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 DEPARTMENT OF ENERGY

 APPLIANCE STANDARDS AND RULEMAKING

 FEDERAL ADVISORY COMMITTEE MEETING

 Department of Energy

 1000 Independence Avenue, S.W.

 Forrestal Building

 Washington, D.C.

 Wednesday, July 31, 2013

 10:09 a.m.

Reported by: Linda D. Metcalf,

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

2 FACILITATOR:

3 Neil Eisner, Navigant Consulting

4

5 PARTICIPANTS:

6 Karim Amrane, Air-Conditioning, Heating, and

7 Refrigeration Institute (AHRI)

8 Ashley Armstrong, U.S. Department of Energy

9 Timothy Ballo, EarthJustice

10 Laura Barhydt, U.S. Department of Energy

11 Jeff Bauman, National Refrigeration & Air-Conditioning

12 John Cymbalsky, U.S. Department of Energy

13 Mary Dane, Traulsen

14 Paul L. Doppel, Mitsubishi Electric US, Inc.

15 Mark Fly, AAON Heating & Cooling Products

16 Geoffrey M. Halley, Sji Consultants, Inc.

17 Charles Hon, True Manufacturing

18 Jill Hootman, Trane

19 Marshall Hunt, Pacific Gas and Electric Company

20 John Hurst, Hex Technologies, Inc.

21 Diane Jakobs, Rheem Manufacturing Co.

22 Tom Johnson, Daikin McQuay
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1 PARTICIPANTS:

2 Jeff Kleiss, Lochinvar

3 Michael Kojak, Underwriters Laboratories LLC

4 Aris Marantan, Ph.D., U.S. Department of Energy

5 Mark Menzer, Intertek

6 Karen Meyers, Rheem Manufacturing Co.

7 Frank Myers, PVI Industries, Inc.

8 Michael Rivest, Navigant Consulting

9 Harvey Sachs, American Council for an Energy-Efficient

10 Economy

11 Ronald Shebik, Hussmann Corporation

12 Frank Stanonik, Air-Conditioning, Heating, and

13 Refrigeration Institute (AHRI)

14 Louis Starr, Northwest Energy Efficiency Alliance

15 Phillip Stephens, Heat Transfer Products

16 Rusty Tharp, Goodman Manufacturing

17 Collin Weber, Navigant Consulting

18 Robert J. Whitwell, Carrier Corporation

19

20

21

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

2 MR. EISNER: I have been asked to go over the

3 schedule because there is still some confusion about

4 the dates that are on the SharePoint site. According

5 to my notes, we are meeting today, which is 7/31, and

6 tomorrow, 8/01. The next meeting is next week, the 7th

7 and 8th. We have another meeting scheduled the 26th and

8 27th of August. And I think we put a meeting on for

9 the end of September, just in case we needed to meet at

10 that time. But right now, everybody I think believes

11 we're on schedule.

12 I don't know if I still have the September

13 date. I remember at the very first meeting, we put on a

14 date in September, September 26th, a one-day meeting

15 according to my notes. Are there any questions about

16 the schedule? And they're all in this room. Aren't

17 they, John? Yes.

18 All right. Does everybody have these new

19 slides?

20 MS. ARMSTRONG: Yes. I'm getting ready to

21 load them. Do you want to go around and do

22 introductions while I get them loaded up there, for the
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1 Reporter?

2 MR. EISNER: Oh. Yes. Let's go around the

3 room, then, for the new court reporter. And then they

4 are loading up a copy of the new slides that they just

5 put up.

6 My name is Neil Eisner. I am the

7 facilitator.

8 MR. BAUMAN: Jeff Bauman, National

9 Refrigeration.

10 MR. STARR: Louis Starr, Northwest Energy

11 Efficiency Alliance.

12 MR. HON: Charlie Hon, True Manufacturing.

13 MR. HALLEY: Geoff Halley, ABMA.

14 MR. KLEISS: Jeff Kleiss, Lochinvar.

15 MS. MEYERS: Karen Meyers, Rheem.

16 MR. SACHS: Harvey Sachs, ACEEE.

17 MR. BALLO: Tim Ballo, EarthJustice.

18 MR. HURST: John Hurst, Lennox International.

19 MR. KOJAK: Mike Kojak, UL.

20 MS. DANE: Mary Dane, Traulsen.

21 MR. DOPPEL: Paul Doppel, Mitsubishi

22 Electric.
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1 MR. THARP: Rusty Tharp, Goodman.

2 MR. WHITWELL: Bob Whitwell, Carrier.

3 MR. STEPHENS: Phillip Stephens, HTP.

4 MR. AMRANE: Karim Amrane, AHRI.

5 MS. BARHYDT: Laura Barhydt, DOE.

6 MR. CYMBALSKY: John Cymbalsky, DOE.

7 MR. MARANTAN: Aris Marantan, Navigant.

8 MR. WEBER: Collin Weber, Navigant.

9 MR. JOHNSON: Tom Johnson, Daikin McQuay.

10 MR. FLY: Mark Fly, AAON.

11 MR. MENZER: Mark Menzer, Intertek.

12 MS. JAKOBS: Diane Jakobs, Rheem.

13 MR. MYERS: Frank Myers, PVI Industries.

14 MR. EISNER: Okay. Everybody, if you've got

15 your name tags, turn them -- or name cards, turn them

16 at an angle, so the court reporter can see them. It

17 would help her.

18 Okay. Ashley, they're up? Are they up or --

19 MS. BARHYDT: Okay. The slides are coming

20 up. I think -- does everybody at the table have a copy?

21 Actually, and I can share. I can pass mine over to

22 Ron.
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1 So today, we are going to wrap up basic

2 model, vote on the last remaining issues there, we are

3 going to hopefully vote on certification, wrap that up,

4 and actually our goal is to hopefully get that done all

5 by lunchtime, and then we will move on to verification.

6 MR. AMRANE: If I may -- Karim Amrane, AHRI.

7 Are we going to be talking about the effective date,

8 the December 31st effective date, at some point?

9 MS. ARMSTRONG: So we can talk about that as

10 part of the certification.

11 MS. BARHYDT: Okay. So one of the -- you can

12 go to the next side. So we had already talked a lot

13 about DOE issuing guidance regarding various different

14 characteristics, and so we put in a slide in here that

15 talks about if DOE issues guidance that would exclude

16 some of the features that we have discussed previously.

17 The model has to be identical, with respect to all of

18 the other features, for us to not select the unit -- a

19 model that has that feature.

20 And so I think everybody was clear on this,

21 but we wanted to make sure that there weren't any

22 questions, and then go ahead and vote on this.
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1 MS. MEYERS: Laura, this is Karen with Rheem.

2 I just want clarification on "must be available for

3 testing at all times." What exactly is meant by that?

4 Are you saying this model must be in stock?

5 MS. BARHYDT: No. Just that it has to be

6 available in your lineup, your offerings.

7 MS. MEYERS: Okay. Thank you.

8 MR. EISNER: Any questions? Comments?

9 Anybody have any objections to this? Any abstentions?

10 MR. DOPPEL: Paul Doppel with Mitsubishi.

11 Could we maybe clean that up a little bit to make sure

12 that it's -- because I think it almost looks like it

13 means you have to have it standing ready.

14 MR. EISNER: So would the language Laura just

15 gave work?

16 MR. DOPPEL: Yeah.

17 MR. EISNER: "Available in your" --

18 MR. DOPPEL: "Available in the" --

19 MR. HUNT: Yeah. And give an extra hundred

20 for me for being a nice --

21 MS. BARHYDT: When you're on the phone,

22 please state your name before your speak, so that the
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1 reporter knows who you are. And whoever made the last

2 comment, if you could actually say that again, I didn't

3 catch it. No? Okay.

4 Does that --

5 MR. EISNER: Is that fine, Paul?

6 Okay. With that change, does anybody object?

7 Anybody abstain?

8 MR. HALLEY: Geoff Halley with ABMA. When

9 you say "in your product line for testing at all

10 times," can we just sort of clarify that a little bit?

11 You mean it's available, but on order. You may have to

12 order it. Okay.

13 MS. MEYERS: Yeah, if we could clarify that

14 because for a manufacturer in production, you know,

15 that's a little unclear. That's why I think you're

16 getting all the questions. So --

17 MS. ARMSTRONG: Basically, you need to offer

18 it for sale, not only to DOE for testing, but it must

19 be available for sale, whether it be for DOE to

20 purchase for testing, whether it be for a customer to

21 purchase for installation. You may have to build it to

22 order if we request it, but --
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1 MR. EISNER: If we put "for sale" in there,

2 would everybody be happy with that?

3 MS. ARMSTRONG: Yeah, that's all right.

4 MR. EISNER: Any objections to this new

5 language? Any abstentions? Okay.

6 MS. MEYERS: Wait just a minute. You're

7 going too fast. I think I'm okay.

8 MR. EISNER: Everybody is okay? No

9 abstentions? All right.

10 Next issue?

11 MR. STARR: This is Louis Starr. Last

12 question on the other one, maybe it's straightforward,

13 but if you have custom models, how does that work? Do

14 you have -- do you do nothing but make custom units?

15 Would that still -- does that still make sense, do you

16 think?

17 MS. ARMSTRONG: Yeah. So, I mean, this -- so

18 to the extent that the optional features that we are

19 issuing enforcement guidance, for them to apply this

20 underlying theme has to be met first. So in order for

21 one of those -- in order for us not to test a unit with

22 one of those optional features, you have to have a unit
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1 with a base feature in your product line for sale at

2 all times. Period.

3 If you do not have one of those, then we are

4 automatically able to test one of the ones with

5 optional features. So that's how this works. So if

6 you only make units with an optional feature -- for

7 example, if you only make HVAC units with VFDs, for

8 example, you don't make anything else, period, we could

9 test one of those.

10 But if you have a base unit without one and

11 it's in your product offering, available for sale at

12 all times, regardless of whether it needs to be built

13 to order, or whether it's in stock or at a distributor,

14 or whatever, then the Department could select the one

15 with the base feature. Would select. Not could,

16 would.

17 MR. WHITWELL: This is Bob Whitwell from

18 Carrier. Just a clarification question. So reading

19 through the positions on the various options, some are

20 described -- the position is that test procedure

21 guidance will be issued, some say enforcement guidance

22 will be issued, and some just say guidance will be
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1 issued. Can you clarify what those different terms

2 mean, or are they all the same?

3 MS. BARHYDT: No, they're not the same. So

4 test procedure guidance -- and we'll go back through

5 and doublecheck all of these, but the ones that say

6 "test procedure guidance" shouldn't say that we won't

7 test something. It just says that we will clarify the

8 test procedure to address whatever the concern was.

9 MS. ARMSTRONG: So an example of that is

10 there is one with about -- that has to do with dampers,

11 right? And it doesn't mean that we won't select a unit

12 with dampers to test; it means that I think what we

13 agreed to is we would fully seal everything before

14 testing. So we could still select that unit, but those

15 dampers would need to be sealed in order to test it.

16 That's the difference. It's the difference between not

17 picking a unit with that feature versus picking a unit

18 for testing but accommodating that feature through, you

19 know, how it's tested.

20 MR. WHITWELL: So then "enforcement guidance"

21 means that those will not be selected.

22 MS. ARMSTRONG: Uh-huh.
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1 MR. WHITWELL: And then there were a few that

2 just said "guidance." Is that --

3 MS. BARHYDT: I'm guessing here, but I think

4 those were ones where we were actually going to have to

5 look at the test procedure and figure out exactly what

6 we could do. We are going to work on addressing the

7 issue. It is just a matter of we are trying to figure

8 out exactly what the best mechanism to do that is.

9 Okay?

10 MR. WHITWELL: Thank you.

11 MS. BARHYDT: Okay. So one of the last

12 remaining issues for basic model was the high static

13 indoor blowers, oversized motors. We had talked

14 previously about issuing enforcement guidance

15 indicating that units will be tested with the base

16 motor, and all motors used within the model grouping

17 would have to have the same relative efficiency

18 performance as the motor included in the base unit.

19 We have got a lot of slides here that kind of

20 walk through how that would work because I know people

21 had a lot of questions about it. So I am actually

22 going to let somebody else go through the slides.
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1 MR. RIVEST: You'll notice a slight

2 difference - - I'm Mike Rivest from Navigant

3 Consulting. You'll notice a slight difference in this

4 description than in the previous description. So let

5 me start by saying the overarching goal here is that

6 when a product is certified with a certain motor, and

7 that certification is extended to a grouping, that the

8 efficiency of the motor -- of all motors in that

9 grouping should be "equivalent" to that of the motor

10 that was used to certify.

11 So the situation that we are trying to avoid

12 is that an extremely efficient motor could be used to

13 achieve a certification rating, and then a far less

14 efficient motor could be used in products in that

15 grouping. And since products in that grouping are --

16 when we are talking about higher static, for example,

17 wouldn't be tested, then the only way of verifying that

18 the motor is in fact equivalent would be to validate

19 the efficiency of that motor.

20 It came to light in conversations that not --

21 motors that are installed within your equipment is not

22 regulated. So previously, this description had been
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1 that if a motor was more efficient than the minimum

2 standard for the base unit, it should also be

3 equivalently more efficient for units in the grouping.

4 But the truth is, since it's not regulated,

5 that motor in the base unit could be less efficient

6 than the minimum standard. In that case, the products

7 in the grouping should be no more or less efficient

8 than the ones in the base unit. So that's the change

9 here, having the parens and saying, "The motor of the

10 same, or better, relative performance shall exhibit the

11 same percentage lower or higher losses from those

12 specified for subtype 1, general purpose motors, under

13 the prevailing federal efficiency standard."

14 So the way to think about this table of

15 efficiencies is not that you are compelled to meet that

16 efficiency. It is simply a scaler, to be able to

17 relate the efficiency or the losses at one horsepower

18 rating to the losses at another.

19 MR. EISNER: Okay. Any questions? Any

20 comments?

21 MR. WHITWELL: So, Mike, if, for example,

22 someone is using an ECM motor, the same -- we would
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1 take the same approach here. If the ECM motor is the

2 base motor, then we would look at the subtype 1,

3 general purpose motor efficiency for that horsepower,

4 look at the relative efficiency, and then all other

5 motors must have the same or higher relative

6 efficiency, correct?

7 MR. RIVEST: That's correct. So the nuance

8 here is that an ECM motor doesn't have poles. So, you

9 know, but presumably if you have motors in that series

10 that do have poles, then you could use, you know, the

11 table that is relevant --

12 MR. WHITWELL: Right. Okay.

13 MR. RIVEST: -- for that; right?

14 MR. WHITWELL: Good. Thanks.

15 MR. FLY: Mark Fly with AAON. So what

16 efficiency are we using for the fractional horsepower

17 in the 48 and 56 frame-type motors? Because in the

18 NEMA tables you have, they all start at one. And for

19 most of the smaller equipment it is going to be less

20 than one.

21 MR. RIVEST: You know, the general answer is,

22 you know, this is not -- this is something we are
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1 discussing, right? So I think the idea, to be similar,

2 would be to use the current minimum federal standard

3 for small motors and scale off of that. Is that --

4 MR. FLY: That isn't in this document,

5 though, right?

6 MR. RIVEST: That isn't in that document,

7 but, you know, we can -- I can look at -- I don't know

8 if it's MG-1 from NEMA, but see where that table is.

9 MR. CYMBALSKY: So I think here we are just

10 looking at the concept --

11 MR. RIVEST: Yeah.

12 MR. CYMBALSKY: -- more than calling out 56

13 frame motors that, you know, aren't on this. But I

14 guess what we want you to think about is just the

15 concept. So you can apply this concept to any motor,

16 because you know what you did in the base, and

17 theoretically you'll know what you will do when you

18 swap out the motor.

19 MR. RIVEST: Right. So this is just a couple

20 of examples here. So example one is a situation where

21 the motor and the base unit that is being used to

22 certify has 10 percent fewer losses than the federal
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1 minimum for a motor of the same type, poles and

2 enclosed/non-enclosed. Then all of the models in that

3 grouping should have, you know, at least 10 percent

4 better in terms of losses than the motor in the base

5 unit.

6 Example two, which is, you know, the

7 realization that these motors aren't regulated, it is

8 just, you know, the example where the base motor is

9 less efficient than the minimum standard, well, we just

10 want to make sure that the motor in the rest of the

11 product grouping is no worse than the one in the base.

12 So if it's five percent less efficient than the minimum

13 standard, then the ones in the grouping should be no

14 worse than five percent more in terms of losses.

15 And the losses are determined by this

16 equation here, basically losses are 740 times

17 horsepower, and that's the output power, and one minus

18 efficiency over efficiency. So you would -- you know,

19 if you want to calculate this out, this is the equation

20 you use.

21 Now, I have prepared a table, a conversion

22 table, and a spreadsheet that allows you to quickly,
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1 you know, look at what the equivalents are.

2 MS. JAKOBS: I have a question. This is

3 Diane Jakobs from Rheem. And last time Frank brought

4 up that, so what if in the higher horsepower motors

5 there is not the range of efficiencies available? And

6 Frank suggested that it say the "highest efficiency

7 available," all of this or whatever is available.

8 And I was thinking about how I would do it.

9 It is almost like you would have to plan out all of the

10 motors that would be available for a particular basic

11 model and choose your basic model motor based on what

12 was available for the very large ones where you have

13 limited choices.

14 And I don't think that that's how things are

15 set up now, and I could see an issue that for Rheem our

16 actual highest volume one is the basic model. And it

17 would have the highest volume, so you would be choosing

18 something that maybe was less efficient because -- so

19 you would have the option of having a two horsepower, a

20 three horsepower, or whatever we are talking about,

21 motor in the future, you know.

22 It is kind of like maybe if you were starting
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1 from the beginning, you could set this all up so it

2 would work. But if you are looking at what is

3 available now, and what we are building now, I don't

4 see -- I'm having trouble visualizing how it will work

5 out. I mean, your example is clear, but, really, what

6 is in our lineup now? And how would we have to redesign

7 something to meet this framework? Did that make sense?

8 MR. RIVEST: Well, so this is talking about

9 the goal. It is not talking about the present state.

10 If there are transition issues, those can be discussed.

11 The ultimate goal is that representations be as

12 accurate as possible. And if it's true that you don't

13 have the same range of availability of efficiency in

14 the larger motors, then, yeah, there are a couple of

15 solutions.

16 One is to make your rating on EER with a less

17 efficient motor in the baseline, and extend your

18 certification through the larger motors. Another one

19 is to break down the grouping, you know, where you have

20 product availability at one efficiency level and have,

21 you know, for larger motors maybe a separate

22 certification. So those are two options.
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1 You know, that is one way of complying in the

2 -- you know, in the longer term. But I don't know what

3 the situation is today.

4 MR. FLY: This is Mark Fly at AAON. So as I

5 see it, just looking on what I would do to do this, say

6 I have a five horsepower unit, three-phased, that I'm

7 certifying under this program, and it takes a half8 horsepower motor at ARI conditions would be the

9 appropriate motor for the case. That would be my base

10 unit.

11 I might have to go get as a special for my

12 certification testing to determine my certification or

13 in my AEDM, however you want to look at it, a motor

14 that was much less efficient than what my standard

15 offering is, so that I can encompass the three

16 horsepower motor that I may want to offer in that

17 product, which I can't get to with what I normally

18 offer in that half-horsepower selection.

19 So that would mean if you picked one of my

20 standard five-ton units, it would always pass by a wide

21 margin because I certified it under a much lower

22 horsepower motor. But I would comply with your
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1 ratings. Is that kind of where you're going on this?

2 MR. RIVEST: I'm not sure I completely

3 followed. So your standard -- so when you certify your

4 five-ton unit --

5 MR. FLY: Right.

6 MR. RIVEST: -- you have to meet certain

7 static pressure requirements and air volume.

8 MR. FLY: Right. And I would want to do that

9 with a motor that was --

10 MR. RIVEST: Small.

11 MR. FLY: -- of low enough efficiency that I

12 could catch the proper offset all the way up the motor

13 line of everything that I had.

14 MR. RIVEST: No, no, no. Let's not talk

15 about the future. So let's say right now the way it

16 works is you have a five-ton unit that is being sent

17 for certification. You select a motor that meets --

18 that allows you to meet the test procedure conditions.

19 MR. FLY: Right.

20 MR. RIVEST: Right? And then you get an EER

21 value.

22 MR. FLY: Correct.
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1 MR. RIVEST: And then you extend that EER

2 value to the rooftops with motors that have far greater

3 horsepower, right?

4 MR. FLY: That's correct.

5 MR. RIVEST: Right. And if DOE were to just

6 buy a five-ton unit from your company, not know what

7 your certification motor is, and test it, the EER value

8 would certainly be lower because the motor is consuming

9 more energy. Correct?

10 MR. FLY: They would buy our standard five11 ton unit.

12 MR. RIVEST: Yes.

13 MR. FLY: With the half-horsepower motor,

14 which would be selected if you put in the ARI

15 conditions.

16 MR. RIVEST: NO. That's not what I said.

17 MR. FLY: Okay.

18 MR. RIVEST: What is your standard rooftop

19 offering motor?

20 MR. FLY: I don't have a standard rooftop

21 offering motor. Every unit is designed and built to

22 order. I have a standard product, but I have a range
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1 of motors available on that.

2 MR. RIVEST: All right. But the conditions

3 under which the test procedure is run require a static

4 pressure that is lower than most any condition that

5 occurs in the field. So in all likelihood the vast

6 majority of the motors that you sell are greater

7 horsepower than the ones in your certification unit.

8 MR. FLY: Correct.

9 MR. RIVEST: Okay. And if DOE were to buy

10 one of those units that -- you know, without specifying

11 the DOE test conditions, just randomly buy any one --

12 MR. FLY: Well, for my company you can't buy

13 a unit unless you specify the conditions. And that is

14 true of I think some class of the HVAC equipment. Even

15 though it's a standard product, that is one of the

16 requirements. It's like, what's the voltage and what's

17 the static pressure and CFM you want to run at?

18 MR. RIVEST: Okay. Fine. But the whole base

19 for this exercise is that we recognize that the -- you

20 know, there is a need for motors that have more

21 horsepower than the DOE test conditions. And you don't

22 want to be held to the EER rating if you install those
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1 motors. Right? That's why we are doing this.

2 MR. FLY: Right.

3 MR. RIVEST: Okay?

4 MR. FLY: Because you are going to be running

5 at off the motor -- I mean, you are going to be running

6 at a point on the fan curve that that fan is not very

7 efficient and for which it was never intended.

8 MR. RIVEST: Correct. And we understand

9 that. So all that DOE is asking is that with that

10 smaller motor that you do end up testing at that that

11 motor be representative of the motors that are actually

12 being installed, that you don't put an ECM in your test

13 unit and get a grade EER, and then in 99 percent of the

14 units you ship you send a definite purpose motor that

15 doesn't even meet --

16 MR. FLY: Right.

17 MR. RIVEST: -- the federal minimum.

18 MR. FLY: In that case, I would --

19 MR. RIVEST: That's the situation we are

20 trying to avoid.

21 MR. FLY: -- I would have to split into two

22 models if I wanted to offer the ECM and claim the ECM
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1 efficiency.

2 MR. RIVEST: Exactly.

3 MR. FLY: Okay.

4 MR. WHITWELL: Unless you have an induction

5 motor that has a higher relative efficiency than the

6 ECM motor.

7 MR. RIVEST: Yes.

8 MR. WHITWELL: Which could happen.

9 MR. RIVEST: Right. I mean, you could elect

10 to simply your certification to not certify with an ECM

11 in the baseline.

12 MR. WHITWELL: Or you could certify with an

13 ECM, and then your optional motors could have higher

14 relative efficiency.

15 MR. RIVEST: Yeah. If that's possible. I

16 don't know.

17 MR. WHITWELL: It's possible. It is possible

18 MR. RIVEST: Okay. Yeah. And that's

19 preferred by DOE, too. Right. So is that -- I mean,

20 is that understood?

21 MR. FLY: Okay. This is Mark Fly with AAON.

22 I'm going to make one more statement and just, you
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1 know, realizing of course as we go up in horsepower the

2 efficiency gets higher --

3 MR. RIVEST: Yes.

4 MR. FLY: -- typically, that's the physics of

5 the thing. And if I've got to have a five percent

6 better than minimum standard efficiency, or let's say

7 that we do an ECM motor, and because the efficiency at

8 that small fractional horsepower minimum efficiency is

9 relatively low, I could have a huge offset, which may

10 be extremely difficult to get that same offset if we

11 have a really high efficiency.

12 So is it a percentage of the offset? Or is

13 it -- if I'm five percent -- if I'm 20 percent above

14 minimum at half horsepower, do I have to be 20 percent

15 above minimum at max horsepower? In which case if it's

16 95 I can't be 115.

17 MR. RIVEST: So that's the example we will go

18 through.

19 MR. FLY: Okay.

20 MR. RIVEST: Yeah.

21 MR. MYERS: This is Frank Myers, PVI. When

22 we were talking about this before, I had suggested that
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1 one possible solution that is much more practical than

2 what you have proposed, albeit it not as -- in the

3 absolute statement of the efficiency, not as accurate,

4 and that was to say that whatever you select in larger

5 horsepower it has to be either the same efficiency as

6 the tested motor or the highest efficiency in that size

7 and class motor. Is that unacceptable to the

8 Department? Because it's the highest that you can get.

9 MS. ARMSTRONG: How do you determine that?

10 MS. HOOTMAN: This is Jill Hootman from

11 Trane. That doesn't always happen. They aren't

12 commercially available -- some of those cases that

13 you're talking about. And, yes, I have laryngitis.

14 MR. RIVEST: Sorry, Jill. Can you repeat? I

15 didn't understand. This is Mike Rivest.

16 MS. HOOTMAN: Okay. So Frank was I think

17 talking about the case where you would take -- when you

18 get into the higher horsepower motors, there becomes an

19 availability, commercial availability issue. And so,

20 you know, if you have a 10 horsepower motor, and then

21 your high static now was a 15 horsepower motor, there

22 are not as many 15 horsepower available in all cases --
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1 48 frame, 56 frame, you know, four pole, six pole, et

2 cetera.

3 So to be able to have the same

4 characteristics, the same AEDM be used, the same fan

5 losses, the same fan curve, et cetera, you are going to

6 -- there might be cases -- I think we found a couple --

7 where we would have some issues, and that there isn't a

8 motor that is of higher efficiency available.

9 Now, I think that your equation here may

10 work. I just haven't applied it.

11 MR. RIVEST: Right.

12 MS. HOOTMAN: But not the simplified way that

13 Frank was describing.

14 MR. RIVEST: Right. So I don't have that

15 data. What I can tell you is this equation is set up as

16 reduction in losses, not increase in percentage

17 efficiency. So as you go up in horsepower --

18 MS. HOOTMAN: That's right.

19 MR. RIVEST: -- the improvement in efficiency

20 gets smaller and smaller. And I know that the motor

21 manufacturers market their motors as bands of

22 equivalence or bands of improvement of losses. So if
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1 we -- they will try to have a full product line of 10

2 percent, 20 percent better than the minimum in terms of

3 losses.

4 Where I was anticipating problems was with

5 ECMs, because we're talking about a different

6 technology there. But, you know, maybe that's not --

7 maybe that's not a concern.

8 MR. MYERS: This is Frank Myers, PVI, again.

9 Is it DOE's intent, with regard to motors, that they

10 are not going to simply buy and not let the

11 manufacturer know and get whatever they get? Or

12 whenever you have a case where there is a motor

13 involved, you are going to inform the manufacturers, so

14 that they can prepare a special unit with lower

15 efficient motors?

16 MS. ARMSTRONG: Why would we do that?

17 MR. MYERS: Well, I thought that's what I

18 heard you describe before that was an option for

19 manufacturers.

20 MS. ARMSTRONG: So as part of the

21 certification that we discussed last week, their base

22 motor configuration has to be declared. So you would
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1 declare your base motor configuration, whatever it is,

2 whatever horsepower it is, whatever accommodation, that

3 is declared at the outset. And that's what we are

4 going to acknowledge as your base unit configuration

5 from there.

6 MR. MYERS: This is Frank again, Frank Myers,

7 PVI. So if you wanted to have a more efficient motor

8 on that product, but you needed to cover the larger

9 motors, then you would have to put a less efficient

10 motor on there instead?

11 MR. RIVEST: Absolutely not. You would

12 certify two groups.

13 MS. MEYERS: So this is Karen with Rheem. I

14 think I'm okay with this. My concern comes that it is

15 kind of a quasi-regulation of motors not covered by

16 federal standards, and I'm just concerned that it seems

17 to be on the kind of edge of the law. I mean, I think

18 it works, but it is almost like we're trying to

19 regulate motors that are not covered by federal

20 standards.

21 MR. RIVEST: Karen -- Mike Rivest -- the way

22 I see this, it is simply -- you know how in the basic
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1 model definition there are words like "same or

2 equivalent," same or equivalent heat exchanger, same or

3 equivalent this. So this is just "same or equivalent

4 motor." It is not -- it is actually not forcing you to

5 use any specific level. If you saw the rewriting of

6 that, it actually explicitly says you can use a motor

7 less efficient than the federal minimum. But it's just

8 defining what "same or equivalent motor" means in the

9 context of grouping all of these units.

10 MS. ARMSTRONG: Yeah. And just to follow on,

11 I think what it also is -- it is same or equivalent to

12 give you the performance that you are demonstrating as

13 your base. So, in other words, what it is doing is

14 saying you have represented a certain level of

15 performance in your base unit, and what this is saying

16 is that, you know, by default the motors that you

17 switch out have to have the relative performance at the

18 conditions that are intended to be used at, on their

19 curves, as the one you are using in the base, which

20 would impact -- it is not regulating the motor

21 efficiency. It is allowing you flexibility to use the

22 different types of motors at the different conditions
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1 outside of the test procedure, to provide that unique

2 utility to the customer that they want, but providing

3 the same relative performance of your equipment.

4 MR. CYMBALSKY: This is John Cymbalsky from

5 DOE. I guess what we're trying -- when we first started

6 this, what the manufacturer said is that our base model

7 platform didn't include the motor. It included the

8 other components, and you routinely change out the

9 motor but don't change the basic model.

10 And what we're saying is, okay, fine, but DOE

11 recognizes that the motor does have a big impact on the

12 energy consumption. So how can we control for that

13 without having to rejigger your whole idea of basic

14 model? So I think that is our goal here, and I think

15 this does that in a pretty -- what I would think a

16 simple way.

17 MR. FLY: Okay. This is Mark Fly again. So

18 I'm going to have an ECM offering in this five-ton

19 unit. I'm going to have something that has a lot more

20 static, say it takes a five-horsepower motor instead of

21 this half- horsepower motor that I've got as an ECM.

22 So I will list an ECM unit model with, you know,
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1 whatever -- my 17 SEER, if that's what it happens to

2 be. And then I will have another model with a much

3 lower SEER, so you cannot buy the 17 SEER above a

4 certain static level because it is going to limit out

5 on the motor that I can do with an ECM motor because of

6 product availability.

7 So I'm just thinking out loud here to make

8 sure that we're all kind of on the same page. You

9 know, so, yeah, I'll have a standard -- I'll have my

10 high efficiency unit, and I can have my standard

11 efficiency unit that you could buy. And if you want

12 two and a half inches or three inches static pressure

13 on that, instead of .2 inches, then you are going to

14 have to buy the standard because I can't get to the

15 high efficiency at that static level.

16 MR. WHITWELL: Bob Whitwell from Carrier.

17 What you just described is my understanding as well.

18 Right.

19 MR. CYMBALSKY: And I think that's the whole

20 point here is that --

21 MS. HOOTMAN: I would agree.

22 MR. CYMBALSKY: -- is that we don't want you
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1 to represent that model as a 17 when it's really a --

2 I'm making up numbers -- 14 or whatever. Okay.

3 MR. WHITWELL: Bob Whitwell.

4 MS. HOOTMAN: Because of technology. I was

5 going to say -- this is Jill from Trane -- because of

6 technology availability, you know, it is going to

7 increase our basic model count just by what you just

8 described, and -- you know, and that is going to be the

9 nature of it until ACMs can get up in the higher

10 horsepowers.

