ice 

10 making production for the uncooled storage I don't 

11 remember the numbers but, you know, they were 

12 significantly lower than production rates for the -- 

13 sorry -- the cooled storage ice maker production rates 

14 were quite a bit lower than the rates for uncooled 

15 storage. Any other questions on that? 

16 MR. MOUW: This is Nate Mouw from 

17 Whirlpool again. With the -- for the same reasons we 

18 expressed yesterday, we disagree with ice makers being 

19 included in this rulemaking and we will provide 

20 commentary on that as well in our written comments. 

21 But past that -- as we look at these efficiency 

22 levels and the way that they were determined, you know, 
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1 for most refrigeration products, cost efficiency is 

2 always a curve and never a line and I think just by 

3 definition the way we have done these curves, as I 

4 understand it, please correct me if I am wrong, is we 

5 have tested two products for each of these and did a 

6 linear interpretation between the two, am is -- is 

7 that correct so far? 

8 MR. WESTPHALEN: That's correct. 

9 MR. MOUW: Okay, so that you know, number 

10 one it doesn't give a good representation of the 

11 products that are on the market. Testing two within 

12 a product class certainly doesn't represent the 

13 market well and secondly, creating two points in a 

14 line is not a good representation of the true costs 

15 involved with improving the efficiency of a product 

16 so we are very concerned with a -- having the ice 

17 makers in this rulemaking but, secondly, the level of 

18 robustness of this information. 

19 We don't think it's accurate to the 

20 realities of improving efficiencies of ice makers. 

21 MR. BROOKMAN: Thank you, Nate. 

22 MR. HAGERMAN: I think we also, Joe 
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1 Hagerman, DOE, we also heard yesterday that we didn't 

2 think that -- or some comments were said that you 

3 didn't think that there was even any efficiency to be 

4 gained in the ice makers right? 

5 MR. MOUW: This is Nate from Whirlpool. 

6 So it wasn't a comment that Whirlpool made and I 

7 think it was based on a comment that Sriram from 

8 AHAM made. In having talked to Sriram, I don't think 

9 -- he didn't correct you yesterday and certainly get 

10 back with AHAM on that, but I don't think that was 

11 the intent of his comment. I think the intent of his 

12 comment had to do with the national landscape of ice 

13 makers installed in homes and the impact of reducing 

14 efficiency of that small amount of products that are 

15 installed. 

16 MR. HAGERMAN: This chart shows there are 

17 substantial -- 

18 MR. MOUW: There could be -- I guess the 

19 other thing we need to think about is, again, as I 

20 discussed yesterday, is, you know, if we are considering 

21 these to be cool or cold storage devices, just as 

22 with refrigerators the efficiency or sorry - the 
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1 energy consumption to maintain a temperature within a 

2 compartment changes with the size of that 

3 compartment. 

4 MR. HAGERMAN: Sure. 

5 MR. MOUW: So either you need to say these 

6 are not storage devices or we need to account for 

7 that as we think about standards. We can call them 

8 hybrid storage devices. 

9 MR. HAGERMAN: Below that we are hybrid. 

10 So I have another question real quick just for Detlef 

11 and the Navigant crew there. You talk about a 

12 baseline here. On the previous two slides, you talk 

13 about a baseline, and you know the zero axis there is 

14 a baseline, could you comment to us and use the 

15 baseline in a previous section that talked about CEC, 

16 right, but these two separate baselines, I assume, 

17 because it is two separate products. 

18 MR. WESTPHALEN: And CEC has nothing to do 

19 with either ice maker. 

20 MR. HAGERMAN: I just want to make sure 

21 that when we say baseline it's not one continuous 

22 running baseline through the whole rule, it is a 
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1 baseline to a product. 

2 MR. WESTPHALEN: Yeah, I had a follow-up 

3 question for Nate in regard to just to get some 

4 clarity and maybe your written comments will have it 

5 in regard to what your thoughts are in terms of how 

6 the volume calculation might play into the test 

7 procedure and the energy conservation standard? 

8 MR. MOUW: This is Nate from Whirlpool. 

9 That's a good question. You know if there's a 

10 desire, we will consider that for written comments. I 

11 wouldn't want to go on record right now with how to 

12 do that but just the inherent nature of a cooled 

13 storage compartment, the energy consumption varies 

14 with the compartment size and, of course, we account 

15 for that in refrigerators, freezers, every other 

16 product that we consider to be a cooled store or cold 

17 storage device. 

18 So you can imagine a 15-inch wide ice 

19 maker versus a 24-inch which may not even exist on 

20 the market today but certainly if you are keeping a 

21 larger compartment cool it consumes more energy. So 

22 if we are considering these to be storage devices 
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1 then we need to take that into account, but I am not 

2 prepared to comment on that today. 

3 MR. BROOKMAN: Charlie Hon? 

4 MR. HON: This is Charlie Hon. There are 

5 several factors involved. Number one is a ratio 

6 between the surface area of the storage bin and the 

7 volume of the storage bin. Secondly, the amount of 

8 doors, seams, anything else that could allow 

9 penetration of air, whether they are a gasket or a 

10 non-gasket because most ice machinery is un-gasketed 

11 because you want air flowing through to help in the 

12 standardized melt pattern that you require for your 

13 product quality. 

14 So there's all kinds of things you can add 

15 in here depending on what your classification of 

16 product is because if you would have a cooled ice 

17 storage area, you would want no air penetration. If 

18 you have an uncooled ice storage area, you would want 

19 penetration so you would get partial melt to keep the 

20 ice fresh. So there are a lot of questions that have 

21 to be answered before you really come up with what 

22 your formula would be because it is dependent on your 
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1 product nature and what your customer demands. 

2 MR. HAGERMAN: Let the record show that 

3 the ice man just spoke. 

4 MR. BROOKMAN: Nate you want to follow 

5 on? 

6 MR. MOUW: Yes, just one more thing that 

7 I intended to mention. Naturally, if you have a 

8 cost-efficiency curve, there's not a curve but a line. 

9 Of course, the impact on that is the payback period 

10 doesn't change with the level of efficiency. The 

11 payback period is -- and I think having read the TSD, 

12 the TSD reflects that -- that regardless of the 

13 efficiency level you choose, the payback period is the 

14 same for the consumer so that just -- it doesn't work 

15 like that so there has to be a better investigation 

16 into the true cost efficiency curves for ice makers. 

17 MR. BROOKMAN: Thanks. Were you 

18 suggesting we take a break now? In this -- 

19 MR. WESTPHALEN: We have 

20 about, I don't know, five more refrigeration products 

21 we don't have much further to go. 

22 MR. BROOKMAN: Yeah, let's keep going. 
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1 MR. WESTPHALEN: Okay, next slide. Here we 

2 get into hybrid refrigeration products, I alluded to 

3 the consideration of using the 2014 refrigerator, 

4 refrigerator-freezer and freezer numerical levels as 

5 the standards for hybrid refrigeration products and 

6 so we get into some of that discussion here. 

7 Hybrids are, in conventional refrigeration 

8 products, in many ways are similar with three key 

9 exceptions affecting the energy. First of all, one 

10 of the compartments in the hybrid is a cellar 

11 compartment, at least half of the volume, which is not 

12 going to be down at 39 Fahrenheit, would be at 55. 

13 Second, the doors that provide access to 

14 the cellar compartment are often made of glass. 

15 Sometimes, those glass doors in smaller units cover 

16 also the fresh food compartment. 

17 Third, the test procedure proposes a usage 

18 factor of .85 for hybrid products based on the 

19 different usage patterns expected for hybrid 

20 products. 

21 So [on] the next slide, the test procedure also 

22 proposes a .69 for annual adjustment factor for 
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1 cellar compartments, which, if you look at a 

2 refrigerator, say, and hybrid refrigerator, it would 

3 mean that the hybrid refrigerator would have a lower 

4 adjusted volume and, therefore, if you use the same 

5 numerical values, same equations, you would have a 

6 lower standard. 

