UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS 

FOR WINE CHILLERS AND MISCELLANEOUS REFRIGERATION 

PRODUCTS 

 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, D.C. 20585 

Room SE-089 Review Center 

Thursday 

February 22, 2012 

 

Facilitator: 

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Charlie Hon 

True Manufacturing 

Joanna Mauer 

Appliance Standards Awareness Project 

Jen Cleary 

Association of Home Appliance Manufacturers 

Jon Wiener 

Earthjustice 

Steve Leybourn 

Association of Home Appliance Manufacturers 

Amanda Stephens 

EPA 

Bill Brown 

GE Appliances and Lighting 

Participants identified through Webinar:

Patrick Murphy 

Director of testing and training 

Refrigeration Service Engineers Society 

Elizabeth Joyce 

California Investor Owned Utilities 

Steve Church 

Whirlpool 

Participants from DOE:

Michael Kido 

 

Lucas Adin 

John Cymbalsky 
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Participants from Consultants:

Detlef Westphalen 

Navigant Consulting 

Kenneth Nsofor 

Navigant Consulting. 

Jeff Greenblatt 

Lawrence Berkeley National Lab 

Erin Claybaugh 

Lawrence Berkeley National Lab 

Greg Rosenquist 

Lawrence Berkeley National Lab 

 

Presenters:

Lucas Adin 

Detlef Westphalen 

Michael Kido 

Jeff Greenblatt 

Kenneth Nsofor
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AGENDA

 ITEM PAGE 

 

Welcome, Doug Brookman 5 

Introductions 5 

Agenda Review, Doug Brookman 6 

Introductory Remarks 9 

Regulatory History overview, Mr. Adin 10 

Scope of coverage, Mr. Westphalen 15 

Rulemaking overview, Mr. Westphalen 61 

Test Procedures, Mr. Westphalen 65 

Market Assessment, Mr. Nsofor 70 

Technology Assessment, Mr. Nsofor 78 

 

Engineering Analysis, Mr. Nsofor 82 

Markup Analysis, Energy Use Analysis, 

Life Cycle Costs and Payback 

Period Analysis, Mr. Greenblatt 87 

Shipments Analysis, Mr. Greenblatt 104 

 

National Impact Analysis, Mr. Greenblatt 109 

Market Impact Analysis, Mr. Nsofor 111 

Plans for NOPR Phase, Mr. Greenblatt 113 

 

Closing Remarks 115 
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Good morning everyone and 

3 welcome. This is the U.S. Department of Energy’s 

4 public meeting on Energy Conservation Standards for 

5 Wine Chillers and Miscellaneous Refrigeration 

6 Products. 

7 Today is February 22, 2012 here in the 

8 Forrestal Building in Washington, D.C. Glad you could 

9 join us. Thanks for being here for an early start on 

10 the day. My name is Doug Brookman from Public 

11 Solutions in Baltimore. It’s our tradition to start 

12 off with introductions around the room. I’ll start 

13 over here, please. Say your name and organizational 

14 affiliation. Most of you are used to turning on 

15 these microphones. Please do so. 

16 Introductions 

17 MR. HON: Charlie Hon, True Manufacturing. 

18 MR. GREENBLATT: Jeff Greenblatt, Lawrence 

19 Berkeley National Lab. 

20 MS. CLAYBAUGH: Erin Claybaugh from Lawrence 

21 Berkeley National Lab. 

22 MS. MAUER: Joanna Mauer, Appliance 

23 Standards Awareness Project. 

24 MR. BROWN: Bill Brown, GE Appliances and 

25 Lighting. 
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1 MS. CLEARY: Jen Cleary, Association of Home 

2 Appliance Manufacturers. 

3 MR. LEYBOURN: Steve Leybourn, Association 

4 of Home Appliance Manufacturers. 

5 MR. NSOFOR: Kenneth Nsofor, Navigant 

6 Consulting. 

7 MR. KIDO: Michael Kido, DOE. 

8 MR. ADIN: Lucas Adin, DOE. 

9 MR. WESTPHALEN: Detlef Westphalen, Navigant 

10 Consulting. 

11 MS. STEPHENS: Amanda Stephens, EPA. 

12 MR. BROOKMAN: Thank you. So, glad you 

13 could join us. Once again, thanks for being here. 

14 Many of you, perhaps most of you are familiar with 

15 these proceedings. I’m going to do a brief agenda 

16 review. 

17 Agenda Review

18 You received a packet of information when 

19 you came in the door that included the agenda and the 

20 PowerPoint slides that would be the basis for both 

21 presentation and discussion as we go on today. 

22 Immediately following this agenda review, there’s an 

23 opportunity for anybody that wishes to do so to make 

24 opening remarks, brief, summary statements about 

25 issues that matter to you, particularly those that you 
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1 wish to have discussed fully during the course of the 

2 day 

3 Immediately following that, we will have a 

4 regulatory history overview by Lucas. We will move 

5 from there to a description of scope. And we’ll take 

6 a mid-morning break, round about 10:30 or so. 

7 Immediately following the break, a rulemaking overview 

8 and framework and test procedure description. Of 

9 course all of these content areas provide an 

10 opportunity for discussion and comment. Following 

11 that, market technology assessment, screening and 

12 engineering analysis. 

13 We’ll take lunch midday, round about 12:15 

14 or so. Following lunch, markups, energy use, life15 cycle cost and payback period analyses; followed by 

16 shipments and national impact analyses, manufacturing 

17 impact analysis, NOPR analyses. And then we are 

18 guessing that we’ll be finished some time after two 

19 o’clock, 2:30 or so this afternoon. There’s yet 

20 another opportunity for anybody to raise additional 

21 issues, additional comments that they’d like to make 

22 at the close. 

23 So that’s the agenda as written. Any 

24 questions and comments? You’ll also note there are 

25 many individuals who have joined us via the web. How 
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1 many do we have via the web? Fifteen. Okay, welcome 

2 to those joining by the web. The Department of Energy 

3 is trying hard to make these meetings accessible and 

4 productive, both, and so what we’re going to try to do 

5 today is – GoToMeeting is the software vehicle, right? 

6 Most of you who have joined us via the web, we’ll try 

7 to provide – we’re going to try it – an opportunity 

8 for you to raise questions and comments during the 

9 course of the meeting. Our webmaster, Emily, is going 

10 to be cueing individuals to ask questions and those of 

11 you that are joining us via the web, please keep your 

12 phones on mute so we don’t get feedback here in the 

13 system, because otherwise, it will kind of blast us 

14 out here in the meeting room itself. Okay. So we’ll 

15 try to make that happen. 

16 I will ask for your consideration. As you 

17 can see, I’ve written up here what I think is not much 

18 more than common sense and courtesy. Please speak one 

19 at a time. Please say your name for the record each 

20 time you speak. I will be cuing individuals by name 

21 as best I can. I also wish to encourage follow on 

22 comments. The back and forth is sometimes very useful 

23 for the Department. There will be a complete 

24 transcript of this meeting. We’ll describe where you 

25 can find the transcript a little later on. 
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1 If you can keep the focus here. Please turn 

2 your cell phones on silent mode. Limit sidebar 

3 conversations. You’ve already figured out how to turn 

4 the microphones on and off with a little LED button, 

5 and if you could be concise. Share the air time. 

6 So, as we had said, now is an opportunity 

7 for anybody that wishes to make brief summary 

8 statements here, raise issues here at the outset. 

9 Yes, please. 

10 Introductory Remarks 

11 MS. CLEARY: Jen Cleary from AHAM. In its 

12 regulation of wine chillers, DOE should adopt or 

13 harmonize with the existing Canadian and California 

14 standards and test procedures for wine chillers. 

15 There is no need to start from scratch by going 

16 through an extensive analysis when appropriate 

17 standards and test procedures are already in place. 

18 In particular, we would make this comment with regard 

19 to items 1-18, 3-2, 3-3, 5-1, 5-3, and 5-4. 

20 In addition, DOE should reevaluate its 

21 priorities and not focus on products with little 

22 opportunity for energy savings when there are more 

23 pressing matters before the Department. For example, 

24 the battery charger rulemaking, the dishwasher 

25 rulemaking, clothes washer rulemaking test procedure 
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1 correlation issues, just to name a few. In some 

2 cases, in this rulemaking, DOE is going too far by 

3 attempting to regulate products that have very low 

4 volumes and/or use small amounts of energy annually. 

5 We would make this comment particularly with regards 

6 to items 1-11, 1-13, and 1-14. 

7 MR. BROOKMAN: And again, you’re speaking on 

8 behalf of AHAM? 

9 MS. CLEARY: Yes. 

10 MR. BROOKMAN: And would you – the first 

11 list, I know some individuals were writing furiously 

12 as you – the first list, read the list again. 

13 MS. CLEARY: Sure. 1-18, 3-2, 3-3, 5-1, 5-

14 3, and 5-4. And we’ll comment on that throughout the 

15 rest – 

16 MR. BROOKMAN: Very good. That’s a start. 

17 Okay. Good. Thank you. Other comments here at the 

18 outset? Nothing additional. Okay. So then let’s go 

19 to then the presentation slides. And we’re going to 

20 hear from Lucas. 

21 Regulatory History Overview 

22 MR. ADIN: Good morning, everyone. My name 

23 is Lucas Adin. For those of you who don’t know me, 

24 I’m the product manager for residential refrigeration 

25 products in DOE’s Appliance Standards Program. And 
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1 I’m the general point of contact for these products, 

2 so whether you have questions today or after today, 

3 I’m the person that you can ask. My email address is 

4 on this first slide, but then it’s also on the very 

5 last slide and my phone number as well, so if you have 

6 questions after today, feel free to contact me. 

7 Sorry, a minor technical difficulty here. 

8 Okay. We’re in business, sorry about that. 

9 So just a few brief items. Actually we’ve 

10 gone through most of this already. The meeting 

11 agenda, Doug essentially went through those items 

12 already. We’ve done some brief introductions, yes, we 

13 did go around the table already, so you’re the 

14 facilitator, Doug, I didn’t know if there were any 

15 particular items you wanted to mention at this point. 

16 Okay. I think we’re good. 

17 Ground rules, we’ve already gone over 

18 essentially all those items, so – 

19 MR. BROOKMAN: We’ve done that. 

20 MR. ADIN: We’ve done that. Okay. The 

21 purpose of today’s meeting, this is the framework 

22 meeting for residential wine chillers and 

23 miscellaneous refrigeration products. So the purpose 

24 of today’s meeting is essentially to present the 

25 analytical process that DOE would go through in the 
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1 course of evaluating potential energy conservation 

2 standards for these products, determining what 

3 products, specifically to cover and setting test 

4 procedures for them. 

5 I should point out that DOE is not actually 

6 proposing anything today. What we are doing is laying 

7 out our process and a basic overview of DOE’s 

8 understanding of these products as of today, our 

9 understanding of the market, of the technical features 

10 of these products and presenting a number of items 

11 that we wish to collect more information about. So 

12 it’s both about how much do we know and how much we 

13 wish to know more about. 

14 So along those lines we also are looking for 

15 comments. There some specific items that we’ll be 

16 asking for comment on and we also encourage 

17 participants in today’s meeting to ask questions or 

18 make comments about any items you think we might be on 

19 the wrong track about or that you think we might be 

20 able to lend some more insight on. 

21 So with regards to comments, you’ll see 

22 throughout the presentation today and throughout the 

23 framework document itself, there are a number of items 

24 on which DOE specifically requests comment, and those 

25 are indicated by these comment boxes, and they are 
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1 identified by a number, so that helps us keep track of 

2 what you’re commenting on. So when you submit your 

3 comments, please make sure to refer to them by the 

4 number that’s indicated in the document. I think 

5 that’s about all there is to say on that. 

6 So with that, I will go on to a very brief 

7 overview of the regulatory history. The authority 

8 that the DOE has to set energy conservation standards 

9 for residential and some commercial equipment was 

10 established by the Energy Policy and Conservation Act 

11 of 1975, which put into place the energy conservation 

12 program for appliances and commercial equipment. DOE 

13 didn’t actually put into effect standards for 

14 residential refrigerators at that time, although DOE 

15 did establish test procedures shortly after. 

16 The first energy efficiency standards for 

17 residential refrigerators actually came into effect at 

18 the federal level with the National Appliance Energy 

19 Conservation Act of 1987, and those standards went 

20 into effect in 1990, and then that Act also required 

21 DOE to conduct rulemaking to determine if more 

22 stringent standards were justified, which DOE did, and 

23 those standards went into effect in 1993, and then a 

24 subsequent rulemaking with a final rule published in 

25 1997 put in the standards that went into effect in 
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1 2001. Those are the standards that are currently in 

2 effect for residential refrigeration products. And 

3 finally, the Energy Independence and Security Act of 

4 2007 required DOE to conduct another rulemaking to 

5 determine standards that would go into effect in 2014. 

6 That rule was just published this past September. As 

7 you can see at the bottom of the slide and those 

8 standards, the compliance date for those is September 

9 15, 2014. 

10 Now the standards that are currently in 

11 effect do not address wine chillers and smaller 

12 refrigeration products. DOE, through a rulemaking, a 

13 final rule published in 2001, modified the definition 

14 of a refrigerator and refrigerator-freezer to 

15 essentially cut off the coverage of these products at 

16 39 degrees, so products that operate warmer than that 

17 are not covered under the present standards. So this 

18 rulemaking would address products that fall into that 

19 category, and so DOE would have to write standards 

20 specific to those types of products, and that’s what 

21 this rulemaking will address. 

22 So with that we get into some more specific 

23 issues related to the scope of coverage, and I will 

24 turn this presentation over to Detlef Westphalen from 

25 Navigant Consulting who will discuss scope of 
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1 coverage. 

2 Scope of Coverage 

3 MR. WESTPHALEN: Thanks, Lucas. So EPCA 

4 provides some scope-related criteria in its 

5 description of refrigeration products that are 

6 covered, specifically excluding those designed solely 

7 for use in recreational vehicles and other mobile 

8 equipment and this particular section, 6292(A)(1), 

9 addresses refrigerators and it has some scope-related 

10 criteria such as they can be operated on alternating 

11 current electricity and the coverage scope excludes 

12 types designed to be used without doors, and also any 

13 type which does not include a compressor and condenser 

14 as an integral part of the cabinet assembly. 

15 Now, through its initial stages, thinking 

16 about consideration of wine chiller rulemaking, DOE 

17 essentially went through the thought process of, okay, 

18 what kind of authority does DOE have and concluded 

19 that it has the authority to modify the current 

20 refrigerator definition which is in 10CFR430.2, to 

21 include wine chillers and similar products. This 

22 authority, however, does not cover products that don’t 

23 use the compressor and condenser as an integral part 

24 of the cabinet assembly as required by the EPCA 

25 provision. Specifically, some of the products that 
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1 were identified in some of the preliminary 

2 investigation were thermoelectric wine chillers, and 

3 also absorption wine chillers. 

4 DOE does have the authority to extend 

5 coverage to new products, and simply establishing 

6 coverage over new products requires that these 

7 products have a minimal annual per household energy 

8 use of 100 kilowatt hours. 

9 To further set an energy efficiency standard 

10 for a newly covered product, there are two key 

11 criteria: 

12  The first is higher annual kilowatt hour usage 

13 bar, at 150 kilowatt hours; 

14  National annual energy use of 4.2 billion 

15 kilowatt hours. 

16 So if the national energy use does not 

17 exceed the 4.2 billion, DOE would be authorized to 

18 establish coverage but not efficiency standards 

19 potentially, for these other types of products, the 

20 thermaoelectric and the absorption type of wine 

21 chillers. And coverage alone, without setting a 

22 national standard would obviously preempt the state 

23 standards, for instance, the California standard for 

24 wine chillers, which does cover the thermoelectric and 

25 other types of products. 
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1 Also regarding the thermoelectric and 

2 absorption, you may be aware that DOE published 

proposed coverage determination on November 8th 3 , 

4 essentially starting to set the stage and start the 

5 discussion on this particular topic. 