11 MR. WHITWELL: Right. This is Bob Whitwell

12 from Carrier. I have another question. So let's say

13 an example where a model uses a seven and a half, 10,

14 15 horsepower motor options. So the seven and a half

15 horsepower motor in this case is, let's say, two points

16 lower loss than the minimum -- the efficiency standard,

17 and the 10 and 15 are right at the efficiency.

18 So can the manufacturer in this case use an

19 AEDM and rate the base product with a seven and a half

20 horsepower motor correcting or adjusting the motor

21 watts based on the difference between that motor's

22 efficiency and the minimum efficiency? So represent
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1 the efficiency at -- with a seven and a half horsepower

2 motor, based on an adjustment of the fan power to bring

3 it down to what it would be with a federal minimum.

4 That way they don't have to have separate basic models

5 for the 10 horsepower and the 15 horsepower motor.

6 MR. RIVEST: I guess the devil is in the

7 details of how you would disclose that and everything,

8 but it leaves the consumer whole.

9 MR. WHITWELL: Thank you. And one other

10 question. So on the smaller motors, say the 48, 56

11 frame, they are not regulated by DOE, so there is not a

12 minimum efficiency. How would that be checked to make

13 sure that -- you know, what the motor efficiency is for

14 the product that is being certified versus the product,

15 the other motor options?

16 MR. RIVEST: You're saying they're not? I

17 think they are regulated.

18 MS. MEYERS: That was my question. That was

19 kind of what my question was earlier.

20 MR. BALLO: This is Tim. Those standards

21 take effect in 2015. And I don't know if the NEMA

22 tables have been updated to reflect the federal
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1 standards, so that could be an issue with the tables

2 being different and maybe affecting which motors

3 wouldn't be included in a basic model once the standard

4 takes effect.

5 MR. RIVEST: So there are definitely NEMA

6 tables of efficiency for those products. They are just

7 not federal minimum requirements, but we could

8 reference those tables, understanding these are just

9 scalers. They're not --

10 MR. WHITWELL: No, I understand. And I

11 understand the approach. My question is more that the

12 manufacturer may be using a motor that is different

13 that may be more efficient than that. And let me see,

14 so for the motors that are regulated by DOE, I believe

15 that all of the efficiencies are labeled on the motors.

16 On the ones that are not, I'm not sure that

17 they are always put on the motor. So the question is:

18 how would DOE enforce this? Or what is the approach

19 that DOE has to enforce this?

20 MS. ARMSTRONG: I mean, so you're referencing

21 the name plates, right? I mean, that's what you're

22 talking about.
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1 MR. WHITWELL: Yes.

2 MS. ARMSTRONG: Yeah. So, you're right,

3 there's no name plate requirements yet for small

4 electric motors. There is a separate rule dealing with

5 such things. I think it is fair to say what we do

6 have, though, is testing procedures in place if we

7 needed to use them. They are already on the books for

8 small -- they were, you know, on the books for -- in

9 order for us to put standards in place. So if we

10 needed to get to that point, we could. Hopefully we

11 never get to that point.

12 MR. WHITWELL: Okay. So basically it's the -

13 - you're relying on the manufacturers to --

14 MS. ARMSTRONG: Right. It's on you guys,

15 right?

16 MR. WHITWELL: Yep. Okay.

17 MS. ARMSTRONG: The responsibility is on you

18 guys to make sure you make a compliant product, right?

19 MR. WHITWELL: Yep. Okay.

20 MR. MYERS: This is Frank Myers with PVI.

21 Since the current minimum requirements for these

22 products and the current ratings for these products
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1 were based on the test conditions, and those were

2 validated through numbers collected from the AHRI

3 certification program at test conditions, isn't this

4 new rule going to cause some piece of equipment that

5 today show one efficiency to show a lower efficiency,

6 and those that are on the borderline are no longer

7 going to be compliant?

8 So it seems like an elevation of the minimum

9 requirements that either begs for another class of

10 equipment, something other -- at a pressure units that

11 operate at --

12 MS. ARMSTRONG: Are you saying there are

13 products right now being made that don't meet the

14 standard?

15 MR. MYERS: No. I'm saying that there are

16 products that are made based --

17 MS. ARMSTRONG: That's what you're asking us

18 to acknowledge.

19 MR. MYERS: I'm sorry?

20 MS. ARMSTRONG: That's what you're asking us

21 to acknowledge.

22 MR. MYERS: What is your belief? Do you
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1 believe that that's the case?

2 MS. ARMSTRONG: I would hope not.

3 MR. MYERS: So you don't believe that the

4 submarine air conditioner would have a different

5 efficiency following this requirement than what it

6 would have otherwise? Since this was not part of the

7 AHRI certification program?

8 MS. ARMSTRONG: I don't know. I mean, I'll

9 let the manufacturers speak. It seems like most of

10 them understand this, and at least on the outside are

11 semi- comfortable with this position. Maybe not ready

12 to wholeheartedly embrace, but semi-comfortable with

13 where it is going. So --

14 MR. MYERS: Well, in that case, I'll ask the

15 manufacturers, are you comfortable that you can look at

16 all of the possible custom pieces of equipment that

17 your customers will ask for, understand exactly what

18 motor will be required for all of your different

19 variations, so that you can make that determination to

20 set up a new line of products that would de-rate down

21 to that minimum motor efficiency level at test

22 conditions. Is that -- are you agreeing that that's
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1 something that's practical and reasonable and your

2 model offerings will be acceptable in the marketplace

3 doing that?

4 MR. WHITWELL: Bob Whitwell from Carrier.

5 There is some new information that's up there today,

6 but based on my understanding of it today, yes, I think

7 we will be okay. We may need to make a few adjustments

8 to some motors in some cases, but I think we can

9 comply.

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

11 I think what DOE is proposing here is a workable

12 solution.

13 MR. EISNER: I'm sorry?

14 MR. AMRANE: It's a workable solution. I

15 think it's fine.

16 MR. EISNER: Okay.

17 MR. FLY: Mark Fly with AAON. I think it

18 would be extremely useful for those applying it,

19 though, to reproduce in the guidance or somewhere the

20 table of efficiency, so that we know exactly what

21 you're looking at, so that we are all looking at the

22 same thing.
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1 And I guess, you know, I brought up the

2 extreme case of the submarine coolers because that was

3 a former company. And there is some possibility that

4 at some level on some extreme cases that you will not

5 be able to offer that product. And we'll just have to

6 tell the Air Force they can't have it, or the Navy they

7 can't have it, so I don't know what to do.

8 MR. RIVEST: Excuse me. I would really like

9 to --

10 MR. FLY: But I haven't because I haven't

11 looked at it.

12 MR. RIVEST: I would really like to emphasize

13 here that this in no way limits product offerings. It

14 may limit the extent of grouping, but absolutely does

15 not limit what can be offered to the market.

16 MR. FLY: Unless it falls below minimum

17 standards.

18 MR. RIVEST: I will repeat: this in no way

19 limits product offerings to the market.

20 MS. MEYERS: This is Karen with Rheem, and I

21 would disagree with that a little bit, because it may

22 take some -- it may initially limit because there is
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1 going to have to be some analysis done and perhaps some

2 new products applied.

3 Like I said before, I think this is a

4 workable solution. I will be hesitant to vote on this

5 today until I truly go back and really understand the

6 impact on our product offering, if any. I mean, you

7 know, I think I'm okay with it, but -- and the other

8 key component of this is, you know, when this would be

9 effective, because we may have to change a lot of

10 groupings. I don't know that. But if we have to

11 change groupings and redo all of that, that takes a lot

12 of resources and time and testing and all of that kind

13 of stuff, to make sure that we have this -- that we can

14 do this.

15 And, again, I think we came up with a pretty

16 unique workable concept, but applying it is -- and the

17 time to do that is another issue.

18 MR. RIVEST: I understand your -- the time

19 element here. Yes.

20 MS. MEYERS: So, you know, if --

21 MR. RIVEST: So, in other words, if you were

22 to just today, you know, eliminate products that don't
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1 meet this rule, that would have an impact to your

2 company.

3 MS. MEYERS: It possibly --

4 MR. RIVEST: Given time --

5 MS. MEYERS: Yeah.

6 MR. RIVEST: -- there is nothing here that

7 prevents you from recertifying; right?

8 MS. MEYERS: Yeah.

9 MR. RIVEST: I understand what you're saying.

10 MS. JAKOBS: This is Diane from Rheem again.

11 I just want to expand on it. I think part of it, we

12 are all thinking about we keep the refrigeration

13 portion the same and change the motors in and out. And

14 our pricing and the way we do things are all based on

15 kind of this unit being designed, and then you are

16 applying different motors to it.

17 You're right, there is nothing to stop us

18 from designing this one-of-a-kind piece of equipment to

19 be really a one of a kind, but there would be a lot --

20 MR. RIVEST: I'm sorry. What one of a kind?

21 MS. JAKOBS: Well, just, you know, if it had

22 a high horsepower motor. And to get the efficiency up
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1 to the correct level, with that high horsepower motor,

2 it would require a redesign of the whole thing. And

3 that would affect the pricing, the amount of

4 engineering time. You know, it would really be an all

5 new thing from the ground up, a whole new design. And

6 that's just kind of not the way we are doing things.

7 So that would mean that product wouldn't be

8 available. You know, maybe it wouldn't be worth it for

9 the money. Maybe the people wouldn't want to buy it

10 for what they -- if they really paid for something

11 engineered from the ground up for their one-of-a-kind

12 application, it might not be economically feasible

13 anymore.

14 MR. RIVEST: So, of course, there are

15 business decisions that each company will have to make

16 about the level of aggregation of certification versus

17 the -- you know, versus redesigning certain products.

18 So you can always make your -- you could put a less

19 efficient motor in your certification unit, so that you

20 have, you know, motors that comply throughout your

21 product range of grouping, or you can cut out your

22 groupings in different ways. So you do, I understand,
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1 have to do some analysis and see what the impacts are

2 in your company. I understand that.

3 MS. JAKOBS: Yeah. And size constraints and,

4 you know, roof curves and all of it, yeah.

5 MR. RIVEST: But remember here, the starting

6 point is we are certifying an EER rating based on a

7 small motor that is often replaced by a much larger

8 motor for field conditions. And we are making

9 representations on the basis of the small motor.

10 So this is a small step into I think getting

11 more accurate consumer information, and it is certainly

12 not, you know, as large a step as could be taken, you

13 know. If you had to literally give an EER rating based

14 on the motors that are installed and shipped, that

15 would be a much bigger headache for you. You would

16 have to de- rate every product.

17 MS. JAKOBS: But the regulation was based on

18 the data in the ARI directory. So does that mean you

19 would have to redo your whole analysis? Because we --

20 it was based on certain assumptions.

21 MR. RIVEST: I was --

22 MS. ARMSTRONG: I think we are moving in the
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1 wrong direction here. We are going forward here.

2 MR. RIVEST: We are going forward. I think

3 the time element is something to think about.

4 MS. ARMSTRONG: Right.

5 MR. RIVEST: But this is the goal, where we

6 are trying to go.

7 MR. WHITWELL: Would it be possible to email

8 this out to us, so that we can share it with some folks

9 and --

10 MR. RIVEST: Sure.

11 MR. WHITWELL: -- get some feedback?

12 MR. RIVEST: Yep.

13 MR. WHITWELL: Okay.

14 MR. EISNER: I have a couple of questions.

15 There have been comments about whether the tables would

16 be available to them. I guess they're the ones that

17 are in here, the NEMA tables. Is there any reason

18 these can't be incorporated by reference or otherwise

19 made available?

20 MS. ARMSTRONG: Yes. We need to look at some

21 variations. But we can at least make what is on the

22 slides available immediately. And then to the extent
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1 we need additional information for other types or other

2 tables, we can look into that. Let us -- give us a

3 chance to do that, but --

4 MR. EISNER: And then, again, the question,

5 is it -- more than one question about timing of the

6 effectiveness of this. Are there possibilities you

7 could consider that could address their concerns?

8 MS. ARMSTRONG: Yes. So we are going to --

9 so right now there is no concept of -- well, the timing

10 for groupings is December 31st; right? That's what's

11 on our regs now. However, we have stated that to the

12 extent we can get through certification and negotiate

13 what gets submitted, we will then pick up the timing;

14 in other words, when the initial cert gets submitted to

15 the Department.

16 So I would say get through the next set of

17 slides. And if we can get through those with a

18 positive outcome, then we are going to talk about when

19 the initial cert -- which would be when the initial

20 groupings and all of the stuff would have to be

21 supplied.

22 MR. EISNER: Are there other questions?
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1 MR. WHITWELL: Bob Whitwell from Carrier.

2 Just since we're on -- the topic of timing has come up,

3 I believe in the current rule it says that it is -- the

4 timing is based on distribution. Is it possible that

5 timing could be based on manufacture date, something

6 for us to talk about as well?

7 MS. BARHYDT: Can I punt the question until

8 we actually talk about timing?

9 MR. WHITWELL: Right. I just wanted to pose

10 it, so that --

11 MS. BARHYDT: No. I --

12 MR. WHITWELL: -- it was part of the

13 discussion.

14 MS. BARHYDT: -- recognize that that's an

15 issue. But I think that that's going to be a whole

16 separate conversation.

17 MR. WHITWELL: I'm willing to hold on.

18 MS. BARHYDT: Okay.

19 MR. EISNER: Other questions or other

20 comments?

21 All right. So some people said they need

22 more time. What are we talking about in terms of more
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1 time?

2 MS. MEYERS: When can we get the slides?

3 MS. HOOTMAN: When can we get the slides?

4 Exactly.

5 MS. MEYERS: Yeah. I mean, it is going to

6 take my company probably at least a week to -- because,

7 you know, to dig into the details of this. So if we

8 could maybe vote on this at next week's meeting, I

9 think we could be ready for a vote. But they are going

10 to have to look at all of this, our lineup, and see

11 what the impact is. So if we could put off until next

12 week, that would be helpful.

13 MR. EISNER: Is a week going to be enough for

14 everyone? Is that okay with everyone? I mean, I would

15 like to walk out of this issue with some idea of

16 whether we're going in the right direction with

17 consensus, whether it -- I've heard a lot of positive

18 statements about it. Nobody has really been negative

19 on it, although some have concerns that they want to

20 address. So is anybody going to need more than a week?

21 All right. Well, then, let's look at these

22 slides again, if there are particular ones you want up
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1 on the screen, see if we can take a vote as to whether

2 somebody thinks that no matter what they are going to

3 object, or whether everybody right now feels that they

4 should -- they might be able to live with this or will

5 be able to live with this.

6 MR. HON: This is Charlie Hon. I have a

7 question for the group that is speaking right now.

8 Would they be ready for the next set of meetings?

9 Because that is next week.

10 MR. RIVEST: So I have number of additional

11 slides and a spreadsheet I would like to show.

12 MR. EISNER: On the same -- okay.

13 MR. RIVEST: Yes.

14 MR. EISNER: Let's go through that and then

15 get back to Charlie's question.

16 MR. RIVEST: I don't want to go step by step.

17 I just want to generally explain what this is. This

18 particular slide just gives an example of a base unit

19 being certified with a five horsepower motor that is

20 more efficient than the federal standard. And it goes

21 through the calculation of what would be the required

22 efficiency of a 10 horsepower motor, just steps you
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1 through an example.

2 Okay. And that -- the conclusion -- whose

3 got the controls? Okay. Can you go to the previous

4 slide? So the summary here was that a unit with a 10

5 horsepower motor that is certified with a basic model

6 having a five horsepower motor at 91.7 percent

7 efficient would be required to have a 10 horsepower

8 motor with a minimum efficiency of 93.5.

9 Slide 8, please.

10 This is just a very condensed -- not really

11 condensed, but a very limited subgroup of data that I

12 have on a spreadsheet that can be shared with you. It

13 just -- this is the table of efficiency requirements

14 coming out of I think it's NEMA 12.12. These are the

15 efficiency requirements for four pole, open frame,

16 general purpose motors.

17 The column on the left, you see the

18 horsepower rating, you see the efficiency requirements,

19 and then just calculated using the previous equations,

20 what the efficiencies are for a motor five percent

21 below, 10 percent below, five percent above, 10 percent

22 above.
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1 So the way you would use this is to look at

2 what your motor is. So let's say you have a five

3 horsepower motor. The minimum standard is 85.5, and it

4 turns out that your baseline motor is an 88.6. Then,

5 the column where the 88.6 is becomes your efficiency

6 table for that grouping.

7 The spreadsheet has this information, but it

8 goes from -- in increments of one percent efficiency

9 losses up to 30, up and down. So it would be used in

10 the same way.

11 So here let's say you have a 10 horsepower

12 motor. You might want to scroll completely to the left

13 there. So the minimum efficiency standard is a 91.7,

14 but that's not what you have in your baseline. Let's

15 say you have a definite purpose motor that is less

16 efficient than the minimum standard, so you would go

17 along that row, see where your motor is. Let's say

18 it's got 91.1. Okay? So that column where the 91.1 is

19 is your column of efficiencies for your grouping.

20 So that should be pretty easy to work. If

21 anyone wants to go through the math -- I hope they do.

22 I, you know, obviously checked, but that's how it could
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1 be workable. Now --

2 MS. MEYERS: And, Mike, can you just walk me

3 through one more time --

4 MR. RIVEST: Sure.

5 MS. MEYERS: -- for like less than one

6 horsepower motors how --

7 MR. RIVEST: So I could prepare a very

8 similar table.

9 MS. MEYERS: That would be very helpful.

10 MR. RIVEST: Yep.

11 MS. MEYERS: Thank you.

12 MS. ARMSTRONG: Jeremiah is going to send the

13 slides out momentarily, and then we could send the

14 Excel sheets out.

15 MS. MEYERS: And the spreadsheet, too?

16 MS. ARMSTRONG: Yes. We'll do that

17 subsequent.

18 MR. RIVEST: If you scroll down, does that go

19 beyond 200? Yeah. So I'm referencing a different

20 table for above 200. I don't know if anyone here uses

21 motors above 200 horsepower. I didn't think so. So I

22 could probably reference another table for the
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1 fractionals.

2 Notice this is for four pole open-type

3 motors. The reality is, it doesn't really matter

4 because it's a scaler. So we can make this simple by

5 just agreeing that this is the most common type of

6 motor. I don't know. What is the most common type of

7 motor used in your products? Is it four pole?

8 MR. THARP: For us, yes.

9 MR. RIVEST: Yeah. And it's probably open

10 type. So this would be the most common type of motor.

11 I mean, we can just agree to use this. If we -- if

12 some do use two pole, six pole, eight pole, and it's a

13 different table of efficiencies, they're not that

14 different. They probably don't scale much differently.

15 But, I mean, we could create these tables for other

16 types of motors.

17 MR. EISNER: And when do you think you'll

18 have the less than one available?

19 MR. RIVEST: I'll try to do it today.

20 MR. EISNER: Does that make everybody

21 comfortable with them being able to talk about this

22 next week? Are there any other questions?
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1 MR. THARP: This is Rusty Tharp with Goodman.

2 I'll say that the NEMA table that is referenced is

3 actually the same that's in 10 CFR 43125. I would

4 prefer to have the reference to the CFR as opposed to a

5 NEMA table.

6 MR. RIVEST: Yeah. I would, too, because I

7 like to sell those MG-1s.

8 MR. THARP: And on the fractional horsepower

9 motors, it was mentioned that there is a federal

10 regulation that has been issued but not yet

11 implemented.

12 MR. RIVEST: Right.

13 MR. THARP: And I would suggest just

14 referencing to what has been released. And do you

15 know, where is that at? Is that in 430?

16 MR. BALLO: It's in the CFR. It is just not

17 -- there is an effective date that is also listed in

18 the CFR that is in 2015, so -- but it's in the CFR.

19 MR. THARP: 429? 430?

20 MR. BALLO: 431, subpart X. I don't know.

21 MS. ARMSTRONG: Yeah. It's towards the end

22 of 431.
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1 MR. EISNER: Okay. Other comments? Other

2 questions?

3 All right. In terms of where we stand on

4 this, does anybody believe that they will still object

5 no matter what they learn over the next week? Is that

6 a yes?

7 MS. MEYERS: I think I'll have to wait to see

8 what the timing discussion -- how that turns out.

9 MR. EISNER: In terms of the effectiveness of

10 these. Okay. Are there others who have serious

11 concerns with this as it exists right now? Does

12 anybody object to my stating that as a general matter

13 everybody believes this is workable but they have to

14 look at the details? Nobody objects?

15 MS. MEYERS: This is Karen with Rheem. I

16 think it's workable. I don't know -- you know, the

17 timing is critical.

18 MR. EISNER: Effectiveness, yeah.

19 MR. MYERS: It's very critical.

20 MR. EISNER: Okay. And nobody abstains? All

21 right.

22 Okay. Why don't we take a 10-minute break?
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1 (Whereupon, a brief recess was taken.)

2 MR. EISNER: Does this bring us up to

3 Certification General? The next slide? Certification

4 Process.

5 MS. BARHYDT: So these slides probably look

6 pretty familiar. I don't think we need to go through

7 all of it again. But if anyone has any questions, we

8 can try again, but --

9 MR. EISNER: Slide 11, I guess.

10 MS. BARHYDT: Go on to 12, 13. Okay. So

11 ready to vote?

12 MR. EISNER: Okay. Any questions? We did go

13 over these last week. Any problems? Concerns? Tim?

14 MR. BALLO: This is Tim Ballo. I do have one

15 -- I mean, I am going to object to this, just on one

16 narrow ground, that I do think the manufacturer

17 identity should be public. You know, that's the only -

18 - that's the entire extent of my objection. So if that

19 wants to be -- if you want to note that. Other than

20 that, I have no problem.

21 MR. EISNER: Let me specifically note the

22 basis for the objection. I think that is valuable
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1 information. Any other comments? Questions?

2 MR. SACHS: This is Harvey. A procedural

3 question because I don't remember our ground rules.

4 How many objections would prevent it from passing?

5 MR. EISNER: More than two, as I recall.

6 MS. BARHYDT: More than three. Three.

7 MR. EISNER: Three.

8 MR. SACHS: Then I will probably join Tim in

9 feeling that information should be public.

10 MR. EISNER: Okay. You want, in other words,

11 the same basis? You want the same basis?

12 MS. HOOTMAN: Does the address have to be

13 public? This is Jill from Trane. Does the address

14 have to be public? Can the name only be public?

15 MR. BALLO: This is Tim. That would be fine

16 with me.

17 MR. WHITWELL: This is Bob Whitwell. What is

18 their reason for wanting to have that public?

19 MR. BALLO: It has never come up for

20 commercial equipment. But for residential equipment,

21 it has been an issue for my organization, trying to

22 identify the source of a problem, in meeting labeling
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1 requirements. If a product is not labeled correctly,

2 is it because the retailer has done something wrong or

3 because the manufacturer has done something wrong?

4 And when we see products that are from a

5 private labeler, if we can trace that back to the

6 manufacturer, it's easier for us to determine, well,

7 it's a problem at the factory, not a policy of the

8 particular private labeler not policing the labeling.

9 So it is mostly I'm objecting because at some

10 point in the future I may submit a Freedom of

11 Information Act request to find out the identity of a

12 manufacturer. So I would like to not have to do that.

13 Or, if I do submit the Freedom of Information Act

14 request, it may end up in court. And I can't take a

15 position here that would be accepting of manufacturer

16 name being withheld. So that's why I'm objecting.

17 MR. EISNER: Any other --

18 MR. HUNT: This is Marshall Hunt, PG&E. And

19 I join, making it a third.

20 MR. SACHS: This is Harvey Sachs, and I will

21 then drop my objection, so we have two objections and

22 this can go forward. But we have the record. Thank
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1 you.

2 Marshall, you get to object if I don't.

3 MR. EISNER: Let me ask whether it would

4 eliminate the need for objections if the agency put

5 something in the preamble asking for comment on the

6 issue.

7 MR. BALLO: This is Tim. That would be fine

8 with me, although, I mean, my position is pretty clear

9 on this. So I don't think that is going to change, but

10 --

11 MS. BARHYDT: Do the manufacturers object to

12 having manufacturer made public?

13 MR. WHITWELL: I would object to that.

14 MR. MYERS: Yes. This is Frank Myers, PVI

15 Industries. Yeah, that is objectionable.

16 MR. EISNER: May I ask why it's

17 objectionable? Are you comfortable with that?

18 MR. WHITWELL: In some cases, for some niche

19 products, we might choose to source a product from a

20 third -- from another manufacturer, and we would prefer

21 not to have that information publicly available. It

22 would be sold under our brand, so we would take
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1 responsibility for the equipment. But we would prefer

2 not to have public awareness of who is manufacturing

3 this product for us if in fact we are not manufacturing

4 it ourselves.

5 MR. EISNER: Frank, is that the same for you?

6 MR. MYERS: That's basically it.

7 MR. EISNER: Is there something here in terms

8 of manufacturer taking responsibility in some public

9 document that would address your concerns? If Carrier

10 said, "For all our products, whether we source them out

11 to a subcontractor or not, we hereby take full

12 responsibility" kind of a statement.

13 MR. WHITWELL: Let me edit that a little bit,

14 because we may in fact decide that we would not do the

15 certification for a product. It might be the

16 manufacturer that does the certification for us. But

17 if we are doing the certification, we would take

18 responsibility for that.

19 However, whether we are doing that or not, we

20 would stand behind the product from a warranty

21 perspective and, you know, product support perspective.

22 MR. EISNER: If the manufacturer, the
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1 subcontractor, does the certification, what does that

2 mean in terms of who is applying to DOE?

3 MR. WHITWELL: Well, that would mean, so the

4 manufacturer who is doing the certification, and the

5 private labeler name and address in this case, could be

6 us. Okay? So it would be our name up there as private

7 labeler but a different name for the manufacturer,

8 right? So I'd prefer in that case that our name be

9 shown, but not the manufacturer.

10 MR. EISNER: Does this help in any way, or

11 are you still going to object?

12 MR. HON: Question. How does that work as

13 far as if you're bringing product in from another

14 country? Isn't that a separate category?

15 MS. BARHYDT: So we do not currently have a

16 distinction in our regulations between an importer

17 manufacturer and an OEM builder manufacturer. But,

18 yeah, on the search sheet there is the distinction.

19 MR. MYERS: This is Frank Myers. Could you

20 describe for me the circumstance where the -- I think

21 it's the fourth line down, "Private labeler name and

22 address, public info, if applicable," could you give me
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1 an example or two of what you mean by that?

2 MS. BARHYDT: So a private labeler is, like

3 Bob was just saying, where they put the Carrier brand

4 on it, and there is someone else building the unit for

5 them. Carrier is the private labeler.

6 MR. MYERS: Okay. So if Carrier buys that

7 from Company XYZ, and it puts the Carrier brand on it,

8 Company XYZ has a responsibility to do this because

9 they're a manufacturer of --

10 MS. BARHYDT: Not necessarily. It depends.

11 MR. WHITWELL: There are options. It could

12 go either way, correct?

13 MS. BARHYDT: So the manufacturer has the

14 responsibility to submit the certification. If it's a

15 domestic manufacturer, then, yes, the domestic

16 manufacturer has the responsibility to make sure that

17 it is certified. In many cases, the private labeler,

18 Carrier, would submit the certification. The main

19 thing is that it has to be certified. But the

20 obligation is on the manufacturer. It just -- it

21 depends on whether it is domestic or foreign

22 manufacturer.
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1 MR. MYERS: Okay. This is Frank Myers, PVI,

2 again. If my company bought something from Company XYZ

3 and they were the manufacturer, and they, therefore --

4 in the U.S., and they, therefore, had responsibilities

5 for reporting to -- what many of us are attempting to

6 not have as public information is the linkage between

7 the two.

8 So if I'm buying XYZ, but it goes out of my

9 door in my catalogue as a PVI product, then I don't

10 want the documents in XYZ's report saying, "PVI is

11 buying this model." We are not wanting to expose to

12 the consumer the difference. The product is still

13 certified, it still has to be verified to the

14 Department, but the linkage, the marketing linkage, is

15 the difficulty.

16 MS. BARHYDT: So brand is required. So the

17 PVI would still be on the certification report. I can

18 tell you that we have manufacturers who submit a

19 certification for a variety of models with various

20 brands on it. And Tim can tell you that we have not

21 released the manufacturer's name, so that linkage has

22 been withheld in the past.
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1 MR. MYERS: How does the phrase "public info"

2 relate to that?

3 MS. BARHYDT: So the private labeler is

4 associated with the brand. So private labeler and

5 brand are public. It's the manufacturer that is not

6 public.

7 MALE SPEAKER: If there is a private labeler,

8 then it becomes public information.

9 MS. BARHYDT: It is just the OEM would be

10 submitting all of the information. So DOE knows who

11 the EOM is, but that's not something that we publish on

12 our website.

13 MS. ARMSTRONG: We wouldn't put it on our

14 website. Right.

15 MR. MYERS: Okay. What you've described, I

16 am still having difficulty reading that into public

17 info for public labeler. But if that's the practice,

18 if that's what the manufacturers want to continue to

19 have, it is not to hide the efficiency of the product

20 from the Department, it's -- the linkage is fine for

21 the Department to have. It's that it is not in the

22 public domain. So you are able to track everything.
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1 MR. STANONIK: Frank Stanonik, AHRI. I'm

2 understanding this that -- and it is probably easier to

3 talk about -- I'm going to use a residential example,

4 but I think the same principle applies in this case,

5 that -- and, excuse me, I'll use a common one.

6 Okay. Sears used to private label tons of

7 stuff, right? And so in this circumstance what would

8 show up, even though Sears wasn't making any of that,

9 what would show up in DOE's list is Sears as the

10 private labeler. So that would be the public

11 information, correct?

12 MS. BARHYDT: Yeah.

13 MR. STANONIK: And so if you --

14 MS. BARHYDT: Actually, it would say Kenmore,

15 but yes.

16 MR. STANONIK: Depends what you're buying.

17 But, so in a similar circumstance with a commercial

18 product, let's take a major distributor of commercial

19 equipment. Let's see -- like Nolan or something. Okay?

20 If Nolan was branding air conditioners, then, again,

21 they would be a private label, and that's what would

22 show up in DOE's lists. So I think that's what they're
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1 saying is if there is a private label, that is what is

2 presented to the public as these are Nolan models or

3 whatever.

4 And on the flip side, if it's simply a

5 Carrier product, well, then, the Carrier name would

6 show up on the list.

7 MR. HON: Question. Charlie Hon. Would this

8 -- because you have a manufacturer name and address,

9 private label name and address, are those separate

10 columns? I'm asking this because if you're a private

11 labeler, then, therefore, there would be a blank in the

12 manufacturing, which would trigger the view of this is

13 not being made by --

14 MS. BARHYDT: No. There is no -- so the way

15 it actually is presented on the screen, there is no

16 manufacturer column at all. So it's not like you would

17 see that there is a hole.

18 MR. HON: Okay. That's what I was wondering.

19 MS. BARHYDT: And we don't publish the

20 address online either.

21 MR. HON: Okay.

22 MR. EISNER: Other questions?
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1 MS. BARHYDT: Most people don't really want

2 the address.

3 MR. HON: A guy I used to work for, we would

4 specify -- we had a lot of contract manufacturing done

5 for us. We were the designer, the part specifier. The

6 manufacturer was nothing more than a -- collect all the

7 parts and put it together, who is then the

8 manufacturer.

9 MS. ARMSTRONG: Is it being done here or

10 overseas?

11 MR. HON: That's --

12 MS. ARMSTRONG: The answer is different.

13 That's why.

14 MR. HON: I know. That's why I'm asking

15 because we did both in the past. I'm just trying to

16 get it clarified in my head because --

17 MS. BARHYDT: So the ones that are made

18 abroad, that's the easiest one. It's the importer.