7 And so, in considering whether these 2014 

8 values would be appropriate, DOE expected that some 

9 of these factors make -- would make that standard 

10 more stringent for hybrid, some would make it less 

11 stringent so DOE conducted an analysis. 

12 The other thing to mention here is that in 

13 regard to the refrigeration systems -- because the 

14 hybrid product does have, say, a fresh food compartment 

15 or if it is a hybrid freezer, a freezer compartment, 

16 the evaporating temperatures would be similar to 

17 those of the conventional products, and, clearly, in 

18 the test, the ambient temperature would be similar. 

19 So that was the basis -- it sort of lays 

20 the groundwork of the assessment of whether these 

21 2014 numerical standard values would be appropriate. 

22 Next slide -- so DOE considered 
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1 refrigerators that are minimally compliant with the 

2 2014 standards compact analysis for one set of 

3 product types and full-sized for another and 

4 considered different features, some of these 

5 different features represent different configurations 

6 such as percent of cellar compartment. 

7 Other differences here represent different 

8 design options, such as different glass door types, 

9 whether the insulation thickness is one level versus 

10 another level. 

11 So next slide -- at a top level, the 

12 results indicate that the existing hybrid products 

13 that use glass doors to cover their entire 

14 refrigerator volume may require the use of more 

15 efficient glass doors or solid door over the fresh 

16 food compartment in order to meet these numerical 

17 values, the 2014 standards. This is using the .69 

18 adjustment factor for the cellar compartment. 

19 The table on the next slide shows that 

20 design options that are fairly common can be used so 

21 that in order to obtain compliance with these 

22 numerical values that will be considered for the 
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1 standards for the hybrids and so the tables, for 

2 instance, in this standard size hybrid's table, you 

3 will see 50% and 75% as the two percentage cellar 

4 compartment values considered and then there are 

5 different variants here in terms of how much of the 

6 door is solid and how much is glass and then the 

7 third column indicates the types of design options 

8 required to be added to a baseline configuration in 

9 order for a hybrid to meet that standard level. 

10 I should note here that these reported 

11 EER's are system EER's operating at what would be 

12 appropriate for a refrigerator, so a fresh food 

13 compartment might be operating in the 15 to 20 to 25 

14 range in terms of evaporating temperature and so 

15 these aren't directly comparable to the rated 

16 compressor EER's. 

17 In general, these compressor -- the 

18 compressor EER's required to attain these system 

19 EER's are fairly modest in terms of the compressor 

20 availability in the market. 

21 MR. BROOKMAN: Steve Rosenstock? 

22 MR. ROSENSTOCK: Steve Rosenstock, EEI. 
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1 Again, I will just say -- I just have a question in 

2 terms of the hybrids. Were they tested using the -- 

3 I'll say the standard refrigerator test procedure 

4 that's used for the non-hybrid refrigerators? 

5 MR. WESTPHALEN: Well, these were evaluated 

6 -- DOE did test some hybrids but most of these 

7 analyses are theoretical and, you know, the assessment 

8 was conducted you know, consistent with the proposed 

9 test procedure, which in many ways is similar to the 

10 existing test procedures for refrigerators and 

11 refrigerator-freezers. 

12 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

13 Okay, but I guess my question is -- is there some 

14 testing data that shows that, you know, when you test 

15 these hybrids with these features in that testing 

16 chamber that they will be able to meet the 2014 

17 refrigerator standard? 

18 MR. WESTPHALEN: We did not put together 

19 these configurations and test them in order to 

20 confirm. 

21 MR. ROSENSTOCK: Okay, so okay, thank you. 

22 That helps because you know it's -- and again Steve 
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1 Rosenstock, EEI, yeah, there's the refrigerator 

2 rulemaking you know, the new standards go into effect 

3 in September, I believe, and so they are not going to 

4 -- you know, they have a couple of years before they 

5 start a new round of rulemaking so it seems like we 

6 are kind of in a way almost shoe-horning the hybrids 

7 into that category where, if the test data shows 

8 separately that they don't meet it, then there could 

9 be an issue. 

10 If, for some reason, a manufacturer does 

11 test a hybrid using the standard refrigerator test 

12 and all of a sudden it's like oh-oh we are 5% over, 

13 then even with these options, then there could be an 

14 issue. 

15 MR. WESTPHALEN: Yes, clearly, you know, 

16 it's important, you know, to get the validation to 

17 eventually you know -- information from manufacturers 

18 that may have experienced testing some similar 

19 configurations that the conclusions of these analyses 

20 are appropriate. 

21 MR. HAGERMAN: And we should just say that 

22 you know that we welcome comments on the test 
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1 procedure that we discussed yesterday and it's out 

2 for public comments. I'm calling you out for not 

3 being here with everybody else. 

4 MR. WESTPHALEN: And so the next slide 

5 shows a similar table for compact hybrids and for the 

6 compact hybrids, an additional configuration was 

7 considered -- that of the glass covering of both the 

8 fresh food and the cellar compartment. 

9 And then the final slide just puts the 

10 issue up for comment in regard to whether the 

11 suggested approach for use of the 2014 refrigerator 

12 freezer standards are appropriate to apply to hybrid 

13 refrigeration products in the way detailed. 

14 MR. BROOKMAN: And also a request for any 

15 additional data. Comments here? Nothing here -- 

16 okay, let's take a break, it's five minutes until 11, 

17 let's take a fifteen minute break which means when we 

18 return at ten minutes after 11 to resume, please make 

19 sure you keep your badges visible as you walk around 

20 the Forrestal Building, the restrooms are on both 

21 ends of the hall, there's a coffee shop down on the 

22 ground floor if you want to go there quickly. 
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1 We have gone through more than half of the 

2 slides in a little less than 2 hours and so if we 

3 proceed at the same pace, we might succeed in getting 

4 through all of the material prior to breaking for 

5 lunch so I'm just suggesting that if we are close at 

6 12:30 or something like that we may extend the work 

7 here of the group and just plug on and give everyone 

8 a chance to get out of here early. We don't in any 

9 way wish to diminish the capacity for comment but 

10 just as a matter of being efficient, that would be 

11 what I would propose as the plan so that if you need 

12 a piece of fruit you should get it now, okay. 

13 So we are breaking and will resume at ten minutes 

14 after 11. 

15 (Whereupon a recess was taken at 10:55 

16 a.m.) 

17

18

19

20

21

22
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1 A F T E R N O O N S E S S I O N 

2 MR. BROOKMAN: Let's resume. Welcome 

3 back, we are going to pick up where we left off. We 

4 covered a lot of ground already, we've got about 40% 

5 left to go here so let's pick up with mark-ups 

6 analysis and you can present up here or from your 

7 seat, either one. If you do it up here you can 

8 advance the slides. 

9 MR. YOUNG: Hello, can everyone hear me ok? 

10 Okay, my name is Scott Young, I'm from Lawrence 

11 Berkeley National Laboratory and I will start on the 

12 sections looking at the mark-ups, energy use, and 

13 lifecycle cost and payback period analysis. There's 

14 mark-ups -- so the first one is the mark-ups analysis 

15 and this is the analysis that aims to convert 

16 manufacturer selling prices to consumer purchase 

17 prices. 

18 In order to do that, DOE has to first 

19 characterize the product distribution channels for 

20 the products and for these products, DOE identified 

21 that the vast majority of products go through a 

22 channel where manufacturers sell to a retailer and 
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1 then retailers sell directly to consumers. 

2 Manufacturer mark-ups are developed in the 

3 engineering analysis, so for the retailer mark-ups, DOE 

4 used the annual retail trade survey to estimate the 

5 mark-ups for the retailer. There are two different 

6 types of mark-ups that DOE uses, one of them is a 

7 baseline mark-up and this is the mark-up that is used 

8 to mark up the prices of baseline products at the 

9 baseline efficiency level. This includes all of the 

10 retailers' expenses and their profit. 

