1 U.S. Department of Energy 

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6 Test Procedure Proposed Rule for 

7 Miscellaneous Refrigeration Products Meeting 

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10:04 a.m. to 2:36 p.m. 

Thursday, January 8, 2015 

1000 Independence Avenue, S.W. 

Room 8E-089 

Washington, D.C. 20585 

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1 
1 APPEARANCES 

2 

3 DOUG BROOKMAN, Public Solutions, Inc. 

4 JOSEPH HAGERMAN, DOE 

s PETER COCHRAN, DOE 

6 ERIC STAS, DOE 

7 MICHAEL KIDO, DOE 

8 ABIGAIL CHINGOS, Office of Enforcement, DOE 

9 TROY WATSON, Navigant 

10 DETLEF WESTPHALEN, Navigant 

11 JUDITH REICH, Navigant 

12 SRIRAM GOPAL, AHAM 

13 STEPHEN B. LEYBOURN, AHAM 

14 JOSEPH C. FONTECCHIO, True Manufacturing 

1s CHARLES HON, True Manufacturing 

16 SCOTT YOUNG, Lawrence Berkley National Laboratory 

17 NATE MOUW, Whirlpool 

18 ESTER SZTEIN, The National Academies 

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2 
1 WEBINAR ATTENDEES: 

2 

3 PRITHVI ACHARYA, Navigant 

4 LAURA BARHYDT, DOE 

s BILL BROWN, GE Appliances 

6 BRIAN BUYNACEK, Emerson 

7 MICHELE CROCIANI, Indel B 

8 MARK DRAKE, Electrolux Major Appliances 

9 PAUL GRIFFIN, Panasonic 

10 DAVID HALL, Electrolux Major Appliances 

11 KELLEY KLINE, GE Appliances 

12 SAMUEL LEVINSON, ICF International 

13 CHRISTOPHER LIBBEY, Austin, TX 

14 JOANNA MAUER I ASAP 

1s EVA MILAKOWSKI, Ministry of Energy 

16 RENATA MORTAZAVI, NRCan 

17 JOHN MYERS, Manitowoc Foodservice 

18 RAQUEL NETO, Navigant 

19 JOSEPH PACELLA, Consumer Reports 

20 TRAVIS PERKINS, Whirlpool 

21 MORIAM RAJI I UL 

22 PHILLIP STEPHENS, Pacific Northwest National 

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3 
1 Laboratory 

2 WEBINAR ATTENDEES: (Cont'd) 

3 ANDREW SULLIVAN, The Vetta Group 

4 WILLIAM VIETH, Navigant 

s MAX WILBAND, LG Electronics 

6 ROLAND MARCINIAK, U-Line 

7 LINDA WILSON, New York, NY 

8 LOU HRKTMAN, Energy & Commerce 

9 ROBERT McARVER, AHAM 

10 JOHNNY MILLER, Viking Range, LLC 

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4 
1 P R 0 C E E D I N G s 

2 MR. BROOKMAN: Let's begin. Please take 

3 your seats. 

4 Good morning, everyone. Welcome. And 

5 happy new year. This is the Test Procedures for 

6 Miscellaneous Consumer Refrigeration Products 

7 Notice of Proposed Rulemaking Meeting. Today is 

s January 8th, 2015, here in the Forrestal Building 

9 in Washington, D.C. 

10 My name is Doug Brookman, Public 

11 Solutions, from Baltimore. Nice to see you all 

12 this morning. We're going to start with 

13 welcoming remarks from Joe Hagerman. 

14 MR. HAGERMAN: So, I'm Joe Hagerman with 

1s Department of Energy. I just want to say welcome 

16 to DOE on one of the coldest days. We'll try to 

17 keep this room warm for everybody. Thank you for 

1s coming out, of course. This is a really 

19 important activity area for us. We really 

20 appreciate hearing your thoughts and your 

21 comments about this new test procedure, and then 

22 tomorrow about the standards. 

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6 

1 So, let's have a really good, 

2 constructive discussion, and we really appreciate 

3 your comments, and we want to hear from you. And 

4 if you're on the Webinar, we hope that you'll 

s send comments or somehow we can have access to 

6 what you're thinking. 

7 So, thank you. 

8 MR. BROOKMAN: Thank you, Joe. 

9 We always start with introductions. I'll 

10 start to my immediate left. You can get used to 

11 turning these microphones on and off. Please say 

12 your name and organizational affiliation. 

13 MR. FONTECCHIO: Good morning. Joseph 

14 Fontecchio with True Manufacturing. 

15 MR. HON: Charlie Hon, True 

16 Manufacturing. 

17 MR. MOUW: Nathan Mouw, Whirlpool 

18 Corporation. 

19 MR. LEYBOURN: Steve Leybourn, with AHAM. 

20 MR. GOPAL: Sriram Gopal, with AHAM. 

21 MR. YOUNG: Scott Young, Lawrence Berkley 

22 National Laboratory. 

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1 MS. REICH: Judith Reich, from Navigant 

2 Consulting. 

3 MR. WATSON: Troy Watson, from Navigant 

4 Consulting. 

5 MR. WESTPHALEN: Detlef Westphalen, 

6 Navigant Consulting. 

7 MR. COCHRAN: Pete Cochran, DOE. 

8 MR. STAS: Eric Stas, DOE, filling in 

9 temporarily for Michael Kido, who is a victim of 

10 the metro. 

11 MR. BROOKMAN: Joe has introduced 

12 himself. 

13 Would you introduce yourself, please? 

14 MS. CHINGOS: Oh, yes. Abigail Chingos 

1s from the Office of Enforcement, DOE. 

16 MR. BROOKMAN: Thank you. Okay. 

17 Well, all of you have received a packet 

1s of information, I hope -- did everyone get one? 

19 which is the PowerPoint slides that we will be 

20 referring to as we go through this material 

21 today. 

22 If you look at page 3, you can see our 

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8 

1 agenda. Immediately following this overview, 

2 there's an opportunity for stakeholders to make 

3 opening remarks, brief summary statements, here 

4 at the outset about issues that matter to you. 

s Following that, we'll plow right into the 

6 content in this packet, Regulatory History; 

7 following that, Products Covered by the Proposal; 

8 and following that, Test Procedure Amendments. 

9 We'll take a break round about lunchtime 

10 or so, 12:00-12:30. And then when we return from 

11 the break, you can see it's listed Compliance 

12 with Other EPCA Requirements. At the end of the 

13 day, yet another opportunity for anyone that 

14 wants to make closing remarks, raise any 

1s additional issues that haven't been covered 

16 sufficiently at this point. 

11 If you refer back to slide number 2, we'd 

18 ask individuals, please, if you would, speak one 

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

20 each time you speak. There will be a complete 

21 transcript of this meeting. Be concise; share 

22 the airtime. 

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1 If you can keep the focus here. If your 

2 cell phones are not on silent mode, please turn 

3 them on silent mode and limit sidebar 

4 conversations. Everybody has already gotten used 

s to turning these microphones on and off. 

6 The Webinar participants, we welcome you. 

7 The Department of Energy is trying hard to make 

8 these meetings totally accessible to all via the 

9 Web. If you would keep your phones on mute and 

10 raise your hand in the software provided to be 

11 recognized to speak. Typically, that's been 

12 working recently, that we can hear you here in 

13 the room. So, we welcome your participation in 

14 this meeting today. 

15 One other reminder, that the Department 

16 encourages everyone, and particularly those that 

11 are joining the meeting via the Web, to submit 

18 written comments after the public meeting. 

19 That's how the Department keeps track of all the 

20 information that comes out during the course of 

21 the meeting today. 

22 So, I'm looking over to the Purpose of 

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10 

1 the Public Meeting, to Joe Hagerman. 

2 MR. HAGERMAN: Sure. This is Joe 

3 Hagerman, DOE. 

4 This is pretty straightforward. So the 

s purpose of the public meeting today is to 

6 present, review, discuss DOE's proposed test 

7 procedures for miscellaneous refrigeration, which 

s includes cooled cabinets, non-compressor 

g refrigerators, hybrid refrigeration products, 

10 which we need to go through, and ice makers. 

11 We, of course, invite comments on the 

12 notice of proposed rule document, and today we're 

13 also going to discuss the next steps in the 

14 rulemaking. And I'll go through the history of 

1s the rule here in a second. 

16 We, of course, invite participants to 

17 write summary comments here today, and then also 

1s as they come up in the course of the regulation. 

19 So, next slide? Here. I'm sorry. We're 

20 not --

21 (Slide.) 

22 MR. HAGERMAN: We haven't been advancing. 

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1 (Pause.) 

2 MR. HAGERMAN: So, the steps in the test 

3 procedure rulemaking, we published the NOPR in 

4 the Federal Register on December 16th, 2014. 

s We're having this public meeting today, on 

6 January 8th. We're interested in receiving 

7 comments from the NOPR from interested parties. 

s DOE is going to review those and consider all 

g comments. And then we're looking for a final 

10 rule of publication sometime in the fall of 2015. 

11 The comment period does close on March 

12 2nd, 2015, so note that date. 

13 Any questions about that history report? 

M (No audible response.) 

15 MR. HAGERMAN: All right. So now is an 

16 opportunity for the stakeholders to go around and 

11 make opening statements if they feel inclined. 

18 MR. BROOKMAN: Comments here at the 

~ outset? 

20 (No audible response.) 

21 MR. BROOKMAN: Nothing at this time? 

22 Nothing at this time. 

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1 MR. HAGERMAN: Let me stand up and see if 

2 anybody from the Webinar. 

3 MR. BROOKMAN: Okay. So then let's 

4 proceed 

5 MR. HAGERMAN: It's going to be a short 

6 meeting, right? 

7 MR. BROOKMAN: Yeah. 

8 (Laughter.) 

9 MR. BROOKMAN: Proceed with the content. 

10 I would call your attention in slide 10 to the 

11 issue box that is there. This illustrates how 

12 the Department calls out an issue for comment and 

13 hopes to receive copious comment based on what's 

14 listed there. 

15 So, then let's proceed with Regulatory 

16 History and scope. 

17 MR. HAGERMAN: And we'll do -- for 

1s everybody that's playing along at home, we'll do 

19 better advancing these slides through the course. 

20 And then we'll, of course, publish this 

21 PowerPoint after the meeting. It's not already 

22 on the docket, so. 

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1 All right. So I'm going to cover the 

2 Regulatory History. So the first slide is kind 

3 of the pre-February 10th, 2011, slide. The 

4 products addressed in this rulemaking weren't 

s currently covered by DOE regulations. 

6 The EPCA Act established coverage for 

7 refrigerators, refrigerator-freezers, and 

s freezers that have these following 

g characteristics: They can be operated with AC 

10 electricity, are not designed to be used without 

11 doors, and include a compressor and condenser 

12 that's integral to the unit. 

13 November 19th, 2011, DOE modified its 

14 definition of "electric refrigerators" to clarify 

1s that refrigerator coverage excludes products that 

16 do not maintain compartment temperatures suitable 

11 for food storage. 

1s So, the next slide brings us more up to 

19 date. On February 10th, 2011, DOE issued 

20 guidance regarding treatment of refrigeration 

21 products that combine fresh food and freezer 

22 compartments with higher-temperature compartments 

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1 not suitable for food storage. We stated that 

2 any size of wine storage added to what would 

3 otherwise be an electric refrigerator or 

4 refrigerator-freezer does not remove that product 

s from the coverage. 

6 However, if a wine storage compartment is 

7 greater than 50 percent of an otherwise freezer, 

s that product is not covered under the freezer 

g definition. And obviously, we'll get into this 

10 in greater detail as we go through the product 

11 class. 

12 DOE published a coverage proposal for 

13 non-compressor refrigeration November 8th, 2011. 

14 And then DOE published the coverage proposal for 

1s the broader range of miscellaneous refrigeration 

16 on October 31st, 2013, which brings us here 

11 today. 

1s The products addressed included wine 

19 chillers using various refrigeration 

20 technologies, thermoelectric and absorption 

21 refrigeration technologies, and then hybrid 

22 refrigeration products, which we'll talk in 

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1 detail today, and ice makers. And these products 

2 would be evaluated under 42 U.S.C. 6292, and 

3 rather than expand the regulatory definition of 

4 refrigerators to include some of these products. 

5 So we'll talk about that in more detail today. 

6 So that takes us to -- any questions 

7 about that, the history of things? 

s (No audible response.) 

9 MR. HAGERMAN: So I'm going to hand it 

10 over to Navigant now. You could probably -- you 

11 can sit at your seat, or you can go up there. 

12 It's up to you. It's such a small --

13 MR. WATSON: I'll go up front. It will 

M be easier then. 

15 MR. HAGERMAN: Okay. 

16 MR. WATSON: Okay. Thanks, Joe. 

17 I'm Troy Watson, from Navigant. And I'll 

18 be taking us through some of the proposals that 

19 are included in the NOPR. 

20 So, as Joe just described in the 

21 Regulatory History, DOE has addressed certain 

22 products that are not currently covered in 

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1 guidance documents and coverage proposals. And 

2 these projects are the subjects of the NOPR we're 

3 discussing today. 

4 So, you could see here, the NOPR covers 

s cooled cabinets, and these are products, such as 

6 wine chillers, that are intended to store -- to 

7 maintain compartment temperatures at higher 

8 temperatures that typical refrigerators. 

9 The second set of products are those that 

10 do not use vapor-compression technology. 

11 The third set are hybrid products. And 

12 these products just combine a warmer storage 

13 compartment, so that's a compartment that would 

14 meet the same temperatures as a cooled cabinet, 

1s but that would be combined with a typical 

16 refrigerator-freezer compartment. And DOE is 

11 proposing to call those "hybrids." 

18 And the fourth group of products here are 

19 ice makers. 

20 And this presentation kind of Jumps right 

21 into a lot of the details. So, I thought I'd 

22 give an overview here of where the proposals 

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1 would be put into effect in the Code of Federal 

2 Regulations based on this proposal. So, there 

3 are two main things DOE is proposing here. And 

4 those are definitions for these products, and 

s then test procedures for these products. 

6 So, first, DOE's proposing definitions 

7 for all these product types. Those would be 

s included in the CFR at 10 CFR 430.2, where there 

g is all the definitions for consumer products. 

10 In addition to new definitions for these 

11 products, DOE is proposing to amend the existing 

12 definitions for refrigerators, refrigerator13 freezers, and freezers. And DOE is proposing to 

14 do that to better clarify the distinction with 

1s these new, proposed product definitions. 

16 So, that should cover all the product 

11 definitions. 

1s For test procedures, testing a lot of 

19 these products is pretty similar to the existing 

20 test procedures for refrigerators or freezers. 

21 So, for certain products, DOE is proposing these 

22 test procedures in the current Appendix A for 

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1 refrigerators, and that would be for cooled 

2 cabinets, the vapor-compression refrigerators, 

3 and all of the hybrid products except for hybrid 

4 freezers. 

s Hybrid freezers would be addressed in 

6 Appendix B, the current test procedure for 

7 freezers. And then ice makers, those are pretty 

8 unique, so DOE is proposing to establish a new 

9 appendix for those. So they would get their own 

10 separate test procedure. 

11 So, hopefully, that kind of frames where 

12 this discussion is going forward today. 

13 MR. HAGERMAN: Can I just ask if that's 

14 -- this is Joe Hagerman -- is that clear to 

1s everybody, what he's presenting? 

16 (No audible response.) 

17 MR. HAGERMAN: Okay. Good. 

18 MR. WATSON: It might not be entirely 

19 clear at this point, but hopefully, as we go on 

20 it will be. 

21 

22 

MR. HAGERMAN: Everybody said yes, so. 

MR. WATSON: All right. So we're good. 

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19 

1 (Laughter.) 

2 MR. WATSON: Okay. So we're going to 

3 start off going through the proposed product 

4 definitions. So, starting with "cooled 

s cabinets," DOE is proposing to define these as "a 

6 cabinet that has a source of refrigeration 

7 requiring electric energy input only and is 

s capable of maintaining compartment temperatures 

9 either (a) no lower than 39 degrees Fahrenheit; 

10 or in a range that extends no lower than 37 

11 degrees Fahrenheit, but at least as high as 60 

12 degrees Fahrenheit." 

13 And one thing to note here is that this 

14 product definition would include both vapor1s compression technologies and non-compressor 

16 technologies, so things like absorption cooling 

11 and thermoelectric cooling. 

1s And one thing to note in this product 

19 definition is you can see there's the 39-degree 

20 Fahrenheit threshold. That's the standardized 

21 compartment temperature for refrigerators. But 

22 DOE is proposing to allow a 2-degree crossover 

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1 for cooled cabinets. 

2 And that's because DOE observed during 

3 testing that some products are able to get a 

4 little bit lower than that 39-degree threshold. 

s But by including the provision that the product 

6 would also maintain temperatures at least as high 

7 as 60 degrees Fahrenheit, that shows that the 

s product is probably intended to maintain 

g compartment temperatures much higher than the 39-

10 degree threshold. 

11 One other thing to note here in this 

12 definition, and this would also be included in 

13 the other proposed definitions, is that when DOE 

M uses the phrase "capable of maintaining 

1s compartment temperatures," that means during 

16 typical room ambient of 72 degrees Fahrenheit. 

17 So, even though many of the test procedures 

18 required testing at a 90-degree ambient, for the 

19 purposes of product classification, that would be 

20 based on operation in a 72-degree ambient 

21 temperature. 

22 I think we asked for comment on this in a 

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1 couple of slides, but I'll pause now before I go 

2 to the next definition, if there's any comments 

3 on the cooled cabinet definition. 

4 MR. BROOKMAN: I think that makes sense. 

s These definitions are important. Comments here 

6 on the proposed definition? 

7 (No audible response.) 

8 MR. BROOKMAN: Nothing here? Okay. 

9 MR. WATSON: Okay. The next proposed 

10 definition is for "non-compressor products." And 

11 DOE is proposing a bunch of these, but the key 

12 point is that the term "non-compressor" means 

13 that the products did not include a compressor 

14 and a condensing unit. And specifically, DOE is 

1s proposing the terms "non-compressor 

16 refrigerator," "non-compressor all-refrigerator," 

11 and "non-compressor cooled cabinet." 

1s And one thing to note here is that DOE is 

19 not aware of any non-compressor refrigerator20 freezers or non-compressor freezers available on 

21 the market. So it's not proposing definitions 

22 for these products at this time. 

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1 And here again is the request for 

2 comment. Item 2 here is for the non-compressor 

3 definition, if there's any comments there. 

4 (No audible response.) 

5 MR. BROOKMAN: In case anybody is having 

6 second thoughts, you can also address "cooled 

1 cabinets" here as well. 

8 (Laughter.) 

9 MR. BROOKMAN: Comments, questions on 

10 these two issue boxes? 

11 (No audible response. ) 

12 MR. BROOKMAN: Okay. 

13 MR. WATSON: Okay. Cruising along. 

14 MR. HAGERMAN: Doug, let's just remind 

1s everybody that they have until March 2nd to 

16 submit those comments to us, as well. 

17 MR. BROOKMAN: Okay. Thank you, Joe. 

18 MR. WATSON: Next main definition here is 

19 for "hybrid products." DOE is proposing the 

20 terms "hybrid refrigerators, " "hybrid 

21 refrigerator-freezers," and "hybrid freezers." 

22 And as I mentioned before, these are for 

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1 the products that combine a warmer storage 

2 compartment temperature with a cooler compartment 

3 temperature, either refrigerator or freezer. 

4 And the key point here is that, for 

s hybrid refrigeration products, at least half or 

6 more of the total refrigerated volume consists of 

7 the warmer storage compartments. And DOE is 

s proposing to refer to these compartments as 

9 "cellar compartments." And we'll jump into that 

10 term a bit more later on. But the key point is 

11 that a cellar compartment has the same 

12 temperature requirements as a cooled cabinet. So 

13 you could think of a cooled cabinet as a product 

14 that consists only of cellar compartments. 

1s So, any comments on the proposed 

16 definition for "hybrid products"? 

17 (No audible response. ) 

18 MR. BROOKMAN: None at this time. 

19 MR. WATSON: And then, finally, the 

20 fourth main set of products here, these are the 

21 ice makers. DOE is proposing the definition that 

22 an "ice maker" is a consumer product other than 

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1 the currently covered products and the other 

2 product types I just went through, that 

3 automatically produces and harvests ice. 

4 And the proposed definition would also 

s exclude any type of ice maker that is certified 

6 under the ANSI-NSF 12-2012 standard. The 

7 proposed definition would also clarify that an 

s ice maker may include a means for storing and-or 

g dispensing ice. 

10 And there's another request for comment 

11 here. I think, in particular, DOE would request 

12 comment on whether the definition requires any 

13 more distinction to clarify the difference 

14 between ice makers and freezers. 

15 MR. BROOKMAN: Yes. Joseph. 

16 MR. FONTECCHIO: Joseph Fontecchio, with 

11 True Manufacturing. 

1s In this definition, NSF 12 is being 

19 referenced as a distinction for not allowing in 

20 residential usage. And NSF 12 is a safety and a 

21 sanitation standard. I'm just trying to 

22 understand how that would exclude a product from 

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25 

1 being used in the home as long as it meets the 

2 energy guidelines for this product class. 

3 MR. WATSON: So, I might have to turn to 

4 Navigant or DOE lawyers here. 

5 MR. WESTPHALEN: This is Detlef 

6 Westphalen. 

7 As we were developing the proposals, 

s there was some discussion within DOE and, you 

g know, amongst the contractors, of what 

10 characteristics would be used to distinguish 

11 between commercial ice makers and residential ice 

12 makers. 

13 And this is the proposal that was put 

14 forth and the proposal that we're putting on the 

15 table as the distinction, that if a manufacturer 

16 goes through the trouble of getting a commercial 

11 certification, that that product would not 

18 necessarily be intended for residential use. 

19 And, you know, clearly, this proposal is 

20 up for comment. 

21 MR. BROOKMAN: And Detlef and you thought 

22 NSF 12 plus ANSI was adequately descriptive, 

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1 accurately descriptive? 

2 MR. WESTPHALEN: Well, if a product does 

3 have that certification, then clearly a 

4 manufacturer has -- and, you know, if a product 

s is listed as being certified under this standard, 

6 then, you know, that would be the distinction 

7 according to this definition. 

8 MR. BROOKMAN: Charlie? 

9 MR. HON: Charlie Hon, True 

10 Manufacturing. 

11 But that's a one near -- pretty much if 

12 you have products already NSF listed, that's 

13 pretty much a one-time cost. It would allow for 

14 the ability to circumvent this regulation, by 

1s getting a product which is fairly low volume, 

16 really not applicable to commercial systems if 

17 you go get it approved through NSF. Then you can 

18 circumvent this regulation. 

