### 202-234-4433 Neal R. Gross & Co., Inc. Page 1 U.S. DEPARTMENT OF ENERGY

+ + + + + PUBLIC MEETING FOR TEST PROCEDURE GUIDANCE FOR ROOM AIR CONDITIONERS, RESIDENTIAL DISHWASHERS, AND RESIDENTIAL CLOTHES WASHERS

+ + + + + FRIDAY JUNE 1, 2012

+ + + + +

The meeting came to order, in room

8E-089 of 1000 Independence Avenue, SW,

Washington, D.C. at 9:00 a.m., Ashley

Armstrong presiding.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 2 PRESENT ASHLEY ARMSTRONG, Department of Energy LAURA BARHYDT, Asst GC for Enforcement, Department of Energy ELIZABETH KOHL, Atty Advisor Department of Energy AMANDA STEVENS, Program Manager, Energy Star Appliances, EPA KATHLEEN VOKES, Energy Star Product Development, EPA PAUL RICHTER, AB Electrolux JENNIFER CLEARY, AHAM RALPH HUDNALL, AHAM STEPHEN B. LEYBOURN, AHAM WAYNE E. MORRIS, AHAM PHILIP J. MANTHEI, Alliance Laundry Systems JOANNA MAUER, ASAP MIKE EDWARDS, BSH Home Appliances Corporation DAVID J. LINGREY, Friedrich Air Conditioning Co. BRICE BOWLEY, GE Consumer and Industrial PHIL HOMBROEK, GE Consumer and Industrial KELLEY KLINE, GE Consumer and Industrial KEVIN CHURCHILL, Intertek LINCOLN BILLINGS, Intertek MARK MENZER, Intertek JOHN I. TAYLOR, LG Electronics JUDITH REICH, Navigant Consulting ED OSANN, NRDC RAVEENDRAN VAIDHYANATHAN, Samsung Electronics America, Inc. DONALD BRUNDAGE, Southern Company JULIA FARBER, UL, LLC VINCENT P. ANDERSON, Whirlpool Corporation WAYNE KLUG, Whirlpool Corporation DANIEL E. TEICH, Whirlpool Corporation

### 202-234-4433 Neal R. Gross & Co., Inc. Page 3 ALSO PRESENT MICHAEL WOODFORD, AHRI KEVIN MESSNER, AHAM WES ANDERSON, Appliance Standards MIZANUR CHOWDHURY, CSA International JOHN CYMBALSKY, DOE TIMOTHY BALLO, EarthJustice GEORGE HAWRANKO, Electrolux North America AMANDA GONZALEZ, Energy Solutions EDWARD WUESTOFF, Friedrich Air Conditioning Co. CHRIS ROBERTS, GE YOOLANDA WILLIAMS, GE Appliances and Lighting ANGELO CACCIATORE, Haier America DANIEL WOODCOCK, IAPMO R&T SEAN SOUTHARD, ICF International MAX WILBAND, LG Electronics STEVE POLINSKI, Miele USA JAVIER BURGOS, Navigant Consulting JUSTIN SCHMIDT, Navigant Consulting RICHARD SHANDROSS, Navigant Consulting TIMOTHY SUTHERLAND, Navigant Consulting DETLEF WESTPHALEN, Navigant Consulting TROY WATSON, Navigant Consulting MVUALA SUAMI, NRCan SAI ARIDI, NSF International WAYNE MYRICK, Sharp Electronics EVA MILAKOWSKI, Ontario Ministry of Energy MIKE SHOWS, UL CURT TREMEL, UL Springboard Engineering DEBRA BENGSTON, Viking Range Corporation

### 202-234-4433 Neal R. Gross & Co., Inc. Page 4 C-O-N-T-E-N-T-S Call to Order and Opening Remarks 6 Ashley Armstrong Department of Energy Introductions 9 Opening Remarks 13 Jennifer Cleary 13 AHAM General Cross-Cutting Test Procedure Discussion 22 Basic Model Definition and New Basic 22 Model Requirements

Model Number 26

Industry Test Procedure Version and 29 Revisions Guidance Procedures and Policies 31 Rounding Policies 36 Other Issues/Open Forum 41 Room Air Conditioner Test Procedure 43 Discussion

Installation of Test Unit in Wall 44 Cavity of Test Chamber Adding Water to Drip Pan Prior to 55 Initiation of Test

Run-In Period 63

Air Sampler Placement 73 Other Issues/Open Forum 83 C-O-N-T-E-N-T-S (CONTINUED)

### 202-234-4433 Neal R. Gross & Co., Inc. Page 5 Dishwasher Test Procedure Discussion 85 2010 Test Procedure Guidance 85 Regarding Cycle Selection Detergent Volume Calculation 93 Substitutions 100 Preconditioning 108 Soiling and Loading Procedures 124 Rinse Agent Container 135 Water Pressure Measurement 138, 158 Drain Height 142 Upper Rack Position 143

Water Hardness 147 Ambient Temperature 152 Differences in Food Soils 156

Clothes Washers 160 Testing Anomalies 161

Drum Volume Measurement 180 Energy Test Cycle 200 Test Cloth Loading Method 202

Water Pressure 208 Recording of Ambient Conditions 211 Standby Measurement 216

### 202-234-4433 Neal R. Gross & Co., Inc. Page 6 1 P-R-O-C-E-E-D-I-N-G-S

2 9:05 a.m. 3 MS. ARMSTRONG: All right. Good 4 morning, everyone. 5 For those who don't know me, my 6 name is Ashley Armstrong. I work here at the 7 Department in Buildings. I oversee the 8 testing procedures, the certification, 9 enforcement, and the Energy Star testing that 10 we do in the Buildings Program for appliance

11 standards. 12 I would like to welcome you today 13 to our discussion, hopefully a productive one, 14 about some of the testing questions and issues 15 that have arisen with respect to dishwashers, 16 clothes washers, and room air conditioners. 17 This is really a forum for you guys 18 to speak, to bring your issues to the 19 Department. We are really here to listen. 20 You will notice that most of the times today 21 we will not be issuing an opinion on most 22 matters. We are going to be listening. We

### 202-234-4433 Neal R. Gross & Co., Inc. Page 7 1 will be taking all the different questions and 2 clarifications and requests back and probably 3 come out with some to-do's from this meeting. 4 But we really appreciate you 5 coming. I encourage you to speak up. This is 6 your opportunity. 7 Just a couple of ground rules. I 8 think you guys know, when you come up to the 9 microphone, either the ones on the side or 10 this one, please push to talk. State your 11 name clearly for the record. There will be a 12 transcript of this posted on the website. 13 Also, state your company affiliation each time 14 you speak, so not just the first time, but 15 each time. 16 Another thing we are going to do, 17 for the participants on the webinar, I welcome 18 you as well. We are going to try to 19 incorporate a two-way dialog with you. So, if 20 you want to talk on the webinar, there is a 21 way you can raise your hand. I will know 22 that, and we will try to integrate you into

### 202-234-4433 Neal R. Gross & Co., Inc. Page 8 1 the discussion by unmuting your line and 2 calling on you. 3 Just as with the participants in 4 the room, I ask you that you state your name 5 for the record as well as your company 6 affiliation before you talk, even if you are 7 speaking on the webinar. 8 This is a new webinar thing for the 9 Department as far as the two-way communication 10 goes. So, if it doesn't work too well, we 11 will go back to listening-only mode. But we 12 are hopeful. We tried it out yesterday. We 13 are moving in that direction at least. 14 So, for anyone else who wants to 15 come join the table, feel free to do so, now 16 that we are starting the meeting and it looks 17 like we have a couple of open spots. 18 Other than that, we are going to go 19 around the room and do introductions of 20 everyone. As soon as Kelley gets seated, we 21 will let her start. You could you just start 22 with introductions, with your name and your

### 202-234-4433 Neal R. Gross & Co., Inc. Page 9 1 company affiliation. 2 MS. KLINE: Hi. Kelley Kline, 3 General Electric appliances.

4 MS. ARMSTRONG: Great. 5 MR. RICHTER: Hello. My name is 6 Paul Richter, AB Electrolux. 7 MS. ARMSTRONG: Okay. 8 MR. LINGREY: David Lingrey from 9 Friedrich Air Conditioning. 10 MR. EDWARDS: Mike Edwards with BSH 11 Home Appliances. 12 MR. ANDERSON: Vince Anderson with 13 Whirlpool. 14 MR. OSANN: Ed Osann, Natural 15 Resources Defense Council.

16 MR. VAIDHYANATHAN: Ravee 17 Vaidhyanathan, Samsung Electronics. 18 MS. CLEARY: Jen Cleary with AHAM. 19 MS. FARBER: Julia Farber with 20 Underwriters Laboratories. 21 MR. MANTHEI: Phil Manthei, 22 Alliance Laundry Systems.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 10 1 MR. MENZER: Mark Menzer with

2 Intertek Labs. 3 MS. KOHL: Betsy Kohl, Department 4 of Energy General Counsel. 5 MS. ARMSTRONG: Ashley Armstrong, 6 Department of Energy, Buildings. 7 MS. BARHYDT: Laura Barhydt, 8 Department of Energy General Counsel.

9 MS. ARMSTRONG: If we could also 10 start on that end in the back, if you guys 11 could actually make your way to the 12 microphone, we are going to get for the record 13 everyone who is in the room. 14 MR. BOWLEY: Brice Bowley, General 15 Electric. 16 MS. CHINGOS: Abigail Chingos, 17 Office of General Counsel, and I work in 18 Enforcement with dishwashers and clothes 19 washers, among other things. 20 MR. CASE: Dave Case, DOE Office of 21 Enforcement as well, and I work with room air 22 conditioners.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 11 1 MS. STEVENS: Amanda Stevens, EPA, 2 Energy Star. 3 MS. MAUER: Joanna Mauer, Appliance 4 Standards Awareness Project. 5 MS. SWOGGER: Denise Swogger, 6 Alliance Laundry Systems. 7 MR. BRUNDAGE: Don Brundage, 8 Southern Company. 9 MR. TAYLOR: John Taylor, LG 10 Electronics. 11 MR. TEICH: Dan Teich with 12 Whirlpool. 13 MR. KLUG: Wayne Klug, Whirlpool. 14 MR. CHURCHILL: Kevin Churchill,

15 Intertek. 16 MR. BILLINGS: Lincoln Billings,

17 Intertek. 18 MR. MORRIS: Wayne Morris with the 19 Association of Home Appliance Manufacturers. 20 MR. HUDNALL: Ralph Hudnall, 21 Association of Home Appliance Manufacturers. 22 MR. LEYBOURN: Steve Leybourn,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 12 1 Association of Home Appliance Manufacturers. 2 MS. ARMSTRONG: Okay. Did we get 3 everybody in the room? If not, please 4 introduce yourself. 5 MS. VOKES: Hi. I'm Kathleen 6 Vokes. I am with the EPA. 7 MS. ARMSTRONG: Okay. Sorry. 8 MS. REICH: Judith Reich from 9 Navigant.

10 MS. BRUNK: Debra Brunk from 11 Navigant. 12 MS. ARMSTRONG: All right. Well, 13 right before we do opening remarks, I just

14 want to make one further comment. For 15 dishwashers, we have an open rule right now. 16 So, I just want to make clear that any of the 17 issues brought up today, the Department 18 doesn't plan to address those. Those will be 19 addressed through the rulemaking process. We 20 encourage you to submit comments to that 21 docket as they may relate to that. You can 22 certainly bring up issues, or if there are

### 202-234-4433 Neal R. Gross & Co., Inc. Page 13 1 issues that haven't been brought up as part of 2 that rulemaking, you can bring them up here, 3 but they will be addressed in that docket, in 4 that rulemaking. So, just to make that clear

5 before we start. 6 With that, I am going to open it 7 for opening remarks. I know there is someone 8 down there who wants to go first. 9 MS. CLEARY: I will volunteer. 10 (Laughter.) 11 I just wanted, first of all, to 12 start by thanking DOE, and Ashley in 13 particular, for holding this meeting today. 14 MS. ARMSTRONG: Can you do me a 15 favor and state your name? 16 MS. CLEARY: Oh, I'm sorry. Jen 17 Cleary with AHAM. 18 We think this is a very important 19 meeting, and we are grateful to have the 20 opportunity to discuss these issues today. 21 In particular, a combination of 22 factors is making correlation and common

### 202-234-4433 Neal R. Gross & Co., Inc. Page 14 1 understanding of DOE's test procedures more 2 critical than ever before. 3 One, standards are becoming more 4 and more stringent, which leaves less room for 5 error during testing. 6 Second, we have increased DOE 7 enforcement testing. 8 And third, third-party verification 9 testing by different laboratories for Energy 10 Star, also, through DOE and certification 11 bodies. 12 So, accordingly, like I started out 13 saying, we thank DOE for holding this meeting. 14 We see it as a very important opportunity for 15 an open dialog to discuss these issues, and we 16 look forward to future meetings like this. 17 Hopefully, today will be successful. 18 In particular, there are several 19 lab processes that I think we will discuss 20 today that are difficult to characterize in 21 the limited wording in the test procedures. 22 The result is that different labs, you know,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 15 1 we have witnessed, are interpreting procedures 2 different, certain procedures in the test 3 procedure differently, which means different

4 results. And the outcome could be false 5 findings of compliance or non-compliance. 6 Some examples of these types of 7 issues that cut across all products: 8 significant digits and rounding. I think 9 there is some significant confusion about 10 DOE's procedure for that for each product. 11 There are provisions in different areas of the 12 rules. And so, we would be looking today if 13 DOE is able to kind of walk us through that so 14 everybody is clear. 15 And also, this is coming up now in 16 Energy Star specifications. I think we would 17 look for those to be the same as DOE, whatever 18 the process is. 19 The approach to new basic models 20 should be the same for DOE and for Energy 21 Star. So, we would hope that there is only a 22 need to report changes that result in a

### 202-234-4433 Neal R. Gross & Co., Inc. Page 16 1 measured energy that is less efficient than 2 the reported value. 3 The approach for the change in 4 model year also needs some clarification. If 5 there is a placeholder for the model year in 6 the model number, we don't think there should 7 be a need for retesting or certification, once 8 that placeholder value is changed for the 9 year. 10 Also, there has been great 11 improvement in the way that DOE has been 12 posting and issuing its guidance, but we still 13 look for a little bit of clarification around 14 the significance of when DOE maybe posts 15 guidance on its guidance website and then 16 later pulls it down. What should we be doing 17 as an industry in that type of situation? 18 Some just examples of why this 19 meeting is necessary for each product. And we 20 plan to go into these issues in depth today. 21 But for dishwashers there are several 22 questions around cycle selection and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 17 1 identifying whether a cycle is soil-sensing. 2 There is some interpretive confusion regarding 3 the detergent volume calculation. There is a 4 significant need for substitutes, both in the 5 soils and the dishware. Flatware is being 6 addressed, but dishware as well. And the need 7 for these substitutions to be specified 8 through a quick and clear procedure as they 9 arise, because these issues will continue to 10 arise. And also, the definition of 11 preconditioning needs some clarification, 12 among other issues. 13 For clothes washers, one main issue 14 is how to address testing anomalies, like an 15 unbalanced load during testing. Also, some 16 further need for clarification on drum volume 17 measurement. Particularly, I know J2 18 addresses many of them, but we are still under 19 J1. And so, we need some more guidance in 20 addition to what is already out there with 21 regard to bad design, the weight used to 22 determine volume, unique design features, and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 18 1 shipping bolts. Also, there is a need for a 2 more detailed description of the test cloth 3 loading pattern and sequence. 4 With regard to room air 5 conditioners, there are some questions 6 regarding there is some variability in the 7 installation of the unit from lab to lab. 8 Also, some labs add water to the drip pan to 9 speed up the time to reach equilibrium, and we 10 would like to discuss that. The placement of 11 the air sampler and, also, the run-in period. 12 Again, just stressing the need for 13 the open dialog which this meeting addresses. 14 We think that we should continue to work 15 together on these test procedure issues. AHAM 16 is constantly working to improve our test 17 procedures, many of which DOE incorporates by 18 reference into its test procedures. And so, 19 correspondingly, we would hope that DOE would 20 revise its appendices to incorporate by 21 reference the most recent version of the AHAM 22 test procedure, where relevant. This will

### 202-234-4433 Neal R. Gross & Co., Inc. Page 19 1 greatly reduce the variation. Many of our 2 changes are to address variation that we see, 3 and there should be a quick process for doing 4 that and to evaluate the impact on measured 5 energy.

6 DOE should also consult 7 stakeholders before issuing final guidance. 8 We think this is the best way to have good, 9 clear guidance and, also, give industry some 10 lead-in time for that guidance, as if it was 11 unclear, there may be some who were not doing 12 it the way the guidance indicates. 13 Also, this guidance should be made 14 publicly available to all stakeholders, so 15 that the tests can be run by all labs in the 16 same way. That is critical. 17 Finally, we would ask, does the 18 Department have some clear criteria that we 19 could evaluate whether it is best to seek 20 clarification through a guidance request, 21 through maybe a petition for a test procedure 22 change. If there aren't such criteria, could

### 202-234-4433 Neal R. Gross & Co., Inc. Page 20 1 they be developed? And we just see this as 2 important for us to help you make the test 3 procedures as clear as possible. 4 So, thank you again for this 5 meeting today, and we have several specific 6 issues that I know our members wish to raise. 7 MS. ARMSTRONG: Great. This is 8 Ashley from DOE. Thanks, Jen. 9 Does anyone else have opening 10 remarks that they would like to make at this 11 time before we get into the details of each of 12 the issues? 13 (No response.) 14 No? Wow. This could be a really 15 quick public meeting. 16 (Laughter.) 17 Okay. So, I will say, like I said 18 at the outset, really I don't have anything 19 but a simplified agenda because this really 20 isn't a presentation of the Department that 21 the Department is making for comment. This 22 really is a forum for you guys to discuss the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 21 1 details, especially examples of what you think 2 or how things are being conducted differently, 3 where the clarifications are needed, where the 4 ambiguities lie. The more details you can 5 provide to us, the more helpful it will be to 6 us, and, hopefully, the more helpful we can be 7 to you, once we get a chance to evaluate 8 things as they come through. 9 So, with that, I am going to move 10 on. Okay. So, the first thing we are going 11 to talk about today is some of the more 12 general items that have been brought up. And 13 granted, I have listed here on the agenda the 14 items that I am aware of today that have been 15 brought to my attention, but by no means does 16 this mean you need to limit your questions or 17 clarifications or requests to these items 18 alone. Feel free, when we get to the end 19 where there are open issues, to bring up any 20 other questions or concerns you may have. And 21 we encourage you to do so. 22 So, the first questions that we

### 202-234-4433 Neal R. Gross & Co., Inc. Page 22 1 have gotten surround the basic model 2 definition and what actually constitutes a new 3 basic model. I am actually going to open the 4 floor for discussion first around what 5 questions may lie or what concerns there are, 6 just so that we can understand. 7 Anybody? 8 MS. CLEARY: This is Jen at AHAM. 9 I don't know if we so much have 10 questions about the basic model definition, 11 but we do think it is important that it be the 12 same, you know, part of correlation I think is 13 that it is the same for Energy Star, which 14 certainly since we initially raised this issue 15 that has definitely been incorporated into the 16 specifications. I think AHAM would continue 17 to believe it would be better if DOE's regs 18 were cited instead of the language copied, so 19 that they would always be the same. But I 20 think that was maybe our main concern there. 21 And with regard to new basic model, 22 as I mentioned in my opening statement, I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 23 1 think we just want to make sure that it is 2 clear that there is only a need to report 3 changes to a product that would result in 4 less-efficient measured energy, that there is 5 no need to report certainly things like a 6 color change. Or more germane would be 7 changing like a part in the product that 8 either would not change the measured energy at 9 all or would change the measured energy to be 10 more efficient. Because the manufacturers 11 have the ability to conservatively rate, there 12 shouldn't be a requirement to report that type 13 of a change or to institute a new basic model. 14 MS. ARMSTRONG: Okay. So, this is 15 Ashley from the Department. 16 Jen, I think what you just said is 17 fairly consistent with the Department's 18 position as far as its regulatory program goes 19 with respect to basic model. And I think 20 Kathleen can confirm that DOE and EPA are both 21 working together on a regular basis. So, to 22 the extent there are differences there, I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 24 1 think we are committed to working through 2 those. I think we think we are harmonized. 3 MS. VOKES: This is Kathleen Vokes

4 from EPA. 5 I am not aware of a requirement for 6 Energy Star to make people report. You know, 7 if it is a basic model, it is part of the 8 family. So, it is just treated the same way 9 in our specifications. 10 So, if you have any examples of 11 instances where you believe that we are not 12 harmonized and we are not doing it the same 13 way, please bring it to our attention. 14 MR. ANDERSON: This is Vince 15 Anderson at Whirlpool. 16 Just to be terribly clear on this 17 -- and, Jen, in your verbiage there, there is 18 a distinction that I want to make sure is 19 clear. Jen said that we would not have to 20 report the change as long as it was equal or 21 more efficient. Actually, what we have 22 proposed is that so long as it essentially

### 202-234-4433 Neal R. Gross & Co., Inc. Page 25 1 meets the rated value. So, there could be a 2 design change that we make that makes the 3 product less efficient; yet, it still meets 4 its rated value. So, I just want to make sure 5 I am terribly clear on that. The rated value 6 is the key parameter to focus on. 7 MS. ARMSTRONG: Okay. This is 8 Ashley Armstrong from DOE. 9 Once again, for the DOE regulatory 10 program, that is correct. As long as your 11 test data still supports your certified rating 12 -- so, for example, if you rate 13 conservatively, if you make changes, it might 14 be slightly less efficient, but that certified 15 rating is still supported; you are good to go. 16 Now I will say, with one caveat, 17 that if you make changes to make a model more 18 efficient and you want to claim that more 19 efficient rating, you do need to recertify 20 your product. But if you do not want to claim 21 that more efficient rating and you still want 22 to go with a conservative rating, you are good