6 I referred to California standards. There 

7 are existing state and foreign standards, particularly 

8 California and Canada. The regulations for these 

9 entities address two product classes, automatic 

10 defrost wine chillers and manual defrost wine 

11 chillers, and the California standards don’t make a 

12 distinction with regard to the technology used, for 

13 instance, thermoelectric, vapor compression, et 

14 cetera. 

15 This last statement here was true when the 

16 initial investigation was conducted, that DOE was not 

17 able to identify any thermoelectric wine chillers in 

18 the CEC database, leading us to believe that either 

19 these units did not meet the standards or that 

20 manufacturers aren’t aware that they’re covered. 

21 However, more recently, a few thermoelectric products 

22 have been identified on the CEC list. 

23 So now we get into scope. I’m going to be 

24 presenting on scope of coverage. I’ll also be, after 

25 the break, talking about the rulemaking overview and 
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1 also test procedures, but why don’t we move forward 

2 with the scope discussion. 

3 As mentioned, EPCA has some requirements for 

4 what criteria need to be met for DOE to establish 

5 coverage, and so DOE considered these options listed 

6 here which fit into the framework of the authority. 

7 The first option being to establish coverage and 

8 standards for vapor compression wine chillers through 

9 the existing authority for residential refrigeration 

10 products by changing some of the definitions in 430.2. 

11 Then, obviously, some sub-options within this option 

12 to be either to pursue coverage of the alternative 

13 technology products or not to. The other option DOE 

14 considered was to lump all the wine chillers into one 

15 new category and try to establish new coverage for 

16 those products. At this point DOE is tentatively 

17 considering option 1A, and I mentioned the proposed 

18 coverage determination for the alternative technology 

19 products previously. 

20 So at this point we have our first request 

21 for comment, and it addresses two key issues here, 

22 number one, would there be any other options that DOE 

23 has? Obviously, one would be not to pursue any kind 

24 of coverage at all, but are there any other positive 

25 coverage options that DOE has and what are the 
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1 comments or feedback with regard to the option 1A? 

2 MR. BROOKMAN: Please introduce yourself. 

3 MR. WIENER: Jon Wiener with Earth justice. 

4 MR. BROOKMAN: Did you turn the microphone 

5 on? Yes, thank you. Jon. 

6 MR. WIENER: We had some concerns about 

7 DOE’s conclusion or perhaps tentative conclusion that 

8 it did not have authority to include vapor compression 

9 wine chillers in a new category, if it was going to 

10 extend coverage to thermoelectric wine chillers, that 

11 it could not include vapor compression wine chillers 

12 in that product category. Is that still DOE’s – am I 

13 accurately conveying that decision? 

14 MR. WESTPHALEN: Maybe I didn’t make things 

15 clear. DOE does have the authority to establish new 

16 product categories, and they could establish a new 

17 product category that includes thermoelectric and 

18 absorption wine chillers. 

19 MR. WIENER: And vapor compression wine 

20 chillers? I believe the framework document said that 

21 vapor compression wine chillers could not be included 

22 in a new product category because they’re already 

23 covered products under EPCA. 

24 MR. WESTPHALEN: DOE felt that because the 

25 EPCA authority for residential refrigeration products, 
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1 refrigerators, refrigerator-freezers, and freezers, 

2 already can be extended to cover vapor compression 

3 wine chillers, that it wouldn’t be appropriate to pull 

4 those out of that authority and put them into 

5 authority for a new product. 

6 MR. WIENER: Well, we – we disagree with 

7 that assessment. We think that the Department does 

8 have authority to do that because the framework 

9 document said those products are already covered, 

10 whether or not DOE has authority to extend coverage to 

11 them by changing the regulatory definition of 

12 refrigerator, the definition of refrigerator currently 

13 does not cover those products. They’re not 

14 refrigerators as far as either the regulation or the 

15 statute is concerned, because the regulation construes 

16 the statutory term refrigerator, therefore they’re not 

17 covered right now, and I think the Department could go 

18 either way with it, and our perspective is that if it 

19 helps the Department make the determination that 

20 national energy consumption for all wine chillers 

21 meets the 4.2 billion threshold, then we’d prefer that 

22 DOE consider including vapor compression wine chillers 

23 along with other types of wine chillers in a new 

24 product category. 

25 MR. WESTPHALEN: Okay. That was essentially 
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1 option 2, that DOE entertain the possibility of 

2 lumping them all together because if you used 

3 thermoelectric and absorption, maybe you only get to 

4 three billion kilowatt hours, and then if you add the 

5 vapor compression, maybe you get to 4.2. I guess 

6 that’s the point of your comment. 

7 MR. WIENER: Yes, and we – I just want to be 

8 clear that we think the Department has the legal 

9 authority to do that. 

10 MR. BROOKMAN: So, Jon, you are relatively 

11 new to these proceedings – 

12 MR. WIENER: Yes. 

13 MR. BROOKMAN: So the Department would 

14 really like to see that in great detail in writing, of 

15 course. 

16 MR. WIENER: We’re happy to provide that. 

17 MR. BROOKMAN: Yes, thank you. Charlie. 

18 MR. HON: I have a simple question. You 

19 keep making reference to alternating current systems. 

20 The danger of that statement can be very serious, 

21 because thermoelectrics inherently, by their nature, 

22 are DC current items. They have to put in a sensor or 

23 transformer to convert AC to DC, but you could 

24 potentially exclude products by hooking a battery 

25 system through them and charging a battery and then 
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1 running the battery into that, which is common in sump 

2 pumps and items like that, and thereby exclude 

3 products from the coverage. 

4 MR. KIDO: Just a real quick follow up 

5 question to that – 

6 MR. BROOKMAN: Michael Kido. 

7 MR. KIDO: -- does that mean that those 

8 products are operating off of something like a lead 

9 acid battery, or are they being – are they plugged 

10 into AC mains? 

11 MR. HON: They can operate off a battery, 

12 which is common in the transport cooler systems, which 

13 run off the car battery. But you could be charging a 

14 battery and then feeding the battery as your power 

15 source, and making a DC system which then would be 

16 excluded from the standard. 

17 MR. BROOKMAN: Lucas. 

18 MR. ADIN: Just as a point of clarification. 

19 This is actually an issue we’re going to get to a 

20 little bit later in the presentation. But DOE does 

21 have the authority to potentially include those 

22 products if it so chooses, it’s just a matter of 

23 redefining its regulatory coverage, but that’s 

24 something we’ll discuss a little bit later. Thanks. 

25 MR. BROOKMAN: Joanna. 
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1 MS. MAUER: Joanna Mauer. So in any 

2 potential determination of coverage, either with 

3 option 1A, just focusing – either option 1A or option 

4 2, we’d encourage DOE, in addition to the 

5 thermoelectric and absorption products, to also 

6 consider additional products such as thermoelectric 

7 compact refrigerators and refrigerators that use vapor 

8 compression refrigeration system, but where the 

9 compressor and condenser are not integral to the 

10 cabinet, so just to consider to those products in 

11 addition to the thermoelectric and absorption wine 

12 chillers. 

13 MR. BROOKMAN: Thank you. So you see the 

14 comment box, and so additional comments on the 

15 coverage options? Anything else? 

16 MR. WESTPHALEN: We have some additional 

17 requests here, more requests for data and information, 

18 perhaps more appropriately for written comments. 

19 First of all, DOE requests shipment information from 

20 stakeholders for wine chillers and related 

21 refrigeration products with segregation of the data, 

22 if possible, to help us understand what types of 

23 products are involved. Also DOE requests energy use 

24 data for wine chillers and related refrigeration 

25 products, and this less to the vapor compression 
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1 products for which the CEC and Canadian databases have 

2 good information, but it applies more to the other 

3 products, other technologies, such as thermoelectric 

4 and absorption. 

5 MR. BROOKMAN: We’re just going to leave 

6 these comment boxes there for a moment so you can read 

7 through it. No comments at this time. Okay. 

8 MR. WESTPHALEN: Okay. We have one slide 

9 here which provides a series of definitions. I’m not 

10 going to go through and explain each – this is just 

11 sort of to set the groundwork of the discussion for 

12 this presentation. But if anybody has any questions 

13 about what we have here, certainly feel free to ask. 

14 Definition for wine chiller. DOE is 

15 considering adopting the following definition for wine 

16 chiller. Very similar to the definition for 

17 refrigerator – electric refrigerator. “A cabinet 

18 designed for the refrigerated storage of beverages, 

19 non-perishable foods, and/or any other items. Not 

20 designed to be capable of achieving storage 

21 temperatures below 39, and having associated 

22 refrigeration requiring single phase AC electric 

23 energy input.” 

24 Then also, the definition for refrigerator 

25 would be modified to include both electric 
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1 refrigerator and electric wine chiller. We also have 

2 a point here that DOE considered whether wine chillers 

3 is the appropriate term for these products, you know, 

4 since there may be other products such as beverage 

5 coolers and such products, and the term wine chiller 

6 may be a little bit misleading, focusing people to 

7 think just about wine chillers, i.e., products for the 

8 storage of wine. 

9 MR. BROOKMAN: So I didn’t think you were 

10 quite finished. You were close on this slide. 

11 MR. WESTPHALEN: I think I was finished with 

12 this slide, the third bullet just addresses whether 

13 wine chiller is the appropriate term for these 

14 products. 

15 MR. BROOKMAN: Yes, I thought I saw a few 

16 grimaces around the room. Yes. Is it Bill? 

17 MR. BROWN: Yes, this is Bill Brown, GE 

18 Appliances and Lighting. If you’re going to include 

19 all products that are above 39 degrees, wine chiller 

20 is not the proper term to use any more. Now you’ve 

21 got wine chillers, you’ve got what they call in the 

22 industry, the beverage centers, so it’s basically 

23 you’ve got two sets of products, those that can 

24 achieve 39 degrees and below, and those that cannot. 

25 So if you had a term that more accurately said that, 
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1 if I’m thinking wine chiller, I’m still thinking the 

2 Canadian definition, design and marketed exclusively 

3 for the storage of wine, and obviously this is not the 

4 type of product you’re going after here. 

5 MR. BROOKMAN: And so you would recommend 

6 another term which would be? 

7 MR. BROWN: Another term, I don’t know – 

8 warmer than 39 degree refrigerators. You’ve got less 

9 than or equal to 39, and greater than 39. 

10 MR. BROOKMAN: My short term memory is still 

11 working and you said beverage centers a few moments 

12 ago – 

13 MR. BROWN: That’s what we call them in the 

14 industry, a beverage center, so basically what you see 

15 in the industry today, you see like a glass door 

16 appliance that looks like a refrigerator. It just 

17 can’t get below 39. 

18 MR. BROOKMAN: Okay. Other comments on this 

19 definition stuff here? So we also want to encourage 

20 wide participation, we have a question or a comment 

21 from Patrick Murphy, the director of testing and 

22 training at the Refrigeration Service Engineers 

23 Society. Patrick, you’re on the line. 

24 MR. MURPHY: Is that better? 

25 MR. BROOKMAN: That’s okay. 
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1 MR. MURPHY: The SNAP program just approved 

2 new refrigerants... 

3 MR. WESTPHALEN: Yes. 

4 MR. MURPHY: Can you hear me? 

5 MR. BROOKMAN: We can hear you, yes. 

6 MR. MURPHY: The SNAP program just approved 

7 new refrigerants - propane, isobutene, blends - and 

8 I’m wondering if that’s something considered in these 

9 standards – they’re all more efficient. 

10 MR. WESTPHALEN: Yes, that might be true, 

11 that’s a topic for the engineering or the technology 

12 assessment in identifying the potential technologies 

13 that could improve efficiency. Most of those new 

14 refrigerants would be used in products that have vapor 

15 compression refrigeration systems, so whether they use 

16 HFC, 134A, or isobutane or what have you, they would 

17 still be considered vapor compression products. 

18 MR. BROOKMAN: But in any event we’ll be 

19 picking that up later? 

20 MR. WESTPHALEN: We’ll be picking that up 

21 later, yes. 

22 MR. BROOKMAN: We’ll save it for later. 

23 MR. MURPHY: Thank you. 

24 MR. BROOKMAN: Thank you, Patrick. Okay. 

25 Any other comments in this definition segment because 
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1 we’re about to move on? Okay. 

2 MR. WESTPHALEN: Okay. Now also related to 

3 definitions, DOE is considering modifying the 

4 definition of compact products to specifically include 

5 compact wine chillers, because most of these products 

6 are within the compact range, and DOE is considering 

7 this in order to make clear that they’re not separate, 

8 standard size and compact size wine chillers or 

9 whatever term will be used to cover the warmer than 39 

10 products. 

11 So now we have requests for comments about 

12 all of these definitional items. I think we already 

13 talked about the request for comment on the suggested 

14 definition for wine chiller, however, we’re also 

15 requesting comment on the modified definitions for 

16 refrigerator and compact products. 

17 MR. BROOKMAN: Questions and comments here. 

18 Bill. Pardon me, Jon. 

19 MR. WIENER: Jon Wiener from Earthjustice. 

20 Our concern, again, is that the definition be written 

21 broadly enough so that it doesn’t exclude too many 

22 products, including some of the products that Joanna 

23 mentioned earlier. Several electric refrigerator24 freezers that maybe do get down below 39 degrees, but 

25 are excluded from the statutory definition of 
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1 refrigerator-freezer, or other types of refrigerators 

2 that might be excluded either by the statute, or might 

3 not be covered under the current regulatory 

4 definition. Obviously, that’ll depend on how many 

5 products you decide to group together in the final 

6 analysis. 

7 MR. BROOKMAN: Okay. Thank you. Additional 

8 comments on these two comment boxes, 1-4, 1-5, 

9 modified definitions? Also product category-related 

10 comments. 

11 MR. WESTPHALEN: The request 1-5 addresses 

12 the issue that we already alluded to regarding a new 

13 term that might include wine chillers and the beverage 

14 centers. You know, one part of this request for 

15 comment is whether anybody has any specific terms that 

16 they think would be good for that, and certainly we 

17 welcome any suggestions. 

18 MR. BROOKMAN: Nothing’s emerged on the 

19 industry side, then? Amanda. Pardon me, Jen. 

20 MS. CLEARY: Jen from AHAM. We may have 

21 some suggestions on the definition but we’re still 

22 working on the specifics, so we’ll provide them in our 

23 written comments. 

24 MR. BROOKMAN: Thank you. Okay. Then 

25 nothing additional? 
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1 MR. WESTPHALEN: Now we move on from the 

2 wine chillers to hybrid products. As some of you are 

3 aware, during the refrigerator rulemakings, DOE became 

4 aware of products that include wine storage with fresh 

5 food compartments, or fruit compartments, or freezer 

6 compartments, and initially there was some confusion 

7 about coverage of these products. About a year ago, 

8 DOE published a guidance document clarifying its 

9 position. In that document, DOE acknowledged that 

10 there’s still some outstanding issues in regard to 

11 that understanding of hybrid products, and that it’s 

12 considering a rulemaking to address them, and so 

13 potentially, this would be that rulemaking. 

14 So, this slide lays out a potential 

15 framework for addressing the hybrid products. 

16 Potentially, DOE would establish a certain threshold 

17 size for a wine storage compartment within a 

18 conventional refrigeration product, you know, at which 

19 point the particular product would no longer be a 

20 refrigerator, refrigerator-freezer, or freezer, and 

21 would instead be a hybrid product or whatever term 

22 would be used to define these. Then there would be 

23 definitions established for these hybrid products. 

24 And then test procedures would be developed 

25 for those products that remain within the 
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1 refrigerator, refrigerator-freezer and freezer 

2 categories, to clarify what one does when testing such 

3 products with the wine storage compartment. Test 

4 procedures and standard would then potentially be 

5 developed also for the hybrid products. 

6 So first, DOE requests general comments on 

7 this draft framework for addressing products that 

8 include the wine storage compartments with fresh food 

9 or freezer compartments. 