19 MR. WESTPHALEN: Hm. 

20 MR. BROOKMAN: Okay. Yes, Joseph? 

21 MR. FONTECCHIO: And just one last 

22 comment to that is, if the difference is the 

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1 energy allowance, and soon we'll get to that with 

2 the refrigerators. But nonetheless, the 

3 commercial products aren't allowed the same 

4 energy, may not even have the same test format. 

s That is how we would differentiate 

6 commercial from residential, is the testing and 

7 the allowances the government mandates for each 

8 product category. NSF and UL are more safety, 

9 sanitation, installation, as opposed to the 

10 energy usage. 

11 MR. BROOKMAN: I think it's clear what 

12 the Department is trying to do here. Is there 

13 something else that you would add that would be a 

14 substitute for this? 

15 MR. FONTECCHIO: I mean, if it complies 

16 with the energy that's being developed at this 

17 point, and any other industry instruction or 

18 guidelines, that would be what defines the 

19 product for the home, just like for the 

20 commercial. It needs to have certain standards 

21 because the customers of the environment it is 

22 used in are protected by the sanitation and the 

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1 safety of UL. 

2 MR. BROOKMAN: Okay. 

3 Charlie? 

4 MR. HON: This is Charlie Hon. 

s A possible alternate could be the amount 

6 of production capabilities within the unit in a 

7 day. Because traditionally in the industry, in 

8 the commercial end of the business, a 50-pound 

9 anything below 50 pounds is considered 

10 residential. Above 50 pounds in the commercial 

11 lot is considered commercial. 

12 That could be changed, because there are 

13 some people that like larger units in their 

14 homes, with big parties and stuff. But in a 

1s commercial application, you're being installed 

16 into a location which usually has local building 

11 codes which require NSF 12 application. That's 

18 just pretty much the reason people get it. 

19 But it doesn't necessarily mean that you 

20 can't have it because of that. You could have a 

21 piece of equipment that is capable of being 50-

22 pound range, and you still want to be able to put 

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1 it in your entire product line. So you just go 

2 ahead and include it in your listing under NSF 

3 12. 

4 So, to me, I think the more applicable 

s logic would be to come up with some cut-point in 

6 production, because a residential unit does not 

7 need NSF 12, because there's no installation 

s requirements under local code. That's the reason 

9 for NSF 12 -- sanitation codes, safety codes, 

10 restaurant-type applications. 

11 MR. BROOKMAN: In a commercial context? 

12 MR. HON: In a commercial context. 

13 MR. BROOKMAN: Yeah. Okay. 

14 MR. HON: And if you're in residential, 

1s most things are approved through an AHAM-type 

16 system. They're not going for the more 

17 expensive. But if you can go more expensive and 

1s get circumventing the regulation, there may be a 

19 lot of activity there. If you can't quite make 

20 it, go ahead and list it with NSF 12 and you can 

21 sell it. 

22 MR. BROOKMAN: Did you wish to comment? 

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1 MR. GOPAL: Yeah. 

2 MR. BROOKMAN: Please say your name 

3 again. 

4 MR. GOPAL: Sriram Gopal, from AHAM. 

5 I notice in subsequent slides that we'll 

6 be bringing this up again. But we just would 

7 like to kind of plant the flag that we definitely 

s question whether a residential ice maker should 

g be included in this test procedure at all, simply 

10 because we don't feel that it's been necessarily 

11 shown that there is a lot of energy savings to be 

12 had here. And so, that's something that we will 

13 be commenting on. 

14 MR. BROOKMAN: Okay. Thank you. 

15 Yes, Detlef? 

16 MR. WESTPHALEN: This is Detlef. 

11 I guess in line with the discussion on 

1s how to distinguish between commercial and 

19 residential, you know, Charlie, you mentioned the 

20 50-pounds-per-day as being the cut off for 

21 commercialized makers. 

22 And, you know, certainly if there are 

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1 other thoughts as to what features that you can 

2 point to, if you have in front of you a 

3 residential and a commercial, how do they differ? 

4 You know, the Department welcomes those comments 

s as to what other types of characteristics could 

6 be used to make that distinction. 

7 MR. BROOKMAN: Charlie? 

8 MR. HON: Charlie Hon, True 

g Manufacturing. 

10 There are very, very few real 

11 differences. All you're looking at is, there are 

12 -- you know, if you get into very large units, 

13 then you have differences because the ice14 generation system is not necessarily integral to 

1s the bin storage. 

16 But in all small units, the bin and ice 

11 generation are all built into one single piece. 

1s So there's almost no differentiation at all. 

19 

20 

21 

22 

MR. BROOKMAN: Thank you. 

Yes? 

MR. STAS: Eric Stas, DOE. 

The different units of ice makers, do 

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1 they all cluster around 50 and then, you know, 

2 what, 50 gallons per day or whatever it is? Or 

3 do they have a big jump? Or is there a very 

4 smooth gradation of ice making capacity? 

5 MR. HON: Traditionally, they've been 

6 ice machines have been basically in large 

7 increment jumps. Fifty pounds of ice generation 

s is actually yield of ice; you will generate fifty 

g pounds of ice in one 24-hour period. Then you 

10 have lOOs. You have 150s, 250s. But they're 

11 usually in incremental jumps because of marketing 

12 reasons. 

13 But you will normally only see a 50-

14 pound, and there are some 100-pound residential 

1s units. But those are for very unusual 

16 applications, and the sales of those are so 

17 minute that you would never really see them. 

18 MR. BROOKMAN: So you're not going to see 

19 a lot of products with 55, 60, 65? 

20 MR. HON: No. They may actually have 

21 that capacity, but they're always listed as a 50-

22 pound unit. 

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1 MR. BROOKMAN: Okay. Okay. 

2 Did you have some individuals? Yes. 

3 MR. WATSON: Got a few. 

4 MR. BROOKMAN: Okay. Troy, go ahead. 

5 MR. WATSON: So on the topic of ice 

6 makers, we've got a comment from Bill Brown that 

1 says, "To differentiate these machines from the 

8 ice makers that are in refrigerator-freezers and 

9 freezers, would DOE consider terming these 

10 products as ice machines or something else?" And 

11 I think DOE would definitely be open to any 

12 recommendations to help differentiate between 

13 those. 

14 MR. BROOKMAN: Okay. That's good. And 

1s let me remind everybody online, please send in 

16 those comments in writing as well. 

17 MR. HAGERMAN: I don't think it's our 

18 intent to make things more confusing, right? 

19 MR. BROOKMAN: Right. 

20 MR. HAGERMAN: I mean, if we can simplify 

21 things, absolutely let's hear those comments. 

22 MR. BROOKMAN: Okay. 

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1 MR. HAGERMAN: I do have one question. 

2 MR. BROOKMAN: So, Joe, please keep 

3 going. 

4 MR. HAGERMAN: I do have one question. 

s When you said 50 pounds, is that a nominal 50 

6 pounds or is that an actual 50 pounds? Do you 

7 know what I mean by that? Like, when you say 50 

s pounds, if I turn that thing on for 24 hours, is 

g it going to make 50 pounds? Or is it going to 

10 make 52 pounds, or is it going to make 60 pounds? 

11 MR. HON: Charlie Hon again. 

12 It is going to be very variant upon 

13 conditions. Harvesting of ice is dependent on 

14 how much -- once the ice is built, once you have 

1s a certain amount of ice and it dumps it out, you 

16 will always have a variation in it. When you 

11 drop it into a storage bin, you have a melt ratio 

1s that's going on, because the bin itself is not 

19 cooled, because you don't want the ice to stay in 

20 there and get stale. So it's constantly melting 

21 itself down. So you have to be very cognizant. 

22 It is -- the 50-pound advertised in the 

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1 commercial end, there's a test procedure where 

2 you take the ice out and you weigh it. So you 

3 have to be able to generate a minimum of the 50 

4 pounds; they market it as a 50-pound machine. It 

5 can generate more than that, and depending on 

6 conditions, you can have a variation in voltages 

7 coming into the building. 

8 Higher voltage increase the cycle speed. 

9 If you have a variation in frequency coming into 

10 the building, increase or decrease the cycle 

11 speed, then you can get a little bit more out of 

12 it. And if you get 52 pounds, that's, you know, 

13 4 percent variance, you're certainly going to 

14 hedge toward that side of it so that you never 

15 get caught shorting somebody on ice. 

16 So, my estimate? A 50-pound machine will 

17 probably produce an average of 55 to 60 pounds. 

18 But you don't want to be on the low side of it. 

19 You want your customer to have at least what 

20 you've promised them. 

21 MR. HAGERMAN: Thank you. That was very 

22 helpful. Thank you. 

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1 MR. BROOKMAN: Thank you. 

2 Do we have additional? Yes? 

3 MR. WATSON: Yeah, a couple more. This 

4 is Troy Watson again. 

s So this is kind of moving over back to 

6 the "cool cabinet" definition. Mariam Raji 

7 commented, "Is there no maximum temperature that 

s the cool cabinets in cellar compartments must 

9 stay below?" And in the proposed definitions, 

10 DOE is not proposing any maximum temperature for 

11 those compartments or products in its proposal. 

12 But we would request comment on whether one of 

13 those would be appropriate. 

14 MR. BROOKMAN: Okay. Good. Thank you. 

15 MR. WATSON: And on that same topic, 

16 Michele Crociani commented, "As a mini-bar 

11 manufacturer, I would like to know how the mini1s bar for a hotel is classified, because it seems 

19 there is confusion on this. " 

20 And I would say, just based on the 

21 product definitions, that would depend on the 

22 compartment temperatures that the products are 

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37 

1 able to maintain and on the refrigeration 

2 technology that's being used, if it's a vapor3 compression refrigerator or a non-compression 

4 refrigerator as, I think, many hotel units are. 

5 (Pause.) 

6 MR. BROOKMAN: Okay. 

7 MR. WATSON: And back to the topic of ice 

8 makers, Andrew Sullivan commented, "Ice makers 

9 should be distinguished from freezers by 

10 percentage volume dedicated to ice production11 storage similar to the definition for a hybrid 

12 wine chiller." 

13 DOE would probably welcome information as 

14 to what the appropriate percentage for that would 

1s be if that's an appropriate way to differentiate 

16 between the products. 

17 MR. BROOKMAN: Is there a rule of thumb 

18 on this, or is it all over the place? 

~ Charlie? 

20 MR. HON: Traditionally, you have some 

21 real serious questions I have to ask here. 

22 Number one is, traditionally, in what we would 

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1 consider an ice maker in the industry, it is 

2 pretty much exclusively making ice. There may be 

3 a very small component. But the primary 

4 refrigeration system is designed for the ice 

s generation. 

6 In a residential refrigerator with an ice 

7 maker inside of it, the primary function of the 

8 refrigeration unit is to generate cold air for 

g the freezer. The ice just is a scavenger off the 

10 side of it. It's usually very low percentage of 

11 your internal volume of your freezer. But if you 

12 get into some large -- some side-by-sides have a 

13 fairly large storage bin. 

14 But you have a difference in the nature 

1s of the ice. Because in an ice machine 

16 exclusively, you're not saving the ice by a cold 

17 environment. The ice itself is stored in a non18 controlled environment. The chilling is from the 

19 other ice. 

20 In a freezer, refrigerator-freezer, the 

21 chilling is from the freezer to keep the ice 

22 cold. 

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

2 MR. WATSON: See, and I think, again, any 

3 written comments that would help clarify these 

4 definitions would definitely be appreciated. 

5 MR. BROOKMAN: So, additional comments 

6 related to these comment boxes before we move on? 

7 (No audible response.) 

8 MR. BROOKMAN: Okay. 

9 MR. WATSON: Okay. Okay. So, as I 

10 mentioned back on the first slide I presented, 

11 DOE is also proposing amendments to the existing 

12 refrigerator, refrigerator-freezer, and freezer 

13 definitions to help improve clarity and 

14 distinguish from the newly proposed definitions. 

15 So, this is the list of the proposed 

16 amendments for these definitions. DOE is 

17 proposing to clarify that these products may 

1s contain cellar compartments. But if the cellar 

19 compartments make up less than half of the total 

20 refrigerated volume, they would still be 

21 considered refrigerator, refrigerator freezer, or 

22 freezer, as appropriate. 

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1 DOE is also proposing to remove the terms 

2 "electric refrigerator" and "electric 

3 refrigerator-freezer" from 10 CFR 430.2. Right 

4 now, these terms are kind of redundant. They 

s just reference "refrigerator" and "refrigerator6 freezer." 

7 DOE is also proposing to move the term 

s "all refrigerator" that's currently in Appendix 

g A. DOE is proposing to move that definition to 

10 10 CFR 430.2, and that would be consistent with 

11 where all the other product-type definitions are 

12 inc 1 uded. 

13 For these definitions, DOE is proposing 

M to replace the current phrase "designed to be 

1s capable of achieving" with the phrase "capable of 

16 maintaining compartment temperatures at." And 

17 this is consistent with the other definitions I 

1s just went through, where "capable of maintaining 

19 compartment temperatures at" would be determined 

20 during operation at an ambient of 72 degrees 

21 Fahrenheit. So this way, all the refrigeration 

22 products would be consistent across the board in 

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1 their definitions. 

2 In these three definitions, DOE is also 

3 proposing to remove references to the storage of 

4 food. The proposed definitions are trying to get 

s more towards concrete temperature ranges, things 

6 like that that someone could point to to get a 

7 better idea of which product type a product 

s should be classified as. 

9 And then, finally, DOE is proposing to 

10 add exclusions of products designed to be used 

11 with open compartments, without an integral 

12 compressor and condenser, or certified under the 

13 commercial standards NSF 7-2009 and UL 471. And 

14 this is to better differentiate between consumer 

1s and commercial products. 

16 So, any -- I thought there was a comment 

17 there. 

18 MR. BROOKMAN: Yes. Joseph? 

19 MR. FONTECCHIO: Yes, Joseph Fontecchio 

20 with True Manufacturing. 

21 The last bullet point about the 

22 differentiation of residential and commercial. I 

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1 mean, today residential products that are sold 

2 for outdoor use have to qualify with UL 471 and 

3 get a complementary listing to UL 250. So in 

4 that example, rating residential equipment to be 

s used in an outdoor kitchen has to come through 

6 471. So that shouldn't be able to differentiate 

7 between the home or the commercial. 

8 And then NSF 7 / again it's a performance 

9 rating to make sure it has cooling capacity to 

10 keep food at a safe temperature in a given 

11 condition. And it's quite a bit about 

12 accessibility in the materials that you use and 

13 the construction of your machinery. 

14 The differentiation is the Energy Guide. 

1s So if we have a product that uses, you know, 

16 three kilowatts and complies with the DOE that we 

11 just did in September, it's a vastly different 

1s test with vastly different energy allowance than 

19 the commercial test. 

20 That's the main distinguisher between 

21 commercial and residential. These additional 

22 safety, installation, and sanitation shouldn't 

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1 limit use in the home. They're a value-add. 

2 MR. BROOKMAN: Charlie. 

3 MR. HON: Charlie Hon with True 

4 Manufacturing. 

s There is also some games can be played 

6 here, because NSF and UL can be attained and 

7 thereby circumvent the standard again. It is a 

8 differentiation level, but in commercial 

9 applications those same standards, if we're 

10 trying to apply a unit to commercial, it says 

11 that you have -- it's also involved in marketing. 

12 If we would advertise it and make it 

13 readily available to the residential market, then 

14 it would have to meet the -- say, a full-sized 

1s refrigerator that would be in a commercial 

16 kitchen. And there are customers who want those 

11 in their homes. It's not a good idea, but people 

18 do want them. 

19 And because we do not market to that and 

20 we do not advertise, and basically advertise 

21 against that application, but we have no control 

22 of it sometimes, it does happen. But by doing 

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1 this, there's no specification in the commercial 

2 ice makers about what defines a residential or a 

3 commercial. 

4 So by going to these two standards and 

s have them met and pay for the few dollars that it 

6 takes to have them met, suddenly we're excluding 

7 them from the energy efficiency standards. And 

8 for those few dollars, if you're able to market 

g your product, it's an advantage. And then you'll 

10 never have to deal with DOE. 

11 MR. BROOKMAN: Okay. Thanks, Charlie. 

12 Yes, please. Sriram. 

13 MR. GOPAL: Sriram Gopal from AHAM. 

14 We're still developing our comments on 

1s this particular question, but one thing was some 

16 feedback we did get from our members is whether, 

11 you know, these definitions could be tied into, 

18 you know, a specific test condition or an ambient 

19 temperature or something like that. 

20 And also, the 72-degree Fahrenheit 

21 ambient condition, we got feedback from members 

22 saying that they generally have a room set up at 

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1 70 degrees Fahrenheit and whether DOE would be 

2 amenable to changing that number. So that's 

3 something we may comment on. 

4 MR. BROOKMAN: Is 70 degrees in some, in 

5 the existing test procedure somewhere? 

6 MR. GOPAL: I need to get clarification 

7 on where that number comes from. 

8 MR. BROOKMAN: Okay. Okay. Thank you. 

9 Yes. 

10 MR. WATSON: Is there any data -- this is 

11 Troy Watson again. 

12 If there's any data or test data 

13 supporting that claim, we would definitely 

M appreciate it. 

15 MR. BROOKMAN: Charlie? 

16 MR. HON: Charlie Hon, True 

11 Manufacturing. 

1s What would you consider normal variation 

19 from 72 degrees? Because a test standard should 

20 have plus or minus on it. 

21 MR. WATSON: Off the top of my head, I'm 

22 not sure if that's included in the reg text. But 

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1 I think for these temperature ranges, it's plus 

2 or minus 1 degree. I know that's what it is for 

3 the 90-degree ambient in the test procedure. 

4 MR. HON: But now we're posing a new 

s condition here, 72. And could you, because it is 

6 not -- it's not a heavy-demand condition, could 

7 you put it 71 plus or minus 2 or something and 

s deal with all of it at one time? 

9 MR. WATSON: I think DOE would definitely 

10 appreciate comments on it, if that's possible, to 

11 help reduce test burden. One thing to point out 

12 here is that the 72 degrees wouldn't be required 

13 for testing the products each time. It's just 

14 for purposes of determining product type, 

1s classification. 

16 MR. BROOKMAN: Good point. Okay. 

11 Additional comments on this series of 

1s points, differentiators really? 

19 (No audible response.) 

20 MR. WATSON: So all those previous 

21 definitions cover specific product types. DOE is 

22 also proposing two additional terms to describe 

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1 groups of products. And the first is 

2 "miscellaneous refrigeration products." This 

3 would be a blanket term that refers to the 

4 products that are addressed by this NOPR that are 

s not currently regulated by DOE. 

6 The second definition would be "consumer 

7 refrigeration product," and that would be another 

s blanket term that refers to both miscellaneous 

g refrigeration products and the currently covered 

10 refrigerator, refrigerator-freezer, and freezer 

11 products. 

12 And DOE is proposing these terms because 

13 there are some provisions in the test procedures 

14 and the certification requirements that apply to 

1s the whole group of products, or both groups, and 

16 this just allows for easier referencing of these 

17 groups of products. 

1s (Pause. ) 

19 MR. WATSON: So again, request for 

20 comment? I think we might have covered the 

21 second point a bit. But on the first point, DOE 

22 requests comment on the blanket terms 

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1 "miscellaneous refrigeration product" and 

2 "consumer refrigeration product." 

3 MR. BROOKMAN: Yes, Sriram. 

4 MR. GOPAL: Sriram from AHAM. 

s AHAM has commented on this in the past, 

6 and we'll be reiterating the fact that we still 

7 don't feel that it's appropriate to lump all of 

8 these products together. We feel that they are 

g different enough that they warrant separate test 

10 procedures. And in that case, each should be 

11 shown to, you know, contribute to energy 

12 efficiency standards on their own and not as a 

13 group. And we question whether, you know, going 

14 down this path is appropriate. 

15 MR. BROOKMAN: Okay. Thank you. 

16 Any additional comments, particularly on 

17 as described, as elaborated, miscellaneous 

18 refrigeration product or consumer refrigeration 

19 product? 

20 (Pause. ) 

21 

22 

MR. BROOKMAN: Okay. 

MR. WATSON: Now, here is a chart. This 

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49 

1 wasn't included in the NOPR, but it kind of helps 

2 to show where the proposed definitions fall into 

3 place in the overall scheme of consumer 

4 refrigeration products. So you can see, within 

s consumer refrigeration products, we have 

6 refrigerators, refrigerator-freezers, and 

7 freezers. Those are our currently covered 

s products. Then we have the miscellaneous 

9 refrigeration products that is the subject of 

10 this NOPR. 

11 And then within those, we have the four 

12 main product types that we've discussed already. 

13 Those are the cooled cabinets, ice makers, hybrid 

14 products, and non-compressor refrigerators. And 

1s then, depending on the product type, there may be 

16 additional definitions within each of those 

11 categories and different product types within 

1s those. 

19 And the specific test procedures for 

20 those products, we'll address those. And we'll 

21 be getting into those in a bit more detail as we 

22 go through those test provisions. 

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1 MR. BROOKMAN: This is a very useful 

2 graphic. 

3 MR. HAGERMAN: Yes. Joe Hagerman, DOE. 

4 Next time, let's start with this. 

5 (Laughter.) 

6 MR. BROOKMAN: It's good. It's very 

7 good. 

8 MR. HAGERMAN: The helpful chart here 

g that you've hit on. 

10 MR. BROOKMAN: Okay. We're going to keep 

11 going. 

12 (Slide.) 

13 MR. WATSON: And so, just another slide 

14 that might be a bit helpful in figuring out the 

15 definitions. This is just an example of how one 

16 would classify a product type. So this example 

11 has two compartments. The top compartment is 

1s larger than the bottom one. And here our example 

19 temperature ranges at both 90 degrees ambient and 

20 72 degrees ambient. 

21 You can see at 90, the temperatures are 

22 pretty high. They would both be in the cellar 

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1 compartment range, but that's at 90 degrees. 

2 Compartment classification, as DOE proposes it, 

3 would be determined at a 72 degree ambient. So 

4 there you could see the temperature ranges are 

5 lower. 

6 They're pretty similar. You could see 

7 the bottom compartment gets below the 39 degree 

s threshold pretty comfortably. The top 

9 compartment gets below 39, but it only gets down 

10 to 38 degrees Fahrenheit. 