19 MR. HON: It's the importer. I know that --

20 MS. BARHYDT: The ones that are assembled

21 here, it would be the person who assembles it.

22 MS. ARMSTRONG: It would be the person who
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1 puts it all together and puts it in the box.

2 MR. HON: Thank you.

3 MR. EISNER: Okay. Any other questions?

4 MR. BALLO: I'm sorry to do this, but now

5 that we've hashed all of that out, I have to amend what

6 I said earlier, because I do object to one other piece

7 of this.

8 The U.S. Customs and Border Protection ID

9 number, I think that also needs to be public, and

10 here's why. If I am making a product offshore and

11 don't provide that number, it doesn't -- it is not

12 clear to me that Customs has all of the information it

13 needs to locate that product when it comes into a

14 shipment and know that it is not in DOE's database, or

15 know that it violates a standard.

16 If you have that information, then Customs

17 knows who to look for. So I'm not sure I'm making that

18 clear, but do you get what I'm saying, Laura?

19 MS. BARHYDT: I do. And --

20 Mr. BALLO: So without seeing that

21 information in the database, I don't know that a

22 manufacturer is providing that information to DOE and
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1 that the product can actually be stopped at port if

2 it's found to violate a standard. I obviously haven't

3 thought this through, but I do have a concern about

4 that.

5 MR. STANONIK: Frank Stanonik with AHRI.

6 Tim, I think -- I mean, I guess I can repeat this just

7 to make sure. I think the last thing you said is

8 something about that DOE wouldn't then know really

9 whether Customs had the information. All right? If

10 it's not public.

11 But my belief is that if in fact -- if this

12 was the requirement, the way it is right now, and in

13 fact you then saw that model listed in DOE's database,

14 it means they have the information. Because I'll just

15 tell you up to now our experience as operating AHRI's

16 programs and sending data to DOE is that they go

17 through those listings with a fairly fine-tooth comb.

18 And so I'm not saying it would be impossible,

19 but I think it would be very unlikely that a product

20 would end up being listed if that information was

21 required and it wasn't provided. So to me the

22 existence of it being listed in the database would say,
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1 "If it is imported, we have that number."

2 MR. BALLO: Would it, though? I mean, for a

3 small manufacturer that is not part of AHRI, would

4 people necessarily -- would DOE necessarily know when

5 they get a certification that doesn't include an

6 importer ID number that the manufacturer is not a

7 domestic manufacturer?

8 MS. BARHYDT: The form has a box where you

9 have to mark that you are either a domestic

10 manufacturer or an importer.

11 MR. BALLO: Okay. Well, that's helpful. So

12 if it's -- I mean, that's my concern, though, that I

13 can't see that DOE has all of the information that it

14 needs to provide to Customs to enforce at the border if

15 a product is found not to violate. So it puts me in

16 the position of trusting DOE to always be on the ball

17 enforcing that, and that's what I'm uncomfortable with.

18 I also wonder, just why is that sensitive

19 information? The importer ID number? I mean, I know

20 you have mentioned before that some people use their

21 Social Security number for --

22 MS. BARHYDT: Yes. So we are not going to
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1 make that public, obviously.

2 MR. EISNER: Okay. Any other questions?

3 Concerns?

4 MR. BAUMAN: This is Jeff Bauman from

5 National. Could I just make -- we seem to have the

6 issue between the manufacturer name and the private

7 labeler name. Would it make sense to have the box be

8 private labeler or manufacturer's name, if you don't

9 have -- or both?

10 MS. BARHYDT: We need both.

11 MR. BAUMAN: Well, but if you don't have the

12 private -- that that could be public, one of those two

13 names would be -- if it's not a private label product,

14 the manufacturer name would be public, I would think

15 that would satisfy some of the concerns about companies

16 that do private label.

17 It's not a private labeled product. Then,

18 the manufacturer name would appear on that column. If

19 it is private labeled, then the private label name

20 would appear there. So he would have somebody to go

21 back to, either the private label or the manufacturer

22 name.
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1 MR. CYMBALSKY: I think what he's saying is

2 when it is private labeled, he doesn't know who the

3 manufacturer is. And he doesn't know who is

4 responsible for the labeling that's not --

5 MS. ARMSTRONG: I mean, technically, if you

6 look at our database right now, I know commercial

7 products aren't on there. But if you look at the

8 columns, it's brand. Brand is what you see, model

9 number is what you see, and from there.

10 All of this other stuff you see about

11 manufacturer or private label, this is a list of

12 information we collect. But as we actually administer,

13 we have all of this stuff in our internal database.

14 It's just Tim can't see it. When he goes online, all

15 he sees is brand and model number and rating.

16 MR. BALLO: That said, it would be helpful to

17 have the private labeler, or manufacturer if there is

18 no private labeler. But it does not address the issue

19 of trying to identify the source of a labeling problem.

20 MR. EISNER: All right. Questions all done?

21 As I understand it, we have two objections on

22 one issue, one objection Tim has on another issue, the
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1 Customs ID number. Any other objections? Any

2 abstentions? Okay.

3 Commercial Warm Air Furnaces. Any questions

4 on this slide?

5 MS. ARMSTRONG: So I have a question for the

6 commercial -- where is he? There he is. Commercial

7 furnace manufacturers in the room. Is this -- and this

8 is just because I haven't had a chance to pull the test

9 procedure. But, Frank, you may be able to answer this

10 off the top of your head, too.

11 Is the configuration -- so is it -- like, in

12 other words, could you set up a commercial furnace's

13 up- flow, down-flow, et cetera, optionally? If so, my

14 opinion is that you should certify what configuration

15 you test it in.

16 MR. STANONIK: Frank Stanonik, AHRI. So I

17 guess -- let me make sure I'm understanding the

18 question. So does the test procedure --

19 MS. ARMSTRONG: Specify a configuration.

20 MR. STANONIK: -- specify a configuration?

21 MS. ARMSTRONG: I don't -- I know the

22 residential one does not, and I don't think --
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1 MR. STANONIK: Wow. I can't answer this one

2 off the top of my head, because I don't think there has

3 been a lot of discussion on the commercial side of the

4 business about configurations because you are simply

5 measuring thermal efficiency. So it really shouldn't -

6 - I'll be careful, but I don't think it should make a

7 difference.

8 MS. ARMSTRONG: I agree. And I've heard that

9 it shouldn't make a difference. But that being said,

10 if there is a difference -- Jill, do you want to --

11 MS. HOOTMAN: It only makes a difference for

12 -- this is Jill from Trane. It only makes a difference

13 if it has nothing to do with test procedure. Your up14 flow/down-flow makes a difference as far as where you

15 put heater safety overloads and how you would put those

16 overload mechanisms in order to cut off heat when you

17 have a problem. It has nothing to do with test --

18 MS. ARMSTRONG: So you don't care what output

19 or --

20 MS. HOOTMAN: -- with output thermal

21 efficiency.

22 MS. ARMSTRONG: -- test then, period.
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1 MS. HOOTMAN: Yes. Right.

2 MS. ARMSTRONG: Regardless of what you test

3 it in, you could care less how I test.

4 MR. STANONIK: I would say right now that's

5 correct. I mean, we'll obviously go back and

6 doublecheck, but I'm running through the test procedure

7 in my mind here, and I just don't see where it should

8 make a big difference. You are essentially setting it

9 up to, you know, get a steady-state, and then you are

10 just measuring flue losses. It --

11 MS. ARMSTRONG: I'm not necessarily

12 disagreeing with you. I'm sorry, Jill.

13 MS. HOOTMAN: But you have already bought a

14 unit, and, you know, you're talking about, you know, a

15 package unit. It's already bought in a configuration,

16 already -- you have already had it in a configuration.

17 You're not going to turn around and make a different

18 configuration for that unit. It is already either a

19 dedicated horizontal or a dedicated down-flow.

20 MS. ARMSTRONG: I agree. But I could buy

21 either one.

22 MS. HOOTMAN: Right.
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1 MR. STANONIK: Right.

2 MS. ARMSTRONG: Okay.

3 MR. EISNER: Other questions?

4 MS. ARMSTRONG: We're good.

5 MR. EISNER: Or concerns? Any objections?

6 Any abstentions? Okay.

7 Next issue is Commercial Package Boilers.

8 Any comments? Questions?

9 MR. STEPHENS: Phillip Stephens, HTP. The

10 question about the information becoming public is still

11 -- I know we are going to discuss the Freedom of

12 Information Act, but I was wondering, the optional

13 submission for additional testing instructions, if that

14 were managed by a third party group, the laboratory

15 itself, would that be sufficient?

16 MS. ARMSTRONG: I mean, at some point, even

17 if it was managed by the third party, I would get my

18 hands on it before I test it. And then it would so be

19 within DOE's realm of FOIA. It is not going to

20 alleviate your concerns.

21 MR. STEPHENS: My question is, why would the

22 Department need it instead of the test lab needing it?
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1 MS. ARMSTRONG: Because I need to tell the

2 test lab what to do. I am testing your product. You

3 are certifying that this is the information you want

4 the Department to use when testing. The same reason

5 the test lab can't just call you. Have some faith.

6 MR. EISNER: Other questions?

7 MR. HALLEY: Geoff Halley, ABMA. Does this

8 optional submission include the details of the testing

9 waiver, if one is applied for?

10 MS. ARMSTRONG: You don't even need that.

11 That will be public.

12 MR. HALLEY: Okay.

13 MS. ARMSTRONG: So if you had -- on the

14 beginning slide, if you've got -- if you've received a

15 waiver for the Department, you have to elect that

16 anyway. So you don't even -- that won't even need to be

17 submitted. That will already be figured out.

18 MR. HALLEY: Fine.

19 MS. ARMSTRONG: Yep.

20 MR. EISNER: Other questions?

21 Ready to vote? Any objections? Any

22 abstentions?
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1 Commercial Water Heaters. Take a look at the

2 slide. Any questions or objections?

3 MR. MYERS: This is Frank Myers, PVI. There

4 is one item in there that we had discussed before, and

5 that is the need to provide -- I can't read that. Let

6 me look on my copy here. The measured storage volume

7 in gallons for equipment that is larger than 140

8 gallons.

9 Notwithstanding the next slide, it says here

10 that we are supposed to submit -- so are we not going

11 to submit, for commercial electric storage water

12 heaters, the measured storage volume in gallons for

13 equipment that is larger than 140 gallons?

14 MS. ARMSTRONG: The answer is it is going to

15 --

16 MR. MYERS: Yeah. I'm looking at the

17 previous slide. And if I read that, it says yes.

18 MR. KLEISS: This is Jeff Kleiss, Lochinvar.

19 I'll make a suggestion that, in that case, could that

20 be another one of the yes/no's of just -- is the

21 storage volume over 140?

22 MS. ARMSTRONG: So I kind of remember the
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1 discussion last -- or two weeks ago. I thought we

2 agreed that just -- we would submit storage volume,

3 period. That that was a way that people -- you know,

4 measured aside, that's a different issue.

5 But I thought we agreed we would submit

6 storage volume. That's a characteristic. That's how

7 you sell your products. You have a rated storage

8 volume on there.

9 Regardless of whether you measure it or not,

10 that's how you identify them, et cetera, et cetera.

11 I thought I heard that that was a non-issue

12 last week.

13 MR. MYERS: I thought we were leaving the

14 measured storage volume off and maintaining those

15 things that were required to comply with the

16 performance requirements. And this is not one that is

17 required to comply with the --

18 MS. ARMSTRONG: Well, that's correct. So

19 that's addressed in the second slide. So this is going

20 to be for the ones that are subject to the standby loss

21 requirement. And we need to work out the wording, but

22 that's what that says.
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1 But the second one -- for the next slide, for

2 the 140-gallon issue, this has the yes/no's. But I

3 think we still agreed to have storage volume, rated

4 storage volume, right? And then, if no, if you don't

5 do -- you know, if you answer no to one of those, then

6 you do have to meet the standby loss requirement,

7 including the measured storage, because the measured is

8 part of the standby loss.

9 So it's just a matter of clearly articulating

10 that, but --

11 MR. MYERS: I'm not sure how that ties

12 together with the exact wording on the screen. Yeah,

13 the rated storage volume is required for products that

14 are 140 gallons or less.

15 MR. HUNT: Hi. This is Marshall Hunt. Is

16 the problem the rigidity of the test to get that

17 storage volume? It seems to me it's something that the

18 general consumer would want to know.

19 MS. ARMSTRONG: I need to work on the

20 language, but the idea here would be if you are -- if

21 you are subject to the storage -- the standby loss

22 standard, then you are submitting measured storage
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1 volume as well as standby loss. And then, if you are

2 opting, because you're 140 gallons or over, to meet

3 those three design requirements, you are doing three

4 design requirements and yes or no's, and the rated

5 storage volume. So whatever you are making

6 representations of for your rated.

7 If you opt to say no to one of those design

8 requirements, and you kick yourself back into the

9 standby loss bucket, then you are back to measured and

10 standby loss. So it's a matter of working out the ifs,

11 and, or buts, in the rule language. But that's the

12 requirements.

13 MR. MYERS: Yeah. I agree with the basic

14 statement that it should match what the requirements

15 are, but I think you said in there that even if it's

16 not needed to meet the requirements because you are

17 over 140 gallons, you want the rated volume anyway.

18 MS. ARMSTRONG: Correct.

19 MR. MYERS: And I still don't understand how

20 that is required by any legislation or current

21 regulation. That seems like something the Department

22 just wants because they want it, as opposed to it is
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1 needed.

2 MR. KLEISS: Jeff Kleiss, Lochinvar. To that

3 point, what is the rationale for not having -- for

4 changing that rated storage volume to rated volume

5 greater than 140 gallons, yes/no?

6 MS. ARMSTRONG: I mean, I think Marshall just

7 answered it. It is an attribute of the product that is

8 identifiable that the consumer wants to know about.

9 So, and right now in your literature, you have volumes,

10 what is the problem with putting it on our website?

11 MS. MEYERS: What is the Department going to

12 do with the information? I mean, we have it available

13 -- this is Karen Meyers with Rheem. We likely have it

14 available in our sales literature.

15 MS. ARMSTRONG: It is.

16 MS. MEYERS: But, again, it kind of goes back

17 to this discussion we had last week. If a manufacturer

18 elects not to put it in their sales literature, and

19 puts a number on there that happens to be false, then

20 what -- there is no course of action for the Department

21 to take, yet the person looking at this information,

22 because it's a government website, I mean, it kind of
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1 gives a whole new -- I mean, if you can't enforce

2 against it, then to me it shouldn't be on the website.

3 MS. ARMSTRONG: You have to declare a rated

4 storage volume period to figure out which bucket you're

5 in. It's like Jeff said. It's just a matter of

6 whether you say a number or whether you say yes or no.

7 You have to figure it out to figure out which bucket

8 you're in.

9 MS. MEYERS: Right. But you're asking for

10 the specific number.

11 MS. ARMSTRONG: And just a yes/no.

12 MR. CYMBALSKY: Right. So if I'm a consumer

13 and I'm using this public database to compare across

14 options for me to purchase, and I know I need 150

15 gallons, I would prefer to see the ones that are 150

16 gallons, not just all of the ones that are over 140.

17 MS. MEYERS: I wouldn't object to a yes/no,

18 but an exact number I would object to.

19 MR. STANONIK: Frank Stanonik with AHRI. I

20 mean, I think we are overthinking this one. If you can

21 go to the original slide, the first slide. Okay. So

22 if we just follow the sequence, okay, so I've got a
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1 commercial electric storage water heater. I need --

2 because of what the minimum -- what the maximum standby

3 loss is, I need to tell you -- admittedly, I need to

4 tell you what the storage volume is. Okay?

5 So if you start from there, I'm going to tell

6 you the storage volume is either 70 gallons or 168

7 gallons. Okay. If I tell you it's 168 gallons, you

8 know, I skip this, I go down to the 140. It's

9 established. Okay?

10 Now, let's look at the gas- and oil-fired

11 ones. I need -- again, because of the standby loss

12 requirement, I need to tell you in this case what the

13 rated storage volume is, so you know what the

14 requirement is.

15 The slight disconnect -- and I think

16 inconsequential disconnect -- is I am giving you rated

17 where that other statement actually is talking about

18 140 and that was -- it goes back to ASHRAE Standard 90.

19 They picked a number really which was like a DMZ kind

20 of thing. There is no products really that have 140.

21 Okay?

22 And so you can determine from the rated
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1 storage volume of the gas-fired products whether or not

2 it triggers this 140 requirement. In fact, the

3 manufacturer will give you that information if that is

4 how they are complying because in fact it becomes too

5 difficult to comply with the maximum standby loss

6 requirement. It's not worse.

7 So I don't think you really need -- it's all

8 there. I don't think you need to say anything else.

9 MS. ARMSTRONG: I agree. But I clarify it on

10 the second slide, just to make sure everybody is clear.

11 I mean, we are collecting that, period. I agree.

12 MR. STANONIK: Yeah.

13 MS. ARMSTRONG: And that was what we agreed

14 to last week.

15 MR. MYERS: This is Frank Myers. What test

16 program is required to determine the validity of a

17 stated rated storage volume above 140 gallons? If you

18 have a 5,000-gallon rating, is that plus or minus what?

19 Is there a test method for that? Does the Department

20 intend to place a test method on that? Since it is not

21 required for anything other than just general

22 information? That is my biggest concern. When you get
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1 into commercial equipment --

2 MS. ARMSTRONG: I mean, that's a test

3 procedure issue. And if we do decide to, we'd have to

4 go through a rule to change it. If we decide to set

5 any kind of procedure or tolerance around what your

6 ratings can be for volume, we would do that in the test

7 procedure rule. There is not one right now.

8 MR. MYERS: For equipment that has a standby

9 loss rating, there is a -- "rated" has a specific

10 meaning. Applying that to equipment above 140, because

11 the standard does not stipulate -- when you call it

12 "rated," it doesn't stipulate where the phrase "rating"

13 is no longer valid.

14 So if we are applying the rated for 140

15 gallons or smaller to equipment above 140 gallons, then

16 that is problematic in 200-gallon, 500-gallon, 5,000-

17 gallon tanks with -- in the commercial world, applying

18 something that was designed for 140 gallons is not

19 appropriate.

20 MS. MEYERS: This is Karen with Rheem.

21 Because of what Frank just said, we will object to this

22 language.
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1 MR. KLEISS: Jeff Kleiss, Lochinvar. I

2 believe there are three points on the second slide that

3 should not be required information as they are shown,

4 one being the rated volume, that that should be a

5 yes/no for the capacities or storage volumes over 140

6 gallons. Under commercial, unfired, hot water storage

7 tanks, the rated storage volume in gallons, there is no

8 efficiency metric that is tied to that unit of measure.

9 And on the commercial gas-fired instantaneous

10 water heaters, the rated storage volume less than 10

11 gallons should be a yes/no rather than an actual

12 volume, because there is no efficiency metric that is

13 tied to any of those. It is merely a qualification of

14 above or below. So a yes/no would be adequate to meet

15 the requirements of the federal --

16 MS. ARMSTRONG: Do you submit this to AHRI

17 now?

18 MR. KLEISS: There is --

19 MS. ARMSTRONG: The answer is yes.

20 MR. KLEISS: Yes. Yes.

21 MS. ARMSTRONG: What is the issue?

22 MR. KLEISS: That it is not required --
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1 MS. ARMSTRONG: I mean, why is it okay for

2 that one and not this one?

3 MR. KLEISS: Why is it required by the

4 Department of Energy? You could use that same question

5 to a number of additional points of information -- that

6 the Federal Government, the Department of Energy, does

7 not require for these standards. Do we report it

8 someplace else? should not be the threshold for

9 determining what information we provide to the

10 Department of Energy.

11 MR. STANONIK: Frank Stanonik, AHRI. I'm

12 going to interject here. Right now, in terms of where

13 our commercial water heater certification program is, I

14 have a serious question whether we are currently

15 listing any products over 140 gallons complying with

16 these criteria, because of the way our program is

17 structured, not that we couldn't or wouldn't, but our

18 program is basically for the moment structured around

19 products that fire at 5,000 btu's per hour or less.

20 I guess you could do that with a -- let's

21 say, a 150-gallon water heater. But my intuition says

22 that if I'm making a water heater with that much
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1 storage, generally I want to have lots of capacity,

2 lots of input. So I think on that particular point I

3 don't think we've - - in our programs that we've even

4 addressed that particular product very much yet.

5 MR. HUNT: This is Marshall Hunt, PG&E. And

6 we run efficiency programs and put a lot of money and

7 will be putting more money especially to get our

8 natural gas savings up. And it seems to me that this

9 information is very important to implement our other

10 efficiency program, and it seems so basic to me, I

11 don't know what the problem is. But we need it, and we

12 need to be able to have one place to go -- DOE -- where

13 we can plan products, we can plan programs, with

14 reliable data and complete data.

15 Thank you.

16 MR. KLEISS: Jeff Kleiss, Lochinvar.

17 Marshall, a question related to that. Can you help me

18 out to understand what it is that you need as far as

19 the volumes for determination of the energy efficiency?

20 MR. HUNT: Yes. Let's say, for example, that

21 we have a retrofit program that we are pushing, and we

22 have identified through our research at our food
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1 service technology lab, or at our lab in San Ramon,

2 that we really want to focus on this particular kind of

3 product, which is characterized in part by its volume.

4 We can't accurately know what models comply unless we

5 know that rated volume, along with other metrics such

6 as the efficiency and whatnot.

7 So we're starting to look more and more at

8 whole systems and the potential for optimizing those,

9 and even getting best practices put together.

10 Therefore, we might just have a situation where the

11 gallon storage is a key parameter. I can't say I know

12 at this moment that we're talking about now and into

13 the future.

14 It seems to me, again, that we could use that

15 information without having to go -- we don't want to

16 have to go to each and every manufacturer, because if

17 we had a rebate program, for example, we'd want to be

18 able to tell distributors there is the list that is

19 qualifying equipment for the incentive program.

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

21 I guess a question for DOE, would DOE verify -- DOE

22 does a test on the water heater to verify the rated
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1 storage volume?

2 MS. ARMSTRONG: Right now, our test procedure

3 has no method to verify our tolerance around it. So

4 there is no intention there. It really is just to

5 collect the information, to make sure you're in the

6 right product class, to make -- you know, for consumer,

7 you know, representation point of view. I mean, right

8 now there is no verification on that rated volume.

9 MR. AMRANE: Karim Amrane again. I guess,

10 too, to make sure that you are in the right category,

11 you should say yes or no, it will be --

12 MS. ARMSTRONG: I mean, this was --

13 MR. AMRANE: No, I understand.

14 MS. ARMSTRONG: -- products though, Karim,

15 right?

16 MR. AMRANE: The reason why maybe some have

17 concern about this is that, you know, you don't know

18 the information will be correct or not. And all of a

19 sudden this number will be on the DOE website, and you

20 will not be able to verify in any way that the

21 information is correct.

22 MS. BARHYDT: So, Karim, let me turn that
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1 around. We routinely, unfortunately, receive

2 certifications that say, "I am in Box X" when they then

3 provide product characteristics that show that actually

4 they are in Box Y. If we don't have a number, there is

5 no way for us to doublecheck that.

6 MS. ARMSTRONG: Plus, just generally, it is

7 going to -- I mean, let's say that you guys end up

8 using a basic model scheme with a bunch of asterisks

9 and a bunch of -- or completely different from model

10 numbers that are on your box.

11 You know, this is another attribute of the

12 product with the rated volume to ensure that if we were

13 to pick a unit for testing that we are matching up the

14 correct certification and the expectations of the

15 values, and the right standard, considering some of

16 these are based on volume, rated volumes or measured

17 volumes. It is just another way. Otherwise, there is

18 no link there; right?

19 It is another characteristic product. I fail

20 to -- this is a fundamental characteristic of a water

21 heater. I fail to see why this is a big issue.

22 MR. STEPHENS: Phillip Stephens, HTP.
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1 MS. ARMSTRONG: It's a number.

2 MR. STEPHENS: I think the point is just

3 exactly what you said. If it lists -- if a

4 manufacturer volunteers that they are a certain gallon

5 capacity, and then you test it and they're not, there

6 is no test method.

7 MS. BARHYDT: So I wasn't talking about

8 testing. I'm talking about -- I'm going to use a light

9 bulb as an example. Somebody says, "I have a four foot

10 GSFL that has a color-coordinated temperature of 41,000

11 Kelvin." In that very same certification, they tell me

12 that it is a U-bend and not a linear lamp. They tell

13 me that it has a 2,300 Kelvin color-coordinated

14 temperature.

15 It is not uncommon for people to make errors

16 in their certifications. And a yes or a no in the

17 wrong column could change whether or not it's a pass or

18 a fail. You tell me the size and I have something to

19 check it against and say, "Oh. I think maybe they put

20 a yes, and what they meant was no."

21 MS. ARMSTRONG: So and to take that a step

22 further, you know, their residential water heater, even
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1 the definitions in the statute, are a little bit

2 complex. As Karen asked me last week, "Where is the

3 residential test procedure?"

4 I mean, the legislation that got passed that

5 says there is this new group of commercial water

6 heaters that are intended for residential use are going

7 to depend on those product characteristics. What is

8 volume? What is -- and we are going to need that

9 information to be able to clearly delineate how things

10 fall out, how they're covered, under which

11 characteristics. You are going to need it, too.

12 What standards and test procedures ultimately

13 are going to apply? While that process is ongoing,

14 this is going to apply to it. And I fail to -- I mean,

15 that's the best reason that I can give you, that that

16 legislation that passed that said there are certain

17 commercial products that are going to be intended for

18 residential use, DOE figured out what it is. We've

19 gotten a lot of feedback on that, but they are going to

20 be based on product characteristics other than just EF

21 or thermal efficiency.

22 So I think that there are good reasons to
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1 collect that information.

2 MR. STEPHENS: Phillip Stephens, HTP. Two

3 points. One, we don't have anything 140 gallons or

4 larger. The second point is I think we are in a

5 situation where the -- which came first, the chicken or

6 the egg? I think what the manufacturers are concerned

7 about is if we say we are 141 gallons, plus or minus

8 five percent, that is a lot more difficult to meet than

9 141 gallons plus or minus 10 percent.

10 So would it be possible for the manufacturers

11 to propose a tolerance for this that we could all live

12 with to meet this requirement?

13 MR. MYERS: This is Frank Myers with PVI.

14 That would be problematic. I'm not saying that it

15 couldn't be done, but it would require at least on our

16 company's part substantial effort to come up with what

17 would be determined.

18 Just to give you an example of what I'm

19 talking about, our company does not represent specific

20 gallons for our storage tanks. Our company promotes

21 them as gallon series. So if you get a 1,000-gallon

22 series tank, you have a variety of gallons as
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1 delivered, because you have different things inserted

2 into the tank that take up a variety of volumes.

3 There are so many of those that impact the

4 volume that we don't tell our customers, "You are going

5 to get X gallons." So there is no plus or minus

6 tolerance. We simply say you are getting a series tank

7 or you're getting a 5,000-gallon series tank.

8 So coming up with the exact number to put

9 into something that is rated is very problematic.

10 Under 140 gallons, the exact -- or 140 or under, the

11 exact gallons will show up based on the test procedure.

12 Above 140 gallons, we use gallon series.

13 So to provide you with, what is the gallons,

14 okay, for which specific model, which does not impact

15 the standby loss, does not impact the efficiency. How

16 do we generate that number? We can give you the gallon

17 series, but it is only loosely related, generally

18 related, to the specific gallons that that product has.

19 MR. BALLO: This is Tim Ballo, and I'm

20 wondering if because this is only used currently for

21 product class identification, if we can just have a

22 tolerance around 140 and just say that if it's below --
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1 or if it's above 135, it's fine. If it's above 145,

2 then it's below or something like that, rather than

3 worrying about tolerances on the 1,000-gallon ones.

4 MR. STANONIK: Frank Stanonik, AHRI. And I

5 am probably going to regret saying this, but having

6 been very much involved in the origins of that

7 requirement, again, that number was picked not with any

8 intent of any tolerance. All right? It is the storage

9 capacity.

10 So a manufacturer who chooses that option,

11 which basically says I don't have to run standby loss

12 tests, I just meet some prescriptive criteria, okay,

13 the idea is that only applies if the storage volume of

14 that model, and all units of that model, are over 140

15 gallons. And I will tell you that that is -- at least

16 for a gas product that is nominally a rated 150-gallon

17 tank. Nominally.

18 And there has never been any consideration

19 discussion anywhere about some tolerance on that

20 requirement. So the only issue -- and, again, you

21 know, I think it could be solved by a yes/no, the only

22 issue is that if DOE ever needed to or wanted to, or
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1 even if our program wanted to confirm that a product in

2 fact was compliant with the appropriate requirement,

3 would be to check the volume to make sure it was at

4 least 140 gallons.

5 And I'll tell you that that is, again, a

6 limited range of products because there is no question

7 that Frank's 1,000 series or even his -- I'll dare say,

8 somebody's 200-gallon series, it is evident from visual

9 that it is probably more than 140 gallons easily. And

10 the real issue is the ones that are right near the

11 margin.

12 MR. SACHS: This is Harvey Sachs. I'd like

13 to amplify Marshall's point, if I can put myself in his

14 shoes, because it is potentially opportunity rather

15 than problem for some manufacturers.

16 Consider the possibility that PG&E and some

17 other companies decide to offer a rebate of so many

18 dollars per gallon of capacity, if it is such-and-such

19 a percent higher than the minimum efficiency. What

20 Marshall wants is to be able to have all of that data

21 in one place to avoid having to go to each of you to

22 get the information.
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1 So this is something which is not about basic

2 certification but about performance beyond the --

3 whether this product is legal to ship in commerce. So

4 I don't know how many manufacturers are in that space.

5 I don't know how many model -- how many units are

6 shipped. And I certainly don't know if PG&E or anyone

7 else is going to put in such a program, but that would

8 be the potential value of having that as a continuous

9 variable rather than a classification variable of above

10 or below 140 gallons.

11 MR. HUNT: This is Marshall Hunt. That's a

12 good way to put it. I've been thinking about what was

13 said about the 5,000-gallon tank. Is there a break

14 point where things are customized, almost one-offs

15 storage tanks, versus those that are on an assembly

16 line and produced in some sort of volume, so that the

17 cost savings is there and they are -- so I don't know

18 the business of the storage tank production, but,

19 again, is there a per limit or a cutoff when we go over

20 to one-offs?

21 MR. MYERS: Probably the best information --

22 this is Frank Myers, PVI. The best information I could
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1 provide on that is within the AHRI water heater and hot

2 water supply boiler program, there is a different set

3 of requirements for products that are larger than 130

4 gallons, which doesn't directly speak to this.

5 But in terms of differentiation getting into

6 the more custom world, there are different requirements

7 that are more accepting of custom-type equipment when

8 you get over 130 gallons and over 199 -- above 199,000

9 btu's. So that is -- I can't say that is a

10 marketplace, but in terms of something that has any

11 form of wider acceptance, that is the current AHRI

12 certification program.

13 MR. HUNT: Isn't there a cutoff at 199

14 gallons in terms of ASME or safety regulations?

15 MR. MYERS: There is a change in ASME

16 requirements at 199,000 btus. Anything larger than

17 that and larger than 120 gallons or larger. So, again,

18 when we are getting up to the 140 gallons, you are

19 clearly into the more specialty, the more one-off. The

20 requirements for standby loss went all the way up to

21 140, which is moving into the more custom and more

22 commercial type equipment.
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1 MR. HUNT: Thank you.

2 MR. EISNER: Other comments or questions?

3 MS. ARMSTRONG: So, Marshall, I have a

4 question for you. Is it acceptable for water heaters

5 or hot water supply boilers that are greater than 140

6 gallons, given what you heard today, to only declare

7 that -- to not submit their actual rated storage

8 volume?