10 MR. BROOKMAN: Comments? Jen. 

11 MS. CLEARY: Jen from AHAM. Yeah, I think 

12 we’ve commented on this before on the guidance but, 

13 you know, our opinion is that the approach that DOE’s 

14 guidance took and in the final rule is inequitable 

15 with regard to hybrid products, as it’s arbitrary to 

16 treat, that freezers and wine chillers are not 

17 covered, but refrigerators and refrigerator-freezers 

18 with wine chillers are covered. And even DOE has 

19 recognized this disparity of treating these products 

20 that way, and the result is that the guidance and the 

21 final rule unfairly incorporated the products into 

22 regulation without an appropriate rulemaking to 

23 address them. This is further demonstrated by the 

24 fact that these issues are now being addressed, when 

25 we’ve already got these products essentially covered 
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1 but there are no test procedures, no definitions, et 

2 cetera, so we’re very concerned about that situation. 

3 And our concern that DOE is now attempting to fill the 

4 holes that it left in its previous rulemaking with 

5 this one, you know, all wine chillers, including the 

6 hybrid products, should be addressed during this 

7 rulemaking, including the coverage of those products. 

8 And I think our question for the General Counsel’s 

9 office is, you know, how was this evaluated, just in 

10 terms of the APA, for example, the fact that these are 

11 covered in the previous rulemaking and now really, the 

12 technical details that need to exist and be dealt with 

13 are only being handled now. 

14 MR. BROOKMAN: Michael Kido. 

15 MR. KIDO: Michael Kido. I’m not going to 

16 comment in any detail on that, but I think it’s fair 

17 to say that DOE does recognize that there are some 

18 limitations to the approach that was laid out in the 

19 February 2011 guidance, and I think that, as you 

20 observed, this effort, assuming that we do go to 

21 rulemaking on it, would be an attempt to try to more 

22 comprehensively address those types of products. So, 

23 as a practical matter, with respect to the definitions 

24 that are already in place, the way that those 

25 definitions are set out in the regulations, I think we 
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1 explained in the guidance as well as the final rule 

2 notice, what our rationale was for the difference in 

3 treatment. So we’re already on the record as to our 

4 position on that matter. 

5 MR. BROOKMAN: Thank you. Jen. 

6 MS. CLEARY: Thank you. That’s all. 

7 MR. BROOKMAN: Joanna. 

8 MS. MAUER: Joanna Mauer. I think we would 

9 encourage the Department to set standards that are 

10 similar in stringency across some of these product 

11 types, taking into account that the measured energy 

12 use of the hybrid product will be different than the 

13 measured energy use of a refrigerator without a wine 

14 storage compartment, and it looks like this draft 

15 framework allows the Department to do that, to account 

16 for the specific characteristics of some of these 

17 products. 

18 MR. BROOKMAN: Okay. Additional comments? 

19 MR. WESTPHALEN: So additional requests for 

20 comments and information. DOE seeks information 

21 regarding the types and configurations of the products 

22 that might need to be considered under this framework 

23 described for hybrid products, including examples 

24 showing product details and information on annual 

25 shipments associated with such products. We should 
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1 say that DOE has published a document listing the 

2 results of some of its research into which hybrid 

3 products are on sale in the U.S. market, and that’s 

4 actually in the docket for the refrigerator test 

5 procedure rulemaking, and that’s something that maybe 

6 we should make available to people so that, you know, 

7 as they respond to this question in written comments, 

8 they don’t duplicate the list, but rather add to it. 

9 MR. BROOKMAN: It isn’t available now? 

10 MR. WESTPHALEN: It is available now. It is 

11 in the refrigerator test procedure rulemaking docket– 

12 I just don’t have the link to it handy here at the 

13 moment. Maybe we could try to find that and provide 

14 it after lunch or something. 

15 MR. BROOKMAN: And did you address 1-9? 

16 MR. WESTPHALEN: I didn’t get to all of 

17 these here. 1-8 addresses whether there should be a 

18 threshold size or percentage of total volume, which 

19 then pushes a product into the hybrid category, and 

20 what should that be? How should it be set up? And 

21 then DOE seeks comment on what kinds of test procedure 

22 revisions would be required to address these products, 

23 whether they remain within the current definitions or 

24 get pushed into the future hybrid categories. 

25 MR. BROOKMAN: We’ve already had some 
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1 discussion on different types of – different 

2 configurations and types that would be included in the 

3 hybrid category. Additional comments on these three 

4 boxes? Jon. 

5 MR. WIENER: Thanks. Jon Weiner, 

6 Earthjustice. Is DOE considering hybrid products as a 

7 sub-category of refrigerators? Am I understanding 

8 that, or would this be a sub-category of whatever new 

9 product category, or whatever we would call the new 

10 product category? 

11 MR. WESTPHALEN: The products with, if you 

12 will, small wine storage compartments that remain 

13 under the definitions for refrigerator or 

14 refrigerator-freezer, obviously would still be covered 

15 under the existing authority and regulations. The 

16 products that then push into a hybrid category, you 

17 know, it would be up to DOE to decide whether, okay, 

18 should those be lumped in with a new product category 

19 including all wine chillers, or – because of the 

20 typical characteristics of the products that DOE has 

21 identified that fit this hybrid definition, they 

22 should be coverable under the EPCA authority, so that 

23 DOE could set up definitions within 430.2 to extend 

24 coverage to them. But it’s not clear at this point 

25 what will be done. 
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1 MR. WIENER: You mean because they normally 

2 have compressors? 

3 MR. WESTPHALEN: They have compression 

4 systems, they have doors that close, they run on AC 

5 electricity, yeah. 

6 MR. WIENER: Well, I’ll make sure to put 

7 this in written comments, but just to repeat myself, 

8 we do believe that DOE has the authority to put that 

9 subcategory into – or count those products towards the 

10 national energy consumption for a new product category 

11 as well. 

12 MR. WESTPHALEN: Okay. 

13 MR. WIENER: They don’t have to be 

14 refrigerators or refrigerator-freezers. 

15 MR. BROOKMAN: Okay. Thank you. So several 

16 comment boxes here. Additional comments on threshold 

17 size or percentage of total volume? Types of hybrid 

18 product categories? And also test procedure 

19 revisions. Nothing additional. 

20 MR. WESTPHALEN: Okay. Item 1-10 

21 specifically addresses whether this action here should 

22 incorporate these hybrid products into our rulemaking. 

23 Really, a very specific question, and then Item 1-19, 

24 specifically asks for comment on the compartments 

25 themselves, you know, whether they be wine storage 
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1 compartments, maybe they should have a different term. 

2 The Australian/New Zealand test procedure, for 

3 instance, calls these something like cellar 

4 compartments. What the request for comment there asks 

5 for information regarding definition and 

6 characteristics of these warmer temperature 

7 compartments. 

8 MR. BROOKMAN: No strong feelings about this 

9 yet. Okay. Joanna. 

10 MS. MAUER: Joanna Mauer, just I think it 

11 makes sense to include hybrid products as part of this 

12 rulemaking. I don’t know much about this market, but 

13 I would guess that these products may become more 

14 common in the future, so it makes sense to adjust them 

15 and develop appropriate test procedures and standards 

16 for these products. 

17 MR. BROOKMAN: Additional comments? 

18 MR. WESTPHALEN: Okay. So here we sort of 

19 extend the scope of view to think about other types of 

20 residential refrigeration products that haven’t been 

21 discussed already and have not yet been covered. The 

22 framework document gets into some details on these, 

23 for example, residential ice makers, and so-called 

24 near-freezers. And so DOE requests comment on whether 

25 any other residential refrigeration products that 
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1 should be considered as part of a potential rulemaking 

2 as we move forward here. 

3 MR. BROOKMAN: You see the comment box – 

4 yes, Jon. 

5 MR. WIENER: John Wiener again. Just want 

6 to repeat something Joanna mentioned earlier. The one 

7 product that I noticed that wasn’t mentioned in the 

8 framework document was a product that AHAM and 

9 Earthjustice submitted comments on in response to the 

10 proposed determination, and those are refrigerators 

11 that have compressors and condensers and fit all the 

12 definitions of the regulatory and statutory – all the 

13 provisions of the statutory and regulatory definitions 

14 except the compressor is located on top of the unit 

15 instead of as a part of the cabinet, and it’s 

16 removable. I don’t know if there’s a neat way of 

17 writing a definition of whatever new product category, 

18 whatever we’re going to call it, that incorporates 

19 both wine chillers and those products, but it’s 

20 something that we would like the Department to pay 

21 attention to, because we think it’s a loophole in the 

22 current regulatory scheme. 

23 MR. BROOKMAN: Thanks. 

24 MR. BROWN: Bill Brown with GE. I would 

25 have a question of why would that product would not be 
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1 covered today. I don’t see anything in the standards 

2 thing that it has to be permanently attached to the 

3 refrigerator, be part of the cabinet. I do know that 

4 in the ISO documents for international refrigeration, 

5 that in order for it to be covered in Europe it has to 

6 be built in a factory. It can’t be pieced together in 

7 someone’s home. Do not see that for the U.S. 

8 MR. KIDO: Michael Kido, DOE. My 

9 understanding of – 

10 MR. BROOKMAN: Michael, get close to the 

11 microphone, please. 

12 MR. KIDO: My understanding of Jon’s 

13 comment, though, refers to a product where the 

14 compressor is not integral to the cabinet, is that 

15 right? 

16 MR. WIENER: Yeah. 

17 MR. KIDO: Right. So if that’s the case, 

18 under the statutory definition that we’re currently 

19 dealing with, with that particular product, there’s 

20 some question as to whether that would actually be 

21 within our scope of coverage right now. That’s 

22 something we can add later on as part of that coverage 

23 rulemaking that we’ve got going on, but right now that 

24 doesn’t seem to be something that’s within the scope 

25 of coverage that EPCA sets out for us. 
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1 MR. BROOKMAN: Bill. 

2 MR. BROWN: You said two things there. You 

3 said you weren’t sure, and then you said it was not 

4 covered. So which is it? Is it you’re definitely 100 

5 percent sure this is not a covered product, or you’re 

6 still determining whether it’s a covered product? 

7 MR. KIDO: Michael Kido. My understanding 

8 is, if this particular product has a compressor that’s 

9 not integral to the cabinet assembly, which is one of 

10 the key components of the scope of coverage that’s 

11 laid out in statute, we don’t have coverage under that 

12 provision. With respect to our ability to extend 

13 coverage as a part of the separate coverage 

14 determination that we’ve got going on, we could get 

15 coverage that way. 

16 I guess to put it in another way, our 

17 authority does not extend coverage to products in 

18 which the compressor and condenser are not an integral 

19 part of the cabinet assembly. And the question to be 

20 answered is what does it mean to be an integral part 

21 of the cabinet assembly. And that issue has not been 

22 definitively decided. 

23 MR. BROOKMAN: So that would be commentary 

24 that would be useful for the Department. Charlie. 

25 MR. HON: Charlie Hon. This is something 
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1 that’s been in the commercial end of the business for 

2 a long time. Basically, it is designed so that the 

3 unit can be serviced without pulling the entire box 

4 out, just bring in a different compressor deck, drop 

5 it on, a couple snap-on connectors and you’re done. 

6 And it’s starting to trickle toward the residential 

7 market, it looks like, but it’s never been considered 

8 as separate units in the commercial end of the 

9 business. But there have been a few people that have 

10 tried to make a common footprint which would allow a 

11 much larger compressor to be dropped in place, thereby 

12 modifying the unit, the internal volume ratio, which 

13 could be a problem in the regulatory state, which 

14 would be field modification. But there are also 

15 companies who are proposing that decks be sold 

16 separately to boxes, and then paired in the field. 

17 And then you end up with a regulatory nightmare. 

18 MR. KIDO: Michael Kido, DOE. Just to 

19 follow up then. So are you saying then that these 

20 particular products would have the compressor part of 

21 what you would ordinarily consider to be part of the, 

22 I guess, the cabinet? 

23 MR. BROOKMAN: Or the enclosure? 

24 MR. KIDO: Or the enclosure of the whole 

25 product? Because I guess that’s sort of – that 
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1 presents sort of, I guess, a different question 

2 because we’re not exactly – I don’t know, I don’t 

3 think we’ve come up with a final determination as to 

4 what the cabinet actually composes – is composed of. 

5 Because if it’s part of the enclosure, I suppose it 

6 could be an argument that could be part of the cabinet 

7 itself. 

8 MR. ADIN: Lucas Adin, DOE. Related to that 

9 is another question. Could the compressor, and I 

10 suppose the condenser as well, as a component, be 

11 located separately from the box? I mean that would 

12 effectively make it a remote condensing type of 

13 product, but is it required that units of this type 

14 actually have that compressor-condenser component 

15 physically attached to the box or could it actually be 

16 located remotely? 

17 MR. HON: It could technically – 

18 MR. BROOKMAN: Charlie. 

19 MR. HON: Charlie Hon. It could technically 

20 be remote. There are very high end installations 

21 where customer refrigeration is done where people do 

22 not wish to hear the noise going on in the compressor 

23 activity, in which case it’s a very expensive 

24 installation, and very, very, very rare to see such a 

25 beast ever built. Because effectively you’re 
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1 building a pure custom unit. 

2 MR. BROOKMAN: It’s a custom piece. 

3 MR. HON: Yes. The other part of the beast 

4 is, in the commercial end, it is quite common to sell 

5 a unit where you snap on a deck which includes 

6 compressor, evaporator and condenser, and fan. So you 

7 just literally unplug it from the junction box, two or 

8 three screws, lift it off. The box maintains as is, 

9 put a different compressor deck in place, and it’s 

10 ready to go. There are customers who ask for boxes 

11 alone, and would like to have a common deck crossing 

12 multiple product lines which they can then screw on as 

13 they feel the need. That could allow for major 

14 differences in compressor horsepower. 

15 MR. BROOKMAN: Is that a common application? 

16 That plug-on to the top of the box? 

17 MR. HON: It is becoming more common every 

18 day. Five years ago, it was non-existent. 

19 MR. BROOKMAN: We’ll let Michael Kido follow 

20 up. 

21 MR. KIDO: Just a real quick question. Now 

22 you said those types of applications are becoming more 

23 and more common. Are they more common in the 

24 commercial context, or are they becoming more common 

25 in the residential complex? 
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1 MR. HON: At this time I’ve not seen them in 

2 the residential, but the technology is well known. 

3 MR. BROOKMAN: Bill, you want to – 

4 MR. BROWN: No, no question. 

5 MR. BROOKMAN: Okay. Thank you. That was 

6 good. That was useful. Joanna. 

7 MS. MAUER: Joanna Mauer. So you mentioned 

8 thermoelectric compact refrigerators before, and I 

9 know DOE has raised a concern with wine chillers, but 

10 if there are only standards on vapor compression 

11 products and not thermoelectric products then there 

12 could potentially be a market shift from the vapor 

13 compression to thermoelectric products and it seems 

14 like there could be a similar concern in the compact 

15 refrigerator market. So we’d encourage DOE to include 

16 thermoelectric compact refrigerators in any 

17 determination of coverage. 

18 MR. BROOKMAN: Jen. 

19 MS. CLEARY: We would reiterate our comment 

20 from the opening statement that DOE should be 

21 refocusing its priorities, you know, not addressing 

22 products that have little opportunity for energy 

23 savings when there are more pressing matters before 

24 the Department. 

25 MR. BROOKMAN: Thank you. Additional 
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1 comments on 1-13? Okay. 

2 MR. WESTPHALEN: We have additional requests 

3 for information on the same theme, you know, for 

4 shipment data or energy use data for these other types 

5 of equipment, and I don’t know if we need to dwell on 

6 these requests for comment, just know that DOE 

7 requests comment on – or requests information, rather, 

8 and data if it is available to allow the Department to 

9 properly assess the potential for energy savings and 

10 make an informed decision regarding pursuit of 

11 coverage of these other product categories. 

12 MR. BROOKMAN: Does the Department know, has 

13 AHAM collected this data, for example? 

14 MR. WESTPHALEN: DOE does not know whether 

15 AHAM collects any of this data for any of these niche 

16 products. It’s possible that manufacturers have some 

17 understanding of the size of the market and could 

18 provide that information. Any such information, 

19 obviously, is better than none. 

20 MR. BROOKMAN: So, I’m not going to linger 

21 on these very long, unless we get some interest here. 