11 The proposed definition for "cellar 

12 compartment, 11 it can go as low as 3 7 degrees 

13 Fahrenheit, but as long as it maintains 

14 temperatures above 60 degrees, it could still be 

15 considered a cellar compartment. So because this 

16 top compartment has a range from 38 to 63, that 

11 would be considered a cellar compartment. The 

1s bottom compartment would be considered a fresh 

19 food compartment. 

20 And then because the top compartment is 

21 larger or makes up more than half of the volume 

22 of this product, that would bump it into the 

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1 hybrid product category. So in this case, you'd 

2 get a hybrid and we just say it's a non3 compressor product. There's nothing to do there. 

4 A hybrid non-compressor all-refrigerator is what 

5 this would be. 

6 So just an example of the steps one would 

7 go through based on the new product definitions. 

s So that takes us to the end of the 

9 product definitions. I know there were a lot and 

10 we've discussed them quite a bit. But if there's 

11 any more comments at this time, I think it would 

12 be a good point to stop. 

13 MR. BROOKMAN: And no one has yet 

14 commented on kind of the inherent logic in all of 

15 this, I don't believe. So whether it's now or in 

16 your written comments, that would be useful for 

17 the Department, for you to say, "Yeah, this kind 

1s of structure, this latching together of features, 

~ that makes sense" or not. Right? I'm searching 

20 for it here, folks. Okay. 

21 So then I guess we're going to move on. 

22 I guess we have one comment from online. 

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1 MR. WATSON: We do. Yep, one more 

2 question online from Michele Crociani again. And 

3 it says, "Mini-bar for hotel is not mentioned. 

4 Do we have to consider it as consumer products or 

5 commercial?" 

6 And I think the response to that would be 

7 that it would be covered under the proposed 

8 definitions, and it's just a matter of what 

g product type it would fall into based on its 

10 compartment temperatures. 

11 MR. BROOKMAN: Okay. Okay. 

12 Okay. Are we ready to move on now? 

13 (Pause.) 

14 MR. BROOKMAN: Oh. Apparently, Joanna 

Mauer, who . . . 15 lS ]Olnlng us online, has a question 

16 or comment. Joanna, unmute your phone and 

17 hopefully we'll hear you. 

18 MS. MAUER: Hi. Thanks. This lS Joanna 

19 from ASAP. 

20 I just got confused on the last slide, 

21 going through the example product, where you said 

22 it would be a hybrid non-compressor product. 

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1 Does that mean it would fall in the category of 

2 non-compressor products? 

3 MR. WATSON: Yes, it would. So this is a 

4 -- it would be both hybrid and non-compressor. 

5 MS. MAUER: And is this a type of product 

6 that you've seen on the market today? 

7 MR. WATSON: No. I don't think so. This 

s is just kind of one of the most complicated 

g examples we could come up with. 

10 (Laughter.) 

11 MR. WATSON: So we decided to go with 

12 that even though it's not necessarily realistic 

13 of the market. 

14 MS. MAUER: Okay. 

15 MR. BROOKMAN: Oh, this doesn't exist? 

16 This is a fabrication, this photograph? 

17 MR. WATSON: The photograph exists, but 

1s it's not this product. The data is made up. 

19 

20 

21 

22 

MR. BROOKMAN: I see. Okay. 

(Laughter. ) 

MR. BROOKMAN: Charlie. 

MR. HON: One other comment. We were 

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1 just sitting here talking about something. The 

2 discussion of a mini-bar is a beast in itself 

3 because that brings up additional discussions of 

4 NSF standards and UL standards. 

5 Because those NSF standards and UL safety 

6 standards are designed for commercial and public 

7 application in certain types of environment. And 

s a hotel usually fits in that category. Hotel 

9 rooms would then fit in that category, the same 

10 as the ice machine and the vending machine in the 

11 hallway, because they are a commercial 

12 application. 

13 So if you use the NSF and UL exclusion, 

14 you may exclude all mini-bars. 

15 MR. BROOKMAN: So that pushes them out of 

16 the, quote, "consumer" designation. 

17 Detlef. 

18 MR. WESTPHALEN: So, this is Detlef. 

19 So what you're saying is that nearly all 

20 hotel mini-bars do have the NSF and UL 

21 certification? 

22 MR. HON: I would say that. It may not 

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1 be true, but if the building inspector wishes to 

2 impose the regulations and there's local codes, 

3 it would be. Certain areas have all-commercial 

4 all buildings fall under certain building 

5 codes for NSF or UL listings. You have to have a 

6 product UL listed in certain applications. 

7 MR. BROOKMAN: Thank you, Charlie. 

8 So this is good comment. Any additional 

g thoughts along these lines before we move on? 

10 (Pause.) 

11 MR. BROOKMAN: Yes, please, Sriram. 

12 MR. GOPAL: I have a question on the 50-

13 percent volume issue. Could you kind of 

14 elaborate on where that 50-percent number came 

15 from? And also, if there's going to be a 

16 tolerance level associated with that 50-percent 

17 volume number, is that something DOE would be 

18 open to? 

19 MR. WATSON: I'll have to turn to Detlef 

20 on the history of that number. 

21 MR. GOPAL: Because we all know that 

22 calculating volumes can be an exercise in and of 

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1 itself. So, you know --

2 MR. WESTPHALEN: This is Detlef. 

3 The 50 percent initially came out of a 

4 waiver request by Liebherr. 

5 MR. BROOKMAN: Detlef, speak up, please. 

6 MR. WESTPHALEN: The 50 percent initially 

7 came out of a waiver request by Liebherr back in 

s 2007 when they wanted to commercialize something 

g that was a hybrid. And so they -- you know, it 

10 was a hybrid freezer. 

11 Certainly, DOE requests comment on 

12 whether 50 percent is the current number and then 

13 justification for why it may or may not be. 

14 The proposal at this point does not have 

15 specifics regarding tolerance on the 50 percent. 

16 For instance, if you're at 49 percent, you know, 

11 if, say, you measure three of these and two of 

1s them are at 51, 50.5, and another one is 49, what 

19 does that do to the product as a whole? And so, 

20 certainly, you know, DOE would welcome some 

21 comments on exactly how DOE should handle that. 

22 MR. BROOKMAN: Okay. Yeah. 

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1 Joanna? Please unmute your phone. Let's 

2 hear from you. 

3 MS. MAUER: I just wanted to follow up on 

4 this example of a hybrid non-compressor 

5 refrigerator. And my question is, if there were 

6 such a product, would it be covered under the 

7 proposed definitions? 

8 MR. WATSON: Yes, it would. DOE is 

g proposing the term "hybrid non-compressor all10 refrigerator" as part of this NOPR. So it would 

11 be covered under that definition. 

12 MR. BROOKMAN: Describe why it would be 

13 covered, Troy. 

14 MR. WATSON: Well, so, yeah. For the 

15 reasons I discussed with classifying the two 

16 compartments and the fact that this example would 

17 not have a compressor and condenser, it would 

18 meet all the requirements of the proposed 

19 definition for hybrid non-compressor all20 refrigerator. 

21 

22 

MR. BROOKMAN: Okay. 

MS. MAUER: So, is in the -- this is 

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1 maybe jumping ahead to the preliminary TSD, but 

2 this would be -- so there's one proposed product 

3 class for non-compressor refrigerators. Are you 

4 saying it would fall under that category? 

5 (Pause.) 

6 MR. WATSON: Off the top of my head, I 

7 can't recall the specific product classes that 

s were considered in the preliminary analysis. Do 

9 you deal with -- are you aware of those? 

10 MS. MAUER: Okay. Perhaps this is maybe 

11 a discussion for tomorrow. 

12 MR. WATSON: Yeah. 

13 MR. WESTPHALEN: This lS Detlef. 

14 Just in response to that, this type of 

15 product does not fit into the class structure 

16 that we'll be talking about tomorrow, if I 

11 remember correctly. However, the classes that 

1s we'll be talking about tomorrow represent 

19 products that DOE has seen on the market. And so 

20 if this particular product did appear on the 

21 market, then DOE would have to decide how to deal 

22 with it, whether the proposals that we'll talk 

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1 about tomorrow for hybrids would take dominance 

2 or whether the proposals for non-compressor 

3 refrigerators would take dominance, and how that 

4 would all get worked out. 

s But it's a good point, Joanna, and 

6 something that maybe in future will have to be 

7 worked out. 

8 MS. MAUER: Thank you. 

9 MR. BROOKMAN: Thank you. 

10 MR. WATSON: I apologize. Next time I'll 

11 keep the examples more realistic. 

12 MR. BROOKMAN: I think it was useful to 

13 try and construct that. 

M Joseph, go ahead. 

15 MR. FONTECCHIO: I just wanted to go 

16 back, if you don't mind, to the slide about the 

17 change in the definition of "electric 

18 refrigerator" or "refrigerators." That's where 

19 you're proposing adding the stipulation for ANSI 

20 and UL. 

21 That's a refrigerator. But now we're 

22 talking about these non-refrigerator products. 

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1 Where do we stand on the definition of those as 

2 relates to the NSF 7 and the UL? Because it 

3 appears that the temperature range defines the 

4 difference between refrigerator and a nons refrigerator as a first separation. 

6 And then also, another one where it 

7 needed to have a compressor and condenser for the 

s refrigerator, where it does not for the 

9 nonstandard. Do we have a full definition of the 

10 nonstandard products? 

11 MR. WATSON: So I think you're asking 

12 whether the definition for the "cooled cabinets" 

13 includes the exclusions for NSF and UL 471? 

14 MR. FONTECCHIO: Yes. 

15 MR. WATSON: I don't believe that's 

16 included in the proposed definitions at this 

17 time. But that might be an oversight, because 

18 I'm guessing that would -- DOE would want those 

19 to be consistent across the board. 

20 MR. BROOKMAN: Okay. Thanks for pointing 

21 that out. 

22 MR. GOPAL: Right. Temperature is the 

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1 big differentiator. 

2 MR. BROOKMAN: Yeah. 

3 MR. GOPAL: And then the compressor. 

4 MR. WATSON: Correct. 

5 MR. FONTECCHIO: So right now you're 

6 saying if it doesn't have a compressor, it can't 

7 be a refrigerator. 

8 MR. WATSON: Right. It would be 

g considered a non-compressor refrigerator. 

10 MR. BROOKMAN: Thank you, Joseph. 

11 MR. FONTECCHIO: Is it a non-compressor 

12 refrigerator, or it's a nonstandard product? 

13 It's not -- the term "refrigerator" goes away 

14 because it doesn't hold the 39 degrees. 

15 MR. WATSON: Okay. So, I think I see 

16 what you' re saying now. If it doesn't hold the 

17 39 degrees, that pushes it to "cooled cabinets." 

18 MR. FONTECCHIO: Yes. 

19 MR. WATSON: And then there's no 

20 differentiation at this point between -- at least 

21 in terms of the product definition, there's no 

22 differentiation between "compressor cooled 

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1 cabinets" and "non-compressor cooled cabinets." 

2 MR. FONTECCHIO: Okay. 

3 MR. WATSON: However, DOE is proposing 

4 differences in the test procedures for those 

s units. 

6 MR. WESTPHALEN: This is Detlef. 

7 Just to clarify, there are separate 

8 definitions for a "non-compressor cooled 

g cabinet," you know, and, you know, a 

w "conventional cooled cabinet" because the test 

11 procedures are different. When we get into 

12 tomorrow's discussion, the classes are not 

13 different, but that's part of tomorrow's 

14 discussion. 

15 MR. FONTECCHIO: Yes. But what I'm 

16 pointing to is that you're wanting to change the 

11 definition of the "refrigerator" as part of this 

18 additional category of cooled cabinets, hybrid 

19 cabinets. And that point is where you wanted to 

20 add the UL ANSI. 

21 This is changing the definition of 

22 "refrigerator." So we're mixing two things here, 

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64 

1 with changing the definition of the 

2 "refrigerator," which is one thing, 39 degrees, 

3 and this "cooled cabinet" greater than 39 

4 degrees. I guess some clarity on the definition 

s of -- you know, a logic tree: What makes it a 

6 cooled cabinet? So we know for sure it can't 

7 hold 39. And according to this, it doesn't have 

s to have a compressor, where this one does. 

g And potentially, the UL and NSF 

10 stipulation, so there's two branches here. One 

11 is a refrigerator or capable of holding 39, and 

12 one is non-capable of holding 39. And so the 

13 definitions need to be more specific. 

14 MR. BROOKMAN: Okay. I mean, I guess the 

1s question of the commercial certifications, the 

16 NSF and UL, that's something that you raised that 

11 Troy said potentially did not get into the 

1s definitions for cooled cabinet. 

19 MR. FONTECCHIO: Yes, sir. 

20 MR. WESTPHALEN: And we should check that 

21 and make sure that's consistent, whatever we 

22 decide to use as a distinction between commercial 

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1 and residential. And that's a good point. 

2 In regard to what is a refrigerator, a 

3 refrigerator without a compressor is not a 

4 refrigerator, according to these definitions. 

5 That's just some, you know -- that's the way the 

6 logic works. So a non-compressor refrigerator is 

7 not a DOE refrigerator. It's a non-compressor 

s refrigerator. 

9 Sometimes, you'll see somebody talking 

10 about a refrigerator. And you just need to keep 

11 clear that when you see the regulatory language, 

12 when it says "a refrigerator, " it means it has a 

13 compressor. 

14 MR. FONTECCHIO: So then, should that not 

15 be called a "non-compressor cooled cabinet"? 

16 MR. WESTPHALEN: Well, we do have a 

11 separate definition, I believe, for "non1s compressor cooled cabinet. " It means the cooled 

19 cabinet without the compressor. 

20 MR. FONTECCHIO: Is that not the same as 

21 the non-cooled or non-compressor refrigerator? 

22 MR. WESTPHALEN: It is not the same. 

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1 MR. FONTECCHIO: Okay. 

2 MR. WESTPHALEN: The temperature 

3 difference makes it not the same. 

4 MR. FONTECCHIO: But because it doesn't 

s meet the temperature and doesn't have a 

6 compressor, it's not a refrigerator? 

7 MR. WESTPHALEN: That's right. 

8 MR. FONTECCHIO: Okay. There could be 

9 some confusion there, is what I'm saying. 

10 MR. WESTPHALEN: Okay. Yeah. 

11 MR. FONTECCHIO: "Refrigerator" now is 

12 being changed to mean 39 degrees. So anything 

13 that doesn't do 39 is going to be a cooled, 

14 hybrid, cellar, portions. I could see the 

1s confusion, depending on the product you have, 

16 which category you need to comply with and which 

11 standard you have to test to. 

18 MR. HAGERMAN: So this is Joe Hagerman, 

19 DOE. 

20 I think we've heard a couple of times 

21 today people confused by determining where they 

22 call in this rubric, right? 

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67 

1 MR. BROOKMAN: Yeah. 

2 MR. HAGERMAN: And I think, you know, 

3 your suggestion of this logic tree, logic map, 

4 some helpful tool, I think, would benefit all of 

s us so we can be ensured that we're not talking 

6 past each other. Right. 

7 MR. BROOKMAN: And I think in this last 

s exchange, we gained some ground on it. 

9 (Laughter.) 

10 MR. BROOKMAN: I think we did. So, 

11 Joseph, thank you for that, and Detlef as well. 

12 Yes. 

13 So, additional thoughts and comments here 

14 before we move on? 

1s (No audible response. ) 

16 MR. BROOKMAN: Okay. Good. 

17 MR. WATSON: So now we'll -- this is back 

1s to Troy Watson. 

19 Now we'll Jump into the proposed test 

20 procedure amendments. 

21 MR. HAGERMAN: So, Michael Kido is now 

22 with us from GC's office. And he pointed out 

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1 that in the larger NOPR -- you know, what you're 

2 seeing here in these PowerPoints are a snapshot 

3 of the NOPR, right? It's not all the details of 

4 the NOPR. So if you go back and actually read 

s the NOPR, he thinks it may explain it a little 

6 bit more clearly. So. 

7 MR. KIDO: Yeah, Michael Kido. 

8 I don't remember. I'm looking at Detlef 

9 right now. At one point, I thought we did have a 

10 matrix of some sort that laid out the different 

11 characteristics. And maybe that would be a 

12 visual tool that folks can use to kind of get an 

13 idea of what we're thinking about. 

14 You know, a logic tree is also a good 

1s idea, too. But I just wanted to make sure 

16 everyone had the same tools that we were looking 

11 at when we were developing this particular notice 

18 

19 

20 

21 

22 

so that we're all on the same page. 

MR. BROOKMAN: Okay. Thank you, Michael. 

Thank you. 

Detlef, do you want to add here? 

MR. WESTPHALEN: Yeah. If it's the 

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1 figure that I think Michael is referring to, 

2 that's something that, you know, we could put on 

3 the docket, for example, to help clarify. 

4 MR. BROOKMAN: Okay. Yeah. I think Joe 

s -- it's a good idea if Joe --

6 MR. HAGERMAN: Our intention is not make7 this-confusing, right? 

8 MR. BROOKMAN: Right. 

9 MR. HAGERMAN: And the whole goal here is 

10 to work with everybody to make this, you know, 

11 easy to understand and accessible. 

12 MR. BROOKMAN: Yeah. 

13 MR. HAGERMAN: So let's do that. Let's 

14 add it to the docket. And if we need to revise 

1s it and put a new document on the docket, let's do 

16 it. 

17 MR. BROOKMAN: Great. 

1s Apparently, Andrew Sullivan, who is 

19 joining us online, has a question or comment. 

20 Andrew? 

21 MR. SULLIVAN: Yeah. I was just, as I 

22 was reading through the NOPR, it just came to my 

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1 -- it seems like we're always playing catch-up 

2 with the definitions, based on all the designs 

3 that are coming out for all these different 

4 products. 

s I just think we need to try and do an 

6 approach, and I'm putting my head towards it, 

7 thinking hard about it, that really modularizes 

8 everything so that it becomes future design9 proof, without handcuffing, you know, developers 

10 or manufacturers in their designs. 

11 But just one of the things as far as 

12 approaches to hybrid products, you know, if it's 

13 not a pure, single, you know, temperature or 

14 single climate compartment, to me it's basically 

1s a hybrid, right? If it's a mixture of different 

16 compartments that have different features and 

11 functions and temperature or climate controls, 

18 then it would be a hybrid. 

19 And there needs to be some sort of 

20 definition that's modularized, regardless of what 

21 the design is. What that is, unfortunately, I 

22 don't know at this point. But we're looking at 

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1 products now that also, you know, are regulating 

2 or monitoring humidity inside as well. And 

3 there's definitely energy-using components that 

4 are involved in that. 

s When you change the behavior or fans or 

6 add heaters into things in order to control the 

7 humidity, which, you know, some wine units do, 

s and then we also have refrigerated humidors out 

g there, how do we classify these or future-proof 

10 the definitions of a hybrid so that, when these 

11 new products come along, they basically fall into 

12 place and, you know, avoid manufacturers from 

13 having to do these complicated waiver requests 

14 and things like that? 

1s But they can actually define their 

16 product themselves through the actual test 

17 procedure and capture these energies. 

1s I just think we need to look at them now 

19 as climate compartments or climate chambers, 

20 rather than just refrigerated, because they are. 

21 We are adding so many different other features in 

22 there to handle, you know, like humidity and 

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1 anti-sweating technology and things like that. 

2 MR. BROOKMAN: Okay. Okay, Andrew. 

3 Thank you. That's helpful. Appreciate that. 

4 MR. WATSON: I think the intent of the 

s proposal is to cover as many types of products as 

6 DOE is aware of. And DOE is trying to anticipate 

7 future products. But if there's something 

s specific in there where a new product type 

9 wouldn't be covered, or there's a technology that 

10 wouldn't be addressed, it would be helpful to 

11 have that specific information to know where the 

12 current proposal is lacking. 

13 MR. BROOKMAN: Are we ready to move on? 

14 (Pause.) 

15 MR. BROOKMAN: Okay. 

16 MR. WATSON: Okay. So now into the test 

17 procedure amendments. The first couple here 

18 aren't specific to miscellaneous refrigeration 

19 products . They just apply in general to 

20 Appendices A and B. 

21 So, first, DOE is proposing to eliminate 

22 the definition numbering in Appendices A and B, 

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1 and that's just to simplify the overall structure 

2 of those test procedures. 

3 The second proposal is, DOE is proposing 

4 to eliminate the provisions for externally vented 

s products from Appendix A. And that's because DOE 

6 is not aware of any of these types of products 

7 currently available on the market. 

8 DOE requests comment specifically on the 

g proposal to remove the externally vented product 

10 provisions and on whether any of these products 

11 are available or may become available in the near 

12 future. 

13 MR. BROOKMAN: No comment. 

14 MR. HAGERMAN: Okay. 

15 MR. WATSON: So back to specific 

16 provisions for miscellaneous refrigeration 

17 products. DOE is proposing sampling plans, 

18 certification reporting requirements, and 

19 provisions for the measurement and verification 

20 of volume of these products that would be 

21 consistent with the provisions that currently 

22 exist for refrigerators, refrigerator-freezers, 

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1 and freezers. 

2 So, the provisions for certification 

3 reporting and sampling plans, those will be 

4 included in 10 CFR 429. The section numbering at 

s this point is 61, but that will depend on the 

6 time of the final rule. I'm sure others may be 

7 added in. 

s One thing to note here is that non9 compressor refrigerators and hybrid non10 compressor refrigerators would have additional 

11 reporting requirements compared to existing --

12 sorry about that -- compared to the existing 

13 requirements for refrigerators and refrigeratorM freezers. 

1s And the requirement would be that if 

16 these types of products are not able to maintain 

17 compartment temperatures at the cold setting, 

1s manufacturers would have to report whatever 

19 temperature they are able to maintain. And this 

20 would be under test conditions at 90 degrees 

21 Fahrenheit. 

22 Ice makers would also have additional 

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1 reporting requirements, and those would be for 

2 harvest rate and the ice hardness used in the 

3 test procedure. 

4 In Section 10 CFR 429.72, DOE is 

5 proposing to allow the use of CAD software to 

6 certify product volumes. This is consistent with 

7 the refrigerator and refrigerator-freezer 

8 requirements. 

g In Section 429.134, DOE proposes to 

10 include volume verification procedures for 

11 miscellaneous refrigeration products that are 

12 consistent with those for refrigerators. 

13 And one thing to point out here is that 

14 these certification requirements wouldn't be 

15 finalized until the time of an energy 

16 conservation standards final rule. But DOE is 

17 proposing them at this point just to get feedback 

18 on whether they're appropriate for this group of 

~ products. 