### 202-234-4433 Neal R. Gross & Co., Inc. Page 26 1 to go. 2 MS. VOKES: And I would just add 3 for that, for EPA for the Energy Star Program, 4 we have a specific clause in our conditions 5 and criteria for certification bodies that 6 says they have to do a reevaluation in the 7 event of significant changes. And the 8 specific language says that they have to have 9 procedures to reevaluate product performance 10 in the event of changes that could affect the 11 Energy Star qualification status of the 12 product the CB has certified. 13 So, the example that you gave is 14 not something that would impact the 15 certification qualification status. And so, 16 you would be fine. 17 MR. ANDERSON: Okay. Thank you. 18 MS. ARMSTRONG: Okay. Issue two, 19 the next issue, we have gotten questions about 20 model number changes and when a model number 21 needs to be changed in terms of DOE's 22 regulatory program.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 27 1 So, do you guys want to speak to 2 any issues regarding or questions regarding 3 that specifically? 4 (No response.) 5 No? Okay. 6 MR. MANTHEI: Phil Manthei from 7 Alliance Laundry Systems. 8 Okay. If the model efficiency were 9 to go down, be less efficient, and we would 10 like to change the certified rating, then does 11 the model number actually have to change? 12 Let's say we are not making any significant 13 change to the model, but we have found through 14 verification and audit testing that the model 15 doesn't meet what we originally certified. 16 MS. BARHYDT: So, again, I can't 17 speak to Energy Star or FTC's requirements. 18 But with respect to DOE's regulatory program, 19 the only time that we require a model number 20 to change is when the product has been found 21 to be non-compliant with the standards. 22 MS. VOKES: I can confirm that is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 28 1 similar for Energy Star. So, if find that a 2 model is disqualified from Energy Star, if you 3 wanted to recertify that it is Energy Star, 4 then we require a new model number. But, 5 otherwise, we don't. 6 MR. MANTHEI: Okay. Thank you. 7 MS. KLINE: Kelley Kline with GE. 8 One question I have seen come in 9 the past is the extent or any guidance around 10 what needs to change in a model number when 11 you are making a change. You know, sometimes 12 it is a question of, can you change 13 engineering digits or is a change in the model 14 year sufficient. Or is there any thinking 15 around how significant the change needs to be? 16 MS. BARHYDT: Okay. So, if DOE has 17 found a product to be non-compliant, it needs 18 to be a change that is going to be visible and 19 noticeable to a consumer. The whole point of 20 that requirement is to ensure that consumers 21 don't get confused between a new model and an 22 old model that was not compliant.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 29 1 MS. KLINE: Okay. And I guess I 2 wasn't thinking about that example in 3 particular where DOE has the non-compliance. 4 I was thinking more of a change in the normal 5 course of things. 6 MS. BARHYDT: Since we don't have 7 any regulatory requirements with regard to 8 those, it is not impacted. 9 MS. KLINE: Okay. Thank you. 10 MS. ARMSTRONG: Okay. Moving right 11 along, the next issue that has been brought up 12 is industry test procedure versions as well 13 revisions when they have been revised, either 14 industry standards, ANSI standards, ASHRAE 15 standards that may be applicable, but DOE has 16 not yet gone through the rulemaking process, 17 but they are available publicly. 18 There have been some questions as 19 to what version should be used. So, for the 20 DOE regulatory program, the version that 21 should be used is always the version in the 22 Code of Federal Regulations. It is that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 30 1 specific version, that specific year. And 2 even if there are more recent substitutes, 3 they cannot be substituted unless we have gone 4 through a rule to update the proceeding. So, 5 I think that is fairly clear. 6 And to Jen's point and her 7 presentation this morning as to DOE adopting 8 the most recent version, we are trying to do 9 that. We have a seven-year lookback provision 10 in our statute to review each test procedure 11 at least once every seven years. If we had a 12 strong need to do so earlier, we could always 13 have that discussion when it arrives. But we 14 are committed to trying to review the test 15 procedures on a regular basis. 16 So, I am going to open the floor if 17 anyone has any questions. 18 MS. CLEARY: This is Jen with AHAM. 19 I think we are revising our test 20 procedures much more than every seven years. 21 So, what would be the best way for us to ask 22 you to update the DOE test procedure?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 31 1 MS. KOHL: You can always submit a 2 petition for rulemaking. 3 MS. ARMSTRONG: Okay? So, the next 4 issue is guidance procedures and policies. 5 When we issue guidance, as you are well aware, 6 our guidance system is relatively new. It is 7 on the website. It is by product. It spans a 8 variety of different categories, some of which 9 is applicability of standards, global 10 coverage, enforcement, certification, and some 11 of which is test-procedure-related, which is 12 probably more applicable to today's meeting. 13 That being said, some of them we do 14 put out for a draft; others we do not put out 15 for a draft because they are the Department's 16 interpretation. That being said, it is our 17 policy, if we put out as draft, to provide a 18 comment period, to send the blasts to 19 everyone. It will also be posted on our 20 website. So, that is basically the guidance 21 procedures more or less. As far as the policy 22 goes, I am turning it over to my lawyers.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 32 1 MS. BARHYDT: We had received one 2 question about the binding effect of the 3 guidance. The guidance that we issue, when we 4 issue a final guidance document, obviously, it 5 is not a legal requirement. It is an 6 interpretation of our existing regulations. 7 But we do say exclusively on every single 8 final guidance that manufacturers may rely on 9 that guidance.

10 MS. KOHL: And that was Laura 11 Barhydt from DOE. 12 MS. ARMSTRONG: So, with that, does 13 anyone have any questions about guidance 14 specifically? 15 This is Ashley from DOE. 16 MS. CLEARY: This is Jen with AHAM. 17 I think lead-in time is 18 particularly important when there is guidance. 19 So, I mean, sometimes it seems like there is, 20 for example, like a 30-day lead-in time to the 21 guidance or there is a specific date that is 22 indicated on the guidance. Is that uniform

### 202-234-4433 Neal R. Gross & Co., Inc. Page 33 1 across all guidance? Or, I think, could it

2 be? 3 MS. BARHYDT: Well, if you are 4 interested in it being a standard amount of 5 time, I would be interested in hearing about 6 that. My expectation would actually be that 7 manufacturers may want variable amounts of 8 time, depending on what they believe the 9 impact of the guidance is. If their 10 interpretation has been radically different 11 from how the Department reached the guidance, 12 it seems to me manufacturers may actually want 13 different amounts of time for the guidance. 14 But, in any case, whenever we put 15 out a draft guidance document, anyone can 16 always comment on what they believe is a 17 necessary amount of time before it goes into 18 effect, whether we specifically ask about that

19 or not. 20 MS. CLEARY: This is Jen with AHAM. 21 Thank you. And certainly, I think 22 when we know there is a certain amount of time

### 202-234-4433 Neal R. Gross & Co., Inc. Page 34 1 and there is an ability to comment, we will. 2 But when there isn't draft guidance and it 3 comes out just final, certainly, we would hope 4 that lead time is always considered. I think 5 there have been some cases where industry 6 would consider the guidance to be a change, 7 and there has been either very little lead 8 time or the lead time hasn't been expressly 9 stated. And so, then, there is confusion 10 about would it be like a standard 30 days or 11 is it today that the guidance was issued? 12 So, I have certainly noticed that 13 guidance has started to have like more of a 14 format. So, that is helpful. I think we 15 would agree that it shouldn't be like 30 days 16 across the board because in some cases that 17 may not be enough. But it is probably never 18 enough to have it be that day. 19 So, I think that would be a 20 situation we would say categorically we 21 wouldn't want to see. I think we would want 22 to have at least like maybe a standard minimum

### 202-234-4433 Neal R. Gross & Co., Inc. Page 35 1 time and more time could be allowed. 2 MS. BARHYDT: So, I know there have 3 been some growing pains with the guidance, but 4 our policy and practice now is that all test 5 procedure guidance goes out for comment. And 6 I might put one little caveat on that. There 7 have been several test procedure rulemakings 8 that have had in the body of the rulemaking 9 guidance and in the preamble. And so, we may 10 immediately just post that out in the guidance 11 document, so that somebody doesn't have to go 12 back and find The Federal Register. But since 13 it was published in The Federal Register, that 14 we wouldn't put out for comment. 15 But any new guidance is going to be 16 put out for comment for test procedures. As 17 Ashley said, we do send out blasts to all the 18 people on our regular mailing list or people 19 who have been interested in the rulemakings. 20 And so, we are trying to make sure that 21 everyone is aware whenever we put out a

22 document for comment.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 36 1 MS. CLEARY: Jen from AHAM. 2 And we thank you for that. That 3 has been very helpful. 4 MS. ARMSTRONG: All right. Moving 5 right along -- this is Ashley from DOE -- is 6 the rounding policies. We have just gotten 7 some questions generally about how is rounding 8 conducted. It is in different places in the

9 CFR. 10 So, as a general policy, before I 11 open the floor, if there are specific rounding 12 provisions in the appendices, in the test 13 procedures themselves, they obviously are 14 required to be followed. If there are 15 specific rounding provisions in the industry 16 standards that are incorporated by reference 17 or the sections of the industry standards that 18 are incorporated by reference, those are also 19 required to be followed. So, that would be on 20 a unit-by-unit basis. And then, if there are 21 different additional provisions in the test 22 procedures themselves about multiple units or

### 202-234-4433 Neal R. Gross & Co., Inc. Page 37 1 averages that they may apply, those are 2 required to be followed. 3 There are also rounding provisions 4 in 430.23. So, I would encourage you to check 5 those as well. That is the general section 6 that talks about the test procedures as well 7 as some of the requirements for the annualized 8 use for FTC labels. There are rounding 9 provisions there. 10 Now I realize that the rounding 11 provisions are not harmonized in our 12 regulations across the board as far as 13 location and whether they are or are not 14 there. So, where we do have rounding 15 provisions, they should be followed. Where we 16 don't have founding provisions at all, DOE, as 17 far as those certified ratings go in terms of 18 we look at the number of significant figures 19 in the actual standard, the energy 20 conservation standard -- that's all -- against 21 their certified rating. So, that is the 22 general matter of practice.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 38 1 That issue is still ongoing, and we 2 will be grappling with it in a future 3 rulemaking to try to kind of standardize the 4 way that it is treated as well as the location 5 to make it a little bit easier. 6 So, I will open the floor at this 7 time. But that is pretty much for the DOE 8 regulatory program. 9 MR. OSANN: This is Ed Osann from 10 Natural Resource Defense Council. 11 Could you just restate the last 12 point you made about what you are intending to 13 do in the future? 14 MS. ARMSTRONG: Oh, just generally 15 that we are going to plan to address rounding 16 provisions where they either do not exist or 17 generally how they are applied to the 18 certified ratings in a future rulemaking. 19 This is Ashley from DOE. 20 MR. OSANN: This is Ed Osann again

21 from NRDC. 22 There would be a future rulemaking

### 202-234-4433 Neal R. Gross & Co., Inc. Page 39 1 specifically on rounding? 2 MS. ARMSTRONG: This is Ashley from

3 DOE. 4 No, it would likely be part of a 5 larger rulemaking. So, for example, if we do 6 another certification and enforcement 7 rulemaking, it may be part of that, yes. 8 MR. BOWLEY: Hello. This is Brice 9 Bowley at GE. 10 I guess the one question I had, and 11 you answered it somewhat, is that if the 12 appendices or test procedures have a rounding, 13 it should be followed. I guess my question 14 is, if it is part of the test procedure, does15 it need to be applied on basically a unit-by16 unit basis, that if a unit is tested four 17 times for certification, it should be rounded 18 each time that the value is calculated? And 19 then, an average is calculated at the end with

20 the rounded values? 21 MS. ARMSTRONG: This is Ashley from

22 DOE.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 40 1 And I caveat this with you should 2 read the specific language in the test 3 procedure just to make sure they don't have 4 additional rounding provisions for like the 5 sample as a whole. And I think you meant if 6 four units are tested, not one unit tested 7 four times? 8 But, okay, so if your sample, 9 though -- most of the test procedures are 10 written on a per-unit basis. If there are 11 rounding provisions in the test procedure, 12 they are applied per unit, each unit. And 13 now, if there is additional sampling or 14 rounding provisions applied to the sample, 15 they would be specified for like the averages 16 or the UCL/LCL, those types of things. Those 17 mostly do not exist right now, though. 18 All right. So, I think that is it 19 with rounding, unless anyone has any other 20 issues. 21 (No response.) 22 Okay. With that, I am going to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 41 1 open the floor to just any other general 2 questions you may have that are not specific 3 just to room air conditioners, dishwashers, or 4 clothes washers, or maybe across the board, 5 before we move into our product-specific 6 section. 7 MR. OSANN: This is Ed Osann with

8 NRDC. 9 One more on rounding. This is 10 actually on significant digits. I think the 11 statement was made that significant digits are 12 based on the metric that is in the standard. 13 Just to be clear, would that mean, 14 for example, that if a standard were expressed 15 as, say, an efficiency of 97.6 percent, that 16 the significant digit would be one decimal 17 place? 18 MS. ARMSTRONG: This is Ashley from

19 DOE. 20 Unless there are specific rounding 21 provisions that prevail, DOE would compare the 22 certified rating to the tenth decimal place,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 42 1 as expressed in the standard, correct. 2 MR. ANDERSON: This is Vince 3 Anderson with Whirlpool. 4 I am just kind of curious. That is 5 the first time I have heard at least that, in 6 the absence of any guidance in the test 7 procedures relative to rounding, we would go 8 to the standards provision. I just wonder if 9 that ought to be documented perhaps as a 10 guidance, so that it is clear how that should 11 be applied. 12 MS. ARMSTRONG: Thanks for your 13 comment. We will consider it. 14 MR. ANDERSON: Okay. 15 MS. ARMSTRONG: Any other remaining 16 questions or open, cross-cutting-type issues 17 that may apply to all the products before we 18 move on to room air conditioners? 19 (No response.) 20 Okay. Does anybody want to change 21 seats? I know that we had a couple of 22 requests at the beginning. So, before I move

### 202-234-4433 Neal R. Gross & Co., Inc. Page 43 1 right into room air conditioners, does anybody 2 want to move around? If anyone else wants to 3 join the table, there are three seats 4 available. I promise I am not that bad. 5 All right. We are moving ahead.

6 We are ahead of schedule here. 7 So, with this, I am going to 8 strongly encourage that everyone speak up and 9 talk because the more details we have about 10 where the variances may lie between different 11 labs, the more it will help us. So, the more 12 details that you can explain, unlike the first 13 section, we really don't have a lot of 14 opinions on the next three at this point. It 15 is really we need to hear from you guys what 16 is happening, where the ambiguities exist, 17 what is going on. So, I strongly encourage 18 you to please come up and please speak up 19 freely as you may wish. 20 So, the first issue that was 21 brought to our attention has to do with the 22 actual installation of the room air

### 202-234-4433 Neal R. Gross & Co., Inc. Page 44 1 conditioner and the test chamber itself. 2 So, with that, I am going to open 3 the floor. I don't know whowants to speak 4 first. Hopefully, a lot of you want to speak, 5 as well as I will be monitoring the phone or 6 the webinar in case anybody else wants to 7 speak on that. Feel free to raise your hand, 8 and we will call on you as we cycle through. 9 But, yes, open the floor. 10 MS. CLEARY: This is Jen with AHAM. 11 We have a handout that we brought 12 which goes through some of these issues that 13 are on the agenda. Would it be helpful to put 14 it on the screen? We have it there as well. 15 MS. ARMSTRONG: Do you want to 16 describe what the general issue is, or 17 somebody? And then, maybe different people 18 can speak to different potential 19 interpretations or that type of thing with 20 additional details other than what is in the 21 box, just to help us understand. 22 MS. CLEARY: Sure. I mean, maybe

### 202-234-4433 Neal R. Gross & Co., Inc. Page 45 1 some of the companies want to speak, too. 2 MR. LINGREY: Yes, this is David 3 Lingrey from Friedrich Air Conditioning. 4 There are basic types of room air 5 conditioners with regard to chassis design. 6 There are fixed chassis designs where the unit 7 is contained as one fixed unit. You can't 8 pull out the internal parts of the unit. It 9 just gets mounted in the wall. 10 Then, there are slideout chassis 11 designs where you would mount the shell into 12 the window, and then you could slide in the 13 internals. When that is slid in, there are 14 some sealing gaskets that normally need to be 15 put in place. 16 The standard, of course, says that 17 no effort shall be made to seal internal 18 construction of the air conditioners. I think 19 that is meant for where there are bulkheads or 20 passthroughs where we seal for piping and 21 electricals and that sort of thing. I can see

22 that that makes sense not to do that because

### 202-234-4433 Neal R. Gross & Co., Inc. Page 46 1 that would be, in effect, probably a 2 manufacturing deficiency if those weren't 3 sealed properly between the indoor and outdoor 4 cavities. 5 But when there is a slideout 6 chassis, the gaskets need to be applied 7 properly obviously. Otherwise, there can be 8 some air changes or exchanges from indoor to 9 outdoor, and vice versa, which would affect 10 the efficiencies. And obviously, those need 11 to be put in place with regard to the 12 manufacturer's instructions and that sort of 13 thing. 14 I think there have just been some 15 cases where, because of placements, optimum 16 placement, it is not necessarily conveyed or 17 understood by the testing lab. In some cases, 18 there have been noticed errors. Okay? 19 And then, for example, an air 20 conditioner may be able to be slid right or 21 left inside the chassis and it tests in 22 performance better when it is on, say, the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 47 1 left side than the right side. That is where 2 things are optimized. 3 Now, in the general public 4 installation instructions, those testing 5 optimization points are not necessarily 6 conveyed because of marketing language 7 simplicities, if you will. So, it is the 8 matter of having a separate document or 9 appendices that could be used by the testing

10 lab to understand that better. 11 Do you follow me? 12 MS. ARMSTRONG: Oh, I follow. Do 13 you know what's coming? 14 This is Ashley from DOE. 15 I guess I want to understand why 16 you feel it is necessary to have additional 17 testing instructions that an actual consumer 18 wouldn't follow when it is installed in the 19 field. In other words, you are not going to 20 get that performance if you don't tell them to 21 install it, as your example, on the left or on 22 the right. If there is an optimal performance

### 202-234-4433 Neal R. Gross & Co., Inc. Page 48 1 location in a window, why should that be used 2 for testing? 3 MR. LINGREY: It is just an example 4 of some of the things that could happen 5 because the consumer doesn't test the product. 6 They install it and they operate it. Okay? 7 And it is just the way it goes. 8 MS. CLEARY: This is Jen Cleary 9 with AHAM. 10 I think what we would be suggesting 11 is that, if the manufacturer's instructions 12 indicate sealing around the unit, for example, 13 then that should be done during the testing. 14 So, that would be something that the consumer 15 would be seeing. I don't think that AHAM 16 would be suggesting anything -- I don't know; 17 I don't think David was suggesting, either -- 18 that the unit should be tested on the right or 19 on the left. I think what we are looking for 20 here is that there should be consistency from 21 lab to lab in how the units are installed. If 22 the consumer would be installing it, sealed

### 202-234-4433 Neal R. Gross & Co., Inc. Page 49 1 around the edges, then that should be done 2 during testing as well. That is how the 3 consumer will see the product. 4 MS. ARMSTRONG: Okay. So, this is 5 Ashley from DOE.

6 And I don't know; we have several 7 labs in the room. And so, I encourage you 8 guys to also speak freely. 9 But I think, from the Department's 10 position, in most cases in our test procedures 11 we follow the installation instructions that 12 are shipped with the unit. And so, that being 13 said, if there are additional specifications 14 that are not shipped with the unit, those are 15 outside the bounds. So, if there are specific 16 instructions you want DOE to follow, they need 17 to be in the installation manual available to 18 the consumer as well as anyone who may buy the 19 unit.

20 Yes? 21 MS. CLEARY: This is Jen at AHAM. 22 I think another issue we have here

### 202-234-4433 Neal R. Gross & Co., Inc. Page 50 1 in this first issue is that some labs may add 2 thermocouples to be able to get some extra 3 information about performance, and some labs 4 may not do that. And so, what we would 5 propose, I think, is that that should be 6 permitted so long as it is not interfering 7 with the airflow or the test results, that 8 there shouldn't be anything to stop a lab from 9 gaining that extra information about 10 performance. 11 MS. ARMSTRONG: This is Ashley from

12 DOE. 13 And, Ed, hang on one second on the 14 line, and I will open it up as soon as I ask 15 Jen a question. 16 Can you just explain to me, I mean, 17 I have an assumption, but can you explain to 18 me what you would use the data from those 19 thermocouples for? 20 MS. CLEARY: I will open that up to 21 companies to share. 22 MR. LINGREY: You know, the issue

### 202-234-4433 Neal R. Gross & Co., Inc. Page 51 1 with regard to thermocouples, I don't know 2 where that originated. I wasn't in all those3 original discussions. But, from a unit-under4 test aspect -- this is David Lingrey, again, 5 by the way -- we would monitor beyond what is 6 done or entered into the ASHRAE 16 standard. 7 For example, we monitor suction pressures and 8 temperatures and discharge pressures and 9 temperatures and some other things. 10 So, we understand how the unit is 11 operating beyond what can be measured in a 12 calorimeter room just by measuring input watts 13 into the space. And so, those are just some 14 things, I think that that is why that was

15 added there. 16 But if that was the case, it should 17 be done in every instance and it should be 18 added in through ASHRAE 16 testing or SPC 19 process. 20 MR. CHURCHILL: Hello. This is 21 Kevin Churchill from Intertek. 22 As far as the thermocouples go,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 52 1 they can be installed on units, and we 2 generally do. They are used just an 3 indication-only purposes. They are not 4 installed internally as far as pressures go. 5 Not all the units come with the availability 6 of hooking on gauge lines or have ports for 7 gauge lines. 8 Also, I would like to speak on the 9 insulation of the units. As far as we go, we 10 can only follow what we are given by 11 manufacturers for the insulation instructions, 12 which those insulation instructions that we 13 follow, we follow them just as the consumer 14 would, step-by-step. So, if they have a 15 right- or left-orientation, if they have a 16 foam-orientation or a sealing-orientation, 17 that is what we follow, which is directly what

18 the consumer would follow. 19 As far as the taping goes, when we 20 do tape, there is a pressure that we must 21 maintain constant between indoor and outdoor. 22 So, the taping is just for a barrier wall

### 202-234-4433 Neal R. Gross & Co., Inc. Page 53 1 purpose, making sure that there is no air 2 infiltration from indoor to outdoor.

3 We do have to make sure to ensure 4 that the taping is not over any sealing of the 5 unit from the chassis itself to the cabinet. 6 I think that is a major point to make there on 7 that, of the insulation and the use of the 8 taping. 9 Thank you. 10 MS. ARMSTRONG: Okay. Emily, do 11 you mind unmuting Ed? 12 MR. WUESTHOFF: Yes, this is Ed 13 Wuesthoff at Friedrich.

