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 DEPARTMENT OF ENERGY

 APPLIANCE STANDARDS AND RULEMAKING

 FEDERAL ADVISORY COMMITTEE MEETING

 Department of Energy

 1000 Independence Avenue, S.W.

 Washington, D.C.

 Tuesday, July 2, 2013

 8:08 a.m.

Reported by: Christine Allen,

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1 A P P E A R A N C E S

2 Neil Eisner, Facilitator

3 DOE and ASRAC Representatives:

4 John Cymbalsky, ASRAC Designated Federal

 Officer, Supervisory Operations Research

5 Analyst, U.S. Department of Energy

6 Laura Barhydt, U.S. Department of Energy

7 Ashley Armstrong, U.S. Department of Energy

8 Other Selected Members:

9 Karim Amrane, ACHRI

10 Timothy Ballo, Earth Justice

11 Jeff Bauman, National Refrigeration & Air-

 Conditioning

12

 John Bean, Schneider Electric

13

 Rodney Beever, United Cool Air

14

 Mary Dane, Traulsen

15

 Paul Doppel, Mitsubishi Electric U.S., Inc.

16

 Mark Fly, AAON

17

 Geoffrey Halley, SJI Consultants, Inc.

18

 John Hurst, Lennox International, Inc.

19

 Charles Hon, True Manufacturing

20

 Jill Hootman, Trane

21

 Marshall Hunt, Pacific Gas and Electric Company

22

 Diane Jakobs, Rheem
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1 A P P E A R A N C E S (Continued)

2 Other Selected Members (Cont'd):

3 Tom Johnson, Daikin McQuay

4 Michael Kojak, Underwriters Laboratories, LLC

5 Karen Meyers, Rheem Manufacturing Co.

6 Peter Molvie, Cleaver-Brooks Product Development

7 Frank Myers, PVI Industries

8 Jeff Kleiss, Lochinvar, LLC

9 Harvey Sachs, American Council for an Energy-

 Efficient Economy

10

 Ronald Shebik, Hussmann Corporation

11

 Louis Starr, Northwest Energy Efficiency

12 Alliance

13 Frank Stanonik, ACHRI

14 Russell Tharp, Goodman Manufacturing

15 Robert Whitwell, Carrier

16 Wes Wostal, Climate Master

17 Navigant:

18 Aris Maranton

19 Michael Rivest

20 Collin Weber

21 Laura Degitsz

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

2 (8:08 a.m.)

3 MR. EISNER: Can we get started? We're on

4 certification of variable refrigerant flow multi5 split, air conditioners, heat pumps. Do you want to

6 finish this one and then go back to the ones where we

7 had IOUs from yesterday or do you want to go to the

8 IOUs first?

9 MS. BARHYDT: We can keep going through.

10 MR. EISNER: Okay. All right. We agreed to

11 some of these things. There were a few things people

12 wanted to check overnight.

13 MS. BARHYDT: So we were talking about

14 having the tested combination indoor unit, whether

15 it's ducted or non-ducted, and the cooling capacity,

16 the EER, the high heating COP for air source and the

17 heating COP for water source as well as the specific

18 test information.

19 You also had on there, "Controller necessary

20 to test." That would be included in the PDF or --

21 MR. DOPPEL: Paul Doppel, Mitsubishi. It's

22 a -- for most companies it's an actual piece and
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1 probably a PC is needed, also.

2 MS. BARHYDT: So meaning that you'd be

3 reporting a model number for the controller or what

4 exactly -- what's the piece of information that you're

5 --

6 MR. DOPPEL: Well, it's a piece of

7 equipment. It's like at --

8 MR. THARP: Like a channel changer for a TV.

9 MS. BARHYDT: Well, you wouldn't be

10 submitting a piece of equipment with your

11 certification report, I don't think.

12 MR. DOPPEL: No, no, no, but that's --

13 MR. THARP: This is just for information for

14 certification.

15 MR. DOPPEL: Okay. Oh, for certification,

16 and we wouldn't need to do that. That would be in the

17 PDF.

18 MS. BARHYDT: Okay.

19 MR. THARP: Information about the

20 controller.

21 MR. DOPPEL: Right. That'll be in the PDF.

22 MR. WHITWELL: Yeah, what's required to set
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1 the unit to run at the proper speed. Bob Whitwell

2 from Carrier.

3 Paul, I think, also, for the heat recovery

4 we would have the matching boxes.

5 MR. DOPPEL: That's listed.

6 MR. WHITWELL: That would have to be part of

7 the tested combination in the case of heat recovery, I

8 think; right?

9 MR. DOPPEL: Yeah.

10 MS. BARHYDT: Hold on one second. Is there

11 any other information?

12 MR. DOPPEL: That should be it.

13 MS. BARHYDT: Okay. Computer room air

14 conditioners. AHRI doesn't have a program for

15 computer room air conditioners. DOE regulations don't

16 have any specific requirements for computer room air

17 conditioners. I think our thought is that the

18 information would be very similar to the information

19 that's collected for other HVAC equipment, although

20 are there additional components? I know some of the

21 computer room air conditioners provide other

22 functionalities, such as controlling the humidity.
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1 Are there additional model numbers associated with

2 that or is that all just built into the models that

3 are the indoor/outdoor?

4 MR. AMRANE: Karim Amrane, AHRI. I don't

5 think I can answer that question, but I think maybe we

6 should add that topic to the discussion --

7 MS. BARHYDT: To the meeting with the --

8 okay.

9 MR. AMRANE: -- next meeting.

10 MR. STARR: This is Louis Starr with NEEA.

11 For computer room air conditioners, ASHRAE 127 has a

12 whole rating procedure, ASHRAE Standard 127. It

13 actually is different. They have an SCOP and some

14 other different metrics.

15 MS. BARHYDT: Right. The metric is

16 different, but in terms of what information we would

17 collect, what I meant was that we would collect them

18 metrically, collect the capacity, we'd collect model

19 numbers. It's just a question of how many different

20 model numbers are there that we would need to be

21 collecting so that we can account for that.

22 And then if we go back --
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1 MS. BARHYDT: So actually I think that goes

2 through the full list of all of the product types for

3 certification, so if you all want to go back to some

4 of the basic model outstanding issues. Was anyone

5 able to get any additional information about -- let's

6 see, did you actually have a slide that was dedicated

7 --

8 MS. TUCKER: No.

9 MS. BARHYDT: Okay. I've got a list.

10 MS. TUCKER: Not linking the list.

11 MS. JAKOBS: About the filters?

12 MS. BARHYDT: That was one of them, yes.

13 MS. JAKOBS: Yeah. This is Diane Jakobs

14 from Rheem. So MERV-6, that's a rating, it has to do

15 with what size particles and how much particles. It

16 doesn't have to do with static, so I'm kind of -- I

17 think that maybe if what we're trying to specify is a

18 static, we should do it some other way because you can

19 have MERV- 6, one inch thick MERV-6, that's one

20 pressure drop. You can have pleated ones, that would

21 be a lower pressure drop. So it seems like we're

22 trying to restrict or specify the pressure drop, and
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1 using MERV rating, I don't think that's --

2 MS. BARHYDT: Is not --

3 MS. JAKOBS: -- a good way to do it.

4 MS. BARHYDT: Okay.

5 MS. JAKOBS: The test entered, I think it

6 has a default of 0.08 if you test without a filter.

7 So I don't know if that would be a good kind of

8 standard value and then anything that's above a 0.08

9 inch water column pressure drop would be a premium

10 filter or some percentage above that.

11 MS. BARHYDT: So when we had spoken before,

12 I was under the impression that there was not a

13 provision in the test procedure that dealt with

14 filters, so you're saying that there is, in fact --

15 MS. JAKOBS: You have an option of testing

16 with a filter or using the 0.08. I called the

17 engineers at home.

18 MR. THARP: This is Rusty Tharp with

19 Goodman. The 0.08 is the residential product, 210/240.

20 MS. BARHYDT: Yeah.

21 MR. THARP: 340/360 itself does not mention

22 static filter requirements at all.
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1 MS. JAKOBS: At all?

2 MR. THARP: The ULE OM does not mention

3 filters. ASHRAE 37 does not mention filters. So for

4 the ULE product there actually is no requirement --

5 MS. JAKOBS: Okay.

6 MR. THARP: -- for filters at all in

7 today's specs.

8 MS. BARHYDT: Okay, because I thought that

9 was why we had the issue in the first place was that

10 there was nothing in the test procedure dealing with

11 it.

12 MR. THARP: Rusty Tharp again with Goodman.

13 And that's something obviously that needs to be

14 addressed, but my suggestion would be to test without

15 filters and just have pressure drop adjustment for

16 filters. That way the issue that Diane brought up of

17 --

18 MS. JAKOBS: I believe, yeah.

19 MR. THARP: Because she's absolutely right,

20 you can have MERV-6 that's a one inch, a MERV 6 that's

21 a four inch and those are going to have significantly

22 different pressure drops, and that could be, you know,
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1 the pass/fail difference for some product and it's

2 nice to have it consistent across the board.

3 MR. CYMBALSKY: So, John Cymbalsky, DOE. So

4 getting back to, you know, what goes shipped into the

5 real world versus the test procedure, so you do the

6 test without a filter, that's fine, but the customers

7 probably want -- I'm guessing, want some type of

8 filter in there or get some type of filter. So is

9 there -- we talked a lot about it yesterday. There's

10 a range 4 to 8 maybe, 6 sounded good, but --

11 MR. THARP: Rusty Tharp again. You're

12 correct. Some manufacturers, though, shipped product

13 without filters.

14 MR. CYMBALSKY: And let them do it in the

15 field.

16 MR. THARP: And let them do it in the field,

17 whatever they want. I will comment that I sat in on

18 an ASHRAE 62.2 meeting in Denver, and they have some

19 fairly extensive data on various filter MERV ratings

20 and pressure drop data that might be useful for

21 somebody to make that determination.

22 MR. FLY: Mark Fly with AAON. Just
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1 remember, Rusty, though, that 210 is used for the

2 stuff under five tons and it's three-phased, so it is

3 a test standard that we will be using in this program.

4 MR. AMRANE: Good point. This is Karim

5 Amrane with AHRI. And maybe one solution would be to

6 amend the test procedure to account for a default

7 pressure drop that we have in 210/240 standard.

8 MS. JAKOBS: This is Diane Jakobs again. So

9 you were talking about they would have filters, but I

10 think in the field you have to do maintenance and some

11 contractors like to do their own thing, you know, so

12 there's a lot of variability. And we don't always

13 supply the filters because they don't like it, so they

14 just throw it all away and they prefer to do their own

15 thing. So it's something that's kind of beyond the

16 equipment in many times, beyond our equipment that

17 we're supplying.

18 MS. BARHYDT: So we'll take another look at

19 this. I'm thinking probably what we will do is issue

20 some kind of short-term guidance and deal with it

21 long- term in the test procedure. I don't see that we

22 can do a whole lot other than that.
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1 MR. STARR: This is Louis Starr with NEEA.

2 Just one thing to consider is that if you're trying to

3 mimic real world conditions, obviously there will be

4 filters in the unit and also they will probably be

5 loaded up with dirt. So it seems like in order to

6 approximate the true performance of the equipment you

7 would want some kind of pressure drop allowance that

8 kind of reflects maybe what the real world conditions

9 might be of the operation of the equipment.

10 MR. DOPPEL: Paul Doppel with Mitsubishi.

11 We keep trying to make this an installed test and it's

12 not. It's a representative test. It's a test of the

13 basic refrigeration system. And, you know, if there's

14 a desire to do an installed efficiency, that's

15 totally, totally different than what we're talking

16 about here.

17 MR. CYMBALSKY: So I agree with that. I

18 guess what we're trying to do here is going back to

19 the motors example, which I don't want to actually

20 talk about right now, but if we're testing them all

21 without a filter, that's what the test procedure

22 allows you to do, but we know that all of them are
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1 going to have a filter. I think we should just try to

2 do -- I'm not asking for the perfect way out here, but

3 I think we can make a slight change and improve it and

4 we'd be happy, hopefully you'd be happy. I'm not

5 asking for the 8 or the 12, something that just would

6 be a more reasonable application to what we know is

7 happening. I think we could all agree that they're

8 going to put a filter in. It may be an 8, it may be a

9 4, it may be a 2, I don't know. But can we agree on

10 anything?

11 MS. MEYERS: So John, this is Karen with

12 Rheem, are you talking just for the equipment tested,

13 to 340/360?

14 MR. CYMBALSKY: Yes.

15 MS. MEYERS: Because we already have a

16 default value for the less than 510 three-phase. So

17 you're talking about --

18 MS. BARHYDT: Yeah, for the 210, the 210

19 provisions would apply.

20 MR. CYMBALSKY: Right.

21 MR. SACHS: John, this is Harvey, and I want

22 to thank Paul for representing the strict
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1 constructionist perspective so nicely, but it's not

2 just about the refrigerant cycle. It's about the

3 piece of equipment and that includes the airflow

4 through it. It's going to be an arbitrary decision

5 what the appropriate filter pressure drop is. It may

6 or may not reflect the concern with what it really is

7 in a dirty RTU on the top of a scumbag office

8 building, but it's not just, in my humble opinion,

9 maybe it's not humble, it's not just about the

10 refrigerant cycle. It's about the piece of equipment

11 and that means the airflow and thus the pressure drop

12 across the filter matter. I'm completely comfortable

13 with leaving this for the test procedure, but I think,

14 Paul, I belong to a different church.

15 MR. KOJAK: This is Mike Kojak with UL. I

16 just wanted to bring up, well, actually two things.

17 One, I wanted to suggest maybe we can do the same

18 thing that 210/240 has with the point, you know, if

19 you're running it without a filter you use the

20 default. And also, I just wanted to bring up for the

21 CRE people when we were talking about the filtration

22 for their units, I think it was brought up that we
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1 were going to test them without any kind of filtration

2 on it. So, you know, I just wanted to bring up is it

3 the same thing if a commercial refrigeration unit has

4 some filtrations you know, a filter on it, is it fair

5 that they get to remove it for the test, but the HVAC

6 people can't?

7 MS. BARHYDT: The issue for the commercial

8 refrigeration equipment was that if it had a specialty

9 filter, such as a flour filter, that would be removed.

10 It wasn't that all filters would be removed.

11 MR. DOPPEL: Paul Doppel with Mitsubishi.

12 You know, it seems that since we have several churches

13 represented that, you know, I mean, there's a reason

14 why we do this test. And if we can't agree, I mean,

15 we should be able to come up with an agreement on what

16 the reason for the test is and the criteria and the

17 circumstances. Because, you know, again, my

18 understanding and everything I've read, and I'm sure

19 other manufacturers would agree and Rusty's got it

20 right here. Is that, you know, the purpose of the

21 test is to do the basic refrigeration system test in a

22 test room condition that's based on, you know, a
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1 building, a configuration. It's not installed. It's

2 not what's going to happen installed. And, you know,

3 we have to be able to come up to some agreement that

4 it's either that or it's not. And if it's not that,

5 then what is it?

6 MR. STARR: This is Louis Starr with NEEA.

7 You know, I realize the limitations of the

8 refrigeration, that we're looking at the refrigeration

9 system, but, in reality, DOE test procedures are

10 actually supposed to mimic real world conditions of

11 how equipment's used. Because it can't really be

12 done, we're doing kind of the compromise, which is to

13 just look at the refrigeration as the most practical

14 thing at this time. It doesn't mean it wouldn't be

15 different in the future. So the closer we can get to

16 the more ideal thing where we're actually simulating

17 equipment that exists in the real world, the better.

18 So that would be my thought about it.

19 MR. THARP: This is Rusty Tharp with

20 Goodman. Actually the Section 42, U.S. Code 6314,

21 says, "Test procedures prescribed in accordance with

22 this section shall be reasonably designed to produce
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1 test results which reflect energy efficiency, energy

2 use, and estimated operating costs of a type of

3 industrial equipment or class thereof during a

4 representative average use cycle as determined by the

5 Secretary and shall not be unduly burdensome to

6 conduct." So it sort of goes in line with both

7 schools of thought, but a lot to what Harvey says.

8 MR. AMRANE: Karim Amrane with AHRI. And I

9 think I agree we probably should have some sort of a

10 default in the test procedure. At the same time, DOE

11 has to recognize the fact that the federal minimum

12 standards established today are based on the current

13 test procedure which does not account for a filter, or

14 at least this procedure doesn't account for it now.

15 So any future changes in test procedures should

16 account for that, too.

17 MR. SACHS: Harvey Sachs. And the question,

18 Karim, to me is, okay, we've all agreed in theory that

19 we ought to have some default added to the test

20 method. There are two questions. How do we get to

21 some sort of an agreement on a date certain by which

22 we do that? And the second question is, gee, is that a
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1 single value for all the 340/360 equipment or does it

2 scale with capacity? So I sure would sleep better

3 tonight if I understood that in 2037 we would finally

4 have this settled.

5 MS. BARHYDT: So, this originally came up

6 because there was a question about high-efficiency

7 filters. Is the norm right now to test with whatever

8 the manufacturer standard filter is or is the practice

9 right now to test with no filter at all? What do you

10 do right now if it doesn't have a high-efficiency

11 filter?

12 MS. MEYERS: This is Karen Meyers with

13 Rheem. For us, and, again, we just build kind of the

14 light commercial, we do it both ways, so it's kind of

15 a cross. If we test it without the filter and it's

16 the small equipment, we use the default value. So for

17 our equipment most high-efficiency filters are applied

18 in the field. So, you know, we have -- I don't even

19 know if I would call it a high-efficiency option, but

20 most of the time that is, you know -- it's definitely

21 not a MERV-8, but most of the time the high-efficiency

22 filtration for our product is applied in the field.
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1 MS. BARHYDT: But so if it's not high2 efficiency and it's not the small equipment being

3 tested under 210 what do you do?

4 MS. MEYERS: It's usually a standard

5 throwaway filter and it's not a high-efficiency filter

6 that's supplied, and it's tested with the filter.

7 MS. BARHYDT: And do you what the pressure

8 drop is from that filter?

9 MS. MEYERS: I don't, but I could get it.

10 But I think it's very minor. I know it's, you know, a

11 MERV, but -- well, we didn't have the MERV rating.

12 MS. JAKOBS: I was running out talking to

13 the guys yesterday, but they were saying if we sell it

14 with a filter, they'll put the filter in. It's a

15 filter that's so inexpensive they never actually ran a

16 MERV test and they're estimating it's between 3 and 4.

17 And if we sell it without a filter, they were using

18 the 0.08 even though I guess it's not required, but

19 they felt like probably they needed something, you

20 know, so they did that. But many times it seems like

21 people don't -- they didn't want to do their own

22 thing. That's part of the design for the installation.
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1 MR. SACHS: Laura, this is Harvey and maybe

2 I could translate what we've just heard from the

3 contractor's perspective. If it's not an extra cost

4 option, at best they put in what the contractors refer

5 to as a rock catcher. It keeps the largest particles

6 away from the evaporator coil.

7 MS. BARHYDT: Right. So my question is not

8 about the high-efficiency filters. It's about what do

9 you do right now for units with a standard filter, how

10 do you test? With or without the filter? And what

11 kind of filter is that or what is the pressure drop

12 associated with that filter?

13 MS. HOOTMAN: This is Jill from Trane. But

14 all of our models, it's a mixed bag. Literally, I

15 mean, there are customers that don't want them, just

16 like Diane was saying, so we ship them without. We

17 ship them with.

18 MS. BARHYDT: What do you test?

19 MS. HOOTMAN: And then test is done

20 typically with the lowest value of that particular

21 product family, but that varies across all these

22 products we're talking about. So some are very --
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1 MS. BARHYDT: But you would typically test

2 with a filter in there?

3 MS. HOOTMAN: Test is done with a filter.

4 MR. THARP: I think it's really a question,

5 I guess, would be what does AHRI do? Since it's not

6 in the ULE OM, do we just test with whatever's

7 received?

8 MR. AMRANE: Maybe he would know better than

9 me.

10 MR. STEM: Mike Stem, Intertek. If the unit

11 comes in with the filter, we test with a filter. If

12 it does not, then we go through the installation

13 manual and see what's recommended. If it's

14 recommended, we would go get one, put it in and test

15 it. If there's no mention of it in the installation

16 manual, then we test without a filter.

17 MS. BARHYDT: Okay, again, I think we're

18 going to go back and look at this. If anyone else,

19 there are still more manufacturers around the table,

20 have information about what they do when they test. I

21 mean, in the short-term, what we're going to be

22 looking to do is to reproduce current practice until
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1 we can actually address this through the test

2 procedure.

3 MR. CYMBALSKY: I mean, I guess my point is

4 wouldn't the manufacturers just want this to be

5 consistent? The competitors, I think, would say why

6 do they get no filter? There's this ambiguity here

7 where Mike just told us a bunch of these could be

8 tested without a filter. The ones that have a filter

9 are getting penalty with the pressure drop. So I

10 guess what I'm trying to -- what we want to do for

11 you, and, hopefully, this is a good thing, is if we

12 can just put a number there that we both can be happy

13 with, we're looking for consistency here in the short

14 run. If we could say it's a 6 or a 5, if we could

15 agree to something, I think it would make everybody --

16 MR. HURST: This is John Hurst from Lennox.

17 We do very similar to what Rheem does. What I'm

18 hearing is we're trying to approximate a MERV rating,

19 but MERV-4 isn't the approximation of a pressure drop.

20 Why wouldn't we come up with a consistent pressure

21 drop that approximates what we agreed on yesterday?

22 MS. BARHYDT: I agree. I think based on the
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1 information this morning that the MERV rating isn't a

2 good proxy for pressure drop, then, by all means, we

3 can look at a pressure drop.

4 MR. AMRANE: Karim Amrane, AHRI. But again,

5 here we're talking about the high filtration, the

6 high- efficiency filter here; right?

