Date: March 18, 2015

Case: The Portable Air Conditioners Test Procedure Meeting

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The Portable Air Conditioners Test Procedure Meeting

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 U.S. DEPARTMENT OF ENERGY PUBLIC MEETING 

THE PORTABLE AIR CONDITIONERS TEST PROCEDURE MEETING 

 U.S. Department of Energy 

 1000 Independence Avenue, SW 

 Washington, DC 20585 

 Room No. 8E-089 

 Wednesday, March 18, 2015 

 9:00 a.m. 
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1 Appearances for Department of Energy Meeting: 

2

3 Doug Brookman, Public Solutions, -- Moderator 

4 Bryan Berringer, DOE 

5 Sarah Butler, DOE 

6 John Cymbalsky, DOE 

7 Ashley Armstrong, DOE 

8 Steven Goering, DOE 

9 Alberto Aloisi, DeLonghi Appliances 

10 Stefano Vit, DeLonghi Appliances 

11 Michael Prager, DeLonghi America, Inc. 

12 Martin L. Besant, Electrolux Major Appliances North 

13 America 

14 Nicole Buccitelli, Navigant 

15 Judith Reich, Navigant 

16 Nadav Singerman, Navigant 

17 Troy Watson, Navigant Consulting 

18 Jim Crawford, HVAC Regulatory Consultant 

19 Camilla Dunham, Lawrence Berkeley National Laboratory 

20

21 Chun Chun Ni, Lawrence Berkeley National Laboratory 

22 Jennifer Cleary, AHAM 
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1 APPEARANCES (CONTINUED): 

2

3 John A. Hodges, Wiley Rein LLP 

4 Sang Lee, DENSO Products and Services Americas, Inc. 

5 Joanna Mauer, ASAP, Appliance Standards Awareness 

6 Project 

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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

2 (9:00 a.m.) 

3 MR. BROOKMAN: Welcome. This is the public 

4 meeting on portable air conditioners, both test 

5 procedures and energy conservation standards. Today 

6 is March 18th, 2015 here at the Department of Energy 

7 in Washington, D.C. My name is Doug Brookman, Public 

8 Solutions, Baltimore. Nice to see you this morning. 

9 We are going to start with welcoming remarks from 

10 Bryan Berringer. 

11 MR. BERRINGER: Yes, good morning and 

12 welcome everybody and everybody on the webinar. We 

13 appreciate your space in the day. We are going to 

14 basically -- we'll talk about this morning the test 

15 procedure section. We are going to work through. If 

16 we get ahead of schedule, we will continue into the 

17 standards rulemaking. It will be considered two 

18 separate document rulemakings, but we will -- again if we 

19 get behind schedule, if we get ahead of schedule 

20 continue with standards as we move on, so it will be 

21 a continuous meeting. 

22 We will take a time for a lunch break so 
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1 everybody has that in there, so we will do that. 

2 Again, this is a new product as far as regulations and 

3 test procedures, so part of the discussion is going to 

4 be developing the test procedure and this afternoon 

5 doing the standards and Ron Majette will be the 

6 project manager on the standards and I am again the 

7 primary contact on the test procedures. 

8 And that you, we want to hear your 

9 discussions and we especially want to hear your 

10 feedback, so that is what this is about to make sure 

11 that we have the right test procedure, and something 

12 that makes sense, something that is repeatable and 

13 reliable and that, you know, we can feel we have a good 

14 product and again thank you. 

15 MR. BROOKMAN: Thank you. I see a few new 

16 faces in the room. We welcome you especially. We 

17 always start with introductions here at the outset. 

18 I'll start to my immediate left. You can get used to 

19 turning the microphone both on and off and getting 

20 close to your face. Please say your name and 

21 organizational affiliation, and I'll start with Jim. 

22 MR. CRAWFORD: Jim Crawford, consultant. 
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1 I am here on behalf of Denso. 

2 MR. LEE: Sang Lee from DENSO. 

3 MR. HODGES: John Hodges, Wiley Rein. 

4 MR. PRAGER: Mike Prager, I'm the head of 

5 the DeLonghi business in North America. 

6 MR. ALOISI: Alberto Aloisi from De'Longhi 

7 Appliances, Italy. 

8 MR. VIT: Stefano Vit from De'Longhi 

9 Appliances, Italy. 

10 MS. CLEARY: Jennifer Cleary with the 

11 Association of Home Appliance Manufacturers. 

12 MS. MAUER: Joanna Mauer of Appliance 

13 Standards Awareness Project. 

14 MR. SINGERMAN: Nadav Singerman, 

15 with Navigant Consulting. 

16 MS. BUTLER: Sarah Butler, DOE. 

17 MR. CYMBALSKY: John Cymbalsky, DOE. 

18 MS. ARMSTRONG: Ashley Armstrong, DOE. 

19 MR. WATSON: Troy Watson with Navigant. 

20 MS. REICH: Judith Reich from Navigant. 

21 MS. BUCCITELLI: Nicole Buccitelli from 

22 Navigant. 
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1 MR. BROOKMAN: And if you please just 

2 stand and speak loudly, we don't need the microphone. 

3 Yes please, stand and speak loudly. 

4 MS. NI: Chun Chun Ni from LBNL. 

5 MS. DUNHAM: Camilla Dunham, LBNL. 

6 MR. BESANT: Mark Besant, Electrolux. 

7 MR. GOERING: Steve Goering, DOE. 

8 MR. BROOKMAN: Again, thanks to all of you 

9 and thanks to those joining us via the web. More 

10 instructions on web participation in just a moment. 

11 All of you received a packet of information I 

12 hope as you came into the room. There's an agenda on 

13 slide page number 3. I will do a very brief review. 

14 Immediately following these introductory slides, 

15 there is an opportunity for anybody that wishes to 

16 make brief opening remarks, opening statements here 

17 at the outset of the key issues from your 

18 perspective. 

19 Moving on from there, we will hear, as 

20 reflected on the agenda, on regulatory history, then 

21 covered products and test procedure proposals. We 

22 will take a break mid-morning round about 10:45 - 
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1 11:00 or so. Moving on from there a discussion and 

2 presentation on compliance. After that, whenever we 

3 get to that place in the content in the slides 

4 provided is yet another opportunity for comments to 

5 make sure that you get a chance to say everything you 

6 wish to say before we move off of the test procedure 

7 segment of this meeting. 

8 As Bryan said we will move directly, if we 

9 get ahead of schedule, into the standards portion of 

10 this meeting. Two meetings today running continuous, 

11 test procedures then standards. However, whenever we 

12 get to a lunch break, roundabout noon, we will take 

13 lunch, okay? So don't be worried about that, but 

14 then whenever we get there we will take up standards. 

15 We will start with an introduction to standards. 

16 There will be another opportunity to comment, brief 

17 summary remarks here at the outset, and then 

18 proceeding, market and technology assessment and 

19 screening, excuse me, engineering analysis then the 

20 manufacturing analysis, markups and energy use 

21 analysis, lifecycle costs and payback period 

22 analysis, shipments and national impact analysis. 
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1 Review NOPR analyses and next steps, and 

2 yet again at the end of the day, whenever we get there, 

3 an opportunity for closing comments, again an 

4 opportunity for anybody to cover any additional 

5 issues that haven't been covered sufficiently. 

6 That's the plan for today. Any questions and comments 

7 on the agenda? Seeing none, I would also ask for your 

8 consideration to make this meeting work well, and 

9 there are some suggested ground rules on the second 

10 slide in your packet. 

11 If you would speak one at a time and if 

12 you would please say your name each time you speak. 

13 We have a new court reporter with us today and she is 

14 not used to this format and this content all that 

15 much. So if you could say your name each time you 

16 speak, that would be very, very helpful. 

17 There will be a complete transcript of 

18 this meeting made available if you could be concise, 

19 share the air time, keep the focus here. If your 

20 cell phones aren't on silent mode, and I'm reminding 

21 myself that I should do mine as well, please turn it 

22 on silent mode if you haven't done so already. And 
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1 webinar participants, we welcome you. The Department 

2 of Energy tries to make these meetings totally 

3 accessible to all of you on the web. Please keep 

4 your telephone on mute so that we don't have feedback 

5 here in the room. Please raise your hand via the 

6 software provided to be recognized to speak. 

7 It's been working pretty well. We 

8 generally -- once we unmute you, you should be able 

9 to speak and participate in the conversation here in 

10 the room. More review of additional housekeeping 

11 items as we go on. 

12 I would also encourage and explicitly ask 

13 that those joining us via the web, that in addition to 

14 listening in and participating today, that you do 

15 submit your written comments to the Department of 

16 Energy. They really benefit from receiving very 

17 detailed written comments under these matters. And 

18 from there I'll turn it back to Bryan Berringer for 

19 -- to describe the purpose of this meeting. 

20 MR. BERRINGER: Thank you everybody for 

21 participating. Can everybody hear me ok? Okay 

22 great, all right. Today we are basically going to 
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1 present DOE's proposal pertaining to test procedures and 

2 energy conservation standards for portable air 

3 conditioners. Again, we invite comments on the notice 

4 of proposed rulemaking, or NOPR as we call it, a 

5 document for the test procedure and this afternoon we 

6 will be talking about preliminary analysis for the 

7 standards. 

8 And we will discuss the next steps in the 

9 rulemaking, and again we invite participants to 

10 provide summary comments or statements that arise and 

11 issues for discussion. We will have time as we are 

12 going along the presentations. Please, if you have a 

13 question, you know, raise your hand to indicate to Doug 

14 that you have a question and we will discuss it then. 

15 And just as far as I know, this is a new 

16 product, so some of you are new to the process. We 

17 talked about a notice of proposed rulemaking. That's 

18 the first step in the test procedure process as we go 

19 to this final rule. So we are at the notice of 

20 proposed rulemaking step point at this point. We 

21 issued the notice of proposed rulemaking on February 

22 12th of this year. It was, the notice was published in 
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1 the Federal Register on February 25th. 

2 The comments, and this is pertaining to the 

3 test procedure -- we have the public meeting today 

4 that is going on, and the comments to this NOPR along 

5 with today's which will be recorded transcript to be 

6 considered as part of our analysis. The comment period for 

7 written comments is closed May 11th, but again, we will 

8 have -- we will also consider all comments that are 

9 considered in the public meeting in the transcript 

10 today. 

11 And then DOE will review all of those 

12 comments, consider those comments, and we will develop 

13 a final rule that will be basically what will be the 

14 --test procedure, so we want to make sure we have 

15 again a good open discussion, that we have a good 

16 product and that we can get a final rule without any 

17 problems. 

18 And we expect to publish that final rule 

19 by the end of the year, December 3lst here, and it 

20 should be what the DOE determines the classification 

21 that portable ACs is, you know, will be a covered 

22 product. So that is something that, you know, is 
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1 in consideration looking at the test procedure and the 

2 analysis, and we will talk about that a little bit 

3 more, probably this afternoon. We will talk about 

4 standards and effective dates and so forth. 

5 Any questions on the purpose of the 

6 meeting today as far as the process? Okay, great. 

7 So then this time we are going to open up the opening 

8 remarks. Mike or John, I know you guys indicated that 

9 you had some opening remarks, so if you could just 

10 state your name you can do it right from your seat. 

11 You just have to push the on button for your 

12 microphone so it is recorded. 

13 MR. ALOISI: I am Alberto Aloisi, Group 

14 Product Compliance and Regulatory Affairs Manager at 

15 De'Longhi Appliances, a major manufacturer of 

16 portable air conditioners. 

17 De'Longhi would support a reasonable DOE 

18 test procedure for portable air conditioners, 

19 including use of AHAM PAC-1. However, as we will 

20 discuss in detail, we are gravely concerned about 

21 DOE's proposal to modify PAC-1 to add an unreasonable 

22 requirement for infiltration air. Adoption of such a 
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1 requirement would be highly damaging to single-duct 

2 portable air conditioners. This includes giving a 

3 false impression of the performance of these 

4 products, which have been meeting the needs of 

5 satisfied customers for over 25 years. If DOE 

6 insists on a requirement for infiltration air, we 

7 urge adoption of the approach we will discuss. 

8 Single-duct portable air conditioners, 

9 despite the limited market share if compared to fixed 

10 air conditioners (such as window and central), 

11 represent a very specific market segment that meets 

12 specific consumer needs. 

13 They are a unique solution for consumer 

14 needs, such as where installation of other categories 

15 of air conditioners is forbidden or impracticable, 

16 for example, in rental situations. They do not have 

17 an impact on the external part of the building, 

18 because they do not need an external unit or a 

19 portion of a unit extending outdoors. 

20 They do not need installation or 

21 preliminary set up (which is required, for example, 

22 for room air conditioners and split systems). They 
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1 can provide an effective cooling just after the 

2 purchase (they are plug and play" appliances). 

3 The small dimension and the design of 

4 single-duct air conditioners allow the user to get 

5 comfort only in the area where this is needed, moving 

6 the equipment from room to room or from dwelling to 

7 dwelling. This allows also a significant energy 

8 consumption reduction because no room is conditioned 

9 without necessity. 

10 Single-duct portable air conditioners are 

11 on the market in the United States and Europe for 

12 more than 25 years, and customers express 

13 satisfaction about their performance and features. I 

14 will have more comments on specific issues. 

15 MR. BROOKMAN: Thank you, and we 

16 appreciate your brevity and we have got a lot to say 

17 on this subject matter, so we will get into the 

18 details as we move along here, thank you. John, do 

19 you wish to go next? Who else would like to make 

20 additional opening remarks here? No one else? No 

21 additional comments here at the onset, okay well then 

22 let's move into the content that is provided in the 
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1 packet. 

2 And we are now going to be moving to the 

3 regulatory history which is on slide 13. 

4 MR. BERRINGER: And let me just -- as we 

5 go through the slides too, you will see issues for 

6 discussion will be in the green box. It's just -- it 

7 will give you an opportunity also for people to 

8 comment on the data or information concerning for 

9 what ACs this will be throughout the standard test 

10 procedure meeting. So as you see, you are going through 

11 the slides this is a point, you know, that DOE has an 

12 issue or a concern with, we would invite comment on 

13 that as part of the analysis so anything that -- when 

14 you see these green boxes, that's an issue that 

15 typically was listed in the notice of proposed 

16 rulemaking or the preliminary analysis, so that will 

17 give us the time to also stop talking and see if 

18 anybody has comments, concerns, questions throughout 

19 the meeting, okay, and then we will just go into the 

20 regulatory history with the portable AC test 

21 procedure. 

22 There are currently no portable AC test 
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1 procedure or standards as far as federal 

2 requirements. DOE gave the notice of proposed 

3 determination for coverage back in July of 2013 and 

4 now its a federal register notice. DOE tentatively 

5 determined that portable air conditioners met the 

6 Energy Policy Conservation Act, or EPCA, for a covered 

7 product criteria, so basically that criteria is, you 

8 know, necessary for purposes of EPCA and the average 

9 household energy usage is likely to exceed a hundred 

10 kilowatt-hours. 

11 DOE published a notice of data 

12 availability in May of 2014 that evaluated industry 

13 test procedures and other modification approaches. It was 

14 also published in the federal register, so again 

15 that's leading into this meeting here too. Concurrent 

16 to this test procedure rulemaking, DOE conducted 

17 a preliminary analysis to consider the establishing of 

18 energy conservation standards for portable ACs, 

19 which again is what we will discuss this afternoon in 

20 more detail. 

21 So in this NOPR, DOE proposes to establish 

22 a portable AC test procedure which is considered a 
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1 new appendix CC. Okay, at this point I want to turn 

2 to -- are there any questions so far on the 

3 regulatory history of where we are at today? Okay, 

4 seeing none we will go ahead and turn it over to 

5 Nadav Singerman from Navigant Consulting, and he is 

6 going to talk about the definition as far as what are 

7 covered products and lead into the next section as far 

8 as the Appendix CC. 

9 MR. BROOKMAN: As we are going along, I'm 

10 going to be cuing for the purposes of making the 

11 transcript clear which page we are on. We are now on 

12 page 15. Nadav? 

13 MR. SINGERMAN: All right thank you Bryan. 

14 So first we are going to begin to discuss the 

15 proposed definitions that were in the test procedure 

16 NOPR. So DOE proposed to define a portable air 

17 conditioner as listed on this slide. This is the 

18 definition that we have been carrying over. It was 

19 initially in the notice of proposed determination and 

20 then again in the notice of data availability. 

21 Just to point out, probably the largest 

22 change that was made here was the proposal to include 
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1 room air conditioners and dehumidifiers to be 

2 excluded from the definition of portable air 

3 conditioners. In the test procedure NOPR, DOE also 

4 proposed definitions for product configurations of 

5 portable air conditioners, being a single-duct unit, 

6 which is a portable AC that draws the condenser air 

7 from the conditioned space without a duct and the discharge 

8 is the condenser outlet air from the conditioned space 

9 through a single duct. 

10 Another configuration that was defined was 

11 a dual-duct unit, where the condenser inlet air is 

12 brought in from outside the conditioned space through 

13 a duct and then, similar to a single-duct unit, the 

14 condenser outlet air is exhausted outside of the 

15 conditioned space. DOE also defined a spot cooler as 

16 a portable AC that draws the condenser inlet air and 

17 also it discharges the condenser outlet air within 

18 the conditioned space and then draws the evaporator 

19 inlet air and discharges the evaporator outlet air to 

20 a zone in the conditioned space. 