14 MS. ARMSTRONG: Go ahead. 15 MR. WUESTHOFF: The only point I 16 wanted to make had to do with listening to, 17 reading the manufacturing instructions, and 18 then reviewing some of the pictures after the 19 test. Sometimes it takes like where you can 20 see that maybe a sleeve was used that had been 21 used repeatedly with the test facility, and it 22 does not represent what is actually

### 202-234-4433 Neal R. Gross & Co., Inc. Page 54 1 manufactured, from what the customer would 2 get. 3 So, sometimes maybe the opportunity 4 to balance the way a unit has been tested may 5 be something that we want to consider because 6 there are cases that you witness the test 7 setup for certain products that we build when 8 being tested for AHRI, for example. 9 MS. ARMSTRONG: Okay. Thank you,

10 Ed.

11 MR. WUESTHOFF: You're welcome. 12 MS. ARMSTRONG: Does anybody else 13 have any comments or questions or details 14 about specifics regarding installation and 15 thermocouple placement or the addition of 16 thermocouples, before we move forward? 17 (No response.) 18 Okay. This is Ashley from DOE. 19 The next issue -- and, Jen, I don't 20 know if my agenda follows yours exactly, but I 21 tried to do it this morning when I got in. 22 But, anyway, the next issue on my agenda is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 55 1 the addition of water to the drip pan -- it 2 should say "drip," not "drop"; sorry -- prior 3 to the initiation of the test. And that does 4 follow No. 2. So, we are good to go there. 5 So, I am going to open the floor 6 about that, discussion of that issue. 7 MR. BOWLEY: This is Brice Bowley

8 at GE. 9 Yes, I think looking at this, and 10 trying to understand why someone would want to 11 add the water, partly comes into the run-in 12 and operation. A lot of times when the units 13 are being run-in as far as for the unit to 14 come to equilibrium, they are not being run-in 15 under standard conditions. They are being 16 run-in in any room that is available to allow 17 the compressor components to wear and to 18 basically come to a stable efficiency. 19 So, even though the units run for, 20 let's say, 24 hours, it may not have generated 21 any moisture and accumulated in the drip pan. 22 So, that being said, when it is put in the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 56 1 room, it is not at a stable condition that 2 represents it running for 24 hours. So, 3 adding water to it allows it to come to a 4 stabilized operation quickly. 5 MS. ARMSTRONG: Thanks. This is 6 Ashley from DOE. 7 Just a question to you. If you 8 were to add water to the drip pan before you 9 start the run-in in a condition, would then 10 you still not have to use the conditioned 11 space or you would still have to use the 12 conditioned space? Then, how long would that 13 decrease the potential run-in? Does that make

14 sense? 15 MR. BOWLEY: Well, the run-in -- 16 this is Brice Bowley at GE again -- the run-in 17 and the effect from the water are different 18 effects. The run-in, as far as if you added 19 the water before the run-in and you run in a 20 non-conditioned space and the humidity is low, 21 you are going to remove the water. 22 MS. ARMSTRONG: So, I guess the ask

### 202-234-4433 Neal R. Gross & Co., Inc. Page 57 1 here, then, if I understand you correctly, is 2 run-in is down on my list, but to add water 3 for what period of time? Just when the test 4 is being initiated or for a certain period of 5 time after run-in, before the test, to allow 6 for stabilization? What exactly are you 7 asking? 8 MR. BOWLEY: Yes, to be added prior 9 to the equilibrium, you start the hour 10 equilibrium. So, there is an hour-long 11 equilibrium. You add the water before the 12 equilibrium, let it run, and spray water. If 13 there is too much water, it will spray off on 14 the condenser and it will evaporate away, and 15 would, hopefully, come to a stabilized 16 condition. 17 And I know Jen's also comment is 18 there may need to be additional work done as 19 far as unit equilibrium, because right now the 20 equilibrium is room equilibrium, but there is 21 no definition around is the unit running at 22 equilibrium.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 58 1 MS. ARMSTRONG: This is Ashley from

2 DOE. 3 So, do you have information as to 4 what you would suggest what a unit equilibrium 5 is as compared to a room equilibrium? I mean 6 not for GE, but generally that would be 7 applicable across the board? 8 MR. BOWLEY: Yes, I don't have one 9 today, but we talked about that at our last 10 meeting, that we need to basically develop a 11 method of determining unit equilibrium. 12 MS. CLEARY: This is Jen at AHAM. 13 So, I think we would probably be 14 talking about this within AHAM and be glad to 15 submit a suggested definition to DOE, if we 16 are able to find one. 17 MR. LINGREY: This is David 18 Lingrey. 19 Yes, I agree with that as well. 20 MR. OSANN: This is Ed Osann with

21 NRDC. 22 Just to be clear, is the addition

### 202-234-4433 Neal R. Gross & Co., Inc. Page 59 1 of the water to reduce the time to prepare the 2 unit for testing or to reduce the running time

3 of the test? 4 MR. LINGREY: It is to reduce the 5 running time of the test, because it takes "X" 6 number of minutes or hours to condense the 7 water out of the air and direct it from the 8 condensate pan into the water slinging area in 9 the condenser, where it is used to help 10 optimize efficiency. Because we pull out "X" 11 pints per hour or grams per minute, or however 12 you want to measure it. So, we are just 13 trying to short-cycle that by adding some

14 volume of water. Whether that water has the 15 right volume or the right temperature, and 16 that sort of thing, needs to be addressed to 17 keep being stable. 18 MR. OSANN: Just to follow up -- 19 this is Ed Osann from NRDC again -- are there 20 any characteristics of the water that affect 21 that at all, either the chemistry or the 22 temperature?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 60 1 MR. LINGREY: The water that is 2 condensed, it is condensed water. So, it 3 doesn't have a lot of any mineral content or 4 anything of that nature as well. So, it needs 5 to be distilled-type water you are adding. 6 But it is so minor, I would imagine, unless 7 you have really terrible water -- as far as 8 temperature goes, you don't want to add in 9 100-degree water, and you don't want to add in 10 40-degree water. It needs to be something in 11 the middle, and wherever that is, I guess the 12 unit would reach equilibrium with the water 13 temperature and with the environment. So, 14 that you would need to interpret as part of 15 that definition of equilibrium. 16 MR. OSANN: One last question. Ed 17 Osann with NRDC. 18 What is the potential reduction of 19 running time of the test? Is this a matter of 20 reducing the time by a few percentage points 21 or is this reducing it by a third? Or what is 22 the sense of how much value this adds in terms

### 202-234-4433 Neal R. Gross & Co., Inc. Page 61 1 of reducing testing time? 2 MR. LINGREY: This is David Lingrey 3 at Friedrich again. 4 I think it varies with unit type 5 and size. I mean, I guess maybe the lab 6 testing people can convey that as well. 7 MR. CHURCHILL: Kevin Churchill 8 with Intertek. 9 As far as adding the water, we 10 talked a little about hours up to days of what 11 the unit would actually have to condense out 12 of the air to actually fill up the drip pan 13 enough to actually get the slinger working up 14 to the conditions that they had it at design. 15 So, adding the water to the beginning of the 16 test would certainly decrease the time that 17 you would have to wait for the condensate to 18 actually be produced from the actual unit. 19 And thus, that would help the unit to actually 20 get itself into the equilibrium point of the 21 unit and stabilizing out the room. So, 22 addition of the water would help just to get

### 202-234-4433 Neal R. Gross & Co., Inc. Page 62 1 the room to the point quicker and the unit 2 running properly quicker, rather than waiting 3 for it to actually produce the water itself. 4 MR. LINGREY: Thank you. 5 MS. ARMSTRONG: Okay. Anything

6 else on water? 7 (No response.) 8 I am actually going to skip one and 9 just go ahead. This seems like a good segue 10 into run-in time before we actually talk about 11 air sampler placement, my favorite topic. 12 So, run-in time, I am going to open 13 the floor. As you know, DOE does not have a 14 run-in time right now specifically in its test 15 procedure for room AC. So, open the floor for 16 a discussion of run-in time, including any 17 specifics. And I am going to ask you to 18 submit data over what that should be. 19 MR. BOWLEY: Brice Bowley, GE. 20 Our past experience has shown that, 21 obviously, the first 24 hours you get the most 22 reduction in energy usage as the compressor

### 202-234-4433 Neal R. Gross & Co., Inc. Page 63 1 components wear, but it continues to drop off 2 up to like 72 hours. But it is an exponential 3 curve, so you are dropping dramatically from

4 zero hours to 72 hours. 5 I think what it is similar to is 6 the EPA measurement for automobiles, which has 7 a 5,000-mile run-in. So, when you look at the 8 two, they are very similar as far as the 9 amount of hours under operation. So, 72 hours 10 for an AC or 5,000 miles for an automobile. 11 MS. ARMSTRONG: So, one question 12 back to you. This is Ashley from DOE. 13 There are a couple of variations, 14 24 all the way up to 72. Are you advocating 15 that 24 is sufficient because most of the 16 benefit is gained in that 24 hours? 17 MR. BOWLEY: I think 24 is 18 sufficient, yes. 19 MS. ARMSTRONG: Does anyone else in 20 the room have thoughts on that or anyone else 21 on the phone? 22 MR. LINGREY: This is David

### 202-234-4433 Neal R. Gross & Co., Inc. Page 64 1 Lingrey, Friedrich. 2 Yes, run-in times do vary by 3 compressor size and manufacturer. But, again, 4 it is important to loosen-up and wear-in those 5 components. So, in 24 hours, we have found 6 that is a good run-in period with a brand-new 7 product. 8 MR. OSANN: Ed Osann with NRDC. 9 Perhaps either AHAM or any of the 10 manufacturers can answer. Is it standard 11 practice for room AC units to be shipped 12 without any running time on them at all? 13 MR. LINGREY: This is David at 14 Friedrich. 15 In most manufacturing -- and I 16 don't know of everybody's manufacturing 17 facilities -- but there is a run test that is 18 performed, but it is certainly isn't of that 19 duration, obviously, because of trying to get 20 the product out. 21 So, we run units for "X" minutes 22 and that's it. But it is really not anything

### 202-234-4433 Neal R. Gross & Co., Inc. Page 65 1 that would be that long. 2 MR. BOWLEY: This is Brice Bowley

3 at GE. 4 The operation time would be five or5 ten minutes. So, it certainly wouldn't wear6 in the compressor components. 7 MS. ARMSTRONG: Okay. Does anyone 8 else have anything they would like to say on 9 run-in before we move on? 10 All right, Detlef, you are on the 11 phone. 12 MR. WESTPHALEN: Hi. This is 13 Navigant Consulting. 14 The only question I have in regard 15 to the run-in is I am aware -- I haven't 16 really looked this up myself -- but I have 17 been told that (phone cuts out) for run-in up

18 to not more than -- 19 MS. ARMSTRONG: We can kind of hear 20 you. I don't know if you are on speaker on 21 your phone, but if you could take it off? You 22 are kind of cutting in and out.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 66 1 MR. WESTPHALEN: Okay. I took it 2 off speaker. 3 MS. ARMSTRONG: Everybody in the 4 room can mute their microphones, if possible. 5 MR. WESTPHALEN: Okay. Is this

6 better?

7 MS. ARMSTRONG: Much better. 8 MR. WESTPHALEN: Okay. The 9 question is in regard to the AHRI standards 10 for some air conditioning products, commercial 11 products, where they talk about a run-in of up 12 to 24 hours and not more. And I guess I am 13 just wondering about the inconsistency of 24- 14 hours-plus versus up to 20. 15 I know that there is a rulemaking 16 getting started on packaged terminal air 17 conditioners, which are very similar, 18 obviously, to the room AC. They use the same 19 ASHRAE 16 standard for the testing. 20 So, the question comes up, what is 21 the appropriate run-in time and why would the 22 AHRI recommendation be up to 20? Back to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 67 1 Ashley's comment about whether there is any 2 test data that would be used to really 3 demonstrate what the right amount of time is. 4 MR. BOWLEY: This is Brice Bowley

5 at GE. 6 I am not sure why AHRI posed a 7 maximum. I mean, again, the units are going 8 to reach a maximum efficiency and continue 9 that maximum efficiency for what would be the 10 equivalent of years after the initial run-in. 11 My suspicion would be that they put 12 a maximum on it to limit test time in the

13 labs. 14 MS. ARMSTRONG: So, this is from 15 Ashley from DOE. 16 I can't speak to AHRI's program and 17 how they run it themselves. I can tell you 18 that DOE just adopted for commercial air 19 conditioning units an up-to limit of 20 hours. 20 An up-to limit, we say we will at least just 21 for commercial, and we did it through a 22 rulemaking, not through guidance, we said that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 68 1 we would do whatever the manufacturer did to 2 certify their products up to 20 hours. 3 So, in other words, if you guys, 4 when you came up with your certified rating, 5 put in the lab time to do 20 hours, we would 6 match that for any DOE-initiated testing that 7 we did. And that is only for commercial, and 8 that was dealt with through the rulemaking. 9 And like Detlef said, I would 10 encourage you to submit test data for room air 11 conditioners or for certain types of 12 compressors that shows over time what the 13 appropriate run-in period may be. Because, as 14 you have heard today, there are a variety of 15 different numbers that are being tossed 16 around. What the appropriate one would be 17 would be something the Department would have 18 to consider. 19 MR. MENZER: This is Mark Menzer

20 from Intertek. 21 I cannot speak for AHRI, certainly 22 on the program, although we do some of them.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 69 1 I don't know of which program you speak. AHRI 2 has about close to 40 programs with 40 3 different sets of rules. But they also do 4 about 2500 tests a year, and the problem just 5 becomes when every unit, 2500 units are being 6 looked at doing run-in. You just run out of 7 time and you run out of space. So, they 8 sometimes put some limits on it, but certainly 9 24 hours or much more than that is not unusual 10 for certain product classes for AHRI programs. 11 MR. ANDERSON: This is Vince 12 Anderson, Whirlpool. 13 I am just curious, when you have a 14 maximum run-in time, then how do you conduct 15 comparison tests between labs? And how was 16 that addressed for those commercial products? 17 In other words, test the product in Lab A and 18 then send it to Lab B and test that same 19 product again to make sure they correlate. 20 MS. ARMSTRONG: Yes. So, this is 21 Ashley at DOE. 22 If we were to do a DOE-initiated

### 202-234-4433 Neal R. Gross & Co., Inc. Page 70 1 round robin for commercial, we would uniformly 2 specify that across the board. So, say, for 3 example, we might use 20 across the board for 4 that unit or those units that we were testing. 5 Does that make sense? So, the same unit will 6 get the same run-in or we would specify the 7 provisions. 8 If it is DOE-initiated testing for 9 verification or enforcement purposes, we are 10 testing at one third-party lab, and that would 11 follow whatever the duration was that was 12 certified with the unit when it was submitted 13 to the Department. 14 MR. ANDERSON: I still didn't 15 understand how you would address that in the 16 round robin. Because when it goes to the 17 second lab, it is going to have 40 hours of 18 runtime on it then. 19 MS. ARMSTRONG: Oh, yes. It is 20 like how are you going to -- 21 MR. BOWLEY: So, this is Brice at

22 GE.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 71 1 I think, normally, a round robin is 2 run, like in air conditioners, it is run for 3 an extended period of time and then sent from 4 lab to lab. So, it is at stabilized operating 5 conditions. 6 MS. ARMSTRONG: So, you would 7 advocate running it in first and then starting 8 the round robin extensively, apparently? 9 Okay. 10 Anybody else. Sorry, this is 11 Ashley. Anybody else or anybody else on the 12 phone for a run-in period? 13 (No response.) 14 If not, we are moving to our last 15 issue for room ACs perhaps. 16 Okay. The placement of the air 17 sampler. I am going to open the floor for

18 that one. 19 (No response.) 20 Okay. Well, quietness means 21 everything is being done right. Because, 22 then, we can take it off the issues list. And

### 202-234-4433 Neal R. Gross & Co., Inc. Page 72 1 uniformly across from lab to lab, 2 manufacturers alike. 3 MR. MORRIS: This is Wayne Morris. 4 Jen had to step out. 5 This is an issue that has come up 6 on a few occasions where the air sampler is 7 placed near the unit. The ASHRAE standard 8 actually specifies a different circumstance, 9 but our question is making sure that the labs 10 are all doing it the same way. Our intention 11 is to make sure that the air sampler is placed 12 in a sequence or in a location where it does 13 not interfere with the movement of the air, 14 but which you actually get a good sampling of 15 the air near the unit. 16 There are units that are, of 17 course, different sizes. And so, specifying 18 one particular distance away may not work in

19 all cases. 20 So, we would just like to know if 21 the Department has any guidance in terms of 22 this or if we could use language as is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 73 1 suggested there on the screen with the request

2 that we have made. 3 MS. ARMSTRONG: This is Ashley from

4 DOE. 5 I am actually going to turn that 6 around to other people in the room. What do 7 you currently do, both the labs and the

8 manufacturer labs? 9 (No response.) 10 I could start calling you by name.

11 You have name cards. 12 (Laughter.) 13 MR. CHURCHILL: Kevin Churchill

14 from Intertek. 15 Obviously, right now, the way we 16 have it is with the sampler trees, every unit, 17 it is taken from a unit basis. Some units do 18 have one inlet; some have two. Some have 19 different placements, depending on the unit 20 style, whether it be a built-in unit or a 21 regular unit. 22 Obviously, the main intent is to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 74 1 try to get the sampling of the air going to 2 the inlet of the unit without restricting any 3 of the airflow to it. So, with that said, we 4 try to get it as close as possible without 5 restricting the air. 6 We use one air sampling tree on the 7 single inlets, two on the dual. We try to 8 place them far enough away from the unit. We 9 have it about three to five feet, is in our 10 procedure. In that comes a point where you 11 need to try to keep it away from the 12 condensing air as well, so you are not 13 recirculating the air. 14 Currently, in the standard I 15 believe they are in the process of updating 16 the picture that they have in there of the 17 actual placement of the unit. Obviously, for 18 manufacturers, they can always step in on that 19 guidance as well on placement of the air 20 sampler tree. 21 Thank you. 22 MS. FARBER: This is Julia Farber

### 202-234-4433 Neal R. Gross & Co., Inc. Page 75 1 from UL. 2 We actually completely agree with 3 what Intertek just said, and we are also 4 running our tests in a similar fashion. 5 MR. LINGREY: This is David Lingrey 6 at Friedrich. 7 Obviously, the sampling tree is a 8 device that can impede airflow. And we feel 9 that there is a location minimum, so to speak, 10 that you don't want to impede on. If there 11 would be something placed in the certification12 document perhaps that would indicate a stay13 away zone or to prevent recirc or prevent 14 impediments there, that might be appropriate. 15 MS. ARMSTRONG: So, this is Ashley. 16 Does anybody do it a lot 17 differently than what Intertek or UL 18 described? 19 (No response.) 20 I guess I am trying to understand 21 what the actual issue is. It seems to be just 22 general agreement with the description.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 76 1 MR. MENZER: Yes, this is Mark

2 Menzer from Intertek. 3 I think it is just one of these, it 4 is an engineering judgment call. In these 5 standards, for consistency, you want to 6 minimize engineering judgments and maximize 7 specificity. 8 MS. ARMSTRONG: Okay. So, thank 9 you. 10 This is Ashley. 11 So, with that in mind, I can 12 appreciate that. To the extent that you all 13 can work together to articulate what that 14 engineering judgment is in a fashion, whether 15 it be through the ASHRAE process, through the 16 AHAM process, through a voluntary consensus 17 process, and submit those to the Department, I 18 think that is something that we would need 19 those details to be able to flesh out some of 20 these issues that you are asking for. 21 Otherwise, I just put my engineering judgment 22 in there. And, well, that might not be a good

### 202-234-4433 Neal R. Gross & Co., Inc. Page 77 1 idea. 2 MR. MORRIS: Ashley, it is Wayne 3 again, Wayne Morris with AHAM. 4 We appreciate that and understand. 5 I think part of the concern has come that the 6 AHAM standard doesn't specify, shall we call 7 it, a minimum or a setback, as David said. 8 The ASHRAE really was not intended for this 9 kind of circumstance. And so, it doesn't do a 10 very good job of specifying. 11 I think that it is not something 12 that we have found that it makes an enormous 13 difference, but it is one of those where it 14 could affect, as we narrow down the amount of 15 deviation or differences that occur, the 16 significant digits of the actual values, this 17 becomes a potential area. So, as we get 18 differences in laboratories that laboratories 19 are testing, we want to try to reduce it. 20 So, I think that your suggestion is 21 probably a good one, that AHAM would take on 22 as a responsibility to make a suggestion of

### 202-234-4433 Neal R. Gross & Co., Inc. Page 78 1 what we believe is the right way to organize 2 this. Whether it be a range or whether it be 3 a minimum distance, we will look at that. 4 I think that you are dealing, also, 5 as Kevin said, with a 3-dimensional kind of 6 situation. It is that optimization where you 7 want to make sure you don't interfere with the 8 airflow, but you also need to get it close 9 enough that you don't have outside influences 10 on this. So, we will look at this and see if 11 we can come back with a suggestion on this. 12 MS. ARMSTRONG: Thank you.

13 MR. MORRIS: Good. Thanks. 14 MS. ARMSTRONG: Okay. So, this is 15 Ashley. 16 We have a question from the table 17 to ask. So, the issue of recirc has come up. 18 So, I am going to ask the labs in the room, 19 all those, as well as anyone else that would 20 like to chime in on this, how do you check for 21 recirc? What do you do now? 22 MR. LINGREY: David Lingrey,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 79 1 Friedrich. 2 There are several ways to do 3 recirculation assessments. One of them is use 4 smoke traces and some different things. Of 5 course, that would be something that would be 6 done in development. 7 Another is computational fluid 8 dynamics and things of that nature. But, 9 again, that wouldn't be something that would 10 be done through --

11 MS. ARMSTRONG: I haven't done that 12 since grad school. 13 (Laughter.) 14 MR. LINGREY: Yes. But just from a 15 research standpoint, there are some methods 16 that are used to come at it. From a design 17 perspective, we add some things to prevent it. 18 MS. ARMSTRONG: So, I am going to 19 come back and say, research aside, when we get 20 into audit checking, or whatever you do in 21 terms of testing, just to check to make sure 22 parts off the line are performing the way they

### 202-234-4433 Neal R. Gross & Co., Inc. Page 80 1 are supposed to; there has been no variation. 2 Do you do any recirc checks then? 3 And if you do, how do you do it? 4 MR. LINGREY: It is David from 5 Friedrich again. 6 We do add instrumentation on units 7 under test that is outside the scope of the 8 test protocols, you know, some thermocouples 9 and some different things that are generally 10 placed to understand if we are getting some 11 recirc. But that is something that I am not 12 sure that the labs are doing. 13 MS. ARMSTRONG: Would you be 14 willing to describe that general placement for 15 me? Like what exactly is it? Where do you 16 put them? What do you do? 17 MS. FARBER: Can I interrupt for 18 just one second. I'm sorry. 19 One of our folks on the phone, he 20 keeps saying that your microphone is going in 21 and out. So, he can't hear what you are 22 saying on the phone.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 81 1 MR. ANDERSON: I think when the 2 light is on -- 3 MS. ARMSTRONG: Yes, so just come 4 close to it. Light on means it is on. 5 MS. FARBER: I am sorry. They are 6 really interested. He is like it sounds like 7 it is active there; I just can't hear. 8 (Laughter.)

9 MR. LINGREY: I don't know what I

10 cut off on.

11 MS. ARMSTRONG: Whatever she asked

12 about. 13 MR. LINGREY: Well, the guy on the

14 back-end. 15 Well, thermocouple placement can be 16 placed on the inlet and discharge areas of the 17 unit, and maybe even in a grid array, to 18 sample over the aspect, the cross-sectional 19 area of that inlet, to see if there are 20 temperature differential that is caused by 21 recirc. 22 MS. ARMSTRONG: This is Ashley.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 82 1 And that wouldn't impact the 2 airflow? 3 MR. LINGREY: Well, thermocouples 4 are just a wire with a small thing.

5 MS. ARMSTRONG: I understand. 6 MR. LINGREY: They are very small, 7 and they probably in most cases will not have 8 any sort of impact. 9 MS. ARMSTRONG: Okay. Thank you. 10 Anybody else? 11 (No response.) 12 So, I am going to open the floor to 13 other issues, if anybody has any, with regard 14 to room air conditioners testing. For those 15 that they want to do an open floor, we are 16 probably going to take a break before we move 17 on to the next product of the day. 18 MR. MORRIS: Ashley, I don't know

19 whether there was a fourth one on that sheet. 20 MS. ARMSTRONG: Yes. I popped that 21 one in front. Yes, that is all the ones I 22 have, I think. Yes, sorry. I could have

### 202-234-4433 Neal R. Gross & Co., Inc. Page 83 1 stood it up. Okay. 2 Yes, run-in we got. 3 So, anybody else have any other 4 issues with regard to room air conditioners 5 that they would like to discuss? 6 (No response.) 7 Okay. At this time, I am going to 8 propose a 15-minute break. There is a coffee 9 shop all the way on the ground floor or, for 10 anyone interested, bathrooms are to the left, 11 elevators to the right. 12 For the room air conditioner 13 manufacturers that are leaving, I thank you 14 for your participation. Should you have 15 additional questions or think of additional 16 things, feel free to email me after the 17 meeting or subsequently. 18 And we will see you back in about 19 15 minutes. 20 (Whereupon, the foregoing matter

21 went off the record at 10:24 a.m. and went 22 back on the record at 10:47 a.m.)