7 MS. BARHYDT: No, so the idea is to come up

8 with a standard way to do a standard test with a

9 standard filtration and that is what we would do for

10 people who are selling a high-efficiency. The whole

11 idea was how do we deal with high-efficiency? And

12 it's like, well, we do whatever we do for standard.

13 But then we've realized we don't know what standard

14 is.

15 MR. AMRANE: Well, that's the thing. The

16 current test procedure, it is a 340/360 test

17 procedure. It does not require a filter. So the

18 default should be testing without a filter. That

19 should be, I guess, the baseline today because that's

20 how the test procedure is written. Now, tomorrow we

21 can change that and that's fine. I mean, I'm not

22 arguing against that. But the baseline should be
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1 based on what the test procedure says today, which for

2 small product it should be the default -- whatever,

3 0.08 inches or for the large it should be nothing.

4 MS. BARHYDT: The test procedure doesn't

5 actually say test without a filter either. So by that

6 standard, if it ships with a high-efficiency filter,

7 we would test it with the filter that it's shipped

8 with, and that's what we were hearing people did not

9 want us to do. But the default isn't just to remove

10 the filter. The test procedure doesn't specify that.

11 MR. THARP: This is Rusty Tharp with

12 Goodman. This is obviously one thing that the ULE

13 Compliance Committee and Engineering Committee will

14 address in the near future and I'm sure we'll come up

15 with something as far as what industry recommendation

16 is to be consistent. So my recommendation will be

17 test without filter and add a delta-P for pressure

18 drop.

19 MR. CYMBALSKY: For the short run do you

20 have any -- for guidance, you know, in this really

21 short period of time? Because right now it seems --

22 MS. HOOTMAN: It will affect all of our
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1 ratings, John, so, I mean, just even to say right now

2 if we wanted to put a 0.5 in there or a 0.8 in there

3 of pressure drop, all of us would have to go back and

4 look at our ratings and see what that means to us

5 because it affects the fan watts, so, therefore, it

6 affects EER. And I don't know that any of us can just

7 sit here and say that. That might mean, in the end

8 run, how much we say it's going to take us to even

9 become compliant with this. You see what I'm saying?

10 MR. CYMBALSKY: Yes, I get it. I guess the

11 real issue is, you know, you want an exemption for the

12 really thick filters and so we don't even know where

13 we're starting from, and so that's a little bit, we

14 don't know how much we're giving up in the EER based

15 on that.

16 MR. THARP: Rusty Tharp with Goodman. I

17 would suggest that we come back at the next session in

18 two weeks with specific values. I don't know if we

19 can, I can try to get something together for my

20 company. I don't know if anybody else can or not, but

21 I think we can probably grab something.

22 MS. HOOTMAN: Well, I could have probably
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1 done it overnight, but I just didn't.

2 MS. MEYERS: But how practically can we

3 implement that? I mean, I understand the long-term

4 request, but the current federal law says 340/360 and

5 so I don't see how we make this change in the short6 term. I mean, how would that guidance work?

7 I mean, if we decide as a group, for

8 instance, let's use the same default value that we use

9 in 210/240, if that affects everyone's ratings does

10 that mean the 11.0 EER suddenly becomes 10.95? I

11 mean, how practically can you implement that?

12 Long term I get it. We need to change the

13 test procedure to account for it. But I don't see how

14 we do this short-term.

15 MS. BARHYDT: The alternative will be for us

16 to ship however, I mean, test however it's shipped.

17 And if it's shipped with high-efficiency, it's tested

18 with high-efficiency.

19 MR. SACHS: This is Harvey. Laura, just to

20 be clear, what I'm hearing is, manufacturers, you want

21 to make sure that you're not offering high-efficiency

22 except as an option so that DOE doesn't penalize you
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1 on a test that you didn't mean to have tested.

2 MR. CYMBALSKY: Correct.

3 MR. DOPPEL: Paul Doppel with Mitsubishi. I

4 think what everyone is saying is that, you know, we

5 have been testing according to the test procedures:

6 340/360, 1230, 210/240 have all been test standards

7 that have been accepted for many, many, many years and

8 in the 10 CFR are annotated as the test procedures.

9 And, you know, if the procedures need to be changed,

10 then, you know, DOE needs to add that somewhere that

11 we put the filters in there. But, you know, right

12 now, we've been testing in a certain way and the

13 efficiency targets that have been established are

14 based on the current test standards. And if we're

15 changing the current test standards, then

16 consideration needs to be given to the efficiency

17 standards.

18 No one's saying that we're trying to outwit

19 DOE. We're just trying to say that, you know, there

20 are certain procedures that we've been going by and we

21 would like to be able to, you know, have somewhat

22 knowledge other than with systems already in AHRI
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1 directory. All of a sudden now they say, okay, you

2 have to add a dirty high-efficiency filter; you have

3 to have the alternate static motor. There's no way

4 that anyone is going to be able to meet the minimum

5 efficiency.

6 So it's just any time there's -- in the past

7 I think it's a requirement there has to be a five-year

8 delay if there's a significant change in the

9 efficiency levels.

10 MS. BARHYDT: So we're not trying to change

11 the test procedure. We're trying to accommodate a

12 request to not test with a high-efficiency filter.

13 MR. DOPPEL: Right, but that's not where the

14 conversation has been going.

15 MS. BARHYDT: And in the process we

16 discovered that nobody in this room is testing the

17 same way.

18 MR. EISNER: So, Paul, why is it a good idea

19 to continue testing the way they're testing if people

20 in the room feel that's not fair?

21 MR. DOPPEL: Paul Doppel. What I'm saying

22 is that it's the -- everybody has been going by what
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1 they know as the test procedure. And, you know, we

2 can get clarification, but if there is clarification

3 given to that testing, then consideration has to be

4 made to the changes that manufacturers are required to

5 make.

6 MS. JAKOBS: Diane Jakobs from Rheem. So

7 going back to we're trying to differentiate between

8 high-efficiency filters and regular or plain

9 efficiency or whatever. So I think I would use 0.08

10 inch water column value from the residential and maybe

11 we can make it a tenth of an inch water column

12 pressure drop, and anything with a higher than that

13 pressure drop would be categorized as high-efficiency

14 and that would be it.

15 MR. AMRANE: This is Karim Amrane with AHRI.

16 I think, Diane, before we can agree to any level I

17 think we need to really make sure of what this level,

18 this pressure drop will do on the efficiency of the

19 product. I mean, apparently --

20 MS. JAKOBS: But below everything would just

21 be the same as it is now, whatever we're doing now.

22 It's just that if it's higher than a tenth of an inch
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1 or 0.08 inch water column, DOE would not select that

2 unit.

3 MR. RIVEST: Mike Rivest. Can I ask you a

4 couple of questions? Is there an option to buy a unit

5 without filters?

6 (Chorus of yeses.)

7 MR. RIVEST: Okay. How do you implement

8 that one inch pressure drop? Is that restriction put

9 in the apparatus?

10 MS. JAKOBS: Did you say one inch?

11 MR. RIVEST: Point one inch, I'm sorry.

12 MS. JAKOBS: We're messing with the orders

13 of magnitude.

14 MR. RIVEST: It's just a number. To me it's

15 just a number, you understand this.

16 MS. JAKOBS: I'm getting really nervous. I

17 keep jumping up and I want -- yeah. So what was your

18 question?

19 MR. RIVEST: How do you implement that 0.1

20 or 0.08? Is it changing the apparatus to put more

21 restriction in it and measuring --

22 MS. JAKOBS: Okay, add the 0.08?
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1 MR. RIVEST: -- or it's a calculation?

2 MS. JAKOBS: Yeah, just the external static.

3 It would be additional, added to the external static

4 pressure when we run the test.

5 MR. STEM: You turn down the airflow tunnel.

6 Turn down the airflow; I think this one is on the

7 airflow.

8 MR. RIVEST: So if the test procedure to

9 says run the unit at 0.45, you would actually be

10 running it at 0.45 plus 0.08?

11 MS. JAKOBS: Yeah.

12 MR. RIVEST: All right.

13 MR. STEM: Right. And I just want to say,

14 you know, the 0.08 for smaller systems is probably

15 realistic because it's a smaller area. For the larger

16 systems, I think Harvey made a comment about bigger

17 systems, bigger pressure drop. You actually have more

18 area, so the pressure's not going to be as high for

19 the larger systems, so it's probably going to be a

20 little bit counterintuitive when you think about

21 pressure drop on the larger systems. But, you know,

22 there are a lot of other standards that have set
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1 precedent for, you know, if they're meant to be

2 installed with the filters, and not just 210/240, but,

3 you know, the fan cooled standards. I think was it

4 430 that does the --

5 MS. HOOTMAN: The air handlers.

6 MR. STEM: -- air handlers, yeah. And I

7 think it's, you know, at least for the fan cools you

8 have 0.05 for Furr end units, things like that. So, I

9 mean, I think Rusty was on the right path with the

10 ASHRAE committee that already did the research work.

11 So, you know, if you could bring that into the picture

12 and actually have the details for what pressure drops

13 from what style of filters that would give you a

14 pretty good direction of where to set those numbers.

15 MS. MEYERS: So, Neil, this is Karen Meyers

16 with Rheem. I have a recommendation. So since high17 efficiency air filtration is an option for most units

18 that we treat this like we do the economizers and

19 such, so that if DOE were to pull one of these units

20 for tests, they would pull the one without the high21 efficiency air filtration or they would remove it

22 prior to the test.
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1 MS. BARHYDT: So I think what we're thinking

2 is along those lines, but we'll just make a point of

3 buying one with a standard air filter and we'll test

4 it with the air filter that it's shipped with. And if

5 the manufacturer doesn't ship it with an air filter,

6 it'll be tested as it arrives. And that's for the

7 larger units. The ones that are subject to 210/240

8 are still subject to the provisions of 210/240.

9 MR. KOJAK: I have a question about that.

10 If it arrives without a filter, but in the

11 installation manual that we're supposed to go by when

12 we install it and the lab to test it and it says in

13 there to add a filter, I would think you'd have to add

14 a filter.

15 MS. BARHYDT: Yeah, we always follow the

16 manual.

17 MR. KOJAK: Okay. So if it doesn't say it

18 at all and it doesn't ship, then you'd test without

19 it?

20 MS. BARHYDT: Yeah.

21 MR. KOJAK: And if it comes without, but it

22 says to put it in, then you put it in.
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1 MS. BARHYDT: Yeah.

2 MR. KOJAK: Okay.

3 MR. EISNER: And does it pay to write up

4 this guidance before the next meeting and talk about

5 it?

6 MS. BARHYDT: I think we're going to be

7 doing a whole lot of drafting.

8 MR. STARR: This is Louis Starr with NEEA.

9 So the ASHRAE standard's 52.2 and they actually go

10 through a little list that, you know, typically air

11 handlers are always -- well, I should say in

12 commercial markets the schedules come out and it used

13 to be 30 percent air filters with the core response

14 MERV-5 to MERV-8. And they're usually just one inch

15 because the four inch costs a lot more money. There

16 is kind of a typical standard of how things are done.

17 Obviously, there's multiple markets and so they sell

18 equipment to many markets.

19 But I don't have the solution of following

20 the instructions out of the installation manuals. A

21 lot of times they're put in there more for liability

22 purposes. In other words, it's going to say, you know,
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1 install the filters because maybe if you don't put the

2 filters there could be some, you know, effect the

3 warranty, so they're trying to make sure that isn't.

4 So, in other words, the people that do due diligence

5 in doing what they should do is putting filters in

6 there are going to be penalized, so it does seem like

7 you should come up with some magic number of 0.08 or

8 whatever it is.

9 MS. BARHYDT: And the Department agrees, but

10 I think we're going to address that through a

11 rulemaking.

12 MR. EISNER: Any other discussion on this

13 issue?

14 MR. CYMBALSKY: So I'll just end it by

15 saying we like the high-efficiency air filters. I

16 think that's a great idea. And honestly, we just want

17 the testing to be a level playing field for all of you

18 and for us to understand it. We're not trying to put

19 a requirement in today so we can go buy a bunch and do

20 our thing. That's not the intention here at all.

21 So it sounds like a long-term fix, but if

22 Rusty and your group come back with any ideas in two
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1 weeks that we can think about long-term or short-term,

2 that would be great.

3 MS. BARHYDT: So did anyone have any

4 additional information about coated coils?

5 Not yet?

6 MR. HON: Charlie Hon, True Manufacturing.

7 We've come up with a lot of different pieces of

8 information, none of which are definitive by any

9 stretch of the imagination, because we could do a

10 multitude of different ways to decide if it's truly a

11 coated coil or not. You could use some arbitrary salt

12 spray number to prove that it was actually doing

13 something worthwhile. You could use some thickness,

14 but it may or may not be worthwhile. There's no

15 perfect answer to it without some actual field tests

16 or product tests requirements, and so we didn't really

17 get a good answer.

18 There are some NSF requirements in Standard

19 7 which give you different levels of coating

20 thicknesses and different levels of coating salt spray

21 for different levels of protection. Those range

22 anywhere from fairly low volumes, fairly low times up
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1 to 500 hours, but that would certainly be unrealistic

2 for what we're doing here.

3 MR. SHEBIK: Ron Shebik with Hussmann.

4 Yeah, unfortunately, I tried to get a hold of some of

5 our competitors to get their feedback and I have not -

6 - I only heard back from one so far. So,

7 unfortunately, nothing to report on this.

8 MS. BARHYDT: Okay.

9 MR. RIVEST: Mike Rivest. You know, when

10 you go to market you make representations about these

11 products. Could the requirements be linked to the

12 representations that you make? So if you say to be

13 used in coastal areas and a five-year warranty, then

14 that would be, you know, beyond what you would be

15 saying about your baseline model, for example.

16 MS. MEYERS: Do you want to share that?

17 MS. HOOTMAN: Corey, I mean, I can somehow

18 send this to you --

19 MS. TUCKER: Yeah, or we can get --

20 MS. HOOTMAN: -- if you want after I say

21 this. This is Jill Hootman from Trane. "Corrosion22 protected condenser coils -- an optional coil that is
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1 likely to provide excellent resistance and durability

2 to corrosive effects of alkalis, acids, alcohols,

3 petroleum, seawater, salty air, and other corrosive

4 environments. Typical processes include a baked

5 phenolic, cathodic epoxy-type electrodeposition,

6 coating or thermoset vinyl, coating that is bonded

7 after coil is assembled, covering the coil tubes,

8 headers, and fin surface. For mildly corrosive

9 environments coils can be assembled from aluminum fin

10 stock that has been coated prior to the fin stamping

11 process. Corrosion durability shall be confirmed

12 through testing per ASTM B117 salt spray test."

13 It's a kind of a definition that --

14 MS. MEYERS: That was what you asked, was

15 this

16 --

17 MS. HOOTMAN: How do we define this coil --

18 MS. MEYERS: How do we define it?

19 MS. HOOTMAN: -- versus a standard coil?

20 (Off microphone discussion.)

21 MR. DOPPEL: Paul Doppel with Mitsubishi. I

22 think we're also looking, first, like a 500-hour or a
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1 1,000-hour test standard.

2 MS. HOOTMAN: Well, it's all over the map,

3 so I just said that it might. I saw all over the map

4 how many people -- what people did on the hour test,

5 but I said that it had to at least be tested to that.

6 And yeah, I think you have to determine what your

7 durability, you know, needs to be because there are

8 people doing 500, there's people doing one-thousands,

9 there's two-thousands, there's everything. So I kind

10 of didn't want to recommend exactly one, but saying

11 that durability tests had to be done.

12 MS. BARHYDT: So the ASTM is a test method

13 and you test it and you basically see how long your

14 particular coating lasts?

15 MS. HOOTMAN: That's right.

16 MS. BARHYDT: So we probably would want to

17 set some limit, like if it added five hours, that

18 wasn't good enough. And if it had it --

19 MS. HOOTMAN: Most minimums I saw were 500.

20 There are a lot that exceed that.

21 MR. HON: This is Charlie Hon.

22 MS. HOOTMAN: Five hundred hours.
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1 MR. HON: That's in the external environment

2 that they're facing. We're talking a different world

3 as well. We have wire shelving which is used directly

4 inside the product. It goes through dishwashers and

5 all kinds of other things. That has a 500-hour salt

6 spray. It's taken out every day and washed.

7 There are other components that are inside

8 of the cabinet which require, what, it's 192-hour salt

9 spray. That is considered wiped down, scrubbing all

10 the time type salt spray in our market, so we're

11 talking two different worlds here. Five hundred for

12 us would be totally unrealistic.

13 MR. THARP: Okay.

14 MR. DOPPEL: This is Paul Doppel with

15 Mitsubishi. We're talking coils. You don't have

16 coils that are --

17 MR. HON: Yes, we have coils inside the

18 refrigerator.

19 MR. DOPPEL: That are washed every day?

20 MR. HON: No, but they are subject to the

21 same -- a lot of the same corrosive activities.

22 Unfortunately, they're not washed every day.
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1 MR. DOPPEL: Well, do they have coatings on

2 them?

3 MR. HON: Yes, some of them do. We have

4 options for coatings. And if you do not wash them

5 every day, you have a much worse condition than if you

6 wash them every day. So that's a thing that we have

7 to consider because they do not get cleaned. They're

8 behind a shroud.

9 MR. DOPPEL: So how often are they replaced

10 then?

11 MR. HON: With an actually coated coil we

12 have a very, very low replacement record. With an

13 uncoated coil it'd be very bad. We'd be replacing

14 coils every couple years.

15 MR. DOPPEL: Paul Doppel. But then it seems

16 that that coating would surpass the 500-hour.

17 MR. HON: Our records indicate that it

18 doesn't; 250 or 300 hours is quite normal for us to

19 see coating records testing.

20 MS. JAKOBS: This is Diane Jakobs from

21 Rheem. And I think that really we need to look for a

22 threshold between kind of the plain one and the
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1 corrosive- resistant one. You're not really looking

2 for what's a good corrosive-resistant to prove that

3 you have a good corrosion-resistant product. It's

4 just are you trying or you're not trying, and then the

5 Department's not going to select that equipment if

6 it's specially designed for a corrosive environment.

7 So I think that, you know, the bar isn't as high, so,

8 you know, the idea that you market it for a specific

9 purpose.

10 And the definition, it seems like that would

11 be sufficient that you don't really need -- if you're

12 selling it as a corrosive-resistant product and it's

13 not, then people will know before too long that it's

14 not working. So maybe we're overthinking it too much.

15 MR. SACHS: John, this is Harvey Sachs. I

16 want to try to capture what I think I've heard in the

17 hopes that it's helpful. A small fraction, but I

18 don't know what that fraction is, of units are shipped

19 with coils that are designed to inhibit destruction in

20 the environment in which they're to be used. Does

21 anyone have an idea of what that is? Is it one

22 percent or 10 percent across these indoor markets for
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1 CRE versus the outdoor markets for condenser coils?

2 MR. THARP: Rusty Tharp with Goodman. I'd

3 say that it's low single digits for outdoor product.

4 MR. SACHS: Okay. No, that's very helpful

5 where I'm going. The second point to me is the real

6 thing is that these coatings may decrease the

7 efficiency of the unit.

8 MR. DOPPEL: Initially.

9 MR. SACHS: Initially, as tested, given Paul

10 Doppel's constraints.

11 (Laughter.)

12 MR. SACHS: After all, it's in the lab. I'm

13 teasing you, Paul.

14 But the important point to me is the

15 Department wants everything that's shipped to meet the

16 efficiency standard and the manufacturers don't want

17 to have to ship these corrosive ones with a different

18 color chassis, a different refrigeration system to

19 compensate for the losses, whether those are heat

20 transfer losses or airflow losses. So the question

21 really boils down, to put it blunt, to whether there's

22 some percentage of product you're willing to wink at
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1 knowing that it would not pass, so you won't test it.

2 Because that's really what I think this discussion's

3 about.

4 MR. CYMBALSKY: So I think the enforcement

5 issue's different than what you just stated, which

6 sounds a lot like backsliding to me, which you would

7 allow a certain percentage of product to not meet the

8 standards. So instead of a 10 it could be a 9-point9 whatever, so that's kind of an issue that we have with

10 that.

11 Enforcement-wise, I think a lot of the

12 topics we're talking about are driven towards

13 enforcement guidance or test procedure guidance, but I

14 think with this one, if we're sticking to the CRE

15 guys, I think they may have a difference of opinion on

16 this one because I think some of them, at least what I

17 heard, all their products, whether it has coating or

18 not, are going to meet the standards. So I think --

19 did I hear that? I think I heard that from you,

20 Charlie.

21 MR. HON: Charlie Hon. We are self22 contained. You know, you just roll it and plug it,
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1 plug and play and you're ready to go type equipment,

2 more than 90, 95 percent of our market. When we ship,

3 everything we have right now, there are probably less

4 than five percent of our total -- definitely less than

5 five percent of our total sales that have coated

6 coils. There are two categories within that, one of

7 which is a specialty item, which is a customer order

8 and an upcharge-type of design for a coated coil

9 insert and applications. Others are standard product

10 which have a coated coil because we know that the

11 entire market is aggressive, such as service-over12 counter. That service-over-counter has a special set

13 of numbers which are more lenient to compensate

14 because everybody's done this in the industry.

15 So when you start talking specials,

16 nonstandard, we're talking far less than one percent

17 of the market in our area. That does not do, I don't

18 want to ever speak for the grocery store-type units

19 because that's a different market that I do not know

20 the numbers for.

21 MR. RIVEST: Mike Rivest. So, you know, I

22 always go back to how we do the engineering analysis
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1 and derive the cost efficiency curves, and then what

2 is assumed to be the baseline system and the utility

3 of that baseline system. And then when we add

4 features that create utility but also cost, we create

5 product classes for that.