21 So to review, some of the portable AC 

22 characteristics and features of single and dual-duct 
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1 units DOE found to be very similar. They have a 

2 similar cooling capacity range of 5,000 to 14,000 BTU 

3 per hour as listed in product literature and tested 

4 according to current industry test methods. 

5 Spot coolers however have larger rated 

6 cooling capacity, greater than 14,000 BTU per hour. 

7 Single and dual-duct units typically weigh about 50 

8 pounds or greater, whereas spot coolers weigh greater 

9 than 100 pounds. Regarding intended application, 

10 single and dual-duct units are typically intended for smaller

11 rooms within homes, whereas spot coolers are intended 

12 for large spaces and harsher applications. 

13 Single and dual-duct units are typically 

14 constructed from plastic materials, whereas spot 

15 coolers are constructed from metal. Regarding condensate 

16 collection, single and dual-duct units typically 

17 have an auto evaporation feature where any collected 

18 condensate is pushed out through the condenser 

19 exhaust, whereas spot coolers typically have an 

20 internal collection bucket which is then drained away 

21 from the unit. 

22 And in terms of market share, single and 
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1 dual-duct units have the vast majority at about 98%, 

2 whereas spot coolers have a much smaller percentage 

3 of about 1 and a half%. So at this time, DOE proposed that 

4 although spot coolers would meet the proposed 

5 definition of portable ACs as gone over in the last 

6 slide, DOE is not currently considering a test 

7 procedure for spot coolers at this time. 

8 So an issue for discussion, DOE seeks 

9 comment on the proposed definitions for portable ACs 

10 and their specific configurations. DOE also seeks 

11 comment on the proposal that spot coolers will not be 

12 tested under the proposed test procedure. 

13 MR. BROOKMAN: Comments here on these 

14 definitions, and comments would be useful as this is a 

15 new product. No comments here? Yes, please, Jim 

16 Crawford? 

17 MR. CRAWFORD: This is Jim Crawford. I 

18 think that the definitions may be overly narrow and, 

19 you know, lead to some confusion as we go downstream. 

20 There seems to be a very definite emphasis here on 

21 residential products, and several of these products 

22 have commercial applications. And the reason I raise 
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1 that point is the usual distinction that we make 

2 between residential and commercial cooling products 

3 is one phase or three phase. 

4 That may not be relevant for these 

5 products, but that may be overly limiting because of 

6 course, commercial applications and industrial 

7 applications have one phase available, and if you have 

8 a product that can be moved around you are more 

9 likely to be connecting to a single-phase source than 

10 you are to a three-phase source. 

11 MR. BROOKMAN: So then in your written 

12 comments you will be more specific about how these 

13 definitions should be revised. 

14 MR. CRAWFORD: Yes, my written comments 

15 will address, excuse me -- capacity, construction and 

16 other matters. 

17 MR. BROOKMAN: Thank you, thanks very 

18 much. No thoughts here on the definitions? Nothing 

19 additional? Okay, let's proceed. 

20 MR. SINGERMAN: Thank you for your 

21 comment. So now we are going to move on and discuss 

22 the specific proposals that DOE has presented to be included
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1 in the Appendix CC. 

2 So just from the outset, DOE identified 

3 various different operating modes for portable ACs. 

4 We have an active mode, standby and off modes, and 

5 then an off-cycle mode. With an active mode, there's 

6 a number of modes that follow within active mode and 

7 also a standby and off mode, and we will discuss those 

8 specifically later. 

9 So moving on to the active mode, DOE 

10 proposed in the test procedure NOPR that an active 

11 mode is defined as when the portable AC is connected 

12 to a power source, has been activated and is 

13 performing a main function, which would be cooling or 

14 heating the conditioned space, the air circulation, as 

15 well as defrosting the refrigerated coil. 

16 So within active mode there is two other 

17 -- there's two primary modes, cooling and heating 

18 mode. Those are both where the main either cooling 

19 or heating function is activated based on a 

20 temperature sensor or a thermostat signal within the 

21 unit, and that the main component for cooling would be 

22 the refrigeration system and for heating would be the 
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1 refrigeration system which are reverse flow or with a 

2 resistance heater that has been activated, or the blower is 

3 running without activation of that primary system. 

4 DOE also identified two other modes that it 

5 has not proposed to be measured in the proposal. The 

6 first is air circulation mode. This is a consumer 

7 initiated mode where the consumer presses the air 

8 circulation mode button on the unit. The main 

9 cooling and heating functions are disabled in this 

10 mode, the fan or blower is operating either 

11 continuously or cyclically to circulate air 

12 throughout the space, and DOE is not including this 

13 mode because it does not have information on the 

14 consumer usage of this feature, which is something 

15 that we would be interested if anybody can comment 

16 on. 

17 The other mode is dry or dehumidification 

18 mode. This is the mode where the unit adjusts its 

19 operation to maximize latent heat removal instead of 

20 sensible heat removal. Typically the duct set up is 

21 modified and there is a drain set up required. DOE 

22 is not including this mode as it is not a primary 
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1 mode of operation and would therefore have a low 

2 impact on annual energy consumption. 

3 Also, a recent metering study showed that 

4 no users use this mode as well, so if it were to be 

5 included it would disproportionately increase the 

6 test burden. So DOE requests comment on the proposed 

7 active mode definition as well as the proposed 

8 definitions of cooling and heating modes. 

9 MR. BROOKMAN: Comments here on active 

10 mode definitions? Okay, no comments here, Joanna 

11 Mauer? 

12 MS. MAUER: I have two questions. One, I 

13 was wondering if you could just explain the units 

14 that have the reverse cycle heat pumps to provide 

15 heating, if you could explain how they work, and my 

16 other question is air circulation mode -- is that 

17 different than the off-cycle mode? 

18 MR. SINGERMAN: Yes, so for your first 

19 question, it will be the same components but there is 

20 one extra component, which is a valve that would 

21 switch the flow of the refrigerant to go backwards to 

22 the unit and would then produce heating inside and 
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1 push cold air outside. 

2 MS. MAURER: This is Joanna. So is there 

3 air coming in from outside, or where is the heat 

4 coming from? 

5 MR. SINGERMAN: I mean there's refrigerant 

6 and there's a compressor inside of the unit, and 

7 depending upon which direction the refrigerant is 

8 flowing in, you have the heat exchanger that's going 

9 to be blowing air. The air will flow over inside the 

10 conditioned space and then there is a heat exchanger 

11 that will be connected to a duct and push air outside 

12 of the conditioned space, and so what will happen is, 

13 depending upon the direction the refrigerant is 

14 flowing in, the indoor heat exchanger could be cold 

15 or hot and so it's just a matter of which direction 

16 it is flowing. 

17 So in cooling, you would have the indoor 

18 heat exchanger be cold and that is the evaporator. 

19 If you switch the flow, the indoor heat exchanger 

20 would be hot. 

21 MS. MAURER: I'll follow up later. 

22 MR. SINGERMAN: Okay sure. Oh, and then the 
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1 second question, air circulation mode yes, it is 

2 different than off-cycle mode. For off-cycle mode, the 

3 unit would actually be -- the mode that it would enter 

4 from would be from a cooling or heating mode and then, 

5 depending upon the temperature of the conditioned 

6 space, then it would cycle to off-cycle mode. Air 

7 circulation mode would be a separate button on the 

8 panel which would say, you know, fan mode or air 

9 circulation or something so that would be separate -- 

10 a separate mode completely from off cycle. 

11 MS. MAURER: Okay. 

12 MR. SINGERMAN: And we will discuss off 

13 cycle later, the definition and how it will be 

14 tested. 

15 MS. MAURER: Thank you. 

16 MR. BROOKMAN: Active mode definitions? 

17 Comments on those? None at this time, okay we are 

18 moving on. 

19 MR. SINGERMAN: Okay so we are going to 

20 begin with cooling mode, first active mode, primary 

21 active mode performance. There are generally three test 

22 procedures that DOE identified that measure portable 
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1 AC performance in cooling mode -- those being AHAM's 

2 PAC-1, CSA has one, as well as ANSI/ASHRAE Standard 

3 128. All of these test procedures measure cooling 

4 capacity and energy efficiency ratio based on an air 

5 enthalpy approach that monitors the air flow rate, the

6 dry-bulb 

7 temperature and the water vapor content of the 

8 air over the evaporator. 

9 So after analyzing these test procedures, 

10 DOE found no significant differences among the 

11 results that were produced from them. So DOE 

12 conducted testing according to PAC-1, at that time it 

13 was 2009 when the testing was conducted, that was the 

14 latest version of AHAM's PAC-1, and DOE approached 

15 this as a baseline testing. DOE also performed 

16 calorimeter testing, which is an approach that looks at 

17 the net cooling to the conditioned space as tested 

18 for room air conditioners and that's ANSI/ASHRAE 

19 Standard 16, and we have just a picture here of what 

20 the test set up looked like. 

21 You have the evaporator exhaust ducted 

22 with instrumentation as well as both condenser ducts, 
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1 as this is a dual-duct unit. Based on the results of the 

2 baseline testing, DOE found that the current industry 

3 test procedures for portable ACs neglect some 

4 significant heat transferring due to air infiltration 

5 and other heat losses, and there's further information 

6 in the May 2014 NODA where a lot of the data is 

7 presented. 

8 So here is just a one graph chart of the 

9 data that DOE collected from its testing, and what we 

10 have here charted is the baseline testing from AHAM 

11 PAC-1, as well as the calorimeter testing, and we show 

12 the cooling capacity and the cooling mode EER. 

13 And what we find is, according to the baseline testing, 

14 the units have much higher cooling capacities and 

15 EERs, whereas the calorimeter test which looks at the 

16 net effect of the chamber to the room had much lower 

17 cooling capacities and EERs. 

18 In fact, some units actually produce a net 

19 heating effect to the chamber. So -- and these 

20 results are based on both single-duct and dual-duct 

21 units. So based on the testing, DOE preliminarily 

22 determined that ANSI/ASHRAE Standard 16, which is the 
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1 calorimeter method, has overly burdensome conditions 

2 and requirements, and they are difficult to maintain 

3 throughout testing. Mainly, it requires a specific 

4 calorimeter chamber and may also require additional 

5 components to help maintain conditions in the space 

6 when the portable AC is operating. For example, some 

7 would be fans to circulate the air, humidifiers, 

8 dehumidifiers and scales to manage all of the 

9 moisture and water that is coming in and out. 

10 Also, there is a pretty complex analysis 

11 that is required to then incorporate all of those 

12 components to determine their heating effects to the 

13 chamber. So DOE found that the AHAM PAC-1 was the 

14 least burdensome approach. However, it would require 

15 some modification to represent typical use. 

16 DOE did not identify any differences 

17 between the 2009 and the updated 2014 version of 

18 PAC-1, so DOE referenced AHAM PAC-1-2014 in the test 

19 procedure NOPR. So in the test procedure NOPR, DOE 

20 proposes that AMAM PAC-l be the basis of the DOE test 

21 procedure for portable ACs. The test method set up 

22 is less burdensome than the calorimeter approach. 
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1 DOE is also proposing that PAC-1-2014, 

2 although it would be the basis, that there be some additional 

3 measurements and calculations to account for 

4 infiltration air, case and duct heat transfer effects, 

5 and we will discuss those later on. So just on the 

6 outset, DOE seeks comment on the proposed reference of 

7 PAC-1-2014 as the basis for the portable AC test 

8 procedure. 

9 MR. BROOKMAN: Jennifer? 

10 MS. CLEARY: Jennifer Cleary. AHAM 

11 supports the use of AHAM PAC-1-2014, and we note that 

12 you did mention that there were no differences in the 

13 2009 and 2014 version and that's generally true. The 

14 main changes that we made were primarily editorial in 

15 nature, I guess you could say, and we are here to 

16 harmonize with the Canadian test procedure. And I 

17 think that brings up an important point, which is that 

18 we, you know, it's important that we have the North 

19 American method here. Canada has in the past 

20 indicated its intent to look at standards for 

21 portable air conditioners. 

22 Right now, their proposals and provinces to 
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1 do so and you know it's important that we have 

2 harmonization between the two countries. And so in 

3 AHAM's view, the best way to accomplish that 

4 harmonization is to incorporate by reference AHAM 

5 PAC-1-2014, period. And so that means we do not agree 

6 with the additional measurements that DOE is 

7 proposing, and of course we will expand on that more 

8 fully in our written comments and perhaps a little 

9 bit today too. 

10 MR. BROOKMAN: Thank you, that was very 

11 clear. Additional comments? Yes, Jim Crawford? 

12 MR. CRAWFORD: Before we go back to -- 

13 MR. BROOKMAN: Turn on your microphone 

14 Jim. 

15 MR. CRAWFORD: I'm sorry. If we could go 

16 back to diagram 24, thank you. When I look at those, 

17 I wonder whether there was any combination made to 

18 essentially eliminate the excess fan power due to 

19 flowing through those relatively long and not ideal 

20 duct layouts. 

21 MR. SINGERMAN: So the larger test duct 

22 connected to the evaporator exhaust -- there's a 
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1 variable speed fan on the end of it, and first we 

2 measured the static pressure without the duct and 

3 then connected the duct. 

4 MR. CRAWFORD: That's what you should be 

5 doing. 

6 MR. BROOKMAN: Thanks Jim, and yes please, 

7 Alberto? 

8 MR. ALOISI: So De'Longhi supported the 

9 use of the AHAM PAC-1 standard without any 

10 modification or corrections. We support the use of 

11 the standard 2014. 

12 MR. BROOKMAN: Thank you. Maybe we take a 

13 five minute break. Will that be sufficient? We need 

14 to restart the webinar, so let's just take a short 

15 break. Don't anyone go anywhere, you can stand up -- 

16 we are just going to restart the webinar. It should 

17 just take a minute, and you can make that quick dash 

18 to the restroom if you wish. 

19 (OFF THE RECORD for a brief break) 

20 MR. BROOKMAN: Okay let's resume. Please 

21 take your seats. Our apologies for the interruption, 

22 especially those of you joining us via the web. We had 
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1 some sort of web interruption and broke the 

2 connection. We had to restart, so apologies for the 

3 break in the action here. We are about to resume. 

4 As we resume, an individual joining us via the web, Ed 

5 Wuesthoff, has a comment. Ed, we are going to try and 

6 unmute you and hopefully we will hear you in the room 

7 and proceed. Yes, you sound good, keep going. Ed, you 

8 are kind of going in and out. You're kind of breaking 

9 up. Try it again, speak slowly and loudly please. 

10 MR. WUESTHOFF: For each of the different 

11 portable air conditioners in the market, there are 

12 specific compressors and fan motors and tubing inside 

13 the encasement. And therefore by design, the end 

14 result of the cooling capacity and the electrical 

15 consumption is based on each manufacturers design, 

16 and therefore, if placed in a condition where -- 

17 capacity and energy consumption will be based on 

18 testing -- so in my opinion there's not a need to do 

19 it -- with any of the electrical components inside 

20 the case, because the end result would be the total 

21 capacity coming from the cabinet and the total 

22 measure of energy consumption. 
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1 MR. BROOKMAN: Okay, I think we have got 

2 that, yes Nadav? 

3 MR. SINGERMAN: So I guess in response, you 

4 know our understanding of PAC-1 is to measure the 

5 evaporator exhaust, the air conditions, and that's how 

6 the cooling capacity is determined. So at least my 

7 understanding is that there is no accounting for the 

8 heat that may be lost in space due to the case, other 

9 components in the case or infiltration air or heat to 

10 the ducts, and we will talk about that, I think, right 

11 after this slide. We are going to dive into the 

12 specifics for the different proposed modifications to 

13 the PAC-1, but that's at least the thought process 

14 that's behind what we are doing. 

15 MR. BROOKMAN: Let's hold additional 

16 comments until we get to that slide, if anyone else 

17 has a comment on that. John, do you have something 

18 here? You're ok? Okay Joanna? 

19 MS. MAUER: Joanna Mauer. I just had one 

20 question. The NOPR talks about the challenges with 

21 the calorimeter approach in maintaining the indoor 

22 and outdoor conditions. I just want to better 
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1 understand kind of why it is more challenging than 

2 testing a room air conditioner? Is it because of the 

3 infiltration air or -- 

4 MR. SINGERMAN: So for the calorimeter 

5 approach, instead of looking at the unit itself you 

6 look at the chamber that it is sitting in and how 

7 much energy is required to maintain the conditions 

8 within that chamber. So while the portable air 

9 conditioner is operating, it is impacting the chamber 

10 and you have to counteract the cooling that it is 

11 providing more heating with the various components, 

12 and some of these chambers that are specific for room 

13 ACs may not be capable for portable ACs, and you 

14 might need to bring in other components to either help 

15 counteract the portable AC's operation. 

16 And also there's the infiltration air that 

17 you are talking about, so to maintain a zero pressure 

18 balance between the indoor chamber and the outdoor 

19 chamber, you have to pass air back into the indoor 

20 chamber, especially for single-duct units that are 

21 pushing air out, and we will discuss on the next slide its 

22 infiltration air that also impacts the indoor chamber 
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1 in which you are using your calorimeter method to see 

2 how much energy is required to maintain the 

3 conditions. So the infiltration air, as well as all of 

4 these other components that may be required, are why 

5 it is so complex. 

6 MR. BROOKMAN: Okay and we are going to 

7 get into more detail on this. Yes, okay Nadav proceed. 