11 In addition, there is also an incremental 

12 mark-up that is used to mark up the incremental 

13 prices going from the baseline efficiency level to 

14 higher efficiency levels and these mark-ups cover 

15 only the portion of the retail expenses that are 

16 expected to change with changes in efficiency level. 

17 So this table outlines all of the average 

18 mark-ups that were determined. Manufacturer mark-up 

19 was discussed in [the] engineering section. The retailer 

20 mark-up was estimated to be 1.36 for baseline and 1.1 

21 for incremental. Then there's an average sales tax 

22 applied here and we will discuss that a little more 
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1 in the LCC section and finally, this is the overall 

2 average mark-up applied across from manufacturer 

3 production costs through to consumer purchase price. 

4 MR. BROOKMAN: When we had this slide 

5 previously this morning, we didn't get any comments on 

6 mark-ups. Should there be any, maybe now would be a 

7 good time to say anything about mark-ups, if you 

8 think these are reasonable, if you think they are 

9 kind of in the ballpark, any comments here? No 

10 comments here. 

11 MR. YOUNG: All right, thank you. Okay so 

12 the next section is the energy use analysis. The 

13 purpose of the energy use analysis is to estimate 

14 the distribution representative site energy use for 

15 consumers of these products. Several steps used to 

16 determine that -- DOE developed the distribution of 

17 the volumes of these products and usage behaviors of 

18 these products, determined the distribution of the 

19 efficiencies that are on the market and estimated 

20 energy use from laboratory tests and manufacturer 

21 websites and also field monitoring, [and] combined that to 

22 get an estimate of field energy use. 
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1 First, I'll deal with cooled cabinets. DOE 

2 first estimated the capacities of cooled cabinets 

3 that are used by consumers. DOE used the results of 

4 a study that used surveys of consumers or people who 

5 own these products. I will refer to this study in 

6 future slides as the LBNL Study. As you can see from 

7 the plot here, from the study DOE estimated the 

8 distribution of sizes for thermoelectric units as 

9 well as for vapor compression units. 

10 As you can see the thermoelectric units 

11 tend to be smaller than the vapor compression units. 

12 Next, DOE estimated the distribution of 

13 efficiencies that are currently on the market. DOE 

14 used a range of government web sites -- government 

15 data bases and retailer manufacturer websites as well 

16 as laboratory and field testing to do this estimate. 

17 You can see for the vapor compression units, they all 

18 have a distribution that tops out at the CEC, 100% of 

19 CEC equivalent and goes lower, whereas the 

20 thermoelectric units have many models that are at a higher 

21 efficiency consumption than the CEC equivalent. 

22 That's the end of the cooled cabinets so 
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1 does anyone have any questions about the cooled 

2 cabinet energy analysis? Okay, I'll move on to the 

3 non-compressor refrigerators. For this section, there 

4 was less information so DOE used a single size, a 1.7 

5 cubic foot, which is the same as what was used in the 

6 engineering analysis. And DOE also used the 

7 laboratory testing to estimate the energy use. 

8 DOE estimated all thermoelectric units 

9 are at the baseline efficiency level, EL-O and that 

10 absorption units are all at the EL-1 level. Yes? 

11 MR. BROOKMAN: Steven Rosenstock? 

12 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

13 I'm just -- so you didn't have any shipment data for 

14 the non-compressor refrigerators thermoelectric and 

15 you are showing them all at EL-O? 

16 MR. YOUNG: Yes, that's right. 

17 MR. ROSENSTOCK: Aren't there models like 

18 at EL-l and EL-2? Again, I'm afraid that by doing 

19 that you are -- there would be a tendency to kind of 

20 overstate the energy savings if the marketplace, you 

21 know, if a mix of, like, the cooled cabinets, where there 

22 is a whole wide range, and whether it's a bell curve 
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1 or whatever that using kind of the extreme case will 

2 tend to, you know, overstate the savings that the 

3 consumers are going to see. 

4 MR. YOUNG: Yes, so there were -- DOE did 

5 test about five units of these and found that there 

6 was somewhat of a distribution of them but relative 

7 to -- there wasn't that much of a distribution by 

8 volume as a volume change, but related to volume 

9 there wasn't that much of a change and so yeah, there 

10 could be more of a range put in there but for this -- 

11 for the initial analysis DOE did not include any. 

12 MR. ROSENSTOCK: Okay. 

13 MR. YOUNG: Any other questions on 

14 non-compressor refrigerators? Okay, then this brings 

15 us to our next request for comment. Are additional 

16 data available on the estimated annual field energy 

17 use of non-compressor cooled cabinets and 

18 refrigerators, both thermoelectric models and 

19 absorption models? This is one area where there is 

20 much less data, much less information than for vapor 

21 compression units. 

22 Now, moving on to ice makers, DOE also used 
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1 the laboratory testing from the engineering analysis 

2 to estimate the energy use for the ice makers. 

3 Similar to the engineering analysis, DOE assumed an 

4 ice production rate of 4 pounds per day. DOE assumed 

5 that cooled and uncooled units were in constant use, 

6 while the portable units were in use 50% of the time. 

7 DOE assumed that 50% of the market share would be 

8 at EL-0 and 50% of the market share would be at the 

9 max available EL. Yes? 

10 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

11 With the assumption that these are residential 

12 products, correct? That they are in constant use, 

13 meaning that they are producing ice 24 hours a day, 

14 seven days a week or that they are -- I guess I'm a 

15 little, just trying to understand when you say an ice 

16 maker in constant use. Once it fills up the bin it 

17 is not going to make any more ice until people take 

18 out a lot of the ice out of the bin. 

19 MR. YOUNG: Yeah. 

20 MR. ROSENSTOCK: And I'm just -- when you 

21 say constant use what kind of a -- I'll say how often 

22 is the ice maker on in that "constant use" type of 
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1 scenario? 

2 MR. YOUNG: Sure yeah, so as outlined for 

3 the test procedure the assumption is that the 

4 consumers withdraw about 4 pounds of ice per day and 

5 that the ice is -- but the ice bin maintains a full 

6 bin throughout the day and so, therefore, the ice maker would

7

8 replenish that 4 pounds of ice as well as replenish 

9 any other ice that melted in the bin, if it was an 

10 uncooled unit during that time. 

11 MR. ROSENSTOCK: Thanks, Steve Rosenstock, 

12 EEI. Just give me a sense, I know there's different 

13 size ice. How many ice cubes is 4 pounds a day just 

14 out of curiosity? 

15 MR. BROOKMAN: It depends on the size of 

16 the -- 

17 MR. ROSENSTOCK: I know it depends on the 

18 size and density of the ice cube but I'll say for the 

19 average ice maker that we are talking about here is 

20 that 20 cubes, 40 cubes, 60 cubes, I just kind of [want to]

21 get 

22 a sense, I'm just thinking about my own home use so. 
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1 MR. YOUNG: Yeah, yeah, you know that's a 

2 good question. I guess I'm not completely sure 

3 either. Detlef do you have any better idea? 

4 MR. WESTPHALEN: I'm going to guess on 

5 the order of 50, 60. 

6 MR. BROOKMAN: 4 pounds ought to be about 

7 -- 

8 MR. ROSENSTOCK: That's a lot of ice, 

9 Steve Rosenstock, EEI. 

10 MR. BROOKMAN: That much ice. 

11 MR. ROSENSTOCK: I don't drink that much 

12 ice in a week myself, and again a big family could 

13 but that's -- 

14 MR. WESTPHALEN: Well, Steve let me ask, do you 

15 have a residential ice maker in your home? 

16 MR. ROSENSTOCK: In my freezer, it's not a 

17 stand-alone one, absolutely not, the one in my 

18 freezer. 

19 MR. WESTPHALEN: If you were the kind of 

20 person that did use a lot of ice, you would probably 

21 get one of these units, a unit. 

22 MR. ROSENSTOCK: Or I'd just leave the 
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1 freezer thing on to make more ice as I needed it but 

2 okay, I was kind of curious just to get a sense of how 

3 much ice are we talking about here in a residential 

4 setting. 