20 MR. BROOKMAN: Nate, please. 

21 MR. MOUW: Okay. Just a question. This 

22 is Nate from Whirlpool. 

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1 There's a -- you had mentioned for ice 

2 makers that ice hardness would be a required 

3 certification. It seems like, as I read the 

4 NOPR, that was specific to continuous-type ice 

s makers. Is this requirement for both, or am I 

6 mistaken? 

7 MR. WATSON: This would only be a 

8 requirement for the ice makers that use it in the 

g test procedure. 

10 MR. MOUW: Okay. 

11 MR. WESTPHALEN: This is Detlef. 

12 As you suggest, the hardness would be 

13 required only for the continuous ice makers, 

14 which could have non-unity hardness. 

15 MR. WATSON: Any other additional 

16 comments at this point? 

17 (Pause.) 

18 MR. WATSON: To move into testing, it 

19 helps to know what type of product you're 

20 testing. So DOE is proposing clarifications for 

21 compartment and product determination type. DOE 

22 is proposing that the "compartment" definition 

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1 would specify that the term and test procedures 

2 denotes either an individual enclosure within a 

3 cabinet or all of the space within a cabinet that 

4 provides temperature storage in the same range. 

s So, the term is used kind of in two ways 

6 within the test procedures at this point. And 

7 DOE is proposing a "compartment" definition that 

s just clarifies that both ways are appropriate. 

9 DOE is also proposing a clarification 

10 that adjacent compartments require a subdividing 

11 barrier. So, if you have two different 

12 temperature zones within a compartment, those 

13 would not be considered separate compartments, 

14 even if they have different temperatures. You'd 

1s need to have a subdividing barrier in there for 

16 them to be considered separate. 

11 DOE is also proposing that if the 

1s subdividing barrier is moveable for testing, it 

19 would be placed in its median position. 

20 And then finally, as I've mentioned a 

21 couple of times, DOE is proposing to clarify that 

22 compartment temperatures would be determined at 

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1 72 degrees Fahrenheit, and this clarification 

2 would be included in Section 10 CFR 429 in with 

3 the certification requirements. 

4 (Pause.) 

5 MR. WATSON: Okay. So, now we're going 

6 to Jump into the actual testing of these products 

7 and compartments. We're starting off with cellar 

8 compartment, and these provisions also applied to 

g cooled cabinets. But this is kind of specific to 

10 if you're testing a warm compartment, these are 

11 the procedures you'd follow. 

12 So, first we have to define the "cellar 

13 compartment." As I mentioned before, it has the 

14 same temperature requirements as for a cooled 

1s cabinet. And you can see it has the same 2 

16 degree crossover, as long as the product operates 

11 as high as 60 degrees Fahrenheit. 

18 When testing cellar compartments, DOE is 

19 proposing to use a standardized compartment 

20 temperature of 55 degrees Fahrenheit. And this 

21 is consistent with existing regulations in 

22 California, in Canada, with the AHAM standard, as 

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1 well as DOE test procedure waivers. And DOE also 

2 conducted market research to see if this 

3 temperature was appropriate and found it to be 

4 right in the middle of the typical operating 

s range for these types of compartments. 

6 (Pause.) 

7 MR. WATSON: So, DOE requests comment on 

s whether that temperature is appropriate, 55 

9 degrees for cellar compartments, and on whether 

10 anybody has input as to whether "cellar 

11 compartment" is an appropriate term to define 

12 these warmer compartments. 

13 (Pause.) 

14 MR. BROOKMAN: Comments here? No? 

15 Yes, Joseph. 

16 MR. FONTECCHIO: Just a slight comment. 

17 When we talk about cellars or cooled cabinets, 

18 we're circling back to 72 degrees now. Are we 

19 saying that in the application of the test for 

20 these products, it's not going to be tested at 90 

21 degrees when you have a cellar compartment? Or 

22 how is that going to be done when you have a zone 

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1 that holds 39 and one that doesn't hold 39? Will 

2 it be tested at 90 degrees? 

3 MR. WATSON: Right. So we'll be getting 

4 into that. 

5 MR. FONTECCHIO: Okay. 

6 MR. WATSON: So, across the board, 72 

7 degrees is used as the ambient for determining 

8 compartment types. So that's where you would 

g check if it needs the temperature ranges included 

10 in the definitions. 

11 MR. FONTECCHIO: Okay. 

12 MR. WATSON: For testing, I wish I could 

13 say across the board it's at 90 degrees, because 

14 that would be easier. But for one product type, 

1s we're proposing testing at 72 degrees. And that 

16 would just be for the non-compressor cooled 

11 cabinets. Everything else would be tested at the 

18 90-degree ambient. And we'll get into the 

19 justifications for that in a couple of slides. 

20 

21 

22 

MR. FONTECCHIO: Thank you. 

MR. BROOKMAN: Additional thoughts? 

(No audible response.) 

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1 MR. WATSON: Another comment here from 

2 the Web, from Andrew Sullivan, asking, "What 

3 should the humidity setting be during testing?" 

4 I don't know that off the top of my head. 

s Detlef? 

6 MR. WESTPHALEN: This is Detlef. 

7 Control of humidity is a new concept in 

8 the discussion of DOE test procedures. Well, not 

g maybe -- I mean, humidity certainly is, for some 

10 test procedures, the ambient condition is 

11 specified at a humidity level. However, 

12 residential refrigerator test procedures do not 

13 specify what to do with internal humidity 

14 controls. And as I say, it's a new concept for 

1s residential refrigerators. 

16 The proposal doesn't have anything for 

11 that. DOE's general test procedures for 

18 refrigerators, refrigerator-freezers, and 

19 freezers do not have anything for that other than 

20 general guidance associated with user-operable 

21 features, which it's hard to say whether they 

22 would be fully applicable for something like 

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1 humidity control. 

2 So this is something that certainly we 

3 would like some comment on. It's not something 

4 that's part of this proposal. 

5 MR. BROOKMAN: Anything additional here? 

6 (No audible response.) 

7 MR. BROOKMAN: Okay. 

8 MR. WATSON: Okay. Continuing on with 

g the cellar compartment proposals. DOE is 

10 proposing that temperature sensor placement for 

11 cellar compartments be consistent with the 

12 specifications in the AHAM standard for wine 

13 chiller compartments. 

14 And I believe this is also consistent 

1s with the setups required for testing fresh food 

16 compartments. 

11 DOE is also proposing that cellar 

18 compartments with separate temperature controls, 

19 those would be tested as special compartments 

20 during testing if the cellar compartment makes up 

21 less than half the refrigerator volume. So if 

22 it's not a hybrid product, it's not a cooled 

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1 cabinet, then you would treat the cellar 

2 compartment as a special compartment, as included 

3 already in the existing test procedures for 

4 refrigerators and refrigerator-freezers. 

s DOE is also proposing to use temperature 

6 settings that are similar to the existing 

7 requirements. So the first test would be 

8 conducted at the median temperature setting. The 

g second test would be conducted at either the 

10 warmest or the coldest setting, depending on all 

11 of the average compartment temperatures at the 

12 median settings. 

13 So, if all compartments are cooler than 

14 the standardized compartment temperatures, the 

1s second test would be conducted at the warmest 

16 temperature setting. Otherwise, the second test 

11 is conducted at the coldest temperature setting. 

18 DOE then is proposing similar energy 

19 calculations to account for cellar compartments. 

20 So, consistent with the existing provisions for 

21 refrigerators and freezers, you take the results 

22 of the test at both the mid and either the cold 

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1 or the warm setting. Then you interpolate the 

2 energy use to the standardized compartment 

3 temperature. And DOE proposes that whatever 

4 compartment gives you the highest energy use be 

s used as the overall energy use for the product. 

6 So, that slide kind of covered a lot of 

7 bullet points in a row. Any comment on the 

8 temperature measurements, the appropriate control 

9 settings for cellar compartments, and the 

10 inclusion of cellar compartments and the overall 

11 energy-use calculation? 

12 MR. BROOKMAN: Joseph. 

13 MR. FONTECCHIO: Just to be clear, if the 

14 cellar compartment is less than 50 percent of the 

1s space, you do not need to measure it, because 

16 it's going to be controlled more so by the 

17 primary refrigerated space. 

18 MR. WATSON: Correct. And it would be --

19 it would need to be set at its coldest 

20 temperature setting, so the maximum energy use 

21 condition. And I think that's the current 

22 requirement for specialized compartments. 

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1 MR. FONTECCHIO: Thank you. 

2 MR. WESTPHALEN: This is Detlef. 

3 Just adding some clarification. If the 

4 cellar compartment of such a unit does not have 

5 control, then you wouldn't have to measure its 

6 temperature and you wouldn't have any set point 

7 to worry about. If it has a setting, it would be 

8 treated as a special compartment. And so as Troy 

g said, the coldest setting, unless it uses heat 

10 addition for any part of its control, in which 

11 case you average the coldest and warmest. 

12 MR. BROOKMAN: Okay. There's a lot of 

13 content here. Any additional thoughts, comments 

14 on these points? 

15 (No audible response.) 

16 MR. BROOKMAN: Nothing additional. Okay. 

17 MR. WATSON: Okay. For cellar 

18 compartment volumes, DOE is proposing to measure 

19 volume consistent with the current requirements 

20 for fresh food compartments. In determining 

21 adjusted volume from the total refrigerated 

22 volume, DOE is proposing that, in cooled 

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1 cabinets, the volume adjustment factor just be 

2 one. Those products are made entirely of cellar 

3 compartments. 

4 For hybrid products, however, the volume 

s adjustment factor would be 0.69, and that's based 

6 on the ratio of the difference between ambient 

7 temperature and standardized compartment 

8 temperature for both the cellar compartment and a 

9 fresh food compartment. 

10 And one thing to note here is this method 

11 is consistent with how the volume adjustment 

12 factor was determined for freezers and 

13 refrigerator-freezers, except that one is greater 

14 than one because there's a greater difference 

1s between a freezer compartment temperature and 

16 ambient, compared to the fresh food compartment. 

11 And then the final proposal here, if a 

18 compartment is capable of operating either as 

19 cellar, fresh food, and-or freezer compartment, 

20 DOE proposes that the highest energy-use position 

21 be tested. And that's consistent with the 

22 existing requirements for convertible 

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1 compartments in Appendix A. 

2 (Pause.) 

3 MR. WATSON: So again, request for 

4 comment here, the volume adjustment factors for 

s cooled cabinets and hybrid products. And then a 

6 request for comment on how to address these if 

7 they are convertible compartments. 

8 (Pause.) 

9 MR. BROOKMAN: Okay. No comments here? 

10 Okay. 

11 MR. WATSON: Okay. Now, moving those 

12 proposals all addressed cellar compartments 

13 specifically. Now we're moving to cooled 

14 cabinets, where we have a product that's 

1s consisting entirely of cellar compartments. So 

16 these, DOE considered appropriate ambient 

17 temperatures and the appropriate usage adjustment 

18 factor for these products. 

19 DOE notes that existing test procedures, 

20 the CSA and AHAM standards, use the 90-degree 

21 ambient and also apply usage adjustment factor of 

22 0. 8 5. So DOE conducted some testing both in the 

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1 lab and in the field to determine whether these 

2 conditions and usage factors are appropriate. 

3 You can see here that it looks like the 0.85 

4 factor may overestimate actual energy use. 

s When you look at operation in a typical 

6 room ambient of 72 degrees, compared to operation 

7 in the 90-degree ambient used for the test 

8 procedure, energy consumption is almost double. 

g In all cases, it was, on average, more than 

10 double, the energy use at 72 degrees Fahrenheit. 

11 So that suggests that that 0.85 usage factor may 

12 be too high for these types of products. 

13 However, one thing to note here is that 

14 the test results usage factors don't account for 

1s additional thermal loads for things like door16 openings or inserting warm food or drinks into 

11 the compartment. 

18 So based on that test data, DOE does 

19 propose to use a 90-degree ambient condition for 

20 vapor compression cooled cabinets. However, DOE 

21 would update the usage factor to a value of 0.55. 

22 And that's based on the average 0.46 ratio that 

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1 was shown in the laboratory test data. But it 

2 would be multiplied by a usage factor of 1.2 to 

3 account for those additional thermal loads. So, 

4 0.46 times 1.2 gives you the overall 0.55 usage 

s factor that DOE is proposing. 

6 So, I guess at this point it's a good 

7 spot to ask for comment on whether the 90 degrees 

8 Fahrenheit is appropriate for these cooled 

9 cabinets and whether the 0.55 is an appropriate 

10 usage factor. 

11 (Pause.) 

12 MR. BROOKMAN: Comments from here? If 

13 you think it's a good idea, it's okay to say so. 

14 (Laughter. ) 

15 MR. BROOKMAN: Charlie. 

16 MR. HON: Charlie Hon, True 

11 Manufacturing. 

18 You took an average of -- to get to 0.46, 

19 correct? But you also have some numbers that are 

20 substantially above that, 0.56, 0.53 on that 

21 chart. That's putting it in your an average 

22 may not be exactly what you would want to do it 

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1 statistically to come up with that number. I'm 

2 very concerned about that number, because if you 

3 do two sigma variation from those, where do you 

4 really fall? 

5 MR. WATSON: Just to clarify, are you 

6 suggesting --

7 MR. HON: I'm not sure that that 0.45 

8 MR. BROOKMAN: Charlie, turn your 

9 microphone on, please. 

10 MR. HON: I'm not sure that that factor, 

11 what you're using, 0.46 factor as an average of 

12 all those components, do you have statistical 

13 validity there? Because they look pretty much 

14 flat. There's no bell curve formation here that 

1s says, "This is truly a mean. " 

16 I see pretty flat numbers, which if you 

17 try to come up with some statistical validity 

1s there, there's not enough points to really do 

19 that and you really don't know where your long20 term mean would be because they're just pretty 

21 much you've got a couple of 0.40's, 0.56, 

22 0 . 5 3 . 

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90 
91 

1 So out of eight samples, when you have 

2 that big a variation, an average may or may not 

3 be statistically valid, just to come up with a 

4 number. You may need to have a bigger number 

s base so you can get a true understanding. Is it 

6 a skewed curve? Is it just a flat situation? I 

7 don't know where this comes from. 

8 MR. WESTPHALEN: This is Detlef. 

9 I guess, you know, let's kind of go 

10 through the discussion here and see whether we 

11 can get to a point where we can potentially have 

12 some suggestions that DOE could consider as 

13 alternative for the test. 

14 Now, historically, when residential 

1s refrigerator test procedures were initially 

16 developed, the approach to deal with the 

17 additional thermal loads was to use an elevated 

18 ambient temperature with closed doors. And there 

19 were some reasons for that. 

20 That approach was then extended to other 

21 products that -- such as freezers. And there was 

22 a recognition that, you know, the additional 

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1 thermal loads associated with freezers are 

2 overestimated by the 90-Fahrenheit ambient. And 

3 then, so the usage factors were applied to try to 

4 get back to what people thought were the right 

s values. 

6 For cooled cabinets that have vapor 

7 compression systems, they generally can maintain 

s their intended compartment temperatures in their 

9 90-Fahrenheit ambient because vapor compression 

10 systems have good capacity. And DOE is aware 

11 that the IEC has gone in that direction for 

12 cooled cabinets, using the 90-Fahrenheit ambient 

13 And part of the reason for sticking with that for 

14 the vapor compression cooled cabinets is to try 

1s to maintain that international harmonization. 

16 So then the question is, what is the 

17 appropriate adjustment factor? DOE conducted 

18 eight laboratory tests to get a sense for the 

19 difference between a 72-Fahrenheit and a 90-

20 Fahrenheit test. These are some numbers. If 

21 there are other numbers that people have that 

22 would lead us to what could be considered a 

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1 better number or a more accurate number, 

2 certainly, you know, that's information that we 

3 could use. 

4 Ultimately, I would submit that it makes 

s sense to select one particular number rather than 

6 to have the number vary based on the 

7 characteristics of the particular product. 

8 So I guess I'll leave it at that and see 

9 if there are other comments. 

10 MR. BROOKMAN: Yes. Joseph. 

11 MR. FONTECCHIO: It is based on history, 

12 right? So if the refrigerator didn't have an 

13 adjustment factor, an upright freezer has 0.85 

14 and a chest freezer has 0.7. So how did those 

1s numbers come to pass? Was it just the 

16 recommendation that there was enough door-opening 

11 -- or the infrequency of door-openings would de18 rate those adjustment factors? 

19 And now you've gone ahead and created a 

20 test paradigm, and you've come up with a number. 

21 It's different than the way the other two were 

22 assigned. And so, it's just a great gap from 

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1 where, let's say, Canada and the CEC had been 

2 monitoring for the last few years. 

3 So just, you know, want to see if this 

4 movement is based in reason compared to the way 

s the adjustment factor had previously been defined 

6 for those other categories. 

7 MR. BROOKMAN: Would you suggest either a 

s different method or a different factor? 

9 MR. FONTECCHIO: I mean, it's good to use 

10 real data. It's just that, is this depicted 

11 accurately enough for this segment in this short 

12 order of time? There are some concerns. 

13 MR. HON: This is Charlie Hon. 

14 I'm very concerned about just, you have 

1s eight pieces of data. That's not a statistical 

16 realm of the market. Eight individual tests 

17 where you would come up with a number. There are 

1s a lot more manufacturers out there, a lot more 

19 products out there than eight. 

20 So I'm concerned that maybe I don't know 

21 all the characteristics of each of the eight 

22 systems. Are they all identical systems? Do 

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1 they have differences in the way they were 

2 constructed, control systems? -- all of which 

3 would change that variable number. 

4 And you may be missing sectors of the 

5 market that you didn't test. I just am very 

6 uncomfortable with an eight-point data system 

7 which is changing national standards. 

8 MR. BROOKMAN: Well, what should DOE do, 

9 Charlie? 

10 MR. HON: Unfortunately, it's going to 

11 the correct answer is a lot of testing or a lot 

12 of data. And that's not easily attainable 

13 without an incurred cost. 

14 MR. BROOKMAN: Joseph, you were going to 

15 add on? 

16 MR. FONTECCHIO: In the NOPR, you 

11 describe how you use the energy allowance based 

1s on the California formula or the Canadian 

19 formula. And the two products you initially 

20 tested gave you this insight that the adjustment 

21 factor may be grossly overestimated. 

22 We really don't have any visibility, were 

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1 those products tested. Or what happens to 

2 products that aren't listed with California, 

3 their range of performance? Perhaps they don't 

4 pass the California values or the Canadian 

s values, so they're not exported and they're not 

6 sold into those states. 

7 I guess these eight that we sampled, do 

s they represent all of the products that are used 

9 in North America? Or is this just ones that were 

10 from Canada, approved in California? Where do 

11 these cabinets come from? 

12 MR. WESTPHALEN: This lS Detlef. 

13 The list of eight is described a little 

M bit more fully. I don't think the brand and 

1s names and models are given, but they're described 

16 more fully in the preliminary TSD. But they are 

11 from a range of products that are within the CEC 

~ database. 

19 They are all, as far as I know, all 

20 single-compressor, vapor-compression. There are 

21 different styles of evaporators and condensers 

22 represented, different sizes. 

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1 MR. BROOKMAN: Joseph. 

2 MR. FONTECCHIO: Just lastly, so there is 

3 the opportunity that there are other equipment 

4 that isn't in the CEC database that's not being 

s given a fair picturing with this. These are 

6 cabinets that have been known to be certified to 

7 a standard and are allowed for sale into Canada. 

8 But there are other cooled cabinets that 

9 are for sale that may or may not pass those 

10 standards today. 

11 MR. WESTPHALEN: My understanding is that 

12 there are very few cooled cabinets sold in the 

13 U.S. that are not sold in California and Canada, 

14 that we've had commentary in the past that, 

1s essentially, it's a North American market. 

16 But the other question I would have is, 

11 do you think the 0.55 is too high or too low? 

18 And if it is too high or too low, how would that 

19 -- would that be unfair to some of those 

20 manufacturers that might have products that are a 

21 little bit different? 

22 MR. FONTECCHIO: You know, probably 

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1 tomorrow, the 0.55 number comes back in the TSD. 

2 And that's what you use to normalize the CEC 

3 efficiency level to begin the efficiency level 

4 status. So, it becomes a very powerful factor 

s with assigning the range of cabinets and the 

6 different energy levels. 

7 So, I think it's good to have a 

8 conversation about where it came from, what's 

9 best, and how that number is used. 

10 In the example of adjustment factor, it's 

11 a very liberal number. But if that factor is 

12 used in a different realm to drop down the energy 

13 levels or efficiency levels, then it can be a 

14 very dangerous number because it's near half. 

15 MR. WESTPHALEN: This is Detlef again. 

16 So, looking at the overall picture, we're 

11 taking the test that they currently use, changing 

18 from 0.85 to 0.55. When we look at the energy 

19 conservation standard, we look at -- you know, 

20 and we'll get into this tomorrow. We look at the 

21 current California standard and call that sort of 

22 a CEC equivalent. You might think of it as a 

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1 baseline. And we adjust it in the same way. 

2 So, we're essentially talking about the 

3 same test; it's just a different number. We're 

4 using the conversion from 0.85 to 0.55 for both. 

5 Now, if we changed to a 72-Fahrenheit 

6 ambient test, then I think there might be winners 

7 and losers, because -- but that's not what we're 

s doing here. So I'm just trying to understand, 

9 you know, if there's a reason for your concern 

10 where I don't understand some unfairness that 

11 we're injecting into the system here that I 

12 should be understanding. 

13 So that's why I'm asking the follow-up. 

14 MR. HON: Our concern is basically that 

1s you're taking what was described as pieces of 

16 equipment that met the Canadian and AHAM's and 

17 the California standard. There are other pieces 

1s of equipment that are sold in the market away 

19 from those states or oblivious to those state 

20 regulations which may or may not be in your 

21 calculation factor here. 

22 So, instead of a 0.55 factor, you may be 

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1 putting on a 0.6 factor onto some equipment 

2 that's already presently in the market. We don't 

3 know the data on that because we have not --

4 everything we've tested would fall close to these 

s ranges. But we know that there are other people 

6 in the market who do -- are very small -- and a 

7 lot of these products are very small market 

s sectors compared to what we're looking at in home 

g refrigeration, certainly not the volume involved. 

10 But we just don't know the statistics of 

11 it because you're using a section of the market, 

12 which is the better section of the market, and 

13 there's another section above that which is less 

14 efficient that has not been put into your 

1s calculations. 