8 MR. SINGERMAN: Okay, so first we are going 

9 to discuss the infiltration air proposal. So when 

10 portable ACs are operating in a conditioned space, 

11 they often create a negative pressure which then 

12 causes other air to come back into the room from 

13 other places, and we refer to that as infiltration 

14 air. 

15 For the purposes of this test procedure 

16 NOPR, DOE assumed that the infiltration air is 

17 originating from the unconditioned or outdoor space, 

18 and so we have a diagram here for a single-duct unit 

19 and dual-duct units. And for a single-duct unit, it's 

20 pushing the condenser exhaust out to the outdoor 

21 outside of the indoor chamber, which then creates a 

22 negative pressure. And so what we assume is that the 
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1 outdoor air is then going to counteract that 

2 condenser exhaust with the outdoor conditions, which 

3 are 95 degree dry and 75.2 wet-bulb Fahrenheit. 

4 And so for a single-duct unit, the 

5 infiltration air is considered with the same CFM or air 

6 flow as the condenser exhaust. For a dual-duct unit 

7 where the condenser inlet and exhaust are both from 

8 the outdoor space, the infiltration air would be the 

9 difference between the air flow of the condenser 

10 exhaust and the inlet -- and the condenser inlet flow. 

11 So that's what we have shown here pictorially. 

12 In the test procedure NOPR, DOE presents a 

13 number of equations that determine the total 

14 infiltration air and heat transfer that's based on 

15 the latent and the sensible heat contribution of that 

16 infiltration air. And so I won't go through these in 

17 detail, but all the variables are defined in the test 

18 procedure NOPR. 

19 The bottom line is you come out with a 

20 total infiltration air heat transfer as the last 

21 equation. So DOE is seeking comment on the proposal 

22 to modify the cooling capacity equation to address 
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1 the effects of infiltration air. We are also seeking 

2 comment on the proposed approach to estimate the 

3 infiltration air flow rate and heat transfer. 

4 Specifically, on the proposal to use the 

5 outdoor test conditions from the AHAM PAC-1 as the 

6 temperature conditions for infiltration air. 

7 MR. BROOKMAN: Yes please, Alberto? 

8 MR. ALOISI: At De'Longhi, we do not agree 

9 with this proposal. We feel that DOE's current 

10 effort to come up with an approach to infiltration 

11 air is fatally flawed and highly damaging to 

12 single-duct products, including giving a false 

13 impression of the performance of these products, 

14 which have been meeting the needs of satisfied 

15 customers for over 25 years. 

16 DOE's proposal for infiltration air, in 

17 particular testing at 95/75.2 degrees F outdoor 

18 conditions, is an unwarranted penalization for 

19 single-duct units because they would be rated under 

20 the worst outdoor conditions, which occurs for a 

21 negligible period of time during the season. 

22 This would have a dramatic negative effect 
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1 on rated capacity and efficiency of single-duct 

2 systems. This is due to the great sensitivity of 

3 ratings for single-duct systems to the selection of 

4 outdoor temperature. Hence, selection of an 

5 appropriate outdoor temperature for rating testing is 

6 a critical factor for single-duct systems. The 

7 proposed testing also fails to properly take into 

8 account the effects of inside air. 

9 According to AHRI 210/240, the recurrence 

10 of outdoor temperatures within 95 to 104 degrees 

11 Fahrenheit is just 2.2% of the whole season. In 

12 contrast, the range from 65 to 80 is 66.1%. As a 

13 consequence, DOEs proposed procedure, considering 

14 95/75.2 degrees F and outdoor conditions, results in 

15 overstating, by far, infiltration air. 

16 In addition, it has to be considered that 

17 a certain amount of fresh air (make up air) is always 

18 required for proper ventilation. For residential 

19 occupancies, 1 to 2 air changes per hour are 

20 recommended. So the effect of air ventilation should 

21 be considered also, in general, for all air 

22 conditioning categories or it should be discounted 
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1 for portables. 

2 If infiltration air is taken into account 

3 for portable air conditioners, we urge adoption of 

4 70 degrees Fahrenheit as the outdoor temperature, 

5 which is the value found by DOE as a single 

6 representative average cooling season temperature for 

7 the United States as a whole. In addition, AHRI 

8 210/240 also has a 50% recurrence associated with an 

9 outdoor temperature of 70 degrees Fahrenheit. 

10 Further, DOE acknowledges that 

11 infiltration air enters the conditioned space 

12 directly from outdoors only in some cases. Indeed, 

13 it says that it is possible that some or all of the 

14 replacement air is drawn from a location other than 

15 the outdoors directly, such as a basement, attic, 

16 garage, or a space that is conditioned by other 

17 equipment. 

18 Thus, DOE's position is based 

19 substantially on the assertion that any air 

20 infiltrating from the other conditioned space likely 

21 also originated from outdoors before being 

22 conditioned by other cooling equipment. It is 
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1 unrealistic not to account for the presence of the 

2 building and inside air in an effort to justify 

3 everything as ultimately being outdoor air and thus 

4 to be deemed as being at the outdoor air temperature. 

5 In that regard, 

6 DOE's approach does not take thermal load 

7 of a room into account. Quite often the ambient 

8 temperature is higher than the outdoor temperature, 

9 requiring the need of cooling. This can be 

10 associated to the presence of internal loads, 

11 computers, cooking appliances, human beings, and 

12 solar radiation. DOE's approach also does not take 

13 thermal lag of the dwelling into account. 

14 During the night, the outdoor temperature 

15 is lower than ambient temperature, but the ambient 

16 temperature may continue to grow due to the heat 

17 accumulated by the building structure during the day. 

18 During the day, the ambient temperature is higher 

19 during the afternoon than in the morning due to the 

20 release of the heat accumulated by the building 

21 structure during the day. 

22 Adjacent rooms can be cooled by central 
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1 systems or can be at lower temperature because 

2 internal loads and/or solar radiation are not present 

3 (basement, garage). The intervening factor of air 

4 coming from adjacent rooms cannot be ignored on the 

5 proposed ground that such air, at some point in the 

6 past, was outdoors. 

7 Thus, the temperature of infiltration air 

8 is weakly related to the outdoor temperature and use 

9 of 95 degrees Fahrenheit is unjustified. 

10 If despite the foregoing, DOE refuses to 

11 use 70 degrees Fahrenheit as the outside air temperature, 

12 it should at least use no greater than 80.6. This is 

13 a well-recognized temperature and is used as the 

14 standard rating condition for single-duct portable 

15 air conditioners in PAC-1. This temperature is used 

16 for single-duct for both indoor and outdoor 

17 conditions. 

18 We stress that making the rarely occurring 

19 95 degrees Fahrenheit temperature as the applicable 

20 temperature for infiltration air for single-duct 

21 portable air conditioners drastically and 

22 unrealistically reduces their rated capacity. This 
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1 is highly damaging to these useful products, giving a 

2 false impression of their performance. 

3 There are further serious implications to 

4 the use of an unwarranted infiltration air 

5 temperature. Such a temperature would affect the 

6 ability to achieve efficiency improvements. This 

7 would undermine a key requirement for a standard that 

8 substantial improvement in energy efficiency is 

9 technologically feasible. Thank you. 

10 MR. BROOKMAN: Thank you, Joanna? 

11 MS. MAUER: Joanna Mauer. We strongly 

12 support incorporating the effects of infiltration air 

13 to get a realistic measure of cooling capacity, and we 

14 also support the proposal to use 95 degree outdoor 

15 air. 

16 MR. BROOKMAN: Additional comments here? 

17 Nothing additional? Okay, yes Ed. You are unmuted. Go 

18 ahead. 

19 MR. WUESTHOFF: Yeah this is Ed Wuesthoff 

20 at Friedrich. 

21 MR. BROOKMAN: You sound good. 

22 MR. WUESTHOFF: Thanks, Friedrich supports 
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1 the discussion that De'Longhi had forwarded, 

2 primarily because within a psychrometric as the air is 

3 tested, the portable air conditioners are designed -- 

4 whether it's a single-duct or dual-duct, it is going 

5 to be measured at a standard temperature and the 

6 standard relative humidity in the indoor room and the 

7 outdoor room, 

8 whether it's being a cooling capacity or a 

9 heating capacity test, and therefore according to the 

10 way the air impact that is listed. The procedure shows 

11 both rooms have to be within 6% of the cooling or 

12 heating capacity, and therefore, because the rooms are 

13 balanced and there is a minor amount of pressure 

14 differential between both rooms, there is no need to 

15 take into account the infiltrated air factor. 

16 MR. BROOKMAN: Okay, thank you Ed. Do we 

17 have additional comments on air infiltration? I know 

18 several individuals thought this was an important 

19 point. Anything else online? Nothing Emily? Okay, then 

20 we are going to proceed. 

21 MR. SINGERMAN: Okay, so moving on to the 

22 standard rating conditions in the NOPR, DOE proposed 
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1 that the ambient conditions for a cooling mode be as 

2 in the AHAM PAC-1-2014 for dual-duct units. That's 

3 80.6 dry and 66.2 wet-bulb for the evaporator inlet, and then

4 an 

5 outdoor condition of 95/75.2 for dry and wet-bulb. For 

6 a single-duct unit it's the same condition for both the 

7 evaporator and the condenser unit. 

8 DOE notes that these conditions are close 

9 to those that are required by the DOE for the room AC 

10 test procedure, which are below on the slide, and so 

11 would result that the cooling mode under the portable 

12 AC test procedure may be comparable or would be 

13 comparable to those for room ACs. 

14 Regarding the inlet air, specifically for 

15 tolerances of the inlet air, DOE notes that ANSI/ 

16 ASHRAE Standard 37, which is referenced by the AHAM PAC17 1, the condenser inlet and evaporator inlet dry-bulb 

18 temperatures must be maintained within a range of 2 

19 degrees Fahrenheit and within half a degree of the 

20 nominal value. However, because single-duct units 

21 have both inlets drawing from the same indoor air 

22 chamber source, there could potentially be a slight 
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1 variation between those two inlet conditions. 

2 In order to make sure that we specify 

3 which condition must be maintained for the primary 

4 condition, DOE proposed to specify that a more 

5 stringent tolerance be in place for the evaporator 

6 inlet dry-bulb, which would be consistent with the 

7 evaporator inlet wet-bulb temperature tolerance, 

8 which is 1 degree Fahrenheit, within a range of 1 

9 degree Fahrenheit and an average difference of 0.3 

10 degrees Fahrenheit. 

11 DOE notes that the condenser inlet dry12 bulb temperature would still be maintained within the 

13 original tolerance. So DOE seeks comment on the 

14 proposed ambient conditions for cooling mode based on 

15 AHAM PAC-1 and also seeks comment on the proposal 

16 to tighten the evaporator inlet dry-bulb temperature 

17 tolerance to minimize any confusion for the test lab as 

18 to which test condition, either the evaporator or the 

19 condenser inlet, should take priority. And again, this 

20 is specifically for single-duct units. 

21 MR. BROOKMAN: Jim Crawford? 

22 MR. CRAWFORD: Just an observation about 
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1 the indoor test conditions. The 80/67 is about 50%, 

2 50-51% relative humidity. The revised conditions are 

3 down on 40% relative humidity. That's a significant 

4 difference in test conditions. It's not comparable 

5 to the window units, and it seems kind of bizarre that 

6 we don't want to go to the metric and so we have 

7 used three digit temperatures for American standards 

8 so that they will be equivalent to two digit 

9 temperatures in the metric standards, which seems a 

10 little strange unless we are ready to go to metric 

11 very soon. 

12 MR. BROOKMAN: Additional comments? You 

13 see the comment box there and particularly the second -- 

14 I direct your eyes to the second request, the proposal 

15 to tighten the evaporator inlet dry-bulb 

16 temperature tolerance to minimize confusion. Comments 

17 on that? Okay, I guess we are moving on. Yes Ed? Oh 

18 Ed, please -- 

19 Ed speak up. 

20 MR. WUESTHOFF: No comment. 

21 MR. BROOKMAN: Okay. Emily says she is 

22 going to leave you unmuted so you could just chime in 
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1 when you feel you wish to. Let's proceed then. This 

2 would be slide 34. 

3 MR. SINGERMAN: Okay, so moving on toward 

4 the other heat transfer effects that we discussed 

5 earlier. The first is a duct heat transfer. DOE 

6 determined that uninsulated ducts would significantly 

7 contribute to heat loss to the conditioned space. 

8 Therefore, DOE proposed in the NOPR that additional 

9 specifications would be provided for the duct heat 

10 transfer measurements that are already in ANSI ASHRAE 

11 Standard 37, which is again referenced by PAC-1-2014. 

12 They are as follows: that there be a minimum of 

13 four equally spaced thermocouples adhered to the 

14 side of the full length of the condenser duct, or 

15 ducts for a dual-duct unit; the temperature 

16 measurement accuracy be within plus or minus half a 

17 degree; and that the convection heat transfer 

18 coefficient be assumed as 4 BTU per hour per 

19 degree Fahrenheit. 

20 DOE proposed a duct surface area equation 

21 as well as an equation to determine the duct heat 

22 transfer. So similarly, DOE determined that there are 
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1 heating effects also from the internal components of 

2 portable ACs and not just the evaporator fan, which is 

3 mentioned in PAC-1-2014, and believe that they should 

4 also be addressed. So therefore, DOE proposed 

5 provisions for determining the case heat transfer to 

6 the conditioned space as follows: that similar to the 

7 duct heat transfer, that there be a minimum of 4 

8 equally spaced thermocouples on each side of the 

9 case and that they be adjusted if they would be 

10 placed on an air intake or duct grille; that the 

11 temperature measurements again be within a half a 

12 degree Fahrenheit; and that the same convection heat 

13 transfer coefficient used. 

14 DOE proposed equations for the case 

15 surface area for each side of the case as well as the 

16 total case heat transfer in cooling mode, which is 

17 just a summation of the heat transfer from all the 

18 case sides. So DOE proposed that the cooling capacity, as 

19 determined by PAC-1-2014, would be adjusted based on 

20 infiltration air, duct and case heat transfer effects 

21 with the equation from the slide, and the plot here 

22 shows what happens to the AHAM or the baseline data 
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1 that we have presented earlier in the presentation 

2 when you take into effect infiltration air, duct and 

3 case heat transfer. 

4 And what you see is that the modified 

5 AHAM, the red dots, are now overlaying on the 

6 calorimeter approach so they are much more in line, 

7 which suggests to DOE that the modified AHAM approach 

8 also is representative of the net cooling, or heating 

9 in some units cases, to the conditioned space. 

10 MR. BROOKMAN: The modified AHAM approach 

11 that you show here, that reflects DOE's current 

12 proposal, those modifications? 

13 MR. SINGERMAN: Yes, with the adjusted 

14 cooling capacity equation above, the cooling capacity. 

15 So yes, that is the modified AHAM is what DOE is 

16 proposing. 

17 MR. BROOKMAN: Joanna? 

18 MS. MAUER: Joanna Mauer. Just a 

19 clarification. This is the modified AHAM data that's 

20 the same data that was presented in the NOPR, which 

21 was modified AHAM? 

22 MR. SINGERMAN: Yes. 
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1 MS. MAUER: And is that -- I understand 

2 that it incorporates the infiltration. Does that also 

3 incorporate the duct and case? 

4 MR. SINGERMAN: Yes, so the data in this 

5 plot represents the AHAM baseline results that we had 

6 determined that were presented in the NODA and also 

7 earlier in the presentation, with those three 

8 adjustments: removing the infiltration, the duct and 

9 the case heat transfer effects. That's what is presented 

10 in this slide. 

11 So we are seeking comment on the proposed 

12 approach to characterize the heat transfer from both 

13 the condenser ducts as well as the case heat transfer 

14 effects. Specifically for the case, that's a new 

15 proposal, and the heat transfer based on an average, a 

16 total of all the heat transfer from all the sides 

17 of the case, which is based on the average surface 

18 temperature and the evaporator inlet temperature. 

19 DOE is also seeking comment on the 

20 proposal to again consider the duct case and 

21 infiltration air heat effects in the adjusted 

22 capacity calculation. 
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1 MR. BROOKMAN: Jim Crawford? 

2 MR. CRAWFORD: I look back to the diagram 

3 of the physical test layout again. You don't need to 

4 go back, but the ducts or anything minimized in the 

5 length, and they kind of bowed down and back up again, 

6 so we have additional length and presumably additional 

7 turbulence. So the condition is not terribly 

8 representative of what you might find in a real 

9 installation. 

10 Correlated to that is the question of the 

11 4 BTU per square foot per degree. I think it would 

12 be appropriate for more substantiation of that to be 

13 given. In reading the test proposal, it sort of seems 

14 to almost come out of the air, and I would think that 

15 with something approaching optimized ducting that one 

16 ought to measure the total coming out of the machine 

17 and the total at the end of the duct and then the 

18 same thing on the inlet to substantiate the use of 

19 that factor. 

20 With respect to the cabinet, I would think 

21 that the air flow over the surface of the cabinet 

22 would generally be expected to be a good deal less 
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1 than the velocity through the duct, and so I would 

2 think that that would be a different animal, and I 

3 don't really think that you are going to have the 

4 same kind of heat transfer from the bottom of the 

5 case to the floor part, or the air that might be 

6 sliding through there, that you would have for the 

7 tops and sides. 

8 MR. BROOKMAN: Okay, thank you. 

9 MR. SINGERMAN: I have a few responses. 

10 MR. BROOKMAN: Yes Nadav? 

11 MR. SINGERMAN: The first being that that 

12 duct set up for the condenser side -- that's based on 

13 PAC-1-2014, which provides distances and that shape. So 

14 that's where that set up came from. If you have a 

15 better way or a different way that you would propose, 

16 we would definitely welcome that in written comments. 