### 202-234-4433 Neal R. Gross & Co., Inc. Page 84 1 MS. ARMSTRONG: Okay. All right. 2 We are going to start back now. We have 3 almost everyone. 4 So, we are going to move right 5 along to dishwashers. 6 Like I said before -- this is 7 Ashley from DOE -- but, like I said before, I 8 strongly encourage everyone in the room to 9 stand up and provide us details. It is hard 10 for the Department to take action items away, 11 at least to further understand and investigate 12 here with what we need to do, without 13 additional details of what is actually being 14 done different and how things are being done 15 different. 16 So, I am once again going to 17 reiterate the strong importance to stand up 18 and, if you all do it the same way, that is 19 great. If it is just that you all do it the 20 same way and that way is not detailed enough 21 in the procedure, that is great, too. I mean, 22 any details, anything that you can provide is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 85 1 helpful. 2 So, with that, moving right into 3 dishwashers, the first question we had was 4 regarding the 2010 Test Procedure Guidance 5 regarding cycle selection. 6 And, Jen, you are going to have to 7 help me out with these, if you don't mind, 8 just walking through. I will put your actual 9 dishwasher one up there, and if you could walk 10 through at least the introductory issue, and 11 then if everyone else could chime in as 12 appropriate, that would be great. 13 MS. CLEARY: Sure. This is Jen 14 with AHAM. 15 While you are putting that up, 16 actually, I can just start with the first 17 issue, which is there was some guidance issued 18 in response to a question from a company in 19 2010 on cycle selection. It stated that a 20 soil-sensing cycle is to be used, even if the 21 normal cycle is fixed. And to some, this 22 guidance changed the interpretation of the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 86 1 test procedure. 2 And so, I think one issue that we 3 had at the time, which with passage of time 4 may be less relevant at this time, although we 5 wouldn't want to see it in the future, is that 6 it would have been better prior to finalizing 7 that guidance if you had sought input, which 8 they are now doing. You are now doing it. 9 So, we appreciate that. 10 This issue, DOE is proposing to 11 address this in the SNOPR that was issued this 12 month. So, we are still reviewing that 13 proposal. We appreciate that DOE is taking 14 the initiative to address it. And we will 15 certainly provide written comments on the 16 issue. 17 But a major concern here is how 18 different labs will do this testing. And so, 19 we do think that there should probably be an 20 interim solution of some kind while the 21 rulemaking is ongoing. 22 This is really a complex matter.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 87 1 So, what AHAM would propose is that, if it is 2 possible for DOE to require or permit 3 manufacturers to indicate on their 4 certification statement the cycles and options 5 that were used during the energy test, that 6 might be a way to address this and to ensure 7 that DOE and other third-party labs that might 8 be doing verification testing would be using 9 the same cycles and options that were

10 selected. 11 It might also be useful to identify 12 in the certification report whether or not the 13 unit is soil-sensing, whether the cycle is 14 soil-sensing. That goes into kind of our next 15 issue as well, but I think that issues 1 and 2

16 on our sheet are connected and stem from the 17 same guidance. 18 So, issue 2 is, how does a lab 19 identify if the cycle is soil-sensing? Again, 20 this is complicated. I am sure companies have 21 more details to share, but that is the general 22 issue.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 88 1 MS. ARMSTRONG: Go ahead. Like I 2 said, I do encourage you -- this is an open 3 rule. I will remind you DOE will not probably 4 at this point, because it is an open rule, 5 make comments. We have proposed stuff. To 6 the extent you have comments on our proposal 7 or further clarification, I strongly encourage 8 you to submit them to this docket. You are 9 welcome to speak in this forum as well, but, 10 also, please submit them to that docket as

11 well. 12 MR. KLUG: Well, good morning. 13 Wayne Klug at Whirlpool. 14 Certainly, the SNOPR content is 15 very helpful in regard to this topic. As I 16 look at the definition of the normal cycle in 17 the SNOPR, and I don't think that has changed 18 very much from the original language of the 19 current procedure. It talks about the cycle 20 type that includes wash-and-dry options 21 recommended by the manufacturer for completely 22 washing a full load of normally-soiled dishes,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 89 1 including the power dry option.

2 As I look at the SNOPR content that 3 is being proposed -- and this is 2.6.3.2; 4 sorry about the chapter-and-verse reference 5 here, but I think it is helpful to have that 6 context -- it looks like that if a normal 7 cycle does not contain a soil-sensing 8 capability, then another cycle that may 9 contain that soil-sensing capability is used 10 or would be used for the testing. 11 And so, really, more for 12 clarification, it sounds like a manufacturer 13 may be able to recommend or identify a normal 14 cycle, but you could have a non-normal cycle 15 of, say, pots and pans on a more heavy-load 16 end of the spectrum or a cycle on the other 17 end of the spectrum that is not as heavy in 18 terms of cycle behavior that could be used for 19 the actual soil-sensing load and not the 20 normal, everyday cycle that would be 21 specified. 22 So, really, I was just looking for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 90 1 more clarification around that topic. Sorry 2 about the long wording and description. 3 MS. REICH: Judith Reich from 4 Navigant. 5 Yes, you are correct, the SNOPR 6 does address that particular topic, and it 7 does, indeed, follow the approach in the 8 guidance that was provided to the 9 manufacturer. And you are also correct in10 that, if the normal cycle does not have soil11 sensing capability, it is the proposal that12 the alternate cycle that does have soil13 sensing capability be tested because the 14 provisions in the test procedure for testing 15 under varying soil conditions are intended to 16 be used for soil-sensing dishwashers. 17 MR. KLUG: All right. Thank you. 18 So, really, just probably more of a 19 footnote would be that the normal cycle may be 20 an everyday use sort of cycle. But one of 21 these other cycles may be less common, less 22 commonly used by customers, but that could end

### 202-234-4433 Neal R. Gross & Co., Inc. Page 91 1 up being used for the actual test procedure. 2 MS. ARMSTRONG: Good. Thank you. 3 MR. EDWARDS: Mike Edwards, BSH. 4 So, how would the verification labs 5 determine if it is a soil-sensing cycle unless 6 we tell them something? 7 MR. BILLINGS: Lincoln Billings

8 from Intertek. 9 The only methods we have to10 determine whether or not a unit has soil11 sensing capabilities is through what is 12 provided via the use-and-care manual of the 13 unit. 14 MS. ARMSTRONG: So, this is Ashley 15 from the Department. 16 So, you are advocating Jen's 17 position of perhaps writing more information 18 upon the certification of the products, about 19 its features? 20 MR. EDWARDS: Mike Edwards from the

21 BSH team. 22 Yes, that is correct, either in the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 92 1 certification report or the manual. 2 MS. ARMSTRONG: Okay. 3 MR. EDWARDS: I think we have to 4 include additional information. 5 MS. ARMSTRONG: So, a question 6 about what you do currently, because, 7 obviously, open rule, but do you all, if it 8 has a soil sensor, is that clearly indicated 9 in the manual shipped with the unit now? 10 MR. EDWARDS: For BSH, it is now. 11 MS. ARMSTRONG: Okay. 12 MR. EDWARDS: But it hasn't always

13 been. 14 MS. ARMSTRONG: Okay. 15 MR. KLUG: I believe that is the 16 case for Whirlpool as well. 17 MS. ARMSTRONG: Okay. All right. 18 Any other issues with the first couple? 19 (No response.) 20 Okay. The next issue I think we 21 are going to go to is the detergent volume 22 calculation.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 93 1 MS. CLEARY: Hi. This is Jen with

2 AHAM. 3 Some interpretative confusion 4 exists regarding the detergent volume 5 calculation. I think there maybe has been 6 some guidance around this. In any case, it is 7 now addressed; DOE is proposing a solution to 8 this in a SNOPR. So, we will certainly submit 9 some written comments. We are reviewing that 10 proposal. 11 We had also raised an issue about 12 the actual detergent itself, and that has also 13 been addressed in the SNOPR, the Cascade with 14 the Grease Fighting Power of Dawn. So, we 15 certainly support that. 16 Upon first review of the proposal 17 with regard to the calculation, though, we 18 think there may still be some room for 19 interpretation that would make verification 20 testing challenging. So, we will detail that 21 in our written comments. 22 Kind of a connected issue here,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 94 1 recently, phosphates are no longer allowed in 2 the detergent and, also, we believe that 3 consumers may be using the tablet form of 4 detergent that could have rinse aid in it as 5 well. And it is a dosage that is the same 6 every time. So, we think consumers are using 7 those more and more, and it may be necessary 8 to do some kind of consumer use study on how 9 those different detergent types should be 10 incorporated into the test procedure as well. 11 That is, obviously, a longer-term thing, and 12 we can provide some more detail on that in 13 written comments as well, but wanted to raise 14 that here today. 15 MS. ARMSTRONG: All right. Thank 16 you. 17 MR. EDWARDS: Mike Edwards, BSH. 18 I think one point of confusion is 19 that, if you run the preconditioning cycles 20 and determine your detergent calculation, and 21 then when you run the actual test, if the 22 water usage comes out differently, what do you

### 202-234-4433 Neal R. Gross & Co., Inc. Page 95 1 do in those cases? 2 And one other one would be that, if 3 you determine from the precondition cycles to 4 use detergent in the pre-wash and the main 5 wash, and then the sensors take out the drain 6 so that they become one and the same, how 7 would you interpret that detergent usage? So, 8 just a couple of things to keep in the back of 9 your mind. 10 MS. ARMSTRONG: Do you have a 11 suggestion? 12 MR. EDWARDS: No, not at this 13 point, but I think it is something we could 14 try to work on. 15 MS. REICH: Judith Reich from 16 Navigant. 17 I just wanted to point out that in 18 the SNOPR one of the proposals would be to 19 require that the preconditioning cycle be run 20 with the same cycle setting as for the energy 21 test to try to ensure that the water 22 consumption that is measured to determine

### 202-234-4433 Neal R. Gross & Co., Inc. Page 96 1 detergent dosing is as close as possible to 2 what is used during the energy test. 3 MR. EDWARDS: Mike Edwards, BSH. 4 So, you do the preconditioning 5 cycles with food soil? Is that what I am 6 understanding? 7 MS. REICH: The proposal right now 8 is for no load during preconditioning. 9 MR. EDWARDS: Mike Edwards again. 10 The sensors and the food soil will 11 impact each other. 12 MS. REICH: I recognize that, and 13 it was an issue of test burden to do the 14 preconditioning without the soil load. 15 MR. KLUG: Wayne Klug at Whirlpool. 16 I think, on that topic, Jen's 17 earlier point and Mike's point, as we look at 18 potentially the use of tablets, which are more 19 commonly-used today perhaps as we migrate in 20 that direction, or look at migration in that 21 direction, that may allow us to move away from 22 that percent concentration approach/concern

### 202-234-4433 Neal R. Gross & Co., Inc. Page 97 1 and use really what the customers are doing 2 when they are putting a tablet or a uni-dose 3 or a set amount of detergent in their machines 4 more and more. It is just an option for us to

5 look at. 6 MS. ARMSTRONG: Okay. Chris 7 Roberts on the phone, I think your line should 8 off mute now. And I am going to ask everyone 9 in the room to mute their lines, if they don't 10 mind. 11 Chris? 12 MR. ROBERTS: Yes, ma'am. 13 MS. ARMSTRONG: There you go. 14 MR. ROBERTS: I just wanted to send15 in a comment. We were talking about the use16 and-care books. And our use-and-care books do 17 not indicate if a cycle (phone cuts out). 18 MS. ARMSTRONG: So, can you get 19 closer by chance to the phone? Or take me off 20 speaker and then speak? Because you are 21 cutting in and out when you are on speaker, 22 please.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 98 1 MR. ROBERTS: How about now? Can 2 you hear me now?

3 MS. ARMSTRONG: Much better. 4 MR. ROBERTS: All right. Yes, 5 there were the comments going about the sensor 6 cycles versus the fixed cycles, and I was 7 trying to just comment that our use-and-care 8 books do not necessarily indicate which cycles 9 are sensor-based and which are fixed. And 10 that is why I shot you that note on the 11 webinar notes through the questions. I think 12 everybody else was commenting that they 13 typically did indicate that. 14 MS. ARMSTRONG: Okay. Thank you. 15 MR. ROBERTS: Thank you. 16 MR. OSANN: This is Ed Osann from

17 NRDC. 18 What company was the speaker with?

19 MS. ARMSTRONG: GE. 20 Okay. Anything else on detergent

21 volume? Go ahead. 22 MR. EDWARDS: I was just going to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 99 1 make a comment. The detergent can influence 2 the sensor decision. So, it is a 3 fairlycritical subject. 4 MS. ARMSTRONG: Okay. Thank you. 5 Like I said, to the extent in your 6 comments in response to the SNOPR, if you have 7 a specific proposal -- I realize the SNOPR 8 recently came out. So, you may not have time 9 to fully have read it, et cetera. But to the 10 extent you have any specific proposals or 11 definitely proposals other than the ones we 12 have, I encourage you to submit those in 13 addition to your comments. 14 Okay. The next one is 15 substitutions. I think there is a variety of 16 questions regarding this, whether it be 17 flatware substitutions, soil substitutions, as 18 well as table, for lack of a better term, 19 tableware substitutions. 20 So, Jen, I will turn it over to 21 you. 22 Some of this is also addressed in

### 202-234-4433 Neal R. Gross & Co., Inc. Page 100 1 the SNOPR as well. To the extent there are 2 other things that need to be addressed, please

3 let us know. 4 MS. CLEARY: Jen with AHAM. 5 Yes, flatware I know is being 6 addressed in the SNOPR. We appreciate that. 7 We made a recommendation to DOE, and we 8 appreciate that the proposal is to adopt that 9 recommendation. 10 Then, there are, though, some other 11 substitutions that we can see right now need 12 to be made. And also, we anticipate that, 13 because like the food soils and the dishware 14 and the flatware are all specified, you know, 15 exactly, that as those things change and they 16 are outside of our control, this is an ongoing 17 issue that things become obsolete. 18 And so, I would think the broad 19 issue with substitutions is that there needs 20 to be some kind of quick and clear process for 21 getting substitutions. 22 Rulemaking, probably while it was

### 202-234-4433 Neal R. Gross & Co., Inc. Page 101 1 very handy that this time around there was an 2 open rulemaking to address flatware, and, 3 hopefully, we can get some of these other 4 issues that we have to raise today taken care 5 of through that rulemaking as well, that is 6 not always the case. If it is no longer 7 available, it is hard or impossible to do 8 testing until there is something uniform in 9 terms of the substitution. So, I think that 10 is the overarching comment. 11 Specifically, for soils that are 12 not available now exactly as DOE has 13 specified, I think one example would be the 14 margarine. I think we have seen some guidance 15 to use the Fleischmann's Original margarine, 16 but would look to see if DOE has guidance on

17 that. 18 AHAM's Task Force will certainly be 19 evaluating substitute food soils and would be 20 glad to make recommendations to DOE, but we 21 would request those substitutions be made 22 clearly and quickly.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 102 1 Also, the dishware -- this is No. 2 5 -- the dishware that is currently -- 3 MS. ARMSTRONG: Can I jump in real 4 quick before we move on for margarine? 5 MS. CLEARY: Yes, yes. 6 MS. ARMSTRONG: So, obviously, any 7 guidance DOE issued will be posted on our 8 website and is only applicable for the 9 regulatory program or is the guidance 10 applicable for the regulatory program. 11 What are manufacturers, third-party 12 labs, doing now if there is unavailability of 13 this margarine? Are you not testing? 14 MR. EDWARDS: Mike Edwards, BSH. 15 We have dishwasher dishes that are 16 in specification. But if we have to get new 17 ones, we could -- 18 MS. ARMSTRONG: Margarine? 19 MR. EDWARDS: Not margarine, no. 20 We are using the margarine that we agreed to 21 in the AHAM group. What is it, Wayne? Do you

22 remember?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 103 1 MR. KLUG: Well, I think that, for 2 example, the margarine, there is a stick 3 original Fleischmann's original that is called 4 or available that is kind of the closest 5 representation of that margarine. So, we 6 really kind of go out, whether it is the 7 detergent or the margarine, we try to find 8 that substitution that is really the closest 9 match, and we talk about it within industry.

10 Go ahead. 11 MR. EDWARDS: We discuss it within 12 AHAM and try to do the same thing. 13 MS. ARMSTRONG: Right. Jen, or 14 whoever, is this an AHAM thing that you guys 15 discuss it and say, okay, we all agree to do 16 this? At what point could you come to the 17 Department? I mean, could you tell us 18 upfront, "Hey, either this is almost obsolete 19 or at least some of our members are having 20 trouble finding it right when it happens."? 21 And then, "Oh, we are working on a solution or 22 an agreement internally."

### 202-234-4433 Neal R. Gross & Co., Inc. Page 104 1 Because the earlier we know about 2 it, the better. Obviously, I don't know how 3 this affects -- we can talk about this 4 internally as far as what pathway might get us 5 to an answer the quickest. 6 But, like I said, to the extent you 7 are using something other than what is in DOE 8 guidance and/or CFR that hasn't been approved 9 specifically by the Department, that would be 10 at your -- 11 MS. CLEARY: Yes, so I think that 12 is why we are raising these issues today, 13 certainly. I think in the future, yes, we 14 probably should notify you when we become 15 aware of the issue, let you know we are 16 working on it, as we did with flatware. I 17 think that would be what we would continue to

18 do. 19 This is Jen from AHAM.

20 MS. ARMSTRONG: And I would also 21 encourage for anyone on the phone or any 22 third-party labs in the room, if you have

### 202-234-4433 Neal R. Gross & Co., Inc. Page 105 1 similar issues, whatever lab it is, that you 2 come to the Department and ask the question 3 when it has to do with a DOE regulatory test 4 procedure. That way, we can issue regulatory 5 guidance and it will apply across the board. 6 MR. KLUG: I think just to 7 underscore Jen's comments, and I think she 8 stated this very well, in that from time to 9 time these items do show up. And a lot of 10 times, there are surprises, like, "Oh, crud, 11 we can't order this fork anymore." And so, we 12 work to try to identify those substitutes and 13 work diligently with AHAM, with the 14 stakeholders, to try to find the right 15 substitution. 16 I think the point to underscore is 17 just that process for substitution, whether it 18 is a guidance approach or an industry-wide 19 waiver. Because, really, the rulemaking is a 20 great process, but it takes time to go through 21 that process. And so, really looking for 22 something that can expedite this, because it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 106 1 is going to come up over and over. 2 Even though we work with the 3 suppliers of, let's say, cutlery and we ask 4 them, "How long will you have the cutlery 5 available," and they say, "Forever," or at 6 least for a fairly long period of time, but, 7 in reality, these things are going to come up

8 over and over for us. 9 MS. ARMSTRONG: Okay. We 10 understand, to the extent we need to talk 11 internally here, but we understand the issue.

12 MS. CLEARY: Jen from AHAM. 13 I think the only other detailed one 14 that we would share today would be the 15 dishware. This would be an example where we 16 are giving you an early heads-up that it is 17 not obsolete yet, what is referenced in 18 Appendix C, but it is getting very difficult 19 to source. So, we will be working on 20 suggesting some substitutes and we will share 21 that with the Department once we have a 22 suggestion.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 107 1 MR. EDWARDS: Mike Edwards, BSH, 2 again. 3 More of a general comment, we need 4 to try to make sure as best we can that we 5 work with Canada and try to get consensus on 6 the interpretations. We are seeing that 7 Canada has a couple of different 8 interpretations in some cases than DOE. That 9 would be very burdensome. 10 MR. KLUG: Yes, just to extend 11 that, that is a good thought, Mike. To extend 12 that a step further is there is a test 13 procedure that Canada uses for energy testing

14 as well. I know there are efforts to have 15 those procedures be common and similar. But 16 it does come up for really both countries. 17 MS. ARMSTRONG: Okay. Moving 18 along, preconditioning is the next issue. 19 MS. CLEARY: This is Jen with AHAM. 20 The issue that we have identified 21 is that the definition of preconditioning is 22 kind of vague, and it is not adequate for the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 108 1 way some products operate today. The SNOPR 2 published this month does make a proposal to 3 address this issue, and Judy was discussing 4 this earlier, which is that the 5 preconditioning cycle would be the same as the 6 one, the cycle or cycles used for the energy

7 test. 8 AHAM does agree with that. That 9 was what our suggestion would have been. 10 However, our first glance at the SNOPR, we 11 think that the language in there may be a 12 little too confusing, and it could just be 13 more simply stated that the cycle used for 14 preconditioning shall be the same as the 15 cycles used for the test. So, we will 16 certainly provide some more detail on that in 17 our written comments. 18 MS. ARMSTRONG: Okay. Thank you. 19 Any other comments or specific 20 concerns regarding preconditioning at this 21 time? 22 MR. KLUG: Wayne Klug at Whirlpool.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 109 1 Probably the only thought that 2 comes to mind is the previous language 3 associated with or in the existing DOE 4 procedure seems to allow for a partial cycle 5 to be used. The language, as I read it, in 6 the SNOPR, 1.1.5, reads, "Preconditioning 7 cycle means the cycle that includes a fill, 8 circulation, and drain to ensure that the 9 water lines and sump area of the pump are 10 primed." And certainly, that is a very 11 important aspect of the preconditioning cycle. 12 But, as I think about this, we 13 really want to ensure that there is an 14 allowance for a complete cycle to be 15 performed, so that sensors can be calibrated, 16 so that the water usage can be established for 17 the amount of detergent used. And so, perhaps 18 as we look at the wording here, we can adjust 19 it to reflect that a complete cycle or cycles 20 be used/allowed for preconditioning. Because 21 I am aware of some laboratories that actually 22 perform more than one preconditioning cycle

### 202-234-4433 Neal R. Gross & Co., Inc. Page 110 1 just to be sure that the machine is cleaned 2 out and they have understood the amount of 3 water usage. 4 MS. ARMSTRONG: Thank you. 5 I actually just have a general 6 question regarding soil sensors for you all. 7 At what point are you sure that the soil 8 sensor has actually been engaged? So, is it 9 clear that, if it runs once in the 10 preconditioning cycle -- and this may just be 11 my lack of knowledge -- but is it clear that, 12 if it runs once, that the soil sensors are 13 engaged or does it actually need to run 14 multiple times when it is first plugged in to 15 make sure that soil sensor is working properly 16 as it was intended? 17 MR. KLUG: I can speak for the 18 Whirlpool product, and the design intent is 19 that one cycle is sufficient to establish the 20 sensor behavior. Now we do have repetitions 21 built in. If, for some reason, that first 22 cycle doesn't calibrate, then it takes another

### 202-234-4433 Neal R. Gross & Co., Inc. Page 111 1 look at the next cycle as well. 2 MS. ARMSTRONG: So, if that one 3 cycle is used for preconditioning, how would 4 you know, in other words? You can chime in

5 here. 6 MS. REICH: Judith Reich from 7 Navigant. 8 I wanted to add to that question. 9 Does that first cycle require a soiled load in 10 order to properly calibrate the sensor? 11 MR. KLUG: For Whirlpool, no, we 12 are really looking at the clear-water base. 13 MR. EDWARDS: Mike Edwards, BSH. 14 I agree with Whirlpool's comments, 15 but in our lab we run two preconditioning 16 cycles, one to clean out anything that may be 17 in the machine, the oils or things like that 18 were used in the manufacturing process, and 19 then the second to actually get the 20 calibration with the clean water. So, we are 21 trying not to use the energy test calibration 22 from something that may be influenced by