6 The idea of having certain product classes

7 that have coating in the base unit, you know, sort of

8 renders it difficult to say -- to define a base

9 coating and then a better coating. And I come back to

10 looking at it from the perspective of the market. You

11 probably wouldn't sell any of those cases without a

12 coating, so the baseline there is a coating. So if

13 you have an option in your product literature that

14 would be the standard case and then there would be the

15 special coil, you know, it's a market representation

16 that you make and you're liable. If you were to sell

17 a coil that doesn't meet that very basic requirement

18 under -- you know, you're not going to invent uncoated

19 coils if they don't exist today because you have to

20 meet your warranties.

21 So that takes away all the need for

22 specification. It just becomes a representation that
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1 this is a coil intended for these conditions. It

2 would be a more expensive coil and it's one that you

3 need for your warranty purposes and for your liability

4 purposes, and we get away from the specification.

5 MR. HON: This is Charlie Hon. That's

6 exactly the reason the service-over-counters have

7 those. We don't build any without it because of the

8 need of the marketplace.

9 MR. RIVEST: So there would be no exemption

10 in your case --

11 MR. HON: No.

12 MR. RIVEST: -- because --

13 MR. HON: I do not know what other groups do

14 because service-over-counter goes well beyond the

15 self- contained units.

16 MR. RIVEST: Right.

17 MR. HON: So I do not know what happens as

18 far as the remote cases go because I do not had a big

19 enough database to ever know that information.

20 MR. RIVEST: Right, whereas if we're talking

21 about a split system or a rooftop that clearly has a

22 design as an option to purchase a covered coil
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1 recommended for these applications, then it's clear

2 that it's something different, more coated, more

3 costly.

4 MR. HURST: This is John Hurst with Lennox.

5 If you had 100 percent of your product with a coated

6 coil, by definition that would be your base model.

7 Okay?

8 MR. DOPPEL: Yes.

9 MR. THARP: Right.

10 MR. HURST: If you have a coated coil on a

11 product line that has one, two percent of a total

12 volume, another alternative is instead of the

13 manufacturer designing a specific model to account for

14 the addition of the coated coil, manufacturers may say

15 it's not worth it for that volume. It'll be a field16 installed option. And I'm concerned that if it goes

17 to being a field-installed option you're not going to

18 get the consistency or the quality that you would have

19 as a factory-installed option. But manufacturers may

20 just back off and say it'll be a field-installed

21 option from this point on, and I think we defeat the

22 purpose of what we're trying to accomplish.
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1 MR. HON: This is Charlie Hon again. In

2 self- contained equipment, field-installed options

3 like that don't exist. That's the base core of your

4 product.

5 MR. HURST: I'm not talking about the 100

6 percent.

7 MR. HON: Right.

8 MR. HURST: I'm talking about the one

9 percent

10 MR. HON: Even at one percent we would never

11 do that. It would never work in the field. In remote

12 cases --

13 MR. HURST: I didn't say it worked.

14 MR. HON: In remote --

15 MR. HURST: I didn't say it would work and I

16 didn't say it would be installed properly.

17 MR. SHEBIK: Ron Shebik with Hussmann. I

18 would agree with you, you would not want a coil to be

19 field-installed on a remote grocery case. And

20 speaking for my company, the cases that we do have

21 coated coils, we test all those coils. We test those

22 cases. The problem is I cannot speak for our
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1 competitors. I don't know the background. I don't

2 know if they have some low-volume coating coils that

3 they would wish to not test because of the low volume,

4 so I can't give a firm answer on that other than the

5 fact that speaking on behalf of my own company we test

6 everything that goes out and the coated coils are all

7 tested because it's the third-party application

8 requirement.

9 MR. HON: Charlie Hon. Everything that we

10 produce with coated coils could meet the standard.

11 It's not a problem to us, but I don't want to speak

12 for other parts of the industry. We have always

13 tested and when they were normally applied we have

14 tested with them. Our numbers are set; we know where

15 they are. So from my company's viewpoint, coated

16 coils are not a problem under the existing numbers. I

17 do not know about other companies.

18 MR. BAUMAN: This is Jeff Bauman from

19 National. I agree with this. And I think we started

20 out, in talking about the issues with CRE, we put

21 coated coils kind of -- it wasn't something I think

22 any of us really thought would be a big issue on CRE,
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1 but I think we're kind of becoming more an issue,

2 again, because we use coated coils. But the fact that

3 I think Charlie's products, Ron's products, our

4 products, Mary's products, we use coated coils in our

5 evaporators because of the applications. I don't know

6 of anybody around this table that it's an issue for

7 because we all test with the coated coils.

8 I don't know of products that, again, Ron,

9 you know, as representatives, our job here is

10 representatives of what we know about the industry, I

11 don't think this is an issue for commercial

12 refrigeration equipment, coated coils, personally. If

13 somebody else has a comment, obviously they'll have a

14 chance to talk about that later when you guys get

15 comments back and, hopefully, people on the phone

16 listening in, they can raise those issues if they're

17 out there. But I think as far as this, you know, our

18 positions of representing the industry, I don't think

19 we have an issue with coated coils.

20 MS. DANE: This is Mary from Traulsen. The

21 only thing I can think of outside, and I do have

22 requests out, too, would be not so much in the under-
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1 counters, but maybe with something that has an outdoor

2 or a military application where it goes on a ship or

3 something like that would maybe have a different

4 higher coated coil, but we can find that out and

5 report back.

6 MR. CYMBALSKY: Okay, thanks. I guess

7 that's what I was trying to say. I don't know if I

8 said that precisely, but I thought I heard earlier

9 that that -- it wasn't a real big issue for you.

10 Okay.

11 MR. BAUMAN: And I'm to sit back and let you

12 duke it out with the HVAC people.

13 MR. CYMBALSKY: Well, I may be willing to

14 throw something on the table for this.

15 MR. SACHS: This is Harvey again. We were

16 trying to think about the HVAC side rather than the

17 refrigeration side and I wonder if there's more to be

18 asked and answered about that.

19 MR. CYMBALSKY: I guess the program's point

20 of view here is that so for residential AC, if you

21 have coated coils, you know, you don't get an

22 exemption. It is what it is. Frankly, for commercial
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1 AC, I see it the same way personally. You know, it is

2 what it is there. So maybe we can horse trade with

3 the motors requirement for the coated coils. I don't

4 know.

5 MR. AMRANE: Karim Amrane, AHRI. You're

6 saying it is what it is, but when DOE does its

7 analysis on the efficiency standard I don't believe

8 the DOE accounts for that either.

9 MR. RIVEST: We just do an analysis.

10 MR. AMRANE: Well, the one that you did in

11 the past never accounted for coated coils.

12 MR. RIVEST: We never did one in the past.

13 MR. AMRANE: I'm talking about residential.

14 We're talking about residential. We're talking about

15 even the commercial. All the analysis that I've seen

16 never accounted for the coated coils. So, again, I

17 mean, yes, if you do this, then it has to be accounted

18 for, that's all I'm saying.

19 MS. JAKOBS: This is Diane Jakobs from

20 Rheem. And I looked it up and I was curious about

21 that, too, because when I looked up the last

22 regulation, whatever, you referenced ARI, the data in
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1 the ARI database. So it just seemed to me the way I

2 think about things that you would have, by doing that,

3 been adopting the ARI characterization, definitions,

4 basic model by using their data, so, to me, it didn't

5 seem right that we could be changing the definitions.

6 You based a regulation on how ARI tested and

7 characterized and listed the data, and ARI looked at

8 the refrigeration system and the smallest, simplest

9 blower. And whatever we were doing, if you used that

10 data when you did the regulation, it is what it is, to

11 me, I mean, that you had adopted that method of

12 looking at characterizing the equipment.

13 So all through this whole thing I've been

14 kind of confused about how you can be changing

15 definitions now. It could be that people didn't

16 understand everything about it, but I think by

17 actually, when I read in the CFR what the -- the

18 discussion, part of it, it seemed like DOE didn't do

19 any specific testing or analysis, but they did

20 reference ARI directory data, so.

21 MR. CYMBALSKY: So, again, going -- so we're

22 talking the residential ones now?
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1 MS. JAKOBS: No.

2 MR. CYMBALSKY: No, okay.

3 MS. JAKOBS: Commercial.

4 MR. CYMBALSKY: I guess my question is, if

5 you -- your basic model's going to be the one without

6 coated coils, but then you coat them and what happens

7 to the efficiency of that unit, all else equal? So

8 the question is do you rate -- again, the rating

9 should be -- of the basic model, in my mind, should be

10 the lower of those two numbers. Otherwise, you can

11 coat any -- coat all the coils and have 12 SEER. I'm

12 going to use the residential example because that's

13 the one I'm more familiar with. So now you have a 12

14 instead of a 13 SEER as your basic model, in my

15 opinion. And I don't see anything in our rule that

16 would say that that was an okay thing to do.

17 MR. THARP: Rusty Tharp with Goodman. I

18 guess along those lines it goes back to it's still the

19 difference in the definition of "basic model." The

20 industry position has always been that the basic model

21 is a base model. And we feel that, you know, all the

22 base models, the basic models that we ship, are in
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1 compliance and then any of the bells and whistles or

2 adders for the application requirements may, you know,

3 all those alter the applied efficiency, going back to

4 what Mr. Doppel likes to talk about.

5 But that's the same story with the

6 residential product in that, you know, there's a

7 testing efficiency that we try to make as -- you know,

8 the Department tries to make the test procedure as

9 realistic as possible. And any differences from that

10 test procedure as applied will alter the efficiency in

11 the field, some improving energy consumption, some

12 hurting energy consumption. So that's the same case

13 residential or commercial. And for the commercial

14 products our industry position is that the base model

15 is basic and all the basic models we ship are in

16 compliance.

17 And I'll also go back to the U.S. Code 42

18 USC 6314, Section 4, says that -- it basically talks

19 about that DOE's to adopt the industry test procedure

20 wherever possible. So it goes back, even when this

21 was written, that the industry test procedure, which

22 our test procedure's always reference to the -- well,
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1 our definition of basic model, the BMG, and that's

2 where -- you know, that's the basic model and that's

3 the test procedure we have.

4 MS. JAKOBS: This is Diane Jakobs from

5 Rheem. But, you know, the ARI directory predated the

6 efficiency. And to me, the basic models were like the

7 cheapest thing, the plainest thing you could buy. And

8 in our installation instructions, and I don't know if

9 anyone else does it, but we give calculations, say, if

10 you add, I think for the high static blower there's a

11 calculation that you can do about how your capacity is

12 affected. So if you're smart you know that, you know,

13 if you're losing capacity, you're probably losing

14 efficiency.

15 So there is something there that states you

16 buy the plain one, you add this option, your output

17 capacity will be affected. But to this audience of

18 engineers, you know. It's not the same residential

19 guys, it's a different -- it's an engineer

20 installation. It's kind of a different way of looking

21 at it. And I'm struggling, too, because my

22 background's residential furnaces.
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1 But, yeah, I've been trying to make sense

2 out of it for myself and that's just the way it seems

3 to be, you know, that there was this directory of --

4 it's kind of amazing when you think about the whole

5 variety of applications and all the things that Mark

6 has talked about, about operating rooms and warehouses

7 and all this stuff. And they figured out a way, ARI,

8 to sort it all out and kind of give a comparable

9 number that you could work from. And then you add

10 stuff on and -- but it was all based around the sealed

11 refrigeration system and then all these bells and

12 whistles were add- ons. And I think, you know, the

13 criteria might have been at a cost, so.

14 And for sure, it wasn't efficiency. That's

15 not the way people have thought about it, you know.

16 And that's probably why we're all here because it was

17 like, oh, my gosh, that's not what we're -- you know,

18 that's not how we think. And you can tell from the

19 natural reaction that there's a mismatch, yeah.

20 MR. CYMBALSKY: I appreciate your candor. I

21 mean, so when you say -- you use those words like I

22 think of them. You said the base model is the
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1 cheapest.

2 MS. JAKOBS: Yeah, like an economy car.

3 MR. CYMBALSKY: The least efficient one.

4 MS. JAKOBS: I don't know, you know.

5 MR. CYMBALSKY: Right. It's the one that

6 MS. JAKOBS: It doesn't have a radio.

7 MR. CYMBALSKY: Yeah, I mean, that's the way

8 I'm looking at it. So, you know, to me, if you make

9 and, again, I'm going to use the residential example,

10 you know, if you have a 13 SEER unit, you're designing

11 it just to meet the standard, which is fine, but if

12 you're going to spray the coils with noncorrosive for

13 the people who need it, it seems to me that it should

14 still be a 13 SEER unit. I mean, that's my --

15 MS. JAKOBS: But I think it evolved

16 differently. It was like outside people started

17 coating them and then it would be -- there were

18 problems with that and then it'd be better if it was

19 done in the factories. So all these things, they

20 started out as being options, add-ons in the field,

21 and I think everyone agrees that it's better if it's

22 done in a more controlled way in the factory. So they
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1 just kind of evolved, but the -- go ahead, someone

2 else.

3 MS. MEYERS: So this is Karen with Rheem.

4 And I think it's important to note that, you know, you

5 have your base model, but then all these other options

6 that can be added to the unit are not done at a --

7 there is a cost associated with that. So under no

8 instances would somebody be adding an option to get

9 away from meeting the minimum efficiency standard.

10 It's just not practical. So the options are added to

11 meet -- there's a utility out there to meet a

12 commercial installation and it's not done as a way to

13 -- as a loophole to meet the minimum efficiency

14 standard.

15 MR. DOPPEL: Paul Doppel with Mitsubishi.

16 When I was with another company, we found out that --

17 and Rusty may have been associated with that company,

18 too.

19 But we found out that we were getting a

20 significant business on sea coast applications because

21 we had a good warranty for our products, but our coils

22 were not coated. And so every two years people would
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1 just get a new coil from us because their coils were

2 totally gone. And once we, you know, kind of figured

3 this out, we said, well, no, this isn't going to work,

4 so you're going to have to have a coated coil.

5 So, you know, I guarantee you that after 6

6 months those people were not getting 13 SEER without

7 that coating, and that's the purpose of that.

8 MR. CYMBALSKY: And I don't disagree. I

9 guess what we're saying is why wouldn't that

10 necessarily be a different basic model that should be

11 rated? You know, and this is why we're here having

12 this discussion. I mean --

13 MS. MEYERS: So, John, why do you look at

14 this different than high-efficiency filtration?

15 MR. CYMBALSKY: Because I actually -- yeah,

16 I mean, I personally think the way -- if you want an

17 exemption for the spray coils, hey, we can spray -- if

18 we're not sure, let's just spray them. If they test

19 it, it gets a credit or whatever. I mean, I'm not

20 saying you would do that, but I'm just -- I see that

21 differently than the filter thing. You're providing a

22 benefit and you're testing it in a way where, you
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1 know, it makes sense that we can see the airflow. But

2 the coil, you know you're going to do this, there's

3 some changes you can -- I think.

4 MS. MEYERS: It's a significant issue to

5 coat a coil in a manufacturing facility.

6 MR. DOPPEL: It's not spraying. It's

7 sending the coil out, in most cases having it dipped,

8 and then brought back as special.

9 MS. MEYERS: It is a significant deal.

10 MR. DOPPEL: And because, you know, if you

11 try to add more fin stock to create, you know, higher

12 efficiency, then you squeeze out -- I mean, you just

13 make it a worse situation because you decrease the

14 amount of space that air can flow through. So you

15 have to keep fin spacing the way it is.

16 MS. BARHYDT: But you're always talking

17 about the refrigeration system is the heart and it's

18 what you are rating and the coil is part of the

19 refrigeration system. So if you have changed your

20 refrigeration system why is that not a different base

21 model?

22 MS. MEYERS: We haven't changed the design
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1 of the refrigeration system.

2 MR. THARP: This is Rusty. I guess a

3 comment to John's comment is that I don't think we're

4 looking for an exception because it, in our view, is

5 that the base model without any of the bells and

6 whistles if what we're rating and that's what we're

7 claiming as the performance. So anything that's added

8 outside of that is not the basic model.

9 And to go to your question of why wouldn't

10 we consider that a different basic model, that goes

11 back to the fact that if we did that for everything,

12 then, you know, some companies would have tens of

13 thousands or hundreds of thousands or millions or

14 trillions of basic models, and that's a way excessive

15 burden if we took that position.

16 MR. CYMBALSKY: Right. We agree and that's

17 why we're here. So I guess we were trying to go

18 through that whole big list and what are the ones we

19 can live with, what are the ones maybe you can live

20 with, and take the list of 12 and maybe there's only

21 two that we need to come up with an opinion on.

22 MR. STARR: This is Louis Starr with NEEA.
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1 You know, one of the things I think the residential

2 may have been okay with the coating thing is they

3 don't sell into industrial markets that probably need

4 that coating on the evaporator coil, so that's why

5 they may not have cared about that.

6 I would be kind of concerned if this did

7 become -- if everybody just started coating their

8 coils you're going to have more, you're going to

9 actually use more energy or the other option is that

10 maybe some of the better manufacturers will continue

11 to coat their coils because they're concerned with

12 their warranty, but some of the people that are not so

13 much concerned, that maybe have worse equipment, will

14 not coat the coils and not care about the warranty,

15 and so you'd sort of be penalizing some of your better

16 market players. So that's kind of -- would also be a

17 concern in my mind.

18 MR. MYERS: This is Frank Myers. In keeping

19 with that, earlier there was a suggestion that perhaps

20 this could be linked to an option that says, "For

21 severe duty or corrosion resistance." And it really

22 sounds like that would be something, it we can do
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1 that, that would be a good way to characterize this.

2 Then if it's a standard, you have to test it. It's

3 part of your basic model. But if you offer this as an

4 option, where only those people that, hey, I need

5 corrosion protection, it's going to be self-regulating

6 because if they don't get that, they need that,

7 they're going to complain. So the black paint idea

8 wouldn't be -- it wouldn't work out in the

9 marketplace, so the marketplace would regulate that.

10 And then those people that do need this efficiency

11 saving over the long haul coating could get that

12 option. Is that not something that's workable for the

13 industry and for DOE? It sounds like a pretty

14 reasonable solution.

15 MS. JAKOBS: This is Diane Jakobs again. So

16 our options would be if we did a coated coil, it would

17 double our testing because you would have with the

18 coating and without the coating, so that would be

19 twice. Or the option would be that you would have to

20 take the rating with the coated coil, so it would be a

21 reduction in our efficiency that would only affect

22 single digit percentages of the market. So it would
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1 just be a reduction of our efficiency if we didn't

2 want to test with and without the coating, so that's

3 kind of the problem.

4 MS. HOOTMAN: This is Jill --

5 MR. BALLO: Go ahead.

6 MS. HOOTMAN: This is Jill from Trane. A

7 couple points back to, Laura, your question on -- it's

8 the same refrigeration system. It is the same exact

9 refrigeration system. That definition said the exact

10 same tubes, the exact same headers; the exact same fin

11 stock gets coated with a coating. So it is the same

12 refrigeration system. When you define a refrigeration

13 system it is the same one.

14 These come at a cost. We would not want to

15 put them in -- no one in their right mind would put

16 these in 100 percent of the time when they only needed

17 them 10. It comes at a cost. It has a lot of OSHA --

18 I mean, we don't like doing this. This is a -- these

19 chemicals have a problem in the plant. You've got to

20 deal with their off-gassing, et cetera. You don't

21 want to do this. We only do this because it is the

22 best thing for our customers that need it in their
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1 application. Otherwise, we will be forced to have

2 them do it in the field and they will cobble up

3 refrigeration systems that will be pitiful by doing

4 this in the field.

5 MR. BALLO: Tim Ballo with EarthJustice. I

6 have just a comment on the idea of using a marketing

7 standard for this and I think that in combination with

8 some sort of minimum performance requirement for any

9 coatings, whether it's the salt spray number that's

10 different for HVAC or CRE if we want to have this for

11 CRE, also, the two things in combination, I think,

12 would work pretty well.

13 MR. STEM: Mike Stem with Intertek. I just

14 want to touch on both points about the standard for

15 testing. We talked about the B117. It gives you

16 methodologies and conditions, but it doesn't

17 necessarily give you any kind of metrics of saying

18 it's to this level or not to this level. You have to

19 use other standards with that in conjunction.

20 And so, you know, I think basically what

21 you're saying, you're really close on the definition,

22 but I think what John's wanting is what's truly a
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1 coated coil and what's not. You know, how do you

2 exclude the people that are trying to skate the

3 system? And you kind of have to set some kind of level

4 and, right now, we don't have a definition of what

5 that level would be. So, I mean, you could look at

6 1654 or 3359 for the adhesion tape to see creeping or

7 other things, but somebody still has to set that level

8 and I think we're still pretty far from that, so.

9 MR. HON: This is Charlie Hon. I have a

10 couple of comments. Number one is that in our

11 industry a coated coil is not the same because the fin

12 spacing's different, things that inherently changes

13 the nature of the evaporate, so it inherently changes

14 the energy efficiency of the system, plus the coating

15 on there is another insulation layer. So we have to

16 redesign to put a different coil into the system.

17 They are not exactly the same. The copper may change

18 to steel, depends on how much corrosion resistance we

19 really want. It just doesn't -- our industry and

20 their industry don't agree on this at all.

21 MR. HURST: This is John Hurst with Lennox.

22 I think my earlier comments were misconstrued as
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1 commercial refrigeration. I think there is a big

2 difference and our company does both. We do

3 commercial refrigeration and commercial HVAC. Where

4 it's a standard, I don't even want to say option, but

5 where it's standard to the equipment, it should be the

6 base model.

7 When you talk about commercial equipment,

8 where it's such a small percentage, if you had to

9 redesign a product portfolio to a higher level to

10 accept a coated coil, which is a small percentage of

11 the sales in the marketplace, what I was saying is a

12 manufacturer of commercial equipment may choose not to

13 make that option and have it tested. It goes to

14 Jill's point that it'll be field-installed.

15 So where it's a large portion of the market

16 and customers, you know, need it, that's the base.