22 Michael? Michael Kido. 

23 MR. KIDO: I’ll just throw that question out 

24 there, does anyone know of any sources that we could 

25 use to get that kind of information? 
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1 MR. BROOKMAN: No knowledge of it at this 

2 time. Okay. 

3 MR. WESTPHALEN: Okay. 

4 MR. BROOKMAN: Joanna, please. 

5 MS. MAUER: Joanna Mauer. Can I just ask a 

6 quick question about the near-freezers? I think DOE 

7 outlined a couple of potential options for addressing 

8 these products. Was one of the options to amend the 

9 definition for freezer without changing the test 

10 procedure? 

11 MR. WESTPHALEN: Because the definition for 

12 freezer in 430.2, DOE presumably had the option to 

13 change those definitions to extend coverage to these 

14 so-called near freezer products. Then, as you point 

15 out, then the issue becomes well, is the current test 

16 procedure for freezers appropriate for these products, 

17 and DOE may then have to consider test procedure 

18 modifications to address them, and also, you know, 

19 develop guidelines for how the existing energy 

20 standards might apply to them. 

21 MS. MAUER: Okay. Thank you. 

22 MR. BROOKMAN: Bill. 

23 MR. BROWN: This is Bill from GE. AHAM does 

24 have comments on how you can use the existing test 

25 procedure for a near-freezer, and we will be providing 
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1 those in our comments, and one possibility would be 

2 use the current test procedure and instead of 

3 interpolating to zero degrees, you extrapolate to zero 

4 degrees. So you’d still be comparing the products 

5 that are called freezers using the same test procedure 

6 without any change in the definition of the test 

7 procedure at zero degrees, you could still use the 

8 same equations, you still got a straight line between 

9 two points, you just extrapolate to zero instead of 

10 interpolating. 

11 MR. BROOKMAN: And so your thinking is, or 

12 AHAM’s thinking is that that will be sufficient? 

13 MR. BROWN: Yes. 

14 MR. BROOKMAN: Thank you. Joanna. 

15 MS. MAUER: Joanna Mauer. Is that a 

16 specific utility of these kinds of products? Are they 

17 currently on the market? 

18 MR. BROWN: I would say that GE does not 

19 have any of these products. We were not aware of 

20 these products existing, certainly see how someone 

21 could design a product that does not get to zero 

22 degrees. 

23 MR. BROOKMAN: I notice that Jen just 

24 stepped out of the room for a moment, so maybe there 

25 is some additional comment to be made there? Not at 
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1 this moment. Any more comments on this segment? 

2 Okay. Charlie. 

3 MR. HON: One question. Near-freezer is a 

4 pretty broad statement. One product that does exist 

5 in the market is that people like really cold beer, 

6 below the standard refrigerator category, but 

7 certainly not to the freezer category, but definitely 

8 would be below any standard which would be allowable 

9 for a refrigerator. Is that going to fall into the 

10 near-freezer? 

11 MR. WESTPHALEN: We don’t know for sure. 

12 One might consider that near-freezers would have 

13 temperatures up to 20, and maybe above 20 would be 

14 like a high performance refrigerator or something. 

15 But obviously, at this point, our understanding and 

16 how many of these products is actually shipped is 

17 somewhat limited and we don’t really know if it makes 

18 sense to pursue all of this. 

19 MR. BROOKMAN: Charlie Hon. 

20 MR. HON: The term freezer, I assume, is 

21 read generally accepted as freezing water, below 32 

22 degrees, and alcoholic beverages have a much lower 

23 freeze point than that. So that’s why I’m confused. 

24 MR. BROOKMAN: You don’t have these 

25 definitions established at this point? 
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1 MR. WESTPHALEN: No. I mean, near-freezer 

2 was discussed in the framework document without any 

3 specific guidance for what the temperature level is, 

4 and the topic was raised in the framework in response 

5 to comments received from one of the stakeholders 

6 during the refrigerator test procedure rulemaking last 

7 year or the year before, indicating that, you know, 

8 the zero Fahrenheit bar would potentially cause some 

9 of these products to be non-covered. And so the 

10 stakeholder felt that we shouldn’t let them get away 

11 with it just because they can’t meet zero Fahrenheit. 

12 MR. BROOKMAN: Charlie. 

13 MR. HON: Charlie Hon. This has been 

14 addressed recently in final rulemaking from the DOE 

15 covering commercial refrigeration. Basically the rule 

16 of thumb was there’s several products involved, wine 

17 chillers were some of those products, basically, that 

18 did not get to the 38 plus or minus two standard, and 

19 ice vending or ice storage machinery, which was in the 

20 mid-twenties was also considered. But basically the 

21 rule of thumb at that point was DOE said turn the unit 

22 as cold as it can go and report as a variance on the 

23 standard, but document what you did. 

24 MR. BROOKMAN: What are these units designed 

25 to do? Do you know? 
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1 MR. HON: Depends on the units. Wine 

2 chillers, depending on what type of wine you’re trying 

3 to hold, could be 45 degrees, 55 degrees, 58 degrees. 

4 Ice storage is generally done between 22 and 30 

5 degrees Fahrenheit for commercial purchased ice, bags 

6 of ice. Beer units in the commercial end, there are 

7 beer units which run at 27, 28 degrees Fahrenheit, 

8 because bars want to sell really cold beer. But if 

9 they go put their light beers in there, they quite 

10 often break the bottles. So there’s a problem with 

11 them. 

12 MR. BROOKMAN: I think maybe we should maybe 

13 at lunch do some taste-testing here. 

14 MR. BROWN: In the refrigerator-freezer 

15 definition, when you look at what is a compartment, 

16 what is a fresh food compartment, what is a freezer 

17 compartment, for fresh food, it’s anything above eight 

18 degrees Fahrenheit. So that’s not – again, just for 

19 your own refrigerators between 32 and 39, but if you 

20 look at just individual compartments, anything above 

21 eight degrees is considered fresh food, so when you 

22 calculate the volume of that compartment it goes into 

23 the fresh food bin, anything below eight is a freezer. 

24 For example, the bottom freezers that have the ice on 

25 the door in the fresh food compartment, that is in the 
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1 20 degree range when you’re storing ice, and that’s 

2 considered to be a fresh food compartment. So just 

3 one more thing to consider when you’re looking at what 

4 is a near-freezer. You’ve already got definitions of 

5 what is a fresh food for a compartment, possibly you 

6 can use that or build on that to come up with what a 

7 near-freezer would be in this definition. 

8 MR. BROOKMAN: Where is that definition? 

9 MR. HON: You can see that in the AHAM HRF10 1, which 10 CFR 430 points to as far as how to 

11 calculate the volumes. 

12 MR. BROOKMAN: Okay. Thank you. Lucas Adin 

13 has a question from someone on line. 

14 MR. ADIN: This was actually just a comment. 

15 This was from Steve Church at Whirlpool in regard to 

16 Item 1-14, residential ice makers. His comment was, 

17 “The intent of Congress with EPCA was not to restrict 

18 these products. A very small number of these products 

19 are sold each year, and regulating these products will 

20 have almost no impact on reducing energy consumption.” 

21 MR. BROOKMAN: Okay. Thanks. Additional 

22 comments relative to these two comment boxes? Bill, 

23 go ahead. 

24 MR. BROWN: One other example from 1-14, 

25 residential ice makers, California does regulate ice 
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1 makers that make above 50 pounds per day, so those do 

2 exist – regulations do exist for that type of product, 

3 but below 50 pounds a day, there is no regulation. 

4 MR. BROOKMAN: Okay. Thank you. Yes. 

5 MR. ADIN: Sorry, this is Lucas Adin, DOE. 

6 Just a quick question on that. Is that specific to 

7 residential ice makers or is it commercial or do they 

8 distinguish? 

9 MR. BROWN: I’m not sure. We don’t have 

10 that product. 

11 MR. BROOKMAN: Charlie? 

12 MR. HON: Charlie Hon. I don’t deal in that 

13 product, but I happen to know the regulations because 

14 there are some questions brought up in some other 

15 meetings. The regulations do not specify application. 

16 They specify less than 50 pounds of ice generated per 

17 24 hour period, or they specify a regulated product, 

18 which is 50 pounds to 2500 pounds of ice generated 

19 within a 24 hour period. After that it’s considered 

20 an industrialized factory, and no longer regulated 

21 under the same standard. 

22 MR. BROOKMAN: So it’s only volume. 

23 MR. HON: How much you can produce in a day. 

24 MR. WESTPHALEN: The ceiling on that 

25 capacity range has been lifted to 4000 pounds per day 
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1 as part of the commercial ice maker rulemaking 

2 recently. 

3 MR. BROOKMAN: Thank you. So I guess we’re 

4 moving on now. 

5 MR. WESTPHALEN: One – I think this is the 

6 last topic under scope, has to do with the 

7 residential/commercial split and this is a question 

8 that has come up recently in rulemakings in regard to 

9 when is a product a commercial product versus a 

10 consumer product. And I’m not going to try to quote 

11 the EPCA guidelines on that, but DOE is aware of 

12 several attributes that could distinguish commercial 

13 types of wine chillers from residential types, but 

14 would like additional information to allow it to 

15 definitively conclude if that is the appropriate 

16 decision that wine chillers with uniquely commercial 

17 features exist. 

18 So we have requests for comments on this 

19 theme, DOE seeks comment on what design and 

20 performance characteristics distinguish the wine 

21 chillers used in commercial applications, whether any 

22 of these wine chillers are manufactured on the same 

23 product lines as residential wine chillers and 

24 whether, to any extent, commercial wine chillers are 

25 distributed in commerce for personal consumer use. 
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1 Obviously, DOE seeks details regarding the magnitude 

2 of those sales. 

3 And then, a related, catch-all item, 1-16, 

4 DOE seeks comment on whether the commercial and 

5 residential wine chillers should be addressed with the 

6 same test procedures and energy standards within the 

7 same rulemaking. 

8 MR. BROOKMAN: Charlie. 

9 MR. HON: Charlie Hon. Several comments 

10 here. Number one, wine chillers, large commercial 

11 wine chillers, do trickle into the residential market. 

12 Commercial manufacturers like our company try and 

13 avoid that at all cost, even though we have no control 

14 over the dealers selling the product into the 

15 residential market. But due to the way they’re 

16 designed, they’re a disaster in a home because 

17 commercial application wine chillers are done on the 

18 same commercial refrigeration systems as commercial 

19 refrigerators which are, shall we say, noisy at best. 

20 If you put them in your home, you probably not want 

21 them in your home very long, because they make a lot 

22 of noise and it’s quite often objectionable in a 

23 kitchen environment, when people are sitting around 

24 talking and the thing turns on, it makes a lot of 

25 racket over the conversation. 
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1 It does happen. It is very – it’s not 

2 common and manufacturers try and avoid it for two 

3 reasons, number one is we don’t want to get caught in 

4 a legal issue, crossing the bounds and not having 

5 registered, or our product registered for one market 

6 and not the other with the DOE. Secondly, is our 

7 field concerns as far as warranty come and customer 

8 dissatisfaction are so great that we discourage any 

9 sales of our commercial products in the home market. 

10 Secondly, at this time, you’ve got to be 

11 very cognizant that if they go the same standards, 

12 these are different applications. If you take a 

13 product which is designed for a commercial 

14 application, you’re assuming that the waiter or 

15 waitress or whomever is handling out the wine is in 

16 that cabinet on a very consistent basis. If you’re in 

17 a restaurant, there’s going to be bottle after bottle, 

18 after bottle being opened, and that wine cabinet is 

19 being opened almost continuously. And under 

20 commercial design, we design to capture air recovery 

21 within the first three to five minutes in a commercial 

22 unit. You don’t want that kind of air movement in a 

23 residential unit because you’ll dry out your corks and 

24 ruin your wine. 

25 Commercials are designed to move wine in and 
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1 move wine out. And they consume a lot more power 

2 because that quick recovery and constant air movement, 

3 which means you have fans in there moving it all the 

4 time. That’s so the wine is presentable to the 

5 customer on a regular basis during a heavy rush of an 

6 all-evening restaurant. And the residentials, that is 

7 not the case. Quite often a wine bottle will sit in 

8 it for several weeks or months. 

9 MR. BROOKMAN: What happens in the unit– 

10 when the restaurant’s not open? Is there a different 

11 cycle or something? 

12 MR. HON: Oh, it just goes to a totally 

13 different cycle, by demand, but your recovery times 

14 are totally different. You’d use one-third the 

15 horsepower in the compressor in the residential than 

16 you would in the commercial. 

17 MR. BROOKMAN: Good. That was helpful. Do 

18 you have additional comments related to these two 

19 comment boxes, Charlie? 

20 MR. HON: Definitely – this is Charlie Hon 

21 again – definitely the commercial penetrating into the 

22 home market is very, very low. There’s no coverage 

23 discussions whatsoever that I’ve seen and people who 

24 are buying what is known as wine cellars for their 

25 house, which is a walk-in cabinet, quite often remote 
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1 refrigeration systems. And I don’t see that being 

2 covered or discussed anyplace in this document. 

3 MR. BROOKMAN: Any comments on whether 

4 commercial and residential wine chillers – whether 

5 commercial and residential wine chillers should be 

6 covered under the same test procedures and energy 

7 standards? Bill. 

8 MR. BROWN: My comment would be based on his 

9 comments that they’re two different appliances, and 

10 should not be lumped into the same product category. 

11 MR. BROOKMAN: Thank you. Charlie. 

12 MR. HON: Charlie Hon. The commercial 

13 standard is ASHRAE 72 which has eight hours of door 

14 openings, every ten minutes you open each door. Under 

15 normal residential design, your product is gone by 

16 that period. You just cannot maintain your 

17 temperatures in a residential unit opening it every 

18 ten minutes. The test is much more severe for 

19 commercial because it is what happens in the real 

20 world. And as such, locking them into the same 

21 process, I do not believe is a logical thing to do. 

22 MR. BROOKMAN: That detailed comment is very 

23 useful, thank you. Lucas. 

24 MR. ADIN: Lucas Adin, DOE. I’m just going 

25 to read one more question that came in through the 
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1 webinar. This is from Elizabeth Joyce of the 

2 California Investor Owned Utilities. And Elizabeth 

3 says, “It’s our understanding that DOE is already 

4 considering coverage for commercial wine chillers 

5 under the ongoing commercial refrigeration rulemaking. 

6 Can DOE clarify its scope of coverage here?” 

7 I don’t know that we can offer any specifics 

8 today. I think that’s something, at least in regard 

9 to this rulemaking, that we’re still trying to figure 

10 out. We need more information about it. So 

11 unfortunately I can’t offer a specific answer. 

12 MR. WESTPHALEN: Just a clarification 

13 question for Charlie. My understanding is that there 

14 are no separate test procedures for wine chillers, 

15 commercial wine chillers as compared with commercial 

16 refrigerators, that it's basically the same test 

17 procedure except obviously you can’t reach the same 

18 integrated average temperature. 

19 MR. HON: That is part of the recent final 

20 ruling that came out within the last month and a half 

21 concerning non-standard products in the commercial 

22 refrigeration business, where you cannot get it cold 

23 enough to run the standard test. They do not 

24 differentiate whether they’re wine chillers, because 

25 there’s much broader categories in the commercial end. 
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1 Wine chillers, or this type of thing, chocolates and 

2 flowers are all covered under the same standard, 

3 because any of those three products, if you get them 

4 to 38 degrees Fahrenheit, you’re destroying the 

5 product, and as such they’re all designed to be much 

6 warmer than that, and the units are designed to cover 

7 that category. And that’s why, in the commercial end, 

8 it doesn’t say wine chillers. It has avoided that 

9 because they don’t want to start categorizing and 

10 saying, well, this is a wine chillers, or you’re 

11 applying it for chocolates, or you’re applying it for 

12 flowers. It is a non-standard refrigerator, because 

13 there are more and more product categories appearing 

14 all the time to cover, so they didn’t want to specify 

15 coverage of wine. But chocolates and flowers are the 

16 most counted. 

17 MR. WESTPHALEN: Okay. 

18 MR. BROOKMAN: Additional questions or 

19 comments? Okay. 