17 Regarding -- just to respond to the 

18 convection heat transfer coefficient, just to clarify 

19 that that's referring to the outer surface of the 

20 ducts, not the inner surface of the ducts. So we are 

21 talking about the outer surface. 

22 MR. BROOKMAN: Jim? 
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1 MR. CRAWFORD: I've been reading about 

2 paratroopers, and somebody jumped out of a plane. And 

3 would I do it? And the answer is no, and the relevance 

4 of that is to the ducting. If the ducting layout 

5 that is shown is not what DOE considers to be an 

6 appropriate layout, then I would think that the 

7 ducting layout ought to be made more appropriate, 

8 shorter and more direct than that. 

9 MR. SINGERMAN: Just to clarify, I wasn't 

10 saying that duct set up that DOE doesn't believe that's 

11 appropriate. Just that's what's in PAC-1 and DOE has 

12 accepted that as a common duct set up, and if you have 

13 alternate information --. 

14 MR. BROOKMAN: That's a useful 

15 clarification, Nadav. Alberto, you are next. 

16 MR. ALOISI: You get -- the reason we are 

17 against this kind of additional correction is that 

18 modified result of the test procedure, of an existing 

19 standard. In this specific case, I believe that the 

20 suggested proposal could lead to a big problem 

21 possibly from the laboratory, because if we 

22 measure that all of the units are perfect or --it is 
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1 quite easy to recognize each face and cool 

2 measurement and average temperature of that face, and 

3 this is now a dangerous situation. 

4 Each appliance has a specific shape and 

5 they are -- so each different laboratory can measure 

6 different face on the single faces and different 

7 results. So this specific correctionwould be quite poor. 

8 MR. BROOKMAN: Okay, Jennifer Cleary, who 

9 is joining us online, offers the following comment. 

10 AHAM opposed these adjustments to PAC-1 and will 

11 comment further in written comments. We echo some of 

12 the earlier comments made by De'Longhi and 

13 Friedrich. Yes, Joanna? 

14 MS. MAUER: Joanna Mauer. We support 

15 incorporating the duct and case transfer effects again 

16 to get at a more realistic measurement of actual 

17 cooling capacity, and we really appreciate all of this 

18 data that was provided in the NOPR comparing the 

19 calorimeter results and the modified AHAM results. And 

20 there seems to be a fairly good correlation between 

21 the two, which gives us comfort with the proposed DOE 

22 test procedure. 
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1 MR. BROOKMAN: Okay, thank you. Additional 

2 comments before we move on? Okay. 

3 MR. SINGERMAN: Okay, so DOE also made some 

4 proposals in the NOPR regarding condensate collection 

5 and the test set up for units. When DOE conducted 

6 testing, it did so with a drain line attached to 

7 monitor the condensate collection within the unit. 

8 However, the drain line was elevated to 

9 simulate testing with the drain plug. DOE observed 

10 that all the units had an auto-evaporation feature 

11 and that no unit during testing cycled off because of 

12 a full internal condensate collection bucket. 

13 So therefore, DOE is proposing that a 

14 portable AC be set up in accordance with manufacturer 

15 instructions and specifically as follows: that if there 

16 is an auto evaporative feature, then the drain plug 

17 that is provided should remain in place as shipped. 

18 If there is no auto evaporation feature or if the 

19 internal bucket fills up during testing and the unit 

20 cycles off, the test is invalid and should be 

21 stopped, the drain plug removed, the condensate drain 

22 installed and the test restarted at the beginning. 
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1 A unit is only tested -- the unit is only 

2 tested with an included pump activated if it's 

3 required by the manufacturer in the set up 

4 instructions or if there is no condensate drain line 

5 or other way to remove condensate. DOE also made the 

6 following proposals regarding the control settings: 

7 first that the fans should be set to maximum, if 

8 possible; that the temperature controls be the lowest 

9 available on the unit; that, for a louver opening, it 

10 should be the maximum possible area and that the 

11 louvers should be parallel to the air flow, if they are 

12 adjustable, and that louver oscillation should be off 

13 or disabled if possible. 

14 DOE believes that these settings would 

15 represent consumer settings to achieve the primary 

16 function of cooling as quickly as possible and to 

17 help maintain conditions during testing. DOE also 

18 proposed -- regarding the test unit placement, DOE noted 

19 that ANSI/ASHRAE 37, which is referenced by PAC-1, 

20 specifies space requirements for only the outdoor 

21 chamber. So DOE proposes that the same outdoor 

22 chamber space requirements also be applicable for the 
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1 indoor chamber, and they are as listed here. But 

2 basically they are 6 feet from any inlet or exhaust 

3 grille and that 3 feet from any other surface. 

4 DOE also made another proposal regarding 

5 the electrical supply. PAC-1-2014 doesn't specify a 

6 single test voltage. However, it does state that the 

7 nameplate voltage should be used. In order to ensure 

8 repeatability in testing, DOE proposed that the input 

9 standard voltage be maintained at 115 volts plus or 

10 minus one percent and the electrical supply be 

11 maintained at the nameplate listed frequency within 

12 plus or minus one percent. 

13 So DOE is seeking comment on all of those 

14 proposals, specifically the test set up for units 

15 with and without means for auto-evaporation, regarding 

16 the control settings as well as the unit placement in 

17 the chamber. 

18 MR. BROOKMAN: Alberto? 

19 MR. ALOISI: Yes, one question. Are also 

20 the partition walls between doors with the blower 

21 between the wall? 

22 MR. SINGERMAN: I believe so, yes. The 
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1 partition wall would be considered a wall of the 

2 indoor chamber. 

3 MR. ALOISI: Okay, so this means that the 

4 unit should be placed at least six feet far from the 

5 petition wall so this -- 

6 MR. SINGERMAN: I believe so. I guess what 

7 you are saying is that the ducts lengths aren't long 

8 enough to accommodate that. Okay, so that's a great 

9 comment, and if you could put that in writing as well 

10 we will consider that down the road. 

11 MR. ALOISI: Okay, thank you. 

12 MR. BROOKMAN: Additional comments? You 

13 see the request for comment that is on the screen, 

14 set up requirements, control settings and placement 

15 from chamber wall surfaces. Yes, Jim Crawford? 

16 MR. CRAWFORD: I was wondering with this 

17 slinger ring, in particular, how you go about measuring 

18 the latent capacity, cooling capacity of the machine. 

19 The condensate comes off the evaporator, goes into 

20 the apparatus and makes it sling it out with the 

21 condenser. How are you measuring that cooling 

22 capacity? 
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1 MR. SINGERMAN: So the indoor cooling 

2 capacity is measured by monitoring the air conditions 

3 of the evaporator exhaust, which looks at both 

4 sensible and latent components of that. 

5 MR. BROOKMAN: Additional comments before 

6 we move on? For those of you that are curious, I was 

7 going to suggest that we work for about another 

8 fifteen minutes then we will take a break, okay 

9 Nadav? 

10 MR. SINGERMAN: Okay, so that was the 

11 cooling mode section. Now we are going to move into 

12 the heating mode as an active mode. In the test 

13 procedure NOPR, DOE proposed that the same test setup 

14 and general conduct of the cooling mode test be used 

15 for the heating mode, which is generally based on the 

16 ANSI/ASHRAE Standard 37, and that the following test 

17 requirements are still applicable to heating mode as 

18 they were proposed in cooling mode. So they are listed 

19 here. 

20 For the test conditions for heating mode, 

21 DOE identified ANSI/AHRI 210/240 which provides test 

22 conditions in heating mode for a heat pump with a 
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1 single-speed compressor and a fixed-speed indoor fan, 

2 similar to portable ACs. 210/240 provides three different

3 test 

4 conditions: high temperature, frost condition, and low 

5 temperature with the same indoor conditions but 

6 different outdoor inlet air conditions. 

7 DOE believes that the H1, the high 

8 temperature test conditions, are the most 

9 representative of typical heating mode use which 

10 would be -- portable ACs would be used, DOE believes 

11 would be used as supplemental heaters or for low 

12 capacity heating, and so therefore, DOE proposed in the 

13 NOPR that the following conditions be used during 

14 heating mode for indoor, for both dual and single15 duct units: a 70 degree Fahrenheit dry-bulb and 60 

16 degree wet-bulb temperature, and for the condenser 

17 inlet, for dual-duct, outdoor conditions would be 47 

18 and 43 dry and wet-bulb and the same indoor 

19 conditions for single-duct units. 

20 So for the adjusted heating capacity 

21 equation, the calculations in PAC-1-2014 would result 

22 in negative cooling, which is heating for capacity, so 
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1 DOES proposes to multiply the measured capacity 

2 according to PAC-1-2014 by negative 1 to represent 

3 heating capacity and that the negative heating values 

4 of the duct infiltration and case are added to the 

5 adjusted heating capacity. So DOE proposes that the 

6 adjusted heating capacity be calculated as follows. 

7 So DOE is seeking comment on the proposed 

8 test setup, rating conditions and conduct to 

9 determine heating mode performance for portable ACs. 

10 MR. BROOKMAN: Comments here? Okay, I see 

11 none. 

12 MR. SINGERMAN: Okay so for the last 

13 active mode that we are going to discuss, air 

14 circulation mode, just very briefly, DOE wants to note 

15 again that we do not have information on the 

16 prevalence of the consumer initiated air circulation 

17 mode, and therefore at this time, DOE is not proposing 

18 to measure this air circulation mode and would like 

19 to seek feedback on this proposal, and specifically if 

20 there is any usage information on this consumer 

21 initiated air circulation mode. 

22 MR. BROOKMAN: Jennifer? 
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1 MS. CLEARY: Jennifer Cleary. And I 

2 apologize because I just stepped out and I do have a 

3 comment on the comment box before as well and then 

4 this one. 

5 MR. BROOKMAN: Let's back up to that one 

6 please. 

7 MS. CLEARY: The heating mode -- so the 

8 AHAM certainly questions including this. Mainly, we are 

9 concerned about what appears to be a serious lack of 

10 data to support including this in the test procedure, 

11 and by that I mean consumer usage data. I really 

12 don't see a good understanding of how often consumers 

13 are using this feature and whether that would justify 

14 the burden of including this in the test procedure, 

15 and then to connect to the next comment box, where DOE 

16 is proposing not to include a measurement for air 

17 circulation mode because of the lack of data. 

18 So we agree with that, that in the absence 

19 of data DOE cannot proceed, and we would suggest that 

20 the same care needs to be taken in regard to the 

21 heating mode. 

22 MR. BROOKMAN: In the absence of data and 
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1 also generally speaking on other grounds, you would 

2 support this proposal? 

3 MS. CLEARY: Yes, to not include the extra 

4 test. 

5 MR. BROOKMAN: Correct. 

6 MS. CLEARY: Yes. 

7 MR. BROOKMAN: Other thoughts in response 

8 to this comment box, air circulation mode proposal, 

9 slide 47? Okay. 

10 MR. SINGERMAN: Okay, so now we are going 

11 to move on to off-cycle mode. So in the NOPR, DOE 

12 proposed a definition for off-cycle mode. It is a 

13 mode in which the portable AC has cycled off the main 

14 heating or cooling function based on a thermostat or 

15 the temperature sensor signal. It may or may not 

16 operate the fan or blower in this mode, and it will 

17 reactivate the main cooling or heating function again 

18 based on other thermostat or temperature sensors. 

19 So to conduct a test to determine the 

20 average power consumed during off-cycle mode is as 

21 follows: following a cooling mode test, that the set 

22 point part of the unit should be adjusted to a 
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1 temperature that is greater than the chamber 

2 conditions, which would then automatically cycle off 

3 the cooling function; that the adjustable 

4 fans be set to maximum possible; and that the off 

5 cycle mode energy consumption measurement begin 5 

6 minutes following the end of the last compressor 

7 cooling cycle. 

8 The power consumption would then be 

9 monitored for two hours. DOE proposed that there be 

10 a five minute window between the last compressor 

11 cooling cycle and the beginning of off-cycle mode 

12 to not penalize the utilization of cold evaporator 

13 coils to provide additional cooling to the room when 

14 the compressor has cycled off. 

15 DOE also proposed that the off-cycle mode 

16 test only be conducted once following cooling mode to 

17 then minimize test burden. So DOE is seeking comment 

18 on the proposed provisions for measuring energy 

19 consumption in off-cycle mode, including all the 

20 control settings, as well as measuring period start 

21 and duration, and also seeks comment on whether off22 cycle mode energy consumption would be independent of 
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1 the ambient conditions of the chamber. 

2 MR. BROOKMAN: Yes Joanna? 

3 MS. MAUER: Joanna Mauer. I just have a 

4 question about how these units are operating in off5 cycle mode. So when the fan is running in off-cycle 

6 mode, is it only the evaporator fan, and does that mean 

7 that no air is being exhausted outside or is some air 

8 being exhausted outside when the fan is running in off9 cycle mode? 

10 MR. SINGERMAN: I think it might vary 

11 depending upon manufacturer. Specifically, the fan 

12 operates to either dry off the evaporator coils, which 

13 are the indoor side, so that would be the primary fan 

14 that would be operating to circulate air through the 

15 room or to dry off the coils. But conceivably both. 

16 MS. MAUER: This is Joanna again. So the 

17 reason some units are exhausting the air outside off18 cycle mode -- that means that there is also being 

19 infiltration in off-cycle mode, and if that's the case, 

20 then you would think that should be incorporated also. 

21 But I would need to better understand first. 

22 MR. BROOKMAN: Ashley Armstrong? 
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1 MS. ARMSTRONG: I was just going to say 

2 you have a couple of manufacturers here that could -- 

3 MR. BROOKMAN: Can someone address 

4 Joanna's? Alberto? Turn the microphone on. 

5 MR. ALOISI: Thank you. Only the internal 

6 fan is usually working in the off-cycle mode, usually 

7 fan power. 

8 MS. MAUER: So that means that there's no 

9 air being exhausted outside when that internal -- 

10 when it's just that internal fan that is on. 

11 MR. ALOISI: Again, we don't view the 

12 infiltration as a real problem as I discussed before, 

13 so we -- the reason why we have not used the fan is 

14 not for infiltration, but because in this case it is 

15 not required. 

16 MR. BROOKMAN: Thank you. Yes Jim? 

17 MR. CRAWFORD: I think that this off-cycle 

18 mode that we are talking about is what is 

19 conventionally called continuous fan, is it not? I 

20 mean, normal air conditioning and heat pumps, 

21 continuous fans in the cooling mode or the heating 

22 mode, the fan runs whether the compressor is running 
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1 or not. 

2 MR. SINGERMAN: I think that it would be 

3 in that case, but also some of these units don't run 

4 the fan continuously when the set point is reached. 

5 They may cycle the fan, but it sounds like it's the 

6 same. 

7 MR. CRAWFORD: It would help wherever 

8 possible to use the terminology of the trade 

9 convention. 

10 MR. SINGERMAN: I think the issue then 

11 would be that it may be confusing because many of 

12 these units do not run the fan in this way in this 

13 mode. 

14 MR. CRAWFORD: I bet the tech could figure 

15 that out. 

16 I think it's worth noting 

17 that in the heating mode, we have used two digit 

18 imperial units for temperatures, not soft conversions 

19 from metrics, and I encourage that we do that. 

20 MR. BROOKMAN: Okay. 

21 MR. CRAWFORD: Now one of the reasons -- 

22 one of the justifications possibly for that is the 
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1 fact that the U.S. HSPF and such keep on measurements 

2 that are general enough, pretty broadly adopted in 

3 the world. 

4 MR. BROOKMAN: Okay, we are going to move 

5 on. 

6 MR. SINGERMAN: So now we are going to 

7 move on to standby and off modes and all of the 

8 subsequent modes that fall under that. So in the 

9 test procedure NOPR, DOE proposed the following for 

10 standby mode as a definition, which is common with 

11 many products that DOE covers. 

12 DOE also proposed inactive mode, which is 

13 a standby mode which facilitates activation of active 

14 mode by a remote switch, internal sensor, timer, that 

15 provides continuous status display. In the NOPR, DOE 

16 discusses two other low power modes that are not 

17 measured. The first is bucket full mode, which is 

18 initiated when the condensate level in the internal 

19 collection tank reaches some threshold that the 

20 manufacturer has set. 

21 During this mode, active modes are 

22 disabled and will be reactivated when the collection 
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1 tank is drained or emptied. The other mode is the 

2 delay start mode which has -- DOE found has 

3 comparable power consumption levels to inactive mode 

4 and is a mode that facilitates the activation of an 

5 active mode via a timer but does not persist for an 

6 indefinite period of time. 

7 So regarding these low power modes, DOE 

8 expects the power draw of all of them would be 

9 similar for inactive, bucket full and delayed start. In order

10 to reduce the test period and to just simplify the 

11 testing, DOE is proposing to measure the power 

12 consumption for only inactive mode and not the other 

13 two, and that the annual hours associated with the 

14 delay start and bucket full mode, which DOE expects to 

15 be low, would then be combined with those operating 

16 mode hours. 