16 Because they had to have met a standard 

11 line here to be in California and Canada. There 

1s has to be there's a baseline there. But since 

19 this is presently a non-regulated national 

20 market, you've eliminated a lot of numbers here, 

21 which may impact your total viewpoint of the 

22 market. Just because California has a standard, 

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1 I don't know what percentage of product is not 

2 sellable in California. I don't know what's not 

3 sellable in Canada. 

4 But we're certainly now going to put --

s those products that are not sellable in 

6 California and Canada are now going to be huge 

7 decrease in energy consumption to meet any new 

s national standards. 

9 And from a viewpoint -- I'm just trying 

10 to be fair here, saying I don't know what the 

11 ramifications of the market are. Is it going to 

12 hurt our company tremendously? No. But it 

13 could. If we'd start playing some other, more 

14 specialized products with special features in 

1s them, these numbers could be very damaging. 

16 MR. WATSON: So if I could jump in, I 

17 think from what I understand, it sounds like this 

1s might be more of an issue in the standard side of 

19 things that we could address in tomorrow's public 

20 meeting, where those products might not fall in 

21 with the efficiency levels that we determine 

22 based on CEC data or something like that. 

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1 MR. HON: Right. Right. Charlie Hon 

2 again. 

3 But you've brought it up in this meeting, 

4 so it needs to be addressed in this meeting. 

5 MR. BROOKMAN: Yeah. The underlying 

6 comment, though, is the derivation of the factor. 

7 MR. HON: Yes. 

8 MR. BROOKMAN: Yes. Okay. 

9 I think we've covered this now. I'm 

10 ready to move on. If anybody objects to that 

11 let's move on. 

12 Joe. 

13 MR. HAGERMAN: Then you should say, too, 

14 that, you know, we welcome any data that you can 

1s provide to help us give us guidance on what that 

16 number should be, right? 

17 MR. BROOKMAN: Exactly. Yeah. 

18 MR. WATSON: And then, not to get back on 

19 the same topic, but we got a comment from the 

20 Webinar. 

21 

22 

MR. BROOKMAN: Yes. 

MR. WATSON: Asking where the 1.2 usage 

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1 factor came from. And that's supposed to 

2 represent loading and door-openings. And DOE 

3 lacks good data on what the usage factor would be 

4 associated with those door-openings. The 1.2 was 

s determined as the ratio of the usage factor for 

6 upright freezers compared to chest freezers. 

7 And the idea is that chest freezers 

s likely wouldn't have as many door-openings or as 

9 frequent loading of warm packages, whereas 

10 upright freezers would probably have more 

11 frequent door-openings. 

12 And DOE expects that the usage for cooled 

13 cabinets would probably be similar to upright 

14 freezers. So we took the ratio of those usage 

1s factors to try to separate out the door-opening 

16 and loading thermal load. 

17 MR. BROOKMAN: Charlie. 

18 MR. HON: Charlie Hon again. 

19 Do you have any average -- I'm trying to 

20 get a feel for this one. Do you have any what 

21 you would consider normal amount of door-openings 

22 in an 8- or 24-hour period in that logic? 

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1 MR. WATSON: No. So this is based on the 

2 existing usage factors in the freezers' test 

3 procedure in Appendix B. 

4 MR. HON: Right. 

5 MR. BROOKMAN: I would think the 

6 manufacturers have, whether they want to disclose 

7 it or not, data on what their expectations are of 

s usage patterns and the like. And, boy, it would 

g be most useful to disclose, whether it's under an 

10 NDA or however you want to do it, to provide that 

11 to the Department of Energy so they can get these 

12 usage factors close to the mark. 

13 I saw somebody else. Yes, Joseph. 

14 MR. FONTECCHIO: Just one more time. The 

1s 20 percent was the difference in what two values? 

16 MR. WATSON: So, the usage factors for 

11 upright freezers divided by the usage factor for 

1s chest freezers. And those are 0.85 and 0.7, 

19 respectively. 

20 MR. FONTECCHIO: So, it's difficult to 

21 -- we need a number to have for adjustment for a 

22 product that holds this temperature band. So 

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1 this 20 percent add-on now is related to those 

2 numbers that come from perceived door openings; 

3 is that correct? If a refrigerator has got one 

4 factor, the freezer has got 0.85 of it and the 

5 chest has got 0.7? 

6 So, previously, 0.85 was the number for 

7 California and Canada. And now we want to drop 

s down to 0.55? It's just hard to understand how, 

g what you did things before, to now completely 

10 switch to take part of it and then take the 

11 standard averaging number. Is it accurate? 

12 MR. BROOKMAN: It seems like we need to 

13 provide time for ya'll to develop these as 

14 written comments. 

15 MR. FONTECCHIO: Yes. 

16 MR. BROOKMAN: I don't think we're 

11 gaining ground on it now. I want to move on. 

18 MR. HAGERMAN: No, I agree with that. 

19 And you know, these are a starting point, right? 

20 So this is our methodology for coming up with, 

21 you know, a straw man, a bogey, whatever, right? 

22 Comment. 

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106 

1 MR. BROOKMAN: Yeah. 

2 MR. HAGERMAN: Give us data. 

3 MR. BROOKMAN: And the Department really 

4 appreciate your, yeah, detailed comments here. 

5 MR. WATSON: And two more comments from 

6 the Webinar. These are from Michele Crociani 

1 again. The first says that, "For some absorption 

s refrigerators at 90 degrees Fahrenheit ambient, 

9 it is impossible to work." 

10 And then the next also says that, "For 

11 chemical reasons, raising the ambient temperature 

12 is not the same as opening doors many times, 

13 because gas mixes are less performance at 90 

M degrees Fahrenheit." 

1s And I think the next section we're about 

16 to ]Ump into will address these comments, where 

11 we talk about the non-compressor cooled cabinets. 

18 MR. BROOKMAN: Okay. 

19 MR. WATSON: So, as the comments stated, 

20 certain technologies may not be able to operate 

21 in the 90-degree Fahrenheit ambient. So, DOE 

22 conducted testing on three non-compressor cooled 

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1 cabinets. And from that testing, DOE has a 

2 concern that testing at 90-degree ambient would 

3 not give representative results for those 

4 products. 

s So you could see here, DOE conducted the 

6 same testing at 72 degrees and 90 degrees. And 

7 there wasn't a consistent ratio of energy use 

s between those two ambient temperatures like we 

g saw for the compressor products. 

10 So for these, it varies widely. For the 

11 first product there, it used over four times as 

12 much energy at the warmer conditions. For 

13 product 3, it uses just about the same amount of 

14 energy in both conditions. 

1s And the reason for this, it's because few 

16 units are actually able to maintain the 55-degree 

17 temperature at 90 degrees. So, for example, unit 

18 3, it looks like it was already working as hard 

19 as it could to maintain compartment temperatures 

20 at the 72-degree Fahrenheit. When the ambient 

21 was increased to 90, compartment temperatures 

22 increased, it was still working just as hard. 

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1 And that's why you end up with the same energy2 use result. 

3 So based on these test results, DOE feels 

4 that it's not appropriate to test non-compressor 

s cooled cabinets at the same 90-degree Fahrenheit 

6 condition. Instead, it is proposing to test 

7 these products at 72 degrees Fahrenheit. 

8 And then, the only usage adjustment 

9 factor that would need to be applied there is for 

10 the door-openings and the warmer loading. And 

11 that would be the 1.2 that we discussed on the 

12 last slide. 

13 MR. BROOKMAN: Comments here? 

14 MR. WATSON: I'll leave it on this slide. 

1s But, yeah, any comments on the non-compressor 

16 cooled cabinet proposal? 

11 (No audible response.) 

18 MR. BROOKMAN: Charlie. 

19 MR. HON: I'm looking at these numbers. 

20 And this is a bit of a quandary. I'm going to be 

21 looking at this from a food-safety standpoint. 

22 Okay. 

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1 If you're not capable, you do not have 

2 any excess capacity built into your system, as 

3 your numbers here indicate, there's very limited 

4 capacity on some of these other pieces of 

s equipment so that they cannot cope with an 

6 increase in temperature. Yet, we're allowing for 

7 warm product to be put inside the cabinet. 

8 Have you done any discussions as far as 

9 how -- basically, to do it safely, you have to 

10 figure out -- okay. Normally, if a warm product 

11 is put into a refrigerator and brought to safe 

12 food temperature, you want about a four-hour 

13 maximum time window for food-safety reasons. 

14 Yet, from these numbers, I'm seeing the 

1s fact that these products, some of these products 

16 may not have enough capacity to cool down non17 previously-refrigerated product for a very 

1s extended period of time, because the capacities 

19 are just not there in those numbers. 

20 MR. WATSON: Just to clarify here, this 

21 is specifically for cooled cabinets. 

22 MR. HON: I see. 

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1 MR. WATSON: So the target temperature in 

2 these is 55 degrees Fahrenheit. 

3 MR. HON: Right. Okay. 

4 MR. WATSON: So, the same provisions for 

s excess load might not be included in these 

6 products as for other refrigerators. 

7 MR. HON: Okay. Because it's really 

s marginal stuff to get to 55 here. 

9 MR. BROOKMAN: Do we have any additional 

10 there's a request for comment. Additional 

11 thoughts, questions, comments on this content? 

12 (No audible response.) 

13 MR. WATSON: Okay. Another proposal for 

14 cooled cabinets here. This one is regarding 

1s light bulb energy use. So, DOE is aware that 

16 there are some differences regarding how this 

17 would be addressed in testing. The CSA standard 

1s requires that the light bulb would be tested on 

19 and off, and then the results averaged. 

20 The AHAM standard, which is referenced by 

21 Appendices A and B, requires that features that 

22 are not required for normal operation be set in 

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1 their lowest energy-use state. So in that case, 

2 it would be off. 

3 And LBNL further conducted a survey to 

4 investigate light bulb energy use and found that 

s consumers leave the light switch off in 90 

6 percent of products. 

7 So, based on these survey results and for 

s consistency with the AHAM standard, which is 

g referenced in Appendices A and B, DOE is 

10 proposing to test cooled cabinets with the light 

11 bulb switch off, or in the lowest energy-use 

12 position if there's no hard on-off switch. 

13 DOE requests comment on this proposal. 

14 MR. BROOKMAN: So, we ought to be able to 

1s get a comment yea or nay on this, yes? 

16 MR. FONTECCHIO: We like this one. 

17 (Laughter. ) 

18 MR. BROOKMAN: Thank you, Joseph. I hate 

19 to force your hand. 

20 Other comments from stakeholders on this 

21 one? 

22 (No audible response. ) 

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1 MR. BROOKMAN: Okay. 

2 MR. WATSON: Okay. So that wraps up 

3 cooled cabinets. 

4 Now we're moving on to the non-compressor 

s refrigerators. 

6 MR. BROOKMAN: Joanna Mauer has a 

7 question or a comment. 

s Joanna, please. 

9 MS. MAUER: Going back to the testing of 

10 cooled cabinets, it seems to us that it would be 

11 much better to test all cooled cabinets under the 

12 same ambient temperature conditions, so both 

13 vapor compression, as well as thermoelectric 

14 products. 

1s And our initial thought, at least, is 

16 that it would be better to test all products at 

11 72 degrees. We recognize kind of the benefits of 

1s harmonization and the precedent of testing 

19 refrigerators at 90 degrees. But 72 degrees is 

20 certainly much more representative of how these 

21 products are actually used in the field. 

22 MR. BROOKMAN: Okay. Thank you, Joanna. 

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1 MR. WATSON: And just to clarify there, 

2 when you say "test all products at 72," are you 

3 referring to just these new proposals that DOE 

4 has included in this NOPR? As opposed to the 

s existing tests for refrigerators and 

6 refrigerator-freezers? 

7 MS. MAUER: So I don't have a specific 

s comment now. I mean, I think it certainly raises 

g the question going forward of whether it would 

10 make sense to test all types of refrigerators and 

11 freezers at 72 degrees to better represent field 

12 conditions and something that we can think more 

13 about. 

14 MR. BROOKMAN: Okay. 

15 MR. WATSON: Thank you. 

16 Okay. So on to non-compressor 

17 refrigerators. 

18 The first issue, again, is ambient 

19 temperature. And here, DOE notes that it expects 

20 consumers to use non-compressor refrigerators in 

21 the same way that consumers would use existing 

22 refrigerators or refrigerator-freezers. 

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1 So, because the 90-degree Fahrenheit 

2 ambient condition is supposed to account for 

3 consumer usage, DOE is proposing to apply that 

4 again for non-compressor refrigerators. And then 

s these would then have a usage adjustment factor 

6 of 1.0, because the intent is for the ambient at 

7 90 to capture all of the usage factors. 

s One thing to point out here is that DOE 

9 tested several of these non-compressor 

10 refrigerators and found that, at an ambient 

11 temperature of 90 degrees, none were capable of 

12 maintaining internal compartment temperatures 

13 near 39 degrees Fahrenheit. And I think they all 

14 were 8 or 9 degrees, at least, higher than that. 

15 MR. BROOKMAN: Wow. 

16 MR. WATSON: So, to account for this in 

11 testing, DOE considered use of the extrapolation 

1s approach that's currently in Appendices Al and 

19 Bl. These are the older test procedures where, 

20 under testing, compartment temperatures don't 

21 reach the target value, but those test procedures 

22 would use an extrapolation to work back to the 

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1 standardized compartment temperatures. 

2 However, for these non-compressor 

3 refrigerators, a lot of times using that 

4 extrapolation approach results in unreasonable 

5 energy-use values. So DOE found it wouldn't be 

6 appropriate in these cases. 

7 So, given that, DOE proposes that nons compressor refrigerators that aren't capable of 

9 reaching that standardized compartment 

10 temperature, they would only be tested at the 

11 cold setting. And then the energy use as 

12 measured at that setting would be the result for 

13 that unit. 

14 Then, because the compartment 

15 temperatures aren't reaching the 39-degree 

16 Fahrenheit, DOE felt that it should be noted 

11 somewhere. So DOE is proposing that the 

1s compartment temperature maintained during testing 

19 be reported in the certification report. 

20 And another thing to point out here, even 

21 though the compartment temperatures aren't 

22 reaching the 39-degree at the 90-degree ambient 

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1 condition, these products would maintain that 

2 compartment temperature in an ambient of 72 

3 because they would be required to do that to even 

4 fall under this category of non-compressor 

s refrigerator. 

6 MR. BROOKMAN: Charlie. 

7 MR. HON: Charlie Hon. 

8 Question for you. You're saying that 

g they would be required to include in their report 

10 that they couldn't maintain 39 degrees Fahrenheit 

11 in here. But is there any warning labeling being 

12 considered to warn customers that if they would 

13 apply these in other than the 72-degree 

14 environment, they could be jeopardizing food 

1s safety? 

16 MR. WATSON: Not in this proposal, but I 

17 think that would be an issue for FTC or something 

~ other than DOE. 

19 And on the standard side of things, 

20 that's something that we'd welcome coming on as 

21 regarding consumer utility and things like that. 

22 MR. HON: I have a serious concern about 

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1 that because the theoretical 72 is a nice thing. 

2 But you get into elderly people, and they don't 

3 keep their buildings at 72 degrees. There are 

4 people who don't have air conditioning. There 

s are people that put units in garages. So this is 

6 -- this scares me. Because these are compressor 

7 refrigerators. They're not a 55-degree 

s temperature. 

9 MR. WATSON: Just to clarify, these are 

10 non-compressor refrigerators. But, yeah, they 

11 would be considered refrigerators. 

12 MR. HON: Non-compressor refrigerators. 

13 They would be considered refrigerators capable of 

14 protecting food. Am I correct here? 

15 MR. WATSON: Yeah. And just to clarify, 

16 this is based on products that are already out 

17 there. So this is based on what's on the market. 

18 MR. HON: Okay. 

19 MR. WATSON: Any additional comments on 

20 the proposal for non-compressor refrigerators? 

21 (No audible response.) 

22 MR. BROOKMAN: Okay. 

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1 MR. WATSON: Now, another proposal 

2 addressing non-compressor products. The current 

3 Appendices A and B require test periods, 

4 stabilization periods, temperature-averaging 

s periods that are based on complete compressor 

6 cycles. However, because these types of products 

7 don't have compressors, those terms aren't 

8 appropriate. 

9 So DOE proposes to clarify that, in the 

10 test procedures where there's a reference to 

11 compressor cycles, that applies to both a 

12 compressor cycling, as well as just a 

13 refrigeration system cycling. And the same 

14 requirements would be applied to both compressor 

1s units and non-compressor units. 

16 Any comments there on whether that's an 

17 appropriate clarification? 

18 (No audible response.) 

19 MR. WATSON: Okay. And we're going back 

20 to the extrapolation approach for products other 

21 than the non-compressor refrigerators. So 

22 MR. BROOKMAN: Let me just pardon me 

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1 for interrupting. 

2 MR. WATSON: Sure. 

3 MR. BROOKMAN: Let's get a read on where 

4 we are. We've been at this for two hours now. 

s We're a little more than halfway through the 

6 slides at this point. We're going to take a 

7 break for lunch here before too long. 

s I'm wondering whether we want to keep 

9 doing this for another little bit or whether we 

10 want to break shortly. What is your general 

11 sense? Two hours is typically about the 

12 attention span of most extraordinary humans. So 

13 before long, we're going to have to take a break. 

14 Do you want to keep going right now, or 

1s do you want to take a break for lunch right now? 

16 MR. HAGERMAN: You know, Doug also forgot 

11 to tell you that we have a wonderful cafeteria. 

~ (Laughter.) 

19 MR. BROOKMAN: We do have a good 

20 cafeteria here. 

21 Yes? 

22 MR. GOPAL: Yeah, I think the agenda said 

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1 12: 3 0 I SO - -

2 MR. BROOKMAN: Okay. So we'll stick with 

3 the agenda then. We'll go till about 12:30. 

4 We'll go for a little while longer. 

s I'm noting that some of the complicated 

6 concepts here, we're not getting as much comment 

7 as we might if we were fresh, is my hypothesis. 

s But let's plug on for a little bit 

g further. Okay. Keep going. 

10 MR. WATSON: Okay. So, back to the 

11 extrapolation approach. 

12 Now that DOE is proposing that the 

13 product types be determined under a 72-degree 

14 ambient temperature condition, certain products 

1s might run into not meeting the standardized 

16 temperatures at the 90-degree ambient temperature 

17 during testing. 

1s So, previously, based on the interim 

19 final rule in 2010, these products would just 

20 receive no rating if they couldn't maintain the 

21 standard temperatures at 90 degrees Fahrenheit. 

22 But now, with the clarification, these products 

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1 would receive ratings, and DOE is proposing a 

2 method to attribute an appropriate energies to 

3 these products. 

4 So, DOE is proposing to use the same 

s extrapolation approach if products are not able 

6 to maintain the standardized temperatures at 90 

7 degrees Fahrenheit. And this would apply to all 

8 the products other than those non-compressor 

g refrigerators that we just discussed. 

10 Also, one thing to note here is that DOE 

11 is proposing a couple of restrictions on this 

12 calculation, where the warm test must have the 

13 higher temperature and it must have lower energy 

14 use compared to the test at the cold settings. 

1s And this prevents the wildly inaccurate energy16 use representations from the extrapolation. 

17 Any comments here on whether that 

18 approach is appropriate? 

~ (Pause.) 

20 MR. BROOKMAN: No comments. Okay. 

21 MR. WATSON: All right. Now we'll move 

22 on to hybrid products. 

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1 This is all pretty similar to what we've 

2 gone over for the other units. . . DOE is proposing 

3 a 90-degree ambient temperature for these 

4 products. And while we had the 72-degree ambient 

s for the non-compressor cooled cabinets, all of 

6 the hybrid products, by definition, have at least 

7 one or more fresh food compartments or freezer 

s compartments. So the 90-degree ambient 

9 temperature would be appropriate for these. 

10 DOE is proposing a usage adjustment 

11 factor of 0.85 for these units. And that's 

12 because DOE expects their usage to be similar to 

13 that of cooled cabinets, because at least half of 

14 the product is made up by a cellar compartment. 

1s And then DOE is proposing the same logic 

16 and energy-use calculation for testing these 

11 products. For temperature control settings, it 

1s would be the same, where you used the median 

19 setting for the first test. Based on the results 

20 of that test, you would then use either the warm 

21 setting or the cold setting for the second test. 

22 And then, DOE is proposing the same 

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1 interpolation calculation, or extrapolation if it 

2 cannot maintain the compartment temperatures. So 

3 you'd use the results of the mid, cold, or warm 

4 tests to extrapolate or interpolate to the 

s standardized compartment temperature to determine 

6 the overall energies for hybrid products. 

7 So, nothing too unique for hybrids, but 

8 it pulls together some of the proposals for other 

g products. Any comments on these? 

10 MR. BROOKMAN: Yes, Joseph. 

11 MR. FONTECCHIO: Just to clarify. So, 

12 hybrid means more than 50 percent is in the 55-

13 degree range. So, 0.85 is used in this example 

14 as the adjustment factor for a product that's 

1s majority above or in the 55-degree range. Cooled 

16 cabinets, it's 100 percent, and we're currently 

17 using 0.55. 

18 So, there is another rift here between a 

19 product that's, in essence, doing the same thing, 

20 albeit there's a percentage of space at that 

21 temperature band. But the usage factor is a 

22 drastic proportion different. 0.85, if it's good 

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1 enough for the hybrid, seems to be -- if it's 

2 based around the usage, which is the door3 openings for a 55-degree machine, then the cooled 

4 cabinets should harmonize. This would be the 

s proposal. 

6 MR. BROOKMAN: Okay. 

7 MR. WATSON: Just one point to clarify on 

s that is the usage factors account for both the 

g door-openings in consumer usage, as well as 

10 scaling back to the expected energy use at the 

11 72-degree Fahrenheit ambient. 

12 For cooled cabinets with compressors, 

13 there's a bigger energy hit in going from 72 to 

14 90 degrees, because the compartment temperatures 

1s are at 55 degrees Fahrenheit. So when you're 

16 comparing that to the ambient, you're jumping 

11 either 55 to 72, or 55 all the way up to 90. 

1s There's a bigger delta T there. 

19 So for these hybrid products, at least 

20 one compartment in the product has a lower 

21 temperature, either fresh food or freezer. So 

22 for those systems, it's a bit less of a hit 

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1 jumping from 72 to 90 degrees ambient. So for 

2 that reason, the usage factor is higher. 