20 MR. WESTPHALEN: I thought the last one was 

21 the last one, but maybe this one is, under scope. We 

22 talked briefly earlier about products that can operate 

23 on both AC and DC electric power. DOE is aware that 

24 there are such products. Many of these products are 

25 clearly marketed for mobile applications, such as 
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1 recreational vehicles, and for that reason they would 

2 not be subject to coverage under the EPCA authority. 

3 However, DOE is considering the possibility 

4 that there may be significant numbers of these 

5 products that are used in stationary applications, so 

6 DOE seeks information regarding products that can 

7 operate on either AC or DC are distributed to any 

8 significant extent to applications where they are used 

9 in stationary status. What types of products are 

10 there? What annual shipments are there? 

11 And DOE also generally seeks comment on 

12 whether it should consider extending coverage to such 

13 products. 

14 MR. BROOKMAN: See the comment boxes. No 

15 comment. Okay. Well, it’s just about 10:30, let’s 

16 take a coffee break. We’ve made good progress here, 

17 really appreciate the quality and breadth of the 

18 comment. It’s 10:30. Some of you are fairly new to 

19 the Forestall Building, you must wear this badge if 

20 you’re going to walk around inside the Forestall 

21 Building. There are rest rooms on both ends of the 

22 hall here. We’re on Floor 8, and all the other floors 

23 – they’re stacked up and down. There’s a coffee shop 

24 on the ground floor. Take the elevator bank down, and 

25 hang a left and just 20 yards up the hallway, there’s 
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1 a coffee shop. If you’re going to get coffee, do it 

2 quickly. Sometimes they’re stacked up during the 

3 coffee break. 

4 We will resume at 10:45 here in this room, 

5 and this room will be supervised. You can leave your 

6 stuff. So thanks for a good start on the day, we’ll 

7 resume at 10:45. 

8 (Whereupon, at 10:30 a.m., the meeting was 

9 recessed for a 15 minute period.) 

10 MR. BROOKMAN: Okay. So we are, I think, on 

11 slide 29 now. Yes? And back to Detlef Westphalen. 

12 Rulemaking Overview

13 MR. WESTPHALEN: Thanks, Doug. So I’m going 

14 to be going over a set of slides here that talk about 

15 the rulemaking overview and framework and this general 

16 group of slides is in many of the rulemaking 

17 presentations so most of you will have seen these 

18 before and hopefully we can go through them quickly, 

19 but certainly anybody that has questions, whether in 

20 the room or on the webinar, certainly ask us. We want 

21 to make sure you understand what’s going to be 

22 happening. 

23 First of all, EPCA lays out seven factors 

24 that need to be considered when considering energy 

25 conservation standards. These are well discussed in 
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1 the statute and the DOE analyses that are conducted, 

2 sort of line up to answer questions associated with 

3 each of those factors. And I’m not going to get into 

4 the detail here. Essentially, the analyses are done to 

5 address this EPCA requirement. 

6 Generally, there are four key steps in an 

7 energy conservation standard rulemaking process. We’re 

8 here in the framework stage. The framework document 

9 was published recently. We then generally move into 

10 preliminary analysis, you know, in which we start to do 

11 some of the analyses, understand the technology, do 

12 initial estimates of life-cycle costs and national 

13 impacts. Then we present that information and have a 

14 public meeting similar to what we have here. 

15 Then having that information, we move into 

16 the Notice of Proposed Rulemaking stage where some of 

17 the analyses are adjusted based on stakeholder comment. 

18 Additional analyses are conducted that are required to 

19 feed into setting of standards. Candidate standard 

20 levels are chosen and specific levels are then proposed 

21 as the standards for the products. Then there’s 

22 another opportunity for stakeholders to comment on 

23 those proposed standard levels. And after that, based 

24 on all the information and comments collected, DOE 

25 moves to a final rule stage. 
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1 This slides shows the anticipated timelines 

2 for the parallel rulemakings, the test procedure 

3 rulemaking that would address what are the test 

4 procedures that would be put into the regulations for 

5 these products, and also the energy conservation 

6 standard. And it shows that – obviously this is a 

7 draft – but the intent would be the test procedure 

8 Notice of Proposed Rulemaking would be published prior 

9 to the energy conservation standard preliminary 

10 analysis, and likewise, that the test procedure final 

11 rule would be published prior to the energy 

12 conservation standard Notice of Proposed Rulemaking. 

13 This would potentially lead to a final rule 

14 in the middle of 2014, with compliance date in the 

15 middle of 2017 for these products. 

16 Now, recently DOE has considered the 

17 potential to accelerate some of these rulemakings in 

18 order to more quickly get to regulations, if that makes 

19 sense. Some of the options for that would be 

20 stakeholder negotiation which would then be considered 

21 in the DOE analyses that could save seven to 21 months, 

22 depending on how early in the process an agreement is 

23 reached. 

24 DOE could alternatively consider bypassing 

25 publication of preliminary analysis and move directly 
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1 to a NOPR phase and that might save six to eight 

2 months. 

3 So here we have a request for comment on 

4 whether DOE should consider acceleration of the 

5 timeline and publish a possible final rule. Which of 

6 these options might be feasible or recommended and what 

7 are the potential implications? 

8 MR. BROOKMAN: Jen. 

9 MS. CLEARY: Jen Cleary. I think we would 

10 oppose option two which would bypass the preliminary 

11 analysis. We think that’s really an important 

12 opportunity for stakeholders to give feedback early in 

13 the process and impact the rulemaking, so we would not 

14 go for that option. 

15 MR. BROOKMAN: Would you comment on option 

16 one? 

17 MS. CLEARY: I think that’s something we’re 

18 certainly open to discussing. 

19 MR. BROOKMAN: Okay. Thank you. So DOE is 

20 being quite flexible in offering some additional 

21 options here. Additional comments on these options? 

22 Joanna. 

23 MS. MAUER: Joanna Mauer. I guess all I’d 

24 say at this point is in terms of option one, at least 

25 from the efficiency advocate perspective, it’s very 
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1 helpful to us to have DOE preliminary analysis to be 

2 able to enter into negotiations. 

3 MR. BROOKMAN: Thank you. Okay. 

4 MR. WESTPHALEN: That covers the overview on 

5 framework, now we move into preliminary analysis in 

6 test procedures. 

7 Preliminary Analysis in Test Procedures

8 I’ll be presenting on some of the issues 

9 associated with test procedure. The past test 

10 procedures, the Code of Federal Regulations prescribes 

11 DOE test procedures for residential refrigeration 

12 products, but these test procedures currently do not 

13 include test procedures for testing wine chillers, 

14 such as standardized temperatures that are consistent 

15 with the use of these products. 

16 AHAM, CEC and Canada have test procedures 

17 for wine chillers, and the test procedures – these 

18 test procedures are very similar to the existing test 

19 procedures that DOE and AHAM have for refrigerators, 

20 except for different standardized compartment 

21 temperature and also a usage factor which we’ll talk 

22 about in a moment. 

23 Some refrigeration products have a 

24 correction factor associated with them that is 

25 intended to address different levels of usage 
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1 associated, for instance, with door opening. The test 

2 procedure in use, the AHAM test procedure in use in 

3 California and Canada has a 0.85 usage factor, which 

4 is applied to the measured energy use, which 

5 essentially reduces the result by about 15 percent, or 

6 exactly 15 percent. 

7 DOE requests comments on whether a 

8 correction factor is appropriate for calculating wine 

9 chillers energy use, whether .85 is the appropriate 

10 value, and whether this is the appropriate value or if 

11 another value is appropriate, whether there is any 

12 data that suggests – that supports the particular 

13 number. 

14 MR. BROOKMAN: So 15 percent commenting on? 

15 Bill. 

16 MR. BROWN: This is Bill from GE. Those 

17 correction factors do exist today for the upright 

18 freezers and for the chest freezers, the chest freezer 

19 being .7, and an upright freezer being a .85. I only 

20 conclude, take a look at the expected door openings 

21 for this product and you’d say they’re about the same 

22 as you’d expect for an upright freezer product, not a 

23 chest freezer. The AHAM test procedure was simply 

24 mimicking the California, the NRCan test procedure 

25 when we added it to the HRF-1, just use the existing 
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1 .85 correction factor. 

2 One other item that wasn’t included is that 

3 - the existing NRCan test procedure does have a 

4 provision if you have a manual light switch, you click 

5 on, click off the light, that you test it with it on, 

6 you test with it off, and you take the average. That 

7 doesn’t exist in the California test procedure. 

8 MR. BROOKMAN: Do you have – would you state 

9 a preference for those two different methods? 

10 MR. BROWN: I would say the implication is 

11 from Canada, that if you – they would say probably 

12 half the customers would turn that on and leave it on 

13 forever, and the other half would not. Many of the 

14 products that are out there today have a light that if 

15 you turn it on, it will turn itself off, and the 

16 existing test procedures say that you test that with 

17 it off. If it’s manually initiated and automatically 

18 terminated, it’s at its lowest energy consuming 

19 position. So I would, if I were going to say which - 

20 California or the NRCan - probably the NRCan is more 

21 representative, and might push manufacturers to look 

22 at a different type of system. 

23 MR. BROOKMAN: Okay. Thank you. Yes, 

24 Joanna. 

25 MS. MAUER: Joanna Mauer. I believe DOE has 
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1 been conducting some field metering on residential 

2 refrigerators. Has that included any metering of wine 

3 chillers? 

4 MR. WESTPHALEN: What I’m aware of is 

5 metering of wine chillers, but not refrigerators, and 

6 maybe Jeff can speak a little bit more to that. 

7 MR. GREENBLATT: This is Jeff Greenblatt 

8 from Lawrence Berkeley Lab. During the refrigerator9 freezer rulemaking process, we did meter some 

10 refrigerators and freezers, as well as gathering data 

11 that other entities had metered previously. There’s 

12 no current metering going on in refrigerators or 

13 freezers. We have preliminarily metered a small 

14 handful of wine chillers, focusing on thermoelectric 

15 units in order to get some preliminary estimates of 

16 energy use. 

17 MR. BROOKMAN: Michael Kido. 

18 MR. KIDO: My understanding is that those – 

19 those are informal measurements that were taken at 

20 this point, and I don’t think – 

21 MR. GREENBLATT: That’s correct. 

22 MR. KIDO: Right. 

23 MR. BROOKMAN: Informal. Okay. Thank you. 

24 Additional comments? 

25 MR. WESTPHALEN: We have a slide addressing 
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1 standby and off mode and request for comment. EPCA 

2 requires DOE to consider standby mode and off mode 

3 energy consumption when amending test procedures and 

4 DOE expects that any test procedure for wine chillers 

5 would be a variant of the existing test procedures for 

6 refrigerators. This test currently measures all the 

7 energy use, essentially when the compressor is on as 

8 well as when the compressor is off, so the feeling is 

9 that standby and off mode would already be captured in 

10 those measurements, and so DOE concludes that 

11 establishing separate provisions for standby and off 

12 mode for wine chiller testing is not necessary. But 

13 DOE requests comments on whether anything hasn’t been 

14 considered in coming to this conclusion. 

15 MR. BROOKMAN: Jen. 

16 MS. CLEARY: AHAM agrees that standby would 

17 be captured in the existing test procedures and that’s 

18 what we think DOE should adopt, so we agree. 

19 MR. BROOKMAN: Okay. Thank you. Additional 

20 comments? Okay. 

21 MR. WESTPHALEN: This is just a list of the 

22 test procedure key issues. They really have all been 

23 addressed already, you know, some of them in the scope 

24 discussion, and some of them in the discussion we just 

25 had. But DOE seeks comment regarding whether there 
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1 are any other key issues associated with the 

2 development of test procedures for wine chillers that 

3 should be considered that we haven’t yet discussed. 

4 MR. BROOKMAN: Other key issue comments? 

5 MR. WESTPHALEN: Okay. And at this point I 

6 welcome my colleague Ken Nsofor who’s going to be 

7 talking about market technology assessment and the 

8 screening and engineering analyses. 

9 Market Technology Assessment 

10 MR. NSOFOR: Thanks, Detlef. Kenneth 

11 Nsofor, Navigant Consulting. The next few slides will 

12 talk about some of the analysis DOE plans to conduct 

13 in the preliminary stage. First, there’s the market 

14 and technology assessment. The purpose of the market 

15 assessment is to understand and characterize the 

16 market of wine chillers, understand the manufacturers. 

17 In this analysis DOE plans to identify manufacturers’ 

18 wine chillers, understand the niche players and the 

19 large manufacturers of wine chillers in the industry, 

20 estimate the shipments and trends in the market, 

21 identify the federal regulations and initiatives out 

22 there today in an attempt to improve the efficiency of 

23 wine chillers, and also identify various technologies 

24 that could improve efficiency of wine chillers. 

25 Right now we open up comments to 
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1 stakeholders and everybody out here. Just give us a 

2 little feedback and help with the market analysis. 

3 Typical information we may need, like shipment, and if 

4 anybody could open up comments. 

5 MR. BROOKMAN: Bill. 

6 MR. BROWN: Does DOE or Navigant intend to 

7 visit individual manufacturers like you did in the 

8 refrigerator rulemaking in order to get this type of 

9 data, or would you expect it to be submitted and 

10 become public information? 

11 MR. NSOFOR: The answer to that question is 

12 yes. During the preliminary manufacturing impact 

13 analysis, Navigant and DOE plans to visit 

14 manufacturers and there’s a plan to have an NDA in 

15 place as well, so we can handle confidential 

16 information. 

17 MR. WESTPHALEN: This is Detlef Westphalen. 

18 I’d like to add to that oftentimes in these 

19 rulemakings there’s an information gathering exercise 

20 that one of the trade organizations might endeavor to 

21 conduct. The question would be whether AHAM and 

22 AHAM’s members would be interested in working to 

23 assemble some data that would be relevant to the 

24 rulemaking, you know, in particular, shipment data, 

25 efficiency level data of existing products, and things 
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1 like that. In some rulemakings this has worked very 

2 well, in other rulemakings the trade organization is 

3 not very receptive to that kind of an effort. But 

4 obviously, that’s one of the things we’re talking 

5 about here that potentially would be very important to 

6 make sure that DOE understands the market. 

7 MR. BROOKMAN: Jen. 

8 MS. CLEARY: We’re certainly willing to look 

9 into what data we might be able to collect. It may 

10 depend on how we currently collect data on wine 

11 chillers, like what the break downs are, things like 

12 that. So we’ll just have to evaluate our current data 

13 collection and what we might be able to do in support 

14 of this rulemaking. 

15 MR. BROOKMAN: A question came up a little 

16 earlier this morning: do you collect some data now, 

17 Jen? 

18 MS. CLEARY: Yeah, I think we do collect 

19 some. I really have to look, though, to see exactly 

20 what we collect. I think it may be fairly limited. 

21 MR. BROOKMAN: Detlef, I myself remain 

22 unclear and sometimes the timetable changes for these 

23 different rulemakings. Typically in the manufacturer 

24 interviews happen a little further downstream. You’re 

25 suggesting they could happen quickly. 
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1 MR. NSOFOR: They will happen during the 

2 preliminary phase. We do have two stages of 

3 interviews. One is conducted in the preliminary 

4 stage, like the stage after this public meeting, and 

5 after the NOPR phase as well. 

6 MR. BROOKMAN: So you’re thinking about 

7 getting to these interviews pretty quickly? 

8 MR. NSOFOR: Detlef will – 

9 MR. BROOKMAN: Detlef. 

10 MR. WESTPHALEN: Yeah, this is Detlef. Yes, 

11 as Ken said, generally interviews are conducted prior 

12 to the preliminary documents being published, and then 

13 prior to the NOPR documents being published, and some 

14 of the material covered in each of those series of 

15 interviews is different because, you know, some of the 

16 focus initially is very much on the technical side, 

17 and the manufacturer impact side of those interviews 

18 is at the preliminary stage. But DOE would certainly 

19 be very much interested in engaging the manufacturers 

20 in those kinds of discussions. Depending on all the 

21 stakeholder feedback and some of the decisions that 

22 DOE makes, you know, it’s not clear whether we will be 

23 reaching out to the manufacturers right after this 

24 meeting to try to schedule interviews, or whether that 

25 might be pushed down the road a little bit so that we 
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1 can understand exactly what scope DOE is going to be 

2 addressing. But certainly prior to finalizing the 

3 preliminary analyses we will be interested in having 

4 those initial meetings. 