17 Just note in DOE's test sample, all of 

18 the units had electronic controls and defaulted to 

19 inactive mode when they were connected to the power 

20 source. However, DOE is aware that some units may be 

21 capable of entering off mode, and those are likely units 

22 with electromechanical controls. 
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1 So for those units that would enter off 

2 mode, DOE has proposed the following definition for 

3 off mode, which is consistent with many other 

4 products. For standby and off mode, to determine the 

5 power consumption, DOE proposed in the NOPR that 

6 inactive mode and off mode for portable ACs be 

7 tested according to the IEC Standard 62301, which is 

8 in accordance with the requirements of the Energy 

9 Independence and Security Act of 2007. 

10 DOE also included some clarifications for 

11 this proposal: that the testing may be conducted at 

12 the cooling mode or heating mode test conditions, as 

13 they meet the IEC Standard 62301 conditions and 

14 tolerances; that the electrical supply voltage would 

15 be maintained at 115 volts plus or minus 1 percent, 

16 similar to a cooling mode; and the same for the 

17 frequency. 

18 Also, the inactive mode and off mode 

19 testing should be conducted after the power level has 

20 dropped to the lowest level. So DOE seeks comment on 

21 the proposed definitions, as well as the provisions 

22 for measuring energy consumption in standby, inactive 
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1 mode, and off mode. 

2 MR. BROOKMAN: Comments -- you see the 

3 comment box, standby mode and off mode proposals. No 

4 comments here? Okay Jim, go ahead. 

5 MR. CRAWFORD: The bucket-full mode is 

6 that kind of a new mode? 

7 MR. SINGERMAN: It would be a mode in 

8 which the unit is operating in cooling mode, condensates 

9 collecting, and either the auto evaporation feature 

10 can't keep up or the drain plug is in and there is no 

11 other evaporation, and the manufacturer has set a 

12 certain safety threshold how to shut the unit off. 

13 MR. CRAWFORD: Didn't I understand that 

14 they all have auto evaporation? 

15 MR. SINGERMAN: Right. So all of the units 

16 in DOE's test sample had auto evaporation. However, 

17 it's possible there are units without auto 

18 evaporation. 

19 MR. CRAWFORD: And you tested 36 to 38? 

20 Did they all keep ahead of the condensate? 

21 MR. SINGERMAN: Yes. 

22 MR. CRAWFORD: Okay, so this is testing for 
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1 an anomaly, basically. It's just something doing what 

2 it is designed to do. 

3 MR. SINGERMAN: That was why we were not 

4 proposing to measure -- 

5 MS. ARMSTRONG: You just made our case for 

6 us. That's why I'm proposing not to do it. 

7 MR. BROOKMAN: So that was actually -- so 

8 we agree. Jim Crawford, do you wish to agree? 

9 MR. CRAWORD: I would not consider 

10 disagreeing with it. 

11 MR. BROOKMAN: Thank you Jim Crawford. 

12 Additional comments here on standby modes and off 

13 mode proposals? Let's take a break. It's about 

14 10:50. Let's take a 15 minute break. Please make sure 

15 to wear this badge visible as you walk around the 

16 Forrestal building. There are restrooms on both ends 

17 of the hall. We are going to break for fifteen 

18 minutes, which means we will resume at 5 minutes after 

19 1 here in the room, and thanks for a good start. We 

20 have covered a lot of ground already. And probably 

21 when we return, if we make our way through the test 

22 procedure portion and start on standards, we are just 
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1 going to plug on there for a while, probably pause 

2 for lunch around about 12:30 or in that general range 

3 somewhere, okay. 

4 (OFF THE RECORD - 15 minute break) 

5 MR. BROOKMAN: Let's resume. Please take 

6 your seats and let's get started. So let me note 

7 that I think the quality of the comments were 

8 excellent so far this morning, and we are going to 

9 proceed where we left off with Nadav. 

10 MR. SINGERMAN: So up until now I've been 

11 discussing the cooling capacity, heating capacity 

12 and the average power in each mode. Now we are going 

13 to move on to the proposal that DOE included in the 

14 NOPR regarding the energy efficiency ratio, with a 

15 combined energy efficiency ratio. 

16 So the combined energy efficiency ratio, or 

17 the CEER, combines energy use for active mode, standby 

18 mode, off-cycle mode and off mode into one single 

19 efficiency metric. First, the cooling and heating 

20 capacities as we have discussed previously are measured 

21 and the total annual energy consumption is then 

22 calculated for a specific unit, using a weighted 
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1 average that is based on the annual operating hours 

2 in each mode and the average power associated 

3 with each of those modes. 

4 However, in order to proceed with the 

5 calculation, it is necessary to identify the cooling 

6 and heating season lengths and then determine the 

7 annual mode, specific mode operating hours in each of 

8 the seasons as well as the rest of the year. So to 

9 move forward, first DOE investigated cooling and 

10 heating season lengths. 

11 For the cooling season length, DOE proposed 

12 the same number of hours as in the room AC rule being 

13 proposed for the portable AC rule, which was 2,160 

14 hours. For the heating season length, DOE produced 

15 three estimates. The first was based on the furnace 

16 fan rulemaking, which was 4,160 hours. Then DOE came 

17 up with two more estimates. The first looked at a 

18 2012 national climate analysis of all hours at less 

19 than 55 degrees. 

20 DOE identified 55 degrees as the threshold 

21 based on the New York City building heating season 

22 length. DOE then looked at a third estimate, which 
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1 looked at hours less than 45 degrees. We adjusted the 

2 climate analysis and came up with 2,903 hours. 

3 DOE reduced the specific temperatures 

4 because it believes that correlates to each season, as 

5 portable ACs are primarily used as supplemental 

6 heaters with lower temperatures. And just to briefly 

7 go over the analysis that DOE produced -- went through 

8 to first determine the number of hours for each state 

9 associated with each temperature, so within each 

10 temperature bin, a number of hours for each state. 

11 Then DOE identified portable AC ownership 

12 based on the room AC data that's in RECS to determine 

13 the ownership in regions, sub-regions and specific 

14 states, and then used the weighted-average approach to 

15 combine the number of hours at or below the certain 

16 temperature threshold to determine the sub-region or 

17 regional and then the national hours at less than 

18 those temperatures. So that's where we came up with 

19 estimates two and three. 

20 So for the annual mode operating hours, 

21 that was the season lengths for the operation hours 

22 themselves. DOE based the cooling season mode 
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1 operating hours on the room AC rulemaking. For the 

2 portable ACs, off-cycle mode would include fan only 

3 mode hours due to the room AC rulemaking, and 

4 portable ACs inactive and off mode hours would 

5 include delay start and bucket full mode hours from 

6 the room AC rulemaking we had discussed previously. 

7 DOE assumed that the percentage of operating 

8 time for each mode within heating season would be the 

9 same as that for cooling season. Outside of cooling 

10 and heating season, DOE assumed that three-quarters of 

11 portable ACs are unplugged completely, and that a 

12 quarter of them are unplugged half the time. This 

13 was based on the fact that they are portable units 

14 and easily moveable from room to room and removed 

15 from the window, and therefore would primarily be 

16 unplugged outside of the cooling and heating season. 

17 DOE associated all plugged-in hours 

18 outside of the cooling and heating season as inactive 

19 hours. So based on those assumptions, DOE provides 

20 the operating mode hours based on the cooling-only 

21 room AC estimates, so that's the second column for 

22 cooling only. And then three other heating season 
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1 estimates for the cooling mode operating hours based 

2 on the heating season length estimates that we 

3 presented previously. 

4 For units with heating capability, DOE 

5 proposed in the test procedure NOPR that the cooling/ 

6 heating estimate three be used, and DOE expects that 

7 portable ACs are used as supplementary heating 

8 during periods of cool outdoor temperatures at less 

9 than 45 degrees Fahrenheit. So that's why the 

10 estimate number three was proposed. 

11 DOE also presented alternate cooling 

12 season scenarios in the NOPR. This is based on a 

13 recent study that developed a model to estimate the 

14 amount of time spent or the percent of time spent in 

15 cooling, fan only, and standby modes as a function of 

16 the outdoor temperature. After analyzing this report, 

17 DOE expects that the modes in the study align with 

18 cooling mode, off-cycle mode, and inactive/off mode as 

19 previously defined. 

20 The study identified two applications of 

21 portable ACs. The first was residential use where the 

22 consumer has daily interaction with the product, and 
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1 then consumer use where there is minimal consumer 

2 interaction. DOE then, to determine the number of 

3 hours and percent of time spent in the modes, had to 

4 come up with representative outdoor temperature. So 

5 DOE determined an average outdoor temperature for 

6 each state based on the national climate data from 

7 June through September as representative of the 

8 cooling season, and then used a weighted-average 

9 approach similar to before based on the RECS data. 

10 And DOE ended up determining that a representative 

11 average cooling season outdoor temperature was about 

12 70 degrees Fahrenheit. 

13 So using this metering study, DOE 

14 calculated the percent of time spent in each mode in 

15 the cooling season and then -- which is represented 

16 in the second and third column, and then also 

17 determined a third scenario which was an average of 

18 the residential and the consumer use scenarios. And so 

19 the result is that for a cooling mode -- a cooling 

20 season of 2,168 hours, cooling mode operating hours 

21 would be 126, 187, and 507 hours in the different 

22 scenarios. 
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1 If this approach were to be adopted, then 

2 the proposed off-cycle and off mode hours would then 

3 have to be updated from that table that I had 

4 previously. 

5 So DOE seeks comment on the proposed cooling and 

6 heating season length and the mode operating hours 

7 that would then be used to calculate combined energy 

8 efficiency ratio. 

9 MR. BROOKMAN: Jennifer Cleary? 

10 MS. CLEARY: I'm Jennifer Cleary with 

11 AHAM. AHAM is dismayed, I guess, at the serious lack 

12 of data underlying this proposal. You know, the 

13 amount of time just on these slides, and even more 

14 numerous in the proposed rule, that DOE talks about 

15 assumptions in estimates is alarming. I think these 

16 annual mode operating hour assignments have really 

17 led to what the outcome is going to be in the final 

18 outcome -- in a sense randomly assigning hours is 

19 not appropriate. So DOE is assuming percentage of 

20 operating time, they are assuming the usage outside 

21 of cooling and heating season, and there is not much 

22 basis for these assumptions. 
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1 So either they are -- you are comparing to 

2 other products that may or may not have similar usage 

3 patterns to this product, using data from previous 

4 rulemakings that may not carry over here. There's 

5 really no description as to even why those products 

6 should be looked at in terms of if they have had similar 

7 usage to portable air conditioners, and we would argue 

8 that in fact, many of them do not. 

9 So I would think DOE needs to do a much 

10 better job on using that consumer use data for this 

11 product that we are going to determine what the 

12 operating hours should be. In particular, looking at 

13 the heating mode, you know, I commented on that earlier 

14 that there needs to be more data on the issues raised 

15 here. DOE seems to be assuming that consumers will 

16 use portable air conditioners in heating modes when 

17 it is the very coldest out, and we disagree with that. 

18 AHAM believes that actually these products 

19 would be used more often by consumers when it is not 

20 as cold out, for example when you are not quite ready 

21 to turn the heat on, ready to turn the air 

22 conditioner off, so we will provide more detail in our 
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1 written comments on all of this but the bottom line 

2 is there needs to be some real data underlying this, 

3 not just we don't have data, therefore we assume x, y 

4 or z. 

5 MR. BROOKMAN: Jennifer, do you know of any 

6 additional data, any sources for -- do you have the 

7 capacity at AHAM to gather some? 

8 MS. CLEARY: I don't know if we currently 

9 have consumer usage data for this product, but we will 

10 certainly look into what we have. We are willing to 

11 work with the Department and are supportive of this 

12 overall effort, so we can certainly see what we can 

13 do. We will urge individual companies, to the extent 

14 that they have this type of information, to share it. 

15 So we are working on seeing what we have. So we are 

16 not here just to criticize you for the lack of data. 

17 If we have it to provide, we will. But I think the 

18 important thing to point out there is, even if we 

19 don't have it and can't provide it, or companies don't 

20 have it and can't provide it, that that doesn't mean 

21 that DOE should then just say, well we asked for the 

22 data and we did not get it and therefore we will 
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1 proceed with our assumptions. 

2 DOE still needs to get this data, even if 

3 we cannot provide it. 

4 MR. BROOKMAN: Okay, thank you. You see 

5 the comment request there on operating hours. 

6 Additional thoughts, comments here? 

7 MR. WUESTHOFF: Yes, this is Ed Wuesthoff. 

8 MR. BROOKMAN: Yes, Ed. Please go ahead. 

9 MR. WUESTHOFF: I wanted to also state 

10 that Friedrich is an air conditioner manufacturer, and 

11 the portable air conditioners that we also sell, we 

12 rate our energy consumption based on 750 hours, 

13 currently the same we have to use in room air 

14 conditioners, and the ones we sell, they are all below 

15 100 kilowatt-hours per year based on that way of 

16 calculating annual energy consumption. 

17 So we would favor using the same energy 

18 usage hours for cooling mode as a room air 

19 conditioner, which is 750 hours. And I also wanted to 

20 comment about the cooling season of 70 degrees. It 

21 seems rather low for an outdoor temperature to be 

22 using air conditioning. I would assume it would be 
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1 more like 80 degrees as a starting point. 

2 MR. BROOKMAN: Okay, thanks Ed. 

3 MR. WUESTHOFF: You are welcome. 

4 MR. BROOKMAN: We are about to move on. 

5 Final comments? Okay. 

6 MR. SINGERMAN: Okay. DOE proposed the 

7 calculation for energy efficiency ratio in the NOPR. 

8 This is performed using the adjusted cooling and 

9 heating capacity that we discussed previously, as well 

10 as the average power in both cooling and heating mode 

11 as seen on the slide. And just to note that, due to 

12 variations in the operating mode hour estimates, the 

13 preliminary analysis for the concurrent energy 

14 conservation standards rulemaking, which will be discussed

15 later, 

16 used the cooling mode EER as a basis for efficiency 

17 levels. 

18 DOE also proposed equations and 

19 calculations to determine the annual energy 

20 consumption for each of the modes that we have 

21 discussed, using the mode annual hours as well as 

22 the average power in that mode. DOE proposed a 
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1 summation of all modes other than cooling and heating 

2 mode to determine the annual energy consumption of 

3 those modes, and then used these equations to 

4 calculate the annual operating costs that is proposed 

5 in 10 CFR 430.23. So let's move on to the combined 

6 energy efficiency ratio. 

7 DOE proposed a cooling-only CEER, and when 

8 calculating this, the operating hours used are 

9 the cooling only that were in that first table with 

10 the mode operating hours. DOE also proposed an 

11 overall combined energy efficiency ratio for units 

12 with both cooling and heating, and just to note that 

13 for units with no heating mode, that this overall CEER 

14 would simplify to the cooling-only CEER above, and that 

15 for units with heating mode, where this full CEER is 

16 used, DOE is proposing that the estimate three be 

17 used to calculate the CEER. 

18 So DOE seeks comment on the proposed 

19 equations to calculate the cooling mode CEER as well 

20 as the overall CEER and incorporate performance for 

21 both cooling and heating modes in addition to all the 

22 other low power modes. 
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1 MR. BROOKMAN: Thoughts here? Nothing at 

2 this time, okay. 

3 MR. SINGERMAN: Okay, so a few last things 

4 with the sampling plan and rounding requirements from 

5 the NOPR. The first is that DOE proposed, as they do 

6 for other similar products, that the rounding -- that 

7 the sampling plan requirements for an efficiency 

8 method would be applicable, as well as rounding 

9 requirements for the cooling and heating capacity. And 

10 values of the EER and the CEER would be the mean of 

11 all measured values in each tested unit of the basic 

12 model, and that all the capacities would be rounded to 

13 the nearest 50, 100, 200 or 500 BTU per hour, according 

14 to Table 1 in PAC-1-2014, and that the EER and the 

15 CEER would be rounded to the nearest 0.1 kilowatt16 hours. 

17 DOE also in the NOPR noted that it 

18 identified one small business manufacturer with 

19 manufacturing facilities in the United States. DOE 

20 notes that it selected PAC-1-2014's approach to help 

21 minimize active mode test 

22 burden. Manufacturers commonly report the cooling 
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1 capacity and the EER according to ANSI/ASHRAE 

2 Standard 128, and PAC-1-2014 is an industry-accepted 

3 standard that utilizes similar test equipment and the 

4 same basic methodology as ANSI/ASHRAE Standard 128. 

5 Regarding off-cycle standby and off mode 

6 test procedure impacts, IEC Standard 62301 may be 

7 conducted in the same test chamber as either cooling 

8 or heating mode, and so there is minimal additional 

9 testing costs in terms of moving the unit. And DOE 

10 identified the wattmeter that would satisfy the requirements

11 for these tests would be approximately $2,000. So 

12 based on this, DOE concluded that the proposed rule 

13 would not have significant economic impacts on small 

14 entities. 

15 So DOE seeks comment on the testing burden 

16 and tentative conclusion that both test 

17 procedures would not be burdensome to conduct. 

18 MR. BROOKMAN: Comments on test burden? Yes, Jim 

19 Crawford. 

20 MR. CRAWFORD: You indicated that there 

21 was one small business. Is it DOE -- has that 

22 business requested exemptions and is it the intention 
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1 to grant exemption? 

2 MR. BROOKMAN: Ashley Armstrong? 

3 MS. ARMSTRONG: So no, there's been no 

4 obligation, but there is also nothing for them to be 

5 exempt to, since there are not rules in place yet. 

6 MR. BROOKMAN: Okay, yes. Jennifer Cleary? 

7 MS. CLEARY: Jennifer Cleary. I think we 

8 will have comments on this in our written comments, 

9 but I think we question whether this is -- and some 

10 of the changes that are being proposed to PAC-1. I'm 

11 not sure yet and thinking about it, and certainly will 

12 provide feedback and written comments. 