3 And if there's any data that would 

4 provide a better indication of what it should be, 

5 DOE definitely welcomes that. 

6 MR. BROOKMAN: Joseph? 

7 MR. FONTECCHIO: That's a great 

s explanation. It's about the definition, right? 

9 And if greater than 50 percent makes it a hybrid, 

10 then remaining portion is what you're using to 

11 rate up the adjustment factor, because it's 

12 colder than 55. 

13 So maybe the number should be, instead of 

14 55 based upon sampling cabinets that may or may 

15 not have been universal for all products in the 

16 U.S., then it mirrors how this number came to 

11 pass. So a percentage of 0.85 to account for the 

1s 100 percent being at 55. 

19 MR. BROOKMAN: Okay. Additional thoughts 

20 here, comments? 

21 

22 

(No audible response.) 

MR. BROOKMAN: Okay. 

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1 MR. WATSON: Okay. Now I'll turn things 

2 over to Detlef to go over the ice makers. 

3 MR. BROOKMAN: We're at a natural break 

4 point. Let's go to lunch. 

5 (Laughter.) 

6 MR. BROOKMAN: Let's go to lunch, yes. 

7 It's about 10 minutes after 12:00. We'll resume 

s here at 10 minutes after 1:00. 

9 Most of you are familiar with the way 

10 this works here in the Forrestal Building. You 

11 must have this badge visible. This room will be 

12 secured. You can leave your stuff here. 

13 There are restrooms I didn't say it 

14 this morning -- on both ends of the hall. 

1s Because we haven't left here yet this morning. 

16 To get through the security portal at the 

11 big cafeteria, which is down to the ground floor 

1s and about 100 yards in that direction, you might 

19 need an ID to get back through the security 

w portal. 

21 But otherwise, I think we made good 

22 progress today already. And we'll continue that 

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1 when we resume at 10 minutes after 1:00. 

2 MR. HAGERMAN: You should also say if you 

3 don't want to go to the cafeteria, there's a 

4 Subway down at the same place you got Dunkin 

s Donuts. It's a lot easier to get to than walking 

6 through the -- underneath the 

7 MR. HON: Visitors have to go through 

s security coming back from the cafeteria. 

9 MR. HAGERMAN: Ah, that's right. 

10 MR. BROOKMAN: Yeah, they do. But since 

11 you've got a badge, it's easier. Yeah. 

12 Okay. We'll see you back here to start 

13 up at 10 minutes after 1:00. 

14 (Whereupon, at 12:13 p.m., a luncheon 

1s recess was taken, to resume at 1:15 p.m.) 

16 AFTERNOON SESSION 

17 MR. BROOKMAN: Okay, thanks for being 

1s back on time from lunch. Let's resume. And 

19 Deter is up there -- Detlef, pardon me -- is up 

20 there to present. 

21 Sir, I apologize, Detlef. 

22 MR. WESTPHALEN: Thanks, Doug. 

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1 MR. HAGERMAN: He has a new nickname now. 

2 We have Deter. 

3 (Laughter.) 

4 MR. BROOKMAN: I've got a buddy; pardon 

s me. I got confused. Go ahead. 

6 MR. WESTPHALEN: Okay. I'll be talking 

7 about ice makers and then some of the additional 

8 incidental items and other EPCA requirements that 

g are further on in the discussion. 

10 But first of all, ice makers. So, DOE is 

11 proposing test procedures for ice makers. And 

12 that starts with proposing some definitions. 

13 Some of these definitions borrow from the 

14 commercial ice making world. Some are new, 

1s because there different variations within the 

16 residential ice making space. 

17 So the following definitions describing 

18 the ice makers would be included in 430.2, that 

19 section of the CFR. First of all, "batch type, " 

20 this is an ice maker that makes its ice in cycles 

21 with alternating freezing and harvesting periods. 

22 A "continuous-type ice maker, " which continuously 

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1 makes ice, has sort of a combined evaporator2 auger type assembly that extrudes the ice out of 

3 the top. 

4 The next two terms, "cooled storage" and 

s "uncooled storage," refer to particular types of 

6 ways the ice maker deals with whether it keeps 

7 the ice cold, and also with how it makes the ice. 

8 A "cooled storage ice maker" is more or 

9 less, on the surface of it, a freezer in which 

10 you have sort of residential-style crescent 

11 automatic ice maker in it, maybe enhanced for 

12 higher capacity. But the whole space is kept 

13 cool, including the bin, and the ice does not 

M melt after it's made. 

1s The "uncooled storage ice maker" is a 

16 type a little bit more similar to commercial11 style ice makers, where the cold is applied 

18 directly to what you might consider the ice mold. 

19 The water sort of trickles over the cold 

20 evaporator and freezes. And then, once the ice 

21 is harvested and dropped into the bin, the bin 

22 itself is not kept cold. It's just the 

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1 evaporator ice mold portion that's kept cold by 

2 the refrigeration system. 

3 "Portable ice maker" refers to an ice 

4 maker that does not require a connection to a 

s water inlet and has a reservoir onboard that will 

6 be filled manually in order to provide the water 

7 supply. 

s For test procedures, DOE proposes to 

9 establish new test procedures for ice makers at 

10 10 CFR 430.23(ee) and also to establish a new 

11 Appendix BB that will have some of the detailed 

12 test procedures with it. 

13 And it should be mentioned that the 

14 testing is substantially different than the 

1s testing for many of the other products that we 

16 talked about this morning. Hence, DOE is 

11 proposing establishing the new appendix rather 

1s than trying to fit this into the existing 

19 Appendices A and B. 

20 Some definitions associated with the test 

21 procedure itself. And in this particular page 

22 here, we have a typo. In the "harvest" 

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1 definition, I believe it's correct in the notice. 

2 "'Harvest' means the process of freeing or 

3 removing ice pieces from an ice maker, ice making 

4 mold, or evaporator." 

5 I'm not going to read through all of 

6 these definitions. I think many of them are 

7 self-explanatory. The purpose of proposing them 

8 and putting them in the regulations is to try to 

g get some clarity for them. 

w But I will talk about the "ice making 

11 cycle" definition. It's defined for batch-type 

12 ice makers, which undergo an ice-making cycle. 

13 And it refers to "the period of time required to 

14 produce and harvest one batch of ice," and it is 

1s defined to start shortly after a harvest or 

16 immediately after a harvest, and then continue on 

17 to the end of the next harvest. 

~ A "replacement cycle" is defined for 

19 uncooled-storage ice makers, including portable 

20 ice makers. And this definition is associated 

21 with the measurement of the ice storage energy 

22 use, which we'll get to a little bit later, when 

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1 there isn't any active ice production going on to 

2 fill the bin. It's just the ice maker responding 

3 to some meltage in the bin and replacement cycle 

4 to refill the bin to its full level. 

s And basically, it refers to a period of 

6 operation of ice making, either with a continuous 

7 ice maker, a continuous cycle, or a continuous 

s operation with a batch ice maker, one or more 

9 series of ice making cycles until the bin sensor 

10 is satisfied again and the ice making stops. 

11 I think at this point we have two 

12 requests for comments, requesting comments on the 

13 proposed definitions to this point. 

14 MR. BROOKMAN: Comments? 

15 Yes, Sriram. 

16 MR. GOPAL: Yeah, I alluded to this 

11 earlier, but I think we have a real issue with 

1s including ice makers in this rulemaking at all. 

19 We feel that these are such different products 

20 that, you know, they really should be a category 

21 unto themselves. And if they were made a 

22 category unto themselves, we don't feel that the 

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1 energy savings are there to warrant any kind of 

2 energy-related regulation on them. 

3 And we'll be making comments to that 

4 effect in our written comments. 

5 MR. BROOKMAN: Thank you. Are you 

6 suggesting that they wouldn't -- in the event 

7 that they, energy efficiency regulations, were 

s established, that the efficiency level is high 

9 enough already that it wouldn't make a 

10 difference? 

11 MR. GOPAL: I'm saying the savings just 

12 aren't there. Even if you were to increase the 

13 number of units that are in the field, that the 

14 energy savings aren't there to warrant regulating 

1s them. 

16 

17 

18 

19 

20 

21 

22 

MR. BROOKMAN: Okay. 

Additional comments? There are a lot of 

definitions here. Additional comments on any of 

these? 

Charlie. 

MR. HON: Yeah. I have one comment on --

where is my 

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1 (Pause.) 

2 MR. HON: Okay. You have batch-type ice 

3 makers. There's basically two different batch4 type ice makers, one which is a fill-the-trough 

s and let the water sit and freeze. 

6 The second is a cascade water across the 

7 top of it, which is it does two things. 

s Number one, it removes minerals from the ice 

9 because the minerals stay in the liquid. You 

10 actually get the purer water freezes against the 

11 coils, and the minerals tend to wash off and are 

12 ejected down a drain. 

13 And that gets into discussions, secondary 

14 discussions on water efficiency, because you 

1s always have a certain amount of high-mineral 

16 water being flushed down the drain after each 

11 cycle. 

18 The second is the type of ice. Because 

19 when you do that, when you run the cycles with a 

20 cascade waterfall effect, you end up with a very 

21 high-quality ice without mineral content in it. 

22 And it is very clear and precise-looking and has 

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1 a market application because of the nature of the 

2 cube that comes out of it. 

3 So they are totally different in the way 

4 they work, and there are major differences in the 

5 amount of energy consumed because of the 

6 different technologies. 

7 MR. BROOKMAN: Are you suggesting that 

s there should be two batch-type definitions? 

9 MR. HON: It could easily be split in 

10 half. The majority of the products in the home 

11 market, depending on where your application may 

12 be -- because if you go to California and water 

13 restrictions, they don't want the cascade-type 

14 products because you lose 20 to 30 percent of 

15 your water down the drain on every cycle. 

16 MR. BROOKMAN: Okay. Okay. 

17 MR. HON: But because you've chilled that 

1s water, too, you have to dump out cold water. So 

19 it's a different beast. 

20 MR. BROOKMAN: Um-hrn. Okay. Thanks, 

21 Charlie. 

22 John Myers is apparently -- who has a 

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1 comment or a question, who is joining us online. 

2 John, speak and we'll hope to hear you. 

3 MR. MYERS: Yes. This is John Myers, 

4 Manitowoc Ice, Manitowoc Food Service Group. 

s I concur with those statements, primarily 

6 the fact that these devices should be removed 

7 from scope due to the relatively low sales volume 

s and potential savings in energy. 

g And then also, the fact of the categories 

10 included are so different with respect to a spray 

11 ice or cascading ice type making versus a static 

12 ice making. It's -- there are so many different 

13 product categories within this that it's not 

14 nearly as clear-cut as other products that have 

1s been discussed today. 

16 MR. BROOKMAN: Thank you. So your first 

11 comment, you're joining Sriram's comment about 

1s including ice makers? 

19 MR. MYERS: Correct. 

20 MR. BROOKMAN: Okay. Thank you. Just 

21 wanted to clarify. Great. 

22 Other comments on all of these 

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1 definitions before we move on? 

2 (No audible response.) 

3 MR. BROOKMAN: Okay. 

4 MR. WESTPHALEN: Well, I guess, if I can 

s ask a follow-up question, Charlie? To the extent 

6 that there are these two different styles of 

7 batch ice makers, would the additional 

s description of cooled storage versus uncooled 

9 storage not be sufficient in order to give an 

10 indication of how those ice makers are different? 

11 And I guess I would then follow up, I 

12 mean if you don't have a full response on this 

13 now, I can understand. But maybe in the written 

14 comments, make some suggestions as to what kind 

1s of additional terminology perhaps should be used 

16 in order to complete that distinction. 

17 MR. HON: Right. I would think it would 

1s -- this is Charlie Hon again. 

19 I would think that it's basically my 

20 comments are particular to batch type. Cooled or 

21 uncooled storage is a separate category 

22 completely. You can have cooled or uncooled bin 

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1 storage with either type of ice you make. So 

2 they're really -- they're completely unrelated in 

3 the way you make it. 

4 The only question is uncooled or cooled 

s bin storage. Cooled bin storage will give you a 

6 different approach because you have a secondary 

7 situation. You know, are you going to run a 

8 refrigeration coil to keep the bin cold? And 

g that gets into some semantics on how that 

10 happens, whether it's efficient or inefficient 

11 highly arguable. 

12 Also, how much consumption of ice you 

13 have, because if you're a high-volume consumer of 

14 ice and you empty your bin three fourths of the 

1s way down, an uncooled bin storage isn't 

16 efficient, more efficient than a cooled bin 

17 storage. But if you're a light user and have a 

18 large full bin most of the time, when you have a 

19 cooled bin, that is the more efficient method. 

20 So you've got balancing acts here you're 

21 playing from one product to the other. And you 

22 don't know what your market is. In the batch ice 

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1 machines, you know that you have high water 

2 usage, low water usage, and also increased power 

3 consumption. But you get a higher-quality 

4 product out of it. 

s And so, every one of these is a separate 

6 category. So there's a lot of categories here 

7 that you have to consider what are we doing. 

s Because we could have a batch-type cascade system 

9 with an uncooled storage bin. You could have the 

10 batch-type cascade system with a cooled storage 

11 bin. 

12 So you don't know, because most all 

13 residentials are a one-piece unit. You don't get 

14 to be the commercial where you put the ice 

1s machine on top; that's a separate category. The 

16 bin below it is a separate category, because you 

17 can mix and match in the field. Residentials are 

~ not like that. 

19 MR. BROOKMAN: Okay. Great. Thanks, 

20 Charlie. 

21 Yes. 

22 MR. MOUW: Yeah, I just want to concur 

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1 with Charlie's statement on the discussion about 

2 the ice quality. 

3 You know, many of us may not be familiar 

4 with it, but the cascading type presents a very 

s different ice than the non-cascading type. And 

6 it's a "utility," I guess is the word we should 

7 describe it as. It's a utility that our 

8 consumers desire and pay for. And so it is 

9 different. And as a result of that increased 

10 utility, there is an impact on energy 

11 consumption. 

12 MR. BROOKMAN: Okay. 

13 MR. MOUW: so I think we want to 

14 recognize that not just as, you know, a talking 

1s point, but as a mention of consumer utility, 

16 because it is a very different consumer utility 

11 for the cascaded ice. 

18 MR. BROOKMAN: Okay. Thank you, Nate. 

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

20 Not to put ya'll on the spot, that ya'll 

21 have been very thoughtful in your comments. Do 

22 you share the concern that the shipment volumes 

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1 of these are so low that we shouldn't be talking 

2 about this? I mean, you just articulated all 

3 these different, you know, consumer features and 

4 this desire to have this ice. But then we also 

s hear that, "Oh, well, there's not a lot of these 

6 being sold." 

7 So, you know, it's sort of a -- you know, 

8 it's sort of a mixed message sometimes, right? 

9 I'm just trying to understand that for my own 

10 MR. HON: I do not know from your 

11 standpoint what would be a low-volume product. 

12 How many kilowatts are we going to save? How 

13 many units are sold? I don't know. 

14 MR. HAGERMAN: That was my follow-up 

1s question. Do you also share the belief that the 

16 products that are being sold right now are as 

17 energy efficient as they can possibly be made? 

18 MR. HON: My opinion is that there are 

19 almost every product in the market, including 

20 commercial refrigeration, residential 

21 refrigeration, everything else, there is a -- no 

22 one is making the perfect unit. There's always 

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1 some improvements that can be made. But you have 

2 cost-benefit ratios. 

3 MR. HAGERMAN: Yes, sure. Absolutely. 

4 Notwithstanding that, of course. 

5 MR. HON: Do I believe that our market, 

6 that everybody is making the most efficient 

7 units? Of course not. There are certain 

s commodity products which are driven by cost. 

9 Like we're discussing here, a high-utilities ice 

10 machine 

11 MR. HAGERMAN: Ice machine, right. 

12 MR. HON: -- which is clear, crystal ice, 

13 which people really want if they're taking 

14 bottled water and pouring it on top of it, to not 

1s introduce the minerals from the tap back into 

16 your system. That has a utility factor. 

17 But it also has a negative effect on 

1s energy. It also has a negative effect on water. 

19 MR. HAGERMAN: Right. 

20 MR. HON: So, how do I answer that 

21 question? I don't know. 

22 MR. MOUW: This is Nate, from Whirlpool. 

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1 I'll just maybe add a few comments. I 

2 think, depending on what question you're asking, 

3 I think what Sriram, I guess maybe we can 

4 clarify from an AHAM perspective. But, you know, 

s in your TSD you talk about a statutory 

6 requirement for national energy consumption, and 

7 there's a specific requirement that needs to be 

s met for a, quote, "product." 

9 And so that the outstanding question is, 

10 what does that mean? And I think, you know, 

11 clearly, a group of products has been compared to 

12 that statutory requirement. So the question is, 

13 is that appropriate? 

14 You know, I think we have to consider 

1s and I've commented on this before -- that, you 

16 know, and you guys responded to it in the TSD, 

17 that, you know, a box that cools something, 

1s that's its purpose. It cools something. And 

19 then I guess ice makers are so far out on that 

20 spectrum, it's designed to produce ice to the 

21 consumer. It's not designed to cool something. 

22 And so, to lump that in with these other 

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1 products that are all boxes that have cooling 

2 systems to keep something cool, that seems 

3 questionable. 

4 So that's, I think, what the comment is, 

s is considering ice makers by themselves will 

6 nowhere near meet that statutory requirement. 

7 And so that's the comment. I mean, as -- you 

8 know, from a national energy consumption 

g perspective, ice makers are nowhere near meeting 

10 that requirement. 

11 MR. BROOKMAN: Charlie? 

12 MR. HON: This is Charlie Hon one more 

13 time. 

14 He made a comment that's very important, 

1s I think, and there's another thing that has been 

16 glossed over so far in the meetings. 

17 There are two different reasons for 

18 refrigeration. The first is food safety. The 

19 second is preferences. Keeping something at 

20 keeping wine at a certain temperature is a 

21 preference. The wine will maintain itself in, 

22 other than adverse conditions, in a drinkable 

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1 form for a very extended period of time without 

2 refrigeration. 

3 Refrigeration, I think, in definition is 

4 being glossed over here in the residential market 

5 that it's not glossed over in commercial market. 

6 The residential needs to be considered are, is it 

7 a food safety issue or a preference issue? 

s And some of these boxes we're talking 

g about here, we just heard that, okay, we can't do 

w anything with it. It can't stay at 39 degrees 

11 above 72 degrees Fahrenheit ambient. That scares 

12 the heck out of me. If it's not being marketed 

13 as a convenience device because it's marketed as 

14 a refrigerator, a refrigerator, by common 

15 definition, is a food-safety device. 

16 And that's my number-one concern here 

11 today, because I read over all the standards. 

1s And there's no differentiation. 

19 MR. BROOKMAN: Okay. Thanks, Charlie. 

20 Sri ram? 

21 MR. GOPAL: I just want to tag on one 

22 point to what Nate said about another reason why, 

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1 you know, ice makers should probably be 

2 considered a different product. Just the fact 

3 that their test procedure requires a new 

4 appendix, I think, is a recognition on DOE's part 

s that they are very different. 

6 And so, if they require a wholly separate 

7 test procedure, then they're probably a wholly 

8 separate product. And if they are a wholly 

g separate product, then the analysis of how much 

10 energy savings should be done separately and not 

11 lumped in with the rest of the products that are 

12 part of this rulemaking. 

13 MR. BROOKMAN: Okay. Thank you. 

14 MR. HAGERMAN: The reason I brought it up 

1s at this time is I, you know, got the feeling that 

16 that was the elephant in the room that we hadn't 

17 quite discussed yet in a very clear way, right? 

18 And I just wanted to get your feedback on it. 

19 I mean, I think you can appreciate the 

20 challenges that we're faced with, too, right? I 

21 mean, these things are not refrigerators like you 

22 think in a home. These are more like, like you 

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1 say, convenience devices or convenience 

2 refrigeration devices, right? They're definitely 

3 a derivative of what, you know, our parents 

4 always had as white goods, a white refrigerator 

s in the house, right? 

6 We've got to start -- we've got to 

7 systematically start thinking about how we deal 

s with this, right? And this is our attempt to do 

9 that in a meaningful way, I think. 

10 So I hope you appreciate the problem that 

11 we're grappling with, too. 

12 MR. HON: We understand completely. And 

13 that's the reason we're here. That's the reason 

14 we're also pointing out the vast differences, 

1s because if you're using a convenience device, a 

16 preference device, the error factor can be much 

17 greater. 

18 If you're dealing with food safety, there 

19 are federal codes on food safety. It's 41 

20 degrees Fahrenheit or below. You'd better have 

21 your food there or it's not considered a safe 

22 condition for that food storage. That's FDA 

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1 regulations. So that needs to be considered as 

2 part of the formula. 

3 In commercial refrigeration, we have 

4 different categories even in NSF. There's an NSF 

s step 7 standard, which is food storage. It has 

6 special cleaning requirements. It has lots of 

7 other requirements. It also has maximum 

8 temperature requirements. 

9 Then you can also go into a lot of the 

10 glass-doored refrigerators, quote-unquote, 

11 "refrigerators," that do actually meet 

12 refrigerator temperature standards, but are not 

13 held nearly so close because a bottle of soft 

14 drinks or energy drinks or something is not going 

1s to get you sick if it's held at 45 degrees. 

16 But if you get a milk product at 45 

11 degrees for an extended period of time, that date 

18 on that label is no longer valid. It becomes a 

19 food-safety issue. 

20 MR. HAGERMAN: So I appreciate all your 

21 comments. They're very thoughtful, and they help 

22 me understand this, too. 

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1 One question, though. As the -- after 

2 you - if you have a cascading ice machine and 

3 the ice, the sheet of ice is made and then it's 

4 cut, right? And you have the higher-quality of 

s ice, which you're saying, what is the 

6 classification of the compartment that that ice 

7 is held in? Is that a food-safety-defined 

s compartment? It is. Okay. 

9 MR. HON: It is a food-safety 

10 MR. HAGERMAN: Defined. 

11 MR. HON: -- compartment. And in a 

12 commercial application, you have to have 

13 standardized cleaning procedures, periodic 

14 cleaning, everything else. 

1s In a residential, like everything else, 

16 it's as the owner decides to do it. You give 

11 them an instruction sheet on how it should be 

18 done. 

19 MR. HAGERMAN: Right. Per the manual, 

20 right. 

21 MR. HON: Right. Which says, take some 

22 sort of a bleach-type system, wash it out on this 

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1 schedule. Whether they do it or not is --

2 MR. HAGERMAN: Not your problem. 

3 MR. HON: -- not our problem. But it 

4 still has to be there. 