5 MR. BROOKMAN: Okay. Thank you. Jen. 

6 MS. CLEARY: Can you give us an idea – I 

7 understand that the request for data in this framework 

document you may be expecting them March 14th 8 when 

9 comments are due, but if we do have data, what we 

10 would be able to give at that time would be very 

11 limited, so is there another date by which it would be 

12 helpful for you to have any other data we may have? 

13 MR. WESTPHALEN: This is Detlef. I think 

14 the best way to approach this is to have some kind of 

15 a dialogue where we work out, okay, what kind of shall 

16 we say, information forms could be generated that the 

17 manufacturers might provide information for; or 

18 whether you have information available that you’ve 

19 already collected. I don’t think this has to be 

20 within the context of the comment period. Data 

21 submissions are certainly welcome at any time. 

22 MR. BROOKMAN: So you’ll be in touch. 

23 MR. WESTPHALEN: Yes, we’ll be in touch. 

24 MR. BROOKMAN: Is the bottom line. 

25 MS. CLEARY: Thank you. 
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1 MR. BROOKMAN: Put the initiative on 

2 somebody there. 

3 MR. WESTPHALEN: Thank you. 

4 MR. BROOKMAN: Yes, thank you, Detlef. 

5 MR. GREENBLATT: And this is Jeff 

6 Greenblatt. I just also want to reiterate, we’ll be 

7 mentioning this a little bit later this afternoon with 

8 regards to other kinds of data, but in particular 

9 since shipments are mentioned here, you know, that 

10 kind of information would be useful over the next few 

11 months, since we have until the end of the year to 

12 publish a preliminary analysis. But that data needs 

13 to be in place a few months before so that we can put 

14 that into all of our calculations. 

15 MR. BROOKMAN: Okay. Great. Final comments 

16 on this? 

17 MR. NSOFOR: All right. The next slides are 

18 about product classes. DOE has identified potential 

19 product classes for this rulemaking. One is 

20 residential wine chillers with manual defrost and the 

21 second is residential wine chillers with automatic 

22 defrost. 

23 Listed below are the criteria that DOE goes 

24 by in selecting product classes. To pull examples: 

25 the type of energy used, the capacity, and other 
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1 performance-related features that might warrant a 

2 separate product class. 

3 The slide requests comments in regards to 

4 the two product classes DOE has identified so far. 

5 MR. BROOKMAN: Yes, Jen. 

6 MS. CLEARY: AHAM thinks that DOE should 

7 adopt the Canadian and Californian approach with 

8 regard to both of these items. 

9 MR. BROOKMAN: Okay. Additional comments, 

10 and particularly if there are additional thoughts on 

11 these product classes? Nothing additional. Okay. 

12 MR. NSOFOR: Now we have more comments on 

13 the next slides, pretty much, the next comments are 

14 whether wine chillers have automatic defrost for the 

15 class, and whether they have manual defrost as well. 

16 item 3-5. 

17 MR. BROOKMAN: Comments on these? Okay. 

18 MR. BROWN: This is Bill from GE. One of 

19 the questions I see: do any wine chillers utilize 

20 manual defrost? And just looking at the California 

21 Energy Commission’s database, there were five out of 

22 200 or so. 

23 MR. BROOKMAN: What is manual defrost? 

24 MR. BROWN: Manual defrost is manual, you 

25 have to actually – the customer has to actually 
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1 perform an action to remove the defrost – to remove 

2 the frost. You turn it off and you let it melt, don’t 

3 recommend scraping it off, but some people do that as 

4 well. So yes, you have to take an action to make it – 

5 and get rid of the water. Automatic basically it 

6 defrosts by itself and evaporates the water by itself. 

7 And looking at the NRCan database, there were, you 

8 know, five or so of those products that were manual 

9 defrost as well, so they do exist. It’s just not a 

10 lot, it’s in the one percent of the market. I’m just 

11 saying, from the number SKUs, I don’t know the number 

12 of the sales that go with those SKUs. 

13 MR. BROOKMAN: Is there a trend line there? 

14 Jen? 

15 MS. CLEARY: I don’t – again, am not aware. 

16 Can’t answer that question. 

17 MR. BROOKMAN: Yes, Detlef. 

18 MR. WESTPHALEN: This is Detlef Westphalen. 

19 I guess, you know, we looked at the databases, and we 

20 questioned the existence of the manual defrost 

21 products because some of those products listed in the 

22 databases aren’t for sale any more. Others are 

23 actually now advertised on their websites as having 

24 automatic defrost, so we were only able to find one 

25 product where we couldn’t definitively say it’s not 
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1 manual defrost, but we couldn’t say definitively that 

2 it is either. 

3 The request for comment also addressed the 

4 question of whether active heating is required to 

5 achieve defrost in any of these products that are 

6 termed automatic defrost, since compressor off cycle 

7 defrost is an option for automatic defrost. 

8 MR. BROOKMAN: Comments on active heating? 

9 Bill? 

10 MR. BROWN: This is Bill again. To say it’s 

11 required or not, I can’t really say, but most of the 

12 products that I’ve seen out there, it’s off cycle 

13 defrost. Especially the temperatures you’re running 

14 and the low run times that you’ve got, you’re just not 

15 going to build up – you’ve got so much off time 

16 between the compressor, that you really do not need an 

17 active heater. 

18 MR. BROOKMAN: Okay. Thank you. 

19 Technology Assessment 

20 MR. NSOFOR: During the technology 

21 assessment, DOE tries to understand how the products 

22 consume energy, and also come up with technology 

23 options that could help improve efficiency of wine 

24 chillers. Listed in the slides are the technology 

25 options going forward, that DOE plans to investigate 
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1 further. I’ll give you a little time to look it over. 

2 And a lot of these technology options came about from 

3 the refrigeration rulemaking that was published 

4 already. 

5 The next slide opens up comment about the 

6 technology options listed in the previous slide. 

7 MR. BROOKMAN: And indeed, if there are any 

8 additional technologies that may or should be 

9 investigated. Or comments on these, for that matter. 

10 Charlie. 

11 MR. HON: On your list I do not see anything 

12 about lighting. 

13 MR. NSOFOR: Okay. We don’t have that in 

14 here but we’ll definitely look into it. 

15 MR. HON: Because LED lighting is making 

16 major impacts in some other areas and would definitely 

17 make an impact on the total refrigeration 

18 requirements. 

19 MR. BROOKMAN: They’re in little units now? 

20 MR. HON: Yep. 

21 MR. BROOKMAN: Okay. Wow. 

22 MR. BROWN: This is Bill from GE again. If 

23 you adopt the NRCan definition, that’s a yes, lighting 

24 should be considered because on and off. With the 

25 current DOE test procedure, the testing is done with 
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1 no door openings. So lights wouldn’t come on, it 

2 wouldn’t matter what light you put in the product. 

3 MR. BROOKMAN: Charlie. 

4 MR. HON: Charlie Hon. But what about if 

5 there’s a switch. 

6 MR. BROWN: That’s what I’m saying, if you 

7 adopt the NRCan definition, then NRCan does say test 

8 it on and off, take the average. 

9 MR. BROOKMAN: So that’s helpful. Any 

10 additional things that should be added to this list or 

11 comments about what would not be appropriate to be 

12 included in this list? Okay. 

13 Screening Analysis 

14 MR. NSOFOR: The next thing I’ll talk about 

15 is the screening analysis. The purpose of the 

16 screening analysis is to screen out technologies that 

17 DOE does not consider in its engineering analysis. So 

18 looking at the technology options, we’ll look – we had 

19 on the previous slide. DOE goes by four different 

20 criteria in screening out technologies. One of them 

21 is technology feasibility. This pretty much means 

22 that the technology has to exist in a commercial 

23 application, and in prototype. If that technology 

24 doesn’t exist today, DOE will not consider it further. 

25 It has to be practical to manufacture, 
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1 install and service. Whatever technology DOE tries to 

2 implement to improve efficiency has to be available on 

3 a large scale at the time the standard is set. 

4 And the last two criteria are pretty simple, 

5 self-explanatory. Any technology must not impact the 

6 health or the safety of the people using it. 

7 This slide would – 

8 MR. BROOKMAN: Hold on. Please, Jon. 

9 MR. BROWN: One question is does DOE 

10 consider technologies that are patented? You know, 

11 one manufacturer can use this technology but no one 

12 else can. 

13 MR. BROOKMAN: Detlef? 

14 MR. WESTPHALEN: This is Detlef Westphalen. 

15 In answer to that comment, DOE can consider efficiency 

16 levels that are attained by such technologies if 

17 alternative technologies would be available to other 

18 manufacturers to achieve those levels. 

19 MR. NSOFOR: In other words, if that 

20 technology provides benefits to one specific 

21 manufacturer, DOE would not consider the technology 

22 further. 

23 MR. BROWN: I would just like to see that 

24 spelled out then, because I haven’t seen that in any 

25 of the DOE documents before. There have been 
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1 technologies out there that have been one manufacturer 

2 can use it and no one else can, and that is looked at 

3 as it’s available to the whole market place, and it’s 

4 not. 

5 MR. BROOKMAN: Thank you. So you see the 

6 four factors that the Department considers. 

7 Additional comments on those? Nothing additional. 

8 Okay. 

9 Engineering Analysis 

10 MR. NSOFOR: The next slide will talk about 

11 the engineering analysis. The goal of the engineering 

12 analysis is to create a cost relationship, cost13 efficiency relationship in implementing more energy –

14 efficient technologies for wine chillers. DOE plans to 

15 use a combination of different approaches, mainly a 

16 design option approach, efficiency level approach, and 

17 reverse engineering approach. 

18 And I’m not going to read every one out right 

19 now. Just ask for comment. We request feedback on 

20 other options 

21 MR. BROOKMAN: So you can see the comment box 

22 there. All set? Okay. So additional comments related 

23 to the engineering analysis methodology? Okay. 

24 MR. NSOFOR: Like I said before, one of the 

25 approaches DOE plans to use in the establishment of the 
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1 cost-efficiency relationship is reverse engineering. 

2 Listed below are the products that DOE plans to reverse 

3 engineer, tear apart to understand how the technologies 

4 help improve efficiency. And it’s a combination of the 

5 two different product classes, automatic and manual 

6 defrost. And we’d like to get feedback from 

7 stakeholders about our selection choice. That’s the 

8 next slide for comments. 

9 This slide talks about setting up a baseline 

10 going forward. DOE plans to use the Californian and 

11 Canadian baseline – standards as baseline, and if you 

12 look there, we have a formula, I believe the manual 

13 defrost is approximately - maximum energy is about 281, 

14 and the automatic defrost is about 370-something. DOE 

15 plans to use these as the baseline and understanding 

16 how implementing different technology options, how the 

17 cost and efficiency differs between the baseline and 

18 more efficient standard. 

19 MR. BROOKMAN: So go back to the preceding 

20 slide. 

21 MR. NSOFOR: Sure. 

22 MR. BROOKMAN: So if you would take a peek 

23 at what the Department is considering for its tear down 

24 analysis. Comments? Are these representative? Let’s 

25 proceed to the next. 
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1 MR. NSOFOR: The next is just the comment 

2 down at the bottom. Seeking if these and the 

3 California and Canadian as baseline is appropriate. 

4 MR. BROOKMAN: So you can see the comment box 

5 there at the bottom of the page, 5-1. Input from 

6 stakeholders and whether the equations for maximum 

7 annual energy consumption based on the California and 

8 Canadian regulations are appropriate to represent the 

9 performance at baseline of wine chillers. No comments 

10 on Canadian or California regulations and that 

11 baseline? Okay. 

12 MR. NSOFOR: The next slide is the 

13 incremental efficiency levels DOE plans to establish in 

14 this rulemaking. And for automatic defrost, DOE plans 

15 to establish efficiency levels up to 40 percent from 

16 the baseline; and for the manual defrost, about 25 

17 percent. 

18 We’d also like to get comments on these 

19 numbers. 

20 MR. BROOKMAN: Joanna. 

21 MS. MAUER: Joanna Mauer. So DOE is required 

22 to look at the maximum technologically feasible levels, 

23 and this doesn’t seem to be a product category where we 

24 necessarily assume that the most efficient products 

25 that are commercially available truly represent a max 
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1 tech level. 

2 MR. NSOFOR: That’s correct. Although we 

3 have products out there that use less energy than the 

4 maximum established standard, by the time DOE factors 

5 in other different design options, we might have a 

6 different max tech out there that could actually be 

7 lower than the best efficient unit out in the 

8 marketplace. 

9 MS. MAUER: Okay. And we’d encourage DOE 

10 definitely to look at what the real max tech is as I 

11 think they did in the residential refrigerator 

12 rulemaking, where I believe there were – the max tech 

13 levels were beyond the best products available in the 

14 market. 

15 MR. NSOFOR: I think going forward we will 

16 have – potentially might have a different max tech than 

17 the best product out there. 

18 MS. MAUER: Okay. 

19 MR. NSOFOR: This slide is talking about 

20 industry data collection. Pretty much request 

21 participation from stakeholders in collecting data. We 

22 talked about this previously, when we started. And we 

23 would like to get comments about products out there 

24 from stakeholders, and appreciate their participation, 

25 in giving us feedback as well. 
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1 MR. BROOKMAN: Comments on industry data 

2 collection? 

3 MR. NSOFOR: And this answers the question to 

4 the GE comment about proprietary designs. And like I 

5 said before, DOE evaluates all design options that are 

6 commercially available, including proprietary design, 

7 but if a design gives one manufacturer an advantage, 

8 DOE will not consider that design option. And also we 

9 maintain confidentiality with manufacturers as well. 

10 MR. BROOKMAN: See the comment boxes. 

11 There’s more there, for example, cost data, how the 

12 Department might acquire that. Nothing additional. 

13 MR. NSOFOR: This slide talks about outside 

14 regulatory change. In conducting an engineering 

15 analysis, DOE looks at all the regulations out there to 

16 understand how the combination of different regulations 

17 impact manufacturers. It could be -- a lot of 

18 regulations could create a burden for manufacturers, so 

19 DOE considers this in this analysis. And the last is 

20 just the comments out there to understand different 

21 regulations out there that DOE might want to get 

22 information from manufacturers that could potentially 

23 impact manufacturers of wine chillers. 

24 MR. BROOKMAN: Any other pending regulatory 

25 action that might impact this rulemaking? 
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1 MR. NSOFOR: And Jeff will do the next 

2 slides. 

3 MR. BROOKMAN: Next, we’re going to hear from 

4 Jeff Greenblatt. Markups, Energy Use, life-cycle 

5 costs, payback period analyses. 

6 Markups, Energy Use, Life-cycle costs, 

7 Payback period analyses 

8 MR. GREENBLATT: Thank you everyone. Can you 

9 hear me okay? So, I’m going to talk to you about the 

10 modeling after the engineering work has been done, in 

11 order to get ultimately to estimates of life-cycle 

12 cost and national impacts. The first step is to 

13 determine the markup, which is a factor that converts 

14 the cost of goods sold, which is reported from the 

15 engineering analysis to a final consumer price. 

16 There are usually two types of markups that are 

17 considered and that was considered for the 

18 refrigerator-freezer rulemaking. A baseline markup, 

19 and an incremental markup, and the factors for these 

20 can be different, and often are. 

21 The baseline markup essentially includes all 

22 of the additional costs that are incurred in going 

23 from the manufactured product to the final retail 

24 price, that is consistent with a product that meets 

25 just the minimum efficiency level. That is, without 
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1 an increase in efficiency. So this includes all of 

2 the costs of the distributor, distributors’ 

3 overheads, profits, but not including sales tax which 

4 is applied separately. 

5 By comparison, the incremental markup refers 

6 to those markups that are incurred only in 

7 association with selling a more efficient product, 

8 and so it generally tends to be much smaller. 

9 Certain costs, such as direct labor costs, rental 

10 occupancy, et cetera, do not vary with the efficiency 

11 level, so would not be included in that incremental 

12 markup, but certain costs, such as marketing of a 

13 more efficient product, would. 