17 But in a situation where it could be 3 percent of the

18 market, manufacturers may choose not to offer that as

19 a factory-installed option. All I was saying is make

20 sure we understand the implications of that. So where

21 it fits, it fits, and where it doesn't, we ask that

22 you consider it.
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1 MR. STANONIK: Frank Stanonik with AHRI. I

2 just want to go back to this suggestion that you need

3 to quantify -- you have this test to determine that

4 it's a protective coating, the salt spray test or

5 whatever, but this suggestion you need to quantify it

6 I don't think really is necessary.

7 Keep in mind, I mean, okay, so if you run

8 some kind of test to determine that it does qualify as

9 an ASTM protective coating, that's all you really need

10 because, don't forget, it's the manufacturers'

11 products' reputation that's on the line here. They're

12 doing this because they know it goes into an

13 environment that if they don't provide a quality

14 coating their coils wear out very quickly, their

15 efficiency goes to hell in a hand basket, and their

16 customers will tell them that. And the fact that --

17 once you've determined, okay, it's a protective

18 coating as described by ASTM, that should be enough.

19 If it's a thin coating or whatever,

20 honestly, that's going to be the manufacturer's

21 problem. And, on top of that, that would

22 theoretically have the minimum effect on the heat
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1 transfer of the coil anyhow if it's the thinnest of

2 coatings. But the issue of is it a good enough

3 coating doesn't really apply here. I mean, once you

4 establish it's a protective coating for the purpose of

5 protecting against these harsh environments, that's

6 enough to say it's a coating that was there because

7 the manufacturer if he doesn't provide it and that

8 product gets installed in that environment you're not

9 going to have a very good operating product.

10 MR. AMRANE: Karim Amrane, if I may. I

11 mean, he was looking at the coated coil as being a

12 penalty on the efficiency, which is true. I mean,

13 when a unit it will be a penalty on the efficiency of

14 the unit. But if you look at the benefit of the

15 coated coil you will see that overall, maybe over a

16 few years, it will help energy efficiency because if

17 it's not coated, if it's in an environment with a lot

18 of corrosion, the coil will leak, the refrigerant will

19 leak, and the efficiency of the product will go down.

20 I mean, this is so overall, I mean, you

21 have to look at this as well as what is the impact of

22 a coated coil on the life of the equipment and whether
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1 overall, if you have it, you'll probably be better

2 off. So it's not just detrimental. Yes, if you do

3 want a brand-new unit, obviously you will probably

4 lose efficiency, but if you look over the lifetime of

5 the product, probably it's a benefit to the efficiency

6 of the product.

7 MR. EISNER: Wes, did you have a question or

8 a comment?

9 MR. WOSTAL: Yes, thank you. I just wanted

10 to point out there's been some discussion regarding a

11 metric to determine if it's -you know, what kind of

12 protection the coating gives, such as the salt spray

13 test B117. There are some coatings out there, such as

14 tin plating, that are coatings for coils. Now, that

15 would just be the tubes. It wouldn't cover the fin

16 stock as well, but they are protective coatings and

17 they probably would not fare very well in a B117 test.

18 So I just wanted to throw that out there and put that

19 out for everybody to think about, that passing a B117

20 isn't necessarily the threshold for everything. And

21 that's it.

22 MR. KLEISS: Jeff Kleiss, Lochinvar. I
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1 don't think that there's -- I think everybody at the

2 table understands that coatings are a good thing,

3 manufacturer-applied coatings are a good thing, a good

4 option as far as lifetime efficiency of the product.

5 I also don't think that there's anybody at the table

6 that doesn't understand that adding a coating to a

7 product is going to reduce its efficiency from a basic

8 product or an uncoated coil.

9 Do I understand correctly that DOE's concern

10 on this is that by adding a coating to a product that

11 it -- is the concern that it might be misrepresenting

12 the efficiency of the product or is it more that we

13 might be selling noncompliant product?

14 MS. BARHYDT: The latter.

15 MR. KLEISS: Okay, so if the major concern

16 of DOE is not selling a noncompliant product, then to

17 the manufacturers is the greater concern or is the

18 biggest concern the excess of test burden, of testing

19 with coating? Then could it be a reasonable

20 compromise to say that there'd be a generic penalty

21 applied for applying a coating that could be used to

22 qualify whether or not a product would be compliant?
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1 And it could still be an option of manufacturers to

2 actually test to get a less restrictive -- they could

3 have the option of either taking their basic number

4 and being hit with a certain penalty on efficiency for

5 coating or else they could actually choose to test if

6 they have an exceptionally good coating process.

7 Would that be a reasonable compromise that would cover

8 both parties?

9 MR. WHITWELL: Bob Whitwell from Carrier. I

10 think the other issue that the manufacturers have is

11 if all products have to meet the base efficiency level

12 with coated coils or would the impact -- assuming an

13 impact of coated coils is going to increase the cost

14 of all the products for a small percentage of market?

15 MR. HURST: If the entire portfolio --

16 MR. WHITWELL: So it's the tail wagging the

17 dog here is the concern I would have with that.

18 MR. THARP: And it also goes back to the

19 burden of the certification and documentation required

20 for all these additional base models.

21 MR. WHITWELL: Right.

22 MS. HOOTMAN: It goes back to --
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1 MR. EISNER: Use your microphone.

2 MS. MEYERS: So, Neil, I'm going to make a

3 recommendation to try and move this along. I'm going

4 to recommend that coated coils be treated like

5 economizers in ERVs, that they not be tested as long

6 as there is a model available without the coated

7 option. So, you know, if it is your complete

8 portfolio, then, of course, you know, it would be

9 pulled and subject to verification, but since this is

10 an option that it be treated like economizers, ERVs,

11 high-efficiency air filtration, et cetera, and that

12 the model that is subject to testing and verification

13 is without this option.

14 MR. EISNER: Your reactions?

15 MS. MEYERS: Or commercial HVAC.

16 MS. BARHYDT: And that was your starting

17 position.

18 MS. MEYERS: Neil, the way I understand this

19 works is, you know, it's a negotiation and we can take

20 a vote and see if this passes or not.

21 MR. EISNER: There seem to be so many

22 variables that it's hard to say you've got to test for
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1 each variable or a very, very small percentage to

2 begin with, but does the statute --

3 MS. BARHYDT: And we have given on virtually

4 every single one of them. There are a few of them

5 that we have concerns with.

6 MR. HON: Charlie Hon. Isn't this why we

7 have AEDM programs?

8 MS. BARHYDT: Yeah, the AEDM addresses the

9 testing burden.

10 MR. CYMBALSKY: I think here's the problem

11 as I see it, I think, from their point of view, is if

12 you're designing a unit just to meet the standard,

13 let's say it's 10, anything you do to that unit is

14 going to cause it to fail the standard. So if they

15 sprayed -- as soon as they spray the coil, it's a

16 failure. I think that's what the concern is. If

17 they're designing over the standard by 10 or 15

18 percent, I don't think this is --

19 MS. MEYERS: So, John, I'm going to disagree

20 with you on that because it may or may not fail. It

21 may fall within this five percent, I don't know. But

22 you are making an assumption that any unit that you
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1 test with a coated coil is not going to meet the

2 standard and I don't think --

3 MR. CYMBALSKY: No.

4 MS. MEYERS: -- that's an honest --

5 MR. CYMBALSKY: Not at all.

6 MS. MEYERS: That's just exactly what you

7 said.

8 MR. CYMBALSKY: No, I said if you design to

9 it, a residential unit to a 13 and you spray the coil,

10 the efficiency goes down. That's what I've been told

11 in the room, so that, I think, is what the problem is

12 here. If you design it to a 14 and spray it, it won't

13 fail, I don't think, but.

14 MR. AMRANE: Karim Amrane with AHRI. But,

15 again, we're changing the rule of the games, in a way,

16 because, as I said, any of the analysis DOE has done

17 on those products never counted for the coils. As a

18 matter of fact, it's a very common practice for DOE to

19 look at our directory and to say, yes, this is what

20 the market is, this is what industry. What we have

21 rated in our directory is not coated coils. So I

22 think if you want to change the game, that's fine. I
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1 mean, I'm not against changing the game. But then it

2 has to be done accordingly, I mean, not use the

3 current federal standard to say, well, you know, you

4 have to meet it with the coated coil where that was

5 not how those standards were established in the first

6 place.

7 MR. CYMBALSKY: Right. So I think we're not

8 saying like as of now if, you know, boom, you know,

9 we're not -- at least that not what I'm here to say.

10 MR. AMRANE: Okay. I thought that's --

11 MR. CYMBALSKY: You know, we're talking

12 about how to move this forward, not come tomorrow, you

13 know, if you have a coated coil, you know, I don't

14 think we're trying to say that at all. We're trying

15 to solve what we think is --

16 MR. DOPPEL: Paul Doppel with Mitsubishi. I

17 think one last time I'd like to make it sure that

18 everyone, that you guys understand that coating on the

19 coil extends the life and the efficiency of that

20 system wherever it's installed. And without that,

21 then the energy usage goes up significantly and the

22 cost to the consumer goes up significantly. This is
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1 something that is beneficial. There may be a trade2 off, but it provides, in the long run, it provides so

3 much more that I agree with what Karen said in that

4 this should be treated like an economizer.

5 MR. EISNER: Why don't we take a break for

6 10 minutes?

7 (Whereupon, a brief recess was taken.)

8 MR. EISNER: All right, we're ready to get

9 going again. And as usual, I believe Karim has a

10 proposal to put on the table to fix everything.

11 MR. AMRANE: Karim Amrane, AHRI. Just a

12 suggestion to move this issue forward. What we would

13 like to recommend is that DOE study the impact of

14 coated coil on efficiency. And maybe as part of the

15 rulemaking the DOE's currently doing on this type of

16 product, to establish maybe a new product class for

17 coated coil, if necessary.

18 Meanwhile, however, until that is done, you

19 should grant an exemption for product that are shipped

20 that way.

21 MS. BARHYDT: So by exemption you mean the

22 same sort of guidance that says that we will not test
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1 a product with a coated coil?

2 MR. AMRANE: That's correct, that you will

3 test an equivalent product without, yeah.

4 MS. BARHYDT: If one is available.

5 MR. AMRANE: Yes, of course. If it's to do

6 only what's --

7 MS. BARHYDT: If it's the --

8 MR. AMRANE: -- provided by the

9 manufacturer, that's fine, it has to be tested that

10 way. But if it's just an option, then you will test

11 the one without the coated coil.

12 MR. CYMBALSKY: Okay, I think I can live

13 with that, but I'm not sure we should apply it to

14 PTACs and other product classes other than what we've

15 been discussing because I think, like I said, for

16 residential and I think for PTACs, maybe SPVUs, is a

17 different issue altogether. But I would live with

18 your proposal for the product class we were just

19 talking about. Does that sound good?

20 MR. AMRANE: Well, again, I mean, I think

21 the same approach should be taken for the other

22 products, too. I mean, SPVUs are very much like the
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1 product we're talking about. I mean, they're used in

2 commercial applications the same way.

3 PTACs, I would say, you know, the same. I

4 mean, we need to study the impact and maybe there's no

5 need for a special product class or maybe there will

6 be a need for it, I don't know. But I think if we

7 apply these requirements today, we're changing the

8 rule of the games. I don't think that's how

9 manufacturers have been, I guess, interpreting the

10 regs or testing that way.

11 So I think it's fair that we are willing to

12 consider this in future rulemakings and you'll be

13 doing one and we are doing one on (inaudible)

14 products. You'll be doing one on PTACs, too, I

15 believe; SPVU as well. So it can be looked at as part

16 of the rulemaking process. We're not talking about 10

17 years here. We're talking about something that you

18 are currently doing or will be doing shortly.

19 MR. MYERS: This is Frank Myers with PVI. I

20 was asking during the break around the room a number

21 of manufacturers, I didn't get to everybody, but the

22 general sense that I got for coatings as an option in
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1 the commercial industry is less than 1 percent of the

2 total units sold have this option, so it's a really

3 small slice. If there are those around the room that

4 disagree with that number that I didn't talk with,

5 again, I'm not talking about those that are standards.

6 It might be a little bit higher for those that are

7 standard, but those would be tested. It's when it's

8 an option; the number for the industry of the percent

9 sold of total is less than one percent.

10 MR. SACHS: This is Harvey Sachs. And I

11 certainly think we need to find something workable in

12 the short run and sustainable in the long run. There

13 are several pieces of information I would like to see

14 that require some actual measurements in some cases.

15 One is what Frank was talking about. Across

16 this 340/360 ranges, as well as for other products,

17 what is the fraction shipped or should be shipped with

18 these anti-corrosion coatings? What's a good test for

19 this being a good coating or an adequate coating so we

20 don't get loopholing? What's the impact on pressure

21 drop and energy on the fan side from using these

22 coatings range? Is it de minimis or this a fair
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1 amount of fan energy? And what's the change in heat

2 transfer across these things?

3 I think if these numbers all point to a de

4 minimis, it's going to be a whole lot easier for

5 everybody. But whether or not it's de minimis, I

6 think it's going to guide us in figuring out what the

7 right path is.

8 MR. CYMBALSKY: So are you okay with us

9 dealing with it in the current rulemaking, as Karim

10 suggested, or do you need this information before you

11 would vote on this proposal?

12 MR. SACHS: Well, I think there's -- this is

13 Harvey again. There's some information which we can

14 get in two weeks. Is this stuff one percent, five

15 percent, or 10 percent of the various product classes?

16 My sense is that that's information that's at-hand

17 from the manufacturers. And for the rest of it,

18 nobody in this room's in the position to do that

19 testing in time constraints of this process, so the

20 rulemaking is the least bad way to proceed that I can

21 think of.

22 MR. EISNER: Do we know of any tests that
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1 have been done, that could be obtained from reliable

2 sources?

3 MR. SACHS: That was our facilitator asking.

4 MR. CYMBALSKY: Has AHRI tested any? Do you

5 have any test results coated, uncoated?

6 MR. AMRANE: This is Karim again. I don't

7 believe that we do, but many manufacturers do, I don't

8 know. I mean, that's --

9 MR. THARP: This is Rusty with Goodman. I

10 guess my comment would be that if you install the

11 system with an uncoated coil, take that coil out, get

12 it coated, put it back together, you've now adjusted

13 the charge in the system and other factors in the test

14 setup, and I would say that you have just as much --

15 anything difference would be noise in the testing

16 because, you know, you've changed the way the unit's,

17 you know, put in. Because obviously in testing you're

18 going to pull that unit out and take the coil out and

19 wait for it to go get coated, et cetera. And we don't

20 have any significant amount of data that would -- like

21 where you test the coils to I think it's AHRI 420 or

22 410 for coil-only where we have, you know, X-number of
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1 samples uncoated and X-number of samples that are

2 coated and a good comparison between those.

3 So I don't think -- the bottom line is I

4 don't think we really have any good data that says

5 here's a substantial difference. I would say, from my

6 engineering background, that for what we do there's

7 probably less than 1 percent difference.

8 MR. WHITWELL: In performance?

9 MR. THARP: Yes, in system performance.

10 MR. WHITWELL: Yeah, we have some data that

11 suggests if it's just the outdoor coil that's coated,

12 it's in the 1 percent range. If it's the indoor coil

13 as well that's coated, which sometimes it can be

14 because of corrosive products in the air entering the

15 indoor side, it can be higher on the evaporator side,

16 so up to a combined four percent if both coils are

17 coated. Rough data.

18 MR. THARP: And then, again, one of our

19 concerns is if those are -- you know, because it is

20 such a small portion of the market -- and I commented

21 to you offhand I don't think we offer it, but we do

22 offer it, an ultra-gold coating. Our coating is a we
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1 get a thin stock that's pre-coated with a corrosion

2 inhibitor and then we stamp out the fins and that's

3 what we provide our customers if they ask for it. And

4 they just -- there's not enough volume to make a

5 different basic model for us, but yet if we include

6 that to be tested, that just -- since we're only

7 allowed five percent across the board and, you know,

8 we feel that there's eight percent plus variance just

9 in the test procedure. So if you take the same unit

10 and test it different places, you're going to get a

11 significant difference in the results. We just don't

12 want a penalty to be applied because of the variance

13 that's there in the test procedure necessarily,

14 throwing on top of that the unit performance

15 differences.

16 MR. EISNER: Are we talking about the

17 possibility, when we talk about guidance, adding

18 something to the preamble that perhaps everybody could

19 agree to adhere? Because I hear a lot of agreement.

20 It will improve efficiency over the life of the

21 system. It will cause a decrease in efficiency at the

22 test. There's so much room for a variance within the
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1 testing itself that that's going to affect doing one

2 or two tests, what results you're going to get. You

3 put all that information in a preamble and you say, as

4 a result we have decided -- we, the agency, have

5 decided -- that we're going to address this through a

6 separate rulemaking in the future because it is such a

7 small percentage of the sales. We believe that for

8 the near future we will test without the corrosion in

9 there and not require that it be added in, but we

10 want, you could even say we will put a footnote and

11 number saying if you add corrosion control it will

12 have an effect, something like that. Or you could

13 just explain it in the preamble and make that

14 available on a website. Are we going in the right

15 direction?

16 MS. BARHYDT: Yeah, I think we can agree to

17 that framework where in the short run we won't be

18 testing anything with a coated coil and that long-term

19 we'll deal with it through the rulemaking process.

20 MR. EISNER: And you could use some of the

21 data that some of the members can give you to show it

22 may even be a very, very small problem.
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1 MS. BARHYDT: Yeah.

2 MR. EISNER: Is that a satisfactory

3 solution, everybody?

4 MR. THARP: John, you had commented that we

5 had a proposal. Is that along the same lines or is it

6 different?

7 MR. CYMBALSKY: We're willing to live with

8 that one. Mine was much better, but.

9 But I'm saving by aces for the next topic.

10 Yeah, so for the PTAC, I think. I don't know if I

11 want to buy-off on the PTACs yet. Yet. Can we table

12 the other two products and just focus on what we've

13 been discussing? I really need to think more about --

14 MR. THARP: I guess -- this is Rusty, I

15 would suggest that we all, I think we have a general

16 consensus, but I would suggest that we wait to do any

17 official voting until next time because I'll have time

18 to think on all the options would be my suggestion.

19 MR. CYMBALSKY: Okay, I think that's fair.

20 MR. EISNER: Should we try to have preamble

21 language to talk about for the next meeting or at

22 least an outline?
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1 MS. BARHYDT: I will commit to do my best to

2 get stuff written up, but we've actually gone through

3 a lot of material so far. And so we'll try and put

4 some pen to paper and get something out to everyone to

5 read. It may not be final draft, but we'll get

6 something down.

7 MR. CYMBALSKY: I think we agree in

8 principle I think is the best way to say this. And so

9 I think we'll dot the I's.

10 MR. BALLO: Just one addendum to that. I do

11 not have a problem with not testing coated coils while

12 we wait for the rulemaking to work that out. I do

13 think, though, that it sounds like we're not too far

14 from getting some sort of maybe just a temporary

15 definition for some sort of standard that a coil would

16 have to meet to be considered coated, whether that's

17 500 hours on a salt spray test or whatever. But I

18 think that would be really helpful to prevent

19 loopholes in the interim until we do get to a

20 rulemaking.

21 MS. BARHYDT: I agree. My only concern is

22 the gentleman who was on the phone was talking about a
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1 different type of corrosion, a way of addressing

2 corrosion that he said that that test method wouldn't

3 work on. So I just want to make sure that we don't

4 inadvertently limit it to a certain type of

5 technology.

6 MR. BALLO: That one sounded like maybe a

7 case for a test procedure waiver if that one's really

8 --

9 MR. EISNER: I mean, are we talking -- we

10 had been talking during -- I was talking during the

11 break -

12 -

13 MS. HOOTMAN: When I --

14 MR. EISNER: -- about ASTM standard. Is

15 that the one that would be acceptable to DOE?

16 MR. CYMBALSKY: I think Jill had a good

17 definition.

18 MS. HOOTMAN: Yeah, and I admit I did

19 everybody's equipment that's in the room and Wes is a

20 water source heat pump manufacturer. I am also, so I

21 only did look at my water source heat pumps, but when

22 I looked at commercial HVAC, all of us had an ASTM
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1 test. And those words or those kinds of coatings were

2 what we are using. So what he suggested is a kind of

3 coating that is only to the tubes and not to the fin

4 stock. It would not be truly a corrosive and would

5 not likely work under alkalis, acids, salt spray, et

6 cetera. It would not be in.

7 MR. WHITWELL: Yeah, it could help to

8 prevent leaks, but is not going to prevent having the

9 fin corrode away.

10 MS. BARHYDT: Okay. So it sounds like, and

11 keeping in mind that you are representing the whole

12 industry, not just your companies, it sounds like this

13 is a good description of what a corrosion-protected

14 coil would be.

15 MR. FLY: This is Mark Fly with AAON. The

16 B117 salt spray test is a good test for acidic and

17 salt, chlorine-based environments. There may be other

18 chemicals that need a different kind of test, but the

19 vast majority of the units sold, even though we're

20 talking about this less than, you know, small single

21 digits, are really for sea coast application for most

22 of our products, for this product class. And that's
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1 usually saltwater environment and so a salt spray test

2 is an appropriate kind of test for that. It's an

3 accelerated life test.

4 So, you know, I think that this is the

5 appropriate test for the vast majority of what it is.

6 And if you had a special requirement for a special

7 chemistry, then I think a test waiver would be the

8 appropriate way to go about getting around that.

9 MR. THARP: This is Rusty with Goodman. On

10 that definition, it only discusses processes that are

11 after the coil is completely assembled and, as I

12 mentioned, what our company provides is a coated coil

13 where the coating is applied to the fin stock prior to

14 stamping of the fins, as Jill had mentioned, also,

15 previously.

16 MS. HOOTMAN: So look at the sentence near

17 the end, "For mildly corrosive environments coils can

18 be assembled from aluminum fin stock -- "

19 MR. THARP: Thank you,

20 MS. HOOTMAN: " -- that has been coated

21 prior to fin stamping."