5 But it is still something that you're 

6 consuming, so it still needs safety coverage. 

7 MR. HAGERMAN: Okay. 

8 MR. BROOKMAN: Okay. Thanks, Charlie. 

9 MR. WESTPHALEN: Okay. So, clearly, 

10 there are other issues. What we're talking about 

11 here is focused more on, you know, if you were to 

12 regulate an ice maker, how would you measure its 

13 energy use? 

14 MR. WESTPHALEN: Next, we'll talk about 

15 the ice maker energy-use metric. DOE considered 

16 a couple of things here, first the kilowatt hour 

17 per 100 pounds of ice metric that is used for 

1s automatic commercial ice makers. And just for 

19 reference, that test procedure calls for testing 

20 in a 90-Fahrenheit ambient condition, using 70-

21 Fahrenheit inlet water. 

22 One thing DOE recognized is this method 

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1 does not capture the energy use for storage or 

2 replenishing ice. Some of DOE's testing showed 

3 that the energy use associated with the storage 

4 of ice can be very significant, you know, on an 

5 ongoing basis. 

6 And depending on what the assumptions are 

7 for how much of the ice is actually used in a 

s day, you look at, okay, how much energy is 

9 associated with producing that much ice that I'm 

10 using versus how much energy is associated with 

11 just keeping the bin full while, you know, it's 

12 waiting for me to take some ice. 

13 So, depending on the assumptions, a range 

14 of 5 percent to 91 percent for storage. So, 

15 clearly, this is significant for ice makers. 

16 Also, clearly, EPCA, for residential 

11 products, requires consideration of standby and 

1s off-mode energy use. Hence, you know, whether or 

19 not this is significant, DOE has to address this 

20 issue and somehow deal with it. 

21 So the other approach that DOE considered 

22 was the kilowatt-hours-per-year metric, 

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1 accounting for a representative ice production 

2 per day and the storage energy use and, you know, 

3 putting those two numbers together to come up 

4 with an annual energy use. 

5 DOE concluded that this latter approach 

6 was the most appropriate way to formulate the 

7 energy-use metric for ice makers. 

8 So, issue box 25, DOE requests comment on 

g the proposal to use an annual energy-use metric 

10 that includes both storage and ice production 

11 energy-use components. 

12 MR. BROOKMAN: Comments? 

13 (No audible response.) 

14 MR. BROOKMAN: Nothing here? Okay. 

15 MR. WESTPHALEN: Okay. So, we talked 

16 about what would the representative daily ice 

17 consumption rate be. That clearly is a question. 

1s And DOE did not, in order to obtain a number for 

19 this, was not in the position to do extensive 

20 field surveys in order to determine a number. 

21 The four-pound daily ice production 

22 number was considered to be a reasonable number, 

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1 a little bit more than double the 1.8 that was 

2 initially being discussed for a refrigerator 

3 automatic ice making test procedure. Many of 

4 these ice makers can produce far more than four 

5 pounds a day, but it is not felt that, on an 

6 average annual basis, that they would be using 

7 that much ice. Certainly, there would be much 

s more intimate ice use in a residence than there 

9 would, for instance, with a commercial ice maker 

10 in a restaurant. 

11 So this is the proposed level. And 

12 certainly, we'll get into the request for comment 

13 later, where DOE requests any information that 

14 might be helpful in adapting this number to 

15 something that might be more close to reality if 

16 there is any data available. 

11 Most of the additional points here I've 

1s already covered. There are some questions as to 

19 what the numbers should be. If anybody has any 

20 comments, c_ertainly we welcome them now. 

21 

22 

MR. BROOKMAN: Sriram? 

MR. GOPAL: Yes. We don't agree that the 

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1 four pounds a day is a reasonable number. We 

2 think it should be closer to the 1.8 or even 

3 less. Just it seems that four pounds a day is 

4 just unrealistic, and it doesn '_t make sense to 

5 us. So. 

6 MR. BROOKMAN: Can you provide, can you 

7 say why? 

8 MR. GOPAL: Well, we came up with a 

g number of 0.76 in terms of the ice makers in 

10 refrigerator-freezers. 

11 MR. BROOKMAN: Okay. 

12 MR. GOPAL: Now, we acknowledge that if 

13 you have an ice maker, you're probably going to 

14 consume more than if you're using the ice maker 

15 in your refrigerator-freezer. But to say that 

16 it's going to be more than four times more, I 

17 think DOE needs to justify that in order to use 

1s that number in a regulation. 

19 MR. BROOKMAN: I guess DOE would be 

20 hoping that the manufacturers would understand 

21 use patterns from their consumers and things like 

22 that and somehow they'd be able to get that 

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1 information. 

2 MR. GOPAL: We'll talk to our members. 

3 MR. BROOKMAN: That would be great. 

4 MR. GOPAL: Yeah, yeah. 

5 MR. BROOKMAN: Okay. Additional comments 

6 on four pounds or other alternatives? 

7 Charlie. 

8 MR. HON: This is Charlie Hon. 

9 I think we have a real dichotomy here, 

10 because people who buy ice makers as a 

11 freestanding piece of equipment I do not believe 

12 are your normal ice consumers. 

13 MR. BROOKMAN: In the residential market. 

14 MR. HON: In a residential market. They 

15 quite often -- but you look at the units. You do 

16 not see under-10-pound-a-day ice machine very 

17 often. You see 20s, 50s, 50-pound-per-day-type 

1s units being sold on a regular basis. Not a high 

19 volume, but a regular basis. 

20 And I don't know how that equates to the 

21 total ratios of units sold in a I do not have 

22 a full spectrum. I would think that AHAM would 

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1 have a much greater understanding of all the 

2 different possible abilities as far as volume 

3 production versus losses versus because if you 

4 have a 50-pound ice machine, which is a 

5 residential unit, that 4-pound-per-day can be 

6 your loss as it sits there without any action 

7 going on. And you have a melt-out, it could 

8 easily be four pounds per day. 

g So I don't know where these numbers are 

10 you have to differentiate that from -- which 

11 is inside of a refrigerator freezer versus what 

12 is a standalone ice machine. 

13 MR. BROOKMAN: Additional thoughts here? 

M Yes, Nate. 

15 MR. MOUW: Yeah, this is Nate from 

16 Whirlpool. 

11 Just to that point, and maybe Detlef, 

18 perhaps you can expand a little more on that four 

~ pounds per day. I mean, that is, as I understand 

20 it, having skimmed through the TSD, that is the 

21 amount of the ice you are assuming that the 

22 consumer is taking out of the ice maker. 

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1 Any amount of melt would be included in 

2 the ice storage metric, right? So if there is 10 

3 pounds melting in a day, that's already measured, 

4 according to this proposed test procedure, and 

5 the 4 pounds is just the assumed amount of ice 

6 that is actually removed from the ice maker by a 

7 consumer. Is that accurate? 

8 MR. WESTPHALEN: That is correct, 

g although the test procedure doesn't try to 

10 capture the meltage from the four pounds, you 

11 know, when we're doing the production part of the 

12 test procedure. But, yes, the four pounds would 

13 be the used ice. 

14 And so, if you're using this procedure 

15 and 50 percent of the energy is storage and 50 

16 percent is the production for the four pounds, 

17 then it's roughly four pounds meltage. So, some 

1s of these units do have meltage, you know, on the 

19 order of four pounds in a day. 

w (Pause.) 

21 MR. WESTPHALEN: So, now we get into test 

22 conditions and setup. In general, DOE tried to 

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1 follow the existing refrigeration product test 

2 procedures, set up requirements to the extent 

3 possible where they're applicable to ice makers. 

4 And things such a clearance distances for the 

5 cooled storage ice makers, steady-state 

6 conditions, you know, what it takes to be 

7 considered steady-state. 

8 DOE proposes ice makers be tested in 72 

g Fahrenheit ambient. And the thought process here 

10 is that ice makers are likely not opened as of ten 

11 as, you know, regular refrigerators. So 

12 certainly, testing at a 90-Fahrenheit ambient 

13 would overestimate the amount of load associated 

14 with door-openings. 

15 The ice maker test procedure measures the 

16 ice production energy use directly, so any load 

17 associated with the 90-Fahrenheit test for a 

18 refrigerator that would be attributed to like 

19 manual ice making or something like that, you 

20 know, isn't applicable here. Basically, all the 

21 production is separately measured. 

22 Hence, DOE concluded that it would be 

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1 much more representative to use a 72-Fahrenheit 

2 ambient, an average residence temperature, 

3 essentially, for this test. 

4 DOE proposed inlet water conditions of 72 

5 Fahrenheit, plus or minus 2 Fahrenheit, and DOE 

6 recognizes that, in many cases, supply-water 

7 temperature may be lower than that. However, in 

8 order to reduce test burden requirements of 

9 having a separate water supply giving you that 

10 temperature, DOE proposed 72, assuming that there 

11 would be equilibration with the ambient 

12 conditions in the room. 

13 That's also a factor in the test 

14 procedures that were being considered for 

15 refrigerator-freezer's measurement of automatic 

16 ice makers in those products, again for test17 burden reasons. 

18 For portable ice makers, where there 

19 wouldn't be a water supply, per se, DOE proposes 

20 requiring putting water into those ice makers at 

21 55 Fahrenheit. And this is associated with 

22 accelerating the stabilization period, because in 

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1 DOE testing, we saw that if you fill the 

2 reservoir at a warmer temperature, it takes 

3 several cycles for things to stable out, and then 

4 the reservoir gets into a range close to that 55. 

s It depends on the particular ice maker, but this 

6 is felt to be a reasonable median temperature in 

7 order to try to accelerate that stabilization 

8 period. 

9 MR. MOUW: Detlef, I'm sorry. Can you 

10 repeat why we would go to a 55 degrees rather 

11 than a 72? I think that's what you just 

12 described. Could you just I'm sorry -- just 

13 repeat that so I can get more clarity on that? 

14 MR. WESTPHALEN: That's in order to 

1s reduce the stabilization time period. In our 

16 testing, we saw that if you fill the reservoir 

17 with 72 Fahrenheit, you get very slow ice 

18 production, initially, because the water is so 

19 warm. And, you know, as time goes by, the water 

20 cools down, and then, you know, you start to 

21 steady out. 

22 And at those steady conditions, you have, 

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1 you know, depending on the ice maker, you know, 

2 low 50s, high 50s. But we felt that 55 was a 

3 reasonable temperature to get some consistency in 

4 the test. 

5 MR. MOUW: Okay. Thanks. 

6 MR. WESTPHALEN: So, here we request 

7 comment on some of these particulars associated 

s with temperatures. 

9 (Pause.) 

10 MR. BROOKMAN: Comments on these 

11 temperatures? 

12 (No audible response.) 

13 MR. BROOKMAN: Okay. 

14 MR. WESTPHALEN: Okay. More on test 

1s conditions and setup. The proposal calls for 

16 temperature controls if they exist to be set to 

17 the median position, any user accessible ice 

1s piece size control to be set for the largest ice 

19 piece size, data collection for temperature power 

20 and energy be not less than once per minute in 

21 order to make sure the test data capture the 

22 times associated with the ice making cycles. 

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1 For cooled storage ice makers, the test 

2 procedure calls for a single temperature sensor 

3 in a location that is designed to give a 

4 representative temperature, but then not 

s interfere with the ice making process in order to 

6 determine stabilization for the ice storage 

7 portion of the test. 

s The proposal calls for the tubing used to 

9 convey the water from the ice maker to the test 

10 lab floor be as specified in the consumer 

11 instructions supplied with the cabinet, that 

12 those drain lines be installed running downwards 

13 without any uphill portions. 

14 And that if there is a pump within the 

1s unit that is used to push water out of the unit, 

16 if it's optional, only required when you need to 

11 run that water uphill to a drain, then it 

1s wouldn't be used in the test. However, if it 

19 must always be energized, then that would be 

20 required to be energized during the test. 

21 More on the test itself for -- this is 

22 for the ice making portion of the test. This 

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1 part of the test measures the energy use required 

2 per piece of ice, or per weight of ice, during 

3 filling of the bin. The proposal requires a two4 hour stabilization period prior to beginning of 

s the test. 

6 The test calls for a perforated container 

7 similar to what's used for testing of commercial 

8 ice makers to capture the ice. And then the melt 

9 would fall down into the bin and be drained. 

10 The test period during which the energy 

11 use is calculated and the ice is being captured 

12 for weighing would consist of a whole number of 

13 ice making cycles of at least six hours for batch 

14 ice makers or until the ice maker stops 

1s automatically if it's less than six hours. But 

16 for batch makers, in any case, it would be a 

17 whole number of ice making cycles. 

18 The ice making cycles would be defined by 

19 observing the power trace. However, I believe 

20 the test procedure also -- the proposal also 

21 points to some other methods that could be used 

22 in order to determine when the harvest has 

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1 occurred in order to identify the ice making 

2 cycles, particularly for uncooled -- or for 

3 cooled storage ice makers if the power trace is 

4 not sufficiently indicative of that cycle. 

s For a continuous-type of ice maker, a 

6 period of six hours of ice making would represent 

7 the test period for which the energy use would be 

8 measured. And the proposal allows for doorg openings. The idea is that you would put the 

10 perforated container into the ice maker when you 

11 start the test period, and run through the test 

12 period, and collect six hours of ice. 

13 But in some cases, the geometry of the 

14 ice maker may be such that that size of a 

1s perforated container may not easily come out of 

16 the bin at the end of the test full of ice. And 

11 so, in those cases, the proposal calls for 

18 allowing periodic retrieval of ice during that 

19 test period. 

20 There are requirements on time for the 

21 door-openings in order to minimize the thermal 

22 load associated with those interventions. 

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1 And then, the test. The proposal also 

2 calls for 1 percent accuracy in precision for 

3 weighing ice similar to what is required for 

4 commercial ice makers. 

5 So here we request comments on any of 

6 those details at the last page or two. 

7 MR. BROOKMAN: Charlie. 

8 MR. HON: Charlie Hon. 

9 I have a serious question, for two 

10 different reasons. I do not know the correct 

11 answers; I'm going to ask you. 

12 Okay. Drain lines shall be installed 

13 running downwards from the ice maker's drain 

M outlet. That is not how products are normally 

15 put into the field. Do you want -- there's two 

16 reasons for that. First off is if you have a 

17 drain going straight down. Cold air is heavier 

18 than warm air. And if you have no obstruction in 

19 there of a P-trap design, the cold air will 

20 continue to flow down the tube and warm air will 

21 come into the top of the bin to replace it. 

22 Secondly, for sanitation reasons, you 

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1 always want to put a P-trap in a water drain so 

2 that, shall we say, you don't want fumes. If 

3 you're going to a sewer drain, there is a certain 

4 amount of sewage in a sewer drain. And gases 

s from that, quite often, carry a lot of bacteria. 

6 And it is possible for those to be pulled back 

7 into the ice if you don't put a P-trap in. 

8 And also, cockroaches crawl up. So you 

9 want some obstruction there. If it's only for 

10 the test procedure, it's not a problem because it 

11 would be standardized. But it will change the 

12 energy consumption slightly. As the ice melts, 

13 the cold air is continually flowing downhill and 

14 out of the unit and being replaced by warm air on 

1s top of it. 

16 MR. WESTPHALEN: Yeah, I think that's a 

17 great comment, and I think, you know --

18 MR. HON: I don't know what's going to 

19 happen. I know there will be slight increase in 

20 energy consumption because of that. It won't be 

21 huge. But that is not how they're built in the 

22 field because of other reasons. You don't want 

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1 that to happen ever in the field. 

2 MR. WESTPHALEN: Yeah. We'll certainly 

3 consider changes perhaps pointing to installation 

4 instructions and otherwise downward --

5 MR. HON: Because if it's just for 

6 testing, it's a standardized condition, that 

7 everybody is playing with the same conditions. 

8 But if it's -- you're not testing a standard unit 

g then. 

10 MR. WESTPHALEN: No, understood. 

11 MR. HON: Thank you. 

12 MR. BROOKMAN: Additional thoughts here? 

13 A lot of specificity on these test conditions 

14 setup, as well. 

15 (Pause.) 

16 Nothing additional? Okay. 

17 MR. BROOKMAN: John Myers, you're on. 

~ Speak. 

19 MR. MYERS: -- not use some of those 

20 standard terminology from AHRI as far as for 

21 stabilization and -- because two hours may not be 

22 adequate to guarantee that the unit is operating 

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1 repeatedly. 

2 MR. BROOKMAN: Okay. Thank you. 

3 Other comments before we move on? 

4 (No audible response.) 

5 MR. BROOKMAN: Okay. 

6 MR. WESTPHALEN: I guess I should point 

7 out, issue 31 here requests comment on an aspect 

8 that I'm not sure made it into the slide, the 

9 requirement to retrieve the ice within two 

10 minutes after the end of the ice making test 

11 period. 

12 (Pause.) 

13 MR. WESTPHALEN: The point of this is to 

14 assure that the meltage from the ice is limited 

1s and that you don't wait like three hours for 

16 retrieving the ice. 

17 MR. BROOKMAN: Charlie. 

18 MR. HON: Charlie Hon. 

19 Couldn't that also be attained by 

20 plugging the drain temporarily and measuring the 

21 water that had also melted off? 

22 MR. WESTPHALEN: That's something we 

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1 could consider as well. 

2 MR. BROOKMAN: Okay. 

3 MR. WESTPHALEN: Okay. Moving on to the 

4 ice storage test, this is the portion of the test 

s that addresses how much energy is used just 

6 keeping the ice there ready to use. 

7 And for this, the proposal calls for the 

s test to be conducted when the ice maker enters a 

9 mode where it either maintains a cooled storage 

10 temperature if it's a cooled storage type of ice 

11 maker, or, you know, a time period when it 

12 occasionally replenishes the melted ice that's in 

13 the bin. 

14 So this test would be conducted while the 

1s ice storage bin is full, and the proposal calls 

16 for using only the ice produced by the unit under 

11 test. So you couldn't put in some ice that might 

1s have larger size and melt much more slowly. 

19 For a cooled storage ice maker, the test 

20 period would occur after a period of 

21 stabilization that would be defined very similar 

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1 freezers based on that one thermal couple near 

2 the top of the bin, and then using a test period 

3 similar to what is used for a refrigerator or a 

4 refrigerator-freezer. 

s For an uncooled storage ice maker, where 

6 the additional energy use is associated with 

7 producing additional ice to fill the bin, it's a 

s very different test and much more variability in 

9 what you see with different ice makers. So the 

10 proposal calls for a 48-hour test in which a 

11 whole number of replacement cycles occur, and 

12 that this would start at the end of an ice making 

13 period and then end at the end of a replacement 

14 cycle. 

1s So here we request comments on those 

16 proposals associated with the ice storage portion 

11 of the test. 

18 MR. BROOKMAN: Any thoughts here? Ice 

19 storage tests. 

20 (No audible response.) 

21 

22 

MR. BROOKMAN: Okay. 

MR. WESTPHALEN: For continuous ice 

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1 makers, the test procedure calls for 

2 consideration of the ice hardness. The ice 

3 hardness is the fraction of the ice that is 

4 actually ice, because continuous ice, you know, 

s has some portion that's still liquid water 

6 contained within the crystalline structure. 

7 DOE proposes that, on the assumption that 

s most of these residential ice makers make nugget 

g ice, which have an ice hardness in the vicinity 

10 of 0.85, to allow the use of the standard 0.85 

11 ice hardness value as an option, or if the 

12 manufacturer feels that it would be beneficial or 

13 worthwhile to actually measure the hardness to 

14 use the hardness test procedure that is part of 

1s ASHRAE 29, then DOE proposes that there would be 

16 an ice hardness adjustment factor be calculated 

17 according to this equation. 

1s And basically, what this represents is, 

19 you know, the amount of energy use required to 

20 make 100-percent-hardness ice, starting with 72-

21 degree Fahrenheit water, divided by the amount of 

22 energy that would be removed for the given ice of 

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1 the given ice hardness. 

2 MR. BROOKMAN: Sriram. 

3 MR. GOPAL: I just have a question. 

4 What's the rationale of including a hardness 

s calculation at all? 

6 MR. WESTPHALEN: Well, this was 

7 introduced in the commercial ice maker test 

s procedure. And the reason to do it is so that if 

g you have a continuous ice maker, you couldn't 

10 just improve your energy use measurement by 

11 reducing your hardness. 

12 MR. GOPAL: And I guess my concern is 

13 that that sounds like a performance issue. And 

14 you know, I'm not sure that a performance metric 

1s should work its way into an energy conservation 

16 standard. 

17 MR. WESTPHALEN: Well, the proposal for 

1s the test does not require any particular hardness 

19 level. 

20 (Pause. ) 

21 

22 

MR. GOPAL: Thank you. 

MR. WESTPHALEN: So, moving on to the 

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1 energy use calculation --

2 MR. MOUW: I'm sorry, Detlef. Can I just 

3 ask one question? This is -- I think you had 

4 mentioned that this ice hardness portion is just 

s for continuous type. And I think you had 

6 mentioned that it's an optional. Is it optional 

7 to use ice hardness to more accurately represent 

s the amount of ice you've created? 

9 MR. WESTPHALEN: That's correct. DOE 

10 decided that the test burden associated with the 

11 hardness measurement would probably not be 

12 worthwhile for most of these residential units. 

13 MR. MOUW: Okay. So it would not --

14 "optional" means that it's not required. It's 

1s something you could do should your product 

16 benefit from doing so. 

17 MR. WESTPHALEN: Right. Exactly. 

18 MR. BROOKMAN: John Myers, you're next. 

19 MR. MYERS: Once again, you know, this is 

20 -- once again, this is John Myers. 

21 The flake-nugget residential market is an 

22 even smaller segment. And once again, I believe 

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1 that the effort and the energy savings required 

2 would be, you know, once again out of scope 

3 compared to the rest of the products that are 

4 covered under this NOPR. 

5 MR. BROOKMAN: Okay. Thanks, John. 

6 Charlie? 

7 MR. HON: This is Charlie Hon. 

8 I'm concerned there's a problem here that 

g DOE needs to be aware of, because the flake 

10 market and the nugget market in certain regions, 

11 if you have low water availability, give you 

12 effectively 100 percent yield from your water to 

13 ice. There is no loss because all the minerals 

14 come right through with it. And there, you don't 

1s have a purging cycle in there. 

16 And that's a question, because it's very 

17 possible, in the near future, California will go 

18 to restricting the amount of water down the 

19 drain. And if -- so if you start pulling certain 

20 pieces of this out, you may have a problem. 