### 202-234-4433 Neal R. Gross & Co., Inc. Page 112 1 external stuff. 2 MR. OSANN: This is Ed Osann with

3 NRDC. 4 Just an observation. It is not 5 clear whether this calibration is something 6 that is required, is a self-calibration of the 7 sensor or this requires a tech to actually do 8 something to the machine. 9 MR. KLUG: For Whirlpool, it is a 10 self-calibration. 11 MS. ARMSTRONG: This is Ashley from

12 DOE. 13 I will say the Department has seen 14 instances where the first cycle doesn't engage 15 the sensor, for whatever reason. So, there 16 are at least some products out there the 17 Department has come across in testing where we 18 have not been able to engage the soil sensor 19 on the first run. 20 That being said, if there is 21 variation in the industry or even within a 22 given manufacturer's model offerings, I would

### 202-234-4433 Neal R. Gross & Co., Inc. Page 113 1 ask, how do we ensure that the soil sensor is 2 engaged? 3 (No response.) 4 Everyone is staring at me, for 5 those on the phone who don't have the benefit 6 of seeing the room. 7 MR. EDWARDS: This is Mike Edwards,

8 BSH. 9 We have equipment in our labs, and 10 we can tell that very easily in our internal 11 tests. But I don't know how to describe it 12 for you to tell that. 13 MS. ARMSTRONG: So, how would DOE 14 figure that out if it was running a 15 verification test at a third-party lab? How 16 would a third-party lab figure that out? 17 MR. KLUG: Wayne at Whirlpool. 18 I think my answer is the same as 19 BSH, as Mike's. With our internal equipment, 20 monitoring some connection to the controls, 21 and so forth, we can get varying levels of 22 that detail. But, for an outside lab, I am

### 202-234-4433 Neal R. Gross & Co., Inc. Page 114 1 not sure there is a clear way of determining

2 that. 3 MS. ARMSTRONG: So, then, our 4 question would be, if there is variation -- I 5 realize there may not be variation between 6 those in the room here -- but if there is 7 variation within the industry, is it 8 worthwhile running multiple preconditioning 9 cycles or a number of them, or maybe the 10 manufacturer specifies that certification 11 represents how many cycles that may take for 12 you to ensure that the soil sensor actually is 13 engaged, or whether or not it needs soils 14 versus clean water, or the characteristics 15 that would perhaps, maybe not ensure 100 16 percent of the time, but for the most part it 17 would be engaged? 18 MR. KLUG: I think there is benefit 19 to the additional cycles. For example, if the 20 machine is taken out of the box, and maybe 21 there is some sort of residual dirt in a 22 factory process, something, that first clean-

### 202-234-4433 Neal R. Gross & Co., Inc. Page 115 1 out cycle or first cycle could be used to 2 clean the machine, if you will. 3 So, additional cycles, at least the 4 way our machines are set up, if it doesn't 5 calibrate on the first cycle, an additional 6 cycle would give it that opportunity to 7 calibrate. So, more is better, although we 8 try to make sure it functions as intended 9 within that first cycle. 10 MR. EDWARDS: Mike Edwards. 11 I will just add to that some. 12 Depending on how the manufacturers write in 13 their program logic, it could receive a 14 calibration error. And what they do after 15 that could depend on whether you are getting a 16 sensor response or not. So, if it gives a 17 calibration error and they just stop the 18 process, then it will have a default path that 19 it would go to. So, it kind of depends on 20 what the manufacturers are doing and their 21 philosophy. So, you can't really answer for

22 all the manufacturers.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 116 1 MS. BARHYDT: This is Laura Barhydt

2 at DOE. 3 If there is some kind of a 4 calibration problem, is there a light or a 5 readout or something on the unit that would 6 indicate that? 7 MR. EDWARDS: No. Again, it 8 depends on what the manufacturer decides to 9 do. It doesn't mean that they can't ask for 10 another calibration within that same run. So, 11 there could be multiple calibration requests 12 in that same cycle. 13 MS. ARMSTRONG: Okay. So, it would 14 just keep trying to calibrate, even though you 15 are running the same first preconditioning? 16 MR. EDWARDS: I know what we do, 17 but I don't know what everyone else -- 18 MS. ARMSTRONG: Right. That could 19 be the case, though? I got it. Okay. 20 MR. KLUG: Yes, similar with 21 Whirlpool, it will work to calibrate on the 22 subsequent cycle.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 117 1 MS. ARMSTRONG: Okay. 2 MS. BARHYDT: This is Laura Barhydt

3 at DOE. 4 One other thing that we have 5 encountered is that some units don't run the 6 selected cycle, depending on what feedback it 7 is getting through its sensors. Is there any 8 way for a test lab to know whether it is 9 really running the cycle that has been 10 selected or not? Does that not make any sense 11 to you? 12 (Laughter.) 13 So, my understanding -- 14 MS. ARMSTRONG: Like an override --

15 MS. BARHYDT: Yes. 16 MS. ARMSTRONG: -- is the best way 17 to say it. 18 MS. BARHYDT: Something didn't 19 calibrate or some issue was detected. And so, 20 the unit defaults to some kind of set cycle 21 that it knows to run in order to remedy the 22 issue.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 118 1 MR. EDWARDS: Mike Edwards, BSH. 2 It is obviously difficult to 3 comment because I don't know exactly which one 4 you are talking about. But the complexity of 5 cycles is increasing, and there are multiple 6 sensor decisions and there are multiple things 7 the sensors are doing now. They are speeding 8 up motors. They are changing temperatures. 9 It is not just about water fills. 10 I think it would be, again, very 11 difficult for labs outside the manufacturer to 12 know exactly what is happening within the 13 cycle. We watch it very carefully when we run 14 tests, and we know what paths we wanted to 15 take when we do certain things. 16 That didn't answer your question, 17 but maybe it helped. 18 MS. BARHYDT: This is Laura Barhydt 19 at DOE again. 20 I think what I am wondering is, is 21 there some kind of information you could 22 provide that would be something that the lab

### 202-234-4433 Neal R. Gross & Co., Inc. Page 119 1 could see and say, I don't know, "It ran for 2 20 minutes. Clearly, it didn't do what it was 3 supposed to do."? Or "It ran for 45 minutes. 4 Clearly, that was not the normal cycle that 5 was supposed to be the energy test cycle."? 6 So, is there some kind of 7 characteristic that you could convey possibly 8 in a certification report or through some 9 mechanism that the lab would know whether or 10 not it is getting what it thinks it is 11 getting? 12 MR. KLUG: Wayne at Whirlpool. 13 For example, if you were to watch 14 the cycle behavior, there are indicators that 15 are in, for example, the wattage chart and the 16 water usage results of that product that would 17 be indicators of how that machine is operating18 or behaving. But that would be dishwasher19 specific, and I know within our various 20 products we build, that there is a lot of21 different approaches. And so, the one-size22 fits-all would probably be difficult. You

### 202-234-4433 Neal R. Gross & Co., Inc. Page 120 1 would have to look at it product-by-product. 2 MS. BARHYDT: Okay. Thank you. 3 MS. ARMSTRONG: We have somebody on 4 the line who would like to speak. So, Debra, 5 can you --

6 MS. BENGSTON: Sure. 7 MS. ARMSTRONG: Make sure you are 8 off speaker and you should be ready to go. 9 MS. BENGSTON: I will try to speak. 10 One of the things I can recommend is that 11 usually if the lab will read the use-and-care, 12 I believe there are charts that have an 13 overview of the cycle which talk about how 14 cycles should be, approximate (phone cuts 15 out). That would give the lab a clue to the 16 sensor may have run. And if it did not meet 17 the energy cycle, if it was listed in the 18 manual, the temperature, the main wash, then 19 they would know most likely that the 20 calibrating sensor did not happen. 21 MS. ARMSTRONG: Okay. So, you 22 broke up just slightly during that. So, I am

### 202-234-4433 Neal R. Gross & Co., Inc. Page 121 1 going to repeat what I think I heard, just so 2 you can confirm. 3 Basically, I thought you said that 4 within the manuals there are various 5 descriptions/characteristics of the different 6 cycles that would be run, that the labs could 7 compare what actually happened to ensure or 8 give some indication whether the actual 9 correct cycle was actually run or if there was 10 some overriding function that took place and 11 something needed to be rerun. Is that fair? 12 MS. BENGSTON: That is fair. 13 MS. ARMSTRONG: Okay. And can you 14 just remind us who you are with? 15 MS. BENGSTON: Viking Range 16 Corporation. 17 MS. ARMSTRONG: Thank you so much. 18 Anybody else? 19 MR. EDWARDS: This is Mike Edwards. 20 We do put water usages in our 21 manual, but we normally do not include a 22 chart. So, I mean, you give the min and the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 122 1 max water usages. If it is between those two 2 figures, then most likely -- 3 MS. ARMSTRONG: Well, one could 4 argue, though, I mean, obviously, most people, 5 everyone in the room gets those numbers right. 6 But if it happens to be a maximum water usage 7 that exceeds that table, it is not necessarily 8 indicative of the wrong cycle, correct? 9 MR. EDWARDS: Correct. That is

10 correct. 11 MS. ARMSTRONG: Okay. So, we would 12 like some indicator maybe other than one that 13 would also potentially indicate that there is 14 an issue with compliance, if possible. 15 MS. FARBER: This is Julia Farber

16 from UL. 17 I just wanted to go back to the 18 preconditioning question about how 19 laboratories are running. At the moment, our 20 laboratories are running one conditioning run, 21 and that is because of DW-1, your 22 recommendation.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 123 1 MS. ARMSTRONG: All right. Anybody

2 else? 3 (No response.) 4 We are going to move on to drain 5 height. And I am going to quickly pass this6 one to Jen. Or do you want to do yours, soil7 loading procedures? That is fine, too. Do 8 you want to move -- MS. CLEARY: Yes, 9 if you don't mind, I think we tried to 10 prioritize. 11 MS. ARMSTRONG: Yes, that's fine. 12 MS. CLEARY: Okay.

13 MS. ARMSTRONG: Please do. 14 MS. CLEARY: So, there are a number 15 of these issues with the soiling details and 16 loading procedures. I think the overall 17 comment we would have is that anytime there is 18 soiling involved or loading being done of 19 soiled and non-soiled dishes, it is really 20 helpful for labs to have like a visual of what 21 other labs are doing. So, some of these 22 issues, the best way to solve them may be for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 124 1 DOE to allow other labs, including 2 manufacturing labs, to view how DOE's labs are 3 doing the testing because that would be the 4 best way for everyone to know if they are 5 doing it the same way. 6 That could be done through like a 7 YouTube video or something or to actually go 8 to the lab. This is something, the YouTube 9 video is something we are sort of starting to 10 use in AHAM to know if everybody is doing 11 things the same way, because we may actually 12 be using the same words to describe something, 13 but in actual practice, when you see it being 14 done, it is different. 15 So, that is a tool that we are 16 finding to be useful, and we might suggest 17 that DOE do the same thing as well. I know we 18 have also made this recommendation with regard 19 to the Energy Star test procedure development 20 right now for dishwashers. So, that is sort 21 of an overarching comment. 22 Then, we have some very detailed

### 202-234-4433 Neal R. Gross & Co., Inc. Page 125 1 soiling questions I think here, as well as 2 some recommendations. So, No. 8 on our issue 3 list here -- 4 MS. ARMSTRONG: Let's go back for a

5 second.

6 MS. CLEARY: Yes. 7 MS. ARMSTRONG: This is Ashley from

8 DOE. 9 So, for the most part, I will say, 10 as of now, we are using the same third-party 11 labs that everyone in this room has access to. 12 So, to the extent you know there are 13 differences between the way the soils are 14 being applied, the way the loading is being 15 done, I ask that you, rather than -- well, the 16 YouTube video site, I actually ask that you 17 point it out. 18 Obviously, we would like to 19 articulate something to the extent we could or 20 to the extent that it is necessary. What 21 specific instructions are needed in addition 22 to what already may be provided, either in the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 126 1 AHAM method or outside of that? What is 2 actually being done different from lab to lab 3 in terms of soiling or how they are being 4 applied or how they are being loaded?5 Because, like I said, for third6 party replication, we are using third-party 7 labs, and at that point we want the test 8 procedure to be fairly standalone -- to be

9 standalone. 10 MS. CLEARY: This is Jen with AHAM. 11 We want the same thing. 12 Unfortunately, I think we are suggesting the 13 video because there are some times where we 14 may think everyone is doing it the same way, 15 and that isn't the case. That is where the 16 actual witnessing can be very helpful, to know 17 that information. 18 But to address your other issues 19 about instances we do know about, we have some 20 of those today to share.

21 MS. ARMSTRONG: Who wants to share 22 those instances?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 127 1 MS. CLEARY: This is Jen from AHAM. 2 I would be glad to share those instances. 3 (Laughter.) 4 So, the first would be there have 5 been some questions about the use of a brush 6 versus a spatula for soiling the dishes. 7 DW-1-1992 actually makes some reference to the 8 utensils, but it doesn't provide specific 9 details beyond like the order of the 10 application of the soil. So, this is one 11 where certainly things should be discussed. 12 We will work to develop some 13 uniformity there and suggest them to AHAM. I 14 am not sure if companies want to give any more 15 detail on this point today. 16 MR. KLUG: I think that, first of 17 all, I like the idea of a video. I like the 18 idea of lab-to-lab visits. As we look at 19 procedures such as this, repeatability and 20 reproducibility become very significant. And 21 many of those sources of variation are subtle, 22 and many of them have no significance, but

### 202-234-4433 Neal R. Gross & Co., Inc. Page 128 1 some may or some do have some significance. 2 Just to select one, oatmeal, for 3 example, how well it is spread out on the 4 plate, the clumps of oatmeal, how long the 5 oatmeal may sit before it is used, all of 6 those may or may not have some significance. 7 And you can really go through all of the 8 soils, all of the instruments set up, and find 9 a number of things that can bring variation to 10 the procedure. 11 Really, the challenge is, which of 12 those are the most significant? We are aware 13 of some that are of no significance. There 14 are some we are currently exploring that we 15 think have some significance. 16 So, the challenge is how to 17 communicate those, and often doing that in 18 words is very difficult to do. And so, the 19 picture is worth a thousand words. The video 20 is worth, well, maybe a few more than that. 21 And so, that sort of approach will help us 22 move, I think, in the direction of less

### 202-234-4433 Neal R. Gross & Co., Inc. Page 129 1 variation. 2 And some of the things we have also 3 talked about here today, and some of the 4 callouts of the margarine, for example, may 5 introduce some differences if an alternate 6 soil is selected that may not match the 7 original callout. And so, there is really a 8 lot of places where that variation can creep 9 in. 10 So, I don't think a simple 11 explanation or even in a list necessarily gets 12 us to that solution. It certainly helps. It 13 certainly is helpful, but I like the idea of 14 something that photo-video-documents the 15 procedure, the application method of soils, 16 how that takes place. 17 MR. EDWARDS: This is Mike Edwards,

18 BSH. 19 I also agree with the comments from 20 Whirlpool. I just wanted to give a couple of 21 examples.

22 I have been to labs that had the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 130 1 refrigeration equipment to keep the food soils 2 in located three floors away. So, every time 3 when they are working to prepare the food 4 soils, they would have to stop, go get 5 something, come back. The same labs, the 6 kitchen facilities were not where the 7 dishwashers were tested. So, things were 8 being transported. 9 This all adds time to the process. 10 It takes longer for the techs to do the 11 process, and then it increases the drying time 12 of the food soils, actually. So, things like 13 that are hard to capture in a written test 14 procedure. And I agree again, that the video 15 would be a helpful tool.

16 It can be subtle as well. Just 17 soiler-to-soiler variation, you can have two 18 people -- and we see this frequently within 19 our labs -- two people that are following the 20 exact same procedure, have different 21 applications of the soils. I know we call it 22 a measurement system evaluation within our lab

### 202-234-4433 Neal R. Gross & Co., Inc. Page 131 1 where we have multiple people do the same task 2 at the same time over and over, so we work to 3 commonize a method that is consistent. And 4 certainly, that becomes more challenging as 5 you look at interlaboratory, across-laboratory 6 type procedures and protocols. 7 MS. ARMSTRONG: So, two questions. 8 One, I think we would be interested in what 9 exactly you are identifying that is different 10 in your lab? I mean, what are the details? 11 What is being put on differently? 12 I assume you are using the same 13 materials in the same kitchen with the same 14 drying times, but what is being done 15 differently really than what is in our test 16 procedures? That is (a), maybe an ask for you 17 guys. 18 And then, to your point, I am not 19 clear how drying time, temperature of the food 20 applications, whether it comes from the third 21 floor or around the corner, or whatever, how 22 really that would be solved by a video,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 132 1 because the video would just show you grabbing 2 the food. In other words, I am not 3 understanding how it would solve that issue. 4 Temperature of the food being put 5 on, a specific drying time, something like 6 that, maybe, but I am not sure how a video 7 would show me grabbing something out of the 8 refrigerator right next door, should I be 9 lucky enough to be in the so-called video. 10 No, I am just saying -- 11 (Laughter.) 12 But, you know, I guess I am trying 13 to understand exactly. Maybe it is pictures. 14 Maybe it is additional specificity with the 15 actual conditions. What it actually is that 16 is needed? 17 So, I don't know if anybody else 18 needs to say anything. I know we have someone 19 on the phone. Debra, again, wants to say 20 something. 21 So, Debra, we are going to try this 22 one more time because I heard there is a lot

### 202-234-4433 Neal R. Gross & Co., Inc. Page 133 1 of feedback on the line. So, I do ask that 2 everyone has their microphones off in the 3 room, and that you not use speaker, and speak 4 as loudly as you can into the phone so that 5 you don't cut out this time. 6 MS. BENGSTON: Okay, I will try. 7 Ashley, one of the main things that 8 when I have visited outside labs, the 9 differences I have seen in soiling, soiling 10 mixture, one was (phone cuts out) or the lack 11 of knowledge of what reconstituted milk 12 actually was. I have seen and witnessed 13 outside labs not put the water back into the 14 milk directly (phone cuts out) or measure dry 15 milk into the oatmeal mixture. That is one 16 (phone cuts out). 17 No. 2, when a lab has measurement, 18 the actual leveling of the food soil spoons 19 (phone cuts out) because it affects the amount 20 of soil that is placed on the dish. I have 21 also witnessed like (phone cuts out), the time

22 factor.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 134 1 And I also was in labs that I have 2 worked in myself. I have seen individuals 3 interpret the soil methodologies differently. 4 I am (phone cuts out) the video to 5 try to eliminate (phone cuts out) the 6 discrepancies within the soiling procedure. 7 MS. ARMSTRONG: Okay. Thank you.

8 MS. BENGSTON: You're welcome. 9 MS. ARMSTRONG: Anyone else on 10 soiling or loading procedures? 11 (No response.) 12 No? All right. Moving along, Jen, 13 I assume you wanted to go ahead and discuss 14 other issues. It seems like we are moving 15 fairly quickly. 16 MS. CLEARY: Yes. So, I mean, it 17 seems like maybe we didn't need -- you know, 18 we gave very detailed explanation I think of 19 the specific soiling issues up above in the 20 chart. So, maybe we don't need to read 21 through them today --

22 MS. ARMSTRONG: Sure.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 135 1 MS. CLEARY: -- is the sense I am 2 getting. It sounds like no one else thinks we 3 need to verbally go through them. 4 Okay. So, the other issues, I 5 think these just we couldn't group them 6 together. But the first one would be rinse 7 aid. I think some labs have been observed to 8 fill their rinse aid container with water 9 before starting the test cycle to prevent the 10 indicator light from turning on. But the test 11 procedure does not address this practice. 12 AHAM would suggest that the rinse agent 13 container should not be filled with water at

14 the start of the test run. 15 MS. ARMSTRONG: Okay. So, this is 16 Ashley. 17 Can you explain why, why or why

18 not? 19 MS. CLEARY: So, I will leave that, 20 I think, a little more detail to the 21 companies. 22 MR. EDWARDS: I think the reason

### 202-234-4433 Neal R. Gross & Co., Inc. Page 136 1 that this was done is to get the LED light to 2 go off, so it would not be included in the 3 power consumption evaluation, is how it was 4 explained to me. 5 I guess I would just say that, to 6 me, if it says don't use rinse aid, you 7 shouldn't use rinse aid. You shouldn't put 8 anything else in there. 9 MS. CLEARY: So, I think that is 10 why AHAM's suggestion is what it is, you know, 11 for an anti-circumvention type of measure. 12 MS. ARMSTRONG: Okay. The next

13 one? 14 MS. CLEARY: Okay. The next one, 15 No. 14 on our list deals with water pressure 16 and where it is measured. This is partly 17 addressed in the May SNOPR where AHAM had 18 suggested that the pressure should be measured 19 as the water is flowing, and that is the 20 proposal in the SNOPR as well. We support 21 that and will indicate such in our written

22 comments.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 137 1 But there is also an issue -- and I 2 definitely would leave this to better be 3 described by technical experts here -- but 4 that the pressure is expected to drop when the 5 valve opens, and the length of time where the 6 pressure would be different than what is 7 required in the test procedures should be 8 limited. And the test procedure right now 9 does not have a required amount of time for10 that limit. So, AHAM would suggest a two11 second limit for that transient pressure drop. 12 MS. ARMSTRONG: Do you know what I 13 am going to ask? 14 MS. CLEARY: You want to know why 15 two seconds instead of any other time? 16 (Laughter.) 17 We will address that in our written

18 comments. 19 MS. ARMSTRONG: Thank you. 20 MR. KLUG: Wayne, Whirlpool. 21 Maybe one other thing we may want 22 to think about, just to plant the thought, is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 138 1 the height at which the pressure measurement 2 is made. I have seen some measurements made 3 at a height further above the dishwasher. And 4 so, really, your pressure per foot of height, 5 it is approximately .4 or .5 psi. And so, we 6 may want to look at just prescribing where 7 that measurement takes place. I don't think 8 it introduces a lot of significance, but it 9 may allow us to tie down where that pressure 10 is actually measured. 11 MS. CLEARY: This is Jen with AHAM. 12 Oh, I'm sorry, did someone else 13 raise their hand? Yes, they should go first. 14 MR. OSANN: Yes, I had a question. 15 This is Ed Osann with NRDC. 16 I had a question on the AHAM 17 handout with regard to pressure. It indicates 18 that the length of this drop should be limited 19 to assure that water flowing into the unit is 20 at the proper pressure. I am not sure why --

21 I don't know how that relates to the two 22 seconds, and if it were five seconds or twenty

### 202-234-4433 Neal R. Gross & Co., Inc. Page 139 1 seconds, how would that affect the water 2 flowing into the unit at the proper pressure? 3 And either it is flowing pressure 4 or it is static pressure. If you are 5 measuring flowing pressure, does that matter 6 whether it is seconds after the valve is 7 opened or twenty seconds after the valve is 8 opened? 9 MR. KVAIDHYANATHAN: The question 10 here is flowing pressure needs to be measured. 11 But what really happens is, if you look at, 12 monitor the pressure, the flowing pressure, 13 you know, it changes when the valve opens. It 14 drops down and then gets back to the normal 15 level. If it drops down for a longer time, 16 what it really means is the valve float is 17 going to change, too. So, you don't want to 18 have a longer drop. 19 So, what we are saying is, I would 20 say the stable condition should happen sooner 21 than later. I think that is what is behind 22 this comment. If it does happen after a long