22 MR. THARP: You mean you've got to read all
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1 of it?

2 MS. HOOTMAN: Yeah.

3 MR. EISNER: Wes, you wanted to add

4 something?

5 MR. WOSTAL: Yes, Wes Wostal, ClimateMaster.

6 Just to add a little bit to what was being discussed

7 earlier, we do also offer an E-coating which, I agree

8 100 percent, applies to the B117 salt spray test. And

9 the tin plating that I brought up is a very, very,

10 very -- I would say probably less than one percent,

11 which I think you were talking about, going around the

12 room there, that most companies are less than one

13 percent. You know, it is -- for commercial

14 applications it is very, very seldom that we do that.

15 So I just wanted to bring it up so that in

16 the future, if it did come up, it was something that

17 everybody -- that had been discussed here. And I

18 think a waiver would probably be a perfect solution.

19 Thank you.

20 MS. BARHYDT: Thank you.

21 MR. MYERS: This is Frank Myers. Could that

22 all be condensed down to corrosion-protected condenser
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1 coils, "Corrosion durability shall be confirmed

2 through testing per ASTM B117 salt spray test," and

3 leave the rest of that out? That's really the

4 operative term. The rest of it is marketing-speak.

5 MR. CYMBALSKY: Do they market with those

6 words in it? Wow. Really?

7 MR. MYERS: Yeah, that appears to be a

8 marketing specification as opposed to --

9 MS. HOOTMAN: It's truly out of our guide

10 spec, yes.

11 MR. MYERS: And the operative element in

12 that entire diatribe is the last sentence. So it

13 looks like for us going with the definition is having

14 that last sentence.

15 MR. CYMBALSKY: If I ever "baked phenolic"

16 on a menu anywhere, I'm going to run.

17 Whatever that is.

18 MR. HON: This is Charlie Hon. I'd also

19 like to take the part of the last sentence where it

20 says, "aluminum fin stock." Just take the word

21 "aluminum" out of that because there are other

22 possible fin stocks. The second to the last sentence
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1 says, "aluminum fin stock."

2 MR. THARP: I got it, but if we're going to

3 get rid of the whole thing --

4 MR. CYMBALSKY: Yeah, we might get rid of

5 the whole -- I mean, it's open for discussion how much

6 we need in here.

7 MR. EISNER: I mean, does anybody disagree

8 with the suggestion?

9 MS. MEYERS: Just one little suggestion.

10 The third word, we should put "evaporator/condenser

11 coils."

12 UNIDENTIFIED SPEAKER: Yes, right. Good

13 catch.

14 MR. MYERS: Yeah, in terms of being

15 universal it would seem just taking that last sentence

16 with the change that was just added in and leaving the

17 rest of that out, everything else appears to be

18 restrictive. If we go with that last sentence, then it

19 will cover everything no matter how you produce it.

20 Whatever is coated has to comply with the B117.

21 MR. CYMBALSKY: So, Frank, you're suggesting

22 starting with "typical," cross out "typical" all the
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1 way down to "process."

2 MR. THARP: This is Rusty. Before we do

3 that, just to the point that Mike Stem made earlier,

4 ASTM B117 is a test procedure. It doesn't provide

5 pass/fall criteria. It doesn't provide duration. So

6 you'd have to say -- we'd have to add in something

7 that says what the pass/fail criteria is. Is it just

8 withholding pressure? Is it, you know, performance

9 before and after? There's other factors there.

10 So I personally think that the information

11 in between is salient to the description of what a

12 coated corrosion protection coil is. Maybe you want

13 to put it after. You know, put the last sentence

14 first, but the rest of the information is salient to

15 the discussion at hand, especially without a pass/fail

16 criteria on the test procedure.

17 MR. MYERS: This is Frank Myers, PVI, again.

18 I understand what you're saying. If one goes through

19 the trouble of actually conducting that test, they

20 have differentiated themselves between those that

21 don't conduct that test. If there was a need, again,

22 rather than include all that intervening information,
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1 then the lowest number that I've heard that a

2 manufacturer use I believe was 192 hours.

3 MS. BARHYDT: But that -- I believe 500 was

4 the lowest number we heard for HVAC.

5 MR. MYERS: No. Yes, but to cover

6 everything and to get over the hump of you have to

7 test to some hours --

8 MS. BARHYDT: I think we would prefer to

9 have this specific to products, not just a generic

10 statement.

11 MR. MYERS: Maybe I don't understand what

12 the effort is here. I thought we were trying to make

13 sure that this was not a coat of black paint. And

14 you're going to have significant compliance at 192.

15 I'm not sure that those pre-coated pieces will comply

16 even with 192. It's all a matter of the level of

17 corrosion protection you're offering. And if we have

18 a low number or no number, we'll be able to cover

19 every variation of this so that somebody doesn't,

20 well, I have a protective coating that's an option.

21 And if they do, they have to have done this. They

22 can't just say it and throw something on. They will
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1 have had to have run the B117 salt spray test.

2 MS. BARHYDT: Rusty, you mentioned the pre3 treated before stamping. How many hours?

4 MR. THARP: My guess is the fins would last

5 500 hours. The performance before and after, I don't

6 know what the degradation is.

7 MS. BARHYDT: Right.

8 MR. THARP: But I know that the fins with

9 the coating last better than the ones without.

10 MS. HOOTMAN: Yes, I would agree, fin stock

11 still at that point would be a 500-hour test on

12 commercial HVAC. And I understand what you're saying,

13 you want to now make this commercial HVAC different

14 from -- right.

15 I'm sorry, this is Jill from Trane. I agree

16 with Rusty. I think that the other words need to be

17 in there. They are describing a specific thing.

18 You're trying to get away from just the "I'm just

19 going to paint a coil." It has a specific purpose.

20 MR. THARP: Just tacking onto that. A

21 standard coil, copper tube, aluminum plate fin, would

22 probably endure 500 hours of an ASTM B117 without
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1 leaking. The performance would probably stink pretty

2 bad, but it would still be, you know, able to

3 pressurized in all likelihood after 500 hours. So

4 it's a matter of the heat transfer, which is why we're

5 putting the coating on to begin with.

6 MR. FLY: Rusty, I'm not sure you'd have any

7 fins left.

8 MR. THARP: (Off microphone.)

9 MR. FLY: Right.

10 MR. CYMBALSKY: Okay, I'm going to propose

11 we just leave it as is unless somebody really, really

12 has a problem with it. I mean, at this point, I think

13 we're getting -- turning the screw and stripping the -

14 -

15 MR. SACHS: Harvey Sachs. I'm not real

16 excited about that mildly corrosive environments

17 language for coated fin stock. Among other things it

18 sounds to me like something that has all sorts of

19 opportunities for galvanic and it just doesn't seem to

20 fit the category we're talking about of seaside

21 environments and equivalent. I don't have a dog in

22 this fight, but I'm a little uncomfortable with that
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1 approach and nobody's telling me that it's pervasive,

2 common, or --

3 MR. THARP: No, I'm just removing the phrase

4 for mildly corrosive environments.

5 MR. STANONIK: Yeah, Frank Stanonik, AHRI.

6 That's high-risk concern, so where it says "typical

7 processes" at the very end, simply add "fin stock that

8 is coated prior to the stamping process," or something

9 like "the use of fin stock that is coated prior." I

10 mean, this goes to the end of the list. A typical

11 process includes baked phenolic, blah, blah, blah.

12 MR. THARP: Just like that.

13 MR. STANONIK: And then just make it one

14 more of the possibilities.

15 MR. EISNER: Does this work for everybody

16 now?

17 MR. BALLO: I still have a concern that we

18 haven't specified any level of performance. All we've

19 said is corrosion durability shall be confirmed, but

20 all we've said is we're going to run the test, not

21 what the outcome would be.

22 MS. HOOTMAN: This is Jill from Trane.
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1 "Shall be confirmed to a minimum of 500 hours," or put

2 "500 hours after ASTM B117 salt spray test."

3 MR. EISNER: Is that number acceptable to

4 everybody?

5 MR. THARP: For commercial HVAC.

6 MR. CYMBALSKY: This is only applying to the

7 commercial HVAC at this point.

8 MS. TUCKER: We'll put it here just so we

9 know.

10 MR. EISNER: Okay, everybody agree? Okay,

11 no objections are heard.

12 MR. CYMBALSKY: Tim, this is okay? This is

13 --

14 MR. BALLO: (Nods.)

15 MR. CYMBALSKY: Okay, good.

16 MR. AMRANE: Karim Amrane with AHRI. I hope

17 we're not forgetting about the other product because I

18 think maybe a similar definition would --

19 MR. CYMBALSKY: No, we're going to come back

20 to it.

21 MR. AMRANE: Exactly, eventually we should

22 come back to that. Yeah, not now.
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1 MR. CYMBALSKY: Okay. No more coated coils.

2 You want to talk about motors now?

3 UNIDENTIFIED SPEAKER: Yes.

4 MR. CYMBALSKY: All right. What do you got,

5 Karim? What do you got for motors?

6 MR. AMRANE: Nothing.

7 (Laughter.)

8 UNIDENTIFIED SPEAKER: We're coating them.

9 MR. CYMBALSKY: No, I think they're called

10 encased; right? You encase them.

11 Okay. So we thought about the motor issue a

12 little bit. I think we have a proposal that's similar

13 in feature to what we just discussed with the coated

14 coil, so.

15 So if you're going to use -- I'm going to

16 talk in terms that I can understand, which may not be

17 engineering specifically correct. So if you use a 2

18 horsepower motor, let's say, I'm making up numbers, in

19 your base model, the NEMA chart will have the

20 efficiency of what it is and all that. If you go up

21 to a five horsepower motor, what we're proposing is

22 that you map to the NEMA chart with that motor. And
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1 then everything else, we won't test the five horse, et

2 cetera, et cetera.

3 So what we're trying to do here is guarantee

4 that if you're swapping out motors, the efficiency

5 band is the same. It's just scaled higher. Does that

6 make sense?

7 I'm sorry?

8 (Off microphone discussion.)

9 MR. CYMBALSKY: We've done several

10 rulemakings here, so I think we have tables that can

11 help out. But the rest would go -- we wouldn't test

12 the bigger motor as their basic model, so the rest

13 would fall in line with what we just talked about with

14 the coils.

15 MS. HOOTMAN: This is Jill from Trane.

16 You're falling back to the tables that you have for

17 just the motors only, when you have the motor-only

18 rulings? Is that what you're saying, those tables?

19 Like 2 percent -- you know, 97 percent or 98?

20 Okay, I understand what you're getting at.

21 MR. THARP: So if you have a --

22 MS. HOOTMAN: I understand what you're
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1 getting at. I'm not sure what that means to our

2 units.

3 MR. THARP: So if you have a two horsepower

4 that's 95 percent efficient and we offer two through

5 20 horsepower range, you'll test the two horsepower as

6 long as all motors we provide are at the 95 percent

7 efficiency level, so that's the same --

8 MR. RIVEST: This is Mike Rivest. So

9 actually, not quite. So NEMA has several grades of

10 motors, the minimum being the minimum standard. I

11 think it's probably backed right now. We're in the

12 process of looking at higher standards.

13 Conceptually, what we're trying to make sure

14 is that the motor you supply for your compliance

15 testing is not of a higher grade than the ones you use

16 in your actual products that you sell. So in theory,

17 just purely in theory, you could come in with an ECM

18 motor as your test unit and you could have maybe even

19 a blower section that's been specially tuned or just

20 an efficient blower design and that would help meet

21 the minimum standard. And that would be fine so long

22 as you continued using an ECM motor for every product
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1 that you were capturing with that test. Same with the

2 blower.

3 So the NEMA charts simply refer to an

4 efficiency scale. So efficiency on motors, it gets

5 better as the motors get bigger. So it's not just a

6 matter of establishing 95 and then everything else has

7 to be 95. If it's 95 and it scales and the NEMA

8 premium motor would be a band above, so we want to

9 make sure that you're switching out motors to motors

10 of equivalent performance level, not equivalent

11 efficiency.

12 And that would apply, also, to other

13 components in the system that are key. So we talked

14 earlier yesterday about having different blower

15 designs. Now, some may just be different for reasons

16 such as static or things like that, but there may be

17 designs that are inherently more expensive and

18 efficient. So we wouldn't want, you know, a specially

19 designed test unit to throw technologies -- have

20 technologies thrown at it that wouldn't be

21 incorporated in the other products. So I don't know

22 how we put that in words, in writing, but that's the
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1 concept.

2 MR. MYERS: This is Frank Myers, PVI. I'm

3 not an expert in all motor types, but I would question

4 whether all motor types, this mapping you're talking

5 about is available in every size and configuration and

6 type of motor. And we certainly wouldn't want to

7 lower the base model's motor efficiency so that you

8 could use a higher efficiency of that same class. So

9 you might want to consider putting in something like

10 it maps over or the highest class available for that

11 specialty motor, the highest class that's available so

12 that you're not having to lower the efficient of the

13 base model down to be able to use it.

14 MR. CYMBALSKY: So if you lowered the

15 efficiency of the base model, you'd have to recertify

16 with that less-efficient motor, I would assume.

17 MR. MYERS: Or that might keep you from

18 putting a higher efficiency motor in the base model if

19 you wanted to improve the efficiency of the base model

20 because that might lock you out of some of these

21 after- the-fact -- or you let somebody in the field do

22 it. And one way around that would be just to say it
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1 either maps or the highest available for that category

2 of motor.

3 MR. RIVEST: I mean, it's feasible that, you

4 know, the most efficient motor's available at 5

5 horsepower, but not at 20. That's possible.

6 MR. MYERS: That's the thought.

7 MR. RIVEST: So you're just trying to make

8 sure that there's a motor available.

9 MR. MYERS: If you can't do the direct map,

10 you have to go to the highest in that category class -

11 -

12 MR. RIVEST: That's available.

13 MR. MYERS: -- whatever the description

14 would be.

15 (Off microphone discussion.)

16 MR. CYMBALSKY: So I think you get the

17 flavor of what we're trying to do here. I'm not

18 asking for a decision on the spot, you know. And

19 again, so current practice today would go along with

20 what we did with the coil, so.

21 MR. WHITWELL: Bob Whitwell, Carrier. Can

22 we get something drafted up there on the screen so
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1 that we can take it home with us and have it to look

2 at over the next few days?

3 MR. CYMBALSKY: We'll draft something to

4 send around before the week's up. How about that?

5 MR. WHITWELL: Before the end of this week?

6 MR. CYMBALSKY: Yes.

7 MR. WHITWELL: Okay.

8 MS. BARHYDT: We'll find the band so that we

9 can point you at that as well.

10 MR. WHITWELL: Okay.

11 MS. HOOTMAN: Yeah. So this is Jill from

12 Trane. Carrier, ah.

13 I didn't do that. Nope, I never. Not yet

14 anyway.

15 MS. MEYERS: What's your name?

16 MS. HOOTMAN: Yeah, Jill. I got that.

17 Mike, I kind of -- I mean, I understand what you're

18 getting at and I would agree that as you go up in

19 motor size, you're going to higher. The only thing

20 that I'm kind of worried about -- and maybe those

21 tables, I'm visualizing them -- is the fractional

22 horsepowers. And, of course, in our three through 510
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1 products we've got the fractional horses that we're

2 dealing with.

3 MR. RIVEST: It's always true. I believe

4 it's always true that bigger is always more efficient.

5 MR. THARP: But when you get to the smaller

6 sizes, five ton and less, those aren't always not

7 very often are belt drive, are they? Most are direct

8 drive with multispeed.

9 MS. HOOTMAN: They're direct drive.

10 MR. DOPPEL: We have both.

11 MS. HOOTMAN: Yeah, you got both belt drive

12 and direct drive smatterings through those product

13 lines.

14 MR. FLY: Mark Fly with AAON. So I'm just

15 going to clarify a few things and nod if you agree.

16 But what you're talking about is we should be rating

17 with the least efficient that we offer within that

18 line and that that will be available in commerce for

19 you to pull in test, the least efficient in that line.

20 That doesn't prevent me from putting an ECM motor as

21 an option in there. But if I want to rate it as an

22 ECM motor and have a higher rating, then I need to go
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1 in and create another model group.

2 So, you know, that's -- so if you pull an

3 ECM motor and I've rated it something better, then I'm

4 going to perform better. If you pull the lowest

5 common denominator, this Plain Jane unit that's got

6 the cheapest motor in there, then you should be able

7 to get the -- and then the other is a paperwork

8 exercise. If you look at one that's got a five

9 horsepower motor, you look at the efficiency, you

10 compare it back to the efficiency of the tested rated

11 motor and see if it follows the curve. Is that

12 correct? Okay. I'm fine with that. It seems like a

13 reasonable compromise.

14 MR. CYMBALSKY: So my going in position was

15 nothing, just to let you know.

16 I'm a reasonable person.

17 MR. EISNER: Any other concerns?

18 Everybody's okay with this approach?

19 MR. CYMBALSKY: And then in the long run,

20 the test procedure issue, I think, is still a long-run

21 debate here about what we should do about the static

22 and all that.
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1 MR. SACHS: And that leads me to my concern,

2 which is that motor wouldn't be there if it wasn't

3 hooked to a blower. And I'm really worried about the

4 watts per CFM at external static much more than what

5 the rating is on the motor. There is no motor that I

6 can't defeat with a bad fan to say nothing of the bad

7 ductwork downstream. But the manufacturer's

8 responsible in my mind for the air movement efficiency

9 and the motor is just a poor means of trying to

10 reflect that.

11 MR. MYERS: Harvey, this is Frank Myers,

12 PVI. Harvey, I would remind you of the example that

13 was given a number of meetings ago of the gentleman

14 who had been requested to put one of his air15 conditioning units for a docked submarine where its

16 standard horsepower was quite low, but they had to put

17 in, and I forget the number, but let's say 100

18 horsepower motor to be driving that against the

19 pressure that was contained within the submarine in

20 order to air-condition it.

21 I don't disagree that the best would be to

22 be able to get the -- come up with the watts for the
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1 amount of air that is moved, in this case I think what

2 DOE has done is said, well, that's perhaps not

3 practical, not reasonable, but here's something that

4 is reasonable. They're offering out something that's

5 not the best, but it captures at least that element of

6 it. So I think it's a reasonable compromise.

7 MR. SACHS: This is Harvey. And, Frank, I

8 think we're in violent agreement. My concern is that

9 that was a 30 inch of static application and my

10 concern is how many building are approaching that.

11 And I doubt there are very many at 30, but we're

12 certainly seeing a lot which are designed to several

13 inches of external static and that's where the fan and

14 motor together -- well, across the board that's where

15 they matter.

16 MR. RIVEST: This is Mike Rivest. Now, I

17 know we're going through a blower rulemaking at this

18 point, but are all your motor-blower combinations

19 available with ratings of watts per CFM?

20 MS. HOOTMAN: No.

21 MR. RIVEST: Okay, because if they were that

22 would be nice.
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1 MR. SACHS: But, Mike, the context is that -

2 -

3 MS. HOOTMAN: Read the comments. They were

4 bad.

5 MR. RIVEST: I read a lot of comments.

6 MR. SACHS: The context is that this is

7 going to be linked one way or another to what's

8 happening in 90.1 in looking at system efficiencies.

9 The information is going to have to be generated in a

10 useful way from the manufacturer for the designer. So

11 it may not be married up, but it's certainly linked.

12 MR. FLY: This is Mark Fly with AAON. Mike,

13 I'd caution you a little bit about looking at fan

14 efficiency grades inside packaged equipment because I

15 can apply a much lower FEG fan in application blowing

16 through, say, a gas heater and I could apply a much

17 higher fan and end up using more horsepower than the

18 fan that has a much lower FEG because of the system

19 effects. A lot of the really high FEG fans are going

20 to have very high discharge velocities, which is not

21 compatible with filters and coils and things like that

22 nor is it compatible with a bullhead tee that's 3 feet
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1 down below the end of the discharge of the ductwork.

2 It causes terrible system effects.

3 So here, again, we're kind of in one of

4 these situations where the test -- the ideal test

5 setup may not fit reality very well. So I understand

6 the concern and I don't have a solution, but I don't

7 think we should be -- we need to be real careful about

8 over- constraining components within packaged

9 equipment where we're giving it a package rating.

10 MR. MYERS: This is Frank Myers, PVI. That

11 was a bit of what I was attempting to get at by saying

12 the highest available for what you need to meet those

13 needs. So if you need a motor that can do those

14 things that you're talking about, then it needs to be

15 equal to the efficiency of your base or the highest

16 efficiency available in a motor that does those

17 things. So it wasn't just in general, it was when you

18 specify what that motor needs, what the blower needs

19 to do, then the highest efficiency for the motor that

20 will achieve that that's available.

21 MS. BARHYDT: So we'll get some information

22 out about the bands, and it sounds like otherwise
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1 we're generally -- we have a way forward on the motors

2 issue.

3 Let's see, I believe some people were going

4 to go look at dehumidification.

5 MS. TUCKER: Do you want me to go back to

6 that?

7 MR. AMRANE: Thank you.

8 MS. TUCKER: Yeah, no problem. I'm sure

9 that's not going to be the final language.

10 MS. BARHYDT: We had a question about

11 dehumidification. How is the unit with

12 dehumidification components differentiated from a unit

13 that doesn't have them? Did anyone have a chance to

14 look at this issue?

15 There was a request that we not test units

16 that had dehumidification. And we're asking how would

17 we know. Is it --

18 MS. HOOTMAN: (Inaudible.)

19 MS. BARHYDT: -- clear that this is an

20 option?

21 MR. DOPPEL: Somebody brought up advanced

22 technology.
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1 MR. SACHS: This is Harvey. I brought up

2 advanced technologies and the issue there is what you

3 would do to test something like the proverbial Cromer

4 cycle, which is a novel application of a desiccant

5 wheel that is built into the end of the packaged unit.