13 MR. BROOKMAN: Thanks. And now as we had 

14 said at the outset, we are at the conclusion of this 

15 portion of the meeting the test procedures portion, 

16 we would welcome any final comments, concluding 

17 remarks, brief statements about issues that haven't 

18 been covered sufficiently during the course of the 

19 meeting today. 

20 MR. BERRINGER: Does anybody have any 

21 other remarks on the test procedure? 

22 MR. BROOKMAN: No additional comments 
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1 here, okay. 

2 MR. BERRINGER: Well Nadav thank you for 

3 that great presentation today and thank you everybody 

4 for your participation. The slide we have right now 

5 is again we are -- the comments that are made today 

6 are recorded and a transcript will be made available 

7 as part of the docket, part of the public record. 

8 Again, the written comments from the proposed 

9 rulemaking open until May 11th. Please reference the 

10 docket number and RIN number. There is an email address

11 here. 

12 You could also mail something to Brenda Edwards here or

13 courier. 

14 The information is there. 

15 So again, I thank everybody for their 

16 participation and at this point since there's no 

17 additional comments, we were going to go on to 

18 standards. 

19 MR. BROOKMAN: Jim Crawford has a question 

20 or a comment. 

21 MR. CRAWFORD: Do we know when that 

22 transcript will be available? 
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1 MR. BROOKMAN: As soon as possible. 

2 MR. BERRINGER: Probably about two weeks 

3 by the time that we get it from there, two to three 

4 weeks, and we will have it posted. But we have to 

5 review the transcript ourselves to make sure it is 

6 acceptable, and we are going to post it on -- we will 

7 be posting it. 

8 MR. BROOKMAN: Another comment? 

9 MS. MARCHETTI: Len? 

10 MR. BROOKMAN: Apparently Len has a 

11 comment, joining us online. Len, you are now unmuted. 

12 MR. SWATKOWSKI: This is Len Swatkowski 

13 from OceanAire, and I didn't hear it mentioned during 

14 any of that discussion today the impact on commercial 

15 portable air conditioning, and since we have been 

16 working with national association of manufacturers 

17 company and have developed and submitted a definition 

18 for commercial portable air conditioners, can I 

19 assume that the comments you have made so far are 

20 exclusive of that small category of products? 

21 MR. BROOKMAN: Ashley Armstrong? 

22 MS. ARMSTRONG: This is Ashley from DOE. 
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1 One of the first things we discussed at the very 

2 beginning of the webinar, actually, when we were 

3 having problems with the webinar, which could be why 

4 you may not have had an opportunity to see it, was the 

5 definition of portable air conditioner and the scope 

6 of applicability of the test procedure. 

7 So as DOE believes that the portable air 

8 conditioners are all encompassing to those products, 

9 that we have needed DOE to clarify that, you know, the 

10 test procedures being addressed today did not 

11 specifically -- do not apply to spot coolers as we 

12 define them in the proposed rule. So there were some 

13 comments earlier about perhaps the definition being 

14 too narrow and DOE should consider modifications for 

15 that definition, especially those that may come during 

16 written comments. Obviously, if you have specific 

17 comments about what should and shouldn't be included 

18 in that definition or what should or shouldn't be put 

19 in terms of scope of the test procedures we are 

20 talking about this morning, we welcome that. 

21 MR. SWATKOWSKI: We had sent comments in a 

22 couple of weeks ago specific to that, and I assume we 
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1 are not going to drop the definition of commercial or 

2 portable air conditioner today. 

3 MS. ARMSTRONG: I think if you have a 

4 position on whether the test procedure should apply 

5 and whether standards should apply to what you are 

6 calling commercial portable air conditioners, you 

7 should present that on the record so that we have it. 

8 DOE did receive some feedback regarding commercial 

9 -- obviously, I think it would be helpful though for 

10 you to present your position to the group because 

11 then other people than DOE, then everyone can hear 

12 it. 

13 MR. SWATKOWSKI: Okay, well we have already 

14 provided comment about how the kind of -- being a small 

15 company with 10 or 15 people, there's only three 

16 manufacturers here in the U.S. that this would have a 

17 severe economic impact on, and I'm kind of wondering 

18 if that has been taken into account when you thought 

19 about small business and then, because it's not 

20 negligible, but I think it would be devastating to us. 

21 While we were looking more towards having 

22 exclusion for commercial because it's such a small 
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1 part of the portable air conditioning market, that we 

2 didn't provide those comments as well, but we can in 

3 our written remarks. 

4 MR. CYMBALSKY: This is John from DOE. 

5 Thank you for that. Slide 16 actually comes in a 

6 statement from the slide. You can see it now on your 

7 screen. All of those coolers would meet the proposed 

8 definition of portable ACs. DOE is not considering 

9 the test procedure for spot coolers at this time, so 

10 therefore -- I'm sorry, can I finish please? Therefore, 

11 the small business owners quoted do not reflect this 

12 point that we made here on the slide. 

13 MR. BROOKMAN: Please keep going. 

14 MR. SWATKOWSKI: I just wondered, did that 

15 spot cooler definition include the commercial 

16 portable air conditioners? 

17 MS. ARMSTRONG: This is Ashley from DOE. 

18 I think you need to refer to the actual definition in 

19 the proposed rule, and if you do not feel that it 

20 encompasses what you are calling commercial you 

21 should comment on that. I mean, generally speaking, I 

22 don't know exactly what you are calling commercial, 
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1 but generally speaking, DOE believes that that was the 

2 intent. 

3 MR. SWATKOWSKI: Okay. 

4 MR. BROOKMAN: Okay, thanks Len. That is -- 

5 we are drawing to the conclusion of the test 

6 procedure portion of this meeting. Final comments 

7 and any additional comments before we close out? Jim 

8 Crawford. 

9 MR. CRAWFORD: I want to come back on that 

10 same chart I guess. What -- as Ashley points out, there 

11 is no distinction between residential and commercial 

12 in the wording of that paragraph that she said a 

13 moment ago. The wording throughout, residential, 

14 residential and consumer, and the author didn't seem 

15 to have commercial in mind. And if I can take you back 

16 to the chart on 16, are we to interpret that the 

17 scope of today's discussion, morning and afternoon, is 

18 limited to the capacity range of 5,000 to 14,000 

19 BTU's per hour? 

20 MS. ARMSTRONG: I think you should think 

21 about the scope. This is Ashley with DOE. So 

22 starting with the definition on top, you should think 
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1 of the scope of today's discussion as any product 

2 that would meet that definition with the exception of 

3 we have said that this test procedure as proposed 

4 today is not applicable to spot coolers. So that 

5 leaves single-duct and dual-duct. And can you go to 

6 the next slide. 

7 So this is what we believe the general 

8 characteristics are. So if we got it wrong, please 

9 provide feedback on it if those characteristics are 

10 applicable or are all encompassing. 

11 MR. CRAWFORD: No one is suggesting you 

12 got it wrong. The question had to do with whether or 

13 not we should assume that the scope is limited to 

14 5,000 to 14,000 BTU's per hour. 

15 MS. ARMSTRONG: So there's not a specific 

16 implementation of scope with regard to capacity in 

17 the definition of what is defining the covered 

18 products. 

19 MR. CRAWFORD: If you don't have a test 

20 procedure, this leads us to believe that this 

21 morning's discussions deal with product between 5,000 

22 and 14,000 BTU's per hour. That's what we have been 
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1 led to believe here, and we are anticipating that this 

2 afternoon's discussion is going to deal with 

3 proposals related to performance standards for 

4 equipment. 

5 Will the performance standards being 

6 verified by the test procedure of this morning's 

7 discussion, which means that this implies that the 

8 capacity range for this afternoon's discussion was 

9 5,000 - 14,000. 

10 MS. ARMSTRONG: Thanks. So I am going to 

11 try to clarify this one more time. So DOE believes 

12 our scope of coverage and our capability of the test 

13 procedure and standards when we get there, at least 

14 what proposals are going to be based on these 

15 definitions -- so what I am trying to tell you is 

16 that these definitions don't actually have all of 

17 those characteristics listed in them explicitly. 

18 However, based on DOE's own market 

19 research, based on DOE's testing, based on DOE's 

20 teardowns of physical units, based on DOE's talking 

21 to people within the industry for their manufacturer 

22 interviews, the characteristics shown on slide 16 are 
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1 the general characteristics of products we feel would 

2 meet those definitions. 

3 Thus, that's what's reflected in the 

4 analysis. However, these specific points arent in the 

5 actual definition, so if there is a product that has 

6 characteristics other than those general 

7 characteristics shown on slide 16 that would 

8 otherwise meet these definitions, they would be in. 

9 MR. BERRINGER: This is Bryan. You had 

10 mentioned, and all I heard earlier was in the 

11 definition, you were talking about three phase versus 

12 single phase, and the definition is calling out single 

13 phase. But you did indicate earlier that there are 

14 commercial units that would be a single-phase 

15 application. 

16 MR. BROOKMAN: Jim Crawford again? 

17 MR. CRAWFORD: Let me take an example. 

18 Company X decides to make 100,000 BTU per hour, dual19 duct unit. And they are dumb enough to do a single 

20 phase, okay. And they do it -- 

21 MR. BROOKMAN: Ashley says it's in. 

22 MS. ARMSTRONG: Otherwise meets the 
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1 definition. If it meets the definitions on this 

2 slide, it would be in. 

3 MR. CRAWFORD: Slide 16 doesn't mean a 

4 whole lot. 

5 MS. ARMSTRONG: Slide 16 means what we 

6 based our analysis on. Of those products out there 

7 today, however, like I said, those characteristics are 

8 not in our definitions and our definitions are what are 

9 defining scope. 

10 MR. CYMBALSKY: Someone wants to make 

11 14,001, which is probably a more realistic. 

12 MR. BROOKMAN: So that was John Cymbalsky. 

13 Thank you John. So we have established that chart's 

14 illustrative based on what they have found so far, 

15 okay. So now, thanks for these comments, thanks for 

16 those clarified remarks Ashley and John, both of you. 

17 Any additional comments as we move toward closure 

18 here? Okay, Bryan has already shown how you submit 

19 your comments. 

20 MS. ARMSTRONG: Bryan, before you 

21 transition, we may just turn off the webinar because we 

22 have a separate transcript. 
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1 MR. BROOKMAN: Right, and I thought we -- 

2 MS. ARMSTRONG: I do want to ask everyone. 

3 We have two options. 

4 So we have two options. We can continue. 

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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A

a.m 1:17 4:2

ability 44:6

able 10:8

absence 64:18,22

AC 16:20,22 17:22

19:6,16,21 23:11

28:1 30:6 31:7

46:9,12 57:14

65:13 76:12,13

77:11,12 78:1,3,6

78:21

AC's 36:15

acceptable 91:6

accepted 55:12

accessible 10:3

accommodate 60:8

accomplish 32:3

account 31:3 40:8

41:2 42:1,7,13

45:15 93:18

accounting 35:7

accumulated 42:17

42:20

accuracy 49:16

achieve 44:6 58:15

acknowledges 41:10

ACs 12:21 16:9

17:18 21:5,9 23:3

29:3 30:21 36:13

36:13 37:10 46:13

50:2 62:2,10 63:9

72:6 77:5 78:2,4

78:11 79:7,21

94:8

Act 17:6 72:9

action 34:3

activated 23:12,19

24:2 58:2

activation 24:3

70:13 71:4

active 23:4,5,6,9,10

23:16 25:7,9

27:16,20,21 61:12

63:13 70:13,21

71:5 75:17 87:21

actual 56:16 94:18

98:5

add 13:21

added 63:4

addition 10:13

40:16 41:7 86:21

additional 9:4 10:10

15:20,21 22:19

30:4 31:2 32:6,11

35:15 44:16,17

45:17 48:12 49:8

53:6,6 55:17 57:1

60:12 61:5 66:13

74:12 83:6 84:6

88:8 89:22 90:17

95:7 99:17

address 22:15 38:22

68:3 90:10

addressed 50:4

92:10

adhered 49:13

adjacent 42:22 43:4

adjustable 58:12

66:3

adjusted 50:9,19

51:13 52:21 62:20

63:5,6 65:22 77:1

85:8

adjustments 52:8

56:10

adjusts 24:18

adopted 70:2 81:1

adoption 13:22 14:7

41:3

Affairs 13:14

affect 44:5

affiliation 5:21

afternoon 5:4 11:5

13:3 17:19 42:19

95:17

afternoon's 97:2,8

agenda 7:12,20 9:7

ago 92:22 95:13

agree 32:5 39:8

64:18 74:8,8

AHAM 2:22 13:19

29:10 30:13,18

31:10,11 32:4

33:9 39:5 46:2,16

47:15 50:22 51:5

51:7,10,15,19,21

52:5 56:10,19

64:8 81:11,11

82:18 83:7

AHAM's 28:1,14

32:3

ahead 4:16,19 8:9

18:4 44:18 73:4

73:20 84:8

AHRI 40:9 41:7

air 1:2 4:4 9:19 11:2

13:16,18,22 14:2

14:6,8,10,15,22

15:4,10 17:5

18:16 19:1,2,5,6,8

19:11,14,16,17,19

19:19 23:14 24:6

24:7,11 25:16

26:1,3,9,9,11 27:1

27:6,8 28:4,5,8,18

29:4 30:7 31:4,21

34:11 35:5,9 36:2

36:3,8,16,19,21

36:22 37:3,9,12

37:14,16 38:1,5,5

38:8,9,14,16,20

39:1,3,6,11,16

40:8,15,17,17,19

40:20,21 41:2,3

41:11,14,19 42:2

42:3,4 43:3,5,7,11

43:15,20,21 44:4

44:12,15 45:2,3

45:10,15,17 46:14

46:15,21 50:10,20

51:2 52:21 53:14

53:21 54:5 58:11

61:2 62:6 63:13

63:16,18,21 64:16

65:8 67:7,7,14,17

68:9,20 82:7,16

82:21 84:10,11,13

84:18,22 91:15,18

92:5,7 93:2,6 94:1

94:16

alarming 81:15

Alberto 2:9 6:6

13:13 33:7 39:7

55:15 59:18 68:4

align 79:17

allow 15:4

allows 15:7

Aloisi 2:9 6:6,6

13:13,13 33:8

39:8 55:16 59:19

60:3,11 68:5,11

alternate 55:13

79:11

AMAM 30:20

ambient 42:7,15,15

42:18 46:1 47:14

67:1

America 2:11,13

6:5

American 31:19

48:7

Americas 3:4

amount 40:17 45:13

79:14 81:13

analyses 9:1

analysis 8:19,20,21

8:22,22 11:6 12:6

13:2 16:13,16

17:17 30:10 76:18

77:2,7 85:13 98:4

99:6

analyzing 28:9

79:16

and/or 43:2

animal 54:2

annual 25:2 71:13

75:21 76:1,7

77:20 81:16 84:16

85:19,21 86:2,4

anomaly 74:1

ANSI 49:10

ANSI/ 46:15

ANSI/AHRI 61:21

ANSI/ASHRAE

28:2,18 29:22

58:19 61:16 88:1

88:4

answer 55:3

anticipating 97:1

anybody 7:15 9:4

16:18 24:15 89:20

apologies 33:21

34:2

apologize 64:2

apparatus 60:20

Apparently 91:10

Appearances 2:1

3:1

appears 64:9

appendix 18:1,8

23:1

appliance 3:5 6:11

6:12 56:4

appliances 2:9,10

2:12 6:7,9 13:15

15:2 42:11

applicability 92:6

applicable 43:19

58:22 61:17 87:8

96:4,10

application 20:9

98:15

applications 20:12

21:22 22:6,7

79:20

apply 92:11 93:4,5

appreciate 4:13

15:16 56:17

approach 14:7 28:5

28:16 30:14,22

35:21 36:5 39:2

39:10 42:6,12

51:6,7,10 52:12

77:14 80:9 81:1

87:20

approached 28:14

approaches 17:13

approaching 53:15

appropriate 40:5

53:12 55:6,7,11

81:19

approximately

88:11

area 15:5 49:20

50:15 58:10

arent 98:4

argue 82:7

Armstrong 2:7 6:18

6:18 67:22 68:1

74:5 89:2,3 91:21

91:22 93:3 94:17

95:20 96:15 97:10

98:22 99:5,20

100:2

ASAP 3:5

Ashley 2:7 6:18

67:22 89:2 91:21

91:22 94:17 95:10

95:21 98:21 99:16

ASHRAE 46:16

49:10

asked 83:21

assertion 41:19

assessment 8:18

assigning 81:18

assignments 81:16

associated 41:8

42:10 71:13 76:2

77:9 78:17

association 6:11

91:16

assume 37:22 83:3

84:22 91:19 92:22

96:13

assumed 37:16

49:18 78:7,10

assuming 81:19,20

82:15

assumptions 78:19

81:15,22 84:1

attached 57:6

attic 41:15

author 95:14

auto 20:17 57:16,18

73:9,14,16,17

auto-evaporation

57:10 59:15

automatically 66:2

availability 17:12
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Avenue 1:8