14 We gather whatever public information we’re 

15 able in order to calculate the baseline and 

16 incremental markups, but obviously additional 

17 information from manufacturers or others would be 

18 helpful. So we ask for stakeholders to provide that 

19 information if it’s available. 

20 MR. BROOKMAN: I guess this is more – 

21 principally at this point a notation about future 

22 activity. 

23 MR. GREENBLATT: Yes, whether this is an 

24 appropriate approach going forward. 

25 MR. BROOKMAN: No comment here. Okay. 
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1 MR. GREENBLATT: Okay. And then the next 

2 step is determining energy use of the products in 

3 actual use. So it’s important to determine the 

4 actual energy use of these products in the 

5 residential setting in order to assess the energy 

6 savings potential of more efficient products. And 

7 this provides the basis for our estimates in the 

8 life-cycle cost analysis. 

9 So for residential refrigerators, 

10 refrigerator-freezers, and freezers, we were able – 

11 DOE was able to rely on information provided in the 

12 residential energy consumption survey, or RECS. 

13 However, RECS does not have information on wine 

14 chillers, so even knowing the distribution of these 

15 products in homes is not very well known, let alone 

16 knowing what the energy consumption of these products 

17 are. 

18 So the approach that we’re taking is to look 

19 at the limited sales data that’s available and 

20 combine that with estimates from California’s maximum 

21 energy use standards in order to estimate a range of 

22 energy use for vapor compression wine chillers. The 

23 problem with this approach are two limitations: that 

24 one, we’re only able to estimate the maximum energy 

25 use for each model as opposed to its actual use in 
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1 the field, and it’s also unknown whether the test 

2 procedure provides a reasonable estimate of the 

3 actual energy use of these products. 

4 So because of this lack of information, DOE 

5 is seeking in situ field measurements as one possible 

6 way to get more accurate information about the energy 

7 use of wine chillers and other miscellaneous products 

8 in the field. 

9 So some question boxes here. DOE seeks 

10 comment on its approach in estimating the annual 

11 energy consumption based on the combination of sales 

12 data and the existing energy conservation standards 

13 from California. We’re looking for additional data 

14 sources for establishing energy consumption and we’d 

15 also like comment on the viability of using in situ 

16 field measurements. Do you have any comments? 

17 MR. BROOKMAN: Jen. 

18 MS. CLEARY: AHAM has some serious concerns 

19 about the in situ field measurements. They’re really 

20 not going to be that accurate, we don’t think, 

21 especially – mainly because it’s hard to compare them 

22 to like a test procedure energy usage. So we’ll 

23 provide a lot more detail in our written comments, 

24 but we have some serious concerns about that 

25 approach. 
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1 MR. BROOKMAN: Okay. Thank you. 

2 MS. CLEARY: Also – actually I have a 

3 question. I don’t think you mentioned the rebound 

4 effect here, or even to talk about – better. 

5 MR. GREENBLATT: Yes, I believe we’ll mention 

6 that in a couple of slides. 

7 MS. CLEARY: Okay. So I’ll just ask the 

8 question then, it’s about that. 

9 MR. GREENBLATT: Okay. Let’s wait until I 

10 present the material. 

11 MR. BROOKMAN: Yeah. Joanna. 

12 MS. MAUER: Joanna Mauer. Could you just 

13 explain a little bit more about what you mean by 

14 using in situ field measurements, or what that would 

15 involve? 

16 MR. GREENBLATT: Sure. In situ field 

17 measurements basically means metering devices that 

18 are being used in a residential setting. So it would 

19 be attaching a meter to a number of wine chillers or 

20 other products, and taking measurements for a period 

21 of weeks or months. 

22 MR. BROOKMAN: Yes, Jon. 

23 MR. WIENER: Can you say a little bit more 

24 about why the Department thinks California’s maximum 

25 energy use standards might be valid? My concerns are 
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1 that they’re maximum, one, they’re older, two, and 

2 that they include thermoelectric products as well. 

3 MR. GREENBLATT: It’s easier all – 

4 MR. WIENER: As it’s written. I don’t know 

5 if they’re actually – it’s unclear to what extent 

6 they’re actually covering thermoelectric products. 

7 MR. GREENBLATT: Right. To DOE’s knowledge – 

8 well, DOE does not know whether it includes 

9 thermoelectric products. I think that the feeling is 

10 that it probably doesn’t, but we’re not actually 

11 sure. And DOE is – we agree with these concerns 

12 exactly, that it is – it represents a maximum, so DOE 

13 doesn’t actually know what the energy use of these 

14 products are in actual use. 

15 MR. WIENER: It would seem it would be a 

16 useful way of double-checking DOE’s own – if you 

17 reach the – pick a number, you arrive at a number and 

18 then you can check it against the maximum and make 

19 sure it’s not less stringent than what California has 

20 said. It would be useful in that way. I can’t see 

21 that it would be useful as a data point in another 

22 way, because it’s going to skew your data, 

23 presumably. 

24 MR. GREENBLATT: Then again, it may actually 

25 be accurate, but without having other complementary 
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1 information, it’s hard to say. But it’s not going to 

2 be a low estimate of energy use because it’s a 

3 maximum. 

4 MR. WIENER: I would agree with that. 

5 MR. BROOKMAN: Detlef. 

6 MR. WESTPHALEN: This is Detlef Westphalen. 

7 Regarding the discussion about the California energy 

8 standards, they don’t really distinguish 

9 technologies, so that thermoelectric products sold in 

10 California are subject to those requirements and as 

11 mentioned previously, a few such thermoelectric 

12 products have been found on the database, and I don’t 

13 know if it was NRCan’s database or California’s 

14 database. I believe Lucas was involved with that. 

15 MR. ADIN: If I remember correctly it was 

16 California. 

17 MR. WESTPHALEN: California, so one would 

18 assume that thermoelectric products that are legal to 

19 be sold in California, and are actually being sold, 

20 are subject to that maximum as well. 

21 MR. ADIN: I would hope so. 

22 MR. BROOKMAN: Yes, Jen. 

23 MS. CLEARY: Has DOE asked CEC if they cover 

24 thermoelectric products? 

25 MR. WESTPHALEN: This is Detlef. We did ask 
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1 that question and they said, yes, they’re covered. 

2 MS. CLEARY: Thank you. 

3 MR. BROWN: The only question I would have is 

4 has anyone investigated how CEC arrived at their 

5 equations that they use today? Did they go through 

6 the same diligence that DOE did, or just exactly what 

7 did they do? I know those equations have been around 

8 for a while. 

9 MR. BROOKMAN: Yes, thanks Jon. 

10 MR. WESTPHALEN: This is Detlef. In response 

11 to that, it’s very difficult to find out how 

12 California developed those standards. It’s very 

13 difficult to find any information as to even when 

14 those standards first took effect, so we have not 

15 been able to find that information, and certainly 

16 we’ll do more research to look into it. 

17 MR. BROOKMAN: So I made an error, that was 

18 Detlef, and prior to that, it was Bill. Okay. Thank 

19 you. So these are good comments. Additional 

20 comments related to these comment boxes? Okay. 

21 MR. GREENBLATT: Okay. I’ll move on then. 

22 So one possibility that DOE is considering is whether 

23 the annual energy use could be characterized with a 

24 sensitivity analysis, so basically getting around the 

25 problem of having only a single maximum energy use 
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1 number, instead it could be done with a high and low 

2 estimate of energy use, based on minimum and maximum 

3 efficiency that is seen, perhaps, in the CEC 

4 database, or other data, in order to bracket the 

5 life-cycle cost and national energy impact results to 

6 help determine economic feasibility of setting the 

7 various efficiency levels. 

8 And the comment that AHAM had mentioned, DOE 

9 seeks comment on the rebound effect associated with 

10 more efficient wine chillers. Basically, we’re 

11 questioning if a wine chiller is made to be more 

12 efficient, does the consumer actually end up using it 

13 more in terms of, on a normalized basis, more 

14 intensively than a less efficient wine chiller or 

15 would a consumer purchase a larger product, all other 

16 things being equal, and thereby use more energy with 

17 a more efficient product. 

18 MR. BROOKMAN: Jen. 

19 MS. CLEARY: And so the framework document 

20 states that DOE has determined that the rebound 

21 effect doesn’t apply to home appliances. So I was 

22 just kind of wondering why is this being addressed if 

23 it doesn’t apply? Why waste the time looking at it? 

24 MR. BROOKMAN: Lucas? 

25 MR. ADIN: Yeah, this is Lucas Adin from DOE. 
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1 I mean that’s a general presumption, but we’re 

2 certainly interested in any information suggesting 

3 that that presumption is incorrect, or that there’s 

4 some reason we should be considering that particular 

5 aspect in our analysis. So it isn’t to say that 

6 we’re going into this with a firm conviction that 

7 it’s not a factor, but at least that’s the 

8 presumption as of right now. 

9 MS. CLEARY: Thanks. 

10 MR. BROOKMAN: Okay. Jon. 

11 MR. WIENER: Jon Wiener, Earthjustice. The 

12 question about the sensitivity analysis. Does the 

13 Department have experience with using sensitivity 

14 analyses to – for these standards? My concern is how 

15 OMB might react and what they might require you to – 

16 they might pick the low estimate and just treat that 

17 as the actual estimate. Has that come up before? 

18 MR. GREENBLATT: This is Jeff. I don’t have 

19 direct experience with that, but Lucas are you 

20 familiar with other proceedings where we’ve had a 

21 sensitivity analysis? Or Michael? 

22 MR. ADIN: I’m not sure I could comment 

23 specifically on that. 

24 MR. BROOKMAN: So you can see the comment 

25 boxes up there and we’ve at least taken a shot at 
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1 both of those. Additional comments? 

2 MR. GREENBLATT: Okay. So the next item to 

3 cover is calculation of life-cycle cost and payback 

4 period analysis, standard part of the DOE procedure. 

5 So the life-cycle cost analysis consists of two main 

6 elements, estimate of the first cost, basically the 

7 consumer price paid plus any installation costs, and 

8 then the operating costs over the life of the 

9 product, which includes both the cost of supplying 

10 the energy, as well as maintenance costs. And these 

11 operating costs are discounted to a particular year 

12 in order to arrive at the total life-cycle cost. And 

13 life-cycle cost is calculated as a difference between 

14 the cost of a baseline efficiency unit and a more 

15 efficient unit, so looking at whether that total 

16 number is greater or smaller. 

17 This is done from the consumer’s perspective, 

18 and one thing to point out is this is done as a 

19 statistical analysis where a number of the variables 

20 – variable inputs vary, and are sampled using a Monte 

21 Carlo statistical approach, so essentially different 

22 households will have different features in terms of 

23 the amount of energy that the product uses, its size, 

24 the lifetime of the product and other characteristics 

25 of the household, the temperature, since this is a 
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1 product that’s driven partly by interior room 

2 temperatures. 

3 And then the payback period is a simple 

4 calculation that equals the first cost divided by the 

5 operating cost over a single year. 

6 Now that’s done for the preliminary analysis. 

7 For the later stage of analysis, there’s also a 

8 subgroup analysis that’s performed, so certain 

9 consumer groups may be especially vulnerable or have 

10 other different characteristics that set it apart 

11 from the main sort of general population, and so DOE 

12 routinely looks at potential consumer subgroups and 

13 does an analysis only on that group to see whether 

14 the life-cycle cost impacts are significantly 

15 different than might cause it to consider this 

16 information in setting the final standard levels. 

17 For instance, the different regional 

18 electricity prices is often a significant factor in 

19 making the life-cycle cost not the same from one part 

20 of the country to another. 

21 DOE requests input into any consumer 

22 subgroups that might be appropriate when considering 

23 standards for these products. 

24 MR. BROOKMAN: I think it’s an interesting 

25 question. No subgroups come to mind. 
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1 MR. GREENBLATT: I’ll just say for the record 

2 that we generally look at low income and seniors as 

3 routine subgroups, but sometimes others, depending on 

4 the particular product at hand. 

5 MR. BROOKMAN: Charlie. 

6 MR. HON: It may sound somewhat tacky, but I 

7 think you’re going to discover that when you look at 

8 your subgroups, it’s a different group of subgroups 

9 than normal standard, because this is not a required 

10 product for the market. You’re dealing with a 

11 different nature product, usually more affluence 

12 involved in it. 

13 MR. BROOKMAN: As they get more senior do 

14 they drink more wine, for example? Do they need 

15 special consideration? 

16 MR. HON: Sorry. From a – Charlie Hon – from 

17 a construction viewpoint, you have to be very cognizant 

18 of that because a lot of wine coolers are built as 

19 under-counter models, and with senior citizens, they 

20 don’t work, because they have problems getting up and 

21 down. So they’re more interested in above counter-type 

22 configurations. 

23 MR. BROOKMAN: Additional comments on 

24 subgroup analysis? 

25 MR. GREENBLATT: Okay. Thank you for that 
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1 comment. I’m not – this next chart shows all of the 

2 different elements in the flow chart of calculating the 

3 final life-cycle costs. I’m not going to go through 

4 all of these, but if anybody has comments or questions 

5 about these particular elements, if you can read it, 

6 either on your handout or on the chart, I’ll be happy 

7 to answer any questions. 

8 Now one thing in particular that we wanted to 

9 ask for comment on has to do with installation, 

10 maintenance and repair costs, and particularly whether 

11 these costs change with more efficient products. It’s 

12 DOE’s assumption that the cost of installation, if any, 

13 would probably be identical between a baseline unit and 

14 a more efficient unit, and that this would probably 

15 also be the case for repair and maintenance of 

16 products. But we don’t know for sure, so any 

17 information that stakeholders have to shed light on 

18 this would be useful. Also, just estimates, even of 

19 the baseline efficiency installation, maintenance or 

20 repair costs would be helpful for our analysis. 

21 I’ll just read this last bullet here, unless 

22 the efficiency increase is considered result in 

23 significantly larger or heavier products, DOE expects 

24 that more efficient products will not incur increased 

25 installation costs. 
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1 So there’s several comments here. I won’t 

2 read them all, but basically I summarized these 

3 requests for comments on the previous slide – 

4 MR. BROOKMAN: And also maintenance, correct? 

5 MR. GREENBLATT: Yes – installation, repair 

6 and maintenance costs. 

7 MR. BROOKMAN: So, Jen. 

8 MS. CLEARY: Jen Cleary. AHAM agrees that 

9 the installation costs probably won’t vary depending on 

10 the efficiency of the product. 

11 MR. BROOKMAN: In some previous rulemakings I 

12 seem to recall that some commenters suggested that more 

13 efficient products with a different configuration that 

14 led to higher efficiency may need more maintenance or 

15 repair. Jen? 

16 MS. CLEARY: We don’t have comments on that 

17 at this time. Just installation. 

18 MR. BROOKMAN: Okay. Just thought I’d try 

19 it. So no additional comments on this? 

20 MR. GREENBLATT: Oh, actually I think there 

21 is one here. 

22 MR. BROOKMAN: Yes, Charlie. 

23 MR. HON: There’s going to be some 

24 correlation there. A lot of your high efficiency fans 

25 are more prone – have a shorter life cycle. There will 
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1 also be, I think you will find a difference in life2 cycle costs because there’s a definite difference in 

3 these products. They’re what I would consider a throw4 away product after five years. If you’re paying $3-500 

5 dollars for a unit, you don’t get it fixed. If you’re 

6 paying $2500 for a unit, you get it fixed. So you have 

7 a definite discussion between repair cost and 

8 additional purchase price. 

9 MR. BROOKMAN: Okay. Thank you. What’s the 

10 life span between those low-end products and high-end 

11 products? 

12 MR. HON: Charlie Hon again. That’s highly 

13 debatable because there’s a lot of very reliable low 

14 end products that don’t have all the features. They 

15 just do a very good job at keeping it near target 

16 temperature, but they don’t have all the bells and 

17 whistles added on, and the more bells and whistles you 

18 put on, the more problematic you become. 