6 I'm able to raise the issue. I don't know how to test

7 these. And my concern is that we not get in a

8 position which we're inadvertently discouraging or

9 penalizing innovation, whether it's that or

10 direct/indirect evaporative cooling or whatever it is.

11 MS. BARHYDT: And we're okay with saying we

12 won't test units that have dehumidification

13 components. Our question was just how do we know which

14 models do and don't have that because we don't want to

15 be in a situation where we get something and we test

16 it and someone says, oh, well, that has this

17 dehumidification aspect to it.

18 MR. AMRANE: Karim Amrane. I think if you

19 get the unit you will see right away if it has the

20 component or not. I think it can be obvious. Now,

21 whether it can be distinguished with the model number,

22 I don't know. Maybe that's something that you have to
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1 ask the manufacturers.

2 MR. FLY: This is Mark Fly with AAON. As

3 far as I know, that's always an optional feature.

4 It's really a specialty feature. It's only going to

5 happen in a few of the units, mostly high-end units.

6 It kind of figures in to dedicated outdoor air

7 systems. You see them more often in those kind of

8 systems than not. But in my view, what we intended

9 when we wrote this section was to have a heat wheel, a

10 plate, a desiccant spray section. It is an additional

11 component besides the evaporator coil. Not just an

12 evaporator coil could be called a dehumidifier even

13 though it does dehumidify.

14 MS. BARHYDT: Okay.

15 MR. FLY: An additional component --

16 MS. BARHYDT: That's our concern.

17 MR. FLY: In addition to the evaporator

18 coil. And then we address reheat coils further down

19 and we've already talked about those. And that's

20 another way of doing dehumidification is you cool it

21 down and reheat it up through the evaporator coil.

22 And we've already addressed that, also. So between
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1 the reheat coils and this dehumidification additional

2 component that would be a feature, an optional

3 feature, that would cover, I think, for everyone in

4 the HVAC world what we intended by this item.

5 MS. HOOTMAN: And they're all options --

6 MR. FLY: But it would not just be an

7 evaporator coil or some magic evaporator coil that

8 just dehumidifies better than everybody else's.

9 MR. KOJAK: I would think that would be a

10 concern of the contractor that's contracted to obtain

11 the test unit, that you just make sure to let them

12 know to get a unit that doesn't have that equipment on

13 it. Because every manufacturer's going to designate it

14 differently within their model numbers, so they would

15 have to have some prior research to look up what model

16 numbers that you would want to obtain that doesn't

17 have that in there.

18 MS. HOOTMAN: This is Jill from Trane.

19 Along with what Mark said, it's a separate digit than

20 the coil, the standard coil in the unit. So what

21 we're getting at, it's not mutually exclusive. I

22 mean, it's totally an additional. So it would be
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1 pretty clear that you either had it or you didn't have

2 it.

3 MS. BARHYDT: So the other issues that I

4 show as remaining are both CRE issues, one deals with

5 display lighting and one deals with methodology for

6 dealing with the condensate pan. And DOE is not

7 prepared yet to really propose something on how to

8 address those yet. We do agree that they need to be

9 addressed. We just haven't quite figured out what our

10 position would be on that, so.

11 MR. CYMBALSKY: Right. I saw the e-mail

12 trail from last night and I think part of the issue is

13 I don't think you guys have general agreement on -- at

14 least the condensate pan seemed to be an issue. It

15 seemed like you had a good proposal for the lights

16 that I read, but.

17 MR. SHEBIK: Ron Shebik with Hussmann. As

18 far as lights go, I mean, from the grocery case

19 perspective, I think it's pretty comfortable that if

20 the lights are -- I want to say lights or TV monitors

21 or audio monitors, whatever are used to illuminate the

22 product inside the case, those are items that would
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1 definitely be included within the testing. Dry goods

2 shelves, displays, and stuff like that, that's

3 external to the case. It's on the outside of the

4 case. We would propose that they would not be part of

5 the test requirement because it's not inherent to the

6 case itself. It's something that's driven by the

7 customer. The self-containing case was kind of the

8 gray area with the panel.

9 MR. HON: In self-contains all testing and

10 all base information has been done with external

11 lighting included in it, so we have no problem with

12 that. We understand it completely. But we're getting

13 now into the market where the market is asking for

14 more and more and more. And eventually, we have to

15 say, well, where do we cut it off? Because if it's

16 purely lighting, do we absorb all lighting or do we

17 end up with some other marketing feature which is put

18 on there besides just the lighting? We don't know the

19 answer to that because we have customers who would

20 want unbelievable amount of stuff hanging on the unit

21 powered from it. So we have to -- we are sort of

22 stumped as to what the right answer is because we will
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1 have customers that will push that limit.

2 MR. BAUMAN: This is Jeff Bauman from

3 National. John, when you said that you felt like we

4 had -- basically e-mails, that you were getting a

5 grasp on the lighting almost sounds like we're less

6 confident than you are on that. Can you tell us what

7 you kind of took out of the e-mails last night? And,

8 I mean, I think there were some proposals there. I'm

9 not sure which you're referring to.

10 MR. CYMBALSKY: I guess I was focusing on

11 the lighting that was directed at the product versus

12 not. In one of the proposals I read it was a

13 distinguishing characteristic. Now, Charlie's just

14 said that a lot of the external lighting actually gets

15 tested and it may not be directed at the product, from

16 what I'm hearing.

17 MR. HON: That's correct. A lot of the

18 external lighting's directed at the customer.

19 MR. CYMBALSKY: At the customer.

20 MR. HON: For marketing reasons.

21 MR. CYMBALSKY: And you're counting that now

22 in the --
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1 MR. HON: Yes.

2 MR. CYMBALSKY: Yeah.

3 MR. BAUMAN: Yeah, I agree with that. And I

4 think, also, one of the things that I know I discussed

5 in my portion of the e-mail was defining external --

6 you know, we kind of take -- if it lights the product

7 internal or is internal, it's got to be part of it

8 because it's going to affect refrigeration and affect

9 the performance. If it's external I believe there

10 becomes, hopefully, a separation point that we may be

11 able to determine where it's integral to the product

12 or an essential part of the product versus a

13 nonessential part where it would be something you

14 could remove without affecting the function of the

15 unit. I don't know how easy that's going to be to

16 define, but that seems to be -- because, like Charlie

17 said, it might be -- companies come in, put video

18 displays and things like that on there. Where do you

19 draw that line? And I think that's that line that is

20 the challenge to try to define.

21 MR. HON: This is Charlie Hon again.

22 There's also questions because in the display cabinet
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1 market there are multiple different designs of display

2 cabinets, some which include pass- through-type units

3 where they have doors on both sides of the unit. And

4 those quite often are used in grocery stores and major

5 marketers where they put it at the end of a checkout

6 counter and thereby rather than have two separate

7 refrigerators, actually have one that can be accessed

8 from either side of the counter and cut down their

9 total number of items in the store.

10 Those quite often have double lighting:

11 double lighting going in inside the unit on

12 the product because there's two different sizes to

13 view the product from, also double lighting on the

14 outside of the product, marketing. And that gets

15 really dicey, but we have a parallel to that in the

16 refrigeration testing. And the refrigeration test has

17 if you have a pass- through cabinet, you do not open

18 all the doors. You only open the doors on one side

19 during the test cycle because they know the extra load

20 that it puts on the unit.

21 MR. STARR: This is Louis Starr with NEEA.

22 You know, if the Department of Energy wouldn't -- it
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1 kind of depends whether they consider that you can

2 have multiple metrics, but I think -- they're not

3 going to say it now.

4 Okay, well, the second metric would be an

5 exterior power allowance and interior power allowance,

6 and then because they're --

7 MR. CYMBALSKY: That sounds so easy, I know.

8 MR. SACHS: This is Harvey Sachs and I'm

9 conflicted because the efficiency advocate in me wants

10 to limit all the energy waste and, at the same time,

11 I'm really hit by Ron's comment that there's lighting

12 that is mounted within the refrigeration case to

13 attract the customer. So its load is included even

14 though it's not illuminating the product. Did I

15 misunderstand?

16 MR. SHEBIK: Yeah, I think, yeah. I'm

17 talking about lighting in the case that shines on the

18 product itself.

19 MR. SACHS: Oh, okay.

20 MR. SHEBIK: So it draws the customer to the

21 product itself. It's not advertisement lighting.

22 MR. SACHS: It's not advertising it.
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1 MR. HON: This is Charlie Hon. But I did

2 refer to those.

3 MR. SACHS: Well, I shouldn't confuse you

4 two.

5 MR. HON: We only worked across the hall

6 from each other for years.

7 MR. SACHS: In my concern for fairness I

8 still come back to what I tried to say yesterday, that

9 if it's -- one easy discriminator to me conceptually

10 is if the lighting is within the refrigerated case,

11 then it's presumptively about lighting the product.

12 And if it's outside the refrigerated case, it seems to

13 me that it's mostly about advertising, drawing

14 customers.

15 MR. CYMBALSKY: Well, you can envision a

16 case. I'm sure this -- I don't know. I don't know if

17 I've ever seen it, but you could just like make bolt

18 on, like, hanging lights that shine down on the food

19 that are external to the case, mounted in the field

20 maybe, not have any illumination in the case, but have

21 some, like, spotlights that --

22 UNIDENTIFIED SPEAKER: Shadow makers.
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1 MR. CYMBALSKY: Whatever you call them. And

2 they could be very high wattage, torchiere-type bulbs

3 for that.

4 MR. SACHS: But they would not be integral

5 to the product.

6 MR. CYMBALSKY: Well, they wouldn't be, but

7 then they would be mounted externally and not include.

8 I mean, the question is that's the kind of thing that

9 is troubling; right? You could add maybe 400 watts of

10 lighting that way.

11 MR. HON: This is Charlie Hon. There's also

12 another factor in there and that is the fact that a

13 lot of these glass-doored merchandisers are ENERGY

14 STAR. And the numbers we've been -- the comments we've

15 heard in the past is that the listings on DOE listings

16 should match that of ENERGY STAR. And ENERGY STAR

17 requires all lights on all the time. And they do not

18 give you an exception for inside and outside.

19 MR. BALLO: To Harvey's point, not to

20 disagree with Harvey, but the definition for

21 commercial refrigeration equipment does indicate that

22 it both refrigerates and displays product. And to me
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1 that marketing aspect is part of the display of the

2 product. So, you know, I'm willing to draw a line

3 somewhere, but I think there is some level of

4 marketing that has to be included.

5 MR. HON: If we would draw the line on the

6 inside cabinet lighting only, we would have so many

7 ENERGY STAR products you wouldn't believe it. That'd

8 be about three to five years away.

9 MR. CYMBALSKY: okay, so it sounds like

10 we'll need to think more.

11 MR. HON: We're just asking for guidance

12 here because the market as we stand today is pushing

13 the envelope. Where do we as a supplier to our

14 customers say I can't do that because it doesn't meet

15 energy standards? Or I can't do that because I cannot

16 make it into ENERGY STAR. You will have to give up

17 that criteria if you wish to have this. So we have a

18 series of levels upward that we stop into and whenever

19 we have potential add-on features, we understand we

20 balance out our customers all the time with the lights

21 and the sign panels and the size of the sign panels

22 all the time. That's just a constant activity that we
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1 always function under. But when we get to these newer

2 features, when somebody wants to put an LED display on

3 there with a commercial playing over and over and over

4 again, eventually when does that come away from the

5 value of the unit itself and go into a separate market

6 and category?

7 MR. EISNER: Other comments? Thoughts? Do

8 you guys need more? Do you know where you want to go

9 on this?

10 MR. CYMBALSKY: We don't know where --

11 MS. BARHYDT: We don't know where we want to

12 go on it yet, but I don't think we need more

13 information right now. We just need to sit down and

14 hash through it some.

15 I think that wraps up everything that we had

16 wanted to accomplish during this 2-day session.

17 MR. EISNER: Okay.

18 MS. BARHYDT: So if people want to go catch

19 a plane.

20 I'm shocked there hasn't already been a

21 stampede out the door.

22 MR. KLEISS: Jeff Kleiss. There is one
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1 thing I would like to ask.

2 MS. BARHYDT: Sure.

3 MR. KLEISS: We talked about the FOIA

4 information yesterday. And on the DOE website there's

5 a -- let me get to my file here, there's a test

6 report, a standard default test report. And in that

7 standard default test report it provides -- DOE's

8 asking for the third-party lab to provide information

9 that includes the specific components that are in it:

10 pictures of the unit, pictures of the setup, you know,

11 coil information, et cetera. And I feel confident

12 that you would understand that that's confidential

13 business information as far as the specific components

14 are installed. And I guess what I would like to ask

15 is that you allow either us or DOE perhaps would mark

16 up the standard test report to indicate which of those

17 data you would consider confidential and which are not

18 confidential.

19 MS. BARHYDT: How are the components

20 confidential business information? Anyone who

21 purchases one --

22 MR. THARP: Well, if they want to go
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1 purchase it --

2 MS. BARHYDT: -- would see it.

3 MR. THARP: -- that's fine, but it

4 shouldn't be --

5 MS. BARHYDT: But that doesn't make it

6 confidential business information. Confidential

7 business information is information that you as a

8 corporation hold close, do not share except under

9 contractual licensing agreements with other people who

10 are bound to keep that information confidential.

11 MR. WHITWELL: So confidential may be not

12 the right word for it, but there is a value to it;

13 right?

14 UNIDENTIFIED SPEAKER: Right.

15 MR. WHITWELL: It's maybe proprietary or

16 something because someone would have to go out and

17 spend the money to buy that unit in order to get that

18 information that through FOIA they could get free.

19 MR. THARP: And part of the difference is

20 getting the information for free through FOIA versus

21 going out and doing, pretty much all competitors do

22 competitive analysis and we support Bob and Jill and
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1 everybody by buying one of their units every few

2 years.

3 MR. WHITWELL: Our new models, our first

4 sales we generally know where they're going, right.

5 MR. THARP: So we do that, but that's part

6 of our business cost and we don't want somebody else

7 getting that information at no cost.

8 MR. EISNER: So maybe we make you guys pay

9 the money to the government instead.

10 MS. HOOTMAN: And you've paid a price for

11 it, so I don't think you should give that away free,

12 also.

13 MR. AMRANE: Next year's money, I guess, is

14 what it is.

15 MR. THARP: I'm sure we as an industry would

16 be happy to mark up these reports and tell you what we

17 believe is confidential information or proprietary

18 information that should not be openly shared.

19 MS. BARHYDT: So I will bring with me to the

20 next meeting the legal standard.

21 MS. HOOTMAN: Okay.

22 MR. EISNER: Do you want them mark it up so
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1 we can discuss the issues? What Laura's saying is she

2 cautions whether she's got the legal authority to

3 protect it once she's got it.

4 MS. BARHYDT: Yeah.

5 MR. EISNER: You're saying you think it's

6 proprietary and it should -- maybe you should be going

7 back and asking not only what information you think

8 should be protected, but come back with the arguments

9 your lawyers would make as to why they think it should

10 be protected.

11 MR. HON: Charlie Hon. As a manufacturer

12 I'm concerned because if we're starting to report

13 every supplier and every component into a system, then

14 we're bound where we can't substitute products.

15 MS. BARHYDT: No, this isn't a reporting

16 issue. This is an issue of if we purchase a product

17 and we test it, we have that information. It's not

18 something that you would be submitting in the

19 certification report.

20 MR. HON: This is Charlie Hon again. But

21 even at that point I do not necessarily know which fan

22 you got if you buy a unit from me. We've chosen the -
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1 - if we're doing a normal marketing process, we have

2 an option on several different component choices.

3 MS. BARHYDT: Right.

4 MR. HON: So we may not know which one you

5 actually have. And then if we have to submit all of

6 our possible alternatives, then we have a real mess.

7 MS. BARHYDT: No, no. So there's nothing

8 that you're submitting in this scenario.

9 MR. AMRANE: Karim Amrane. Changing the

10 subject before leaving. Can we review the timeline

11 and where we are and what's left and quickly?

12 MS. BARHYDT: Yeah. Do you have the

13 MR. EISNER: Before we get into that, Wes,

14 you had a question or a comment?

15 MR. WOSTAL: Yes. Wes Wostal,

16 ClimateMaster. I just wanted to state that I had sent

17 -- I owed the definition of condenser water reheat for

18 water source heat pumps to you guys, and I sent that

19 to Karim yesterday morning, so we don't have to go

20 over it at this point. It's basically exactly the

21 same as the definition for hot gas reheat. I just --

22 where the differences applied I changed the words in
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1 that definition, so it follows exactly the way that

2 the hot gas reheat definition does. And I just wanted

3 to let you guys know that so can put it in. So that's

4 it.

5 MR. KLEISS: Also, Jeff Kleiss, we had

6 talked yesterday some about the volume measurements

7 for storage water heaters and unfired storage tanks.

8 I did go back and look at the Federal Register on

9 that. I would like to have a discussion on that.

10 MS. BARHYDT: Oh, okay. We can discuss

11 that.

12 MR. KLEISS: Okay. It's page 35 of the

13 slides if you still are -- in terms of the federal

14 regulations for the minimums, according to 10 CFR Part

15 431.110, for electric storage water heaters it is

16 based on the measured storage volume. So what we've

17 got listed there is appropriate.

18 For commercial gas-fired and oil-fired

19 storage water heaters, the required value should be

20 the rated storage vale, and that's what determines the

21 federal minimums that have to be met. The measured

22 storage volume is used to calculate the standby loss,
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1 but there doesn't seem to be any reason why that would

2 need to be reported.

3 Same thing for, well, really for all the

4 gas- and oil-fired products.

5 MR. STANONIK: Frank Stanonik, AHRI. To be

6 clear on that last point, the measured volume is used

7 when you actually run the test, so you're actually

8 measuring the volume of the test unit. You're not

9 having a measured volume of a theoretical model.

10 MR. KLEISS: Right.

11 MS. BARHYDT: So I think we're okay with not

12 collecting the measured volume for the commercial gas13 fired and oil-fired, but I think we do want to add a

14 few pieces of information to collect for units that

15 are greater than 140 gallons to reflect the design

16 requirements.

17 MR. KLEISS: Right. The standing pile at R18 12.5.

19 MS. BARHYDT: Yeah.

20 MR. KLEISS: With regard to the

21 instantaneous units that are less than 10 gallons, I

22 appreciate that in the slide that it shows the storage
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1 volume and it doesn't specify whether it's rated or

2 measured. There is no, you know, measurement method

3 or a standard associated with it other than it being a

4 threshold to determine whether or not it's low to the

5 gallons. So I don't know if that is something that

6 does need to be reported or not.

7 MS. BARHYDT: That was for instantaneous?

8 MR. KLEISS: That's for commercial gas9 fired. It's on the next page.

10 MS. TUCKER: Instantaneous less than 10,

11 okay.

12 MR. KLEISS: Less than 10.

13 MS. BARHYDT: We'll take a look at it.

14 MR. KLEISS: Okay. And then, of course, we

15 did have a discussion about the unfired storage tanks,

16 but I don't think there's anything new that I have to

17 add to that that I haven't already said several times.

18 MR. EISNER: Anything else on this subject?

19 MS. BARHYDT: Nope.

20 MR. EISNER: You wanted to go over the

21 calendar?

22 MS. BARHYDT: So the schedule. We have down
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1 - - so this still isn't the updated one.

2 MS. TUCKER: Oh, sorry.

3 MS. BARHYDT: So, at this point, on 7/17

4 we're finishing up basic model and certification.

5 Hopefully, we can actually vote on those on the 17th

6 and then we'll start the verification laboratory

7 accreditation process on the 18th. So everything is

8 just bumped down accordingly.

9 We will meet with SPVU and CRAC before the

10 17th so that we can have all of the basic model issues

11 resolved at the 17th meeting.

12 MR. AMRANE: Send me your --

13 MS. BARHYDT: Definitely. And we will also

14 be sending out all of the information that I think

15 we've pretty much resolved. I know we haven't voted

16 on anything, so we'll put it all on paper so that

17 everybody can review it in preparation for the meeting

18 on the 17th.

19 If you have any issues, by all means go on

20 SharePoint, mark stuff up, e-mail so that, hopefully,

21 we can get issues resolved in advance so that we're

22 really ready to go in and vote on the 17th.
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1 MR. EISNER: Questions?

2 MR. SACHS: This is Harvey. Could you send

3 out that calendar when it's updated? I think you

4 heard you saying --

5 MS. BARHYDT: Yeah, it's no SharePoint, but

6 we can e-mail it.

7 MS. HOOTMAN: The updated one's on

8 SharePoint?

9 MS. BARHYDT: Yeah. Actually, I think the

10 way it shows it right now is verification starts on

11 the 17th because I was thinking we might wrap up basic

12 model and certification this trip.

13 MS. HOOTMAN: Okay.

14 MS. BARHYDT: But it doesn't sound like

15 we're ready to do that yet, so it'll bump down.

16 MS. HOOTMAN: And then are you -- this is

17 Jill at Trane. Are you going to send out slides about

18 verification, specifically the laboratory

19 accreditation process, what you're thinking there? Or

20 what -- do we have those slides already? Were those

21 out there?

22 MS. BARHYDT: Are they in that -- I think
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1 they were in the last packet.

2 MS. HOOTMAN: They are, okay. All right.

3 MS. TUCKER: They're at the end of this

4 packet.

5 MS. HOOTMAN: Oh, we just never got there on

6 this?

7 MS. TUCKER: Yeah.

8 MS. HOOTMAN: Okay.

9 MR. SHEBIK: Laura, for CRE, in order to get

10 to the voting next week, what's the takeaway that you

11 need -- well, what do you need from us? Like what's

12 our action item? The heating condensate pan,

13 lighting? What kind of information do you need or do

14 you need anything from us?

15 MS. BARHYDT: If you all reach an agreement

16 with an industry as to what you think would work, that

17 would be ideal.