9 MR. HUNT: The last phrase got garbled.

10 Please repeat.

11 MS. ARMSTRONG: Oh. Is it acceptable for

12 water heaters or hot water supply boilers that are

13 greater than 40 gallons -- 140 gallons not to submit

14 rated storage volume? But anything below -- like

15 anything not subject to this exclusion would be

16 submitting either measured or rated data.

17 MR. HUNT: Certainly, it is acceptable, but

18 it means that I can't run a program. Much like Harvey

19 made a good presentation of, I can't run a high

20 efficiency program and include that very, very

21 fundamental characteristics, as you have made the

22 point, of storage volume. And also, I could be -- not
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1 be able to do something about system sizing like for a

2 restaurant of certain capacity in terms of people and

3 whatnot.

4 So it would limit my abilities to produce

5 some of the energy efficiency programs that might

6 really benefit those manufacturers who decide to step

7 up and do a large volume unit with very high

8 efficiencies, what with a condensing system or some

9 kind of cascading. I don't know what is possible out

10 there. I just know that manufacturers are very

11 inventive, and we'd like to save gas, save carbon

12 output in the environment by running programs, and

13 we're directed to do that by our Public Utilities

14 Commission.

15 So it would limit us, and I don't think

16 that's going to benefit more innovative and advanced

17 manufacturers.

18 MR. STANONIK: Frank Stanonik, AHRI. And I

19 would suggest that -- I mean, I understand Marshall's

20 concern, but I would suggest in this case it's a

21 theoretical discussion because, again, for this class -

22 - this category of water heaters -- and, again, this is
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1 water heaters where the storage capacity is part of the

2 product. It's not a separate tank. It is part of the

3 product.

4 And the requirements are only that it has to

5 have a certain level of insulation, no standing pilot,

6 and a flue damper. And so I would ask you, how do you

7 write a program to promote a better product than that?

8 The only thing you could do is say, okay, and it has to

9 have a higher thermal efficiency or something.

10 Well, that's irrelevant to the volume anyhow.

11 I mean, in this particular case, knowing the rated

12 volume of that product is not going to be able to help

13 you write an incentive program for these particular

14 pieces of product, because it is all prescriptive

15 requirements.

16 MS. ARMSTRONG: All right. DOE gives

17 declaration rated storage volume greater than 140. The

18 rest stays the same. Vote away.

19 MR. KLEISS: I believe we are still

20 discussing. I will -- I appreciate that concession.

21 And even though we don't make tanks that -- or storage

22 water heaters that fall into that consideration. I'm
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1 sorry. Jeff Kleiss, Lochinvar.

2 My objections to the -- or recommendation to

3 use yes/no for the three different areas of rated

4 storage volume for units with 10 gallons or less

5 commercial unfired hot water storage tanks, and the

6 water heaters with 140 gallons or more and the other

7 conditions, is based more on the principle of DOE

8 requiring reporting information that is not necessary

9 for determining the efficiency or meeting the minimum

10 efficiency levels.

11 It is a matter more of principle than of

12 trying to withhold certain information or being afraid

13 of reporting it. Lochinvar does report volumes of our

14 units through AHRI, and AHRI does provide a website

15 where there is data that could be selected, sorted

16 through, to identify information.

17 I did not understand that the purpose of this

18 group, the purpose of this information, was to create

19 that kind of a database. But, rather, my understanding

20 is that this was to determine appropriate reporting for

21 the DOE to verify the compliance with the efficiency

22 regulations.
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1 MR. SACHS: This is Harvey Sachs. We had a

2 lot of -- a fair amount of discussion about test

3 procedure versus capacity. And eventually the gears

4 ground, and I thought about other product classes. We

5 will classify residential air conditioners, central air

6 conditioners, in a capacity group, as a three ton or a

7 two ton or a two and a half ton.

8 Is there actually any kind of a test

9 procedure or tolerance span that has been adopted by

10 anybody for -- whether your 34,000 btu unit is a three

11 ton or a two and a half ton? It's pretty loose, I

12 think.

13 I'm just asking -- I'm just trying to draw

14 the - - Harvey Sachs again -- draw the analogy that in

15 other parts of the regulatory framework the question of

16 tolerance spans and tests for capacity as a descriptor

17 of the product if -- not in my experience, but a big

18 issue. And other than the question whether it's over

19 140 -- over or under 140 gallons, or that is a void

20 space in the product availability anyhow, I am not sure

21 why this has been so important.

22 MR. CYMBALSKY: So I'm going to suggest to
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1 vote. Let's -- yes or no, and move on.

2 MR. EISNER: Okay.

3 MR. CYMBALSKY: No defaults to where we are

4 today, so -- it's already in the reg, so, mean --

5 MR. EISNER: Okay. Those who object, want to

6 state that you object?

7 MR. KLEISS: Jeff Kleiss, Lochinvar. Object.

8 MR. EISNER: Does anyone else object?

9 MS. MEYERS: Karen Meyers, Rheem.

10 MR. HUNT: Marshall Hunt, PG&E, objects.

11 MR. EISNER: Okay. Anybody abstain? We have

12 three objections, so it does not pass.

13 MR. CYMBALSKY: I figure that the

14 refrigeration guys have to get their turn here. It has

15 been a few hours for you.

16 MR. STEPHENS: Phillip Stephens, HTP. Neil,

17 could I propose that we come back and revisit this one

18 after lunch?

19 MR. EISNER: The CRE one, or the one we just

20 finished?

21 MR. STEPHENS: The one we just finished to

22 see if there is some middle ground we could find
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1 somewhere, because I would hate for this to go through.

2 We discussed previously how important it is to present

3 the ASRAC Committee with a unanimous consensus and have

4 everything positive. So to have one thing negative is

5 very concerning to me.

6 MR. EISNER: Okay. If we can work this out

7 over lunch, I think people will generally be happy.

8 MR. CYMBALSKY: Cheerios, anyone?

9 MS. ARMSTRONG: I mean, I can tell you with

10 100 percent certainty, if you go back and read some of

11 the comments we've gotten for a uniform descriptor,

12 think twice about what you're voting on.

13 MR. EISNER: Okay. So we can -- everything

14 is open to coming back to if it improves the document.

15 All right. CRE.

16 MS. ARMSTRONG: We are going to agree on

17 these next ones really quickly. These are the same

18 ones we discussed last week on the phone and we agreed

19 to. Can we just vote?

20 I promise I didn't change anything. Same

21 thing for HVAC, so get -- you guys get ready because

22 that's next.
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1 MR. SHEBIK: Hey, Ashley, this is Ron Shebik,

2 Hussmann. I do have questions on the second slide.

3 Just for clarification, under the remote condensing

4 unit section, the second-to-the-last bullet, you have

5 "The equipment family designation as described in the

6 section."

7 MS. ARMSTRONG: Yeah.

8 MR. SHEBIK: Is that the same as equipment

9 classification? Is that your VCTRC?

10 MS. ARMSTRONG: Yes.

11 MR. SHEBIK: Okay. If that's the case, then

12 in the next bullet it says, "Condensing unit

13 configuration." Now, are you looking for parallel and

14 conventional, or are you looking for self-contained or

15 remote?

16 MS. ARMSTRONG: Self-contained or remote.

17 MR. SHEBIK: Why would you add that? It's

18 already in the equipment classification.

19 MS. ARMSTRONG: I get it.

20 MR. SHEBIK: Okay.

21 MS. ARMSTRONG: We can consolidate.

22 MR. SHEBIK: The last -- okay. The last
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1 question I have on this is: where in the certification

2 report does it deal with one-of-a-kind models that are

3 built for a customer-specific request?

4 MS. ARMSTRONG: What is your question?

5 Sorry.

6 MR. SHEBIK: One-of-a-kind models, one-of-a7 kind cases, they would build specifically for one

8 customer. Where does that show up in the report?

9 Because it is not going to be in our product offering,

10 but it would be in our certification report.

11 MS. ARMSTRONG: It depends on if that one-off

12 model is part of -- if you can incorporate it as part

13 of your existing basic models that you have already

14 certified, or if it needs to be completely separate.

15 So it's not going to be -- I mean, I'm not going to

16 have a separate line item for one-offs; right?

17 It is that if you decide that one-off is a

18 separate basic model and want to certify it that way,

19 you need to certify all of this information. If you

20 decide that it's subsumed by another basic model, then

21 you are okay.

22 MR. SHEBIK: Okay. I guess maybe to clarify
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1 my question, when we certify, if we have a model that

2 we built for a unique -- sorry, a unique model that we

3 build for our customer, but it's not going to show up

4 in our product offering, if you look at a Hussmann case

5 listing, you are not going to see a listing because we

6 build for a specific customer.

7 MS. ARMSTRONG: I understand.

8 MR. SHEBIK: Does that pose any problem at

9 all? Because you are not going to be ordering that case

10 for testing. You wouldn't --

11 MS. ARMSTRONG: We can order that case for --

12 I could call you and ask you for one, like a DOE-built

13 one, right? Not that I necessarily would. I'm just --

14 MR. SHEBIK: Okay.

15 MS. ARMSTRONG: I mean, it's on you, right,

16 to certify it?

17 MR. SHEBIK: Okay.

18 MS. ARMSTRONG: If we find out about it.

19 MR. SHEBIK: Okay. I think that answered it.

20 Thank you.

21 MS. ARMSTRONG: Okay.

22 MS. DANE: Mary Dane from Traulsen. If we
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1 cross out the condensing unit configuration, wouldn't

2 you also have to either cross out or add in "If

3 applicable under PDF to require charging instructions

4 for remote cases"? In case we don't supply that

5 condensing unit? Thank you.

6 MS. ARMSTRONG: I think you still need that.

7 I'm not following.

8 MS. DANE: In a remote, we don't supply -- we

9 may not supply the condensing unit.

10 MS. ARMSTRONG: Then, how are you making

11 certification representations of what that --

12 MS. DANE: I'll have to go back and check,

13 but, like I said, if you're taking it out of one,

14 wouldn't you add "if applicable" at the other?

15 MS. ARMSTRONG: We just took it out of that

16 one because it technically -- in our regs, the

17 equipment family designation, the way we have it

18 defined in our equipment classes, it does subsume

19 whether it's remote. It already makes that declaration,

20 so it's redundant.

21 MS. DANE: Okay.

22 MS. ARMSTRONG: So I don't think you need "if
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1 applicable." I mean, you need charging instructions,

2 period.

3 MS. DANE: Okay.

4 MR. EISNER: Other questions? Concerns?

5 Ready to vote on CRE? Any objections as

6 changed?

7 MS. BARHYDT: Hold on just a second, Neil.

8 We're looking at the regs.

9 MS. ARMSTRONG: Change "equipment family

10 designation" to "equipment class designation." But we

11 already have that anyway, because that's at the front

12 of the -- but that's fine.

13 MR. EISNER: Okay. As changed, any

14 objections to the CRE slides? Any abstentions?

15 MR. HON: Quick question. Because the remote

16 cases are not testable as they -- as you would order a

17 remote case, how are you going to procure the other

18 half of the system?

19 MS. ARMSTRONG: With the hole aside issue.

20 MR. HON: Okay. Just asking.

21 MS. ARMSTRONG: I get it.

22 MR. HON: Because we may -- if you had asked,
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1 maybe we could help you on that.

2 MS. ARMSTRONG: I have no doubt that we will

3 need some assistance.

4 MR. EISNER: Okay. Anything else? This one

5 is passed unanimously? Okay.

6 MS. ARMSTRONG: So this is the same ones we

7 discussed for air-cooled equipment last week, and the

8 second page is what the PDF will require. The only

9 difference, you will see there is no optional IEER that

10 was removed from the discussion.

11 MR. THARP: Rusty Tharp. I just want to

12 confirm that the PDF is not public information.

13 MS. ARMSTRONG: Correct.

14 MR. THARP: Thank you.

15 MS. ARMSTRONG: It's true. It's not

16 considered -- it's not public.

17 MS. BARHYDT: Although making the distinction

18 between it is not public and that we will not be

19 proactively publishing it. If we get a FOIA, then we

20 send it back to you and get submitter's views and go

21 through the whole process.

22 MR. EISNER: Okay. Other questions? Other
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1 concerns?

2 Ready to vote? Any objections? Any

3 abstentions? Okay.

4 MR. WHITWELL: Bob Whitwell from Carrier.

5 I'm okay with this. Just a comment that, you know,

6 this is adding some more reporting requirements for

7 manufacturers. And I think it would be good if DOE and

8 EPA could get together and have common input for DOE

9 requirements and Energy Star, so we don't have to do

10 separate submissions. I know that's not something that

11 is going to happen right away, but I think it's

12 something that we should be working toward. Right?

13 MS. ARMSTRONG: We agree. We actively are

14 trying to do that.

15 MR. WHITWELL: Thank you.

16 MR. EISNER: Do you want EPA's address?

17 MR. AMRANE: Karim Amrane with AHRI. Did we

18 discuss last time that this kind of information would

19 be on the -- I guess on an as-needed basis or if we

20 will have to provide this for every model that we

21 certify to DOE? And that --

22 MS. ARMSTRONG: Basic model.
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1 MR. AMRANE: -- every basic model. And every

2 time it -- okay. I thought we talked about -- I recall

3 that we discussed the burden that manufacturers will

4 have to maintain those PDF files. So there was no

5 resolution to that? I don't know. Do we want to talk

6 about this?

7 MR. WHITWELL: I mean, it is a burden, but I

8 guess my thought is I would rather do it up front than

9 have to scramble and pull it together when we are in

10 the middle of many other things that we are working on.

11 So at least we can plan for this and do it up front.

12 If we have to submit this information, I would rather

13 not have to make it a fire drill.

14 MS. DANE: This is Mary from Traulsen. I do

15 remember that conversation, and I do think that it was

16 hanging out there, because there was also some

17 discussion not only that it was burdensome, but it

18 would have to be a rev-level requirement each time that

19 it came up.

20 And I'm not comfortable that all of that was

21 solved, but we really weren't offered any opportunity

22 or any other alternative other than perhaps the
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1 extension date of having to comply with it, because we

2 will have to go back and create all of these records,

3 even in CRE and some of the other fields. And I'm not

4 -- I haven't quite figured out how smaller companies

5 are going to do that, and I'm sure it is going to be

6 burdensome even for the larger ones.

7 MS. HOOTMAN: This is Jill from Trane. I

8 mean, it's all in the timing, you know. If it's going

9 to take us a lot -- I agree with Bob; we need to do it

10 upfront. It is required for essentially getting the

11 correct test. It is not created today, so starting from

12 square one on millions of models is going to take a

13 long time.

14 MR. EISNER: Okay. Anything else? Anybody

15 want to react to that? Okay.

16 MS. ARMSTRONG: I just have a question for

17 Jill. I mean, and maybe we should kick this to later

18 when we talk about timing. But, I mean, when you

19 reference millions of models, I mean, I thought part of

20 the process of going through all of this stuff with --

21 what is the base model? What is in and what's out?

22 What's not tested?
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1 All of the different types of things we may -

2 - we are going to issue and we have agreed to issue was

3 to get that number down from millions to what you do

4 today. And if I look in the AHRI directory, there is

5 nowhere close to millions.

6 MS. HOOTMAN: Yeah. But we've got to make

7 sure that they are all included, that those millions of

8 models are included in those base models, so all of --

9 MS. ARMSTRONG: Yeah, yeah. I'm not -- I

10 don't disagree that it's a huge undertaking and it's a

11 lot for you guys to do and appreciate the efforts. But

12 at the same time, you know, I think the magnitude is a

13 little different. The base model isn't millions.

14 MR. WHITWELL: Yeah. We are not in the

15 millions or trillions that we thought we were going to

16 be before.

17 MS. ARMSTRONG: You're going to change your

18 comment?

19 MR. WHITWELL: But it is more base models

20 than what we currently have with AHRI. It will be more

21 base models than what we have today.

22 MS. ARMSTRONG: But, I mean, even if I look
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1 at the AHRI, we're talking hundreds, if I look at the

2 ones today. So hopefully that -- hopefully it doesn't

3 increase magnitudes. I mean, that was the goal here,

4 right?

5 MR. WHITWELL: It won't be seven digits, so -

6 -

7 MS. ARMSTRONG: I really hope your co-worker

8 is on the phone for that.

9 MS. HOOTMAN: I will say that I -- it is at

10 least a thousand, but --

11 MS. ARMSTRONG: Okay.

12 MR. EISNER: Okay. PTACS? Any questions?

13 Any concerns?

14 Ready to vote? Any objections?

15 MR. AMRANE: Karim Amrane, AHRI. Do we have

16 to say that this is a standard or non-standard? Or the

17 sleeve size will take care of this, right?

18 MS. ARMSTRONG: You have to declare product

19 class anyway. It is part of -- so that is going to

20 take care of that, too. Yep.

21 MR. EISNER: So no objections? Any

22 abstentions?
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1 MR. BALLO: Are we deleting wall sleeve

2 dimensions?

3 MS. ARMSTRONG: No.

4 MR. EISNER: Okay. We have unanimous

5 consensus on this one.

6 SPVUs? Any questions? Any concerns?

7 MR. AMRANE: This is Karim Amrane, AHRI. I

8 think the COP is at 47 degrees, so I think --

9 MS. ARMSTRONG: Whatever the --

10 MR. AMRANE: Whatever. Yeah, I mean, just to

11 be clear. Right, okay.

12 MR. EISNER: Okay. Ready to vote?

13 MR. AMRANE: The test procedure can rate the

14 product at 17 as well, so that's why. But the

15 regulations are made on 47 degrees, so that's why maybe

16 just adding at 47 would be helpful.

17 MR. SACHS: This is Harvey Sachs. I would be

18 a lot happier if it didn't sort of rub salt in my

19 wounds with the 47. I'd like to leave it open for that

20 possibly to be the 17 rating at some point.

21 MR. AMRANE: Again, today the requirement is

22 at 47. This is Karim with AHRI. It's not 17. So if
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1 DOE tomorrow wants to rate it to -- the COP at 17,

2 that's fine; DOE would be able to add that. For now,

3 this is what it is.

4 MR. SACHS: It's a bitter pill, Karim. It's

5 a bitter pill.

6 MR. HUNT: This is Marshall Hunt, PG&E. As

7 mentioned last time, I am very concerned about the

8 changeover point and the dropping of the COP to one at

9 a very high temperature.

10 MR. EISNER: Any reaction to that?

11 Any other concerns? Ready to vote? Anybody

12 object? Anybody abstain? Okay. Then we've got a

13 unanimous vote on that.

14 DOE wants to discuss the next slide a little

15 more before we get into a discussion here. So you are

16 all free to go to lunch. Have a nice, easy, relaxing

17 lunch. We have a couple more slides and then we'll get

18 to verification.

19 MALE SPEAKER: What time are we reconvening?

20 MR. EISNER: 2:00.

21 (Whereupon, a recess was taken.)

22 MR. EISNER: Everybody take their seats.
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1 All right. Are we ready to start with VRF?

2 MS. BARHYDT: So, Paul, I think you helped

3 come up with these. Do you want to walk us through the

4 suggestions?

5 MR. DOPPEL: Paul Doppel with Mitsubishi. So

6 basically we have -- for VRF we have the two

7 categories, very similar to ULE. In fact, the bullet

8 points under each of these two are I think exactly as

9 the commercial unitary large equipment.

10 So any questions on these?

11 MS. HOOTMAN: It's not being shown on the

12 webinar.

13 MS. ARMSTRONG: Is that better?

14 MS. HOOTMAN: Yes, thank you.

15 MR. THARP: Can you speak up, Jill?

16 MS. HOOTMAN: No. And you love it.

17 MR. DOPPEL: That was Rusty Tharp. That was

18 not Paul Doppel.

19 MS. HOOTMAN: I know who it is.

20 MR. DOPPEL: Hey, Jill, they're piling on.

21 MS. HOOTMAN: I know they are. Kind of like

22 lions in the den.
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1 MR. DOPPEL: Okay. So are there any

2 questions on this page?

3 Okay. Next page, then on the PDF, these are

4 the items that would be required. What is sort of

5 different from what the unitary large equipment had was

6 that we would identify indoor and outdoor units that

7 are defined in the test accommodation, and then any

8 components that would be needed for heat recovery, if

9 it's a heat recovery system.

10 And then, since these systems are primarily

11 heat pumps, the rated heating capacity would be listed.

12 We changed the airflow for each indoor unit, and

13 instead of frequency set point it is compressor,

14 because it could be one or more than one.

15 And then we took out charging instructions

16 and we took out motor -- base motor classification, or

17 whatever that was, and then we added this statement at

18 the bottom of the system set up for testing, including

19 charging instructions that are consistent with the

20 installation manual.

21 MR. EISNER: Okay. Any questions? Any

22 comments?
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1 MR. HUNT: This is Marshall Hunt, PG&E.

2 Could you go back one slide, please? Out of concern

3 for peak power, okay, you've got the EER in there? I

4 see that. How about less than 65,000 would be the EER?

5 MR. DOPPEL: For less than 65,000, it's just

6 the SEER.

7 MR. HUNT: I know. We need the EER. Peak

8 power is very important to us, and this is one way we

9 can get at it. SEER is not adequate for --

10 MR. DOPPEL: EER is available on the AHRI

11 website.

12 MR. HUNT: I'd like it to be on this site.

13 MR. DOPPEL: Yeah, but it's not on the -- if

14 you go back to the unitary equipment less than 65,000,

15 it's not there either, because it's not a requirement.

16 MR. WHITWELL: The SEER is not a DOE metric.

17 I mean, the EER on these.

18 MR. HUNT: I have to ask. I won't object,

19 but I just want to keep it in front of people's minds.

20 MR. STARR: This is Louis Starr with NEEA. I

21 assume that it does become -- because that's one of the

22 rulemakings they're looking at has EER and SEER. So
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1 that could change, and if that does, does that mean

2 that this would reflect that change or not? Because

3 they're talking about which metric -- there is a

4 discussion of switching between those metrics for

5 rating of equipment. There was a rulemaking about it.

6 MS. ARMSTRONG: Correct. So I think there is

7 a couple of things. One is we did finish a rulemaking

8 for residential, which in a certain picked up EER. And

9 we have it with -- that's out of the scope of these

10 negotiations. That is purely residential.

11 MR. DOPPEL: That's only EER for air

12 conditioners.

13 MS. ARMSTRONG: Correct.

14 MR. DOPPEL: Right.

15 MS. ARMSTRONG: And then we are -- we have

16 another rulemaking open for unitary equipment, but not

17 three-phase less than 65. So 65 and above, I believe,

18 to contemplate EER to an IEER switch.

19 MR. DOPPEL: Okay.

20 MR. EISNER: Other comments? Questions?

21 Everybody ready to vote? Any objections?

22 Any abstentions? Okay. We have unanimous agreement
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1 here.

2 That brings us up to Computer Room Air

3 Conditioners.

4 MS. ARMSTRONG: This is Ashley from DOE.

5 This is just a reflection of our regulations.

6 MR. AMRANE: Karim Amrane with AHRI. Why are

7 you requesting the economizer presence?

8 MS. ARMSTRONG: Because there is a difference

9 in standards between whether it is or not.

10 MR. AMRANE: There is?

11 MS. ARMSTRONG: Yeah. It's in here. We have

12 product class distinctions based on that, so that's

13 why.

14 MR. AMRANE: Again, Karim Amrane, AHRI. As

15 far as the condenser medium air-cooled, water-cooled,

16 those are product classes, right? So do you need that?

17 It's --

18 MS. ARMSTRONG: We can do it either way, so -

19 -

20 MR. AMRANE: So I guess some additional

21 suggestions from the manufacturers, in addition to the

22 net sensible cooling, they are suggesting that we add
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1 the net cooling capacity.

2 MS. ARMSTRONG: Okay.

3 MR. AMRANE: And the airflow rate in SCFM.

4 MS. ARMSTRONG: And do they want to put that

5 in the PDF, I assume? They probably don't want to put

6 that as part of the public --

7 MR. AMRANE: Again, that's, you know, for

8 them to -- I guess at this point in time, I don't think

9 that there are -- they want this to be information

10 available.

11 MS. ARMSTRONG: They do want it to be.

12 MR. AMRANE: Yeah.

13 MS. ARMSTRONG: Okay.

14 MR. AMRANE: Yeah.

15 MS. ARMSTRONG: Okay.

16 MR. AMRANE: But on SCFM. SCFM.

17 MR. STARR: This is Louis Starr with NEEA. I

18 was just looking at 127. It seems like they also split

19 out something to do with the chilled water, whether the

20 air handler's chilled water or not. So it seems like

21 that would need to be in there as well. It looks like

22 you've got the condenser medium, but then the part
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1 about whether the evaporator side --

2 MS. ARMSTRONG: Is that the --

3 MR. STARR: Well, it's an ASRAC product, so I

4 don't know how that translates into your CRF. But the

5 ASRAC product is based upon Standard 127, so I'm

6 assuming the information -- it seems like you need that

7 information presented in order to get the ratings and -

8 - this is the 2007.

9 MR. AMRANE: You have to look at the ASRAC

10 table where the efficiencies are.

11 MS. ARMSTRONG: That's what he's looking at.

12 MR. AMRANE: Okay.

13 MS. ARMSTRONG: There's like an extra

14 category. I don't know where it is.

15 MR. AMRANE: So I don't know.

16 MS. ARMSTRONG: I don't know either.

17 MR. STARR: Well, there are some other

18 things, too, I think with the outside air temperatures,

19 too. But I don't know. With the --

20 MS. ARMSTRONG: I assume that the temperature

21 is --

22 MR. AMRANE: Right. No. The new 127 has
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1 other air temperatures, and that is maybe for DOE later

2 on to look at that. But right now it's only the 75-

3 degree return.

4 MR. STARR: Yeah. And I think the ASHRAE one

5 is actually the older one, the 2007. Even though it

6 came out -- the new one came out in 2012, I don't think

7 the ASHRAE 90.1 was --

8 MR. AMRANE: Exactly.

9 MR. STARR: -- they didn't overlap to catch

10 up the new efficiencies.

11 MR. AMRANE: You're right. This is something

12 that we do.

13 MR. EISNER: Okay. Other questions or

14 comments?

15 Ready to vote? Are there any objections?

16 Any abstentions? Okay. It's unanimous.

17 That brings us up to -- now, there was some

18 discussion earlier about some talks about lunch.

19 Anything come out of that that we want to talk about?

20 MR. THARP: Rusty Tharp, Goodman. We need to

21 do Water Source Product also, certification

22 information. And I'd like Jill to chime in on that one,
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1 please.

2 MS. HOOTMAN: Stop, Rusty, stop.

3 MS. ARMSTRONG: All right. So the first

4 thing is we don't have separate slides for water-cooled

5 and evaporatively cooled. Is there anything that would

6 make them different from air-cooled? Any of the --

7 like can you provide -- right now our regs are the

8 same, regardless of whether it's air-cooled, water9 cooled, or evaporatively cooled. So if I change this

10 heading to encompass water-cooled and evaporatively

11 cooled, will that take care of it?

12 MR. THARP: This is Rusty with Goodman. I

13 believe that water source needs a flow rate specified.

14 MS. ARMSTRONG: So I'll do water source

15 separate, but water-cooled and evap-cooled, are we

16 okay? So you'll be providing this.

17 MR. EISNER: So no disagreement with making

18 that change? No objections? No abstentions?

19 MS. ARMSTRONG: So, let's see.

20 MR. STEPHENS: Phillip Stephens, HTP. Just a

21 question for clarification. For all of the different

22 programs, sometimes we reference optional submission
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1 for a PDF, and sometimes we reference PDF to require.

2 MS. ARMSTRONG: Correct. It was done

3 purposely.

4 MR. STEPHENS: Okay. That's the

5 clarification I was looking for. Thank you.

6 MS. ARMSTRONG: I think those are all true.

7 Any issues yet? Are we okay with this one?

8 MR. FLY: This is Mark Fly with AAON.

9 Ashley, do you want to put water source in with evap10 cooled and water-cooled, since it's a different test

11 procedure?

12 MS. ARMSTRONG: I don't have to. I can do it

13 separate. I'm going to list them out separately in the

14 regs. But for the purposes of discussion, is it easier

15 for me to do them separate?

16 MR. FLY: Yes.

17 MS. ARMSTRONG: Okay. Separate.

18 Water source discussion. So do you want me

19 to put "water flow rate," Rusty, instead of this?

20 MR. THARP: Yes, I think we should. I think

21 that is manufacturer-specified value.

22 MS. ARMSTRONG: Anything else that needs to
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1 be changed here?

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

3 This is for what kind of equipment?

4 MS. ARMSTRONG: Water source heat pumps.

5 MR. STARR: Water source. Okay.

6 MS. HOOTMAN: Do you need rate of static when

7 you are going to actually go back to zero? I mean,

8 doesn't the standard take it back to zero?

9 MS. ARMSTRONG: It normalizes it; right?

10 MS. HOOTMAN: Yep.

11 MR. JOHNSON: This is Tom Johnson. You

12 should have GPM, some kind of a flow rate, GPM, some

13 kind of standard CFM that you've got that.

14 MS. ARMSTRONG: No, I don't.

15 MR. JOHNSON: No, you don't. Yeah.

16 MS. ARMSTRONG: Rated airflow? Okay.

17 MR. JOHNSON: And then a static pressure for

18 if you use an ECM motor. And my guy just said, "Got

19 it."

20 MS. ARMSTRONG: Thank you.

21 MR. SACHS: This is Harvey Sachs. Tom,

22 please remind me. I thought the fan was sort of netted
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1 out in the rating method for water source. So the ESP

2 is -- Karim, this is one of your tests. One, two,

3 three --

4 MS. ARMSTRONG: It is normalized, Harvey, but

5 you still have to test first.

6 MR. DOPPEL: And the net out is a set value,

7 regardless of the type of air motor that you are

8 actually using; right?

9 MR. BALLO: All right. So tell me, do I want

10 it or not? I think I want it -- want the ESP.

11 MR. THARP: Yes. We want to know what the

12 rated static is, yes.

13 MR. BALLO: Thank you.

14 MS. ARMSTRONG: Oh, look. The vote already

15 decided itself.

16 MR. SACHS: I couldn't hear that. Was it

17 directed at me?

18 MS. ARMSTRONG: No. I added yours. Somehow

19 after you spoke, Harvey, the vote already decided. I'm

20 just joking, sorry. Can we vote on these, though, for

21 water source?

22 MALE SPEAKER: Do we have the efficiency
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1 performance?

2 MS. ARMSTRONG: Yep. EER, COP, cooling

3 capacity, and type of heating. It seems to be what our

4 regs say.

5 MR. JOHNSON: So I think, Ashley, if we use a

6 variable speed compressor, it might be a different

7 model, but we would need the compressor speed.

8 MS. ARMSTRONG: Is that definite that --

9 MS. HOOTMAN: Isn't that in your --

10 MR. JOHNSON: Am I right there, Rusty? Yeah.

11 MS. HOOTMAN: Yeah. We're looking at

12 frequency set points, whether that's a VFD for airflow

13 or whether that's frequency for compressors. Stop

14 laughing, Rusty.

15 MS. ARMSTRONG: In his defense, it actually

16 wasn't him this time.

17 MR. THARP: It was Karim.

18 MS. HOOTMAN: I'll still blame Rusty.

19 MS. ARMSTRONG: I think we're good.

20 MR. JOHNSON: I think we're good.

21 MS. ARMSTRONG: Okay.

22 MR. EISNER: Okay? Everybody is all right?
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1 Any objections? Any abstentions? Okay. We are

2 unanimous on this one.

3 MS. ARMSTRONG: And can I extend the air4 cooled to water-cooled and evaporatively cooled? Or do

5 I need separate slides?

6 MR. WHITWELL: For water-cooled, we need to

7 include the water flow rate.

8 MR. FLY: So I'll say this publicly instead

9 of just privately back here in the back of the room. I

10 think that at some point we may want to look at makeup

11 water temperature for evaporative-cooled, but that's a

12 test standard issue, not really this compliance issue.