### 202-234-4433 Neal R. Gross & Co., Inc. Page 140 1 time, that may impact how much it fills as

2 well. 3 Yes, generally, now the fill time 4 can be like one minute. 5 MR. OSANN: Right. 6 MR. KVAIDHYANATHAN: So, if it is 7 one minute, and if they are losing twenty 8 seconds of one minute, that can be quite 9 significant. You are not maintaining the 10 pressure at the right level during that time. 11 MS. ARMSTRONG: Okay. Thanks, 12 everyone. 13 Anything else on water pressure 14 before we move on to rack position? 15 (No response.) 16 Okay. Moving along -- 17 MS. CLEARY: This is Jen with AHAM. 18 Actually, before we get to rack 19 position, if it is okay, I think I had 20 something on the drain height, which is not 21 currently specified in the DOE test procedure. 22 AHAM would propose that this should

### 202-234-4433 Neal R. Gross & Co., Inc. Page 141 1 be specified and that it could be indicated 2 that the installation shall be per the 3 manufacturer's installation instructions. If 4 there are no such instructions, then AHAM 5 would suggest that the height shall be a 6 standard level of 20 inches, which is what we

7 have observed to be the standard. 8 MS. ARMSTRONG: Okay. Keep going. 9 MS. CLEARY: Okay. No. 16, the 10 rack position, this is the upper rack. The 11 position of that can -- and I will leave this 12 to experts in the room to further describe, 13 but to just give a brief description -- it can 14 impact the water pressure and the consumption 15 during the test. But the test procedure does 16 not indicate what position that rack should be 17 in. And some dishwashers do have multiple 18 positions that it could be in. 19 So, we think this is a complex area 20 that needs to be resolved. AHAM would be glad 21 to work with the Department to do so. In the 22 interim, what we would suggest is that this

### 202-234-4433 Neal R. Gross & Co., Inc. Page 142 1 could be indicated as part of the 2 certification statement, like which position 3 the rack was in during the test. And then, we 4 could work as a longer-term solution to 5 identify what the best position would be in 6 the test procedure. 7 MS. ARMSTRONG: Two questions. One 8 would be, is there a reason that it should be 9 different than the as-shipped position? And 10 No. 2 would be, if it is a big issue that 11 shows high variation, and you allow 12 manufacturers the discretion to choose what 13 that position is, what is to say that they are 14 doing it uniformly or at least equitably? 15 MS. CLEARY: I would definitely -- 16 this is Jen with AHAM -- open this up. I 17 think individual companies may be able to give 18 you more information. But my understanding is 19 that the as-shipped position may not always be 20 the same and/or how the consumer is getting it 21 may not always be in the same position. There 22 may not be a way to make that uniform. Now

### 202-234-4433 Neal R. Gross & Co., Inc. Page 143 1 that may not be the case for all companies, 2 but for some that may be the case. So, that, 3 I think, is part of the difficulty. 4 MS. ARMSTRONG: And then, one other 5 just before your time ends, you can address 6 this, too. If it is not the as-shipped 7 position, are there actually instructions in 8 the installation manual telling the consumer 9 that this is the default position that the 10 rack should be in? 11 MR. EDWARDS: Mike Edwards, BSH. 12 It is true that the varying 13 positions of the rack may impact the pressure 14 slightly. That could influence the rate the 15 food soil falls off the dishes and the sensor 16 decisions. 17 I don't consider it a critical 18 issue, but it could cause testing problems 19 when a verification lab runs a test. So, it 20 could show up. 21 Yes, it is in our manual, but it 22 has been recently added.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 144 1 MS. ARMSTRONG: And is it different 2 than the way you ship?

3 MR. EDWARDS: That one I cannot

4 answer. 5 MS. ARMSTRONG: Okay. 6 MR. EDWARDS: And it varies from 7 product to product. We have several 8 platforms. So, they are not all the same. 9 So, my suspicion would be they are all shipped 10 the same, but the manual is telling you to do 11 different things with it when you run the 12 energy test. 13 MS. ARMSTRONG: The manual actually 14 has a position for the energy test and -- 15 MR. EDWARDS: It is now in our 16 manuals, yes.

17 MS. ARMSTRONG: Wow. 18 MR. KLUG: Wayne at Whirlpool. 19 I am not sure what is in our 20 manuals. So, I have got to go look. And I 21 have to check on what our shipped position is. 22 I would share Mike's comments that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 145 1 there might be a slight difference in water 2 pressure, again, due to height, and how that 3 feeds the upper spray arm. 4 The consumption piece, I am kind of 5 scratching my head because I am not sure there 6 is an impact there. And so, I think we 7 probably want to look at that, that word, and 8 see if that needs to be pulled out of here. I 9 think it is more of a water pressure, soils 10 coming off the dishes topic. 11 MS. ARMSTRONG: Anybody else have 12 anything else with this? 13 (No response.) 14 Do any of the labs want to say what 15 you currently do when you set up a dishwasher? 16 Do you follow the installation instructions? 17 Do you do as-shipped? 18 MR. BILLINGS: Lincoln Billings at

19 Intertek. 20 We currently typically test under 21 as-shipped conditions. 22 MS. ARMSTRONG: Thank you.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 146 1 MR. KLUG: I have to check what we

2 do. 3 MS. ARMSTRONG: Okay. Jen, do you

4 want to move on to water hardness? 5 MS. CLEARY: Jen with AHAM. 6 As I know everyone is aware, 7 Appendix E does not have a water hardness 8 requirement. As part of the Energy Star test 9 procedure, DOE did propose to adopt a water 10 hardness requirement. And I believe the 11 proposal was to adopt the requirement in

12 DW-1-1992. 13 And then, there was a question 14 about whether the 2009 should be cited 15 instead. And I believe in AHAM's comments on 16 that we indicated that that proceeding was not 17 the time to change the DOE test procedure. 18 But, now that there is an open rulemaking, 19 perhaps this would be an opportunity to 20 address this. 21 AHAM would propose that DOE adopt 22 the DW-1-2009 water hardness specification,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 147 1 which is similar to 1992 but more detailed. 2 And there was a study to support those 3 specifications, and we would be glad to share 4 the details in some written comments and

5 feedback. 6 MR. OSANN: This is Ed Osann from

7 NRDC. 8 What is the objective of the AHAM 9 standard, either the 1992 version or the 2009 10 version? Is it to provide not just 11 standardization, but standardization around 12 what? Is this chemistry supposed to be 13 representative broadly or is it supposed to be 14 challenging? Or what is the point of the 15 specification? 16 MR. KLUG: Lab consistency. 17 MR. OSANN: Consistency? 18 MR. KLUG: From lab-to-lab, yes. 19 MR. ANDERSON: Are you talking 20 about for water hardness in particular?

21 MR. OSANN: Yes.

22 MR. KLUG: Yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 148 1 MR. OSANN: And is the 2 specification that is in the AHAM standard, is 3 it consistently hard or consistently soft, or 4 where does it land on that spectrum? 5 MR. KLUG: The current callout in 6 both 1992 and 2009 versions of DW-1 call out 7 zero to 85 ppm of water hardness, which is 8 about zero to five grains. 9 The clarification or the detail 10 that Jennifer was referring to for the 2009 11 version is that it also calls out that that 12 PPM level is based on the calcium carbonate

13 content. 14 MR. OSANN: Just a follow-up 15 question. I was wondering whether AHAM has 16 any data as to how representative that level 17 of hardness is. 18 MS. CLEARY: Yes, as I mentioned, 19 we did have a study to support selecting that. 20 Maybe Wayne can indicate exactly who did the 21 study. I can't remember off the top of my

22 head.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 149 1 MR. MORRIS: This is Wayne Morris 2 with AHAM.

3 The work that the DW-1 Task Force 4 did prior to 2009 was in contact with the 5 American Water Works Association to try to get 6 the most general range of water hardness that 7 they felt was in municipal supplies. 8 Obviously, if you are dealing with well water 9 or something like that, the consumer may vary 10 considerably. But this was their way of 11 detailing it, and their suggestion was not 12 only to detail the grains, in this case the 13 PPM, but also to do it based on calcium 14 carbonate, since there are some other methods 15 of specifying it, in addition to that. They 16 felt this would tie down more specifically and 17 leave less lab-to-lab variation. 18 MR. OSANN: This is Ed Osann again. 19 This was felt to be representative 20 of publicly-supplied water? 21 MR. MORRIS: Yes. The range that 22 they had asked for us to do, which is, as

### 202-234-4433 Neal R. Gross & Co., Inc. Page 150 1 Vince indicated, zero to 85 PPM is considered 2 to be, shall we call it, the normal range that 3 occurs in municipal-supplied water. 4 MS. ARMSTRONG: Okay. Any last 5 comments or questions regarding water

6 hardness? 7 (No response.) 8 If not, we are going to move on to 9 ambient temperatures. 10 MS. FARBER: This is Julia Farber

11 from UL. 12 I just have a note here that in our 13 experience as well, the difference between 14 varying soft and hard water could potentially 15 impact your results. And that is dictated

16 based on the hardness of the water. 17 And also, similar to Intertek, we 18 are performing all of our testing standards 19 based on the manufacturer instructions. 20 MS. ARMSTRONG: Moving on to 21 ambient temperature. 22 MS. CLEARY: This is Jen with AHAM.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 151 1 Ambient temperature in Appendix C 2 is expressed as a range, 75 plus or minus five 3 degrees Fahrenheit. And we think that that is 4 fine, but it would be better if the test 5 procedure or guidance could expressly state 6 that the intent of the procedure is actually 7 to maintain the 75 degrees, not to go anywhere 8 in that range. So, you shouldn't be aiming to 9 run the test at 70 or 80, and that, in fact, 10 the test is intended to be run at 75 degrees 11 Fahrenheit. 12 MS. ARMSTRONG: Okay. I mean, 13 technically, then, would you be in favor of 14 tightening the range, tightening the 15 tolerance? Even if you shoot for the 16 midpoint, I mean, it is a valid test in that 17 range. 18 MS. CLEARY: Right. So, this is 19 Jen with AHAM. 20 I think that tightening the range 21 maybe could be a possibility. The difficulty 22 would be every lab is going to have a

### 202-234-4433 Neal R. Gross & Co., Inc. Page 152 1 different test chamber, and there may be 2 varying abilities to have a tighter range than 3 five. So, I think that might be something 4 that you might need to find out. 5 I know we did submit comments with 6 regard to DOE's proposal to widen the range, 7 and we would oppose that. We think at least 8 it needs to be this tight. 9 So, we could look at if a tighter 10 range would be possible, but right now I think 11 our sense is that, because labs are different, 12 maybe the plus or minus five, that this is 13 kind of the best that we can think of to do 14 with those variabilities. 15 MS. ARMSTRONG: Yes. So, I may 16 request that if you could think of some 17 specific language that would achieve your goal 18 of shooting for 75 but allowing dips above and 19 below that, we would welcome that. Because 75 20 plus or minus five, I mean I read that and I 21 think it is fairly clear you shoot for 75, but 22 if you go above or beyond, there is a

### 202-234-4433 Neal R. Gross & Co., Inc. Page 153 1 tolerance there for that reason.

2 MS. CLEARY: Jen from AHAM. 3 Yes, we will work on some language.

4 MS. ARMSTRONG: Thanks. 5 MR. KLUG: Wayne at Whirlpool. 6 I think that the lab impact that 7 Jen spoke of is probably the key challenge to 8 overcome on the value of the temperature. 9 Certainly, centering is very important, and we 10 would support language around centering those

11 values. 12 I think, from our perspective, even 13 tightening those values does have a lot of 14 benefit. But, again, that comes up against 15 what the lab equipment might be capable of. 16 But certainly, tighter is better. Centering 17 is better. And language to make sure that you 18 are actually targeting 75 and not some other 19 within the range would be beneficial. 20 MS. REICH: Judith Reich from 21 Navigant. 22 It would be helpful if you could

### 202-234-4433 Neal R. Gross & Co., Inc. Page 154 1 provide information on this issue, whether the 2 key issue is the capability of the lab or 3 really how much the temperature affects the 4 performance, whether if you are operating it 5 at 70 or 80 degrees really has a difference on 6 the performance of the unit. 7 MR. BILLINGS: Lincoln Billings

8 from Intertek. 9 We do understand fully that the 10 intent is to target 75 and do aim to maintain 11 that condition. Also, I think it is important 12 that that condition is met prior to the test 13 for the soil drying as well. 14 MS. ARMSTRONG: Okay. Any other 15 dishwasher issue, whether it be those on the 16 sheet, other issues? Any other comments as 17 they relate to dishwashers before we break for

18 lunch? We are about an hour ahead here. 19 MS. CLEARY: This is Jen Cleary 20 with AHAM. 21 I hate to get in the way of lunch, 22 but just the last issue on our sheet.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 155 1 MS. ARMSTRONG: Okay. 2 MS. CLEARY: I think we have 3 addressed this in a general way already, but 4 this would be one specific instance where 5 there is a more recent version of DW-1, which 6 is incorporated by reference in Appendix C. 7 We would recommend DOE incorporate by 8 reference the 2009 version of DW-1. There are 9 some differences in the food soils there. So, 10 clearly, in order to do that, DOE would need 11 to determine whether there would be an impact 12 in measured energy from those changes. And 13 AHAM, we don't know for sure right now, but we 14 would be glad to work with DOE on figuring

15 that out. 16 MS. ARMSTRONG: Thank you. 17 MR. KLUG: Yes, Whirlpool would 18 support that as well. The differences are 19 fairly subtle, soiling order, how the egg is 20 prepared, a couple of other minor items. But 21 it would be beneficial to cite the most recent 22 reference, primarily because some labs perform

### 202-234-4433 Neal R. Gross & Co., Inc. Page 156 1 both the 1992 and 2009 procedures, and it 2 would be certainly convenient to be able to 3 have one size fit all. 4 MR. EDWARDS: Mike Edwards, BSH. 5 We also support it, but we would 6 want to go in and check to make sure it didn't 7 influence sensor decisions. 8 MS. ARMSTRONG: Okay. I think we 9 would welcome any data that you would be 10 willing to share with us, once you did that 11 comparison. 12 MR. EDWARDS: If you guys are 13 serious about accepting the proposal, then we 14 will go in and test. 15 MS. ARMSTRONG: We are always 16 serious here at the Department. 17 Okay. So, I take it there are no 18 other dishwasher issues. I have had a request 19 to at least -- oh, one more? Oh, go ahead.

20 Go. 21 MR. BILLINGS: Lincoln Billings 22 from Intertek again.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 157 1 I hate to jump around, but going 2 back to item 14, referring to the pressure 3 drop issue, it seems that, judging by the 4 suggested two-second limits indicates that 5 there may or may not be, I will say, an 6 industry-accepted allowance for transient 7 conditions. If that is the case, I would just 8 like to ask where that is aligned or 9 specified, because we run into the same issue 10 and generally throw any transient condition

11 test. 12 MS. ARMSTRONG: They ask for 13 industry-accepted positions. 14 MR. EDWARDS: I can tell you where 15 the two seconds came from. It is what we all 16 felt our labs were capable of. 17 MS. ARMSTRONG: Okay. So, any 18 other dishwasher? Free feel. 19 (No response.) 20 I have been asked to ask everyone 21 in the room, if you want to move straight to 22 clothes washers to get out of here early or if

### 202-234-4433 Neal R. Gross & Co., Inc. Page 158 1 you want to break for lunch. I don't know how

2 long the clothes washer one -- I will take a

3 vote. I mean, majority rules here. I will

4 sit here with you if we want to keep going.

5 Anybody?

6 So, how about this, 10-minute

7 break? Or a 15-minute break is fine,

8 whatever. Reconvene at 25 after or so, 20

9 after. Is that okay? So, 20 after, and we

10 will go right to clothes washers.

11 (Whereupon, the foregoing matter

12 went off the record at 12:08 p.m. and went

13 back on the record at 12:33 p.m.)

14

### 202-234-4433 Neal R. Gross & Co., Inc. Page 159 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 1:33 p.m. 3 MS. ARMSTRONG: Okay. I would like 4 to welcome everyone back from that quick lunch 5 break we just had. 6 (Laughter.) 7 We are going to move through to 8 clothes washers. We are running quite a bit 9 ahead of schedule, and it may be perhaps that 10 we can end quite early and get everyone home 11 to enjoy their weekend, even if they have to 12 travel by air. 13 So, with that, we are going to 14 segue into clothes washers. I am going to go 15 ahead and turn the first issue over to Jen to 16 introduce. 17 Like I said, I am going to keep 18 saying the same thing. I encourage you to 19 provide detailed data, ask each other 20 questions, so that we can really identify 21 where there might be differences of 22 interpretations that the Department really

### 202-234-4433 Neal R. Gross & Co., Inc. Page 160 1 needs to consider what action it can take. 2 MS. CLEARY: Okay. Jen, AHAM, 3 again. 4 I know that the manufacturers in 5 the room will have more details to share, 6 particularly on this first issue. So, I will 7 just tee it up a little bit. 8 Essentially, what we are dealing 9 with here is how to handle testing anomalies. 10 One example would be an unbalanced load. You 11 know, DOE's test procedure doesn't address 12 exactly how to handle those situations, if 13 there is like a certain threshold of 14 acceptability, for example, or when a test 15 might need to be disregarded and a new test

16 run. 17 We believe that labs probably are 18 making different determinations as to when to 19 invalidate a test run and restart it. Both 20 third-party labs and manufacturer labs may 21 have different processes that they follow

22 there.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 161 1 So, this is a pretty complicated 2 issue because the anomalies could be 3 different. But what AHAM is suggesting is 4 that, in the case of an obvious unbalanced 5 load, the test should be invalidated and

6 restarted because the test results should not

7 be based on a run that the consumer would 8 notice as abnormal. 9 We also think that a more general 10 way to handle this in a uniform way would be 11 something similar to -- I have the wrong IEC 12 number there, but it should be 60456, similar 13 to that approach which we have included in 14 this handout. 15 Now the exact wording in the IEC 16 version, it can't just be cut and pasted into 17 DOE's procedures. So, AHAM certainly would 18 like to continue to work on this and make some 19 suggestions in more detail to DOE. But we 20 wanted to put out there today that this could 21 be one way of handling it. So, I would 22 certainly ask the experts in the room to give

### 202-234-4433 Neal R. Gross & Co., Inc. Page 162 1 some more detail around exactly what the issue 2 is and what different labs have been seen to 3 do, and what our suggestion is here as well. 4 MS. ARMSTRONG: Everyone is looking

5 at me. 6 So, I just have a question before 7 we jump into this. Perhaps some of the 8 manufacturers and/or the labs can say what 9 they do. 10 If it is an unbalanced load, will 11 the cycle automatically prematurely terminate 12 in all cases or is it possible that it will 13 actually finish? 14 MR. HOMBROEK: This is Phil

15 Hombroek from GE. 16 It really depends on the machine 17 and the complexity in the machine. Some will 18 completely terminate and others will have 19 other unbalanced algorithms to try to regain 20 balance and try to restore the machine to 21 normal operation. 22 MS. ARMSTRONG: So, to Jen's point

### 202-234-4433 Neal R. Gross & Co., Inc. Page 163 1 earlier, how would a consumer and the 2 Department know that it is unbalanced if it 3 doesn't prematurely terminate? 4 MR. BILLINGS: Lincoln Billings

5 from Intertek. 6 We have seen units that actually 7 have an indicator light where we will give the 8 user instructions as per the use-and-care

9 manual. 10 MS. ARMSTRONG: And if it doesn't? 11 MR. HOMBROEK: Then, you're right, 12 in most cases it would terminate. But it 13 depends on the complexity of the machine. We 14 have some that certainly have out-of-balance 15 algorithms that will take additional action, 16 and they will inform the consumer that it is 17 rebalancing or stop the machine and 18 redistribute your cloths. 19 So, this is something that kind of 20 needs to be considered, contrary to probably 21 your thoughts. But the DOE cloth load is a 22 complicated load to wash. It is in some cases

### 202-234-4433 Neal R. Gross & Co., Inc. Page 164 1 more difficult than a mixed load. When you 2 lay those DOE cloths completely flat, one on 3 top of another, and you pour water right over 4 the top of it, especially in some of the newer 5 machines, what you do is create a solid, 6 concrete pancake, if you will, of DOE cloth, 7 and your machine needs to be able to agitate 8 it enough and to have the right kind of 9 routine to mix it up and not create any kind

10 of out of balance. 11 And this is coupled with the fact 12 that, obviously, we are trying to reduce the 13 amount of water over and over again as much as 14 possible. So, we use these routines on a lot 15 of higher-end machines to try to regain the

16 balance. 17 But in the case of some machines, 18 we may stop the machine and go through an 19 entire new fill. Okay? And filling the 20 machine again in that kind of condition, the 21 consumer is not like the DOE and causes 22 probably more use of water than we would like.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 165 1 In the case where everything is 2 working properly and we load the cloth just 3 the way that we would like to, obviously, more 4 often than not, we don't have these types of 5 conditions, but there are occasions that we 6 do. And we just ask that the DOE consider it. 7 MR. MANTHEI: Phil Manthei from 8 Alliance Laundry Systems. 9 With the front-loading washers 10 predominantly, of course, gravity prevails. 11 And so, the load will tend to always be on one 12 side. So, the machine has routines, you know, 13 software, to try to balance that load out. Of 14 course, the test procedure, one of the things 15 that we did years and years ago was to make 16 sure that the test procedure tested the 17 maximum load size to allow for less unbalance 18 to occur during the test. 19 What can happen is in some units 20 the software will say, okay, I cannot take 21 this load; it is unbalanced; I cannot take it 22 up to high-speed spin. And therefore, it will

### 202-234-4433 Neal R. Gross & Co., Inc. Page 166 1 drop down to a lower-speed spin. 2 What could be done, I suppose, is I 3 don't know that everybody puts in their user 4 instructions what the actual spin speeds are 5 of high, medium, and low speeds, et cetera. 6 Oftentimes, that is only in the promotional 7 material, the sales spec material. But 8 knowing what the intended maximum spin speed 9 is for the energy test cycle certainly could 10 be one thing that would help the test labs to 11 know whether it was an appropriate cycle run. 12 MS. ARMSTRONG: Anybody else? Any 13 other characteristics that would help 14 determine unbalanced load outside of just an 15 indicator light or a premature termination? 16 MR. KVAIDHYANATHAN: This is Ravee 17 from Samsung.18 Unbalanced is one of the special19 cause type of issues. You know, it can 20 happen. And there are other types of 21 situations, too, where a single test run may 22 not represent the system behavior. So,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 167 1 unbalanced is definitely one of the issues in 2 the examples that we wanted to cite. It is 3 both on horizontal and top-load and front-load 4 washers. It can change the cycle. 5 And how the machine reacts depends 6 on the system. Some machines, you know, they 7 can continue the cycle at lower spin speed. 8 Some add water. I think the MEF and Water 9 Factor numbers, for example, are going to be 10 different for the specific run where it went 11 through an off-balance or other type of 12 special-cause issues. 13 So, given that fact, how do we 14 identify that? And how do we separate it from 15 one of the runs which are special-cause runs 16 and take it out of the calculation? 17 MS. ARMSTRONG: Right. That is 18 kind of the question I just asked you, too. 19 (Laughter.) 20 You know, we are trying to 21 understand how will we differentiate between 22 what one would call an anomaly for which you