18 MR. CYMBALSKY: I think we can float at

19 least one idea for one of those. Not the lighting.

20 MR. SHEBIK: Okay.

21 MR. CYMBALSKY: The lighting one, yeah, I

22 don't know. I have to think about that.
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1 MR. SHEBIK: Okay.

2 MS. BARHYDT: Anything else? Everybody have

3 a safe flight.

4 MR. CYMBALSKY: Yes.

5 (Whereupon, at 11:23 a.m., the

6 Appliance Standards and Rulemaking

7 Federal Advisory Committee Meeting was

8 adjourned.)

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Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013 

1 CERTIFICATE OF COURT REPORTER 

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3 I, CHRISTINE ALLEN, the Court Reporter before whom 

4 the foregoing proceeding was taken, do hereby certify 

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7 my direction; that said transcript is a true and 

8 accurate record of the proceeding; that I am neither 

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sts~lJ14~ L~~)~ CHRISTINE ALLEN 

Digital Court Reporter 

Date 

(866) 448 - DEPO 

www.CapitaIReportingCompany.com © 2013 

142 
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 1

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2013

0

0.05 33:8

0.08 9:6,8,16,19

20:18 25:3 30:9

31:1,20,22

32:10,14 36:7

0.1 31:19

0.45 32:9,10

0.5 26:2

0.8 26:2

1

1 83:1 86:7,12

1,000-hour 40:1

10 28:8 43:22 45:8

67:17 77:13,17

80:6 82:16 84:15

135:14 136:21

137:10,12

10.95 27:10

100 49:5 50:5

67:16 94:8

112:17

1000 1:9

11.0 27:10

11:23 141:5

12 14:5 56:11,13

64:20

12.5 136:18

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127 7:11,12

13 56:14 60:10,14

62:6 78:9

14 78:12

140 136:15

15 77:17

1654 69:6

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138:5,10,11,18,2

2 139:11

18th 138:7

192 98:2,14,16

192-hour 41:8

2

2 1:12 14:9 103:17

104:19

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2037 19:3

210 12:1 14:18

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15:18 27:9 28:6

33:2 34:7,8

250 42:18

2-day 129:16

3

3 20:16 70:17

114:22

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300 42:18

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340/360 9:21 14:13

19:1 24:16 27:4

28:6 83:16

35 135:12

37 10:3

4

4 11:10 14:9 20:16

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400 127:9

410 85:22

42 17:20 57:17

420 85:21

430 33:4

431.110 135:15

5

5 23:14 108:4

500 38:1 40:8,19

90:17 98:3

99:5,22 100:3

102:1,2

500-hour 39:22

41:5 42:16 99:11

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52.2 35:9

6

6 8:19 10:20 11:10

23:14 62:5

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7 37:19

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90.1 114:8

95 46:2 105:4,6

106:6,7

97 104:19

98 104:19

9-point 45:8

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a.m 1:13 4:2 141:5

AAON 2:16 11:22

92:15 110:14

114:12 118:2

able 8:5 16:15

17:3 28:21 29:4

98:18 100:2

107:13 111:6

112:22 117:6

123:11

absolutely 10:19

absorb 121:16

AC 53:20 54:1

accelerated 93:3

accept 70:10

acceptable 91:15

102:3

accepted 28:7

accessed 124:7

accommodate

29:11

accomplish 49:22

129:16

accordance 17:21

according 28:5

135:14

accordingly 79:2

138:8

account 7:21 12:6

18:13,14,16

27:13 49:13

accounted

54:11,16,17

accounts 54:8

accreditation

138:7 139:19
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 2

(866) 448 - DEPO

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accurate 142:8

aces 89:9

achieve 115:20

ACHRI 2:9 3:13

acidic 92:16

acids 39:2 92:5

across 11:2 15:12

21:21 43:22

83:15 84:2 87:7

113:14 126:5

action 140:12

activities 41:21

activity 128:22

actual 4:22 37:15

83:14 105:16

actually 7:13 8:1,6

10:4 13:19 15:16

17:10,16,20

20:15 23:1 25:5

32:9,17 33:12

35:9 37:12 42:11

55:17 62:15 65:9

75:2,5 90:2

97:19 105:9

122:14 124:7

134:5 136:7

138:5 139:9

add 7:6 25:17

28:10 29:2 31:22

34:13 47:3

58:10,16 59:9,12

63:11 88:11

94:3,6 97:6

101:7 127:9

136:13 137:17

added 18:19 32:3

40:17 61:6,10

64:7 88:9 96:16

addendum 90:10

adders 57:2

adding 61:8

74:6,10 87:17

addition 49:14

118:17

additional 6:20

7:1 8:5 32:3 37:4

75:20 118:10,15

119:1,22

add-on 128:19

add-ons 60:20

address 23:1 25:14

36:10 88:5

118:18 120:8

addressed 10:14

118:22 120:9

addresses 77:8

addressing 91:1

adequate 83:19

adhere 87:19

adhesion 69:6

adjourned 141:8

adjusted 85:12

adjustment 10:15

admit 91:18

adopt 57:19

adopted 55:11

adopting 55:3

advance 138:21

advanced 116:21

117:2

advertisement

125:21

advertising 125:22

126:13

Advisory 1:6

141:7

advocate 125:9

AEDM 77:7,8

affect 25:22 66:21

88:1 123:8

affected 58:12,17

affecting 123:14

affects 26:5,6 27:9

against 24:22 72:5

79:1 112:18

agency 88:4

aggressive 46:11

ago 112:13

agreed 4:10 18:18

23:21

agreement 16:15

17:3 18:21 87:19

113:8 120:13

140:15

agreements 131:9

ah 109:12

ahead 61:1 67:5

AHRI 6:14 7:4

12:5 18:8 22:5

24:4 28:22 30:15

54:5 71:1 78:14

80:11 85:4,21

101:5 102:16

136:5

air 2:11,13 4:5,16

6:13,15,16,21

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33:5,6,17,21

34:3,4,5

35:10,13 36:15

39:3 63:14 76:11

86:14 112:8,14

113:1 118:6

air-condition

112:20

airflow 15:3,11

32:5,6,7 44:20

63:1

alcohols 39:2

alkalis 39:2 92:5

Allen 1:16

142:3,17

Alliance 3:12

allow 45:7 130:15

allowance 13:7

125:5

allowed 87:7

allows 13:22

already 14:15

28:22 33:10

118:19,22

129:20 137:17

139:20

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alternate 29:3

alternative 27:15

49:12

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altogether 81:17

aluminum 39:9

93:18 95:20,21

96:1 99:21

am 91:20 142:8

amazing 59:4

ambiguity 23:6

amend 12:6

American 3:9

Among 100:17

amount 63:14 84:1

85:20 113:1

121:20

Amrane 2:9 7:4,9

12:4,5 18:8 22:8
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 3

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2013

24:4,15 30:15

54:5,10,13 72:10

78:14 79:10

80:11

81:2,5,8,20 85:6

102:16,21 103:6

116:7 117:18

132:13 134:9

138:12

analysis 46:22

54:7,9,15 55:19

78:16 131:22

Analyst 2:5

annotated 28:8

answer 7:5

37:15,17 51:4

121:19,22

answered 53:18

anti-corrosion

83:18

anybody 26:20

52:6 74:5 96:7

anyhow 72:1

anyone 8:4 22:18

29:4 37:3 43:21

58:9 116:13

130:20

anything 9:8 14:10

30:12 56:15 64:7

77:13 85:15

88:18 137:16,18

138:16 140:14

141:2

anyway 109:14

anywhere 37:22

95:16

apparatus 31:9,20

apparently 30:19

appears 95:7

96:17

Appliance 1:5

141:6

application 14:6

51:7 53:2 57:2

68:1 92:21 113:9

114:15 117:4

applications 46:9

49:1 52:5 59:5

61:20 82:2 94:14

applied 19:17,22

51:13 57:3,10

74:21 87:12

93:13 134:22

applies 94:8

apply 14:19 72:3

81:13 82:7

106:12

114:15,16

applying 74:21

102:6

appreciate 59:20

136:22

approach 81:21

101:1 111:18

approaching

113:10

appropriate 15:5

93:2,5,8 135:17

approximate 13:6

23:18

approximates

23:21

approximation

23:19

arbitrary 15:4

37:11

area 32:15,18

46:17 121:8

areas 38:13

aren't 110:6

arguing 24:22

arguments 133:8

ARI 54:22

55:1,3,6,7,20

58:5 59:7

Aris 3:18

Armstrong 2:7

arrives 34:6,10

Ashley 2:7

ASHRAE 7:11,12

10:3 11:18 33:10

35:9

aspect 117:17

128:1

ASRAC 2:3,4

assembled 39:7,9

93:11,18

associated 7:1

21:12 61:7,17

137:3

assume 107:16

assumed 47:2

assuming 75:12

assumption 77:22

ASTM 39:12

40:12 71:9,18

91:14,22 95:2

97:4 99:22 102:2

at-hand 84:16

attempting 115:11

attract 125:13

audience 58:17

audio 120:21

authority 133:2

available 76:6

81:4 88:14

107:5,10,11

108:1,4,8,12

110:18 113:19

115:12,16,20

Avenue 1:9

average 18:4

away 12:14 21:6

47:21 48:4 61:9

92:9 99:18

117:19 128:8

129:4 132:11

B

B117 39:12 68:15

73:13,17,19

92:16 94:8 95:2

96:20 97:4

99:1,22 102:2

backed 105:11

background 51:1

86:6

background's

58:22

backsliding 45:6

bad 42:13 84:20

100:2 112:6

114:4

bag 21:14

baked 39:4 95:15

101:11

balance 128:20

Ballo 2:10 67:5

68:5 90:10 91:6

101:17 102:14

127:19

band 104:5 106:8

109:8

bands 115:22

bar 43:7

Barhydt 2:6
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 4

(866) 448 - DEPO

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4:9,13 5:2,9,18

6:10,13 7:7,15

8:1,9,12

9:2,4,11,20 10:8

12:18 14:18 16:7

19:5 20:1,7

21:7,18 22:1,17

23:22 24:7 25:4

27:15 29:10,15

34:1,15,20

35:1,6 36:9 37:3

38:8 40:12,16

63:16 74:14

76:16 77:3,8

80:21 81:4,7

88:16 89:1

90:1,21 92:10

94:20 98:3,8

99:2,7 109:8

115:21

116:10,19

117:11

118:14,16 120:3

129:11,18

130:2,19 131:2,5

132:19 133:4,15

134:3,7,12

135:10

136:11,19

137:7,13,19,22

138:3,13

139:5,9,14,22

140:15 141:2

base 47:7,8 49:6

50:3 56:21,22

57:14 59:22 61:5

63:20 64:5

70:6,16 75:11,20

103:19

107:7,13,15,18,1

9 115:15 121:10

based 16:22 18:12

23:22 25:1 26:14

28:14 55:6 59:10

135:16

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38:15 47:2,3,12

basic 8:4 13:13

16:21 47:17 55:4

56:5,9,14,19,20,

22 57:15

58:1,2,6 62:10

64:8,10,14 66:3

74:7 75:3 87:5

104:12 138:4,10

139:11

basically 40:13

57:18 68:20

122:4 134:20

basket 71:15

Bauman 2:11

51:18 53:11

122:2 123:3

Bean 2:12

become 26:9 65:7

becomes 27:10

47:22 123:10

becoming 52:1

Beever 2:13

begin 77:2 100:5

behalf 51:5

behind 42:8

believe 10:18 54:7

80:9 82:15 85:7

88:7 98:2,3

110:3 116:3

123:9 128:7

132:17

bells 57:1 59:11

64:5

belong 15:14

belt 110:7,11

beneficial 80:1

benefit 62:22

72:14 73:5

besides 118:11

121:18

best 21:4 67:22

90:1,8 112:21

113:5

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22:8 47:9

60:18,21

65:10,15 73:1

89:8 99:9 106:5

111:3,4 119:8

beyond 12:15,16

38:14 48:14

bigger 32:16,17

104:12 106:5

110:4

biggest 74:18

bit 26:13 32:20

83:6 94:6 103:12

114:13 115:11

black 66:7 98:13

blah 101:11

blower 55:9 58:10

105:19,20

106:2,14 112:3

113:17 115:18

blowing 114:15

blunt 44:21

BMG 58:1

board 11:2 87:7

113:14

Bob 6:1 75:9

108:21 131:22

boils 44:21

bolt 126:17

bonded 39:6

boom 79:8

bottom 86:3

bound 131:10

133:14

boxes 6:4

brand-new 73:3

break 80:5 82:20

91:11

brief 80:7

bring 15:16,20

16:2 33:11 94:15

132:19

brought 10:16

15:22 63:8 94:9

116:21 117:1

build 19:13 48:7

building 15:8 17:1

113:10

built 7:2 117:5

bulbs 127:2

bullhead 114:22

bump 139:15

bumped 138:8

bunch 23:7 36:19

burden 64:15

74:18 75:19 77:9

burdensome 18:5

business 61:20

130:13,20

131:6,7 132:6

buy 31:4 36:19

58:7,16 131:17

133:22

buying 34:3 132:1

buy-off 89:11

C
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 5

(866) 448 - DEPO

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cabinet 41:8

123:22 124:17

128:6

cabinets 124:2

calculate 135:22

calculation 32:1

58:11

calculations 58:9

calendar 137:21

139:3

candor 59:20

capacity 4:15 7:18

19:2 58:11,13,17

Capital 1:17

capture 43:16

captures 113:5

capturing 106:1

car 60:2

care 65:14

cared 65:5

careful 115:7

Carrier 3:15 6:2

75:9 108:21

109:12

case 6:7 47:14

48:10 50:19

57:12 91:7 113:1

120:18,22

121:3,4,6,7

125:12,17

126:10,12,16,19,

20

cases 47:11 48:18

50:12,20,22 63:7

83:14

catch 96:13 129:18

catcher 21:5

categories 46:6

categorized 30:13

category 100:20

108:1,10 129:6

cathodic 39:5

cause 77:14 87:21

causes 115:2

caution 114:13

cautions 133:2

certain 18:21

28:12,20 45:7

47:6 75:4 91:4

certainly 38:1

83:11 107:6

113:12 114:11

CERTIFICATE

142:1

certification 4:4

5:11,14,15 8:3

75:19 133:19

138:4 139:12

certify 142:4

cetera 67:20 76:11

85:19 92:6 104:2

130:11

CFM 112:4 113:19

CFR 28:8 55:17

135:14

challenge 123:20

chance 52:14

116:13

change 14:3 24:21

27:5,12 29:8,10

69:17 78:22 84:1

96:16

changed 28:9

63:19,22 85:16

134:22

changer 5:8

changes 18:15

30:4 63:3

69:12,13

changing 28:15

31:20 55:5,14

78:15 79:1 82:7

134:9

channel 5:8

characteristic

122:13

characterization

55:3

characterize 66:1

characterized 55:7

characterizing

55:12

charge 85:13

Charles 2:19

Charlie 37:6 40:21

45:20,21 48:5

50:1 51:9 69:9

77:6 95:18

123:16,21 126:1

127:11

133:11,20

Charlie's 52:3

122:13

chart 103:19,22

charts 106:3

chassis 44:18

cheapest 58:7 60:1

111:6

check 4:12

checkout 124:5

chemicals 67:19

92:18

chemistry 93:7

chlorine-based

92:17

choices 134:2

choose 70:12,18

75:5

Chorus 31:6

chosen 133:22

Christine 1:16

142:3,17

church 15:14

churches 16:12

circumstances

16:17

claiming 64:7

clarification 30:2

clarify 110:15

class 18:3 80:16

81:18 82:5 92:22

107:8,10,11

108:10

classes 47:5,6

81:14 84:15

cleaned 42:7

clear 27:20 49:1

116:19 120:1

136:6

clearly 48:21

Cleaver-Brooks

3:6

Climate 3:16

ClimateMaster

94:5 134:16

close 68:21 131:8

closer 17:15

Co 3:5

coast 61:20 92:21

coastal 38:13

coat 56:6,11 63:5
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 6

(866) 448 - DEPO

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65:11,14 98:13

coated 37:4,11

39:10 42:11

46:5,8,10

49:2,5,10,14

50:21

51:6,10,15,21

52:2,4,7,12,19

53:4,21

54:3,11,16 56:6

61:22 62:4

66:16,20 67:11

69:1,11 70:10

72:11,15,17,22

75:12,13 76:4,6

78:1,21 79:4,13

80:14,17 81:1,11

85:5,12,19

86:2,11,13,17

88:18 90:11,16

93:12,20 96:20

97:12 100:17

101:8,9 103:1,13

coating 37:19,20

39:6 40:14

42:16,19 45:17

47:7,9,12 51:2

60:17 62:7

65:2,4,7

66:11,18 67:2,11

69:14

71:4,9,14,18,19

72:3,4,6 73:12

74:6,10,19,21

75:5,6 79:18

83:19 86:22 92:3

93:13 98:20 99:9

100:5 103:8

coatings 42:1,4

44:6 68:9 72:2

73:13,14,16

74:2,3 82:22

83:18,22 92:1

cobble 68:2

Code 17:20 57:17

coil 21:6 37:11

38:22 39:7,17,19

42:11,13 46:8,10

47:15,17

48:1,2,22

49:6,10,14 50:18

53:4 62:1,4

63:2,5,7,18 65:4

66:16,20

69:1,11,16 70:10

72:1,11,15,18,22

74:8 77:15

78:1,9

79:4,13,19

80:14,17 81:1,11

85:11,18

86:11,12 88:18

90:15 92:14

93:11,12 97:12

99:19,21 103:14

108:20

118:11,12,18,21

119:7,20 130:11

coil-only 85:22

coils 37:4 38:22

39:9 41:15,16,17

42:14 43:19 44:1

46:6 47:19 50:21

51:2,6,10,16,21

52:2,4,7,12,19

53:21 54:3,11,16

56:6,11 60:12

61:21 62:1,17

65:8,11,14 71:14

73:14 75:12,13

76:4 78:17,21

85:21 86:16

90:11 93:17 95:1

96:11 103:1

104:14 114:21

118:18 119:1

collect 7:17,18

136:14

collected 6:19

collecting 7:21

136:12

Collin 3:20

color 44:18

column 9:9

30:10,11 31:1

combination 4:14

6:7 68:7,11

combinations

113:18

combined 86:16

comes 22:11 34:21

67:17

comfortable 15:12

120:19

comment 11:17

32:16 52:13 64:3

68:6 73:8 85:10

125:11 134:14

commented 86:20

89:4

comments 52:15

69:10,22 114:3,5

127:14 129:7

commerce 110:18

commercial 16:3,7

19:14 35:12

52:11 53:22

54:15 56:3 57:13

61:12

70:1,3,7,12

76:15 82:2 83:1

91:22 94:13

99:12,13 102:5,7

127:21 129:3

135:18 136:12

137:8

commit 90:1

committee 1:6

25:13 33:10

141:7

common 78:18

101:2 111:5

companies 4:22

51:17 64:12

92:12 94:12

123:17

company 1:17

2:21 26:20 50:20

51:5 61:16,17

70:2 93:12

company's 51:15

comparable 59:8

compare 111:10

comparison 86:2

compatible

114:21,22

compensate 44:19

46:13

competitive

131:22

competitors 23:5

38:5 51:1 131:21

complain 66:7

complete 76:7

completely 15:12

93:11 121:12

compliance 25:13

57:1,16 98:14

105:14

compliant 26:9

74:22

comply 96:20

98:15

component 117:20

118:11,15 119:2

133:13 134:2

components 6:20
Capital Reporting Company

Appliance Standards and Rulemaking Federal Advisory Committee Meeting 07-02-2013

Page 7

(866) 448 - DEPO

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41:7 106:13

115:8 116:12

117:13

130:9,13,19

compromise 17:12

74:20 75:7

111:13 113:6

computer

6:13,15,16,21

7:11

concept 107:1

conceptually

105:13 126:9

concern 15:6

65:17

74:9,11,15,17,18

75:17 77:16

90:21 101:6,17

112:1 113:8,10

115:6 117:7

118:16 119:10

126:7

concerned 49:16

65:6,11,13

133:12

concerns 77:5

86:19 111:17

condensate

120:6,14 140:12

condensed 94:22

condenser 38:22

44:1 94:22

134:17

condition 16:22

42:5

conditioners 4:5

6:14,15,17,21

7:11

conditioning 2:11

112:15

conditions 13:3,8

17:10 48:1 68:16

conduct 18:6

97:21

conducting 97:19

confident 122:6

130:11

confidential

130:12,17,18,20

131:6,10,11

132:17

configuration 17:1

107:5

confirmed 39:11

95:1 101:19

102:1

conflicted 125:9

confuse 126:3

confused 55:14

conjunction 68:19

consensus 89:16

consider 13:2 42:7

64:10 70:22

82:12 107:9

125:1 130:17

consideration

28:16 30:3

considered 41:9

90:16

consistency 23:13

49:18

consistent 11:2

23:5,20 25:16

constant 128:22

constraining

115:8

constraints 44:10

84:19

constructionist

15:1

Consultants 2:17

consumer 79:22

consumption

57:11,12

contained 45:22

48:15 50:2

112:19

Cont'd 3:2

context 114:1,6

continue 29:19

65:10

continued 3:1

105:22

contracted 119:10

contractor 119:10

contractors 12:11

21:4

contractor's 21:3

contractual 131:9

control 88:11

controlled 60:22

controller 4:19

5:3,20

controlling 6:22

conversation

29:14

cool 2:13 118:20

cooled 33:3

cooling 4:15

117:10

cools 33:7

COP 4:16,17

copper 69:17

99:21

core 35:13 50:3

Corey 3:22 38:17

corporation 3:10

131:8

correct 11:12 28:2

81:2 103:17

111:12 122:17

correctly 74:9

corrode 92:9

corrosion 38:21

39:11 65:21 66:5

69:18 72:18 87:1

88:8,11 91:1,2

95:1 97:12 98:17

101:19

corrosionprotected 92:13

94:22

corrosionresistant 43:3

corrosive 39:2,3,8

41:21 43:1,6

44:17 86:14 92:4

93:17 100:16

101:4

corrosiveresistant

43:2,12

cost 21:3 47:1,4

59:13 61:7

67:14,17 75:13

79:22 132:6,7

costly 49:3

costs 18:2 35:15

Council 3:9

counted 78:17

counter 46:12

124:6,8

counterintuitive

32:20
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counters 53:1

counting 122:21

couple 31:4 42:14

67:7 69:10

course 76:8 81:5

109:22 137:14

Court 142:1,3,17

cover 73:15 75:7

96:19 98:5,18

119:3

covered 48:22

covering 39:7

CRAC 138:9

CRE 15:21 44:1

45:14 51:20,22

68:10,11 120:4

140:9

create 47:4 63:11

111:1

credit 62:19

creeping 69:6

criteria 16:16

59:13 97:5,7,16

128:17

Cromer 117:3

cross 19:15 96:22

curious 54:20

current 18:12

22:22 24:16 27:4

28:14,15 79:3

84:9 108:19

currently 80:15

82:18

curve 111:11

curves 47:1

customer 46:7

121:7 122:18,19

125:13,20

customers 11:6

21:15 67:22

70:16 71:16 87:3

121:19 122:1

126:14

128:14,20

cut 121:15 124:8

cycle 15:2,10 18:4

117:4 124:19

Cymbalsky 2:4

11:3,14 13:17

14:14,20 23:3