13 It's not in the standard today, so that's something we

14 need to address in the test standard. There is no

15 water flow rate that is needed for evaporative-cooled

16 because it's going to be -- you know, it's going to

17 self-regulate itself by the capacity in the conditions.

18 MR. STARR: It seems like typically on at

19 least the evaporative-cooled there is an effectiveness

20 is kind of how you look at when you're selecting units.

21 But I don't know how it regulates in, but it's

22 different than the other equipment.
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1 MR. FLY: This is Mark Fly. I'm talking

2 about evaporative condensing, not evaporative-cooled

3 units. So evaporative-cooled units, I think we

4 actually excluded that component earlier, so we're not

5 covering that at the moment that I can tell.

6 MR. HUNT: Marshall Hunt.

7 MS. ARMSTRONG: Go ahead, Marshall.

8 MR. EISNER: Marshall, are you there?

9 MR. HUNT: Yes, thank you. PG&E. I agree

10 with Mark that we did exclude the evaporative pre11 cooler last meeting.

12 MR. EISNER: Okay. Everybody okay with this

13 as modified? Any objections? Any abstentions? Okay.

14 Next?

15 MR. DOPPEL: Ashley, Paul Doppel with

16 Mitsubishi. So we need to do a VRF water source also.

17 So if you took this page -- it might be easier to just

18 do -- take the water source, make it VRF, but take the

19 second page from the VRF and add water flow rate to

20 that.

21 MS. ARMSTRONG: Take the second page from VRF

22 and add water flow rate. And then --
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1 MR. DOPPEL: Then on the front page you would

2 have to add --

3 MS. ARMSTRONG: -- refer to water source for

4 those requirements. Right?

5 MR. DOPPEL: Yep.

6 MS. ARMSTRONG: Does that work?

7 MR. DOPPEL: Mimic water source?

8 MS. ARMSTRONG: Water source slide. Sorry.

9 I can just -- these.

10 MR. DOPPEL: Yeah. So for the -- but you go

11 to the page before that. Okay. So those items should

12 be added to the VRF front page.

13 MS. ARMSTRONG: Okay. I mean, they're the

14 same as the ones on the bottom, right?

15 MR. DOPPEL: Yeah.

16 MS. ARMSTRONG: So that would be covered.

17 But okay.

18 MR. DOPPEL: So it would be another category

19 at the very bottom. Just add -- you would have to add

20 another -- just a whole other -- if you just copy that

21 from the water source and make --

22 MS. ARMSTRONG: Yeah, I get it. It's the
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1 exact same wording, though, right?

2 MR. DOPPEL: Yes. And just drop it all the

3 way at the bottom of the VRF and say "water source

4 VRF."

5 MS. ARMSTRONG: Okay.

6 MR. DOPPEL: That's good.

7 MS. ARMSTRONG: Do you want me to do a

8 separate slide for water source VRFs?

9 MR. DOPPEL: No. You've got it now.

10 MS. ARMSTRONG: That's okay?

11 MR. DOPPEL: It's good now. Thanks.

12 MR. EISNER: All right.

13 MS. ARMSTRONG: So are we good here?

14 MR. EISNER: Everybody okay? Any objections

15 or abstentions to the modifications on water source?

16 Okay.

17 MR. AMRANE: Was the water-cooled --

18 MS. ARMSTRONG: The water-cooled and

19 evaporative cooled would be identical to the air-cooled

20 except for the water flow rate.

21 MR. AMRANE: Karim Amrane, AHRI. The water22 cooled product is in 65. I believe it's an EER
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1 requirement, not a SEER.

2 MS. ARMSTRONG: Yeah, you're right. Is that

3 good?

4 MR. AMRANE: Karim Amrane, AHRI. Even the

5 COP, I'm not sure it applies to them. We need to look

6 at that.

7 MS. ARMSTRONG: Yeah. I mean, that's why it

8 says, "As necessary to meet the standards."

9 MR. AMRANE: Okay.

10 MS. ARMSTRONG: So it's not going to be

11 required unless you have a standard there.

12 MR. AMRANE: Okay.

13 MS. ARMSTRONG: We'll just have to go -- I

14 mean, when we go through and articulate each one.

15 MR. EISNER: Okay. Anything else? Are we

16 set? Is there any need to go back to commercial water

17 heaters?

18 Everybody got quiet all of a sudden. Okay.

19 Verification of --

20 MR. HUNT: Hello. This is Marshall Hunt,

21 PG&E.

22 MR. EISNER: Go ahead, Marshall.
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1 MR. HUNT: Marshall Hunt, PG&E. Okay. I am

2 considering removing my objection, but actually I

3 objected for a different reason, but I still want to

4 hear from the other two folks, because I don't want it

5 necessarily to go forward if they really have major

6 concerns. I could also be expressing my concern at the

7 same time. But could we hear from the other two

8 objections?

9 MR. KLEISS: This is Jeff Kleiss, Lochinvar.

10 If I could suggest, where we've got the rated storage

11 volume greater than 140 gallons, yes/no, if we could

12 copy that text and put it in DOE -- for the

13 instantaneous water heaters and change the volume to

14 10.

15 MS. ARMSTRONG: So that's not going to work

16 for DOE. We want the number.

17 MR. KLEISS: Okay. Well, we can vote on it.

18 MS. ARMSTRONG: Well, we can just leave it,

19 and you can vote on that.

20 MR. KLEISS: We already did. So if you

21 would, please, put that language up there with the 10

22 gallons. And then if we could -- and you could just
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1 line through the rated storage volume there. And we

2 can discuss that, and I would suggest that we can vote

3 on that because all of -- that would eliminate the

4 information that is not required for efficiency rating

5 or verification of those products.

6 MS. MEYERS: Yeah. Rheem can support the

7 proposal as it is on the slide now.

8 MS. ARMSTRONG: Yeah. So the top one is not

9 going to work because I can already tell you, with the

10 uniform descriptor coming down the pipeway, that's

11 going to be obsolete. And so there is no point in

12 adopting something that is going to be obsolete in six

13 months. So that's not something the Department can

14 support.

15 MS. MEYERS: Well, Ashley, it's kind of hard

16 for us because we haven't even seen the proposed rule,

17 and then we don't know that the proposed rule is going

18 to actually be the final rule. So that's our issue

19 here.

20 MR. AMRANE: Karim Amrane, AHRI. But,

21 Ashley, you can always revise it later on when this

22 rule is out.
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1 MS. ARMSTRONG: The rule is not even going to

2 be finished in time.

3 MR. STEPHENS: Phillip Stephens, HTP. I'd

4 like to point out, with the text there and the

5 groundwork rules we laid, we can still pass something

6 with two objections. And with the DOE having two

7 votes, then --

8 MS. ARMSTRONG: We only have one vote.

9 MR. STEPHENS: You've got one vote? Okay.

10 MR. MYERS: Ashley, let's talk about the

11 instantaneous with less than 10 gallons. So even --

12 all right. So the uniform descriptor is going to

13 change the break point, then. Okay? But there will

14 still be commercial water heaters that fit in this box.

15 MS. ARMSTRONG: Frank, there is no reason,

16 for something that is less than 10 gallons, that you

17 can't state what the rated storage volume is.

18 MR. MYERS: Well, actually, there is a

19 reason, because you don't need it for anything. All

20 you need -- the reason, again, this goes back to ASHRAE

21 90.1, and the reason that the 10 gallons came into

22 being was that it was essentially determined that at
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1 some point in the design of an instantaneous water

2 heater, at some point the amount of water that is

3 within the tubes, because we were typically thinking of

4 tube-type products, and the energy that is contained in

5 those tubes, becomes significant. And so it was

6 somewhat arbitrarily said, "Well, if this holds more

7 than 10 gallons, we want to measure a standby loss."

8 And so if it's less than 10 gallons, it

9 doesn't matter if those tubes only hold one gallon, 1.5

10 gallons, 3.5 gallons. It is irrelevant. And in fact,

11 for those products, technically there is not a rated

12 storage volume. There is an amount of water that is

13 contained within the water heater, but whether it's

14 one, six, or eight, as far as the efficiency

15 requirement for this product, it doesn't matter.

16 MS. ARMSTRONG: I mean, you can make the same

17 argument, right? The product classes are delineated by

18 storage volume, whether it be rated, whether it be

19 above or below. The same thing happens -- we just went

20 through unitary, and they are delineated by cooling

21 capacity, 65 to 135. It's a bucket, too, but yet

22 they're willing to tell us the attributes of those
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1 products. I don't understand why it's such an issue,

2 and this is the anomaly in this product.

3 MR. MYERS: So, again, water heaters --

4 appreciate that the commercial water heater market, the

5 way -- it is actually, by the way, also defined in the

6 law, okay? I could have a 40-gallon -- I could have a

7 commercial water heater that holds 40 gallons that

8 fires at 200,000 btu's per hour. That, by definition,

9 is an instantaneous commercial water heater.

10 MS. ARMSTRONG: I understand.

11 MR. MYERS: Okay. And so what this was

12 trying to capture, what this was trying to capture, was

13 in fact those -- that subgroup of instantaneous water

14 heaters that are tube-type products. That it's

15 basically a coil tube where the water runs through the

16 tube and the heat plays over the tubes. Okay?

17 I will tell you that those manufacturers --

18 it has not been their practice, not their history, to

19 measure the volume, the amount of water that's in those

20 tubes. The only thing that they look at, because this

21 has been around a long time -- the only thing they look

22 at is, did I happen to build one that is big enough
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1 that the tubes contain 10 gallons? In which case they

2 now have additional requirements.

3 But that is -- you know, they basically say,

4 "Am I 10 or less, or am I 10 or" -- you know, how do I

5 relate to 10? They don't -- I am not aware that they

6 go around advertising that, oh, this particular

7 commercial instantaneous tube-type water heater holds

8 1.5 and this one holds three, or whatever. They

9 haven't been doing it; that's the point. They haven't

10 been doing it in terms of a rated volume.

11 MR. STEPHENS: Phillip Stephens, HTP. I

12 would like to point out there again that we found a

13 solution that the manufacturers are comfortable with

14 that will still pass. And we recognize the fact that

15 it is going to go to the Federal Government, right?

16 But I'm sure you're going to have a majority say in

17 that with the ASHRAE. We understand that.

18 But this way we can show that the

19 manufacturers are in consensus and in agreement with

20 what we expect and what we would prefer for this

21 situation, because what you are asking for is more than

22 what we are required to do by law right now. And we
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1 haven't seen --

2 MS. ARMSTRONG: You are required by law to

3 submit rated storage volume right now. So if I don't

4 change anything, that is what you submit come December

5 31st.

6 MR. BALLO: This is Tim. And I hear Frank's

7 point about the less than 10 gallon instantaneous

8 models. I'm wondering, though, for hot water storage

9 tanks that the rated storage volume does seem like

10 something that is information that has some value to

11 people looking at those products. I guess I have a

12 bigger problem with that than I do with the less than

13 10 gallons.

14 MR. KLEISS: This is Jeff, Lochinvar.

15 Ashley, you said that as of December 31st we would be

16 required to report volumes. Is that based on what is

17 written in the Federal Register? Or is that based on

18 what is in the templates that have been submitted?

19 You're looking up chapter and verse, Laura?

20 MS. BARHYDT: Yep.

21 MR. KLEISS: Thank you.

22 MS. BARHYDT: Would you like me to read it to
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1 you?

2 MR. KLEISS: Please.

3 MS. ARMSTRONG: Storage volume in gallons.

4 It doesn't say rated or measured. You guys wanted it

5 to be rated. So it wasn't confusion that it was

6 measured. Storage volume in gallons.

7 MS. BARHYDT: Unfired? Unfired, it says

8 measured.

9 MS. ARMSTRONG: This one.

10 MS. BARHYDT: Oh, that one.

11 MS. ARMSTRONG: Yeah. So we are fixing the

12 measured one, which you didn't want it -- want, and

13 we're changing -- and the other one says "storage

14 volume," which you guys wanted "rated." So, yes, it's

15 already in there.

16 MR. MYERS: This is Frank Myers. Are you

17 reading from the ---

18 MS. ARMSTRONG: 429.

19 MR. MYERS: -- the rule that was made back a

20 little over two years ago and then was extended and the

21 deadline was extended?

22 MS. ARMSTRONG: Yes.
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1 MR. MYERS: And that is a part of this

2 negotiation because of the problems that we had with

3 it? Is it that rule that you are reading?

4 MS. ARMSTRONG: Uh-huh.

5 MR. MYERS: Okay. So we are here trying to

6 fix all of those things, because those things --

7 MS. ARMSTRONG: As are we.

8 MR. MYERS: -- are problematic. Yeah.

9 MS. ARMSTRONG: We gave, right, on the 140

10 gallons. But the other one is important to us.

11 MR. MYERS: To have the "rated storage volume

12 in an instantaneous product less than 10 gallons" is

13 important to you. Is that what you're saying?

14 MS. ARMSTRONG: That's what I said.

15 MR. MYERS: Because nothing in the

16 regulations require anything other than the cutoff

17 point.

18 MS. ARMSTRONG: We have discussed, right? I

19 mean, at this point, we can -- it's --

20 MR. SACHS: Ashley, this is Harvey. Maybe I

21 can try a different approach. Can you remind me of the

22 definition of a commercial tankless or instantaneous
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1 water heater?

2 MS. ARMSTRONG: All right. Yeah. Give me a

3 second, Harvey.

4 MR. SACHS: And what I'm really interested in

5 -- this is Harvey -- is the contrast, if any, between

6 this and the definition for the residential tankless.

7 MS. ARMSTRONG: So the instantaneous ones are

8 in terms -- well, in the CFR they're in terms of input

9 ratings.

10 MR. SACHS: So what is the minimum input

11 rating for commercial tankless?

12 MS. ARMSTRONG: Water heater that has an

13 input rating not less than 4,000 btus per hour -- per

14 gallon.

15 MR. SACHS: Per gallon.

16 MS. ARMSTRONG: Correct.

17 MR. SACHS: I guess where I'm coming from is

18 seeing a need for products that fill the hole now that

19 we have in the sort of two to 10 gallon --

20 MS. ARMSTRONG: Absolutely.

21 MR. SACHS: -- buffer range, that that is

22 what is going to kill our cold water sandwiches, with
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1 all due respect to manufacturers to the other type of

2 product. And what I'm aiming at -- and I'm not sure

3 where that leaves me -- is to make sure that we don't

4 wind up with a regulation that discourages the

5 introduction of sort of next-generation products,

6 whether fire tube or water tube, that actually do

7 provide that buffering function and extend the range of

8 utility of these as part of efficient solutions.

9 And I'm not sure that -- my instinct is that

10 knowing the number of gallons of buffer, I won't even

11 call it storage, is going to be helpful, but I'm not

12 sure if that's going to get in the way of what my real

13 goal is. But I'm pretty sure that I'm -- I'm having

14 trouble accommodating what I'm hearing as this being a

15 training point, that we gave on the 140 so we're going

16 to be rigid on this.

17 MS. ARMSTRONG: Okay.

18 MR. EISNER: Any other comments?

19 MR. KLEISS: Jeff Kleiss, Lochinvar. Just it

20 -- as written, would this allow DOE to perform what --

21 to report and validate products as they are required

22 to? Or is there a deficiency within this that would
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1 keep you from doing your job?

2 MS. BARHYDT: It does not provide the same

3 level of validation that we are accustomed to. It does

4 not provide the same level of validation that we have

5 for other products, no.

6 MS. ARMSTRONG: For almost all of our other

7 products. We collect product attributes. We have

8 agreed to a lot of them today.

9 MR. KLEISS: Okay. And there was one other

10 thing that -- Jeff Kleiss again -- that you surprised

11 me on. I just didn't catch this. But there are other

12 product types that there are attributes that you are

13 capturing that are not required for determination of

14 compliance with the efficiency regulations?

15 MS. BARHYDT: For example, I think Ashley

16 listed earlier capacity. Those are buckets, but we are

17 not saying, "Are you in this bucket or that bucket?"

18 We're saying, "What is your capacity?"

19 MR. KLEISS: And that was for --

20 MS. ARMSTRONG: And that's a rated value.

21 That's for all of our HVAC products. We do the same

22 thing with clothes washer capacity or -- yeah, there's
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1 a lot of them.

2 MR. AMRANE: Karim Amrane with AHRI. But

3 this requirement has been in place since the beginning,

4 so --

5 MS. ARMSTRONG: Well, I mean, it's the same,

6 though. It's an attribute of a product, but yeah.

7 MR. THARP: Rusty Tharp with Goodman. On the

8 HVAC part, the capacity is needed, at least to some

9 point, to determine the static at which you operate.

10 But some of the things that we agreed to are also the

11 PDF that's not public, and so I guess the question,

12 too, would be -- that I have is, if this were submitted

13 in a PDF format that is not publicly available, would

14 that be acceptable to both parties as --

15 MS. ARMSTRONG: The Department is okay with

16 that.

17 MS. MEYERS: I mean, the way it's proposed up

18 there, we are providing whether it has a rated storage

19 volume greater than 10 gallons or not. So we are

20 providing -- we are saying yes or no. So we are

21 providing that information. We are not asking that

22 that be stricken. We are just asking it to be a yes or
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1 no answer. So that does kind of provide that product

2 attribute that you referred to.

3 MR. KLEISS: This is Jeff Kleiss, Lochinvar.

4 The major objection that I have is not on reporting the

5 information, but, rather, just the principle of asking

6 for information that goes beyond what is required to

7 determine -- for you to do your job, to determine the

8 efficiency or that we comply with the efficiency

9 standards.

10 Now, granted that that is already in place in

11 other areas in the standard, I would be willing to jump

12 ship and change my vote on the 10 gallon and reporting

13 of volume. I would prefer that we keep the commercial

14 unfired water heater storage tanks striking the storage

15 volume.

16 MR. MYERS: Excuse me. Jeff, could you speak

17 up just a bit, please?

18 MR. KLEISS: Sorry. Just saying that I would

19 be willing to revert to reporting volume on the

20 instantaneous water heaters, but would like to keep the

21 unfired water heater storage tank volume stricken. I

22 don't know that the group -- I don't know if we should
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1 vote one way or the other. I'm just giving you my

2 personal statements.

3 MR. EISNER: Do you want to take a break for

4 10 minutes and talk among yourselves? Would that help?

5 After this discussion?

6 MR. MYERS: This is Frank Myers. Just a

7 general comment on those two points. Reporting the

8 information, particularly if it's not public record

9 because you don't want a customer -- a user making a

10 choice based on where in the under 10 gallons that is,

11 you know, there is not a benefit to more gallons is

12 better or benefit to less gallons is better. It is

13 just instantaneous. It's not a part of the selection

14 criteria.

15 So reporting it to DOE I wouldn't have a

16 problem with as long as it didn't show up where the

17 public is making a choice based on that. That's just a

18 general -- that's my feeling on it.

19 I do agree with you on the storage volume,

20 that that one is not used for any part of the

21 efficiency parameters and doesn't really have a place

22 for collection.
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1 MR. BALLO: This is Tim Ballo. So now I'm a

2 little bit confused because people are willing to

3 report the information that has no value for anyone who

4 would be looking at this. But the information that

5 would have value, if I wanted to buy an unfired hot

6 water storage tank, I think I would want to know how

7 big it is. But that's the information I can't access.

8 MR. MYERS: This is Frank Myers. To respond

9 to that, the Department has said they would be more

10 comfortable in seeing the actual value rather than just

11 up or down on the 10 gallons. I don't see where that

12 is significant, but if -- you know, I'm saying that

13 that's one where I would not have a particular problem

14 with. It's not information that we have today. We

15 would have to go out and measure all of these units.

16 Many of them are so far under 10 gallons that we don't

17 bother measuring them. But if the Department feels

18 they really have to have that, then it's something that

19 could be done.

20 In terms of the energy parameters, if you get

21 a small storage tank or a large storage tank, it has to

22 comply with the exact same requirements. So in terms
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1 of energy description and selection, it has no value.

2 They can go to any customer's catalogue and select by

3 size. But in terms of any choice they make being more

4 efficient and less efficient, it has no value. So I

5 don't see where that should be in the DOE directory.

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

7 Doesn't the storage volume, though, affect how much

8 drawdown you can have? I mean, it is part of -- would

9 be part of the design selection criteria. Even as much

10 as if you had three people in the house or two people

11 in the house, you need to know the capacity in order to

12 make the correct selection.

13 So you would have efficiency, but the other

14 item you need is how much water you are going to use,

15 which is reflected in how much drawdown you have in

16 that tank. So it seems like --

17 MR. MYERS: I understand from -- this is

18 Frank Myers, PVI. I understand from a system point of

19 view you are correct; it has value. But from a

20 selection point of view, it makes no difference because

21 they all comply with the exact same requirement. So

22 there is not a "we should get them to do more of this
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1 one than that one." There is no benefit.

2 When you are deciding what size tank to buy,

3 you go to whatever manufacturer you choose to and you

4 buy the tank that you need, based on those criteria, if

5 that's what you're doing. But you don't buy one that

6 is more efficient or less efficient. They have the

7 exact same requirement.

8 MR. STARR: Well, it seems like, I mean, just

9 in a basic house where you have two people, you can

10 make a selection between 50 gallons or 80 gallons when

11 an 80 gallon is going to have more standby losses. So,

12 in theory, they would both be efficient in how they use

13 water, but one is going to have more standby losses.

14 So I would choose the smaller tank with the

15 same efficiency as the bigger tank.

16 MR. MYERS: That is not necessarily the --

17 you are -- I understand where you're going, but per

18 gallon you are going to have less standby loss with the

19 larger tank. But, again, it depends on what you need.

20 And all I'm saying is you go to anyone's catalogue and

21 you select by gallons. You don't need that information

22 in the DOE list to make a better choice. There is
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1 nothing about adding it into the DOE list that

2 encourages you or in any way helps you to make a better

3 choice. It's superfluous information there.

4 MR. STARR: The only other thing it does is

5 when you're trying to set up incentive programs you

6 know what your market has in terms of capacities. And

7 so then you are trying to set up a program and

8 understand what other things are out there, so you are

9 trying to match up attributes of the market to what you

10 have in data that you have collected about your

11 information.

12 So knowing what -- in other words, if you're

13 going to rebate for 50-gallon water heater tanks, you

14 have to know what tanks are on the market in order to

15 write up that this tank would meet that part of the

16 program. So from the stand of trying to set up

17 incentive programs, it does matter.

18 MR. MYERS: Okay. I don't see how, but okay.

19 I mean, if every tank in existence that is legal to

20 sell meets the exact same requirement, I don't see how

21 the program can -- they are either available or they're

22 not available as a tank, but there is no change in
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1 requirement. So having that information here does no -

2 - offers no benefit to incentive programs or otherwise.

3 MR. EISNER: Did you have a comment, Karen?

4 All right. Why don't we take a five-minute

5 break?

6 (Whereupon, a brief recess was taken.)

7 MR. EISNER: All right. Back on water

8 heaters. Any further discussion?

9 MS. ARMSTRONG: So our discussion -- I think

10 we do want some -- so for the first class, rated

11 storage volume is up there. I think that's something

12 that we want. The second one, for unfired water tanks,

13 we want some indication of volume, whether that be a

14 calculated volume, an estimated volume, some type of

15 volume. I don't know what the right words would be,

16 but some indication of volume for that one. The rest

17 we're fine with.

18 MR. MYERS: This is Frank Myers.

19 MS. ARMSTRONG: It could be your suggestion

20 of some type of capacity-type thing.

21 MR. MYERS: There was some discussion during

22 the break that on the second bullet up at the top for
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1 water heaters and hot water supply boilers less than 10

2 gallons that there might be increased acceptance if the

3 words were changed to the water volume in gallons,

4 because you don't really think about those as storage,

5 and there is no test technique for rated and measured.

6 So if it was just the water volume in gallons, that

7 would resolve quite a bit.

8 MS. ARMSTRONG: Can we do that for both of

9 them? Is that -- can that be the breakpoint for

10 everyone to be happy?

11 MR. MYERS: I was about to say --

12 MS. ARMSTRONG: Can we do that across the

13 board?

14 MR. MYERS: -- the same thing for the --

15 MS. ARMSTRONG: Yes?

16 MR. MYERS: -- second one.

17 MS. ARMSTRONG: Done.

18 MR. MYERS: I think you'd like to hear me

19 out.

20 MS. ARMSTRONG: No, she said okay.

21 MR. MYERS: It's in your best interest if you

22 heard me out, trying to help you out. Only worrying
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1 and thinking about you, Ashley.

2 In the second one, there is one additional

3 word that might be helpful and that's -- since it is

4 the storage we are talking about there, to say "the

5 stored water volume in gallons." And with that,

6 everything else looks right.

7 MS. MEYERS: So we're giving on one, too.

8 MS. ARMSTRONG: Great.

9 MS. MEYERS: That's what that --

10 MR. EISNER: Okay. For the record, are there

11 any objections?

12 MR. HALLEY: Are the cherries still on the

13 table?

14 MR. HUNT: Hi, this is Marshall Hunt, PG&E.

15 Hello?

16 MR. EISNER: Go ahead, Marshall.

17 MR. HUNT: Okay. I'll withdraw my objection.

18 MR. EISNER: Marshall, are you looking for

19 the cherries?

20 MR. HUNT: Yes, please. The big ones. Yes.

21 But I withdraw my objection. I just want to let people

22 know that there is this problem when we run programs
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1 that we need information. So let's try to do something

2 better. Thank you.

3 MR. EISNER: Okay. No objections? No

4 abstentions? Unanimous vote.

5 Are we ready for Verification?

6 MS. ARMSTRONG: No, one more thing, which is

7 there's not a slide for Neil, and this is where you

8 really get to have some fun -- the date. Now that we

9 have actually agreed to what will be submitted, the

10 Department is going to agree in good faith that we are

11 going to also agree on motors next week. And we are

12 willing to entertain dates at this time.

13 MR. THARP: Rusty Tharp with Goodman. Just

14 real quickly, if we could go back to the VRF slide.

15 I'd just like to make sure we add in the terminology

16 three --

17 MS. ARMSTRONG: Yeah. I got it.

18 MR. THARP: All right. You've got it.

19 MR. EISNER: Have you got everybody's vote

20 for that?

21 MR. THARP: Yes.

22 MR. EISNER: In writing? Okay.
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1 MS. ARMSTRONG: There is not a slide for

2 this, but the date right now is December 31st of this

3 year. We'll open the floor to you guys.

4 MALE SPEAKER: December 32nd.

5 MR. MYERS: This is Frank Myers with PVI.

6 There has been a wide variety of discussion within the

7 industry about why we need two years, why we need 18

8 months. Now I'm speaking -- that's discussions that

9 have been had. I'll speak purely for PVI, and that is

10 that we could -- we would like to have 18 months, but

11 we could get this done within 12 months.

12 MR. AMRANE: Karim Amrane, AHRI. I think we

13 have been on record several times asking for 18 months

14 from the publication of the final rule on the AEDM. So

15 I'm not sure when this rule is going to be out, but I

16 think that it would be appropriate to give us at least

17 18 months from that time.

18 MR. STEPHENS: Phillip Stephens, HTP. Do we

19 have an update on the AEDM final rule?

20 MALE SPEAKER: Good question.

21 MR. STEPHENS: You haven't gotten that issued

22 yet?
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1 FEMALE SPEAKER: Ashley's done.

2 MS. ARMSTRONG: That's on the record. So you

3 will see a proposal first. Obviously, we have agreed

4 to a bunch of different things. That's being fast5 tracked. That's all I can say, you know, as soon as

6 possible.

7 MR. STEPHENS: Phillip Stephens, HTP. I

8 think it will be difficult to really give a timeframe

9 until we see the final rule for the AEDM.

10 MS. ARMSTRONG: Well, we negotiated that,

11 right? So let's -- I can't say assume everything, but

12 that's where we're --

13 MR. STEPHENS: Could we say 18 months after

14 the AEDM?

15 MS. ARMSTRONG: That can be your suggestion

16 to the Committee.

17 MR. STEPHENS: Well, yeah, not just

18 publication but after the AEDMs become effective.

19 MS. ARMSTRONG: Well, that's from the final

20 rule date.

21 MR. FLY: This is Mark Fly with AAON. Do we

22 want 18 months after the AEDM, or 18 months after we
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1 have published this rule final? Because things could

2 change in part of the reporting requirements here

3 through the rulemaking process, I assume. We're not

4 locked down.

5 MS. ARMSTRONG: So you guys -- you have to

6 remember we voted on these with good faith, negotiated

7 effort. Give some credit here.

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

9 Assuming that things kind of remain similar to what we

10 have agreed upon, and it stays that way, would the

11 manufacturers be able to work on a different time

12 table? I mean, if nothing changes from now until the

13 final -- if everything we agreed on stays the same, it

14 seems like it doesn't need to start at the date that it

15 becomes published, that we could maybe give some time

16 on that time schedule.

17 The other part of it is I'm kind of

18 interested in, what sets this timeline, whether it's 12

19 or six months, or six, 12, 18? They seem multiple of

20 six is what I'm noticing.

21 And so it almost seems like we're negotiating

22 for, you know, I want six, you want 18, we're at 12,
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1 and so a better position would be is, what actually

2 needs to happen in order for the -- I mean, I guess

3 we've known for a couple of years that something is

4 going to happen or supposed to happen.

5 So there must be some readiness from the

6 manufacturers, and then helping to understand what the

7 regulations are going to be, which we have spent the

8 last two months working on. We have kind of a pretty

9 good shape of what that is, and so I'm kind of wanting

10 to understand maybe what some of the hurdles are that

11 are going to create a timeline of 12 months, of 18

12 months, or two years. It would be helpful to kind of

13 understand what those issues are.

14 MS. DANE: Mary Dane from Traulsen. I can

15 kind of give you a little background. For some of the

16 companies, it is going to be that we are going to have

17 to go back and we are going to look at groupings and

18 putting our AEDMs together. And even if you don't

19 start with that point, some of the requirements that we

20 have agreed to and voted on, such as the PDFs that we

21 need for submission, some of that is going to take some

22 time to set all of those up. So I would say that
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1 anything before 18 months, you know, with the rule

2 going into effect, would kind of be different and very

3 burdensome for a manufacturer.

4 MR. THARP: Rusty Tharp with Goodman. Go

5 ahead.

6 MR. STEPHENS: Phillip Stephens, HTP. I

7 guess my preference would be the lowest common

8 denominator or the smallest manufacturer. They are

9 going to have the fewest resources. They are going to

10 have the greatest impact to their overall business.

11 But by the same token, that would give the larger

12 manufacturers amazing benefit. They would have a lot of

13 extra time to go ahead and optimize every system they

14 have. So we don't want that either. So it's somewhere

15 in the middle, right?

16 MR. EISNER: Everybody is talking a set

17 number of months for the whole rule, and then certain

18 exceptions here we're talking about with respect to

19 small entities. Could you agree to something that would

20 give small entities more time than the larger

21 businesses? Could you agree to something where the

22 more difficult provisions would go into effect later on
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1 if that were possible, and other provisions would go

2 into effect earlier?

3 MS. DANE: Who would define that? This is

4 Mary Dane from Traulsen. Who would define who is small

5 and who is large and who has resources and who doesn't?

6 I mean --

7 MR. EISNER: There are some definitions that

8 are used in rulemaking in general under the Regulatory

9 Flexibility Act. But this group could agree to a

10 definition. So think about some of that in terms of

11 how much time you're asking for.

12 MR. BALLO: Another way this could be divided

13 up, for the residential products there is an annual

14 recertification requirement that varies by product. So

15 if there are certain products within the large group of

16 products that are covered by this group for which there

17 aren't as many changes, there aren't as significant

18 burdens associated with the certification, those could

19 go more quickly, and then more time would be given for

20 the products for which more would have to be done. I

21 don't know that we need to have one date for

22 everything. Actually, that might not even be a bad
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1 idea, just in terms of everybody crushing to get

2 everything done all at once.

3 MR. EISNER: I mean, there is another

4 possibility built on that, which is to have phase-ins.