### 202-234-4433 Neal R. Gross & Co., Inc. Page 168 1 wouldn't have a light, you wouldn't have a 2 premature termination. The consumer may not 3 know it would finish its cycle, but it would 4 use more energy or water, or whatever it is. 5 It would use the different cycle than it 6 normally did or it would use a different spin 7 speed, or whatever it may be. How do we 8 determine that without going through this 9 whole process, getting the test results, 10 saying, hey, DOE has these test results that 11 show that your unit uses 50 percent more 12 energy? And you say, "Oh, no, it had an 13 unbalanced load." I mean, how do we get to 14 the point where we can recognize that at the 15 forefront rather than after we have finished 16 verification testing or enforcement testing? 17 Where do you draw the line between 18 something that is using more energy and water 19 consistently versus something that was tested 20 with what you guys are calling an anomaly? 21 Are there any characteristics specifically 22 that we could look at in the test or the test

### 202-234-4433 Neal R. Gross & Co., Inc. Page 169 1 data that would give an indication of that, 2 other than just the lights are the easy ones, 3 but it won't finish the cycle is an easier 4 one. We don't just necessarily throw test 5 data out per se. 6 So, I am asking you guys. How do 7 you determine what to do when you come up with 8 your ratings? 9 MR. MANTHEI: This is Phil from 10 Alliance Laundry Systems. 11 With the spin speed, that one is 12 fairly obvious. You can measure the spin 13 speeds and compare them to what the product 14 literature or specification is for that model, 15 and know if you are at the right one. 16 MR. OSANN: This is Ed Osann with

17 NRDC. 18 I think there is a concern here 19 about, or we would raise a concern about to 20 what extent these conditions really are 21 anomalous. As the control logic of these 22 machines becomes more sophisticated over time,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 170 1 you could envision sort of a gradation of what 2 you might consider intervention in rectifying 3 non-standard conditions. And it might be 4 that, for marketing purposes, a machine, a 5 design would intentionally intervene more

6 often. 7 I think, as presented, it is hard 8 to argue against the ability to throw out 9 truly anomalous results. But it seems like 10 there ought to be more on the record here 11 about how often this occurs and how to 12 distinguish this occurrence from what 13 consumers are likely to encounter more 14 frequently. 15 MR. KVAIDHYANATHAN: This is Ravee 16 from Samsung. 17 There are potential ways of 18 addressing and understanding the special-cause 19 situations. In the test tunnel, for example, 20 for the water factor, multiple units are 21 tested and multiple runs are done at different 22 load sizes, too.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 171 1 So, when we look at the data, it is 2 probably we can do some types of statistical 3 validation or analysis to see which runs are 4 out of the norm. When we have multiple data 5 points, it is easy to find the special-cause 6 runs from the normal test runs. So, that is 7 one way of addressing that in terms of taking 8 it out. 9 Again, if all the runs seem to be 10 like special-cause runs, that is the typical 11 behavior of the system. So, we can't take 12 anything out. But if a few runs are out of 13 spec in terms of what the other runs are, it 14 may be easy to use statistical means to 15 separate the data out. 16 MR. TEICH: This is Dan from 17 Whirlpool. 18 So, Ravee, are you suggesting that 19 a limit, some kind of a statistical level be 20 set, that if special-cause runs occur, if we 21 hit this level, then we would be allowed to 22 take those out of the equations, out of the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 172 1 calculations? Or are you talking about 2 addressing the question of gathering data to 3 determine statistically how many times that 4 happens? I am not sure. 5 MR. KVAIDHYANATHAN: I was just 6 imagining the washing machine testing. You 7 know, we test multiple units and multiple load 8 sizes, multiple temperatures. So, we do have 9 a good dataset in terms of what each of those 10 test runs resulted in, you know, water 11 volumes, energy consumption, recycle time. 12 All this information is out there, and if we 13 want to identify those specific runs which are 14 anomalies, there is the possibility to treat 15 this, you know, look at the data to understand 16 which one is out of the norm. We can maybe 17 define some limits, some statistical limits, 18 to determine which one might be out of the

19 norm. 20 MR. HOMBROEK: I was just going to 21 state that GE would certainly be in favor of 22 setting some type of limit to the number of

### 202-234-4433 Neal R. Gross & Co., Inc. Page 173 1 anomalies that is described in the IEC example 2 that has been provided. 3 We also would like to state that 4 different labs are interpreting this in 5 different ways. You may go to one third-party 6 lab and they may throw out information giving 7 a certain set of criteria versus another lab 8 may do it differently. And this is an area 9 where I believe that harmonization needs to be 10 in place. 11 MS. ARMSTRONG: Okay. So, I am 12 actually going to turn to AHAM and the labs. 13 So, I want to know if you would be willing to 14 share how AHAM in their verification program 15 is going to determine an anomaly like this. 16 What set of criteria do you plan to use? And 17 then, for the labs, if you could speak to that 18 as well in terms of what you do now? 19 MS. CLEARY: This is Jen with AHAM. 20 I think we could provide that 21 information to you later. 22 MS. ARMSTRONG: Thank you.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 174 1 MS. FARBER: So, this is Julia with

2 UL. 3 We have noticed that there is4 definitely a difference between the top5 loading and the front-loading washing 6 machines. We tend to see that unbalanced 7 loads in front-loading machines are often just 8 redistributing the loads. We usually will 9 keep those in the test run, and we have a 10 tendency not to see anomalies in that 11 situation. 12 But in the top-loaders, we will say 13 that there are a couple of different 14 situations where we do see either an indicator 15 light or we notice that the cycle is changing 16 or we will see an additional amount of water 17 entering the machine. That will give us an 18 indicator that there is something amiss, and 19 that leads us to possibly question whether or 20 not it is an anomaly. 21 We do want to ask, though, if there 22 is a possibility to get a little bit of

### 202-234-4433 Neal R. Gross & Co., Inc. Page 175 1 additional clarification from the DOE and/or 2 from AHAM on what situations you would prefer 3 us to keep those test data and when you would 4 like us to throw it out. We are totally open 5 to hearing your thoughts on that. Of course, 6 we are a test laboratory that is here to serve 7 our clients and you guys as well. So, 8 whatever guidance you offer to us is going to

9 be the one that we use. 10 Thank you. 11 MS. ARMSTRONG: Anybody want to 12 speak to the specific sets of criteria that 13 they know are different? 14 (No response.) 15 We can't consider a uniform 16 specification without knowing some ideas of 17 what that should look like or what is actually 18 being done differently. It is pretty hard. 19 So, if you want to think about it 20 and suggest things later, that would be fine. 21 But it is hard to understand. 22 MR. TEICH: This is Dan from

### 202-234-4433 Neal R. Gross & Co., Inc. Page 176 1 Whirlpool. 2 I am just struggling right now, and 3 I think we need to work as an industry to 4 define what is the definition of an anomaly, 5 the level at which one type of an anomaly may 6 become enough that we throw out that cycle. 7 And so, sitting here today, I don't 8 think we can list each one of those, give any 9 specifics. But I am not opposed at all to 10 doing that as an industry and coming together 11 and agreeing on some different levels. I 12 think it would be a great idea because we do 13 have quite a bit of interpretation among all 14 the manufacturers, I think, Whirlpool 15 included. When do we include that cycle; when

16 don't we? 17 And we have different ways of 18 informing our consumers, whether we tell them 19 in owners' manuals go ahead and re-adjust, do 20 something, or we indicate via lights. So, I 21 think it is way too broad to try to address 22 right now.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 177 1 MS. ARMSTRONG: Okay. I am going 2 to make -- this is Ashley from DOE -- I wanted 3 to make one request that you keep in mind when 4 you do this. 5 For assessment testing, when we 6 test one unit, we don't have the luxury of a 7 large dataset to see where an anomaly may lie. 8 Just because the ratings are off by a certain 9 percentage, doesn't necessarily indicate an 10 unbalanced load. We have had a unit 11 consistently fail by 200 percent, I mean over 12 many units tested. 13 So, just because there is a 14 threshold -- so I ask you to consider that. I 15 think, from the Department's point of view, we 16 are sensitive to the fact that there are 17 testing anomalies and we would like to be able 18 to articulate better. But, on a single test 19 deviation from the ratings is not a unique 20 indication that it is a test anomaly or a 21 defective unit. So, when you think about 22 that, that is the challenge from our

### 202-234-4433 Neal R. Gross & Co., Inc. Page 178 1 perspective. 2 Okay? 3 MR. MANTHEI: This is Phil Manthei 4 from Alliance Laundry Systems. 5 On the unbalanced load situation, 6 when you are testing one unit, right now the 7 test procedure for the RMC only requires 8 recording the RMC for the maximum test load at 9 the cold cycle. I think it has the same 10 cycle, and wash and rinse have the same 11 temperature. 12 If you did that for the other 13 cycles that you are testing, because you are 14 testing like at the maximum load size, the 15 average load size, minimum -- so, you have got 16 three, and then you have got three 17 temperatures. You could actually have like 18 nine cycles. If you recorded the spin speed 19 and RMCs from those other ones, you would have 20 the kind of statistical information, I think, 21 even on just testing one unit, to know that 22 that one that is critical that you are using

### 202-234-4433 Neal R. Gross & Co., Inc. Page 179 1 right now is the one test at maximum load and 2 cold wash is an anomaly. 3 MR. TEICH: This is Dan from 4 Whirlpool. 5 I think that is somewhat, Ravee, 6 what you were getting at. We run enough 7 cycles in one test to determine just from 8 those if there is an anomaly that stands out.

9 MR. KVAIDHYANATHAN: We need to 10 prepare a good proposal and communicate to you 11 as the industry. 12 MS. ARMSTRONG: I think that would 13 be very helpful. 14 Okay. 15 MS. CLEARY: This is Jen from AHAM. 16 I think the next several issues 17 have to do with the drum volume measurement. 18 We know that this has been a topic that we 19 have sought guidance on in the past. There is 20 existing guidance on drum volume measurement 21 for Appendix J-1, and Appendix J-2 also gives 22 some more detail. So, many of the issues have

### 202-234-4433 Neal R. Gross & Co., Inc. Page 180 1 been addressed. 2 However, there are still some 3 questions that we would seek further guidance 4 on from DOE. That is what these questions are 5 intended to do. 6 Issue No. 2 has to do with the bag 7 design, that the test procedure specifies use 8 of a poly sheet, but it doesn't go into more 9 detail than that. A flat sheet is going to 10 result in some folds in the material, which 11 can lead to an inaccurate measurement. 12 So, what AHAM would suggest is that 13 a bag be used to reduce folds in the material, 14 and we would ask that this be clarified in the 15 procedure, maybe as a recommendation of best 16 practices or whatever the Department, if you 17 agree, find the best for doing that, if there 18 is any more detail. 19 MR. MANTHEI: This is Phil Manthei 20 from Alliance Laundry Systems. 21 I think most of the manufacturers 22 have been using bags for years and years and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 181 1 years. But we are aware that at least one lab 2 attempted to do it using plastic sheets, and 3 it was a disaster. 4 MS. ARMSTRONG: Here is where the 5 fun part starts. DOE used sheets -- look at 6 the faces -- when we did testing. I ask, have 7 you done any round robin or activities within 8 each lab to show that there is a significant 9 difference between sheets and a bag? We did 10 our round robin. The results yet are not 11 public. They will be at some point. But I 12 think we didn't see a whole lot of difference 13 attributable to that issue. 14 MR. TEICH: This is Dan from 15 Whirlpool. 16 To my knowledge, I have never seen 17 a round robin done. I am anxious to see the 18 results of what you are talking about. 19 But I think for the manufacturers, 20 when we attended the verification visits, it 21 just stood to us -- since most of us, and I 22 think all of us, have used bags for years,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 182 1 like Phil said -- it just stood out as a huge 2 area of variability. 3 MS. ARMSTRONG: Potential? Or you 4 have data that shows it is?

5 MR. TEICH: We do not have data. 6 MS. ARMSTRONG: So, potential? 7 MR. TEICH: Potential, yes. 8 MS. ARMSTRONG: Okay. 9 MR. TEICH: And that is why I said 10 I am anxious to see your results on the round 11 robin, if it was done. 12 MS. ARMSTRONG: I mean, to the 13 extent -- well, just one second -- to the 14 extent we have done any verification testing 15 and used sheets, I mean, we haven't come 16 knocking on your doors. The ratings are 17 coming out pretty similar. 18 (Laughter.) 19 Not to say that that doesn't mean 20 we shouldn't look into it, but I am just 21 saying -- 22 MR. TEICH: Right. Okay.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 183 1 MS. CLEARY: This is Jen from AHAM. 2 I think, as I mentioned in my 3 opening remarks, as the standards get more 4 stringent, this could become an issue. So, I 5 think that that would be our concern as well, 6 that as the requirements are tighter and 7 tighter and there is less room maybe even for 8 conservative ratings, which may be helping 9 variability right now, this may become a more 10 important issue at that time. 11 So, the results of the current 12 round robin may not show that as much. I 13 don't know. We will need to look at the data

14 and evaluate that as well. 15 MR. HOMBROEK: This is Phil from GE 16 again. 17 When this came up, it was during 18 our AHAM round-robin testing, finding out 19 which lab we wanted to choose for verification 20 testing. As I recall, in this particular 21 incident the lab in question, when they 22 measured it, ended up putting that particular

### 202-234-4433 Neal R. Gross & Co., Inc. Page 184 1 washing machine in a new category. So, it did 2 even have an impact in that result. 3 I will have to look through some 4 material, but I can look back, I guess it was 5 about a year ago, at the data that we took at 6 each individual third party. But it certainly 7 did change the load size for this one third 8 party. 9 MR. TEICH: And this is Dan from 10 Whirlpool. 11 I guess I would ask, since the 12 industry has used bags for many years, is 13 there a particular reason why a bag wouldn't 14 be considered as something to be standard? 15 MS. ARMSTRONG: I am just trying to 16 understand. So, if we go through a uniform 17 requirement, we are going to have to have a 18 rationale for doing such things. So, I am 19 trying to understand why is it the bag. And 20 if there are large differences, obviously, 21 that indicates that there should be. But if 22 there are little to no impacts on the energy

### 202-234-4433 Neal R. Gross & Co., Inc. Page 185 1 used, as long as you are implementing it the 2 correct way, then it seems like having choices 3 is not necessarily a bad thing. 4 MR. TEICH: Right. Yes, and I 5 think the gap is we just need to support that 6 with data. And so, the round robin, from what 7 you said a few minutes ago, it sounds like one 8 is completed, has been completed, or is in 9 process. 10 MS. ARMSTRONG: We did a limited 11 one, right, before? 12 MR. TEICH: Okay.

13 MS. ARMSTRONG: And I am not sure 14 that you can draw 100 percent conclusion bags 15 versus sheets. So, that being said, I think 16 there is a common understanding that labs may 17 have used different mechanisms. We didn't see 18 a large variation in results, but we will see. 19 MR. TEICH: Well, I would 20 offer -- you know, maybe I am going way out of 21 the box -- but I don't think we would be 22 opposed to participating in a round robin to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 186 1 confirm or gather data. 2 MS. ARMSTRONG: Okay. Other 3 manufacturers that agree to do that as well? 4 I appreciate that offer. I will

5 ask. 6 MR. MANTHEI: This is Phil Manthei 7 from Alliance Laundry Systems. 8 I think it is just makes common 9 sense. I mean, you have a cylinder, and 10 trying to put a flat sheet into a cylinder

11 makes no sense. 12 MS. ARMSTRONG: All right. Moving 13 along -- oh, anybody? 14 MR. TEICH: I was just going to 15 say, again, going along with what Phil said, 16 it opens up much more areas for 17 variability/interpretation. How do you wrap 18 the flat sheet around it? That is where we 19 saw the issues. 20 MS. ARMSTRONG: Okay. Moving along 21 to energy test cycle, or I might have them out 22 of order on my agenda.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 187 1 MS. CLEARY: Yes, I think we still 2 had some other drum volume measurement issues. 3 MS. ARMSTRONG: Okay. Keep going. 4 MS. CLEARY: Yes. And I think, 5 just to expand on the last point real quickly, 6 it is that this could be down to like 7 hundredths of a point in terms of the 8 categories of the washers. So, that is what 9 Phil, I think, was indicating. That is why we 10 do see the potential here. 11 MS. ARMSTRONG: I mean, just to 12 clarify, the Department is not opposed to 13 clarifying, where needed, but we will need 14 some rationale.

15 MS. CLEARY: Yes. Understood. 16 I think that issue No. 3 on our 17 sheet -- that is Jen at AHAM -- we probably 18 don't need a lot of discussion on. It is 19 something we just wanted to make sure to put 20 on the record maybe, so that maybe labs are 21 aware of this, that DOE procedure requires the 22 weight of the water to be used to determine

### 202-234-4433 Neal R. Gross & Co., Inc. Page 188 1 the volume. NRCan may have a different 2 procedure. We just think it is worthwhile to 3 verify that all the labs are using the proper 4 volume-measuring procedure, as required by

5 DOE. 6 MR. KVAIDHYANATHAN: Yes, this is 7 Ravee, Samsung.

8 The measurement of water volumes 9 and weight, you know, the accuracy depends on 10 the standard. So, what it really means is 11 that, by using different approaches, the 12 accuracy of measurement can be different. So, 13 the weight measurement is done with more 14 accuracy compared to the volume measurement, 15 as per the standard. But the result will also 16 be different if you use a different method in 17 terms of accuracy.

18 MS. ARMSTRONG: I don't know that 19 you want me to say anything other than you 20 have what our test procedure requires. I 21 don't have it in front of you, but I assume 22 that you have articulated it correctly.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 189 1 MS. CLEARY: Yes, I think we see 2 part of this -- 3 MS. ARMSTRONG: Sure. That's fine. 4 Fair enough. 5 MS. CLEARY: -- open forum as 6 putting it out there in the open, yes. Okay. 7 The fourth issue that we have 8 identified -- and this is also with regard to 9 drum volume measurement -- deals with unique 10 design features. So, this is sort of a broad 11 category. We have identified one such 12 situation could be the seal and the gasket in 13 a horizontal-access machine, that labs could 14 be interpreting this differently as how to 15 measure the volume when there are different 16 designs up in the drum. 17 We would suggest specifically with 18 regard to this gasket and this seal issue that 19 the measurement of volume should not include 20 the volume of the corrugations in the gasket, 21 that bags should just be draped over the 22 gasket, not extending into it. That would be

### 202-234-4433 Neal R. Gross & Co., Inc. Page 190 1 the specific language I think AHAM would 2 suggest and shouldn't be seeing like the bag 3 or the sheet being like stuffed into the 4 gasket. 5 There may also be other unique 6 designs that either exist now for some 7 manufacturers and not others or may be coming 8 onto the marketplace that DOE should also be 9 evaluating. We certainly recognize that it 10 would be the manufacturer's, the individual 11 manufacturer's own to come to DOE with those 12 designs, but, overall, what we would be 13 requesting today is that there should be a 14 method to quickly and uniformly address these 15 designs, so that all labs could be and would 16 be testing in the same way. 17 MS. ARMSTRONG: Okay. I mean, I 18 would encourage you to come to DOE if you have 19 a design for which you think the guidance does 20 not specifically or clearly articulate how to 21 do something before you do your certification 22 testing and before any subsequent verification

### 202-234-4433 Neal R. Gross & Co., Inc. Page 191 1 testing may be done. That is going to be the 2 easiest way to deal with this. 3 And to Jen's point, we will think 4 of ways that we can expedite a response with 5 whatever regulatory mechanisms we have 6 available to us. 7 MR. MANTHEI: Do you mean that each 8 manufacturer should come to you? 9 MS. ARMSTRONG: So, to the extent 10 you want to work with AHAM, because you all 11 have a common design that needs to be 12 addressed, that is fine. If each manufacturer 13 has a different issue, you may also come to us 14 individually. That is kind of at your 15 discretion, depending on the potential designs 16 that may need further clarification which you 17 do not feel is adequately addressed by our 18 test procedure or guidance. 19 This is Ashley from DOE. 20 MR. OSANN: This is Ed Osann. 21 I have got a question about the 22 AHAM position. In this case, seeking to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 192 1 clarify that the volume of the corrugations in 2 the gasket basically are not measured. Is 3 this out of concern for the repeatability of 4 the measurement or is this because -- why 5 should this volume be excluded? 6 MR. TEICH: I think it is 7 repeatability of the measurements, but, then, 8 more importantly, getting at the consumer 9 facing issue, cloths are not meant to reside 10 in that area. 11 As you go through the wash process, 12 we specifically try to keep cloths out of that 13 area. So, how could it be included in a 14 usable capacity. 15 MR. OSANN: So, this goes back -- 16 this is Ed Osann again -- so, this goes back 17 to the notion that the drum volume is supposed 18 to be the extent to which the -- 19 MR. TEICH: The usable capacity. 20 MR. OSANN: -- the volume that is 21 used for washing clothes?

22 MR. TEICH: Correct.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 193 1 This is Dan Teich at Whirlpool. 2 I'm sorry. 3 MS. FARBER: This Julia from UL. 4 I may have some comments related to 5 this issue, but not necessarily specific to 6 the gaskets. So, I am wondering if you want 7 us to wait on that until the end or if you

8 want us to share those comments now.

9 MS. ARMSTRONG: Please share them

10 now. 11 MS. FARBER: Okay. All right. So, 12 we have some clarity questions about the 13 capacity measurement of clothes washers. 14 According to our engineers, the latest 15 guidance is showing examples of where the 16 capacity of clothes washers should be 17 measured, and that has helped to consistently 18 measuring the volume across many models. But 19 the concern is for top-loading models, this 20 capacity measurement does not represent the 21 useful space of loading clothes by the 22 consumer. And when the guidance came out, it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 194 1 represents a much closer -- it was much closer 2 to the usable space than previous 3 interpretations. Now that that has been out 4 for several months after the guidance, there 5 are some models in the market that are getting 6 further from the consumer useful space while 7 still being within the guidelines of the 8 latest guidance. 9 So, it is our suggestion that, if 10 you could at DOE, that guidance documents and 11 schematics get updated periodically to ensure 12 that the measured capacity reflects the usable 13 space, per the intent of the standard. 14 MS. ARMSTRONG: This is Ashley. 15 So, I think, as a general practice, 16 we do not have an issue updating guidance 17 documents where they may necessitate revision. 18 However, we are going to have to know the 19 details about why and what needs to be 20 considered for reopening. 21 MS. FARBER: Thank you. 22 MR. HOMBROEK: This is Phil

### 202-234-4433 Neal R. Gross & Co., Inc. Page 195 1 Hombroek from GE. 2 A question, actually, to UL. Were 3 you talking about the difference between the

4 J-1 and J-2 documents? 5 MS. FARBER: That is referenced in 6 here, yes. 7 And I have another question about 8 the transition of declared capacity from J-1 9 to J-2 and when that might be taking place. 10 Sorry. This is Julia from UL. 11 MS. KOHL: This is Betsy Kohl from

12 DOE GC. 13 The new J-2 is required for use on 14 the compliance date, those new standards that 15 were published in The Federal Register 16 yesterday, I guess. 17 PARTICIPANT: We can't hear you. 18 MS. KOHL: Oh, sorry. 19 Betsy Kohl, DOE GC. 20 Use of J-2 is required on the 21 compliance date of the new standards that were 22 just published in the DFR a day or two ago,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 196 1 assuming that we don't get adverse comments 2 that would lead us to withdraw the rule. 3 MR. HOMBROEK: This is Phil

4 Hombroek from GE.

5 You made reference to a new rule 6 that came out in the last day or something? 7 Okay. And you are backing out more of the 8 standards in J-2 versus what is in the J-1?