19 MR. BROOKMAN: Thank you. 

20 MR. GREENBLATT: I will – actually there are 

21 a couple of these items that did not pertain to 

22 installation and maintenance, so I just wanted to read 

23 them, but before I do, I also want to ask the question, 

24 in another slide or two we’re going to ask about 

25 estimates of the lifetime of these products, so we 
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1 would be open to any information that stakeholders 

2 have, but also the question occurs to me, is it 

3 possible that the lifetime might actually change with 

4 the efficiency of the product? 

5 The questions I wanted to read, just to make 

6 sure that people see it. DOE seeks comments on the 

7 general approach of using probability distribution and 

8 Monte Carlo simulation to conduct the life-cycle cost 

9 and payback period analyses. Also requesting data from 

10 stakeholders to characterize the current mix of wine 

11 chiller efficiencies and the approach for estimating 

12 current and forecasted energy prices, which I’ll state 

13 for the record generally uses forecasts from EIA. 

14 MR. BROOKMAN: Okay. 

15 MR. GREENBLATT: Okay. I’ll move on. Oh, 

16 here’s the lifetime question. Right. So DOE currently 

17 does not have good estimates, or really any estimates 

18 of the lifetime of wine chillers and related 

19 miscellaneous refrigeration equipment. What DOE does 

20 have are well constrained estimates of the lifetime of 

21 refrigerator – standard-size refrigerator-freezers and 

22 freezers, which are approximately 17 and 22 years on 

23 average, respectively. For compact refrigerators and 

24 freezers, DOE has developed certainly less precise 

25 estimates which give mean lifetimes of about five and a 
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1 half and seven and a half years. We would welcome any 

2 information to help us estimate the lifetime of these 

3 other products. 

4 Shipments Analysis 

5 Okay. I’m moving on to shipments analysis 

6 then. After the life-cycle cost analysis is complete, 

7 DOE then makes estimates of the current and future 

8 shipments of products in order to estimate national 

9 impacts of potential efficiency standards. Currently 

10 DOE is aware of two data sources, AHAM and NPD Group, 

11 which provides some shipments data, current shipments 

12 data. Projections based on fits of these data can be 

13 developed and in particular, the estimate of standards 

14 on future shipments will be calculated, essentially 

15 that if there’s an increase in the price of the 

16 product, we have an elasticity that allows us to 

17 estimate the decreased sales of that product as a 

18 result. This is based on some broad analyses of home 

19 appliances generally, not specifically wine chillers. 

20 DOE seeks comments or seeks information about 

21 historical shipments as well as projected future 

22 shipments from stakeholders, and in particular if 

23 information which we’ve asked for already, but I’ll 

24 just repeat since it’s here, what the breakdown is 

25 based on the type of cooling technology, vapor 
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1 compression versus thermoelectric or absorption, and if 

2 DOE is unable to get additional sources of data other 

3 than AHAM and NPD Group, it would seek comment on which 

4 data source is more representative. This is not listed 

5 here on this slide, but it is in the framework 

6 document. There are large disparities in volume 

7 between the AHAM and NPD Group, with the NPD Group 

8 showing significantly higher sales. However, even 

9 there there are some uncertainties because NPD Group 

10 does not represent all sales in the U.S., but only a 

11 portion, and that market share that’s captured is a 

12 little bit – it’s not very precisely known. I think 

13 it’s between about 30 and 50 percent of the market. 

14 MR. BROOKMAN: What is the NPD Group? 

15 MR. GREENBLATT: NPD Group is a private 

16 market research firm that essentially collects sales 

17 data from end use retailers and compiles it and then 

18 sells it to interested parties such as DOE. 

19 MR. BROOKMAN: So comments related to 

20 historical shipments and any other data? Nothing at 

21 this time. 

22 MR. GREENBLATT: Some other questions here. 

23 DOE seeks input on the type of potential scenarios it 

24 should use to forecast base case shipments. I had 

25 hinted about it in the previous slide. Should we 
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1 assume essentially a straight line fit to historical 

2 shipments or something else? We’d also seek, as part 

3 of its preliminary manufacturer impact analysis, the 

4 impact of new standards on wine chiller shipments. 

5 This is related to the elasticity effect that I had 

6 mentioned previously, as well as any other market pull 

7 programs that currently exist to promote the adoption 

8 of more efficient wine chillers. 

9 Okay. No other comments, I’ll move on. 

10 MR. BROOKMAN: Let’s wait. I’m hoping to get 

11 a comment on this one. There ought to be, right? What 

12 would you expect – is this going to be a historical 

13 straight line? Is it going to correlate with housing 

14 starts? With rehab activity? Come on, we can get – 

15 MR. GREENBLATT: With sales of wine? 

16 MR. BROOKMAN: Charlie. 

17 MR. HON: We’ve seen in our sales that the 

18 rehab activity has a major impact into it, as people 

19 redesign kitchens, they want new features in them, more 

20 under-counter appliances, compacters - trash 

21 compacters, drawered refrigeration units, wine 

22 cabinets, a lot of different things going in under 

23 counter, enlarging the kitchen space altogether. New 

24 housing starts, houses that put all these features in 

25 are traditionally somewhat not economically the same 
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1 parallel as the rest of the market, so – 

2 MR. BROOKMAN: So if you can segment the 

3 housing starts to a high end – 

4 MR. HON: High end products would be 

5 important, but there are a lot of – there’s a secondary 

6 – there’s two different sectors of the market. You 

7 have a lot of commodity product bought at the big box 

8 stores, which is a self-contained, put it in the back 

9 of your SUV and drive it home, or a less expensive 

10 product that would not be related to that at all. So 

11 there’s going to be – I think it’s certainly not 

12 linear. It’s certainly going to be increasing in the 

13 near future. 

14 MR. BROOKMAN: Okay. Thank you. You want to 

15 – Lucas Adin. 

16 MR. ADIN: I’m just going to read a comment 

17 that we had sent in from the California Energy 

18 Commission. This regards thermowine chillers, so this 

19 is actually going back a little bit, but this is 

20 actually pretty important to mention. They say that 

21 “The topic of thermoelectric wine chillers is an 

22 interesting one. Some manufacturers of these units 

23 have claimed they cannot reach 55 degree temperature 

24 necessary to perform the California efficiency test for 

25 wine chillers. Operating at a higher, 58 to 60 degree 
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1 temperature, energy use have yet to evaluate these 

2 claims but we are not sure whether to amend our 

3 regulations to accept a product that does not actually 

4 reach a suitable temperature for storing wine.” 

5 And we discussed this a little bit. I mean, one 

6 thing to consider, the energy test is performed at a 90 

7 degree ambient, so I mean, theoretically that could 

8 affect any product’s ability to get down to – to get 

9 down to that test temperature, that standardized test 

10 temperature, depending on how good the insulation is, 

11 so it could be a matter of considering another type of 

12 test as well. 

13 MR. BROOKMAN: Okay. Thank you. You 

14 can see the comment boxes up there. I appreciate the 

15 comment that we did receive. Any additional thoughts, 

16 and also it mentions market pull programs, whether they 

17 exist presently. Nothing additional. Okay. 

18 MR. GREENBLATT: Well, I was going to 

19 cover the national impact analysis, well all of this, 

20 actually, after lunch, but it’s up to you, Doug. 

21 MR. BROOKMAN: Let me see. How much – 

22 it doesn’t seem like we have a lot left, does it? 

23 MR. GREENBLATT: No. 

24 MR. BROOKMAN: So I’d suggest we just 

25 press on and finish. Yes? Yes. Okay. That’s what 
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1 we’re going to do. 

2 National Impact Analysis 

3 MR. GREENBLATT: Okay. So the purpose of the 

4 national impact analysis is to estimate the national 

5 energy savings and national net present value of 

6 consumer savings for higher efficiency level standards. 

7 DOE intends to take into account the rebound effect 

8 associated with more efficient wine chillers, if there 

9 was a reduction in shipments from a more efficient but 

10 more expensive unit that I had mentioned a few minutes 

11 ago. I also forgot to mention that – it was on the 

12 slide – that the LCC as well as this national impact 

13 analysis are all done on Excel spreadsheets so that 

14 stakeholders have full access to the data analysis if 

15 they want to run their own scenarios or otherwise look 

16 into the details of the calculations. 

17 So, mentioned a few times this question of 

18 the efficiency distribution of wine chiller and related 

19 products. What’s especially useful for the national 

20 impact analysis is not so much the breakdown at each 

21 efficiency level, but just the shipment weighted 

22 average efficiency which is what is needed in order to 

23 calculate the national impacts going forward. 

24 Historically, we’ve been able to – or DOE has been able 

25 to get these shipment weighted average efficiencies 
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1 from manufacturers, such as AHAM. We hope that we will 

2 be able to get similar information for wine chillers, 

3 but it’s not apparent that this information is readily 

4 available. 

5 And also the national net present value 

6 calculations are always calculated per OMB guidance at 

7 three and seven percent discount rates, which is 

8 different from the discount rate used in the LCC 

9 analysis, where it’s – it depends on each particular 

10 household. It’s part of the Monte Carlo analysis and 

11 is an average of just over five percent. 

12 So DOE seeks the historical shipment weighted 

13 average efficiency data for wine chillers as well as 

14 market shares, showing the percentage shipped at each 

15 efficiency level. And DOE seeks comments on its plan 

16 to use the established approach of Excel spreadsheets 

17 for modeling national impact and national energy 

18 savings. 

19 MR. BROOKMAN: So the second question should 

20 be no surprise to anyone, that’s established method. 

21 What about historical shipment data? Do we have that 

22 now? Jen. 

23 MS. CLEARY: We’ll check into it. 

24 MR. BROOKMAN: Okay, thank you. 

25 MR. GREENBLATT: Okay. Ken, I think you have 
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1 a few minutes of slides here. 

2 MR. BROOKMAN: Next we’ll hear from Ken 

3 Nsofor. 

4 Manufacturer Impact Analysis 

5 MR. NSOFOR: All right, the next slide, I’ll 

6 talk about the manufacturer impact analysis. The goal 

7 for the MIA is to understand the impact of standards to 

8 manufacturers. During this phase of the analysis, DOE 

9 plans to conduct interviews with manufacturers to 

10 understand how the standards will affect direct 

11 employment, capital assets, and also industry 

12 competitiveness. DOE also plans to understand industry 

13 cash flow using the GRIM, the GRIM stands for the 

14 Government Regulatory Impact Model, and based on the 

15 analysis DOE conducts in this phase, going forward, we 

16 will revisit with manufacturers and conduct the follow17 up interview at the NOPR stage. 

18 As we discussed in the market and technology 

19 assessment, DOE plans to segment out -- understand the 

20 manufacturers subgroup, small manufacturers, the niche 

21 players, and large manufacturers each exhibit a 

22 different cost structure that differs within the 

23 industry. And DOE will try to understand how 

24 implementation of new standards affects each 

25 manufacturer. 
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1 Right now we’ll open up for comment and 

2 request comments from and feedback from stakeholders, 

3 in other words, to try to understand the different 

4 subgroups of manufacturers of the wine chill industry. 

5 MR. BROOKMAN: So are there subgroups that 

6 you would call out at this time? Nothing at this time. 

7 MR. NSOFOR: Again, as we discussed in the 

8 market and technology assessment, DOE tries to 

9 understand different regulations out there that might 

10 become a burden to manufacturers as we go ahead and 

11 implement standards for chillers. Typical regulations 

12 that could affect this rulemaking are regulations for 

13 refrigeration standards, the phase out of HCFC blowing 

14 agents that happened in 2003. Regulations limiting 

15 emissions of greenhouse gases, and also reduction of 

16 hazardous substances. And right now we ask 

17 stakeholders if there are other regulations out there 

18 that could potentially impact manufacturers. 

19 MR. BROOKMAN: No additional regulatory 

20 burdens that come to mind at this time? 

21 MR. NSOFOR: Okay. Jeff, you want to talk 

22 about this. 

23 MR. GREENBLATT: Yeah, it’s like a slide 

24 left. 

25 MR. NSOFOR: It goes back to Jeff. 
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1 Plans for NOPR Phase 

2 MR. GREENBLATT: All right. I don’t have to 

3 rush this, but I don’t think there’s much to say here. 

4 This is Jeff again. So the last part of the 

5 presentation concerns the plans for the NOPR phase of 

6 the analysis. So after the publication of the 

7 preliminary analysis, DOE receives stakeholder comments 

8 and then goes back to revise its analysis and then in 

9 addition, perform some extra analysis steps which are 

10 outlined here. So those extra steps are the life-cycle 

11 cost subgroup analysis that I mentioned earlier, the 

12 full manufacturer impact analysis, and then some other 

13 analyses related to, which are called the downstream 

14 analyses related to the national impact. So DOE 

15 calculates the impact on the utility sector in terms of 

16 changes in power plant operations and construction, as 

17 well as the impact on employment throughout the 

18 country, impacts on air quality and other environmental 

19 concerns, but primarily it’s air quality – CO2, NOX, 

20 SOX, and so on as a result of reduced energy use. And 

21 finally, the regulatory impact analysis, which is an 

22 analysis of alternatives to standards and what the 

23 difference in energy savings would be in those cases. 

24 Now this is standard procedure for all 

25 rulemakings, but as always DOE seeks input on its plans 
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1 to follow this approach, and in particular the 

2 continued use of the NEMS model to come up with utility 

3 impacts and other impacts. That’s one of the comment 

4 boxes here, and on DOE’s plans to assess national 

5 employment impacts, both direct and indirect, if there 

6 are other tools that might be at its disposal to do a 

7 better job of this. DOE has been using the same jobs 

8 model for a number of years, and also comments on DOE’s 

9 continued use of the NEMS model for environmental 

10 impact assessment of its products. 

11 MR. BROOKMAN: So many of you are familiar 

12 with these methodologies. Comments, anything about 

13 wine coolers and related products that would cause the 

14 Department to do something different? I don’t see 

15 anything there. 

16 

17 Closing Remarks 

18 MR. GREENBLATT: I think from Lucas? 

19 MR. BROOKMAN: As we promised at the outset, 

20 an opportunity for anybody that wishes to raise 

21 additional issues, something you don’t think has been 

22 covered sufficiently at this stage, so let’s do that 

23 now. I guess there’s nothing additional. Then, from 

24 my part, I would just thank all of you. I thought we 

25 had a very productive conversation, very efficient this 
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1 morning. And turn it back to Lucas Adin for closing 

2 remarks. 

3 MR. ADIN: Just a few additional 

4 administrative things to cover here. The comment 

5 period at this particular stage of the rulemaking is 

6 open until March 14, 2012, so if you have additional 

7 written commentary you’d like to provide, please 

8 provide it by that date. There is an email address on 

9 this slide, which is where you can send it, or you can 

10 mail it in. There’s an address there as well. For 

11 that purpose, please reference the rulemaking by the 

12 docket number that’s listed there, and/or the 

13 regulatory identification or RIN number. 

14 And that’s about it as far as administrative 

15 things. I’d also like to extend DOE’s thanks for your 

16 participation today. It’s very important to the 

17 rulemaking process and we really appreciate any 

18 information you’re able to provide and any additional 

19 comments. 

20 MR. BROOKMAN: We should also acknowledge and 

21 thank those that have joined us via the web. 

22 MR. ADIN: Yes. 

23 MR. BROOKMAN: Something the Department 

24 wishes to make available to anybody and so glad you 

25 could join us. 
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1 MR. ADIN: Yeah, I hope that’s been useful. 

2 If you have comments about how well that particular 

3 functionality is working, or any suggested 

4 improvements, we certainly welcome those too. 

5 MR. BROOKMAN: Safe travels everyone. 

6 (Whereupon, at 12:10 p.m., the meeting in the 

7 above captioned matter was adjourned.) 

8 

9 

10 

11 

12 

13 

14 

15 

 REPORTER'S CERTIFICATE

 This is to certify that the attached proceedings 

before: 

U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS 

FOR WINE CHILLERS AND MISCELLANEOUS REFRIGERATION 

PRODUCTS 

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 
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Department, Commission, Board, Administrative Law Judge 

or the Agency. 

 Further, I am neither counsel for or related to any 

party to the above proceedings. 

 

Debra Derr 

 Official Reporter 

Dated: February 27, 2012