5 You get your first third done in six months, the second

6 third in a year, and the third third in a year and a

7 half, phase in like that. Again, I don't know what's

8 workable, but don't restrict yourself to it's got to be

9 the lowest common denominator for the hardest company

10 to meet this standard, because there are a lot of

11 people that are going to push back and say, "You need

12 to get to efficiency faster."

13 MR. HON: This is Charlie Hon. I'd like to

14 ask you guys, when were the requirements for every one

15 of these categories actually put into code one way or

16 another? I know that some of ours were 2007.

17 MS. BARHYDT: The certification or the

18 standards?

19 MR. HON: The standards.

20 MS. BARHYDT: The standards vary a lot by

21 product. I mean, it would take me quite a while to

22 pull up all of the different dates.
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1 MR. HON: Are any of them very new?

2 MS. BARHYDT: Cracks are new.

3 MR. THARP: Rusty Tharp with Goodman. I'll

4 throw in, I like Tim's idea of by product class

5 somewhat, because some of these, you know, commercial

6 warm air furnaces would probably be a little bit easier

7 for the certification information than HVAC. But yet

8 we also need to realize that a lot of this information,

9 as Mary indicated, is true for HVAC, that we will be

10 looking at what we want to -- what product classes,

11 what areas, what different products we want to put

12 under which AEDMs.

13 We may have 10 AEDMs that we do for all of

14 our product classes, and that will take some time to

15 put that information together, you know, whether we

16 want to do it for heat pumps or air conditioners or

17 combine them or, you know, where we want to put our

18 split for our AEDMs. So we need to take a look at our

19 test data, our results, our simulation, et cetera, to

20 put all of the accurate -- as accurate as possible

21 information obviously for our AEDMs and for each

22 specific product.
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1 We have to make sure we have the available

2 test data or redo testing for those models. We also

3 have a lot of other DOE activities on our plate. We've

4 got the commercial IER rulemaking that's due by the end

5 of the year also, right? And there may be activities

6 that we have to do for that.

7 You know, many of us also in the residential

8 product arena -- and we have product that we are

9 addressing for January 1, 2015, that we are -- you

10 know, our engineers are in the process of spending a

11 lot of time dedicated to that. We've got the furnace

12 fan rulemaking and all of these other rulemakings that

13 are in process that affect the same resources that

14 would be -- or at least a lot of the same resources

15 that would be working on this information.

16 So that's why I will follow suit with the

17 prior comments that we think off the cuff 18 months

18 would be good in order to get all of this information

19 together and be able to submit it, potentially rolling

20 some out earlier than later, and go down to 12 months

21 would be the minimum that we would like to see.

22 MS. MEYERS: And for Rheem, we are a little
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1 bit unique because we not only have everything that

2 Rusty just mentioned, but also we are affected by water

3 heaters and boilers also, which are part of this. And

4 we also have new residential efficiency standards for

5 water heaters coming in 2015 as well as on the A/C

6 side. So we are probably, I could bet, the most

7 affected company in the room because this affects

8 essentially every single product that we build.

9 MR. MYERS: This is Frank Myers, PVI. Two

10 other thoughts. One, where the people around this

11 table, myself included, have been involved with this

12 and we have one level of understanding of how likely

13 things are to be coming out the way we negotiated it,

14 most of the rest of the world has very little faith in

15 the process until the rule is there and they have to

16 comply and they have a known date. So they're not

17 getting ready like a number of us are getting ready

18 now, because they are going to wait until the final

19 rule is out.

20 Another one to put in the list of all of the

21 things that are in the hopper right now, and another

22 reason that the 18 months sounds better than a shorter
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1 period of time, is that for many of us the same

2 resources that do our new product development come out

3 with higher efficient equipment, that sort of thing,

4 are the ones that are going to have to do this.

5 And if we tie our resources up doing this, we

6 are not coming out with more efficient products. And I

7 assure you, everyone around this table, the bulk of

8 their new product work is on higher efficient

9 equipment. So we wouldn't want to have things bog down

10 to the point where introductions into the marketplace

11 went on hold while we were fast tracking reporting

12 information into DOE.

13 So where our company could do it in 12

14 months, I fully support the 18 months.

15 MR. BALLO: One other idea for flexibility,

16 someone earlier had mentioned, "Well, we won't know

17 what the requirements really are until the final rule

18 because things could change." The way EPA sometimes

19 does these things is a proposed rule comes out with a

20 proposed effective date, and that date will be

21 maintained provided nothing changes in the final rule.

22 And for any elements as to which things change,
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1 additional time will be granted for certification. So

2 that could be one way to address the possibility that

3 things might change in the final rule.

4 MR. EISNER: Other comments? Other

5 suggestions?

6 MR. HALLEY: Geoff Halley, ABMA. From my

7 point of view, I think the sort of datum for the staff

8 point, whatever the time period is, has got to be the

9 approval of a waiver that, you know, the ABMA members

10 are going to have to apply for because it's apparently

11 a fairly slow process to get a waiver approved, from

12 what we're hearing.

13 I mean, I only know of one at the moment,

14 which is, you know, for Pete Moldy's company. And I

15 don't think he has heard anything in probably close to

16 two months.

17 MR. CYMBALSKY: So for waivers, our goal is

18 60 days to try to clear that --

19 MR. HALLEY: Okay.

20 MR. CYMBALSKY: Some do take longer than

21 others, some don't.

22 MR. HALLEY: So, you know, they're not going
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1 to be able to do much until they have got the waiver, I

2 presume, and do some preparation, but not -- but can't

3 get it completed.

4 MR. EISNER: Harvey?

5 MR. SACHS: Harvey Sachs. I sometimes feel

6 like a blind guy trying to understand the elephant one

7 leg at a time. I have been involved in a couple of

8 processes that gave me impressions of the time scales

9 needed.

10 Two observations come out of the consensus

11 process a few years ago for residential air

12 conditioners, heat pumps, and furnaces. And one of

13 them was to reiterate -- one of them sort of adds to

14 the comments about staging because of resource

15 limitations within the firms. Certainly, the

16 manufacturers at that time wanted to have the furnace

17 rule and the air conditioner rule not be simultaneous

18 because of resource constraints, best- laid plans of

19 Mice and Men and all that.

20 The other was that on the furnaces they were

21 fully prepared to meet it in 18 months, and we also saw

22 an 18-month period for the -- after the last appeals
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1 for the 2006 air conditioner standard. That was an

2 enormous Herculean effort by the manufacturers, and

3 this is certainly a much smaller effort and we

4 certainly -- not every product -- every manufacturer

5 had a full product line on January 1, 2006.

6 But I think it's an indication that no more

7 than 18 months is required in the worst case based on

8 this limited perspective I have of industry performance

9 in those proceedings.

10 I'd like to also suggest that there are

11 benefits to manufacturers in some particular

12 categories, I think from providing earlier dates rather

13 than later, particularly those who are in product

14 categories where there is a lot of customization, a lot

15 of options, relatively small production numbers, and

16 large opportunities to smartly use AEDMs. And I wonder

17 if some of these categories within CRE, for example,

18 might want to be ready in 12 months rather than in 18.

19 I'm asking that because I'm trying to get an argument.

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

21 understand what you're asking. I still believe that it

22 will be dependent on the company size and the ability
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1 to dedicate resources to this. What I see happening is

2 like in my organization there is a regulatory person,

3 and, you know, as such I am responsible for safety and

4 some other things that, you know, happen on a daily

5 basis. And then to manage this program and another, it

6 is going to be a very strict -- it's going to be hard

7 to dedicate extra resources.

8 And I'm sure for other smaller companies, I

9 know Phillip speaks up a lot for his, you know, there

10 is a lot of requirements in this, and then, as Paul

11 pointed out, coming online with the AEDMs and having to

12 do verification for testing with that, and all of the

13 other things we're running, it will be difficult to do

14 it in 12 months. I feel a lot more comfortable with

15 the 18-month date.

16 MR. KLEISS: How about 15 months?

17 MS. DANE: Well, I know that's an odd number.

18 MR. SACHS: It's not that odd.

19 MS. DANE: No. I mean, even if there was

20 even some discussion of the difference between it

21 coming into effect and complying with it and

22 enforcement, I mean -- I beg your pardon?
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1 MR. SACHS: This is Harvey again. I think

2 that's all on the table.

3 MS. DANE: Yeah. So I was going to say, I'm

4 still waiting for 18 months.

5 MR. THARP: I'll just throw in, too, that,

6 you know, earlier compliance is not an issue, right?

7 So if 18 months is granted for those that need 18

8 months, if another company can do it in six, or seven

9 even, or five, that they could do it in a shorter

10 period of time.

11 MS. DANE: I promise not to wait until 17-1/2

12 months to start.

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

14 I mean, from a business perspective, if you do 18

15 months you guarantee that you are going to have a

16 planning cycle before you allocate your engineers. My

17 company jumps into their planning cycle about August,

18 so we are going to start here pretty soon. Could we do

19 it in six months? Yeah, I suppose we could. But you

20 are reallocating resources towards something that is

21 already planned, so that's our reason for wanting

22 something plus a year, because we can plan for it, we
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1 can allocate the resources, and we have better

2 visibility to -- how we are going to allocate our

3 manpower.

4 MR. KLEISS: Jeff Kleiss, Lochinvar. I

5 think, you know, most people could agree to 18 months

6 right now. But if we want to try and get a little bit -

7 - push things forward a little faster, I would suggest

8 that maybe we table this, we take this out and discuss

9 it in our different product type groups, and see if we

10 can get a more aggressive schedule by product types and

11 have that ready for discussion next week.

12 MR. DOPPEL: Paul Doppel with Mitsubishi. It

13 seems that maybe we are getting a little bit ahead,

14 because, you know, once we finish this process, aren't

15 there some like rulemaking procedures that have to be

16 followed? And so, you know, when is this actually

17 going to be finalized? My understanding, there is a

18 possibility that there could be changes to what we

19 agree to here, if there is public --

20 MS. BARHYDT: There can be. I mean --

21 MR. DOPPEL: -- comment on that.

22 MS. BARHYDT: -- we do publish a notice of
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1 proposed rulemaking, and there is an opportunity for

2 comment. I mean, certainly the idea behind this is

3 that with everybody sitting at the table representing

4 the various groups, certainly we hope that we don't get

5 adverse comments to whatever we agree to.

6 MR. DOPPEL: True. But if it did happen --

7 MS. ARMSTRONG: But another part is, to

8 change the date also has to go through notice of rule

9 and comment. I mean --

10 MR. DOPPEL: Okay.

11 MS. ARMSTRONG: -- that could also change.

12 So, you know, give us our best effort here to negotiate

13 what we want, and, yes, both of them have to go through

14 notice and comment. So the best bet is to put them

15 through as soon as possible. Otherwise, that December

16 31st date is looming.

17 MR. DOPPEL: Right.

18 MS. ARMSTRONG: Because we need notice and

19 comment to take that one out, too.

20 MR. DOPPEL: Yeah. See, I mean, you're

21 hearing from most of the people that -- like right now,

22 if we could take what we've agreed to and run with that
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1 as final, you're saying 12 months as a minimum. So, I

2 mean, we don't even -- December 31st -- were you

3 talking December 31, 2014?

4 MS. ARMSTRONG: No. The rule is 2013. The

5 date on the books is for this year, right?

6 MR. DOPPEL: I know. I know. I was --

7 MS. ARMSTRONG: I know.

8 MR. DOPPEL: Okay. But --

9 MS. ARMSTRONG: I was just confirming.

10 MR. DOPPEL: Even if we started now, I mean,

11 it would be very difficult for I think anybody to get -

12 - we would have to assume that everything would be as

13 agreed to, and that would be extremely, extremely

14 difficult.

15 MR. STARR: This is Louis Starr, NEEA. That

16 sounds like Jill. Let her go.

17 MR. EISNER: Go ahead, Jill.

18 MS. HOOTMAN: Thanks. Yeah, I mean, I would

19 agree, Paul, and the problem is, I mean, you guys have

20 to have your forms all ready, and programming, such

21 that we can do this uploading of this information. We

22 can't be sitting here in December and you hand us a
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1 form, and then that takes us another six months to get

2 that in, get the data in.

3 So, you know, that -- to me, I need to know

4 how long the notice and public, you know, comment

5 period is. Is that another four to five months? And

6 then, are we going to see programming of the sheets and

7 the upload sometime after that?

8 You know, some of our work can be done

9 earlier like Rusty has said. You know, we can do some

10 things about checking our models and things. But when

11 it comes to this actual PDF data, et cetera, and the

12 uploads, right now I have one person doing that for all

13 of this product. You extend that -- you make that

14 happen in something shorter than a year, I need two

15 more people.

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

17 One thought that Jeff had was people going back and

18 checking on their products and seeing how it would work

19 seems like a good idea. The other aspect of that is

20 maybe splitting it into, what Neil suggested, into

21 small and large companies, too.

22 And it sounds like it also can be if they
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1 have lots of products that's going to be another --

2 companies have lots of products. But kind of an

3 understanding of how it is going to have an impact on

4 those different categories can maybe help set maybe

5 different standards for different -- or different size

6 companies. And I think that would be useful to

7 understand based on that.

8 MR. WHITWELL: Bob Whitwell from Carrier.

9 Just because -- the size of the company doesn't mean

10 that there's more people. We don't have people sitting

11 around doing nothing, so, you know --

12 MR. STARR: We are typically more

13 bureaucratic as well and slower.

14 MR. WHITWELL: Yeah.

15 MR. FLY: This is Mark Fly from AAON. I

16 mean, the other thing is, you know, we've got to -- the

17 start date we can't assume is from today, because all

18 of the people in this room know what's going on. We

19 are not -- not everybody in this room represents

20 everybody in the industry, and there are people that

21 aren't even members of AHRI who build air conditioning

22 equipment that have no idea and aren't participating.
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1 So, you know, at least no one is really going

2 to know what it looks like until the rule gets

3 published in the greater world. And the other thing is

4 a lot of the smaller companies, especially the custom

5 companies that are not participating in this, probably

6 because of limited resources, may have the highest

7 number of listings because of their product mix. And

8 they are typically smaller companies, so that's

9 something to consider.

10 You know, I support the 18 months, but it

11 needs to be from some line in the sand where we are

12 fairly confident that we know what the scope of work

13 is.

14 MR. BAUMAN: This is Jeff Bauman from

15 National. There had been discussions earlier about

16 percentages and regulatory specialties and things.

17 I'll just say, we've got -- a significant part of our

18 engineering department is sitting here. I mean, there

19 is nobody in our company that does regulations. You

20 know, we do what we can.

21 So, but I am understanding all of -- you

22 know, bigger companies have different challenges to it.
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1 But I think splitting it up or trying to get more

2 complicated by categories, I think we ought to just

3 come up with a date that is, you know, acceptable

4 across the board I'll say.

5 I mean, it seems like somewhere in here we

6 are between 12 and 18 months from publication with

7 final notice. It seems like that is kind of the group

8 that we are working with, and I don't think -- but it

9 seems like we're not -- you know, we're not talking

10 about one group saying three years and one group saying

11 two months or at, you know, the end of this year. So

12 it seems like we're not that far off from getting to

13 something that maybe we can all agree upon and get this

14 thing put to bed.

15 I know our management, and I'm sure all the

16 companies around here, the management is asking about,

17 hey, when is there going to -- they are looking at this

18 end-of-the-year date, and we are all, you know, getting

19 nervous about it, and we want to make sure that we have

20 - - and we appreciate you bringing this up. And I'd

21 really like to get this resolved, you know, before we

22 go home today, or there's tomorrow.
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1 MR. WHITWELL: So a question from earlier.

2 I'll bring it up again. So are we talking about

3 implementation date meaning manufacture date, or is it

4 date of sale? Because there are some products, not a

5 lot, but there are some products that are inventory,

6 and so that would have to -- you know, we have to plan

7 out how to deplete the inventory if it's date of sale.

8 If it's date of manufacture, it's more straightforward.

9 MR. DOPPEL: Paul Doppel with Mitsubishi.

10 The other thing that would be important also I think is

11 whatever timeframe we agree to that it be like 12

12 months or 18 months when the final rule is finalized,

13 rather than from now, because we have been through that

14 with the AEDM and that has gotten us into trouble.

15 MR. BAUMAN: This is Jeff Bauman again from

16 National. I guess one question I would follow up on

17 kind of, Bob, is what we are talking about here is

18 certification deadline, when we have to certify

19 products, but it's not changing the regs as far as what

20 products have to comply. I mean, that stuff is already

21 in. I mean, we've got, okay, thanks for the

22 clarification there. I see the nods of DOE saying that
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1 it's a correct assumption.

2 Also, I just wanted to go back real quick,

3 something Harvey mentioned earlier about some companies

4 being ready sooner, there being an advantage there. I

5 mean, we have products -- we have done a lot of

6 testing. We would expect to be done sooner actually

7 than, you know, 12 or 18 months.

8 I think, you know, for DOE to say -- and I

9 assume there is going to be some -- you know, from a

10 certain time you are going to start accepting data, and

11 from that point on until whatever your deadline is, 12

12 or 18 months, in that period -- hey, people, they can

13 get their information in faster. And if that becomes

14 public information, it becomes some type of a sales

15 advantage, then great. So I don't think that

16 necessarily has to put -- you know, affect the

17 deadline, I'll say, from the objective of potentially

18 having a competitive advantage.

19 MR. BALLO: I have heard a couple of people

20 mention that putting the PDFs together is going to be

21 one element that is going to take a particularly large

22 amount of their time. And I'm wondering if it would be
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1 better to split that off, you know, to get the

2 certification, basic information into the database for

3 the public to access, and have an additional period of

4 time to put the PDF together, to the extent that is a

5 big burden.

6 MR. HON: This is Charlie Hon. Why can't,

7 for a designated period of time, DOE just request the

8 PDF when you decide to test that product? That way you

9 don't have to wait for them to write the PDF. They

10 could give a one-month or two-month window to prepare a

11 PDF for that product, thereby eliminating the argument

12 on the PDFs.

13 MS. BARHYDT: So if you don't have to prepare

14 a PDF, how much are you going to shorter the time

15 period that you have already thrown out?

16 MS. MEYERS: So back to Bob's question, so is

17 it going to be based upon manufacture date?

18 MS. BARHYDT: So the certification would be

19 for whatever is in distribution in commerce at the time

20 that you file the certification. The issue, at least

21 what I thought Bob was asking about earlier in the day,

22 was if you have some new model, some new concept, that
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1 you haven't already certified that is not subsumed

2 within a basic model, at what point do I have to submit

3 a certification for that?

4 I thought that's what you were asking earlier

5 today, but maybe I had misunderstood.

6 MR. WHITWELL: No. I was actually talking

7 about current product that could be in inventory. But,

8 yes, that's a good question.

9 MS. BARHYDT: So the certification would be

10 for whatever is being distributed in commerce from that

11 point forward. So sold.

12 MR. WHITWELL: Sold.

13 MS. MEYERS: So that might could be an issue,

14 so -- because you could have --

15 MS. BARHYDT: Yeah. So if it's already with

16 a distributor and somebody else is selling it, it's not

17 subject to the certification provisions. The

18 distribution in commerce is by the manufacturer.

19 MS. ARMSTRONG: So your warehouses. Your

20 control, right?

21 MR. THARP: This is Rusty Tharp. In the

22 Federal Register Notice of the way of the
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1 certification, at the end of last year DOE said, "The

2 Department will refrain from selecting models for

3 assessment testing for which the manufacturer has

4 submitted a valid certification report in CCMS."

5 So I might suggest that we would agree to 18

6 months and DOE would issue a similar statement that for

7 the period up until the effective date -- that way

8 those manufacturers who chose to try to get it done in

9 six months would have a year reprieve.

10 MS. BARHYDT: And if more of you had taken

11 advantage of this fabulous offer, I might be more

12 inclined to go with it.

13 However, given the very weak response we have

14 had to this offer, I am actually not inclined to extend

15 that kind of an offer again.

16 MR. THARP: We assume that this type of

17 activity would be going on.

18 MS. BARHYDT: And we're assessing testing.

19 MR. EISNER: Other comments?

20 MS. MEYERS: I think from our viewpoint we

21 might could agree on a date less than 18 months, if it

22 was based upon the date of manufacture, because you
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1 could have a model in inventory that has maybe been

2 there two months or so that may have been certified or

3 grouped differently than something -- than this

4 procedure is going to require.

5 So that -- I can see that transition being

6 very difficult for us. And it may not have a PDF or --

7 I don't know. If it could be based on date of

8 manufacture, it makes it much easier for us to manage

9 the program.

10 MR. EISNER: Can you move a product to a

11 different category to the rule if it has already been

12 categorized and --

13 MS. MEYERS: Yeah.

14 MR. EISNER: Can you move a product from one

15 category to another after the rule comes out?

16 Manufactured before the date of the rule, sold after

17 the date, is it okay as long as they have changed it

18 and you have used a different basic model to come out

19 with the data?

20 MS. BARHYDT: I don't think that would

21 address what Karen is saying.

22 MS. MEYERS: I don't think it would either,
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1 but, you know, if we are not having to work backwards,

2 and we are saying all products that we manufacturer as

3 of X date must be certified per these new requirements,

4 it is easier for us to plan and manage a project like

5 this, which is going to be pretty massive, so that we

6 can start preparing, and then --

7 MS. BARHYDT: So if I said we would give on

8 that, and it was manufacture, could you do six months?

9 MS. MEYERS: No. There is no way. No way.

10 MS. BARHYDT: And no PDF.

11 MS. MEYERS: No way.

12 Not to do commercial HVAC, commercial water

13 heating, and boilers. Absolutely no way. I was

14 thinking 15.

15 MR. STANONIK: Frank Stanonik with AHRI. I

16 would suggest one way to get around this question of

17 date of manufacture is that at least for the initial

18 submission of the certification reports, because we

19 have nothing right now, right? We are putting

20 something together here. At least for that initial

21 certification there should be a choice that the

22 manufacturer can enter which would be I'm going to say
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1 manufacturer discontinued.

2 Right now, Laura, you know, we have different

3 -- for our own valid reasons, different definitions of

4 "discontinued." But if for that initial certification

5 the manufacturer was able -- was allowed to identify

6 manufacturer discontinued, which means "I used to make

7 them and they are still out there for sale, but I make

8 them no more" --

9 MS. BARHYDT: I'm selling off my stock.

10 MR. STANONIK: Yeah. Right. That might

11 solve some of this, because in fact then effectively

12 what they will be reporting as their current line is in

13 fact things that are being made as of that date.

14 MS. BARHYDT: But, Karen, you would still

15 need to submit that I am selling this product. You are

16 just identifying it as discontinued. Does that

17 actually address your concern?

18 MS. MEYERS: I think it addresses mine. Does

19 it meet your requirements? And like we have products

20 in our -- I mean, we're dealing in product now that's,

21 you know, sellable but not buildable, because we are no

22 longer building it. But if it's still in stock, you
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1 can still sell it. And then we have, you know,

2 products that are discontinued. You can't build it;

3 you can't sell it. So I think from our standpoint we

4 could, but how does that work in with your

5 certification? So --

6 MS. BARHYDT: So because for us we are still

7 meeting the -- you are certifying everything that you

8 are distributing in commerce, and it's -- you are

9 basically designating "I am no longer making this."

10 That is fine. I mean, we can live with that. The main

11 thing is that everything that is being distributed in

12 commerce is certified.

13 MR. STANONIK: And let me interject something

14 here, because it was an assumption behind my suggestion

15 that I want to make sure everybody appreciates is,

16 okay, as operators of efficiency certification

17 programs, you know, notwithstanding whatever we are

18 talking about here, you know, I would still say that

19 for the products I am talking about in fact there still

20 had been some certification at some point in time,

21 although it was not "DOE certification."

22 And so I am making an assumption that in most
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1 cases these discontinued models in fact would probably

2 be covered by somebody's AEDMs anyhow, because they are

3 going -- I would think in most cases, you know,

4 manufacturers are making evolutionary changes, not, you

5 know, complete overhauls of products.

6 MR. STEPHENS: Phillip Stephens, HTP.

7 Stereotypically, if there is anything to do with an

8 increase in efficiency, our company fully supports it

9 and wants it to happen as fast as possible. But in

10 this situation everything we make is going to be

11 affected in the next few years. And it -- I don't

12 think we could do less than 18 months.

13 MR. FLY: Mark Fly with AAON. I know from

14 our company's standpoint the PDF information is one

15 parallel path that we have got to do. But we are also

16 going to -- I also feel like we are going to be doing

17 some testing. We've got to verify our AEDMs. We

18 probably want to test some models, which is not the

19 same resources, strictly speaking.

20 So part of that 18 months is I think it will

21 take 18 months for me to get through the testing I feel

22 I need to do to be confident, probably testing beyond
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1 what you are going to require, but testing that I feel

2 like I need to do to make sure that we are confident in

3 what we are doing.

4 MS. BARHYDT: So from the Department's

5 perspective, we know that we have received comments for

6 18 months from the final rule for the AEDMs. But we

7 have negotiated different AEDM provisions that are

8 considerably less burdensome than what was originally

9 proposed.

10 We have heard from -- many of you referred to

11 your AEDMs. We know that you are all making ratings.

12 The standards have been in effect for a long time. I

13 don't understand why you aren't in a better position to

14 be able to use new AEDM provisions in a shorter

15 timeframe than 18 months after an AEDM final rule. I

16 mean, to me that says we have had two years, nothing

17 has happened. We are negotiating this now; nothing is

18 happening. We are going to go through an entire

19 rulemaking process, which we all know is not as fast as

20 we might like, and nothing is going to happen.

21 And then starting on that day it is going to

22 take me 18 months to get to where I can actually
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1 certify something. And I don't understand why it takes

2 18 months.

3 MR. AMRANE: This is Karim Amrane, AHRI.

4 Laura, I mean, two years happened, but the rule has

5 never been finalized. So before --

6 MS. BARHYDT: We have a final rule requiring

7 certification.

8 MR. AMRANE: No, no, no. That's --

9 MS. BARHYDT: Yes. We have been very

10 responsive in postponing that deadline.

11 MR. AMRANE: I'm talking about the AEDM. I'm

12 talking about the AEDM. The AEDM has --

13 MS. BARHYDT: There are AEDM provisions for

14 everyone except for the CRE.

15 MR. AMRANE: Yes. But those AEDM

16 requirements are different now. They have changed. So

17 do you want the manufacturers to invest time and

18 resources to develop something that will be obsolete?

19 MR. HURST: We already did it with regional

20 standards. I mean, we wasted perhaps millions of

21 dollars developing product that we don't even know if

22 it's going to go into effect. I mean, kind of a sore
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1 subject with us, and I'm sure it's with you as well.

2 But those are real dollars and real investment towards

3 -- unfortunately, we play this game and we don't know

4 when they really go into effect.

5 So we are pretty gun shy about developing

6 product or process or systems to do something that we

7 don't know is going to happen.

8 MS. ARMSTRONG: Yeah. So I think Laura's

9 point, though, was one of you have previously asked for

10 18 months from our final rule, given the proposal that

11 you saw before. And what we did initially when we got

12 into this is voted to bring in AEDMs. We negotiated

13 AEDMs around what you guys thought you could handle,

14 what we were comfortable with. We thought the result

15 was far more workable for everyone. It required

16 significantly less testing.

17 So what Laura's point of view is, the number

18 can't be the same. In other words, we came to the

19 table, you guys came to the table, we all worked

20 together. And if we're talking from the point of a

21 final rule, take away the fact that, yes, you need to

22 know what the final rule is going to be, from the point
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1 of the final rule, what is the new number if you have

2 now seen what the AEDM provisions may look like.

3 Because they were far different before, and you are

4 still saying the same number.

5 MS. MEYERS: I mean, we asked on timing at

6 the very first meeting. I mean, that was one of the

7 questions that we asked, you know, what is the timing

8 of this? What is the timing of this? And there's a

9 statistic, and I don't know if this number is exactly

10 right, but in the last three years there has been 97

11 rulemakings come out from DOE that cover this product,

12 cover water heating and residential and commercial

13 HVAC.

14 So there has been test procedures, there has

15 been like almost 100 in the last three years. So there

16 has been a lot of activity that we have been trying to

17 manage. So, you know, I think that's the reason.

18 There may be some products that we can do shorter, and

19 I think it was Jeff or somebody who said, you know,

20 could we maybe do, you know, small water heaters in a

21 shorter timeframe or three phase less than five ton in

22 a smaller -- in less than 18 months? Perhaps we can do
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1 that.

2 MS. BARHYDT: But we had a proposal that was

3 going to require five tests for every single product

4 class. We are down to two for super-groups of product

5 classes. We have dramatically reduced the amount of

6 testing required in our proposal that we agreed to, and

7 yet the number hasn't changed.

8 MR. THARP: Laura, this is Rusty Tharp with

9 Goodman. I will say that, at least for my company,

10 even though the minimum requirement is still two tests

11 for a very broad range, we would still do -- we would

12 likely do something like one for heat pumps less than

13 10 ton, another one for air conditioners less than 10

14 ton, and we will look at test data for those, because

15 the reality is is you're doing your computer

16 simulations. There are tweaks that you do to have the

17 computer simulations match the test data and to look at

18 how the product operates.

19 And, you know, depending on whether one

20 manufacturer -- and we may be using one type of heat

21 transfer technology, smart coil five millimeter, in

22 some products. We may be using, you know, different
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1 tube diameters, micro channel, and so these various

2 ranges of products we would likely be having separate

3 AEDMs for each one of those.

4 And it will take time for the engineering

5 groups to look at all of these and determine what is

6 the best and most accurate according to the latest

7 rules that we need to do. So that is -- you know, from

8 my standpoint, having been in engineering for 26 years,

9 I think a year is reasonable for that type of activity,

10 along with all of the other activity that is going on

11 as far as regular business.

12 MS. BARHYDT: So, Rusty, you -- and I don't

13 remember if it was specifically you, but a number of

14 people have said, "We have software that estimates

15 efficiency." And you have already developed software

16 that estimates the efficiency of your products. And

17 presumably you already have test data, because you are

18 an AHRI member and you have verification testing done

19 on a regular basis.

20 And presumably that testing is done in

21 accordance with the DOE test procedure. And so if you

22 already have a model, and AHRI members already had a
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1 five percent tolerance, and we have talked about a five

2 percent tolerance, so presumably your model is already

3 within the five percent.

4 So, again, what do you have to do new that

5 you don't already have?

6 MR. THARP: This is Rusty with Goodman. Part

7 of it is the documentation. And, again, going back to

8 our - - you know, we feel that what would probably be

9 most accurate is to break it up for my company probably

10 in various capacities or various product types -- A/C,

11 heat pump, et cetera, you know, maybe do one for water

12 source, one for air source, you know, separate one for

13 PTAC. So we have all of these various groups, and we

14 would feel that, you know, it's -- we need to go look

15 at the test data, look at the simulations, and see what

16 is the most accurate way to make the predictions under

17 the latest rules, to make sure that we're in compliance

18 for every product that we make.

19 MS. BARHYDT: So maybe -- let me word the

20 question a little bit differently. You say that "under

21 the new rules," but the new rules set up a framework.

22 They don't actually -- the AEDM provisions don't
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1 require specific things other than that you have tests

2 and that those tests be within a certain percentage of

3 your estimation.

4 So what is it that -- so from my perspective,

5 it seems like you have a spreadsheet that says, "Well,

6 this was my test data and this is the estimation, and

7 it's within five percent, so I can certify this." It

8 meets the requirements of the reg. What is it that --

9 I just - - I honestly -- I don't understand what it is

10 that I'm missing from that middle part of the analysis.

11 MR. STEPHENS: Phillip Stephens, HPT. I

12 think a different -- a paradigm shift might be in

13 order. Before when we have done this kind of thing, it

14 has been just a handful of product classes, and

15 manufacturers have been able to respond in 12 to 18

16 months. And now you are looking at all of these

17 product classes together, and we are still saying 12 to

18 18 months.