average 17:8 41:6

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85:10,22

aware 71:20

Awareness 3:5 6:13

B

back 10:18 17:3

32:12,16 36:19

37:12 53:2,4,5

64:5 95:9,15

backwards 25:21

badge 74:15

balance 36:18

balanced 45:13

Baltimore 4:8

based 23:19 28:4

29:1,20,21 34:15

34:17 38:14 41:18

47:14 50:19 52:15

52:17 54:12 61:15

65:14,18 76:1,15

76:21 77:12,22

78:13,19,20 79:1

79:12 80:6,9

84:12,15 88:12

97:14,18,19,19,20

99:6,14

baseline 28:15 29:2

29:10,13 50:22

52:5

basement 41:15

43:3

basic 87:11 88:4

basically 4:14 10:22

12:13 17:7 59:2

74:1

basis 30:20 31:2,7

81:22 85:16

beginning 57:22

66:11 92:2

behalf 6:1

beings 42:11

believe 50:3 55:10

55:19 59:22 60:6

96:7,20 97:1

believes 58:14 62:7

62:10 77:4 82:18

92:7 95:1 97:11

benefit 10:16

Berkeley 2:19,21

Berringer 2:4 4:10

4:11 10:18,20

16:4 89:20 90:2

91:2 98:9

Besant 2:12 7:6,6

best 32:3

bet 69:14

better 35:22 54:15

67:21 82:10

big 55:20

bin 77:10

bit 13:2 32:9

bizarre 48:5

blower 24:2,10

59:20 65:16

blowing 26:9

bottom 38:19 54:4

83:1

bowed 53:5

box 16:6 48:13 64:3

64:15 65:8 73:3

boxes 16:14

break 4:22 7:22

8:12 33:13,15,19

34:3 61:8 74:13

74:14,17 75:4

breaking 34:8

Brenda 90:12

brevity 15:16

brief 7:13,16 8:16

33:19 89:17

briefly 63:14 77:6

bring 36:14

brings 31:17

broadly 70:2

broke 34:1

Brookman 2:3 4:3,7

5:15 7:1,8 15:15

18:9 21:13 22:11

22:17 25:9 27:16

31:9 32:10,13

33:6,12,20 35:1

35:15 37:6 39:7

44:10,16,21 45:16

47:21 48:12,21

51:10,17 53:1

54:8,10,22 55:14

56:8 57:1 59:18

60:12 61:5 63:10

63:22 64:5,22

65:5,7 67:2,22

68:3,16 69:20

70:4 73:2 74:7,11

75:5 81:9 83:5

84:4,8 85:2,4 87:1

88:18 89:2,6,13

89:22 90:19 91:1

91:8,10,21 94:13

95:4 98:16,21

99:12 100:1

brought 19:12

Bryan 2:4 4:10 8:8

10:18 18:13 98:9

99:18,20

BTU 20:2,6 49:18

53:11 87:13 98:18

BTU's 95:19 96:14

96:22

Buccitelli 2:14 6:21

6:21

bucket 20:20 57:12

57:19 70:17 71:9

71:14 78:5

bucket-full 73:5

building 14:17 42:2

42:17,20 74:16

76:21

bulb 47:12

burden 25:6 64:14

66:17 87:22 88:15

88:18

burdensome 30:1

30:14,22 88:17

business 6:5 87:18

88:21,22 93:19

94:11

Butler 2:5 6:16,16

button 13:11 24:8

27:7

C

C 4:1

cabinet 34:21 53:20

53:21

calculate 81:7 86:4

86:17,19

calculated 63:6

75:22 80:14

calculating 84:16

86:8

calculation 52:22

76:5 85:7

calculations 31:3

62:21 85:19

call 11:4

called 68:19

calling 93:6 94:20

94:22 98:12

calorimeter 28:16

29:11,15 30:1,4

30:22 35:21 36:4

37:1 51:6 56:19

Camilla 2:19 7:5

Canada 31:19

Canadian 31:16

capability 79:4

97:12

capable 36:13 71:21

capacities 29:14,17

75:20 87:12

capacity 20:2,6

22:15 28:4 29:12

34:14,17,21 35:6

38:22 40:1 43:22

44:13 45:8,9,12

50:18 51:14,14

52:22 56:17 60:18

60:18,22 61:2

62:12,20,22 63:1

63:3,5,6 75:11,11

83:7 85:9 87:9

88:1 95:18 96:16

97:8

care 64:20

carry 82:4

carrying 18:18

case 31:4 34:20 35:8

35:9 50:5,9,14,15

50:16,18,20 51:3

52:3,9,13,14,17

52:20 54:5 55:19

56:15 63:4 67:19

68:14 69:3 74:5

cases 41:12 51:9

categories 14:14

40:22

category 91:20

causes 37:12

CC 18:1,8 23:1

CEER 75:17 86:7

86:13,14,15,17,19

86:20 87:10,15

cell 9:20

central 14:10 42:22

certain 40:17 73:12

77:15

certainly 64:8 83:10

83:12 89:11

CFM 38:5

CFR 86:5

challenges 35:20

challenging 36:1

chamber 29:16,19

30:4,13 36:6,8,9

36:18,19,20,22

37:21 46:22 58:21

58:22 59:1,17

60:2,15 66:1 67:1

88:7

chambers 36:12

chance 8:5

change 18:22

changes 31:14

40:19 89:10

characteristics

19:22 96:8,9

97:17,22 98:1,6,7

99:7

characterize 52:12

chart 29:8 95:10,16

chart's 99:13

charted 29:10

chime 48:22

Chun 2:21,21 7:4,4

circulate 24:11 30:7

67:14

circulation 23:14

24:6,8 25:16 27:1

27:7,9 63:14,16

63:18,21 64:17

65:8

City 76:21

clarification 51:19

55:15

clarifications 72:10

clarified 99:16

clarify 54:18 55:9

92:9 97:11

classification 12:20

clear 18:11 32:11

Cleary 2:22 6:10,10

31:10,10 56:8

64:1,1,7 65:3,6

81:9,10,10 83:8

89:6,7,7

climate 76:18 77:2

80:6

close 5:20 46:8 95:7

closed 12:7

closing 9:3

closure 99:17

coefficient 49:18

50:13 54:18

coil 23:15

coils 66:13 67:12,15

cold 26:1,14,18

66:12 82:20

coldest 82:17

collected 20:17 29:9

collecting 73:9

collection 20:16,20

57:4,7,12 70:19

70:22
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combination 32:17

combine 77:15

combined 71:15

75:15,16 81:7

86:5,11

combines 75:17

come 37:12 38:19

39:10 53:14 80:4

92:15 95:9

comes 60:19 94:5

comfort 15:5 56:21

coming 26:3,4 30:9

34:21 43:4 53:16

comment 8:16 12:6

16:8,12 21:9,11

22:21 24:15 25:6

31:6 34:5 35:17

38:21 39:2 47:13

47:15 48:13,20

52:11,19 56:9,11

59:13 60:9,13

63:7 64:3,3,15

65:8 66:17,21

72:20 73:3 81:5

84:5,20 86:18

88:15 90:20 91:8

91:11 93:14 94:21

commented 82:13

comments 8:4 9:3,6

10:15,17 11:3,10

12:2,4,7,8,12,12

15:14,21 16:18

21:13,14,15 22:12

22:14 25:9,10

27:17 32:8,11

35:16 44:16 45:17

48:12,16 54:16

56:11,12 57:2

60:12 61:5 63:10

73:2,4 74:12 75:7

83:1 84:6 85:5

88:18 89:8,8,12

89:16,22 90:5,8

90:17 91:19 92:13

92:16,17,21 94:2

95:6,7 99:15,17

99:19

commercial 21:22

22:2,6 91:14,18

93:1,6,8,22 94:15

94:20,22 95:11,15

98:14

common 55:12

70:10

commonly 87:22

companies 83:13,19

company 91:17

93:15 98:18

comparable 46:12

46:13 48:4 71:3

compared 14:9

comparing 56:18

82:1

complete 9:17

completely 27:10

78:11

complex 30:10 37:5

compliance 8:2

13:14

component 23:21

25:20

components 25:19

30:5,12 34:19

35:9 36:11,14

37:4 50:1 61:4

compressor 26:6

62:1 66:6,10,14

68:22

compressors 34:12

computers 42:11

conceivably 67:15

concern 16:12

concerned 13:20

64:9

concerning 16:8

concerns 16:18

concise 9:18

concluded 88:12

concluding 89:16

conclusion 88:16

89:14 95:5

concurrent 17:15

85:13

condensate 20:15

20:18 57:4,7,12

57:21 58:4,5

60:19 70:18 73:20

condensates 73:8

condenser 19:6,8,11

19:14,16,17 20:18

28:22 37:20 38:2

38:6,7,9,10 46:7

46:17 47:11,19

49:14 52:13 54:12

60:21 62:16

condition 34:16

43:14 46:5,6 47:3

47:4,18 53:7 62:4

conditioned 15:8

19:7,8,12,15,18

19:20 23:14 26:10

26:12 27:5 28:17

37:10 41:11,16,20

41:22 49:7 50:6

51:9

conditioner 18:17

36:2,9 82:22

84:10,19 92:5

93:2

conditioners 1:2 4:4

11:3 13:16,18

14:2,8,10,15,22

15:4,10 17:5 19:1

19:3,5 28:18

31:21 34:11 41:3

43:15,21 45:3

82:7,16 84:11,14

91:18 92:8 93:6

94:16

conditioning 40:22

68:20 84:22 91:15

94:1

conditions 30:1,5

35:5,22 36:7 37:3

38:2 39:5,6,18,20

40:14 43:17 45:22

46:1,8 47:1,14

48:1,2,4 58:17

61:2,20,22 62:4,5

62:6,8,13,17,19

63:8 66:2 67:1

72:12,13

conduct 61:14 63:8

65:19 88:17

conducted 17:16

28:12,13 57:5

66:16 72:11,19

88:7

configuration 19:10

configurations 19:4

21:10

confusing 69:11

confusion 21:19

47:17 48:16

connect 64:15

connected 23:11

26:11 32:22 33:3

71:19

connecting 22:9

connection 34:2

consequence 40:13

conservation 4:5

11:2 17:6,18

85:14

consider 12:8,12

17:17 52:20 60:10

74:9 92:14

consideration 9:8

13:1

considered 4:17

12:6,9 17:22 38:5

40:16,21 60:1

considering 21:6

40:13 94:8

considers 55:5

consistent 47:6 72:3

constructed 20:14

20:15

construction 22:15

consultant 2:18

5:22

Consulting 2:17

6:15 18:5

consumed 65:20

consumer 14:12,13

24:6,7,14 58:15

63:16,20 64:11

79:22 80:1,1,18

82:10 83:9 95:14

consumers 64:12

82:15,19

consumption 15:8

25:2 34:15,17,22

66:5,8,19,22 71:3

71:12 72:5,22

75:21 84:12,16

85:20 86:2

contact 5:7

content 8:3 9:14

15:22 28:7

continue 4:16,20

42:16 100:4

CONTINUED 3:1

continuous 4:21

8:10 68:19,21

70:15

continuously 24:11

69:4

contrast 40:12

contribute 49:7

contribution 38:15

control 58:6 59:16

60:14 66:20

controls 58:8 71:18

71:22

convection 49:17

50:12 54:18

convention 69:9

conventionally

68:19

conversation 10:9

conversions 69:18

cooking 42:11

cool 56:1 79:8

cooled 42:22

cooler 19:15 94:15

coolers 20:5,8,11,15

20:19 21:2,4,7,11

92:11 94:7,9 96:4

cooling 15:1 20:2,6

22:2 23:13,17,18

23:21 24:9 25:8

26:17 27:4,20

28:1,3,17 29:12

29:12,14,17 34:14

35:6 36:10 38:22

41:6,22 42:9

44:13 45:8,11

46:1,11 47:14

50:16,18 51:8,14

51:14 56:17 58:16

60:18,21 61:1,11

61:14,18 62:22

65:14,17,21 66:3

66:7,11,13,16

68:21 72:12,16

73:8 75:11,19

76:5,9,11 77:22

78:9,9,16,18,22

79:1,11,15,18

80:8,11,15,19,19

80:20 81:5,21

84:18,20 85:8,10

85:16 86:1,9,12

86:19,21 87:9,22

88:7

cooling-only 78:20

86:7,14

cooling/ 79:5

Correct 65:5

correction 55:17

corrections 33:10

correctionwould

56:7

Correlated 53:10

correlates 77:4

correlation 56:20

costs 8:21 86:4 88:9

counteract 36:10,15

38:1

countries 32:2

couple 68:2 92:22

courier 90:13

course 22:6 32:7

89:18

court 9:13

cover 9:4

coverage 17:3 97:12

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Crawford 2:18 5:22

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33:4 47:21,22

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95:8,9 96:11,19

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CRAWORD 74:9

create 37:11

creates 37:21

criteria 17:7,7

critical 40:6

criticize 83:16

CSA 28:2

cuing 18:10

curious 61:6

current 20:4 29:2

39:9 51:11

currently 16:22

21:6 83:8 84:13

customers 14:5

15:12 39:15

cycle 25:14 27:6,10

27:13 66:2,5,7,11

66:22 67:5,9,18

69:5

cycled 57:11 65:13

66:14

cycles 57:20

cyclically 24:11

Cymbalsky 2:6 6:17

6:17 94:4 99:10

99:12

D

D 4:1

D.C 4:7

daily 79:22

damaging 14:1

39:11 44:1

dangerous 56:3

dash 33:17

data 16:8 17:11

18:20 29:6,9

50:22 51:19,20

52:4 56:18 64:10

64:11,17,19,22

77:12 80:6,9

81:12 82:3,10,14

83:2,3,6,9,16,22

84:2

dates 13:4

day 4:13 9:2 42:17

42:18,21

DC 1:9

De'Longhi 6:6,8

13:15,17 33:8

39:8 45:1 56:12

deal 53:22 96:21

97:2

December 12:19

decides 98:18

deemed 42:4

defaulted 71:18

define 18:16 92:12

defined 19:10,15

23:11 38:17 79:19

defining 96:17 99:9

definite 21:20

definitely 54:16

definition 18:6,18

19:2 21:5 25:7

27:13 65:12 70:10

72:2 91:17 92:5

92:13,15,18 93:1

94:8,15,18 95:22

96:2,17 98:5,11

98:12 99:1

definitions 18:15

19:4 21:9,14,18

22:13,18 25:8,10

27:16 72:21 97:15

97:16 98:2,8 99:1

99:8,8

defrosting 23:15

degree 38:3 44:14

46:19 47:8,9

49:17,19 50:12

53:11 62:15,16

degrees 39:17 40:10

40:14 41:4,9 43:9

43:11,19 46:19

47:10 76:19,20

77:1 79:9 80:12

84:20 85:1

dehumidification

24:17

dehumidifiers 19:1

30:8

delay 71:2,14 78:5

delayed 71:9

DeLonghi 2:9,10,11

6:5

Denso 3:4 6:1,2

Department 1:1,7

2:1 4:6 10:1,15

83:11

depending 26:7,13

27:5 67:11

describe 10:19

description 82:5

design 15:3 34:13

34:15

designed 45:3 74:2

despite 14:9 43:10

detail 13:20 17:20

37:7 38:17 82:22

detailed 10:17

details 15:18

determination 17:3

18:19

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20:7,10,13,16

21:1 29:1,20

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24:20 26:11 31:4

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frequency 59:11

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March 18, 2015

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fresh 40:17

Friedrich 44:20,22

56:13 84:10

frost 62:4

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70:17 71:9,14

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88:2

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37:3,9,13,16 38:5

38:8,14,16,20

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inside 25:22 26:6,9

34:12,19 40:8

42:2

insists 14:6

installation 14:14

14:20 53:9

installed 57:22

instructions 7:10

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instrumentation

28:22

intake 50:10

intended 20:9,10,11

intent 31:20 95:2

intention 88:22

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80:2

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K

keep 9:19 10:3 34:7

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matters 10:17 22:16

Mauer 3:5 6:12,12

25:11,12 35:19,19

44:11,11 51:18,18

52:1 56:14,14

67:3,3,16 68:8

MAURER 26:2,21

27:11,15

maximize 24:19

maximum 58:7,10

66:4

mean 26:5 64:11

67:6 68:20 83:20

87:10 94:21 99:3

means 32:5 59:15

60:3 67:18 68:8

74:18 97:7 99:5

measure 27:22 28:3

34:22 35:4 44:13

53:16 55:22 56:5

63:18 71:11 74:4

measured 24:5 33:2

45:5 61:2 63:1

70:17 75:20 87:11

measurement 49:16

56:2,16 64:16

66:5

measurements 31:3

32:6 49:10 50:11

70:1

measuring 60:17,21

66:18,20 72:22

meet 21:4 72:13

94:7 96:2 98:2,8

meeting 1:1,2 2:1

4:4,21 8:7,10 9:8

9:18 10:19 12:3,9

13:6 14:4 16:10

16:19 17:15 39:14

89:15,19 95:6

meetings 8:10 10:2

meets 14:11 98:22

99:1

mention 31:12

mentioned 50:3

91:13 98:10

met 17:5

metal 20:15

metering 25:3 80:13

method 30:1,21

31:19 37:1 87:8

methodology 88:4

methods 20:4

metric 48:6,9,10

75:19

metrics 69:19

Michael 2:11

microphone 5:19

7:2 13:12 32:13

68:4

mid-morning 7:22

Mike 6:4 13:8

mind 95:15

mine 9:21

minimal 80:1 88:8

minimize 47:17

48:16 66:17 87:21

minimized 53:4

minimum 49:12

50:7

minor 45:13

minus 49:16 59:10

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minutes 61:8 66:6

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mode 9:20,22 23:4,5

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23:18 24:6,7,8,10

24:13,17,18,18,22

25:1,4,7,10,16,17

27:1,2,2,3,4,6,7,8

27:10,16,20,20,21

28:1 29:12 46:1

46:11 47:14 50:16

61:11,12,12,14,15

61:17,18,20,22

62:9,14 63:9,13

63:14,17,18,21

64:7,17,21 65:8

65:11,12,13,16,20

65:21 66:5,11,15

66:16,19,22 67:5

67:6,9,18,19 68:6

68:18,21,22 69:13

69:17 70:10,12,13

70:14,17,21 71:1

71:2,3,4,5,12,14

71:16,19,21 72:2

72:3,4,6,6,12,12

72:16,18,18 73:1

73:1,3,3,5,6,7,8

74:13 75:12,17,18

75:18,18 76:2,7,7

77:20,22 78:2,3,4

78:5,8,20 79:1,18

79:18,18 80:14,19

80:20 81:2,6,16

82:13 84:18 85:10

85:12,16,21,22

86:2,10,13,15,19

87:21 88:5,8

model 79:13 87:12

Moderator 2:3

modes 23:3,4,6,17

24:4 25:8 70:7,8

70:16,21 71:7

74:12 76:3 79:15

79:17 80:3 82:16

85:20 86:1,3,21

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modification 17:13

30:15 33:10

modifications 35:12

51:12 92:14

modified 24:21 51:4

51:7,10,15,19,21

55:18 56:19

modify 13:21 38:22

moisture 30:9

moment 7:10 95:13

monitor 57:7

monitored 66:9

monitoring 61:2

monitors 28:5

morning 4:8,11,14

42:19 75:8 92:20

95:17

morning's 96:21

97:6

motors 34:12

move 4:20 8:6,8

15:18,22 22:21