25:19 26:10 28:2

36:14 45:4

53:6,13,19 55:21

56:2,4 59:20

60:3,5,7 62:8,15

64:16 77:10

78:3,5,8 79:7,11

81:12 84:8 85:4

89:7,19 90:7

91:16 95:5,15

96:4,21 100:10

102:6,12,15,19

103:1,4,9 104:9

107:14 108:16

109:3,6

111:14,19

120:11

122:10,19,21

123:2 125:7

126:15 127:1,6

128:9 129:10

140:18,21 141:4

D

D.C 1:10

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Dane 2:14 52:20

data 11:19,20

54:22

55:4,7,10,20

85:20 86:4,10,17

88:21 130:17

database 48:19

55:1

date 18:21

day 41:6,19,22

42:5,6

days 109:2

de 83:22 84:3,5

deal 12:20 24:11

63:9 67:20 88:19

dealing 10:10 84:9

110:2 120:6

deals 120:4,5

dealt 9:13

debate 111:21

decide 27:7 37:10

decided 88:4,5

decision 15:4

108:18

decrease 44:6

63:13 87:21

dedicated 8:6

118:6

default 9:6 12:6

14:16 15:20

18:10,19 19:16

24:18 25:2,9

27:8 130:6,7

defeat 49:21 112:6

define 39:17,18

47:8 67:12

123:16,20

defining 123:5

definitely 19:20

46:4 121:1

138:13

definition 39:13

43:10 49:6 56:19

58:1 67:9 68:21

69:4 90:15 91:17

93:10 95:13

102:18 127:20

134:17,21

135:1,2

definitions

55:3,5,15

definitive 37:8

Degitsz 3:21

degradation 99:6

dehumidification

116:4,11,12,16

117:12,17

118:20 119:1

dehumidifier

118:12

dehumidifies

119:8

dehumidify

118:13

delay 29:8

delta-P 25:17

denominator

111:5

Denver 11:18

Department 1:3,8

2:5,6,7 36:9

44:15 57:8

124:22

Department's 43:5

depends 69:18

125:1

derive 47:1

described 71:18

describing 99:17

description 92:13

97:11 108:13
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desiccant 117:4

118:10

design 20:22 46:8

48:22 63:22

78:8,12 105:20

136:15

designate 119:13

Designated 2:4

designed 17:22

43:6,19 106:19

113:12

designer 114:10

designing 49:13

60:10 77:12,17

designs 106:15,17

124:1

desire 13:14

destruction 43:19

details 33:12

determination

11:21

determine 40:6

71:3,8 73:11

123:11 137:4

determined 18:4

71:17

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detrimental 73:2

Development 3:6

Diane 2:22 8:13

10:16 12:8 21:16

30:6,16 42:20

54:19 58:4 66:15

diatribe 95:12

dicey 124:15

difference 11:1

45:15 56:19 70:2

85:15 86:5,7

87:11 131:19

differences 57:9

87:15 134:22

different

7:13,14,16,19

10:22 13:15

15:14 17:15

37:7,10,19,20,21

41:2,11 44:17,18

45:5 46:19 49:2

53:3 58:19,20

62:10,14 63:20

64:10 68:10

69:12,16 81:17

87:5,10 89:6

91:1 92:18 99:13

106:14,15

124:1,12 134:2

differentiate 30:7

differentiated

97:20 116:12

differently 60:16

62:21 119:14

difficult 47:8

digit 66:22 119:19

Digital 142:17

digits 44:3 92:21

diligence 36:4

dipped 63:7

direct 108:9

110:7,9,12

direct/indirect

117:10

directed

122:11,15,18

direction 33:14

88:15 142:7

directly 41:3

directory 29:1

55:20 58:5 59:3

78:19,21

dirt 13:5

dirty 15:7 29:2

disagree 62:8

77:19 83:4 96:7

112:21 127:20

discharge 114:20

115:1

discouraging

117:8

discovered 29:16

discriminator

126:9

discuss 133:1

135:10

discussed 94:6,17

103:13 123:4

discusses 93:10

discussing 81:15

89:13

discussion 7:6

36:12 39:20

55:18 62:12

73:10 96:5 97:15

104:8 108:15

135:9 137:15

discussion's 45:2

dishwashers 41:4

display 120:5

123:22 124:1

128:1 129:2

displays 121:2

123:18 127:22

distinguished

117:21

distinguishing

122:13

docked 112:15

documentation

75:19

DOE 2:3 6:15 11:3

17:9 18:10 27:22

28:10,19 31:1

33:19 54:6,8

55:18 66:13

74:16 78:16,18

80:13 91:15

113:2 120:6

127:15 130:4,15

DOE's 57:19 74:9

80:15 130:7

dog 75:17 100:21

done 17:12 21:19

22:3 27:1 35:16

40:11 46:14

60:19,22 61:6,12

78:16 79:2 80:18

85:1 98:21 104:9

113:2 121:10

door 129:21

doors 124:3,18

Doppel 2:15 4:21

5:6,12,15,21

6:5,9,12 13:10

16:11 28:3

29:13,21 39:21

41:14,19

42:1,9,15 44:8

49:8 57:4 61:15

63:6,10 79:16

110:10 116:21

Doppel's 44:10

dot 90:9

double 66:17

124:10,11,13

doubt 113:11

downstream 112:7
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draft 90:5 109:3

drafted 108:22

drafting 35:7

draw 123:19

128:2,5

drawing 126:13

draws 125:20

drive

110:7,8,9,11,12

driven 45:12 121:6

driving 112:18

drop 8:20,21,22

9:9 10:15 11:20

12:7 13:7

15:5,11 20:8

21:11 23:9,19,21

24:2,3 25:18

26:3 30:12,13,18

31:8 32:17,21

83:21

drops 10:22 33:12

Dry 121:1

ducted 4:15

ductwork 112:7

115:1

due 36:4

duke 53:12

durability 39:1,11

40:7,11 95:1

101:19

duration 97:5

during 18:3 82:20

91:10 124:19

129:16

duty 65:21

E

earlier 53:8 65:19

69:22 94:7 97:3

106:14

Earth 2:10

EarthJustice 68:5

easier 84:4

easy 123:15 125:7

126:9

ECM 105:17,22

110:20,22 111:3

E-coating 94:7

economizer 80:4

economizers 33:18

76:5,10

economy 3:9 60:2

EER 4:16 26:6,14

27:10

effect 36:2 71:22

88:12

effects 39:2 114:19

115:2

efficiencies 114:8

efficiency 3:11

13:14 18:1 20:2

24:6 28:13,16

29:5,9 30:9,18

33:17,21 44:7,16

47:1 54:7 56:7

57:3,7,10

58:6,14 59:14

61:9,13 63:12

66:10,21 67:1

69:14 71:15

72:12,13,16,19

73:4,5 74:4,7,12

75:4,11 78:10

79:19 80:14

87:20,21 103:20

104:4 105:7

106:4,11

107:7,8,15,18,19

111:9,10 112:8

114:14

115:15,16,19

125:9

efficient 3:9 60:3

105:4,20 106:18

107:12 108:4

110:4,17,19

effort 98:12

eight 87:8

Eisner 2:2 4:3,10

29:18 35:3 36:12

73:7 76:1,14,21

80:5,8 84:22

87:16 88:20

89:2,20 91:9,14

94:3 96:7 101:15

102:3,10 111:17

129:7,17

132:8,22 133:5

134:13

137:18,20 139:1

either 17:4 25:5

54:8 75:3 108:1

120:1 124:8

130:15

electric 2:12,15,21

135:15

electrodeposition

39:5

element 95:11

113:5

else 22:18 26:20

52:13 56:7 58:9

61:2 75:5 96:17

104:1 106:6

132:6 137:18

141:2

else's 119:8

e-mail 120:11

123:5 138:20

139:6

e-mails 122:4,7

employed 142:9

encase 103:10

encased 103:10

endure 99:22

energy 1:3,8

2:5,6,7 3:9,11

18:1 57:11,12

65:9 69:14 72:16

79:21 83:21 84:1

124:22 125:10

127:13,16

128:7,15,16

enforcement

45:4,13

Enforcement-wise

45:11

engineer 58:19

engineering 25:13

46:22 86:6

103:17

engineers 9:17

58:18

entered 9:5

entering 86:14

entire 46:11 75:15

95:12

envelope 128:13

environment 41:1

43:6,20 71:13

72:8,17 93:1

environments

39:4,9 72:5

92:17 93:17

100:16,21 101:4

envision 126:15

epoxy-type 39:5

equal 56:7 115:15
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equipment 5:7,10

6:19 12:16

13:6,9 14:12

15:3,10 16:8

17:17 18:3

19:1,16,17 20:2

35:18 43:5 46:1

50:2 52:12 55:12

65:13 70:5,7,12

72:22 91:19

114:14 115:9

119:12 127:21

equipment's 17:11

equivalent 81:3

100:21 106:10

ERVs 76:5,10

especially 97:15

essential 123:12

establish 72:4

80:16

established 18:12

28:13 79:5

establishing 106:6

estimated 18:2

estimating 20:16

et 67:20 76:11

85:19 92:5

104:1,2 130:11

evaporate 69:13

evaporative

117:10

evaporator 21:6

65:4 86:15

118:11,12,17,21

119:7

evaporator/

condenser 96:10

evaporators 52:5

eventually 102:21

121:14 129:4

everybody 23:15

29:22 65:7 73:19

74:1 82:21 84:5

87:18 89:3 94:17

101:15 102:4,10

119:8 132:1

138:17 141:2

everybody's 46:14

91:19 111:18

everyone 28:4

60:21 79:18 90:4

119:3

everyone's 27:9

everything 16:18

30:20 40:9 44:15

46:3 51:6,9

55:16 64:11

73:20 80:10

96:17,19 98:6

104:1 106:6

129:15 138:7

evolved 60:15 61:1

exact 67:8,9,10

exactly 5:4 40:10

48:6 69:17 78:6

102:21 134:20

135:1

example 13:19

38:15 56:12 60:9

112:12

exceed 40:20

excellent 39:1

except 27:22 131:8

exception 64:4

127:18

exceptionally 75:6

excess 74:18

excessive 64:14

excited 100:16

exclude 69:2

exclusive 119:21

exemption 26:11

48:9 53:22 62:17

80:19,21

exercise 111:8

exist 47:19 50:3

existing 51:16

exists 17:17

expensive 48:2

106:17

expert 107:3

explain 88:13

extends 79:19

extensive 11:19

exterior 125:5

external 32:2,3

41:1 112:4

113:13 121:3,10

122:14,18

123:5,9 126:19

externally 127:7

extra 21:3 124:19

F

facilitator 2:2 85:3

facility 63:5

facing 41:2

fact 9:14 18:11

51:5 52:2 64:11

71:16 78:18

127:12

factor 127:12

factories 60:19

factors 85:13 97:9

factory 60:22

factory-installed

49:19 70:19

fail 77:14,20 78:13

failure 77:16

fair 16:4 29:20

82:11 83:22

89:19

fairly 11:19 37:22

fairness 126:7

fall 77:21 104:13

falling 104:16

familiar 56:13

family 21:21

fan 26:5 33:3,7

83:21 84:1 112:6

113:13

114:13,15,17,18

133:21

fans 114:19

fare 73:17

feasible 108:3

feature 103:13

118:3,4 119:2,3

121:17

features 47:4

128:19 129:2

federal 1:6 2:4

18:11 27:4 79:3

135:8,13,21

141:7

feedback 38:5

feel 29:20 56:21

87:8 130:11

feet 114:22

FEG 114:15,18,19

felt 20:19 122:3

field 11:15,16

12:10 19:18,22
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36:17 37:15

49:15 50:11

57:11 60:20

68:2,4 107:21

126:19

field-installed

49:17,20 50:2,19

70:14

fight 100:22

figured 59:7 62:2

120:9

figures 118:6

figuring 84:6

file 130:5

filter 9:6,10,16,22

11:6,8,19 13:21

14:1,8

15:5,12,19

16:4,9 18:13

19:8,9,11,15

20:5,6,8,14,15,1

7 21:9,10,11,12

22:2,3,11,16

23:6,8

24:6,17,18

25:5,6,7,10,17

29:2,12

34:3,4,5,10,13,1

4 62:21

filters 8:11 9:14

10:3,6,15,16

11:13 12:9,13

13:4 16:10

19:7,17 21:8

26:12 28:11 30:8

31:5 33:2,13

35:13

36:1,2,5,15

114:21

filtration 15:21

16:1 19:22

24:5,9 33:17,21

62:14 76:11

filtrations 16:4

fin 39:8,9,10

63:11,15 67:10

69:11 73:15

92:3,9

93:13,18,21

95:20,22 96:1

99:10,21 100:17

101:7,9

final 90:5 116:9

finally 19:3

financial 142:10

fine 11:6 24:21

60:11 78:22 81:9

105:21 111:12

131:3

finish 4:6

finishing 138:4

fins 87:2 93:14

99:4,8 100:7

fired 136:13 137:9

firm 51:4

first 4:8 10:9

39:22 79:5 97:14

132:3

fit 100:20 115:5

fits 70:21

five 12:2 40:17,22

41:11 46:4,5

77:21 84:14 87:7

103:21 104:1

110:6 111:8

128:8

five-year 29:7

38:13

fix 36:21 80:10

flavor 108:17

flight 141:3

float 140:18

flour 16:9

flow 4:4 63:14

Fly 2:16 11:22

92:15 100:6,9

110:14 114:12

118:2,15,17

119:6

focus 89:12

focusing 122:10

FOIA 130:3

131:18,20

food 126:18

footnote 88:10

forced 68:1

foregoing 142:4

forget 71:10

112:17

forgetting 102:17

forward 79:12

80:12 116:1

fraction 43:17,18

83:17

fractional 109:21

110:1

framework 88:17

Frank 3:7,13

65:18 71:1 82:19

83:15 94:21

96:21 97:17

101:5 107:2

112:11 113:7

115:10 136:5

Frankly 53:22

free 131:18,20

132:11

full 8:2

function 123:14

129:1

functionalities

6:22

furnaces 58:22

Furr 33:8

future 17:15 18:15

25:14 82:12

88:6,8 94:16

G

gallons 136:15,21

137:5

galvanic 100:19

game 78:22 79:1

games 78:15 82:8

gas 2:21 114:16

134:21 135:2

136:4,12 137:8

gas-fired 135:18

gee 18:22

general 82:22

89:15 115:17

120:13

generally 116:1

132:4

generated 114:9

generic 74:20 98:9

gentleman 90:22

112:13

Geoffrey 2:17

gets 62:19 67:11

72:8 106:4

122:14 124:14

getting 11:4 23:9

31:16 61:19 62:6

90:14 93:8

100:13 104:20

105:1 109:18
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119:21 121:12

122:4 131:20

132:7

given 28:16 30:3

44:9 77:3 112:13

gives 68:15 73:12

giving 26:14 115:9

glass-doored

127:13

gone 62:2 90:2

Goodman 3:14

9:19 10:12 17:20

25:12 26:16 44:2

56:17 85:9 93:9

goods 121:1

gosh 59:17

government 132:9

grab 26:21

grade 105:15

grades 105:9

114:14

grant 80:19

grasp 122:5

gray 121:8

great 36:16 37:2

greater 74:17

136:15

grocery 46:18

50:19 120:18

124:4

group 27:7 36:22

111:1

groups 48:13

guarantee 62:5

104:3

guess 13:18 20:18

22:5 23:3,10

24:19 26:10

53:6,19 56:4,18

62:9 64:2,17

82:9 85:10 89:14

99:4 122:10

130:14 132:13

guessing 11:7

guidance 12:20

25:20 27:6 35:4

45:13 80:22

87:17 128:11

guide 84:6 95:9

guys 20:13 45:15

52:14 58:19

79:18 120:13

129:8 132:8

134:18 135:3

H

hall 126:5

Halley 2:17

hand 71:15 97:15

handlers 33:5,6

35:11

hanging 121:20

126:18

happen 17:2 118:5

happens 48:17

56:6

happy 14:4 23:12

132:16

hard 76:22

harsh 72:5

Harvey 3:9 14:21

18:7,17 21:1

27:19 32:16

43:15 53:15

83:10 84:13

100:15

112:11,12 113:7

117:1 125:8

127:20 139:2

Harvey's 127:19

hash 129:14

haul 66:11

haven't 63:22

101:18 120:9

137:17 138:15

having 4:14 47:6

62:11 63:7 92:8

95:13 106:14

107:12 136:9

headers 39:8

67:10

hear 45:19 87:19

heard 21:2 38:6

43:16 45:17,19

53:8 98:1,4

102:11 127:15

139:4

hearing 23:18 25:8

27:20 122:16

heart 63:17

heat 4:5 6:3,7

44:19 71:22 84:1

91:20,21 100:4

118:9 134:18

heater 114:16

heaters

135:7,15,19

heating 4:16,17

140:12

hell 71:15

help 72:16 92:7

104:11 105:20

helpful 43:17 44:4

90:18

hereby 142:4

here's 77:10 86:5

113:3

hey 62:17 66:4

high 4:16 20:1

24:5,6 32:18

33:16,20 43:7

58:10 114:19,20

127:2

high-efficiency

19:6,10,17,19,21

20:5 21:8

24:10,11 25:6

27:17,18,21

29:2,12 30:8,13

36:15 62:14

76:11

high-end 118:5

higher 30:12,22

53:4 63:11 70:9

83:6 86:15 104:5

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107:8,18 109:19

110:22 114:17

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108:1,10

115:12,15,19

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131:8

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95:18 121:9

122:17,20

123:1,21 126:1,5

127:11 128:5,11

133:11,20 134:4
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honest 78:4

honestly 36:16

71:20

hooked 112:3

Hootman 2:20

21:13,19 22:3

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38:17,20,21

39:17,19

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103:18,21

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114:17

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109:22

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41:11

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106:21

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7:3

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65:3

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industry 25:15

46:14 51:12

52:10,18 56:20

57:14,19,21

66:13

69:11,19,20
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78:20 83:1,8

92:12 132:15

140:16

inexpensive 20:15

information 4:18

5:4,13,19

6:11,18 7:16 8:5

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61:12

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73:22 122:2
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129:22 135:5

Jill 2:20 21:13

38:21 67:4,6

91:16 93:14

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lab 34:12 44:12

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120:14 140:19

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107:16

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106:10 128:3

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128:18

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87:20 93:3

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121:11,16,18

122:5,11,14

124:10,11,13

125:11,17,21

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120:15,18,20

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104:13

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64:18,20 101:10

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135:17

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listings 127:15

Literally 21:14
Capital Reporting Company

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literature 47:13

little 26:13 32:20

35:10 83:6 94:6

96:9 100:22

103:12 114:13

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89:7

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73:22

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111:19

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36:21 37:1 88:18

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losses 44:19,20

lot 11:9 12:12,22

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M

magic 36:7 119:7

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12:10

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22:19 23:4 27:20

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128:1,4 134:1

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95:4

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66:9 70:11

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35:12,17,18

43:22 44:1 65:3

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Marshall 2:21

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Master 3:16

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91:6 97:12 98:11

102:18 105:18

109:20 117:22

126:20 127:9

131:15 132:8

133:6

McQuay 3:3
Capital Reporting Company

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mean 16:13,14

17:14 21:15

22:21 23:3 24:21

26:1,7

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6 28:1 30:19

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137:2

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88:21

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93:12,14 99:2

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10:20

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35:14

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120:5

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model's 56:5 107:7

Molvie 3:6

money 35:15

131:17 132:9,13

monitors

120:20,21

months 62:6

morning 24:1
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134:19

mostly 118:5

126:13

motor 29:3

103:11,18,21,22

104:12

105:14,18,22

106:8

107:3,4,6,7,11,1

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109:19

110:20,22

111:3,6,9,11

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113:14

115:13,16,18,19

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113:18

motor-only 104:17

motors 13:19 54:3

103:2,5 104:4,17

105:6,10

106:4,5,9 116:1

motor's 108:4

mounted 125:12

126:19 127:7

move 76:3 79:12

80:12

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multi 4:4

multiple 35:17

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mutually 119:21

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82:19 94:21

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107:2,17

108:6,9,13

112:11 115:10

myself 59:2

N

National 2:11

51:19 122:3

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68:17 73:20

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74:13,16

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60:12

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123:13

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46:16

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87:18 113:2
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period 25:21

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requirements 6:16

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