19 So I think there is a tremendous improvement

20 that we are making here. But just as a frame of

21 reference -- and I am going to put AHRI on the spot --

22 with the recent residential boiler rerate, all of the
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1 condensing residential boilers have to be rerated this

2 year; right? That happened -- the notice came out in

3 December of last year or late November.

4 Do we have a percentage of all the models

5 that have actually been rerated in the residential

6 boiler industry? Because I'm sure not all of them have

7 yet. And that was just doing a heat-up and a cool-down

8 test, but it has affected every condensing residential

9 boiler. And it is -- yes.

10 MS. BARHYDT: This doesn't require all of

11 that testing.

12 MR. STEPHENS: But there are other associated

13 instances. It is very much akin to a tolerance

14 analysis. Tolerances always accumulate. They never

15 subtract. They never reduce. And we are looking at

16 the uncertainty with an AEDM., we are looking at an

17 uncertainty with each product line, and we are looking

18 at the impacts to all of our resources for that.

19 And I don't think there is a manufacturer in

20 here that only has products in one category. I may be

21 wrong about that. But we all have multiple variables

22 that we are concerned about. And the farther it gets
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1 out into the future, the more uncertainty it has.

2 MR. AMRANE: Karim Amrane, AHRI. And we need

3 to keep in mind all of the manufacturers, besides those

4 who are around this table, who have not heard at all

5 the discussions we have been having the last three

6 months. So we need to keep in mind that -- too, those

7 folks who have to find out about all of this, and to be

8 ready for all of this. And I can tell you that not

9 every manufacturer has the same capabilities in terms

10 of developing computer simulation tools or things like

11 that.

12 So I don't think that 18 months is reasonable

13 to be ready for compliance when you have to understand

14 that many manufacturers would find out about it for the

15 first time when this final rule would come out.

16 MR. MYERS: This is Frank Myers, PVI. To add

17 to that, Karim, in addition to manufacturers that are

18 just finding out about it, Laura, you talked about the

19 manufacturers that are in the certification program

20 that already have all of this information. There are

21 lots of us that are not in that certification program

22 and don't have all of that. We have what we have, and
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1 it is not what we need. So we have to generate what we

2 need.

3 We have not been designing our products with

4 an AEDM. We have been testing to make certain that

5 they comply, but we will do that during our development

6 cycle, not on every variation, but we are certain that

7 every variation is covered. But we don't have test

8 data on it, so we have a lot of testing to do to

9 develop our AEDM beyond validating it according to what

10 we have agreed to here for the AEDM. So we have to

11 create that entity.

12 The reason that I feel like I was able -- am

13 able to do it in 12 months is because I have been here

14 in the middle of the negotiation, I know what we agreed

15 to, and based on that I have already begun. But if you

16 add that onto what people that are not in this room are

17 doing, that is their 18 months.

18 You know, I've got it only because I have the

19 privilege of being involved with everything here. So I

20 think the 18 months is not unreasonable. And you

21 talked about, well, it was 18 months before; how can it

22 still be 18 months? If I had known what I know now, I
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1 probably would have been calling for 36 months or 24

2 months before.

3 So the fact that that's what it was was based

4 on a very poor understanding of what all was involved.

5 We have now gone through every line, every detail, and

6 based on that what this group is -- many in this group

7 are saying is 18 months.

8 MR. DOPPEL: Paul Doppel with Mitsubishi.

9 So, you know, even those of us who have had

10 verification testing done by AHRI, and, you know, all

11 of that was based on tests that were done to get those

12 ratings. So to do an AEDM is a new process, and it is

13 -- you know, we don't want to just do two tests and

14 guess at something, and then find out that we missed

15 it. You know, it is going to -- it will probably take

16 more than -- two tests is the minimum.

17 But I'm sure most manufacturers will be doing

18 more than that to make sure that what -- the results

19 that we're getting are going to be within the

20 acceptable limits, and that, you know, we are certain

21 that we are going to be putting out numbers that are

22 fairly accurate.
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1 MR. HON: Charlie Hon. I have a question for

2 everybody. What happens if we can't come to an

3 agreement here? December 31st is real close.

4 MS. DANE: This is Mary from Traulsen. I

5 don't think that -- it's not that we won't come to an

6 agreement. I think it is just understanding what we

7 are asking for.

8 Kind of to your point, Laura, some of the

9 industries, we don't belong to AHRI. Commercial

10 refrigeration, there is only company that belongs to

11 it, so we don't have that verification testing history

12 to go back to and say, you know, we can put a lot of

13 this on there.

14 So, you know, an industry like CRE, depending

15 on -- you know, some of the bigger companies can

16 probably go to it, but it is not just resources. We

17 don't have that history.

18 MR. KLEISS: Jeff Kleiss, Lochinvar. I

19 believe that with the small commercial boilers all that

20 we are reporting is thermal efficiency. It is fairly

21 straightforward. It's a good amount of history. Most

22 manufacturers have product in stock. If they did need
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1 to run additional tests, that is probably something

2 that could be reported in six months.

3 Now, I don't want to throw other

4 manufacturers under the bus without having a

5 conversation with them, but this is going back to the

6 point that if we can just have a week to have some

7 offline discussions, by product class, we can at least

8 offer you some short-term deliverables, I believe.

9 MS. BARHYDT: That sounds wonderful.

10 MR. SACHS: This is Harvey Sachs. I like it

11 also. But what particularly hit me just now is that

12 all of this is going to have a vast learning curve for

13 everybody concerned. And encouraging early submissions

14 or staggered deadlines will help that interface between

15 the manufacturers, the trade associations, and DOE, so

16 that we can learn on classes where it is fairly simple

17 and straightforward and be ready for the hard jobs.

18 So that's one reason why I'm pretty strongly

19 inclined against one size, 18 months, six months, or

20 any other number for all of these product classes, even

21 if people are allowed to submit early.

22 MR. EISNER: Does one week sound good to
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1 everybody?

2 MR. KOJAK: This is Mike Kojak with UL. Can

3 we have written down some of the things we need to talk

4 about over the next week, so when we get back we can

5 vote on it pretty quickly? Like when does the

6 effective date start from whatever timeline we are

7 going to start from? Is it at the end of the

8 rulemaking? Is it at the end of this? When is that?

9 How long do we think we are going to take by product

10 class, by group? And then also, you know, is it going

11 to take effect of the manufacturing date? Or is it --

12 you know, those kinds of things -- can we have it in

13 writing, so at least everyone knows exactly what they

14 need to be talking about for the next time?

15 Because we've had a long discussion, but, you

16 know, we talked about a lot of different things. But I

17 think everyone's head is kind of spinning from a long

18 day, and so it would be nice to have it all written

19 down, so we know exactly what to come back next week

20 with answers to.

21 MR. THARP: I would like to add to that any

22 pending regulations for each product class, just so
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1 nobody overlooks anything.

2 MR. STANONIK: Frank Stanonik with AHRI.

3 And, Neil, I want to answer your question that, no, one

4 week is not enough. And, I mean, I'm being totally

5 practical about it. Tomorrow you are meeting, right?

6 So this week we have Friday. Next week we are meeting

7 Wednesday/Thursday. So one week is actually Friday,

8 Monday, Tuesday.

9 And being totally selfish, you are asking me

10 to consult with commercial water heater manufacturers,

11 commercial boiler manufacturers, commercial furnace

12 manufacturers, commercial air conditioning

13 manufacturers, commercial -- a wide range of my

14 membership, and to try and get some idea of when they

15 think they could comply with an AEDM proposal most of

16 them have not seen.

17 I mean, if I came back -- if you asked us to

18 come back in a week to give you a number that we could

19 all agree on, it would be a number -- you know, at this

20 point it wouldn't be anything different than 18 months.

21 I mean, honestly, we would need at least not -- not the

22 next meeting, but the meeting after that, which I
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1 believe is scheduled for the 21st or whatever.

2 MR. EISNER: The next meeting is late in

3 August.

4 MR. STANONIK: Yeah. I mean --

5 MR. EISNER: If it's not next week, I believe

6 it's the end of August. And the report is due within a

7 few days of that meeting.

8 MR. STANONIK: Well, then -- okay. Then the

9 other option would be that we could come back to you

10 with some alternative suggested dates in between there,

11 which would simply be an email and teleconference or

12 something. But, I mean --

13 MR. DOPPEL: Paul Doppel with Mitsubishi. We

14 had a meeting scheduled for August 20/21. That was

15 tentatively scheduled. So maybe we could redo that.

16 MR. EISNER: I can't be here that date.

17 MR. DOPPEL: Oh, okay.

18 MR. EISNER: That's why when we were talking

19 about dates we scheduled two early and one later.

20 MR. STANONIK: We could let you call in.

21 MR. EISNER: All right. Time difference

22 even?
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1 MR. STANONIK: And if the discussion was

2 simply this issue of what date or what series of dates,

3 because it may end up being staggered, I would propose,

4 do you actually need a sit-down meeting, or could it be

5 teleconferenced?

6 MR. EISNER: How do others feel about a week?

7 MS. DANE: Some of us come from further

8 distances, and so we lose a whole day in travel on top

9 of that. I mean, even at a Friday/Monday/Tuesday work

10 week, some of us come from the other coast and travel

11 on Tuesday. So now we're down to two days.

12 MR. STARR: The other thing to consider --

13 this is Louis with NEEA -- you know, AHRI is probably

14 encompassing and thinking quite a bit of industry, and

15 I'm wondering if they were able to get some information

16 together, and, you know, we can put it on SharePoint or

17 something like that. At least we will have an idea.

18 It takes however long it takes to collect

19 that data. I'm not sure how representative AHRI is of

20 all of the issues that are here. Probably not so much

21 of the refrigeration, but it sounds like the other

22 equipment maybe more so.
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1 MR. STEPHENS: Phillip Stephens, HPT. All

2 kidding aside, this is a prime candidate for something

3 such as a doodle pole. I know AHRI uses those a lot to

4 identify the best time for a meeting. So very similar

5 application.

6 MR. AMRANE: This is Karim with AHRI. But,

7 again, I mean, for the majority of AHRI members, they

8 have no idea what the requirements of the AEDM is, what

9 we have been talking in this room. So, I mean, so just

10 to have a conversation, you know, we need to explain,

11 we need to -- I mean, so I -- again, my suggestion to

12 DOE would be to maybe encourage people to file early

13 information. I mean, if you want this information in

14 six months or, I don't know, a year, I don't know. But

15 then give 18 months from the date of publication of the

16 final rule, the AEDM, to complete all of the

17 certification requirements.

18 So at least you will have some of the data

19 because some of the manufacturers might be able to

20 provide you the information earlier. But at least

21 provide us 18 months, because I know for a fact, I

22 mean, there are some manufacturers who don't know what
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1 an AEDM is and don't have an AEDM, and then who will

2 have to develop one, and that is not going to be done

3 in six months.

4 MS. ARMSTRONG: I mean, so, Karim, you said

5 you -- oh, go ahead, Tim.

6 MR. BALLO: I was just going to say that if

7 there are, you know, hardship situations out there

8 where certain products, certain manufacturers, certain

9 pieces of information need 18 months, fine. But my

10 bottom line is, I want to see -- I want to be able to

11 go to the database and see stuff much sooner than that.

12 And so something has to be six months, something has to

13 be a year. If stuff needs to take 18 months, certain

14 stuff needs to take that long. But I shouldn't have to

15 wait 18 months for everything.

16 MR. AMRANE: Tim, excuse me, but you don't

17 have to do all of this. You are not involved in this.

18 You don't know what it is. Of course, you want the

19 information. But, you know, there are some real issues

20 here. I mean, you know, it takes time, it takes

21 resources, it takes engineers to do all of this. It is

22 not like it is going to happen overnight because just
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1 you want the data in three months or in six months.

2 MR. BALLO: I'm not suggesting that it is

3 that simple. I'm just saying that we have heard a

4 variety of views already on people saying they think

5 that can be done sooner. To the extent things can be

6 done sooner, that's what I'm after. But no one has

7 said that -- well, most people aren't saying that

8 everything will take 18 months.

9 MR. KOJAK: This is Mike Kojak with UL. But

10 that's just the people in this room, and that's not all

11 of the representation of every company in the industry.

12 MR. EISNER: But I have to say to you, in

13 fairness, that you are all here representing those

14 people for quite a few months. They are supposed to be

15 aware of what has been going on on AEDMs. They are

16 supposed to be aware of what has been going on in these

17 other things. Nobody should be surprised by where we

18 are right now.

19 MR. AMRANE: So why is it that DOE hasn't

20 published anything? Then DOE should have published all

21 of the information on the website for everybody to look

22 at. It is only limited to those members of this
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1 Committee.

2 MR. EISNER: The members of this Committee

3 can be talking to the groups that they represent around

4 the table.

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

6 MR. EISNER: Pardon?

7 MR. HURST: John Hurst with Lennox. How many

8 members does AHRI have? A few hundred?

9 MR. AMRANE: Yeah, about 300.

10 MR. HURST: Okay. It's not my job

11 description, working for Lennox International, to

12 communicate to my competitors what happens here. It

13 may be AHRI's charter, but there are some that aren't

14 even members. It is enough that I have to go back and

15 communicate to my own engineering team and product

16 development team. But I don't think it's incumbent

17 upon me to communicate what happens here to other

18 members or non-members in this industry. I think it's

19 unrealistic.

20 MR. EISNER: Let me put it a little

21 differently. If it's not your job, it's the job of the

22 people who aren't here to keep informed and make sure
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1 their views are known. Anybody can be online listening

2 to this. So that's why I'm personally, as the

3 facilitator, having a hard time hearing, "Well, nobody

4 knows what is going on in this room." They all should

5 know what is going on in this room, if they are

6 interested and they want to play a role in the

7 decision.

8 MR. KOJAK: This is Mike Kojak with UL.

9 MR. EISNER: And that works both ways.

10 MR. KOJAK: The things I have been telling

11 the people in my organization is is that none of this

12 is a final rule. This is just what we are recommending

13 to ASRAC. That was what we talked about at the first

14 meeting was these are just recommendations to ASRAC,

15 and that they have the option to change whatever we,

16 you know, submit to them. They are the ultimate

17 decision makers to the DOE.

18 So I don't want to tell my organization,

19 "This is what the new rules are going to be" if it's

20 not a real rulemaking. It still has to go to a

21 proposed rule. People can make comments, public

22 comments. It can change.
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1 So why set in motion things in our

2 organization that is going to cost, like John was

3 saying, you know, multiple -- you know, a lot of money

4 and resources to move something in a direction that is

5 not really a rulemaking, and then, you know, at the end

6 it changes, and then everything is different. So --

7 MR. EISNER: Mike, we're not talking about a

8 rulemaking. We're talking about representation of

9 views with respect to the issues that are being

10 discussed at this table. You are all supposed to be

11 representing more than your particular interest. You

12 are not here to represent Carrier or one other -- some

13 other company. You are here to reflect the views of the

14 people who have common interests, and it may change

15 from issue to issue.

16 The two people in the corner aren't

17 representing all the public -- they are representing

18 all of the public interest groups that aren't here.

19 They have the right to call them up and say, "I don't

20 particularly agree with what I've heard. I would like

21 you to go in there and express my opinion." That's the

22 only way it works, because if we sit down and all agree
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1 to what should be in this proposed rule, and 90 percent

2 of the industry says, "This is the first I've heard; I

3 object" this group won't be successful.

4 MR. WHITWELL: Neil, this is Bob Whitwell.

5 You mentioned Carrier, so I --

6 We, as the industry, we're here, we're trying

7 to represent what we think would be the views of the

8 other manufacturers as well. But to John's point, I

9 mean, we - - I don't feel that we can go out and start

10 having conversations with our competitors and

11 discussing these things directly with them one to one.

12 I think that that's something -- there has been

13 communications that have been going out through AHRI on

14 this. So hopefully they are paying attention. But I

15 don't think we know that they are all, you know,

16 totally up to speed because they are not able to

17 participate in this, or they are not participating in

18 this. Maybe that's --

19 MR. EISNER: That's a key point. They can be

20 listening; they can be making their views known. We've

21 got people sitting in the back room who are not members

22 of the Committee, but have been here regularly or
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1 participated over the phone. So I am a little troubled

2 when I hear that -- we can't expect every single

3 manufacturer to have every single view that they want

4 to raise raised at this meeting. But they are supposed

5 to be able to raise their views either through some of

6 you or through participating themselves. So to say

7 that you need more time to figure that out, when we are

8 going into the last month of the process --

9 MS. MEYERS: There is a huge difference

10 between being aware of the talks going on and the

11 general concepts and actually putting the pencil to the

12 paper and figuring out the impact the resources

13 required and the man-hours that you are going to have

14 to do and scheduling your labs and getting the test

15 cells booked to do all of that information.

16 There is a way huge -- I mean, it is just a

17 night-and-day difference, and so, you know, I have been

18 talking to my people. They are generally aware of it,

19 and they kind of nod their head and, you know, "Well,

20 when are we going to see the final rule, so that we can

21 actually start?" We know exactly what we need to plan

22 for.
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1 So there is a big difference in just

2 awareness and then being able to go back and figure out

3 the project and lay out a project timeline to be able

4 to accomplish all of this and assign the manpower and

5 the dollars and then get the project approved by

6 management, because likely there may be outside

7 testing. And this is going to cost, you know, millions

8 of dollars for the industry to implement some of these

9 new things.

10 So it is a much bigger deal than -- so that's

11 why when it is all approved and we have a final rule

12 and we are pretty sure of what the exact requirements

13 are going to be, that's when the planning process

14 starts, because you are not going to go -- I mean,

15 we've got 90- something DOE rulemakings that have come

16 out in the last three years. That's what we know we

17 need to work on, and that's what we're planning, and

18 that's what the engineers are focusing on, not, you

19 know, this concept out here that hasn't been finalized.

20 MR. DOPPEL: Paul Doppel with Mitsubishi.

21 Also, you know, we have just -- in the last 30 days

22 have finalized what the product types are. I mean,
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1 that was a big unknown. We agreed -- we went through

2 all of the accessories and, you know, we appreciate

3 DOE's openness and going through all of those and

4 helping to parse those out, so that we could actually

5 make determinations on how many basic model groups we

6 were going to have, how many different AEDMs we would

7 have to develop. So, I mean, that's not like that

8 happened four months ago. That has only happened

9 recently.

10 And even today we just -- with the high

11 static motors, alternate static motors, we just

12 finalized that today, and that has a big impact on

13 things that people need to do with models. So it's --

14 you know, I mean, we are really just kind of starting

15 from today with having a certain finality of what the

16 model groups are going to be and how we are going to

17 have to divide products up. So there is still a lot of

18 work to be done.

19 MR. STEPHENS: Phillip Stephens, HTP. I have

20 been trying to jump in a couple of times, so I'm just

21 going to go ahead and do it now. I know for a fact

22 several of us have taken advantage of networking
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1 opportunities and online opportunities to make sure

2 that the industry is aware of this situation.

3 I myself have contacted three or four

4 different manufacturers and discussed it. One is

5 sitting back in the back corner, and that happened at

6 an AHRI event when there were a group of us together.

7 So they chose not to participate. Hopefully, they're

8 on the telephone now. But we can only make the best

9 decisions that we can make with the data we have, and

10 the data we have is our company, right?

11 And you're absolutely right, it is going to

12 take way too long for this if we rely on AHRI to go out

13 and poll every single member, because the results you

14 are going to get are going to be so widely distributed

15 people don't know, so they are going to give

16 tremendously long timeframes.

17 So I think we have to draw that line

18 somewhere, and I think a couple of weeks for us to know

19 -- to go back and review our data and have a better

20 comfort level in our understanding at this point is

21 very reasonable.

22 MR. THARP: Rusty Tharp with Goodman. I will
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1 further add to the response to your question, Laura,

2 about, you know, don't we already have test data. One

3 example, as Paul mentioned, the motors as being

4 finalized today. Let's go back to the code of coils.

5 The code of coils are going to be tested, so we need to

6 go back and look at every single one of our units that

7 we have in production.

8 MS. ARMSTRONG: Really?

9 MR. THARP: Coated coils; right?

10 MS. ARMSTRONG: So should I revisit that

11 decision? Do we want to -- do you want to vote again?

12 MR. THARP: It's crazy talk.

13 MS. ARMSTRONG: Are you bringing that up,

14 Rusty?

15 The industry changed their position?

16 MR. THARP: The cooper coils. Maybe that's

17 it. That's what I was thinking of. Thinking of PTACs.

18 MS. ARMSTRONG: I'm confused.

19 MR. THARP: PTACs, for example. PTACs.

20 There we go. That's what I was thinking of. PTACs is

21 the --

22 MS. ARMSTRONG: So, I mean, what is the
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1 bottom line here? You guys -- I mean, we could talk

2 about this. You guys asked for 18 months, generally.

3 There was a couple of people that said they might could

4 do it earlier. The Department is asking if there is

5 any way we could stage this or go back and think about

6 it. I mean, it doesn't seem like we are going to

7 resolve this today. It seems like you are saying you

8 need more than a week to resolve it.

9 I don't know if it would help to -- one

10 option is to say we won't officially meet tomorrow, let

11 you guys meet as groups or together in your respective

12 industries, or talk to your people back home, or

13 however you want to do it, that's one option, too, to

14 give another working day. Another option is to say we

15 won't meet next week and then --

16 MR. HURST: Can I make another proposal,

17 maybe?

18 MS. ARMSTRONG: Sure.

19 MR. HURST: Maybe as a compromise? We were

20 talking -- you know, we are not going to wait until

21 month 17 day 30 to upload everything.

22 MS. ARMSTRONG: Sure.
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1 MR. HURST: For us it's going to be an

2 iterative process. I am speaking for myself, not for

3 other people I haven't spoken to. But maybe a phased4 in approach that says by a certain time you have X

5 percent, because to the earlier points there are some

6 things that we could do fairly quickly. There are

7 other things that are going to take some time.

8 I just don't know where we are

9 comprehensively. The 18 months -- when I say 18 months,

10 I'm talking about being fully compliant with the

11 regulation, not that we won't load stuff earlier

12 because we can, but maybe if there was some compromise

13 to say if we can get to this point by this timeframe,

14 and maybe define it by broad product categories, maybe

15 that's a compromise. I don't know.

16 MS. ARMSTRONG: I think that -- I mean, at

17 this point, the Department just wants to know, how much

18 time do you want to discuss what your options are? In

19 other words, you guys need to -- you've seen what we've

20 negotiated, you've seen what we've negotiated as to the

21 cert requirements, you've seen what we've negotiated

22 for AEDMs, which were approved by ASRAC and sent to the
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1 Department, you've seen what we've negotiated for basic

2 models. So you have all of the pieces.

3 Now it's a matter of the date, and the date

4 is really important because right now December 31st is

5 still on the books. So what we're asking of you is you

6 guys need a couple weeks, whatever that timeframe is.

7 We are asking for a date. When is the date you want to

8 come back and have those discussions about what date we

9 could vote on or what phased-in requirements or what

10 options there may be that you could present to the

11 group to consider for voting.

12 MS. MEYERS: So just -- I think it's a good

13 suggestion, but let's just walk through the process.

14 So we are supposed to file the final report with ASRAC

15 at the end of August. And how long will it take them

16 to review that? And then how long will it take to

17 write the NOPR? And then will the NOPR be out for

18 comment, for how long, and then how long will it take

19 for the final rule?

20 So if we could walk through that, and we have

21 some pretty good assurances that those dates will be

22 met, then maybe we can give you some pretty good
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1 assurance of when we can meet our dates.

2 MS. BARHYDT: So how fast -- ASRAC already

3 has a meeting scheduled, right, for --

4 MS. ARMSTRONG: It's in the middle of

5 September, likely. We have got the week picked out; we

6 just don't have the final date. But it's likely the

7 second week in September.

8 MS. BARHYDT: So that's when ASRAC would

9 vote.

10 MS. MEYERS: So I'm just going to -- so 9/15,

11 just for -- to plot this out. So they would vote on

12 9/15. So assuming it's approved, how long before the

13 NOPR is in the Federal Register?

14 MS. ARMSTRONG: So it depends; right? One is

15 the AEDM rule is separate and can go -- ASRAC has

16 already voted on that. That's done. It's cleared.

17 MS. MEYERS: Okay.

18 MS. ARMSTRONG: So the NOPR is being drafted.

19 MS. MEYERS: You've got to give us some

20 assurances, so we can give your --

21 MS. ARMSTRONG: Well, you're picking the date

22 from the final rule, so I fail to see why it matters.
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1 MS. MEYERS: Well, you know, it does matter

2 because we have to --

3 MS. ARMSTRONG: It doesn't change anything.

4 Your clock doesn't start until the final rule is done.

5 MS. BARHYDT: You are arguing that you can't

6 take actions until you have a final rule, so --

7 MS. MEYERS: No, I'm not. I'm trying to give

8 you a date, but it -- there is a planning cycle that we

9 all go through, and that we have to budget for, and

10 that we have -- you know, all of our companies have

11 project timelines and resources that we have to

12 schedule.

13 If something like this comes out in -- way

14 past time, way past the budget process, and I can't get

15 resources to devote on it, I'm going to need more time.

16 So for my planning -- I'm speaking for Rheem here --

17 I've got to kind of figure out this timeline, because

18 I've got to be able to figure out, so I can give you an

19 answer.

20 So if -- you know, so I need a little bit of

21 dates, so we can figure out how this would work into

22 our business, plus with all of the other stuff that we
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1 have going on and when that stuff is due. So there is

2 lots of other DOE things that are happening, and we

3 have deadlines on those.

4 So I've got to figure out how I can work this

5 in, because if it's going to fall in the middle of when

6 I have to have all my products ready for regional

7 standards or for residential water heaters or something

8 like that, it is going to affect when I can comply or

9 when I have to have the standby power or any of these

10 other issues that we have.

11 So if it's falling within those, it is going

12 to affect my ability -- if I had nothing else to do, I

13 would -- you know, could get on it really quick, but

14 that's not where we're at. So that's why for me it's

15 important that I can figure out how we're going to plan

16 this.

17 MR. SACHS: Laura, this is Harvey, and if I

18 could just add to that from a slightly different

19 perspective. I am interested in the date the cake is

20 baked, that everything is online, the new system is

21 alive and working. I think I need to understand this

22 timeline, including whatever delay loops OMB can throw,
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1 because for me what -- I really start my timing from

2 the publication of the NOPR, because at that point the

3 world is aware that this is happening, and will start

4 to pay attention and start to think about what it means

5 for their company.

6 So from that perspective, in terms of wanting

7 the earliest possible completion of this CCV -- what is

8 it? CC -- yeah, the process, I think this timeline is

9 important.

10 MS. BARHYDT: So is the biggest issue the

11 AEDM rule?

12 MS. MEYERS: It's not the biggest, but it is

13 the initial piece that we need.

14 MS. BARHYDT: Okay.

15 MS. ARMSTRONG: December 31st. Assume a

16 December 31st final rule date.

17 MR. WHITWELL: Final rule on AEDM?

18 MS. ARMSTRONG: You look surprised. I'm

19 refreshed from maternity leave. I'm ready to go.

20 Game on.

21 MS. BARHYDT: Thirty-day comment period.

22 MS. ARMSTRONG: Thirty-day comment period.
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1 MR. KLEISS: Jeff Kleiss, Lochinvar. I'm not

2 sure that the date really should be what is driving

3 this, based on what John had said. I mean, the

4 assumption that everybody's planning time is not -- is

5 going to be the same just doesn't -- I mean, it may

6 work for one manufacturer but not for all

7 manufacturers.

8 John had said, "I need a year plus whatever -

9 - you know, from whatever my plan date was," I think,

10 if I understood that correctly. So even if we do get

11 the time, I'm not sure that is going to get it.

12 What seems to be a big factor in this, in

13 delaying this, if I am understanding it correctly, is

14 we just defined what is included and what is excluded

15 for some of the product types. But that was not

16 changed significantly for water boilers, for water

17 heaters. And it makes sense that we should be able to

18 come up with a shorter period of time for those

19 products. And maybe we can just -- would it be safe,

20 and we don't even have to go through all of this

21 rigmarole, that for the products where we did create

22 exclusions, where we did change definitions, that we
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1 give them the 18 months and just move forward and we

2 can limit the discussion of a shorter time period to

3 the products -- my products?

4 The ones that didn't change in scope and

5 definition.

6 MR. STEPHENS: Phillip Stephens, HTP. Along

7 those same lines, I think if we want a fast answer

8 today it is probably going to be around 18 months.

9 MS. ARMSTRONG: I don't think we are pushing

10 for an answer today. Right? I think we are asking

11 you, how long do you need to talk to your companies and

12 come back with what you want the Department to

13 consider? This is really -- you guys have asked for

14 the extension or consideration of the extension, so we

15 are asking.

16 Tim's point was, I want to see some type of

17 progress. If some things take 18 months, they take 18

18 months. But along those lines, I want to see some type

19 of progress that the 18 months is going to be just 18

20 months this time. I think I'm paraphrasing for him,

21 but hopefully I got it more or less right.

22 So, I mean, I think that's the question for
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1 you guys. I mean, what is it -- what products can be

2 done quickly? How quickly can they be done? If some

3 things take 18 months, like the PDF, or planning

4 cycles, take the next week or two, you see the

5 proposals, I told you December 31st date. Assume a

6 December 31st date for AEDMs, and then come back with

7 what we really should consider. If it's 18 months, why

8 is it 18 months? If there is something you are willing

9 to do in 10 months or 12 months or step-wise, with

10 different products at different times, what is it?

11 MR. STEPHENS: My concern is that we might --

12 I don't want to sidetrack all of the good progress

13 we've made here by this date, when we will have

14 opportunity to reply in the NOPR with more detailed

15 information that would, by default, give all of the

16 manufacturers time to do that exact same thing.

17 MS. ARMSTRONG: Well, so you --

18 MS. BARHYDT: We have to propose something in

19 the NOPR. Otherwise, we start back with another

20 proposal. So there is no real benefit there.

21 MR. STEPHENS: That's my point. If we

22 proposed 18 months in the NOPR, and then we are all
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1 here, we can all start work on it, that way we will

2 have plenty of time to actually have more detailed,

3 responsive, and accurate answers, to provide back to

4 the Department in --

5 MS. ARMSTRONG: Something tells me we are not

6 going to get comments that say, "I can do it in eight

7 months, DOE. Please revise your proposal."

8 Just saying.

9 MR. STEPHENS: There are always outliers.

10 MS. ARMSTRONG: However, if I went with

11 "Let's propose eight months," I am pretty sure I'll get

12 comments.

13 MR. FLY: This is Mark Fly, AAON. How many

14 NOPRs are you looking at out of this process? Are we

15 looking at --

16 MS. BARHYDT: Two. One for AEDM and one for

17 all of the rest of it.

18 MR. FLY: All the rest of it. And all the

19 rest of it includes the date?

20 MS. ARMSTRONG: Yes.

21 MS. BARHYDT: Yes.

22 MR. FLY: Okay. So not a separate rulemaking
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1 on the date. Okay.

2 MS. ARMSTRONG: The final rule has to be --

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

4 You know, what I ended up hearing is sounded like most

5 of the manufacturers here individually know with inside

6 of a week kind of what they can tell you. It sounds

7 like AHRI would need more time than that if they want

8 to survey absolutely every single customer or every

9 person in their trade association. But it seems like

10 within a week we would have a pretty good

11 representative sample. And then if AHRI is able to

12 provide more information in the interim between that

13 and the 22nd meeting, it seems like we are in a pretty

14 good situation for understanding what the --

15 MR. EISNER: And are you comfortable that

16 what you would provide would be representative of the

17 entire industry? Not exactly the same, but

18 representative of different kinds of companies?

19 MR. STARR: Well, no, what I'm suggesting is

20 that the people at this table are supposed to be

21 representative of the thing. So, in theory, if they've

22 done a good job in selecting them, then you've got a
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1 representative sample. Then, AHRI, in theory,

2 represents their group. Theirs would also be a

3 representative sample as well.