9 Is that what I understand? 10 MR. TEICH: This is Dan Teich from 11 Whirlpool. 12 I hope you are referring to the 13 direct final rule that came out --

14 MS. ARMSTRONG: We are. 15 MR. TEICH: -- which was we saw a 16 pre-version of that, I don't know, two weeks, 17 three weeks ago. 18 MS. ARMSTRONG: Yes. It is just a 19 standard rule. It is not a test procedure

20 rule. 21 MR. HOMBROEK: Got it. I

22 understand.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 197 1 MS. ARMSTRONG: The compliance 2 date, the test procedure is keyed to the 3 amended standards. So, the J-2 is keyed to 4 the amended standards. So, you don't actually 5 have to use the J-2 procedure until the 6 compliance date of the amended standards, 7 which got published yesterday. That is clear. 8 MR. KVAIDHYANATHAN: That is March 9 7, 2015. 10 MR. HOMBROEK: 2015? Okay. 11 MS. ARMSTRONG: Okay. Have we 12 dealt with volume?

13 MS. CLEARY: No. 14 (Laughter.) 15 MS. ARMSTRONG: Oh, okay. Keep 16 going with volume. 17 MS. CLEARY: Jen Cleary.

18 We have one more to address. The 19 current volume measurement guidance, as well 20 as Appendix J-2, the language does make it 21 clear that the shipping bolts are to remain in 22 place. But neither of those documents

### 202-234-4433 Neal R. Gross & Co., Inc. Page 198 1 specifies whether the shipping bolts should be 2 supported. 3 So, AHAM would suggest that DOE 4 should expressly state both in the current 5 guidance and in Appendix J-2, that the 6 shipping bolts should be supported. The 7 reasoning there is that this would prevent the 8 drum from sagging when the water is added and 9 will also keep the unit in as-shipped 10 condition, which we understand to be the 11 intent of both J-2 and the guidance. This 12 will also prevent damage to the unit during

13 the test. 14 So, I don't know if the 15 manufacturers have more they wanted to add to

16 that. 17 MR. HOMBROEK: It is Phil Hombroek

18 from GE. 19 Just to make sure you understand 20 what we mean by being supported, what we mean 21 is that the shipping bolts themselves during 22 the test need to be held or fixed; otherwise,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 199 1 the back of the unit sags down and creates the 2 distortion that has been talked about that can 3 add an impact on your volume and, also, can 4 damage the unit, as we mentioned. 5 And we know this varies between 6 third-party labs as to whether it gets done or 7 not. It does have an impact. 8 Thank you. 9 MS. ARMSTRONG: Okay. Anybody else 10 on drum volume capacity? 11 (No response.) 12 Okay. 13 MR. MORRIS: Thank you, Ashley. 14 This is Wayne Morris from AHAM. 15 The issue that we brought up in 16 item No. 6 has to do with the energy test 17 cycle. This is the concern that is expressed. 18 I mean, I am not going to go ahead and read 19 the entire thing. I think you get the picture 20 on this. 21 But our position is that the 22 sanitization cycle and any other cycles here

### 202-234-4433 Neal R. Gross & Co., Inc. Page 200 1 should not contribute to the accuracy 2 representation. We have suggested here that a 3 consumer usage study needs to be done. If 4 there is not data to show that the consumers 5 use the sanitizing cycle or other cycles 6 often, then the cycle should not be required 7 in the test cycle. 8 So, we would like the Department's 9 comments on this situation, and welcome my 10 colleagues as well. 11 MS. ARMSTRONG: Are you 12 volunteering to do a consumer usage study? 13 MR. MORRIS: Well, we think that it

14 needs to be done. 15 This is Wayne Morris. Sorry. 16 And we would certainly be glad to 17 work with the Department on that. 18 (Laughter.) 19 MS. ARMSTRONG: The Department is 20 always glad to work with you, too.

21 MR. MORRIS: Great. 22 (Laughter.)

### 202-234-4433 Neal R. Gross & Co., Inc. Page 201 1 Maybe this is one of those where 2 one could supply labor and one could supply 3 money. 4 (Laughter.) 5 It would probably have to be a 6 negotiated rulemaking on that one. 7 (Laughter.) 8 MS. ARMSTRONG: Okay. 9 MR. MORRIS: This is Wayne again. 10 Do you have any questions about 11 what we are suggesting there or why? I mean, 12 I think that that is why we t’d this up today, 13 is to see if you understand kind of what we 14 are leading at. 15 MS. ARMSTRONG: Yes, I mean, I 16 think we get it, right? 17 MR. MORRIS: If you want me to, I 18 will go on then. The test cloth loading 19 method varies. We have already talked a 20 little bit about this with regard to the 21 possibility of a setting or a situation that 22 could occur with an unbalance.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 202 1 But the loading of top machines, 2 top-loading machines without an agitator is 3 particularly troublesome, as we have found in 4 some of our testing situations, the test 5 procedure states in the load and the energy 6 clause, by grasping them in the center and 7 shaking them to hang loosely and then putting 8 them into the clothes container. It doesn't 9 define how or where to place that test cloth 10 in the drum. 11 And so, what we had suggested was

12 that DOE could allow the use of a form where 13 the manufacturer indicates the load pattern 14 until a more precise loading can be developed 15 for the test procedure. 16 An alternative to this, also, if 17 the Department is willing, we might be able to 18 look at the possibility of a video, as has 19 been suggested before, that we could develop, 20 circulate comments. And then, if all the labs 21 are in agreement, then we could use that as a 22 loading pattern, if it is an industry-wide

### 202-234-4433 Neal R. Gross & Co., Inc. Page 203 1 situation. If this turns out to be an 2 individual product situation, then this may be 3 a loading pattern that needs to be indicated 4 in some form. 5 So, we would like the Department's 6 thoughts on how best to proceed with this 7 situation. I think we are willing to help 8 with this. But I think that we need to have 9 some indication from the Department which they 10 would prefer before we set out in one 11 direction or another. 12 MS. ARMSTRONG: This is Ashley from 13 the Department. 14 I think, at the outset, we need to 15 understand that there is a significant -- 16 there is an impact on consumption and/or 17 ratings with load pattern variance. We need 18 to get to that first. 19 MR. HOMBROEK: This is Phil from

20 GE. 21 Certainly, different machines 22 operate differently and have different sensing

### 202-234-4433 Neal R. Gross & Co., Inc. Page 204 1 mechanisms by which they determine load size. 2 And it our view that we need to inform the 3 consumer on these specific types of machines, 4 how to properly load the machine to get the5 best performance. And we do that in our use6 and-care manuals, and that is our facility, if 7 you will, to communicate to both the consumer 8 and whoever may be testing our units what the 9 best and most appropriate means to load the 10 machine. 11 But it all comes down to how you 12 load-sense, and different manufacturers do it 13 differently. Sometimes it is a matter of 14 agitating the machine. Sometimes it is a 15 matter of spinning the machine, and some are 16 very complicated and somewhat proprietary. 17 So, at the end of the day, they do 18 operate and we do feel an obligation to try to 19 get to that by communicating to the consumer. 20 But I will say that it will certainly have an 21 impact on the DOE measurement if it is not 22 done properly.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 205 1 MR. TEICH: This is Dan from 2 Whirlpool. 3 And I will just fully agree with 4 everything Phil said. I think this was 5 demonstrated as we did our verification lab 6 visits. And that is truly why we got in a 7 discussion to clarify and came up with this 8 proposal. We all instruct in our 9 instructions. And with the newer machines, 10 relatively-newer machines, it is very, very 11 important. It makes a big difference. 12 MS. ARMSTRONG: Okay. So, to 13 answer Wayne's question about how this should 14 be solved, I think the Department needs to 15 think about this and get back to you before we 16 can tell you kind of our position on the best 17 pathway forward.

18 Thanks. 19 MR. HOMBROEK: Let me just add one 20 more thing. This is Phil Hombroek from GE 21 again. 22 About grasping the cloth versus

### 202-234-4433 Neal R. Gross & Co., Inc. Page 206 1 laying it flat in the machine, I just want to 2 make it quick and brief. It does make a 3 difference if you have a cloth that is held in 4 place and tossed in the basket versus it going 5 flat one on top of another all the way around

6 the basket. 7 Cloths that typically are laying 8 flat on top one after another are going to get 9 to that issue where we are going to have more 10 potential for out-of-balance loads. Because 11 if you can imagine the water going right on 12 top of those flat sheets, all you are doing is 13 creating one solid cake, and that is what we 14 are trying to avoid. That is why it is 15 important to us. 16 Thank you. 17 MR. MORRIS: And this is Wayne. 18 I would add to that, that the issue 19 also is that that is not the way the consumer 20 loads a machine. They don't lay something out 21 flat and then pack it into the machine in a 22 flat method one on top of another. At least I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 207 1 don't ever know of any consumer to do it, or 2 if there is anybody on the telephone that 3 wants to volunteer they do, that would be 4 interesting to learn. But I think that most 5 consumers don't behave in that way. So, this 6 will be closer to approximating the way that 7 the consumer actually does load a machine. 8 Thank you. 9 MS. ARMSTRONG: Any other comments? 10 Questions? 11 (No response.) 12 Okay. Water pressure. 13 MR. MORRIS: This is Wayne again. 14 Thank you. 15 Yes, obviously, this is very 16 similar to the issue that we talked about 17 earlier today in regard to the dishwasher. 18 Our experience has been that labs have been 19 seen interpreting how and where the water 20 pressure is measured and controlled 21 differently. And we are concerned that this, 22 as we described earlier, is important because

### 202-234-4433 Neal R. Gross & Co., Inc. Page 208 1 it is an issue of that drop in pressure that 2 happens when you first open the valve to the 3 situation. 4 So, again, is there a certain 5 amount of time that the pressure can go below 6 the limit. The lab seems to be applying 7 different limits to this situation. So, we 8 have made a suggestion that the pressure can 9 be measured as the water is flowing. That is 10 consistent with what we have said before and 11 what we have talked about earlier. 12 DOE made this change request in 13 Appendix J-2, but we are going to be with J-1 14 for three years. We think it is important 15 that we have a clarification in that 16 situation. Water pressure is expected to drop 17 at the moment the valve opens, and we 18 suggested the two-second limit for the 19 transient pressure drop be added to both the 20 J-1 and the J-2. And so, we are asking that 21 the Department do that by form of guidance. 22 MR. HOMBROEK: This is Phil

### 202-234-4433 Neal R. Gross & Co., Inc. Page 209 1 Hombroek from GE. 2 I think we all kind of collectively 3 agreed that two seconds was reasonable for our 4 own labs' capabilities, and it is something 5 that kind of drives consistency amongst all 6 the groups. 7 If we placed a higher tolerance on 8 it, for example, that would require additional 9 equipment, and so on, in order to prevent any 10 reduction in pressure for less than a second. 11 For example, that would cause a lot of lab 12 restructuring. 13 MS. ARMSTRONG: And just a 14 question. Is this something you pretty much 15 voluntarily maintain now? 16 MR. MORRIS: We do. This is Wayne 17 Morris. We do. Many of the manufacturers 18 have volunteered that they do that as well. 19 And this is also done with the laboratory that 20 AHAM uses in its verification program. 21 As Phil said, it is a capability 22 situation. The labs are capable of measuring

### 202-234-4433 Neal R. Gross & Co., Inc. Page 210 1 it in that timeframe without going to 2 extremely-expensive equipment. And we also 3 think that the labs will see a constancy and 4 very little tolerance changes, differences in 5 their measurements if we do this on a flowing 6 basis, which is, I think, what was intended 7 all along and what seems to be intended in 8 other test procedures.

9 Thanks. 10 MS. FARBER: This is Julia Farber

11 from UL. 12 We are measuring the water as 13 flowing and we agree with the two-second 14 recommendation. 15 Thank you. 16 MS. ARMSTRONG: Okay. Keep going, 17 yes. Ambient conditions. 18 MR. MORRIS: Wayne Morris again. 19 Recording the ambient temperature 20 and humidity is not currently required by the 21 DOE test procedure. This may not be as 22 critical as it was in the dishwasher

### 202-234-4433 Neal R. Gross & Co., Inc. Page 211 1 situation, where the air drying and that 2 situation. But when you pack a large number 3 of washing machines that all are using in some 4 cases heated water as well as cold water into 5 a room to do multiple test runs, all going on 6 at the same time, we think that it is very 7 important that we try to maintain the ambient 8 conditions. 9 And so, we do believe it is 10 necessary that the labs are recording their 11 ambient conditions. And so, we think that it 12 is something that the Department can indicate 13 in guidance that this should be done. 14 We believe it is important for the

15 manufacturers to have the access to those 16 ambient temperatures in case there is any lab 17 dispute that may arise. One of the procedures 18 that the AHAM procedural guide allows for is 19 for the manufacturer to challenge the 20 laboratory. While that is used on the 21 extremely rare occasion, it is important that 22 when you backtrack to those circumstances, and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 212 1 certainly if there is an enforcement action, 2 it is sometimes necessary to go backwards into 3 data. In some cases, you are going backwards 4 a year; you are going backwards a significant 5 period of time. 6 Whereas, a lab may be doing things 7 the same way today that they did, say, 30 days 8 ago, they may be doing things differently 9 today than they did two years ago. And so, as 10 we get more and more data accumulating over a 11 longer period of time, it is important to have 12 these recordings. So, we are suggesting that 13 this is something that the Department, it is 14 good laboratory practice to not only structure 15 this and measure this, but it is also 16 important to record this, if we need to ever 17 go backwards. 18 MR. TEICH: This is Dan from 19 Whirlpool. 20 I guess I would just add that is a 21 practice in our labs. So, that is one of the 22 reasons, if we ever do need to challenge a

### 202-234-4433 Neal R. Gross & Co., Inc. Page 213 1 verification test, we would look for that

2 data. 3 MR. MORRIS: This is Wayne. 4 And it is a practice that we use in 5 our laboratory for our verification program. 6 We think it is probably good laboratory 7 practice for anyone. I find it hard to 8 believe that anybody would not do it, but we 9 also think it is important that, if the 10 Department doesn't specify that, then it is 11 one more variable that we can get to that

12 could affect the results.

13 Thanks. 14 MS. ARMSTRONG: So, a question for 15 you, and forgive my lack of knowledge in being 16 able to quickly find this. Are the humidity 17 conditions actually specified in the test 18 procedure that are required to be maintained? 19 So, why would you want them recorded? I mean, 20 I am not saying at the outset that that 21 wouldn't just be good information to have as a 22 basis for what was going on during the test,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 214 1 but what basis would you have to challenge 2 anything if there is no requirement for them? 3 MR. MORRIS: This is Wayne Morris. 4 The only thing I would say is you 5 are right, it isn't, but it is good laboratory 6 practice in any situation. And almost any 7 standard out there is going to require a 8 temperature and a humidity min and max. So, 9 it is not something that we are asking for 10 that is extremely strange. But if the 11 Department feels that the temperature is the 12 only one they want to ask for being recorded 13 because that is what is in the CFR and the 14 test procedure, we could understand that. We 15 were just asking because it is consistency. 16 MS. ARMSTRONG: Oh, yes. This is 17 Ashley from the Department. 18 As a best practice thing, I am not 19 advocating a position here for the Department. 20 I am just more trying to understand where the 21 request comes from on humidity. 22 MR. MANTHEI: This is Phil Manthei

### 202-234-4433 Neal R. Gross & Co., Inc. Page 215 1 from Alliance Laundry Systems. 2 It could impact, I suppose, very 3 slightly when you do the RMC measurement; you 4 are taking that load out and you have to go 5 weigh it. Well, how far away walking with 6 this load and it is evaporating more moisture 7 and the humidity level in the air is going to 8 have some impact on that. 9 MS. ARMSTRONG: Okay.

10 MR. MORRIS: Go ahead?

11 MS. ARMSTRONG: Yes. 12 MR. MORRIS: Okay. Thank you, 13 Ashley. 14 No. 10, I guess we are asking a 15 question. Is the Department doing any testing 16 per J-2? It would be useful to observe the 17 standby portion of the test. 18 Also, should manufacturers discover 19 the ambiguities in the test procedure language 20 with regard to low-power mode, what is the 21 best process for addressing those with DOE? 22 Is it possibly with industry-sought guidance?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 216 1 We would just like to seek some feedback with 2 this situation. I think that the J-2 now 3 calls out the standby or low-power mode 4 measurement. We just would have liked some 5 information in regard to this. 6 MS. ARMSTRONG: This is Ashley from

7 DOE. 8 So, the J-2 rulemaking is complete. 9 We did do testing in support of that 10 rulemaking during the rulemaking proceeding. 11 That being said, obviously, if you 12 come across in your testing ambiguities on how 13 you think people are interpreting J-2 or if 14 you read it and it is unclear on how you 15 should test for J-2, I encourage you to submit 16 a comment or submit a question. You can send 17 it to me. You can submit it through our 18 guidance database, which is the best way to do 19 it. 20 And obviously, we would issue 21 guidance across the board for all, and a test 22 procedure guidance, as our policy was stated

### 202-234-4433 Neal R. Gross & Co., Inc. Page 217 1 earlier, would be put out for comment. 2 MR. MORRIS: This is Wayne Morris. 3 Is the data that you did in regard 4 to the standby portion or low-power mode 5 portion available? 6 MS. REICH: This is Judith Reich 7 from Navigant. 8 A summary of that data is available 9 in the notices that accompanied the test 10 procedure rulemaking. 11 MR. HOMBROEK: This is Phil

12 Hombroek from GE. 13 I would like to ask, further, if 14 you guys would be willing to offer which lab 15 may have done the testing, so that we might be 16 able to go see some of the testing and maybe 17 set up some of our own units to do that, just 18 to make sure that we are following along what 19 was intended. 20 MS. ARMSTRONG: We did it at our 21 own lab. So, the answer is going to be no. 22 But, that being said, like

### 202-234-4433 Neal R. Gross & Co., Inc. Page 218 1 something was mentioned in the hall. To the 2 extent you guys all go to a third party, and 3 you may want to invite the Department, I don't 4 know that we could necessarily articulate, 5 depending on the spot, but we would definitely 6 be willing to be part of those discussions as 7 to what is going on and how the test procedure 8 is being done, if you all wanted to go to a 9 lab to do it, similar to what you did prior to 10 picking a lab for your verification. 11 MR. HOMBROEK: I think that is an 12 excellent idea. And this is Phil from GE. 13 I would certainly like to suggest 14 maybe a third party that we could all agree to 15 go to and run some testing with the J-2 in an 16 open forum where we could see the test run. 17 MR. MORRIS: Well, Ashley, if there 18 is anybody else, that one of my colleagues 19 might have any additional items, I would 20 certainly be willing. But I think that, 21 overall, obviously, we want to thank the 22 Department for today and for Judy and others

### 202-234-4433 Neal R. Gross & Co., Inc. Page 219 1 who have helped with the workshop. 2 This is something that we have been 3 asking for for a while. I know that you all 4 have seen the need for it as well. But, as we 5 get more and more laboratories involved and 6 more manufacturers with their laboratories 7 involved, as well as, then, in the case that 8 we have verification laboratories and now we 9 have enforcement actions and enforcement 10 laboratories involved in this, the lab-to-lab 11 variation is something that we would like to 12 try to reduce as much as possible. And I 13 think the Department would agree with us on

14 that. 15 The importance, also, cannot be 16 overstated with the fact that, as we begin to 17 squeeze the amount of energy out of these 18 machines -- and it doesn't matter whether we 19 are talking room air conditioners or 20 dishwashers or dehumidifiers or whether it is 21 clothes washers, we are talking about water 22 factors now which are down in the tenths of

### 202-234-4433 Neal R. Gross & Co., Inc. Page 220 1 digits. We are talking about calculations of 2 load volumes that in some cases is extremely 3 minuscule between the one division of a 4 section and another. And we have seen 5 examples of that ourselves. 6 As we begin to look at kilowatt 7 hours per year, certainly in the low triple 8 digits, the differences are beginning to be 9 extremely important. We believe that, 10 overall, this program is extremely well run, 11 that the manufacturers have made a huge amount 12 of investment to make sure that there is 13 absolutely as much as possible consistency 14 across all lines. 15 We voluntarily participated in 16 Department of Energy activities of measuring 17 in our verification program. We help with 18 reporting to DOE when there is an issue that 19 may come up, though it is extremely rare. We 20 have been as cooperative as we can with all of 21 these situations. 22 We appreciate the laboratories.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 221 1 And the laboratories have been very, very 2 cooperative with us in all of these 3 situations. 4 But I think that, as we begin to 5 squeeze this amount of energy and water and 6 other activities, the differences between a 7 unit that may potentially be a non-compliant 8 unit and one that is compliant is extremely 9 low. And so, any reduction in the variability 10 we can do is important, not just to us, but to

11 the consumer. We want the consumer to have 12 faith in the numbers that are shown on the 13 machine and in databases and by the

14 manufacturer. 15 The other situation is also 16 important. And that is that, as we begin to 17 squeeze these numbers down less and less, the 18 manufacturers have got to design machines that 19 meet these. And they have got to be able to 20 do design testing in new machines and know 21 that that same test is going to be done 22 multiple times, and it is going to result in

### 202-234-4433 Neal R. Gross & Co., Inc. Page 222 1 the same results two, three, four years down 2 the road, when it is tested in a verification 3 procedure. 4 So, we have set requirements for 5 picking units up as a certain percentage. It 6 takes several years before you are going to 7 get all the models. And that means that there 8 is a span of time between the time that that 9 was certification-tested to the time that it 10 is verification-tested. And that period of 11 time allows for differences. 12 So, the more that we can do to 13 reduce this by giving guidance, writing it 14 down, putting it in procedures, is all going 15 to go to the credibility of the program and 16 building it into a situation that allows the 17 consumer to have most accurate information. 18 So, thank you, and we appreciate 19 all of the effort that it takes to put these 20 on, people that are on the phone lines as well 21 that have been helpful in communicating. So, 22 it is all a good situation, and we hope that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 223 1 for the other products that we are looking at 2 we can do something like this, and we can do 3 it on an ongoing basis. 4 Thank you. 5 MS. ARMSTRONG: So, I will, just in 6 closing, say we appreciate everyone coming 7 today. We look forward to working together 8 with a lot of the issues that we have 9 identified today that we may not have 10 solutions for right off the bat. But we 11 appreciate your taking the time to come here. 12 As you do encounter additional 13 potential clarifications or issues, I do 14 encourage you to engage the Department early, 15 either through the guidance process or through 16 an email to the product PM or myself. It 17 really helps us both inform our rulemaking 18 processes, but for those that we don't have 19 ongoing, you know, to better understand what 20 we may need to do to help clarify where 21 ambiguities lie, where we can. 22 So, with that, I hope everyone has

### 202-234-4433 Neal R. Gross & Co., Inc. Page 224 1 safe travels and enjoys their weekend.

2 Thanks. 3 (Whereupon, at 1:44 p.m., the 4 meeting was adjourned.)

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150:1 9 94:4 9:00 1:11 9:05 6:2 93 5:3 97.641:15NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com C E R T I F I C A T E

This is to certify that the foregoing transcript

In the matter of:

Before:

Date:

Place:

was duly recorded and accurately transcribed under my direction; further, that said transcript is a true and accurate record of the proceedings.

----------------------- Court Reporter 253

Room A/Cs, Dishwashers and Residential Clothes Washers

US DOE

06-01-12

Washington, DC