57:2 61:6,11

65:11 70:4,7

75:13 76:9 85:4

86:5 99:17

moveable 78:14

moved 22:8

moving 7:19 8:1

15:5 16:2 23:9

27:18 45:21 48:17

49:3 88:9

multiply 63:1

mute 10:4

N

N 4:1

Nadav 2:16 6:14

18:5,12 35:2 37:7

54:10 55:15 61:9

75:9 90:2

name 4:7 5:20 9:12

9:15 13:10

nameplate 59:7,11

narrow 21:18 92:14

national 2:19,21

8:22 76:18 77:17

80:6 91:16

nature 31:15

Navigant 2:14,15

2:16,17 6:15,19

6:20,22 18:5

nearest 87:13,15

necessary 17:8 76:5

necessity 15:9

need 7:2 14:18,20

33:13 34:18 36:14

42:9 45:14 53:3

67:21 94:18

needed 15:5 92:9

needs 14:4,12,14

39:14 64:20 82:9

82:14 83:2 84:2

negative 37:11,22

39:22 62:22 63:2

63:3

neglect 29:3

negligible 39:21

93:20

net 28:17 29:16,18

51:8

new 5:2,15 9:13

11:15,16 18:1

21:15 52:14 73:6

76:21

Ni 2:21 7:4,4

Nice 4:8

Nicole 2:14 6:21

night 42:14

NODA 29:6 52:6

nominal 46:20

noon 8:12

NOPR 9:1 11:4

12:4 17:21 18:16

19:3 23:10 30:19

30:19 35:20 37:16

38:12,18 45:22

49:8 51:20 56:18

57:4 61:13 62:13

65:11 70:9,15

72:5 75:14 79:5

79:12 85:7 87:5

87:17

normal 68:20

North 2:12 6:5

31:18

note 31:11 63:14

71:17 75:6 85:11

86:12

noted 58:18 87:17

notes 46:8,15 47:11

87:20

notice 11:3,17,19,21

11:22 16:15 17:2

17:4,11 18:19,20

noting 69:16

number 7:13 23:6

38:13 76:12 77:8

77:10,15 79:10

80:2 90:10,10

numerous 81:14

O

O 4:1

obligation 89:4

observation 47:22

observed 57:9

obviously 92:16

93:9

occupancies 40:19

occurring 43:18

occurs 39:20

OceanAire 91:13

off- 66:21 67:4,8,17

off-cycle 23:5 25:17

27:2,2,6 65:11,12

65:20 66:11,15,19

67:5,19 68:6,17

75:18 78:2 79:18

81:2 88:5

offers 56:9

Oh 26:22 48:17

ok 10:21 35:18

okay 8:13 10:21

13:6 15:21 16:19

18:1,3 22:19

25:10 26:22 27:11

27:17,19 33:20

35:1,18 37:6,7,8

44:17 45:16,19,21

48:17,21 49:3

54:8 56:8 57:1,2,3

60:3,8,11 61:8,10

63:10,12 65:9,10

69:20 70:4 73:4

73:22 75:3 84:4

85:2,5,6 87:2,3

89:6 90:1 93:13

95:3,4 98:20

99:15,18

once 10:8 66:16

ones 84:14

online 45:19 56:9

91:11

onset 15:21

open 12:15 13:7

90:9

opening 7:16,16

13:7,9 15:20 58:9

operate 65:16

operates 67:12

operating 23:3

24:10 30:6 36:9

37:10 67:4,14

71:15 73:8 76:1,7

77:20 78:1,7,20

79:1 80:20 81:6

81:16,20 82:12

84:5 85:12 86:4,8

86:10

operation 24:19

25:1 36:15 77:21

opinion 34:18

opportunity 7:15

8:4,16 9:3,4 16:7

92:4

opposed 56:10

optimized 53:15

options 100:3,4

order 47:2 59:7

71:9 76:4

organizational 5:21

original 47:13

originated 41:21

originating 37:17

oscillation 58:12

ought 53:16 55:7

outcome 81:17,18

outdoor 35:22

36:18 37:17,20

38:1,2,8 39:5,17

39:20 40:4,5,10

40:14 41:4,9 42:3

42:4,8,14 43:8,16

44:14 45:7 46:5

58:20,21 62:6,17

79:8,16 80:4,5,11

84:21

outdoors 14:19

41:12,15,21 43:6

outer 54:19,21

outlet 19:8,14,17,19

outset 5:17 7:17

8:17 23:2 31:6

89:14

outside 19:12,14

26:1,3,11 37:21

43:11 67:7,8,17

68:9 78:9,16,18

81:20

overall 83:12 86:11

86:13,20

overlaying 51:5

overly 21:18 22:5

30:1

overstating 40:15

owners 94:11

ownership 77:11,13

P

P 4:1

PAC- 46:16

PAC-1 13:19,21

28:2,12,14 29:11

30:13,18 33:9

35:4,13 39:5

43:15 47:15 55:11

56:10 58:19 89:10

PAC-1-2014 30:18

31:1,7,11 32:5

46:2 49:11 50:3
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PAC-l 30:20

packet 7:11 9:10

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page 7:13 18:11,12

panel 27:8

paragraph 95:12

parallel 58:11

paratroopers 55:2

part 5:3 12:6 14:17

16:13 54:5 65:22

90:7,7 94:1

participants 10:1

11:9

participate 10:9

participating 10:14

10:21

participation 7:10

90:4,16

particular 39:17

60:17 82:12

particularly 48:13

partition 59:20 60:1

pass 36:19

patterns 82:3

pause 75:1

payback 8:21

penalization 39:18

penalize 66:12

people 16:7 93:11

93:15 97:21

percent 59:10,12

72:15 79:14 80:3

80:14

percentage 21:2

78:7 81:19

perfect 55:22

performance 14:3

15:13 27:21 28:1

39:13 44:2 63:9

86:20 97:3,5

performed 28:15

85:8

performing 23:13

period 8:21 12:6

32:5 39:21 66:20

71:6,10

periods 79:8

persist 71:5

perspective 7:18

pertaining 11:1

12:2

petition 60:5

phase 22:3,3,7

98:11,12,13,20

phones 9:20

physical 53:3 97:20

pictorially 38:11

picture 28:19

place 8:3 47:5 57:17

89:5

placed 34:16 50:10

60:4

placement 58:18

59:16 60:14

places 37:13

plan 9:6 87:4,7

plane 55:2

plastic 20:14

play 15:2

please 5:20 7:1,3

9:12,21 10:3,5

11:12 21:15 33:6

33:20 34:9 39:7

48:18 64:6 74:14

75:5 84:8 90:9

94:10,13 96:8

plot 50:21 52:5

plug 15:2 57:9,16

57:21 73:10 75:1

plugged-in 78:17

plus 49:16 59:9,12

72:15

point 11:20,20

16:11 18:1,21

22:1 31:17 43:5

45:19 65:22 69:4

83:18 85:1 90:16

94:12

points 95:10 98:4

Policy 17:6

poor 56:7

portable 1:2 4:4

11:2 12:21 13:16

13:18 14:2,8

15:10 16:20,22

17:5,18,22 18:16

19:2,5,6,16,21

21:5,9 23:3,11

27:22 29:3 30:6

30:21 31:7,21

34:11 36:8,13,15

37:10 41:3 43:14

43:21 45:3 46:11

50:2 57:14 62:2

62:10 63:9 65:13

72:6 76:13 77:5

77:11 78:2,4,11

78:13 79:7,21

82:7,16 84:11

91:15,18 92:5,7

93:2,6 94:1,8,16

portables 41:1

portion 8:9 14:19

74:22 89:15,15

95:6

position 41:18 93:4

93:10

possible 41:13 58:8

58:10,13,16 66:4

69:8 73:17 91:1

possibly 55:21

69:22

post 91:6

posted 91:4

posting 91:7

potentially 46:22

pounds 20:8,9

power 23:12 32:18

65:20 66:8 68:7

70:16 71:3,7,8,11

71:19 72:5,19

75:12 76:2 85:10

85:22 86:22

Prager 2:11 6:4,4

preliminarily 29:21

preliminary 11:6

14:21 16:16 17:17

85:13

presence 42:1,10

present 11:1 43:2

93:7,10

presentation 8:2

51:1 52:7 90:3

presentations 11:12

presented 22:22

29:7 51:1,20 52:6

52:9 79:3,11

presents 38:12

presses 24:7

pressure 33:2 36:17

37:11,22 45:13

presumably 53:6

pretty 10:7 30:10

70:2

prevalence 63:16

previous 82:3

previously 75:20

78:6 79:3,19 81:4

85:9

primarily 31:14

45:2 77:5 78:15

primary 5:7 23:17

24:3,22 27:20

47:3 58:15 67:13

priority 47:19

probably 13:3

18:21 74:20 75:1

91:2 99:11

problem 55:20

68:12

problems 12:17

92:3

procedure 1:2 4:15

5:4,11 7:21 8:6

11:5,18 12:3,14

13:1,18 16:10,21

17:1,16,22 18:15

19:3 21:7,12

23:10 30:19,19,21

31:8,16 37:15

38:12,18 40:13

45:10 46:10,12

55:18 56:22 61:13

64:10,14 70:9

74:22 79:5 88:6

89:21 92:6 93:4

94:9 95:6 96:3,20

97:6,13

procedures 4:5 5:3

5:7 8:11 11:1

17:13 27:22 28:3

28:9 29:3 88:17

89:15 92:10,19

proceed 22:19 34:7

37:7 45:20 49:1

64:19 75:9 76:4

84:1

proceeding 8:18

process 11:16,18

13:6 35:13

produce 25:22

29:18

produced 28:11

76:14 77:7

product 5:2,14

11:16 12:16,22

13:14 17:7 19:4

20:3 21:15 22:8

79:22 82:3,11

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products 3:4 7:21

14:4 18:7 21:21

21:21 22:2,5

39:12,13 44:1

70:11 72:4 82:2,5

82:18 87:6 91:20

92:8 96:18 98:1

99:6

project 3:6 5:6 6:13

proper 40:18

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proposal 11:1 13:21

18:22 21:11 24:5

37:9 38:21 39:4,9

39:16 44:14 47:15

48:14 51:12 52:15

52:20 53:13 55:20

59:4 63:19 65:2,8

72:11 75:13 81:12

proposals 7:21

22:22 31:22 57:4

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propose 54:15

proposed 11:4,17

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17:2 18:15,16,19

19:4 21:3,4,9,12

23:10 24:5 25:6,7

31:6 35:12 39:2

40:7,13 43:5

45:22 47:4,14

49:8,20 50:4,14

50:18 52:11 56:21

58:18 59:8 61:13

61:18 62:12 63:7

65:12 66:9,15,18

70:9,12 72:2,5,21

76:11,13 79:5,10

81:2,5,14 85:6,18

85:22 86:4,7,10

86:18 87:5 88:12

89:10 90:8 92:12

94:7,19 96:3

proposes 17:21

30:20 58:21 63:1

63:5

proposing 31:1 32:7

51:16 57:13 63:17

64:16 71:11 74:4

74:6 86:16

provide 11:10 15:1

25:14 66:13 82:22

83:17,19,20 84:3

89:12 94:2 96:9

provided 8:4 10:6

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57:17 93:14

provides 54:13

61:21 62:2 70:15

78:19

providing 36:11

provinces 31:22

provisions 50:5

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pump 58:2 61:22

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purchase 15:2

purpose 10:19 13:5

purposes 17:8 18:10

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push 13:11 26:1,11

pushed 20:18

pushing 36:21

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quarter 78:12

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questions 9:6 13:5

16:18 18:2 25:12

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quick 33:17

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raise 10:5 11:13

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randomly 81:18

range 20:2 40:12

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rarely 43:18

rate 28:5 39:3 84:12

rated 20:5 39:19

40:1 43:22

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ratings 40:3

ratio 28:4 75:14,15

75:16 81:8 85:7

86:6,11

reached 69:4

reaches 70:19

reactivate 65:17

reactivated 70:22

reading 53:13 55:1

ready 48:10 82:20

82:21

real 53:8 68:12 83:2

realistic 44:13

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really 10:16 54:3

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reason 21:22 55:16

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reasonable 13:17

reasons 69:21

receive 93:8

received 7:11

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recognize 56:1

recognized 10:6

recommended

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record 33:19 75:4

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recorded 12:5 13:12

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recurrence 40:9

41:8

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reduce 71:10

reduced 77:3

reduces 43:22

reduction 15:8

refer 37:13 94:18

reference 31:6 32:4

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referring 54:19

reflect 94:11

reflected 7:20 98:3

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related 43:8 97:3

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relatively 32:19

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relevance 55:3

relevant 22:4

reliable 5:13

remain 57:17

remarks 4:9 7:16

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reminding 9:20

remote 70:14

removal 24:19,20

remove 58:5

removed 57:21

78:14

removing 52:8

rental 14:16

repeatability 59:8

repeatable 5:12

replacement 41:14

report 79:16 87:22

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represent 14:11

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51:8 53:8 62:9

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represented 80:15

represents 52:5

request 48:14 60:13

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requests 25:6

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required 14:21

24:21 30:11 36:7

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restart 33:14,16

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restroom 33:18

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result 34:14,20

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results 28:11 29:1

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resume 33:20 34:3,4

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reverse 24:1 25:14

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right 5:11 10:22

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10:5,10 14:22

15:6,6,8 19:1

28:18 29:16 34:6

36:2,12 37:12

42:7 45:6,7 46:9

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74:19 76:12 77:12

78:1,3,6,14,14,21

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rooms 20:11 42:22

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round 7:22

roundabout 8:12

rounded 87:12,15

rounding 87:4,6,8

rule 11:19 12:13,16

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81:14 88:12 92:12

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rulemaking 4:17

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16:16 17:16 76:16

78:1,3,6 85:14

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rulemakings 4:18

82:4

rules 9:9 89:5

run 69:3,12

running 8:10 24:3

67:5,8 68:22

runs 68:22

S

S 4:1

safety 73:12

sample 71:17 73:16

sampling 87:4,7

Sang 3:4 6:2

Sarah 2:5 6:16

satisfaction 15:13

satisfied 14:5 39:14

satisfy 88:10

saying 55:10 60:7

says 41:13 48:21

98:21

scales 30:8

scenario 80:17

scenarios 79:12

80:18,22

schedule 4:16,19,19

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scope 92:5,19 95:17

95:21 96:1,13,16

97:12 99:9

screen 60:13 94:7

screening 8:19

season 39:21 40:11

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77:22 78:8,9,10

78:16,18,22 79:2

79:12 80:8,11,15

80:20 81:6,21

84:20

seasons 76:8

seat 13:10

seats 33:21 75:6

second 9:9 27:1

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selection 40:3,4

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sense 5:12 81:18

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70:14

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22:20 25:18 26:5

26:22 27:12,19

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67:10 69:2,10

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37:19 38:4 39:12

39:19 40:1,3,6

43:14,16,20 45:4

46:6,20 47:20

62:19 96:5

single-phase 22:9

98:14

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sitting 36:6

situation 56:3

situations 14:16

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18:17 21:6 35:11

35:16 36:21 46:10

49:2 50:21 52:10

65:9 85:11 90:4

94:5,6,12 96:6

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27:6 28:17 30:5

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surface 49:20 50:15

52:17 53:21 54:19

54:20,21 59:3

surfaces 60:15

SW 1:8

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unplugged 78:11,12

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11:00 8:1

115 59:9 72:15

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126 80:21

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2 40:19 46:18

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2,168 80:20

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31:13

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2014 17:12 29:6

30:17 31:13 33:11

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210/240 40:9 41:8

61:21 62:2

24 32:16

25 14:5 15:12 39:15

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3 7:13 59:3

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46:5

98% 21:1
11 4 

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