5 MR. BROOKMAN: Steve, you are revealing 

6 that you are not a party-hound. 

7 MR. ROSENSTOCK: Not at home, just 

8 kidding. 

9 MR. BROOKMAN: Nate you are next. 

10 MR. MOUW: No, I was just going to -- to 

11 respond to the comment about you know whether or not 

12 somebody owns an ice maker correlates to the amount 

13 of ice they make. I don't think we have seen data 

14 that suggests that and I personally don't believe 

15 that just as a matter of opinion. 

16 You know, a lot of the consumers that have 

17 these types of products, some have them to be 

18 hospitable for parties and other events, to provide a 

19 large quantity of ice for specific occasions 

20 throughout the year not necessarily because they are 

21 you know, they are responsible with their health and 

22 drink lots of ice water. 
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1 So just for the record, I 

2 don't know that there has been data shown and that 

3 suggests that somebody that uses and buys an ice 

4 maker, stand-alone ice maker, uses more ice than the 

5 average consumer. 

6 MR. BROOKMAN: Interesting. You would 

7 think manufacturers would have this scoped out. 

8 MR. HAGERMAN: The question is, do those 

9 people that have ice makers that have parties, on 

10 average, if you take the amount of ice they consume in 

11 the party phase of their time, does it average out to 

12 4 pounds right? 

13 MR. BROOKMAN: Charlie Hon? 

14 MR. HAGERMAN: You see the problem right? 

15 MR. HON: We have done a few market 

16 studies and had them done but the biggest consumer is 

17 by anyone that has a pool outside, it really is. 

18 MR. BROOKMAN: I'd say we move on, okay, 

19 we have explored this one, keep going. 

20 MR. YOUNG: Yes, so actually, we can go 

21 straight to our request for comment, maybe we have 

22 covered this already. Are additional data available 
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1 on energy consumption and market shares of ice 

2 makers? In particular, we assumed a market share split 

3 using just the two representative models so, and we 

4 added it. As you are mentioning, do we know whether 

5 people who are using [ice makers] largely for parties do they

6 just 

7 turn them on the week before the party and then turn 

8 them off, or do they keep them on all the time. 

9 MR. BROOKMAN: One of our members present 

10 is nodding his head up and down saying yes they leave 

11 them turned on all the time, okay. 

12 MR. YOUNG: So for hybrid products, DOE 

13 reviewed manufacturer websites to determine the 

14 capacities and energy use of hybrid products that are 

15 on the market and DOE identified hybrid products from 

16 4 different product classes that are on the market 

17 already as identified in the engineering analysis. 

18 The table shown outlines the different 

19 product classes that were identified, the average 

20 kilowatt hours per year that was identified from 

21 manufacturer websites and how that relates to the 

22 allowed energy use following the 2014 refrigerator- 
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1 freezer standard. 

2 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

3 That's the 2014 refrigerator-freezer standard, so you 

4 are just doing the equation for the hybrids as if it 

5 was a refrigerator in that class, whether you are 

6 talking about a freezer or whatever, okay, thank you. 

7 MR. YOUNG: So that's the end of the 

8 energy use analysis. Are there any additional 

9 questions on the energy use analysis? 

10 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

11 Going back to the last slide, I'm sorry. 

12 MR. YOUNG: Sure. 

13 MR. ROSENSTOCK: What this slide is 

14 showing is that the hybrids, at least the first 3 

15 classes that they that, again, I'll say the standard 

16 design, that they would have to reduce their usage by 

17 that 54 or 43 or 42% to meet the refrigerator 

18 standard? Is that what the slide is saying for those 

19 classes? Okay, because I know there was a slide 

20 before. Well do we just apply the refrigerator 

21 standards to the hybrid and, again, I know there are a 

22 lot of units out there but this tends to say, well, you 
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1 know, can you get there with those other design 

2 options. I don't know. 

3 You showed all the other design options 

4 for the hybrid in terms of the gaskets and the doors 

5 and everything, it's like, well, this again this might 

6 say they might not be able to do it and they might 

7 need a separate category -- I hate to do this, they 

8 might need a separate category, a separate product 

9 category. 

10 MR. YOUNG: I think this identifies that 

11 there could be models out on the market currently 

12 that do not meet the standard. 

13 MR. ROSENSTOCK: And again, Steve 

14 Rosenstock, EEI, I don't know if this was typical or 

15 was this an outlier again, it always depends on the 

16 range, I'm just trying to get a, you know, when I look 

17 at the data it's like, okay, this is typical, then 

18 it's any time it's significant. If this is the 

19 outlier on the high side then, okay, then maybe there 

20 is a chance, so again I'm just trying to interpret 

21 the table to make sure on the numbers -- I'm 

22 interpreting the numbers correctly, you know. 
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1 MR. YOUNG: Okay. 

2 MR. BROOKMAN: Additional thoughts here 

3 before we move on? Okay. 

4 MR. YOUNG: Okay, the next part I will go 

5 into will be the lifecycle cost and payback period 

6 analysis. This is the part that brings together the 

7 energy use part as well as the pricing and the 

8 engineering analysis components from previous 

9 analyses. The overall purpose of the LCC or 

10 lifecycle costs and payback period or PBP analysis is 

11 to provide an economic evaluation of potential 

12 standard levels from an end user's perspective. 

13 A lifecycle cost is the total cost to a 

14 consumer over the lifetime of the product, from 

15 purchasing the product through to the end of the 

16 product lifetime. 

17 The payback period is the time required 

18 for a consumer to recoup the additional cost of 

19 higher efficiency levels through reduced operating 

20 costs. 

21 There are several steps taken to create 

22 this analysis. The first is to create a sample of -- 
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1 or a group of 10,000 sample purchasers, or sample 

2 consumers. The second is to determine the total 

3 installed cost for each EL. Next is to determine the 

4 operating costs for the first year and the lifetime of 

5 the product. 

6 Next is to calculate the payback period by 

7 dividing the increases in the installed cost for 

8 each EL, by the average decrease in the first year 

9 operating cost. 

10 And the next is to calculate the LCC by 

11 adding the installed cost to the total lifetime cost 

12 and then to calculate the LCC savings by subtracting 

13 the LCC for each EL by the LCC of the EL that would 

14 have been purchased in the absence of the standard. 

15 So the first component is to determine the 

16 purchaser's sample and so DOE developed samples from 

17 respondents to the LBNL Study referred to earlier. 

18 DOE also estimated that the portions of purchases of 

19 cooled cabinets and the non-compressor refrigerators 

20 for each of the product types. 

21 So for cooled cabinets, DOE estimated that 

22 15% would be vapor compression and 85% would be 
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1 thermoelectric. For non-compressor refrigerators, 

2 DOE estimated that 90.5% would be thermoelectric 

3 and 9.5% would be absorption. 

4 Next was determining the total installed 

5 cost and so DOE estimated the baseline purchase price 

6 based upon the purchase price reported by respondents 

7 in the LBNL Study. DOE used a constant price trend 

8 to transform the reported baseline prices as well as 

9 the incremental prices from 2012 or 2013 dollars up 

10 to 2021, the value in the expected year of any 

11 potential standard. 

12 Sales tax was determined by geographic 

13 location for each of the purchasers. And then 

14 installation costs were also estimated from the LBNL 

15 Study but installation costs were assumed to not 

16 change with efficiency level. 

17 Next are the operating costs -- so DOE got 

18 the annual energy consumption from the energy use 

19 analysis. Energy prices were estimated from data 

20 based on EIA, Energy Information Administration or 

21 Agency. Repair and maintenance costs were estimated 

22 from values reported in the LBNL Study. They were 
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1 also assumed to not vary with efficiency level and 

2 DOE used a set of discount rates to discount the 

3 operating costs back to the year of purchase and they 

4 used the distribution of operating rates of typically 

5 for the asset and debt-classes that were typically 

6 used for purchasing appliances such as stocks, mutual 

7 funds, savings accounts, bonds and loans. 