21 

22 

MR. BROOKMAN: Okay. Thank you. 

MR. WESTPHALEN: Okay. Moving on to the 

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1 calculation of the energy use, so these two parts 

2 of the test are put together in order to come up 

3 with the daily average energy use. The ice 

4 making portion of the test would result in a 

5 measurement of energy use per pound, and using 

6 the four pounds per day, you get a daily energy 

7 use associated with the production. 

s And then the storage energy use would be 

9 the average ice storage power consumption 

10 multiplied by the amount of time per day that the 

11 ice maker is not producing the four pounds of 

12 ice. And so, if you have an ice maker that can 

13 only make four pounds in a day, then the storage 

14 portion goes away, according to this calculation. 

15 For portable ice makers, the proposal 

16 calls for using a 50-percent factor to take into 

17 account the fact or the expectation that many of 

1s these portable units would not necessarily be 

19 energized and operating 100 percent of the time 

20 throughout the year. 

21 Here we stop for additional comments. 

22 (Pause.) 

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1 MR. BROOKMAN: Okay. 

2 MR. WESTPHALEN: So, now we move on from 

3 ice makers to some additional topics that are in 

4 the proposal. The first category here is an 

s umbrella category for some incidental changes to 

6 the test procedure text to improve clarity. 

7 First of all, revision of some section of 

8 Appendices A and B to refer to the "two tests" as 

9 opposed to the "two test periods." Test periods 

10 are covered in section 4 of Appendix A or 

11 Appendix B. And they have a particular meaning, 

12 but then in -- then there is discussion of tests 

13 conducted at different temperatures. And the 

14 current test procedure also calls those two 

1s different "test periods," and we're changing that 

16 to "tests" for a little bit better clarity. 

17 Second, revision of the auxiliary 

18 compartment language to use the term "primary 

19 fresh food" or "freezer compartment" instead of 

20 "first compartment"; replacing "should" with 

21 "must" in the definition of "variable defrost 

22 control" just to reinforce that. And this is 

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1 associated with concerns regarding circumvention 

2 if a manufacturer decides to call a particular 

3 defrost control a "variable" when it is not 

4 really variable. And this just reinforces that 

s it is expected that the times between defrost 

6 would change the variable usage patterns. 

7 And finally here, it would extend the 

8 setup provisions of section 2 of Appendix A to 

9 apply to the new consumer refrigeration products 

10 governed in this rulemaking. 

11 Also, we have changes to the volume 

12 calculation instructions. DOE proposes to use 

13 the acronym AV for "adjusted volume." In some of 

14 the sections in the CFR, it's VA instead of AV, 

1s and we're changing to AV in all the sections. 

16 There is also a proposal to require 

17 rounding the volumes of fresh food freezer and 

18 cellar compartments to the nearest 0.01 cubic 

19 feet, and that any volumes measured in liters 

20 would first have to be converted to cubic feet 

21 and then rounded to 0.01 in order to avoid issues 

22 with volume round-off there when considering 

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1 metric versus English units. 

2 Additional changes to volume measurement 

3 instructions are listed here. First of all, a 

4 clarification, and I believe this may already be 

s in a guidance, but is now being introduced into 

6 the test procedure, that the walls surrounding an 

7 automatic ice maker compartment would not be 

8 included in the volume determination. 

9 Also, that an ice maker auger motor, the 

10 volume that it takes up would be included in the 

11 volume of the refrigerator. 

12 Some additional volume calculation 

13 changes. The automatic ice maker kit and the ice 

14 storage bin both would be included in the volume. 

1s The fountain recess and the dispenser insulation 

16 would not be included. And that's consistent 

17 with the HRF-1-2008. 

18 Then, for the ice chute, the volume is 

19 included, you know, up to the dispenser flap if 

20 there is no cover that covers the chute when 

21 there's no ice being dispensed, but not included 

22 if there is a plug or a cover covering that ice 

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1 chute. 

2 So here we have a series of comment boxes 

3 requesting comment on all those incidental items 

4 that I just covered. 

5 MR. BROOKMAN: So, quite a few proposed 

6 changes, incidental and more than incidental, it 

7 seems to me. Thoughts? Like the volume 

s determination piece could be significant, 

9 depending on -- what do you think? Thoughts on 

10 these items here? 

11 (No audible response.) 

12 MR. BROOKMAN: Nothing here? 

13 MR. WESTPHALEN: Okay. We have a 

14 question from the Webinar. Compartment volumes 

1s are already calculated to the nearest 0.1 -- 0.01 

16 cubic foot. How is this different? Question 

17 from Bill Brown. 

18 Well, it may not be different. But it's 

19 being proposed to put the text in the Appendices 

20 to make it clear. 

21 

22 

MR. BROOKMAN: It's a clarification. 

MR. WESTPHALEN: Yeah. 

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1 MR. BROOKMAN: Okay. Or a confirmation, 

2 either one. Okay. 

3 Additional thoughts, comments on these 

4 many instructions and clarifications? 

s (No audible response.) 

6 MR. BROOKMAN: Okay. 

7 MR. WESTPHALEN: Okay. Moving on to 

8 Appendices Al and Bl, the old test procedures, 

g DOE proposes to remove them, since they're no 

10 longer needed. And then we get onto compliance 

11 with other EPCA requirements. 

12 First of all, a consideration of test 

13 burden. The products covered by this rulemaking, 

14 previously most of the products are not covered 

1s by DOE, but they are similar to refrigerators, 

16 refrigerator-freezers, and freezers. The 

11 proposed test procedures are consistent with the 

18 existing tests for the currently covered 

19 products, and therefore, would not represent any 

20 greater test burden per product than the current 

21 DOE test procedures. 

22 For the ice maker test procedure, there 

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1 are some differences. There are some differences 

2 in the requirements for the test facilities, such 

3 as requirement of a water supply line, a scale to 

4 measure ice, perforated container. 

s But those represent fairly small 

6 investment as compared with the test facility and 

7 other equipment required in order to measure 

8 energy use of refrigerators. So on a per-product 

9 basis, the test burden is considered to be 

10 equivalent to that of the existing covered 

11 product. 

12 DOE conducted some assessment, you know, 

13 addressing the regulatory flexibility review 

14 requirements. DOE identified four small business 

1s manufacturers that would be affected by today's 

16 proposals. 

17 For the different products that are being 

18 addressed, cooled cabinets are currently 

19 regulated by the CEC and NRC, NRCan, rather, as 

20 wine chillers. So manufacturers likely already 

21 tested these products. I know there was some 

22 mention of some such products that currently may 

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1 not be registered, certified to CEC and Canada. 

2 But we have also heard that essentially it's a 

3 single North American market, and the Canadian 

4 and California requirements essentially set the 

s standard for North America. 

6 The proposed test procedures would modify 

7 the calculations for these existing products, but 

8 would not require retesting. Hence, any existing 

g cooled cabinets that have been certified to CEC 

10 or Canada would not have to be retested. The 

11 test data would be there. There would simply be 

12 adjustment of the test result. 

13 And DOE estimated that revising the 

14 energy use representations for cooled cabinets 

1s would require 120 hours of effort for each 

16 manufacturer. And this is an estimate, 

17 certainly, where we welcome comment on, you know, 

18 what the effort might be, depending on what the 

19 situation is for a particular small business 

20 manufacturer. 

21 In looking at the remaining products, DOE 

22 considered the cost that manufacturers might 

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1 incur for testing these products and estimated 

2 the average would be $2,500 per test, that there 

3 would be a cost of two tests per unit, per basic 

4 model, rather. 

s Shipping costs to a test lab that would 

6 do the testing, test management and review time, 

7 reporting time, and adding all this up and 

8 assigning representative labor rates for 

9 technician time, et cetera, brought us to a total 

10 estimated cost of $74,000, or $18,500 per small 

11 business, which represents between 0.01 and 0.02 

12 percent of the annual revenues of the small 

13 businesses involved. 

14 MR. BROOKMAN: If we have comments on 

1s DOE's numbers regarding testing costs of 

16 additional details on testing burden, that would 

11 be helpful. 

18 (Pause.) 

19 MR. BROOKMAN: Nothing on those points? 

20 Yes, yes, Joseph. 

21 MR. FONTECCHIO: Joseph again, with True 

22 Manufacturing. 

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1 May we go back to the last slide? 

2 On the second bullet point, see, "The 

3 proposed test procedures would modify the 

4 calculations for these existing products, but 

s would not require re-testing." 

6 Well, those products that were already 

7 tested or are currently been tested were tested 

8 and listed in Canada and California to surpass 

g the values that Canada and California have. 

10 MR. WESTPHALEN: Right. 

11 MR. FONTECCHIO: I guess, depending on 

12 the outcome of the TSD and some of these 

13 analyses, if that value changes, the listings 

14 most likely will not be applicable anymore. They 

1s will fail the Department of Energy's threshold or 

16 level that's established unless it is the same as 

17 the Canadian and the California today. 

18 So, there may be additional burden 

19 associated with surpassing this standard in 

w redesigning. 

21 MR. BROOKMAN: Challenge that 

22 presumption. 

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1 MR. FONTECCHIO: Yeah. Okay. Okay. 

2 MR. WESTPHALEN: Yeah. In response, I 

3 would say that this talks about the burden 

4 associated with the proposed test procedure. 

5 Now, clearly, there would be burden associated 

6 with DOE imposing an energy conservation standard 

7 that would potentially go above and beyond the 

8 test burden. And I think you're referring in 

9 part or maybe primarily to that. 

10 MR. HAGERMAN: I have a question. Joe 

11 Hagerman, DOE. 

12 What's the history of the CEC and 

13 Canadian standard? Was it put in effect 10 years 

14 ago, 4 years ago? And when is it due to be 

15 updated? Do you have any idea? Is it new or old 

16 or what? 

17 MR. FONTECCHIO: I believe California has 

18 been doing it for years. And they just recently 

19 re-upped their publication. I don't believe the 

20 value for --

21 

22 

MR. HAGERMAN: Changed. 

MR. FONTECCHIO: -- for a pass has 

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1 changed with this re-up. And Canada hasn't 

2 either. I think they all want to move a ways 

3 above, similar to what has just occurred with the 

4 refrigerators in September. 

5 MR. HAGERMAN: Is there any Energy STAR 

6 labeled products at all? 

7 MR. FONTECCHIO: Wine is not. That's a 

8 great question. Because wine is not a food 

g temperature, it's inadmissible for Energy STAR. 

10 Now, if the DOE changes it to the temperature 

11 band of 39 and removes the food moniker, perhaps 

12 Energy STAR will --

13 MR. HAGERMAN: Take it out? 

14 MR. FONTECCHIO: take it out and make 

1s those that surpass the standard by a percentage 

16 eligible for Energy STAR; that's our hope. 

17 MR. HAGERMAN: That's something industry 

18 as a whole would like, to have Energy STAR19 labeled wine? 

20 

21 

22 

MR. HON: This is Charlie Hon. 

That's highly debatable. 

MR. HAGERMAN: Okay. 

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1 (Laughter. ) 

2 MR. HON: Depending on the market. 

3 MR. FONTECCHIO: We'd have to get back to 

4 you on that one. 

5 MR. HAGERMAN: Okay. 

6 (Laughter.) 

7 MR. BROOKMAN: Thank you, Sriram. 

8 MR. HAGERMAN: There's no simple question 

9 here. 

10 MR. HON: Energy STAR is a voluntary 

11 program, which is used in marketing. 

12 MR. HAGERMAN: Sure. 

13 MR. HON: And some people are running 

14 more efficient equipment, usually higher-priced 

1s equipment. They want the Energy STAR market. If 

16 you're trying to make lowest-possible market 

11 entry-level products, it's not necessarily that 

18 way. And it's dependent on your market. So I 

19 

20 

21 

22 

don't want to say yes or no. Certain companies 

will want it. 

But I have another question now on the 

same vein just to ask you. Will this be written 

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1 if this standard is followed through on, will 

2 it be written as the standard refrigeration units 

3 are, which is preemptive, states cannot be more 

4 aggressive than the federal standard? 

5 MR. BROOKMAN: Michael Kida. 

6 MR. KIDO: It will be preemptive. It 

7 will be. So anything that the states already 

8 have will be preempted once -- if we were to have 

9 federal standards -- those would be the national 

10 standards that everyone would have to abide by. 

11 MR. HON: And then, can the states apply 

12 for exemption as they do in certain other 

13 categories under DOE? 

14 MR. KIDO: So, there's a provision under 

1s EPCA which permits states to seek a waiver from 

16 the standards that are in place. 

17 MR. HON: Yes. 

18 MR. KIDO: So that would still be 

19 available to them. But they would have to 

20 satisfy certain criteria that are set out in the 

21 statute. 

22 MR. HON: Right. 

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1 MR. KIDO: So, you know, I'm not going to 

2 speculate as to whether DOE would grant something 

3 like that. But that's an option that's 

4 available. 

5 MR. HON: Right. Because one of the 

6 reasons I'm asking that is because it keeps 

7 coming back -- I keep bringing it up, I guess. 

8 But energy efficiency is part of California's big 

9 issue. Water conservation is another major part 

10 of it. And this standard has no provision for 

11 water conservation involved in it. And that's 

12 you know, that's one of those balancing acts of, 

13 what's more important to a region? 

14 And so I'm just trying to get it all 

1s figured out because I want to know where the 

16 standards are leading us as a design criteria. 

17 MR. KIDO: So, under the statutory 

18 provisions that we're operating under here, there 

19 are certain criteria for us to examine before we 

20 go down the path of treating these things as 

21 covered products or to set standards for them. 

22 And those are based on the amount of 

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1 energy that's consumed. So we're -- so for, I 

2 think what someone said earlier that we did not 

3 look at water efficiency as a particular metric 

4 or mark for these particular things. And that's 

s primarily a function of the provisions that we're 

6 conducting this particular proceeding under. 

7 So when we, tomorrow I guess, when we're 

s talking about the preliminary analysis, you know, 

9 a lot of the discussion is going to center on the 

10 energy consumption of these things because that's 

11 the universe that we're operating in right now. 

12 I mean, it's water conservation and water usage, 

13 you know, those are important factors. 

14 And in the provisions that we're looking 

1s at today, they're not present. And we do have 

16 the statutory authority to regulate the water 

11 efficiency of certain types of products. But 

1s those are laid out in the statute. They are 

19 specific requirements. 

20 (Pause. ) 

21 MR. WESTPHALEN: Another comment from the 

22 Webinar. This is from Renata Mortazavi, who is 

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1 with NRCan -- mentions that Canada regulates the 

2 residential wine cooler since 2008 and expects to 

3 harmonize as soon as possible and will align with 

4 the U.S. DOE regulations. 

5 MR. WESTPHALEN: Okay. Thank you for 

6 that information. 

7 MR. BROOKMAN: So, we've laid out here, I 

8 think, Detlef, you've covered that section fully. 

9 Comments? Additional comments on the 

10 regulatory flexibility review, these estimates 

11 here? 

12 (No audible response.) 

13 MR. WESTPHALEN: Okay. Now onto standby 

14 mode and off mode. EPCA requires consideration 

1s of standby mode and off mode for energy test 

16 procedures for residential products. For the 

11 products that keep a compartment temperature 

18 cold, similar to a refrigerators, refrigerators19 freezers, and freezers, the test procedure 

20 already measures all of the operation, even the 

21 compressor off times. So that is already 

22 considered. 

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1 And in addition, the ice -- the proposed 

2 ice maker test procedure includes the ice storage 

3 energy use, so that deals with the standby. 

4 So if we have any comments on that? 

5 (No audible response.) 

6 MR. BROOKMAN: One of our favorite 

7 topics. 

s (Laughter.) 

9 MR. BROOKMAN: No comments on one of our 

10 favorite topics? Okay. 

11 MR. WESTPHALEN: Okay. And I think 

12 that I S it • 

13 MR. BROOKMAN: That's it? Okay. 

14 As we promised you first thing this 

1s morning, now is an opportunity for closing 

16 remarks. Anything that you think hasn't been 

17 covered sufficiently, any new material you'd like 

1s to bring to the floor at this time, now is the 

19 opportunity to do so. 

20 Nate? 

21 MR. MOUW: Yeah. Now that Detlef has sat 

22 down, I have a question for him. 

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1 (Laughter.) 

2 MR. MOUW: Detlef, on ice makers, there 

3 was no mention about measurement of compartment 

4 volume. Why was that? 

5 MR. WESTPHALEN: That's an interesting 

6 question. I think the thought process was that 

7 the ice maker is providing ice, and that's what 

8 the utility is. And so, the test procedure aims 

9 to measure the energy use associated with, you 

10 know, producing that ice and then keeping that 

11 ice ready for the consumer to use. 

12 MR. MOUW: Yeah, and I'm just reflecting 

13 on the TSD. And I'll just read it. It's talking 

14 about, again, whether or not ice makers should be 

1s included in this rulemaking. It says, "In 

16 response to AHAM and Whirlpool, DOE tentatively 

17 concludes that the products under consideration 

18 are all similar and that they utilize 

19 refrigeration, have a similar -- or insulated 

20 'box' construction, and that their function, at 

21 least in part, includes cooler cold storage." 

22 So, you know, I mean, if that is the 

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1 thought process, then it goes on saying that we 

2 should consider it as cooler cold storage and 

3 think about compartment volume. Just go to the 

4 extreme -- if somebody were to make an ice maker 

s the size of a refrigerator for residential 

6 purposes. I don't think it will ever happen. 

7 But should it, they would want an allowance for 

8 the volume of that compartment. 

9 So I'm -- this is more of a comment in 

10 response to what the TSD states, that these 

11 products are for cool or cold storage. So if 

12 that's the case, we need to consider compartment 

13 volume as well. 

14 MR. BROOKMAN: Okay. Thank you. 

15 Yes. Joe Hagerman. 

16 MR. HAGERMAN: Is there any ice making 

17 device that also -- I'm looking at the cover. 

18 The cover sheet has this cute little unit on the 

19 far right that you can see where the ice is made, 

20 and you can see where the ice is stored, and you 

21 can see the insulation around it to keep it all 

22 cold, right? 

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1 Is there any product on the market that 

2 allows you to store, like, beverages up there, 

3 too? So you're making ice and you're also 

4 storing beverages on top, anything like that? 

5 Like a hybrid? 

6 MR. BROOKMAN: Charlie? 

7 MR. HON: I'm not aware of any. From a 

s sanitation viewpoint, we'd be very concerned 

g about that because you're directly above of what 

10 would be considered a food product. 

11 MR. HAGERMAN: The open food product. 

12 MR. HON: Open food product. 

13 MR. HAGERMAN: Right. Okay. All right. 

14 MR. HON: Yeah. 

15 MR. HAGERMAN: Just wondered. 

16 MR. HON: Okay. 

17 MR. HAGERMAN: Charlie, I'm very 

1s impressed with your knowledge of ice. 

~ (Laughter.) 

20 MR. HAGERMAN: I mean, I've never met 

21 anybody that knows so much about ice. I think 

22 you should get the official Iceman Award today. 

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1 (Laughter.) 

2 MR. HON: I wish it was that easy. 

3 (Laughter.) 

4 MR. BROOKMAN: We are eliciting 

s additional comments here at the end of the day. 

6 Other issues that haven't been covered 

7 sufficiently, other issues that you wish to cover 

s now? 

9 (No audible response.) 

10 MR. BROOKMAN: Okay. Let's then -- I'll 

11 turn it back to Joe Hagerman for final remarks. 

12 MR. HAGERMAN: So again, I just want to 

13 thank everybody for their comments today. 

14 Obviously, you know, this is our start to this 

1s process, and we look forward to you being a part 

16 of it till we bring it to closure. 

11 And we're anticipating that we're going 

18 to see these same faces tomorrow, right? So we 

19 welcome you back tomorrow. Just note that we're 

20 going to have an earlier start tomorrow, an 

21 earlier end time tomorrow, too, in case you fly 

22 out of here. So we're going to start at 9:00 

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1 a.m. in the morning, and we're going to try to 

2 get out of here by 2:00. And we did pretty good 

3 today, getting out of here well ahead of time. 

4 So, thank you for your comments, and 

s please remember, March 3rd, I think -- is that 

6 right? March 3rd or March 2nd is the closing 

7 date for the comment period. Yeah, March 2nd is 

s the closing date for the comment period. So, 

9 please send in your comments. 

10 MR. BROOKMAN: Thank you. Thanks to all 

11 of you. 

12 MR. MOUW: Just one question; I'm sorry. 

13 Process-wise, Joe, do we know when the transcript 

M will be posted? 

15 MR. HAGERMAN: No, we do not. But we 

16 will work diligently to get that posted as soon 

17 as possible. I like to err on the side 

1s usually, they send me the transcript, and then I 

19 review it to make sure that, you know, acronyms 

20 are right and concepts are right. And sometimes, 

21 I just err on the side of saying let's post it as 

22 quickly as possible rather than clean it up. 

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1 Because, you know, we're all technical people. 

2 We can get to the meat of the matter. 

3 So I'll move as fast as I can get it from 

4 them. 

5 MR. MOUW: Okay. Thank you. 

6 MR. HAGERMAN: It's not going to be two 

7 years. 

8 (Laughter.) 

9 MR. MOUW: But is it days or weeks? 

10 MR. HAGERMAN: I would say by -- he says 

11 it has to be weeks. But I've done it in the past 

12 in a couple of days. 

13 (Laughter.) 

14 MR. KIDO: At least that's been my 

1s experience. So . 

16 MR. HAGERMAN: Kido has never worked with 

11 me on one of these before. 

18 (Laughter.) 

19 MR. HAGERMAN: We try to do it faster. 

20 believe in a concept called real-time government. 

21 So. 

22 (Laughter. ) 

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199 

1 MR. BROOKMAN: Safe travels. And for 

2 those of you that are heading out -- see the rest 

3 of you tomorrow. Thank you. 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

(Proceedings adjourned at 2:36 p.m.) 

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1 CERTIFICATE OF NOTARY PUBLIC 

2 I, Brian Knieser, the officer before whom 

3 the foregoing proceeding was taken, do hereby 

4 certify that the foregoing proceeding was taken 

s by me and thereafter reduced to typewriting by me 

6 or under my direction; that the transcript 

7 contained herein is a true record of the 

s proceedings; and, further, that I am neither 

9 related to nor employed by any of the parties 

10 whose comments are contained herein. 

11 

12 

13 

14 Brian Knieser 

15 

16 My Commission Expires: March 14, 2019 

17 

18 

19 

20 

21 

22 

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