8 Finally, DOE estimated the lifetime for 

9 products. So for cooled cabinets and non-compressor 

10 refrigerators, DOE fit the survival probability 

11 function to the age distribution reported in the LBNL 

12 Study. For other products DOE estimated that the 

13 lifetime would be similar to refrigeration products 

14 to other similar refrigeration products as reported 

15 in the 2011 final rule for refrigerator-freezers. So 

16 these show all the estimated mean values of 

17 lifetimes. 

18 And finally, DOE estimated the base case 

19 distribution of EL's as we use the EL's that 

20 consumers would purchase if there were no standard 

21 distribution of those and these are based upon the -- 

22 or the same as the efficiency market shares indicated 
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1 in energy use analysis. 

2 So that's the end of the inputs to the LCC 

3 and so are there any questions about the inputs 

4 before I go into the results of the LCC analysis? 

5 Okay, I'll move on. So the results from the LCC 

6 analysis -- we don't have all the results in the 

7 presentation because there are many tables but I do 

8 have the results from one particular product class 

9 and I can go through and identify what is in there 

10 and if people have questions about what is in there 

11 and how to interpret it then I can explain. 

12 You can see the rest of the results in the 

13 TSD. So first are the tables for each product class 

14 are results based upon the assumption that all of the 

15 sampled consumers purchased the same EL's so this 

16 goes to a set of columns first about the LCC, 

17 including the installed cost, the first year 

18 operating cost, the lifetime operating cost and the 

19 total LCC, yes? 

20 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

21 Again, I was going back to your shipment data that you 

22 showed, the efficiency and the market share, EL-0 had 
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1 an approximate market share of about 6% based on your, 

2 I'll say, your shipment data and your data bases. 

3 MR. YOUNG: Yes. 

4 MR. ROSENSTOCK: So this is really kind of 

5 the -- I'll say the worst case efficiency scenario 

6 where it's only about 6% of consumers are going to 

7 see this. All of the other consumers are going to be 

8 like at EL-2 or EL-3 or I think you said before the 

9 de-facto standard right now is EL-4 because of the 

10 California Energy Commission standard so the numbers 

11 on the far right columns except for the lifetime, 

12 those well -- the payback especially will change 

13 quite dramatically as you go down the EL's, as you go 

14 through your analysis, that the weighted average, the 

15 final numbers in the proposed rule are going to be 

16 quite a bit different because they are not all going 

17 to use EL-0 as a baseline right? 

18 MR. YOUNG: Yes, so the overall idea is 

19 that, in this case, this is calculated as we take all 

20 the sample consumers and we assume that they all buy 

21 EL-0 or they all buy EL-1, they all buy EL-2 and 

22 these are the values that would actually come out in 
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1 that case and that's not -- that isn't the actual -- 

2 what would actually happen in the market but that is 

3 just showing them so that you can see all of these 

4 values on a standard level playing field. Does that 

5 make sense? 

6 MR. ROSENSTOCK: Steve Rosenstock, EEI, 

7 yeah, that makes a lot of sense but, again, I guess for 

8 the final analysis that, you know, I'll say EL-2, 3 or 

9 4 is really more of a true baseline to do the energy 

10 savings and the economic analysis that is really 

11 going to the savings -- the reason I mention is that 

12 the savings are going to be quite dramatically a bit 

13 lower if you started, especially like at EL-4 

14 compared to EL-1 or 0. I mean it's strikingly 

15 dramatic. 

16 MR. YOUNG: Yeah, and actually, that's a 

17 very good point and I think if you just hold on to it 

18 until the next slide, it will really come clear after 

19 that. So yeah, so we go through that, the LCC 

20 components and then there's the simple payback period 

21 and that's placed relative to the average lifetime so 

22 people can see the payback relative to the size of 
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1 the lifetime. 

2 So the next slide comes into I think what 

3 Steve was mentioning here is that this talks about 

4 the actual LCC savings that might occur in the market 

5 so we have a column of the percentage of consumers 

6 that have experienced a net cost and the average 

7 lifecycle cost savings and these are calculated using 

8 those base case distributions that you alluded to 

9 that we talked about earlier -- identifying what DOE's 

10 best estimate of where people would purchase their 

11 products in the future or in the absence of a 

12 standard and then placing [a] standard at each of 

13 these given EL levels and then assuming that anyone 

14 who is at an EL level that is lower than the 

15 candidate level for a standard would move up to the 

16 level of the standard. 

17 So in that case, say, that there were people 

18 -- a standard was placed at EL-2, then in that case, 

19 any of the people who would have purchased EL-0 or 

20 would have purchased EL-1 are assumed to now 

21 purchase EL-2 and as a result they -- any savings or 

22 loss that they received as a result of that is 
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1 reflected here and so does that make sense? Okay, 

2 yeah, and so -- go ahead? 

3 MR. ROSENSTOCK: Steve Rosenstock, yes. 

4 MR. YOUNG: Okay, good. And as you can 

5 see, then, there indicates also the distribution, the 

6 number of people that actually have a loss as a 

7 result of that change to the standard as well as the 

8 average lifecycle cost, any questions on this up to 

9 this point? 

10 And so the final slide I wanted to bring 

11 out is just to highlight that each of these, the 

12 numbers that are shown in the table, all the 

13 averages, the averages of a distribution of values 

14 and so each of these are based upon a distribution 

15 and so this would be the distribution of values for 

16 the lifecycle cost savings for EL-5 on the previous 

17 slide and so you can see the average value at about 

18 $39.00, which is what you can see in the table, but 

19 you can see that that comes from a distribution of 

20 values that goes from below zero which is people who 

21 actually have an extra cost as a result of that 

22 standard, up to people who save over $180.00. 
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1 MR. BROOKMAN: Joanna Mauer has a comment, 

2 Joanna, please speak. 

3 MS. MAURER: So I had a question related 

4 to the assumed lifetime for cooled cabinets. We don't 

5 have any information on the lifetime of cooled 

6 cabinets, but the 4.3 years assumed as average 

7 lifetime seems low to us. I was just wondering, if 

8 you could say anything more about how you came up 

9 with that estimate? 

10 MR. YOUNG: Sure yes, thank you very much 

11 for the question. And yeah, definitely, that is one 

12 thing where there is not a lot of data on and right 

13 after this slide that I was just on we have a request 

14 for comment, including asking for data on that 

15 information and so how the 4.3 came from. This came 

16 from that LBNL Study, which asked people who owned 

17 these products how old their product was and so 

18 people reported how old the cooled cabinet that they 

19 had in their house was and based upon that and then 

20 using an assumption that shipments were flat -- were 

21 constant in the past--then that developed that sort 

22 of distribution. 
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1 And so if any of those assumptions are 

2 inaccurate then that could change that so if 

3 shipments had increased recently for any reason 

4 perhaps that could have an effect on it or if, yeah, 

5 or if the people who reported answers are not 

6 representative of all of the consumers I expect to be 

7 another reason for the difference. 

8 DOE is also very willing to get any 

9 additional information because if there is any 

10 additional information on typical lifetimes for 

11 cooled cabinets and non-compressor refrigerators, it 

12 would be very useful for the analysis. Does anyone 

13 here have any information on that? 

14 Okay, so that's the end of the results and 

15 so this brings us to issue box 11, are additional 

16 data available on the historical current or projected 

17 future stock, shipments or lifetimes of cooled 

18 cabinets, non-compressor refrigerators, ice makers or 

19 hybrid products? Much of this information there is 

20 limited data on [these products] and so any information that

21 is 

22 available DOE would welcome. 
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1 So that's the end of these sections, so my 

2 colleague Hung-Chia Yang will come up and do the next 

3 two sections. 

4 MS. YANG: Hello, everyone my name is 

5 Hung-Chia Yang from Lawrence Berkeley National 

6 Laboratory and next I will be presenting the shipment 

7 analysis that DOE conducted to project the future 

8 product shipment and the result from this analysis 

9 serves as an important input for the National Impact 

10 Analysis, which I will present momentarily. 

11 So the purpose of the shipment analysis is 

12 to estimate the current and the projected future 

13 shipments for each product and, most importantly, DOE 

14 reviews the shipment analysis to estimate the impact 

15 of [a] new standard on future shipments. Since the 

16 data on the historical shipments were 

17 very limited, DOE mainly estimated the 2012 

18 shipments based on the LBNL Study. 

19 And the shipments projection[s] are divided 

20 into new construction and replacement markets and the 

21 shipments to hotels were also considered but only for 

22 absorption refrigerators only because 75% of those 
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1 products are believed to be found in hotels. 

2 The impact of new standards on 

3 future shipments were projected using the price 

4 elasticity. And the first part of the shipment 

5 analysis is the base case shipment projections, which 

6 depict the situation where new standards are not 

7 adopted. And shipments in 2012 were derived by 

8 dividing the estimated stock by the mean estimated 

9 product lifetime. 

10 And the shipment projections in new 

11 construction markets were derived by multiplying new 

12 housing starts from an AEO 2014 study by the 

13 household saturation. DOE estimated those household 

14 saturations based on the LBNL Study and assumed that 

15 the household saturation of MREF products would 

16 remain constant throughout the analysis period. 

17 And the shipments for replacement market 

18 would account for the balance of the shipments. And 

19 this table summarizes the saturation of each product 

20 in the U.S. household base on the LBNL Study. 

21 Does anyone have any questions so far? 

22 MR. BROOKMAN: Steve Rosenstock? 
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1 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

2 In the study, how many households were surveyed in the 

3 study? I'm just kind of curious if you know, I know 

4 with RECS they do a sample of 5,000 homes, 5,000 or 

5 6,000 homes, and I'm just kind of curious what kind 

6 of sample size was used for this study? 

7 MS. YANG: So LBNL conducted a separate 

8 study for each of the product type. For example for 

9 the cooled cabinets estimates, the 

10 survey was targeting the cooled cabinet households 

11 owners, which we have a sample size of more than 

12 2,000 households. 

13 MR. ROSENSTOCK: Thank you. 

14 MS. YANG: And this table summarized the 

15 base case shipments that we estimated and the second 

16 column is the estimated 2012 shipments and the third 

17 column is the estimated 2050 shipments, which is the 

18 last year of our analysis period. 

19 And the second part of the shipment 

20 analysis is to look at this impact of standards on 

21 shipments. So the standard case projection used the 

22 purchase price increases and the operating cost 
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1 savings to estimate shipment impacts. And the 

2 price elasticity factor derived from 

3 a literature review of household appliances 

4 were used to determine if the shipments were 

5 decreased due to the increased purchase price and also 

6 the magnitude of those impacts. 

7 And DOE found cooled cabinet shipments would 

8 decrease if the standard would use EL-5 and higher. 

9 However, for other products, DOE found no impacts of 

10 new standards on shipments. And here is -- sorry, you 

11 have a question? Okay, so here is the issue box and 

12 DOE is requesting for comment [on] whether there are 

13 additional data available on the historical current 

14 and the projected future stock shipments and 

15 lifetime for MREF products. 

16 MR. BROOKMAN: Steve? 

17 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

18 Going back to the estimated shipments slide 91, I 

19 guess I'm kind of curious why the increase for some 

20 of them seems to be around, I'll say, the 50% range 

21 between 2012 and 2050 but then for the first two 

22 categories, it's nearly doubling or in the 
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1 non-compressor it's almost quadrupling and I'm just 

2 trying to get a sense of what factors are making 

3 those shipments rise so much higher than the other 

4 products, the other product categories? 

5 MS. YANG: Certainly, for the cool cabinet 

6 and the non-compressor -- 

7 MR. ROSENSTOCK: The delta between the 

8 2012 and 2050 seems so much higher than the other 

9 ones I'm just kind of curious what are the factors, 

10 you know, because the same number of new homes, and 

11 same number of, I'll say, renovated homes are 

12 replacement, what factors are driving their numbers 

13 so much higher as a percentage increase over the time 

14 period? 

15 MS. YANG: So this number was basically 

16 based on the total household units, which is the 

17 current plus the new housing so the reason that 

18 contributes to the big increase that would probably be 

19 the change of housing, the number of housing. 

20 MR. ROSENSTOCK: Okay, Steve Rosenstock, 

21 EEI. I'm just kind of -- I'm just surprised that 

22 there is so much of a difference between all of these 
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1 products, these are kind of, I'll say, secondary 

2 products in the home and I'm just surprised at the 

3 delta of the first two compared to some of the other 

4 ones, that's all -- just an observation, thank you. 

5 MR. BROOKMAN: Charlie Hon? 

6 MR. HON: Charlie Hon, True Manufacturing. 

7 There are also issues in these categories as far as 

8 economics -- the higher of the value of the home the 

9 greater the chances of installing these types of 

10 equipment. In a small home, you will have a 

11 refrigerator and no other additional refrigeration 

12 systems. The bigger the home, the more likely you 

13 are to put in these additionals whether it be behind 

14 the bar, on the patio, you name it, it's going in 

15 there. 

16 MS. YANG: Um-hmm, thank you for the 

17 comment. So far, we haven't considered that 

18 the difference in household size would affect the 

19 value of the saturation rate of the product, thank 

20 you for the comment. 

21 Now, we move on to the national impact 

22 analysis. So DOE conducted the national impact 
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1 analysis to assess the national level impact at each 

2 efficiency level as measured by national energy 

3 saving and net present value of total consumer 

4 economic impact. And DOE used the shipping model to 

5 estimate the total stock of each MREF product 

6 and DOE then aggregate[d] the cost and energy used per 

7 unit in each year. 

8 A difference between the base case and the 

9 standard case in each year will give us the national 

10 energy saving and the net present value of consumer 

11 economic impact. DOE also accounts for the time 

12 value of money through defined discount rates, which 

13 are 3% and 7% when calculating the net present 

14 value. 

15 And here is a simplified illustration 

16 showing how a national impact analysis process would look 

17 like. So from the LCC and the shipment analysis, DOE 

18 are able to derive the national energy savings and 

19 also the national net present value of economic 

20 impact. And those national energy savings and the 

21 net present value of economic impact were calculated 

22 for every product shipped over the period from 2021 
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1 to 2050 that covered thirty years of projection 

2 period. 

3 And this diagram shows how the national 

4 energy savings were actually calculated in the 

5 analysis. So in the shipment analysis, DOE are able 

6 to calculate the base case and standards case shipment 

7 projections from 2021 to 2050 and by multiplying the 

8 shipments with the energy use per unit derived from 

9 the energy use analysis, DOE are able to estimate the 

10 base case cumulative energy use and also the standard 

11 case cumulative energy use. 

12 And then DOE apply a conversion factor to 

13 account for energy consumed during the extracting 

14 processing and transporting of the primary fuel. And 

15 the difference between the base case and standard case 

16 will be the national energy savings. 

17 The next diagram will show how the 

18 national consumer new present value was calculated. 

19 Similarly, the base case and standard case shipment 

20 projections were estimated in the shipment analysis 

21 and from the energy analysis DOE got the 

22 operating cost per unit including energy cost, the 
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1 maintenance and the repair cost and from the LCC 

2 analysis data we will also be able to get the 

3 equipment cost estimated per unit. 

4 So by taking the difference between the 

5 base case and the standard case to derive the 

6 cumulative operating cost of savings and the 

7 cumulative of total equipment cost increase. By 

8 discounting those two values to the present year, 

9 which is 2014, you were able to get the net present 

10 value of the total economic impact. 

11 And here is the list of the inputs that we 

12 use in our national impact analysis and each of these 

13 were output from the many analyses that we mentioned 

14 earlier. And this table summarizes national energy 

15 savings results for each MREF product and, as you 

16 can see, the energy -- the national energy savings 

17 goes up when you move up the efficiency level. 

18 Questions? 

19 And this table shows the cumulative net 

20 present value result by using a 3% discount rate. 

21 And the next table shows the cumulative net present 

22 value by using a 7% discount rate. As you can see, 
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1 the hybrid product is not included and the net 

2 present value result as the absence of the cost 

3 efficiency curve for those products prevents DOE from 

4 estimating the net present value for them. 

5 Is there any questions or comments? I 

6 think that's the end of my presentation thank you. 

7 MR. BROOKMAN: Thank you, move on to MIA. 

8 MS. BUCCITELLI: I'm Nicole Buccitelli 

9 from Navigant and I'm going to be talking about the 

10 manufacturer impact analysis. At this point, this 

11 analysis is in its very initial stages. This is the 

12 section of the DOE downstream analysis that deals 

13 with the economic impacts on manufacturers of new or 

14 amended standards. 

15 And during this analysis, DOE identifies 

16 and estimates impacts on manufacturer sub-groups that 

17 may be disproportionately affected by standards and 

18 during MIA direct impacts on direct employment, 

19 competition within the industry, manufacturing 

20 capacity and cumulative regulatory burdens are also 

21 analyzed. 

22 The core methodology used on MIA are the 
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1 government regulatory impact model, also known as the 

2 GRIM and manufacturer interviews. The GRIM is used 

3 to analyze industry cash flows and the main output is 

4 industry net present value and manufacturer 

5 interviews are used to refine the inputs for the GRIM 

6 as well as devote the sub-group analysis and address 

7 more equality of the issues. 

8 So there are three main phases to the 

9 manufacturer impact analysis. The first being DOE 

10 conducts some initial market research and creates an 

11 industry profile to characterize the industry and 

12 also to identify important issues that require 

13 investigation during interviews. 

14 The second phase is the phase in which DOE 

15 prepares the government, the GRIM model, as a 

16 framework for analyzing industry cash flows and also 

17 prepares an interview guide which will guide the 

18 discussions with manufacturers. 

19 In phase three, DOE interviews 

20 manufacturers and assesses both the quantitative and 

21 qualitative impacts and so you could see at the 

22 bottom there's a little diagram; were essentially 
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1 done with phase one at this point. We have conducted 

2 preliminary manufacturer interviews but the main meat 

3 of inputs for the MIA will come with the NOPR phase 

4 manufacturer interviews, which we will plan on 

5 contacting manufacturers about in the next few 

6 weeks. 

7 During preliminary interviews, there are 

8 some -- a few key issues identified by manufacturers 

9 that we will plan on investigating further during the 

10 NOPR phase interviews. The first one being the 

11 timing of these standards relative to the 2014 energy 

12 conservation standards for refrigerators and 

13 freezers, the impacts of higher selling prices, 

14 impacts on consumer utility, conversion costs and 

15 disproportionate impacts on small businesses. That's 

16 it, any questions? Okay. 

17 MR. YOUNG: All right, Scott Young from 

18 Lawrence Berkeley National Laboratory again. I will 

19 finish up with the analysis that will be 

20 completed at the notice of proposed rulemaking phase. 

21 So following the preliminary analysis, there will be a 

22 notice of proposed rulemaking and in order to do that 
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1 there are several steps to the analysis. 

2 First is to revise the analyses that were 

3 done in the preliminary analysis and these are the 

4 analyses which we have discussed today. And then 

5 there will be a number of additional analyses that 

6 will be performed. First will be the LCC sub-group 

7 analysis and that involves similar to the LCC but 

8 focusing largely on consumer sub-groups that might be 

9 disproportionately impacted by a new standard on 

10 products. 

11 The next is, as Nicole just mentioned, the 

12 manufacturer impact analysis. Following that are the 

13 emissions and the emissions monetization analyses 

14 that assess how standards might affect emissions of 

15 air-borne pollutants. After that, there is also the 

16 utility impact analysis looking at how the standards 

17 could affect electric utilities. 

18 And the employment impact analysis looking 

19 at possible indirect impacts on national employment 

20 due to a standard and finally the regulatory impact 

21 analysis looking at potential other avenues that the 

22 government could take other than standards to achieve 
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1 similar energy savings and also a reduction, or 

2 economic impact. 

3 MR. BROOKMAN: Steve Rosenstock? 

4 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

5 For the emissions analysis and the utility impact 

6 analysis, are there plans to run at least a 

7 sensitivity analysis for the impact of the EPA Clean 

8 Power Plan, which will be under the current schedule, 

9 the rule gets announced this summer and states start 

10 doing their implementation plans either next year or 

11 the year after, but basically, it's full 

12 implementation by 2020? 

13 MR. YOUNG: That's a good question and I'm 

14 not actually sure on that. You know, I don't know. I 

15 have to take a look into that and I'm just not sure 

16 exactly how would that sensitivity how would that 

17 affect, or how would the standards affect that or how 

18 would that affect the standard? 

19 MR. ROSENSTOCK: Well, it would affect the 

20 standards in terms of the fact that the generation 

21 fee which could change over quite dramatically to 

22 meet the -- right now it's a 30% reduction target by 
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1 2030 so that's well within the time frame of this 

2 analysis and I don't think any of that was really -- 

3 I know the mercury rule was announced a couple of 

4 years ago so it might be incorporated in the AEO 2014 

5 for EIA but [the] clean power plan, really, that was 

6 announced last September after AEO came out with 2014 

7 so it's not going to be in any of their projections 

8 at all in terms of electric generation or emissions. 

9 MR. YOUNG: And at that time it would be 

10 -- by the time it was done likely AEO 2015 might be 

11 out and it might be reflected in that possibly, they 

12 do definitely rely on information from the EIA for 

13 that so if it's in that, then yes. 

14 MR. HON: This is Charlie Hon. Now that 

15 we are starting to get to the end of this special 

16 analysis, there is a major rule which has been 

17 proposed by the EPA SNAP group would remove the use 

18 of 134A and 404A as refrigerants. Preliminary rule 

19 said by 2016 in reality -- we know that's probably 

20 much more aggressive than the final rule will be. 

21 The final rule is tentatively coming out late first 

22 quarter of this year. 
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1 And that means re-engineering of almost 

2 every product as far as made for compression 

3 refrigeration system, and has any consideration been 

4 made into those areas? 

5 MR. MOUW: This is Nate from Whirlpool. 

6 Maybe to add to that, or perhaps request that we 

7 clarify for residential refrigeration products, my 

8 understanding is that there is no proposal for a ban 

9 or a limit on use of refrigerants. It's certainly -- 

10 I believe its commercial-only for refrigerants, 

11 certainly residential is impacted by the proposal to 

12 ban the specific blowing agents or foam, blown foam, 

13 that's my understanding. 

14 MR. BROOKMAN: Thank you Nate, Michael 

15 Kido? 

16 MR. KIDO: I guess this is in response to 

17 Charlie's question. Essentially my understanding is 

18 that the process that we would apply when we are looking at 

19 sister agency regulations is that we will take into 

20 account those regulations that have been adopted. 

21 Whether there is room for additional 

22 sensitivity, you know, we will look into it but 
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1 generally the practice is you can't really speculate 

2 what it is that an agency, a sister agency, is going 

3 to end up with. You might have proposals right now 

4 at EPA but it's possible there may be changes to what 

5 they end up adopting versus what they actually 

6 proposed. 

7 MR. BROOKMAN: Steve? 

8 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

9 But again, I know it will be an extra effort but 

10 that's the reason for a sensitivity analysis. If 

11 there's a proposed rule out there then there might be 

12 a way to get some feedback from either manufacturers 

13 or other parties to say okay we think that again, 

14 based on this proposed rule here is the impact of this 

15 proposed rule on the efficiency standards that DOE is 

16 thinking about doing. 

17 MR. KIDO: Like I said, Steve, we will look 

18 into it. 

19 MR. BROOKMAN: Okay, thank you. 

20 MR. YOUNG: Okay, these are all the 

21 additional analyses, any other questions on the 

22 additional analyses? Okay, that's the end of my 
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1 section here. 

2 MR. BROOKMAN: Okay, so now we are to 

3 closing remarks and an opportunity for anybody that 

4 wishes to make remarks here at the end of the 

5 meeting. Summary statements, issues that you wish to 

6 bring to the floor, haven't been covered sufficiently 

7 to date at this time. Charlie Hon? 

8 MR. HON: Charlie Hon. I have one final 

9 comment. We have -- there's been lots of different 

10 market sectors discussed here, some of which had good 

11 data, some of which were very limited data 

12 availability, some of which used factors where the 

13 baseline factor's lowest point is 65, which would 

14 mean we would be starting by reducing the energy 

15 consumption allowable by 35% below the California 

16 Energy Commission and then dropping down from there 

17 fairly quickly, and so our concern is, do we really 

18 know -- there were assumptions made that everything 

19 in the United States met CEC. And that's an 

20 assumption that I cannot accept because, legally, there 

21 are plenty of other places that it is legal to sell 

22 these products. 
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1 And assuming that they are never sold 

2 elsewhere is a very, very big step so I think we need 

3 to get some information. Are there less efficient 

4 products, starting with a 35% reduction is baseline, 

5 that's an aggressive step to start with. It's a 

6 doable step. I understand the market well enough to 

7 know that 35% can be done, but when you get into 

8 specialty products the payback period for 

9 manufacturers, because they are fairly low volume, 

10 become more and more difficult. 

11 MR. BROOKMAN: Okay, thank you Charlie. 

12 MR. HAGERMAN: Joe Hagerman, DOE. So 

13 thank you so much for your comments. It would also 

14 be very helpful if you would submit that as a written 

15 comment too. 

16 MR. BROOKMAN: Additional comments here as 

17 we move towards the end of the meeting? Okay, so then 

18 for my part I'll thank you all, we had a very 

19 productive meeting. I really appreciate all of your 

20 participation here I'm going to turn it back to Joe 

21 Hagerman for closing remarks. 

22 MR. HAGERMAN: I just want to share that 
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1 and hear that we appreciate your participation today 

2 and yesterday too if you were here and just as a 

3 reminder the comment period for the standard that we 

4 discussed today is February 2nd, so we look forward 

5 to your written comments. 

6 And then the comment period closes for the 

7 test procedures on March 2nd, those are two very 

8 important dates and I urge you not to wait until the 

9 last minute because sometimes people have trouble 

10 submitting the comments. 

11 Also just a note to that -- whenever you 

12 submit comments put it through the system and also 

13 email Brenda Edwards so thank you. 

14 (Whereupon meeting was adjourned at 12:10 

15 p.m.) 

16 

17

18

19

20

21

22
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A

a.m 77:16

ability 21:3

able 6:21 11:4 16:16

57:22 74:16 91:6

109:18 110:5,9

111:2,9

absence 93:14 99:11

112:2

absolutely 86:17

absorption 17:12,19

18:8,10,11 20:6,9

21:10 82:10 83:19

94:3 103:22

AC 8:21 14:11

accept 120:20

access 70:13

account 66:6 67:14

68:1 104:18

110:13 118:20

accounts 95:7

109:11

accurate 64:19

Acharya 2:7 4:9,9

achieve 14:8 19:17

115:22

achieved 26:13

34:14

achieving 42:1,8

activities 3:14

actual 33:3 49:4

98:1 99:4

add 15:9 68:14

118:6

added 73:8 89:4

adders 61:18

adding 93:11

addition 19:15

79:11

additional 6:22 16:9

19:13 21:19,21

24:5 25:1 29:8

35:19 38:14 39:21

40:19 50:12 51:5

52:4 55:5 56:15

56:22 58:8 76:6

76:15 83:15 88:22

90:8 92:2,18

102:9,10,15

106:13 108:11

115:5 118:21

119:21,22 121:16

Additionally 24:14

additionals 108:13

address 16:16 113:6

addressed 36:21

addresses 49:20

addressing 57:6

adequate 35:15

adjourned 122:14

adjusted 71:4

adjustment 58:13

58:18,19 59:4,8

59:19 60:5,11

70:22 72:18

Administration

94:20

adopted 104:7

118:20

adopting 58:22

119:5

advance 8:9 9:7,20

37:6 78:8

adverse 37:14,15

AEO 104:12 117:4

117:6,10

affect 41:18 43:21

108:18 115:14,17

116:17,17,18,19

affiliation 4:3

afraid 82:18

age 95:11

agency 94:21

118:19 119:2,2

agenda 5:12

agents 118:12

aggregate[d 109:6

aggressive 117:20

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publicly-available

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rapidly 57:10

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regard 30:16 50:21

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regulations 9:3

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relationship 41:2

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remarks 3:9 5:14

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remember 28:18

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reminder 7:1 122:3

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repair 94:21 111:1

repeats 11:16

replacement 103:20

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replenish 85:8,8

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reports 43:12

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return 16:3 76:18

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reverse 36:10 41:16

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rule 3:13,15,20

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running 21:13

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sample 92:22 93:1,1

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sampled 96:15

samples 93:16

saturation 104:13

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saturations 104:14

save 100:22

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savings 82:20 83:2

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saying 20:16 33:3

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scatter 52:22

scenario 85:1 97:5

schedule 8:14 116:8

scope 12:4

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screened 37:9,11,12

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screening 5:18 11:8

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seat 78:7

SEC 43:12

second 21:10 27:15

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secondary 108:1

secondly 64:13,17

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section 35:19 66:15

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sectors 120:10

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segregations 25:15

seldom 20:11

selected 42:3

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sending 7:4

sense 85:12,22 87:2

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set 13:6 14:1 72:2

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setting 13:5 15:15

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settings 33:1,5

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single 9:15 15:19

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situation 104:6

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sized 23:17

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sold 46:21 47:12

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solid 72:15 73:6

Solutions 2:3 3:8

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somewhat 54:12

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storing 26:15,16

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strategically 56:9

strikingly 98:14

stringent 71:10,11

structure 24:12

studies 88:16

study 81:4,5,6,7

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style 14:4

sub-bullets 23:3

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subject 22:20 46:18

submit 121:14

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substantial 65:17

subtracting 93:12

succeed 77:3

successful 6:18

sudden 75:12

sufficiently 120:6

suggest 60:9

suggested 76:11

suggesting 69:18

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suggests 17:20

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suitable 38:1

summarize 31:10

summarized 105:14

summarizes 104:19

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summary 5:14 7:15

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summer 10:16

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sump 27:22

supplied 28:13

suppliers 12:8

supply 28:11

support 5:2 12:13

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sure 16:14 33:18

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90:12 91:21

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surface 27:21 68:6

surprised 107:21

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surrounding 7:5

survey 79:4 105:10

surveyed 105:2

surveys 81:4

survival 95:10

suspect 53:12,14

suspicious 38:18

SW 1:10

system 14:4,20

27:19 36:17 50:6

54:17 73:11,18

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systems 15:2 20:8

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T's 21:12

table 24:1 25:3

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tables 73:1 96:7,13

take 6:1,1 37:3 68:1

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taken 77:15 92:21

talk 3:17 10:17,22

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talked 13:17 14:1

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talking 14:15 40:22

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tank 20:9

target 19:18 56:10

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targeting 105:10

tax 79:21 94:12

tech 62:7

technical 5:6 12:12

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technologies 2:5

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terminology 14:5

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54:22

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20:22 56:19

thickness 72:9

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65:19 69:6 71:12

87:1 101:12

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19:8,12 25:21

30:9 34:21 35:16

36:1 37:21 38:2

40:12,14 46:6,19

49:20 52:12 57:5

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66:7 69:11 80:8,8

87:13 88:7 91:10

97:8 98:17 99:2

112:6 117:2

119:13 121:2

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70:17 73:7 105:16

thirty 110:1

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39:21 55:5 59:1

60:13 61:4 67:5

92:2

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70:8 113:8,19

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21:5 30:2 57:12

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93:2,11 94:4

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28:16,17,19,20

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101:11 102:4

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28:18 29:8 30:4,9

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103:17 104:7

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139 

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