4 MR. AMRANE: This is Karim with AHRI. But I

5 can tell you for a fact not everybody is on the same

6 page. So it is going to take time for people to bring

7 everybody on the same page. And I'm telling you, from

8 AHRI, it is going to be all over the map. That's why

9 we came up with this 18 months previously, because we

10 felt that it was an overall timeframe that would

11 satisfy the majority of our members.

12 Again, I mean, maybe some are ready to do it

13 faster, and that's fine. That is maybe why you maybe

14 should encourage people to file as soon as they can.

15 But at least give these 18 months as a deadline for

16 everything to be on the database.

17 MR. STARR: I seems like, though, you could

18 do a representative sample of your groups. You know,

19 you've got small members, you've got large members.

20 You can get some kind of representative sample, so you

21 don't really have to get everybody's input. You can

22 take an in-depth look at certain manufacturers in your
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1 group and kind of come up with something faster.

2 MS. MEYERS: When the final rule is issued,

3 will it include, as part of that document, all of the

4 forms and everything that manufacturers need to comply?

5 MS. ARMSTRONG: When the certification final

6 rule -- so one of the things, it is going to depend,

7 right, if you guys decide to certify yourselves or

8 certify through a third party. The forms are largely

9 available now. You guys didn't change the

10 certification requirements that much. You know, 90

11 percent of it is there. You are not going to -- you

12 may see a column difference. But if you want to know

13 what they look like download the one tonight and look

14 at it. They're all there for your products. They're

15 available.

16 MR. THARP: Rusty Tharp with Goodman. I'll

17 say that I would agree -- at least for my company, we

18 could come back at next week's meeting with a date for

19 everything. I think that's reasonable, acceptable.

20 MS. ARMSTRONG: That's the purpose of this

21 working group, right? I mean, if each of your

22 companies are -- everyone has different ideas, let's
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1 discuss them. I mean, that's the whole -- let's come

2 out with the different ideas. Let's discuss them and

3 see if we can reach some type of consensus which

4 everyone is comfortable with. I don't think it

5 requires polling members through AHRI, coming up with a

6 consensus there, and then coming back here. I mean,

7 part of this negotiation is to come up with what you

8 can do for your company.

9 I think that's all we're asking -- go back

10 and see what you can do, how these relate to your

11 companies, and let's come back to the table and discuss

12 them. If you can do that in a week, great, we'll hold

13 meetings next week. If we can't, then we have to wait

14 longer. But the clock is running short because the

15 ASRAC meeting is going to be set for the middle of

16 September.

17 MR. MYERS: This is Frank Myers. We are

18 obligated to represent those that are not around the

19 table, though. So it is not just what we can do. It's

20 what we know that --

21 MS. ARMSTRONG: And they are welcome to

22 participate.
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1 MR. MYERS: -- others can do.

2 MR. HALLEY: Geoff Halley with ABMA. I can

3 tell you what we have done so far. At the end of --

4 when the first sort of interim report went out to

5 ASRAC, I took that and made a presentation to ABMA at

6 their summer meeting. So the members -- it was well

7 attended because it was at a nice place.

8 So the ABMA membership knows what it is. My

9 concern is there are some other sort of outliers that

10 don't know about it, or, if they do, they don't have

11 the engineering capability.

12 MS. ARMSTRONG: And we still have to go

13 through a notice and comment period.

14 MR. HALLEY: Right.

15 MS. ARMSTRONG: Flat out.

16 MR. HALLEY: And so I have taken the liberty

17 of, you know, taking the ABMA thing and putting it out

18 to former clients of mine or existing clients. So, you

19 know, we are trying to expand the knowledge base, if

20 you like, on what it is all about. But there are also

21 some small companies who don't really have the

22 engineering capability to produce this.
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1 You know, they have already got an alligator

2 in swamp situation with their existing business, and

3 then they get this put on top of them. And they've

4 probably got to put it out to somebody to do it for

5 them. And there are not too many people around that

6 are capable of doing it. You know, I've had two people

7 come to me, and I'm not going to do it, basically,

8 because I think I'll have a conflict of interest at

9 some point.

10 MR. EISNER: That's one thing to consider

11 when you are talking about what is possible is whether

12 certain segments, because of their size or some other

13 reason, can't comply in 12 months or 18 months and they

14 need more time, as well as whether some people can get

15 part of it done earlier and part of it done later to

16 give them the flexibility -- all of you the flexibility

17 to say, would it be better to do one-third every six or

18 eight or 12 months than to try to do everything in 18

19 months?

20 MR. SACHS: This is Harvey. I'm moved to

21 comment on a couple of things that have been said. One

22 of them is, Louis, with all due respect, I don't think
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1 we are representative at this table. This is

2 predominantly companies that have shown an active

3 interest in this process, for business reasons or

4 otherwise. And there are a lot of companies that have,

5 for a lot of reasons, not been engaged. They, we hope,

6 will become engaged with the publication of the NOPR.

7 But, Karim, again, with great respect, your

8 job as a trade association is to represent the lowest

9 common denominator. There are going to be people who

10 are going to need waivers, whether small companies or

11 whatever, and I don't think this rulemaking can be

12 addressed to the least capable, but to what industry

13 can do to get us launched into an era where things will

14 be easier once we get over this hump.

15 And it's not at all clear to me that we can't

16 work out something, whether it's different groups

17 coming in earlier, or progress reports. Certainly, Tim

18 has made some suggestions. But I'm not comfortable

19 with the idea that because the least among us will need

20 18 months and then an extension that 18 months is the

21 right number for everything we're doing.

22 MS. MEYERS: So if we selected a date earlier
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1 than 18 months -- Laura, this is primarily for you --

2 would it be possible for the DOE then to agree not to

3 do verification enforcement testing for, say, 18

4 months? So the people that have -- I mean, the people

5 that want the data can get the data, but it also gives

6 time for manufacturers like, you know, oops, this might

7 be -- you know, maybe at month 13, I need to adjust it

8 because it gives me time to go and verify my numbers,

9 do the additional testing, due diligence, and

10 everything else. Just a thought.

11 MS. BARHYDT: So you did catch me in a side

12 bar and I missed the very beginning part of what you

13 said.

14 MS. MEYERS: So if we agreed on a date

15 earlier than 18 months -- that's a big if -- would it -

16 - could the Department say you have to have your data

17 submitted within -- let's just pick 12 as an example.

18 But the Department will not do any verification or

19 enforcement testing until 18 months.

20 So the people that want the data to do

21 analysis, they have something. It may not be as good

22 as it would have been if we had given everyone 18
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1 months to do all of that additional verification

2 testing. But they've got six months in there to kind

3 of do that before they have to worry about any

4 potential penalties coming against them.

5 MR. SACHS: This is Harvey. I'm not sure I

6 agree, but that's the kind of creative suggestion for

7 breaking the jam that I have been asking for.

8 MR. SACHS:

9 MR. BALLO: This is Tim. That sounds like --

10 okay to me. The only caveat is I guess DOE should have

11 the ability to enforce for the failure to certify. So

12 you could just leave products out. That doesn't

13 require testing. That's different, to my mind, then --

14 MS. BARHYDT: So I was actually going to

15 suggest the opposite. Everything needs to be certified

16 say within 12 months. But DOE won't be issuing any

17 civil penalties for any issues therein, so that you

18 have time to go back through, scrub it, make sure that

19 you're comfortable with everything for six months.

20 Well, it's not the same as saying we're not

21 going to do any assessment testing. But basically we

22 are not going to enforce your ratings during that six-
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1 month period.

2 MR. HON: This is Charlie Hon. Basically,

3 you are saying if it doesn't meet DOE minimums, it

4 could be enforceable.

5 MS. BARHYDT: Yeah. Yeah.

6 MR. EISNER: Sort of like a learning period

7 where you work with industry and where they may have

8 made a mistake.

9 MS. BARHYDT: And then -- and I can tell you

10 from experiences with other industries, there is a

11 learning curve, and there is often a lot of back and

12 forth of, did you mean to say this? And asking a lot

13 of questions. So, and that gives us all six months to

14 figure out that everything in there is what is really

15 intended to be in there.

16 MR. MYERS: This is Frank Myers, PVI. You

17 are saying that with the exception of meeting the

18 minimum allowed, if we got something in in 12 months

19 that in the additional six months we found needed to be

20 changed, we could make those changes. There would be

21 no penalty, no enforcement action.

22 MS. BARHYDT: Yep.
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1 MR. MYERS: Okay.

2 MS. BARHYDT: And we could still give 18

3 months on the PDFs. That saved my question.

4 MR. CYMBALSKY: I'm going to have PDF

5 training next --

6 MR. STEPHENS: Phillip Stephens, HTP. I

7 think what you'd see is a lot of unscrupulous people,

8 companies, that would -- there is the possibility with

9 doing that that some manufacturers that are borderline

10 with reaching efficiency levels where rebates are

11 involved would bump their product up, even if it's just

12 for six months, to make a difference in their

13 financials.

14 MR. EISNER: One thing the agency could do is

15 change that to "no intentional violations, would they

16 waive enforcement"?

17 MR. STEPHENS: How would you prove intention?

18 MR. ARMSTRONG: That's why we have lawyers.

19 MR. EISNER: And if you go out and you find

20 out they kept double sets of records and things like

21 that?

22 MS. BARHYTE: Yeah. You can prove willful.
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1 MR. CYMBALSKY: Well, I mean, we do have AHRI

2 certification data now. So I think, to the extent that

3 you see that unscrupulous behavior, I think --

4 obviously, you can make up new basic models, but, you

5 know, I think we would be okay with that.

6 MR. EISNER: These are the kinds of things

7 that I would encourage you to think about. What you

8 hear around the table are views of people who are

9 saying you need to show progress before 18 months, and

10 then you see other people saying it's going to be very

11 hard to do it in 18 months.

12 So you need to see if there are ways that you

13 can have different packages put together where no

14 enforcement for six months, that's the standard, but

15 maybe certain people with really bad situations could

16 get waivers. Maybe small businesses get waivers.

17 Maybe somebody could get credit for doing it even

18 earlier than 12 months, so they could use it to get a

19 little more time with other products.

20 These are all the things you've got to think

21 about whether you can come up with to help DOE come up

22 with something that is fair to just about -- or a great
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1 percentage of the industry. Maybe they can't be fair

2 to everybody, or let them think they're being fair, but

3 there are various things they probably can combine if

4 you convince them they're reasonable.

5 MR. AMRANE: Question to Laura. This is

6 Karim with AHRI. When is the -- when does the clock

7 start, the 18 -- the 12 months or the --

8 MS. BARHYDT: Today?

9 No, I'm kidding.

10 MR. MYERS: I nominate January 1, 2014, since

11 the --

12 MS. BARHYDT: As the due date?

13 MR. MYERS: As the start of the clock date.

14 MR. AMRANE: Assuming there is a final rule.

15 MR. MYERS: Yeah. Assuming there is a final

16 rule then.

17 MS. BARHYDT: No. I was thinking the

18 publication of the final rule.

19 MR. AMRANE: Which final rule?

20 MS. BARHYDT: The AEDM final rule.

21 MR. MYERS: Okay.

22 MS. BARHYDT: Yeah. So it gives you one more
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1 day.

2 MR. FLY: Mark Fly when AAON. When do we

3 anticipate the final rule on the rest of this? Because

4 that defines what the basic models are.

5 MS. ARMSTRONG: I don't think it -- most of

6 the basic model stuff is going to be through guidance.

7 MS. BARHYDT: Yes.

8 MS. ARMSTRONG: So that is not going to be

9 held up in the rule.

10 MS. BARHYDT: But they did have some --

11 MS. ARMSTRONG: But some of the stuff, yes.

12 I mean, that one is harder to estimate.

13 MR. FLY: But I mean, that rule is going to

14 have to come before December 31st because that has the

15 date in it, right?

16 MS. ARMSTRONG: When are we going to get a

17 negotiated package to ASRAC?

18 MR. FLY: Yeah. Assuming that we get that

19 negotiated -- okay. But I --

20 MS. ARMSTRONG: I mean, I think the date

21 thing is -- we are going to try to get -- we understand

22 the importance. We are going to try to get it. But we
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1 can talk about dates all day, seriously.

2 MR. FLY: The other thing that I am a little

3 concerned about is if any of the other rulemaking,

4 particularly the IEER rulemaking, lands in the middle

5 of this -- well, I want to talk about it. We're going

6 to have to have serious talks about the date on that,

7 because we are going to be -- I mean, I foresee me

8 shutting down product development for a year almost.

9 I'm going to be really unpopular at my company.

10 MR. STEPHENS: Along that line, I would

11 recommend that we maintain our current schedule and

12 each of us work on this in parallel to making progress

13 as we have laid out here, so that we don't jeopardize

14 having the report ready for ASRAC on the schedule we

15 already have.

16 MR. EISNER: We have a number of different

17 issues we have to conclude. We are not -- we've got

18 verification. I thought there were some things on the

19 schedule beyond that. Okay.

20 I mean, the current calendar has the list of

21 items. If we want to quickly look at them first, we

22 are talking about verification, accreditation process,
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1 industry programs, certification testing, build to

2 order products; verification and laboratory

3 accreditation, certification testing, build to order

4 products. August 7th we're talking about enforcement

5 process, witness testing, laboratory requirements, the

6 tolerances.

7 MS. BARHYDT: I think most of that is going

8 to end up being all rolled into this last subject area.

9 MR. EISNER: How many hours or days do you

10 think we need for this last issue?

11 MS. BARHYDT: I don't know. Let's see how it

12 goes.

13 MR. EISNER: All right.

14 MS. BARHYDT: We can start now. We have 40

15 more minutes.

16 MS. ARMSTRONG: No, no. Don't get excited.

17 MR. MYERS: This is Frank Myers, PVI. I

18 wonder just in looking around the room at the other

19 manufacturers if we would like to take the time between

20 now and 6:00 as a group, if we could borrow this room

21 for that period of time, to discuss what has been

22 talked about and what we might be able to do. We have
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1 had some interesting ideas put out on the table and --

2 MS. BARHYDT: We can do that.

3 MR. MYERS: -- then perhaps in the morning we

4 could provide at least a little bit more clear picture

5 as to where things are headed.

6 MS. BARHYDT: It's up to you guys.

7 MR. MYERS: Is there interest in doing that?

8 I'm asking the other manufacturers around the room.

9 MS. ARMSTRONG: I mean, to the extent you

10 want to take the room tomorrow, I mean, that's -- this

11 is kind of up to you guys. If there are issues that

12 you want to use the room for instead of starting

13 verification tomorrow, and we'll start up verification

14 at the next --

15 MS. BARHYDT: You all could start at 8:00,

16 and I could get here later.

17 MS. ARMSTRONG: I mean, I'm just saying,

18 while you're all here, if it helps to have some face19 to-face time with each other without DOE in the room,

20 we could remove ourselves from tomorrow, you could work

21 on whatever you need to work on, and we could start

22 verification at the next set of meetings.
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1 MR. MYERS: This is Frank Myers. I think we

2 can probably have, to the extent it is possible for us,

3 these discussions this afternoon, the remaining 35 or

4 40 minutes. And then we can use the first part of the

5 meeting tomorrow to talk about it.

6 Now, if at the conclusion of today's

7 discussion we feel like we need more time, then perhaps

8 we'd let you guys know we'd like to take the first

9 little bit of the meeting tomorrow. But I don't think

10 we are going to need a lot of time to basically just

11 talk about the kinds of things that have been discussed

12 here. And I'd hate to take a whole day away from the

13 other important topics we need to discuss.

14 MR. EISNER: Okay. Is everybody in agreement

15 with that?

16 MR. CYMBALSKY: Do you want to put in a

17 placeholder for an hour tomorrow, just to be sure, or

18 no, you don't?

19 MR. HON: This is Charlie. I think we would

20 be well-advised to take two hours for tomorrow, start

21 it at 10:00, because it is already 5:25. That means

22 this room has to be cleared in 35 minutes. There's not
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1 going to be a lot of discussion this afternoon.

2 MR. CYMBALSKY: So, Frank, what we're

3 discussing is, you know, give you the rest of today

4 plus an hour or two in the morning to continue on.

5 MR. MYERS: If others think that's needed,

6 then I don't want to constrict any good ideas from

7 coming out.

8 MR. WHITWELL: Bob Whitwell from Carrier. I

9 think if we have a little bit of time the rest of the

10 day today to just kind of talk among ourselves and

11 throw out some ideas, I don't know that a lot of extra

12 time tomorrow is going to help that much, because then

13 I need to go back and talk to my folks.

14 MR. CYMBALSKY: Okay.

15 MR. WHITWELL: And get their input on that,

16 and, you know, rather than talk more among ourselves

17 here.

18 MR. CYMBALSKY: So I'd suggest I run out the

19 door really quick so you have 30 minutes.

20 MR. WHITWELL: Yeah. I think that would be

21 better, and we could get to our stuff --

22 MR. CYMBALSKY: 8:00 in the morning, then;
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1 right?

2 MR. WHITWELL: Right.

3 (Whereupon, at 5:23 p.m., the proceedings in

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1 CERTIFICATE OF COURT REPORTER 

2 I, LINDA METCALF, the Court Reporter before 

3 whom the foregoing proceeding was taken, _ do hereby 

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5 the proceeding was thereafter reduced to typewriting 

6 under my direction; that said transcript is a true and 

7 accurate record of the proceeding; that I am neither 

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1 CERTIFICATE OF TRANSCRIPTION

2 I, LISA SIKES, hereby certify that I am not

3 the Court Reporter who reported the following

4 proceeding and that I have typed the transcript of this

5 proceeding using the Court Reporter's notes and

6 recordings. The foregoing/attached transcript is a

7 true, correct and complete transcription of said

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1 15:12 16:2 172:9

177:5 250:10

1,000 100:7

1,000-gallon 97:21

99:3

1.5 144:9 146:8

10 17:22 18:3

28:20 30:1

35:13,17 36:5

51:22 52:4,7,21

53:11 56:3 89:10

97:9 106:4

141:14,21

143:11,16,21

144:7,8

146:1,4,5

147:7,13 149:12

150:19 153:19

154:12 155:4,10

156:11,16 161:1

171:13 201:13

236:9

10:00 255:21

10:09 1:12

100 109:10 200:15

1000 1:7

10-minute 57:22

11 58:9

115 27:16

12 58:10 164:11

166:18,19,22

167:11 172:20

174:13 177:18

178:14 182:1

186:6 187:11

188:7,11

204:15,17

207:13 236:9

243:13,18

245:17 246:16

247:18 249:18

250:7

12.12 52:14

120 102:17

127 128:18

129:5,22

13 58:10 245:7

130 102:3,8

135 99:1 144:21

14 35:2

140 80:7,13,21

82:14 83:2,17

84:5 85:16

86:8,18,20

87:2,17

88:10,14,15,18

89:5 90:15 97:3

98:10,12,22

99:14 100:4,9

101:10

102:18,21

103:5,13 105:17

106:6 107:19

141:11 149:9

151:15

140-gallon 82:2

141 97:7,9

145 99:1

15 28:21,22

35:14,17 36:5

178:16 193:14

150 85:14,15

150-gallon 90:21

99:16

168 86:6,7

17 34:1,3 35:1

121:14,20,22

122:1 227:21

17-1/2 179:11

18 164:7,10,13,17

165:13,22

166:19,22

167:11 168:1

172:17 173:22

174:14 176:21

177:7,18

179:4,7,14 180:5

185:10 186:6

187:12 188:7,12

191:5,21

196:12,20,21

197:6,15,22

198:2 199:10

200:22

204:15,18

206:12

207:17,20,21,22

208:7 210:19

212:20

215:15,21

216:9,13,15

217:8 227:2

228:9

235:1,8,17,19

236:3,7,8,22

239:9,15

243:13,18

244:20

245:1,3,15,19,22

248:2 249:9,11

250:7

18-month 176:22

178:15

199 102:8,13

199,000 102:8,16

2

2 34:13

2,300 95:13

2:00 122:20

20 27:13,14 30:2

20/21 213:14

200 54:19,20,21

200,000 145:8

2006 177:1,5

2007 129:8 130:5

170:16

200-gallon 88:16

100:8

2012 130:6

2013 1:11 182:4

2014 182:3 250:10

2015 36:21 56:18

172:9 173:5

21st 213:1

22nd 238:13

24 208:1

26 202:8

26th 4:7,14

27th 4:8

3

3.5 144:10

30 53:9 223:21

227:21 256:19

300 218:9

31 1:11 182:3

31st 7:8 48:10

147:5,15 164:2

181:16 182:2

209:3 229:4

233:15,16

236:5,6 251:14

32nd 164:4

34,000 107:10

35 255:3,22
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4

4,000 150:13

40 103:13 145:7

253:14 255:4

40-gallon 145:6

41,000 95:10

429 56:19 148:18

430 56:15,19

431 56:20,22

43125 56:3

47

121:8,15,16,19,2

2

48 16:17 29:1

36:10

5

5,000 88:16 90:19

5,000-gallon 87:18

98:7 101:13

5:23 257:3

5:25 255:21

50 158:10

500-gallon 88:16

50-gallon 159:13

56 16:17 17:12

29:1 36:10

6

6:00 253:20

60 175:18

65 126:17 139:22

144:21

65,000 125:4,5,14

7

7/31 4:5

70 86:6

740 18:16

75 130:2

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8

8 52:9

8/01 4:6

8:00 254:15

256:22

80 158:10,11

85.5 53:3

88.6 53:4,5

8th 4:7

9

9/15 230:10,12

90 86:18 221:1

223:15 240:10

90.1 130:7 143:21

91.1 53:18

91.7 52:6 53:13

93.5 52:8

95 27:16

97 200:10

99 25:13

A

a.m 1:12

A/C 173:5 203:10

AAON 2:15 6:10

16:15 21:4 26:21

41:17 132:8

165:21 184:15

196:13 237:13

251:2

abilities 104:4

ability 177:22

232:12 246:11

able 11:4 15:16

29:3 42:5 51:4,5

55:21 66:22 75:9

91:12 92:18

93:20 96:9

100:20 104:1

105:12 122:2

166:11 172:19

176:1 194:5

197:14 204:15

207:12,13

214:15 215:19

216:10 221:16

222:5 223:2,3

231:18 234:17

238:11 253:22

ABMA 5:13 9:8

79:7 175:6,9

242:2,5,8,17

above-entitled

257:4

abroad 69:18

absolute 28:3

absolutely 31:11

42:14 150:20

193:13 225:11

238:8

abstain 9:7 108:11

122:12

abstains 57:20

abstentions 8:9

10:5,9 75:2 78:6

79:22 114:14

116:3 120:22

126:22 130:16

131:18 136:1

137:13 139:15

163:4

acceptable 41:2

103:4,11,17

153:14 186:3

208:20 240:19

acceptance 102:11

161:2

accepting 60:15

102:7 188:10

access 156:7 189:3

accessories 224:2

accommodating

12:18 151:14

accommodation

31:2 124:7

accomplish 223:4

accordance 202:21

according 4:4,15

202:6 207:9

accreditation

252:22 253:3

accumulate

205:14

accurate 20:12

28:3 46:11

171:20 202:6

203:9,16 208:22

237:3 258:7

accurately 92:4

accustomed 152:3

ACEEE 5:16

achieve 14:13

acknowledge 31:4

39:18,21

ACMs 35:9

across 85:13
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Act 60:11,13 78:12

169:9

action 84:20

247:21

actions 231:6

active 244:2

actively 116:13

activities 172:3,5

activity 191:17

200:16 202:9,10

actual 19:16 89:11

103:7 156:10

183:11

actually 6:21 7:4

9:2 13:4,21

25:11 32:4,6

49:8 56:3 67:14

68:15 71:1 74:12

86:17 94:3 107:8

130:5 133:7

134:8 135:15

137:4 141:2

142:18 143:18

145:5 151:6

163:9 167:1

169:22 170:15

180:16 188:6

190:6 191:14

194:17 197:22

203:22 205:5

212:7 214:4

222:11,21 224:4

237:2 246:14

add 110:17

113:2,14 122:2

127:22

137:19,22

138:2,19 163:15

206:16 207:16

211:21 226:1

232:18

added 124:17

134:18 138:12

adding 116:6

121:16 159:1

addition 127:21

206:17

additional 48:1

51:10 78:13 90:5

127:20 146:2

162:2 175:1

189:3 210:1

245:9 246:1

247:19

address 12:8 48:7

50:20 59:12,13

62:9 63:5,22

68:8,9,20 69:2

74:18 116:16

136:14 175:2

192:21 194:17

addressed 81:19

91:4 244:12

addresses 194:18

addressing 13:6

172:9

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adequate 89:14

125:9

adjust 245:7

adjusting 35:20

adjustment 36:2

adjustments 41:7

administer 74:12

admittedly 86:3

adopted 107:9

adopting 142:12

advanced 104:16

advantage

188:4,15,18

191:11 224:22

adverse 181:5

advertising 146:6

ADVISORY 1:4

AEDM 21:13 29:4

35:19 164:14,19

165:9,14,22

187:14

197:7,14,15

198:11,12,13,15

200:2 203:22

205:16

207:4,9,10

208:12 212:15

215:8,16 216:1

230:15

233:11,17

237:16 250:20

AEDMs 165:18

167:18

171:12,13,18,21

177:16 178:11

196:2,17

197:6,11

199:12,13 202:3

217:15 224:6

228:22 236:6

affect 45:3 157:7

172:13 188:16

232:8,12

affected 173:2,7

196:11 205:8

affecting 37:2

affects 173:7

afraid 106:12

afternoon 255:3

256:1

against 85:2 95:19

210:19 246:4

agency 61:4

248:14

aggregation 45:16

aggressive 180:10

ago 81:1 148:20

176:11 224:8

agreed 12:13

81:2,5 82:3

87:13 109:18

119:2 152:8

153:10 163:9

165:3 166:10,13

167:20 181:22

182:13 201:6

207:10,14 224:1

245:14

agreeing 40:22

55:5

agreement 126:22

146:19 209:3,6

255:14

ahead 7:22 137:7

140:22 162:16

168:5,13 180:13

182:17 216:5

224:21

AHRI 2:7 3:13 6:4

7:6 39:2 40:7

41:10 67:1 71:5

72:3 75:16 85:19

89:16 90:11

92:20 99:4

102:1,11 104:18

106:14 116:17

119:4,20

120:1,15

121:7,22 125:10

127:6,14 139:21

140:4 142:20

153:2 164:12

184:21 193:15
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204:21 206:2

208:10 209:9

212:2 214:13,19

215:3,6,7 218:8

221:13 225:6,12

238:7,11

239:1,4,8 241:5

249:1 250:6

AHRI's 71:15

218:13

aiming 151:2

air 22:7 40:4 42:6

67:20 75:3 107:5

126:11 127:2

128:20 129:18

130:1 134:7

136:3 171:6,16

176:11,17 177:1

184:21 201:13

203:12 212:12

Air-Conditioning

2:6,11 3:12

air-cooled 115:7

127:15 131:6,8

139:19

airflow 124:12

128:3 133:16

135:12

akin 205:13

albeit 28:2

alive 232:21

alleviate 78:20

Alliance 3:14 5:11

alligator 243:1

allocate 179:16

180:1,2

allow 151:20

allowed 194:5

210:21 247:18

allowing 32:21

allows 18:22 22:18

already 7:12 38:7

77:13,15,16,18

79:17 108:4

110:18 111:13

113:19 114:11

134:14,19

141:20 142:9

148:15 154:10

179:21 187:20

189:15 190:1,15

192:11 198:19

202:15,17,22

203:2,5 206:20

207:15 217:4

226:2 230:2,16

243:1 252:15

255:21

alternate 224:11

alternative 117:22

213:10

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58:15 66:16

70:10 79:2 86:16

94:2 99:5 107:20

122:7 135:10

141:1 146:4,5

178:3 185:21

191:14 194:15

195:9,19,22

204:21 207:12

222:1 228:2

232:19 234:13

237:11 252:2

258:7 259:2

amazing 168:12

amend 70:5

American 3:9

among 155:4

244:19

256:10,16

amount 45:3 107:2

144:2,12 145:19

188:22 201:5

209:21

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Amrane 2:6 6:4

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92:20 93:9,13,16

116:17 117:1

120:15

121:7,10,13,21

127:6,10,14,20

128:3,7,12,14,16

129:9,12,15,22

130:8,11

139:17,21

140:4,9,12

142:20 153:2

164:12

198:3,8,11,15

206:2 215:6

216:16 217:19

218:9 239:4

250:5,14,19

analogy 107:14

analysis 43:1

46:1,19 204:10

205:14 245:21

angle 6:16

annual 169:13

anomaly 145:2

answer 16:21

69:12 75:9 76:1

80:14 82:5 89:19

154:1 212:3

231:19 235:7,10

answered 84:7

112:19

answers 211:20

237:3

anticipate 251:3

anticipating 30:4

anybody 8:9 9:6,7

50:20 57:4,12

107:10 108:11

118:14

122:11,12

182:11 219:1

anyhow 105:10

107:20 196:2

anymore 45:13

anyone 53:21

54:20 58:7 101:6

108:8 109:8

156:3

anyone's 158:20

anything 11:8

87:8,21 97:3

102:16

103:14,15

109:20 115:4

118:14 130:19

131:5 132:22

140:15 143:19

147:4 149:16

168:1 175:15

196:7 212:1,20

217:20 231:3

anyway 79:16

83:17 114:11

120:19

anywhere 99:19

apparently 175:10

appeals 176:22

appear 73:18,20

APPLIANCE 1:3

applicable 63:22

113:3,14 114:1
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215:5

applied 29:10 43:2

79:9

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140:5

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96:13,14 175:10

applying 41:18

43:16 44:16 63:2

88:10,14,17

appreciate 105:20

119:11 145:4

186:20 224:2

appreciates

195:15

approach 16:1

37:11,18 149:21

228:4

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88:19 100:2

106:20 164:16

approval 175:9

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223:5,11 228:22

230:12

arbitrarily 144:6

area 253:8

areas 106:3 154:11

171:11

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aren't 4:16 17:13

18:7 28:11 74:7

169:17 180:14

184:21,22

197:13 217:7

218:13,22

220:16,18

arguing 231:5

argument 144:17

177:19 189:11

ARI 21:8 23:14

46:18

Aris 3:4 6:7

Armstrong 2:8

4:20 7:9 9:17

10:3,17 12:9,22

28:9 30:16,20

32:10 37:20

38:2,14,17

39:12,17,20

40:2,8 46:22

47:4,20 48:8

54:12,16 56:21

66:13 69:9,12,22

74:5 75:5,19,21

76:8,18,22

77:2,11,20

78:2,4,16

79:1,10,13,19

80:14,22 81:18

82:19 83:18

84:6,15 85:3,11

87:9,13 88:2

89:16,19,21 90:1

93:2,12,14 94:6

95:1,21 103:3,11

105:16 109:9,16

110:7,10,16,19,2

1 111:4,11

112:7,11,15,18,2

1 113:6,10,15,22

114:9,19,21

115:2,6,13,15

116:13,22

118:16

119:9,17,22

120:7,11,18

121:3,9 123:13

126:6,13,15

127:4,8,11,18

128:2,4,11,13,15

129:2,11,13,16,2

0 131:3,14,19

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134:4,14,18

135:2,8,15,19,21

136:3 137:7,21

138:3,6,8,13,16,

22

139:5,7,10,13,18

140:2,7,10,13

141:15,18 142:8

143:1,8,15

144:16 145:10

147:2

148:3,9,11,18,22

149:4,7,9,14,18

150:2,7,12,16,20

151:17 152:6,20

153:5,15

160:9,19

161:8,12,15,17,2

0 162:8 163:6,17

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2 227:18,22

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230:4,14,18,21

231:3

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235:9 236:17

237:5,10,20

238:2 240:5,20

241:21

242:12,15

248:18

251:5,8,11,16,20

253:16 254:9,17

articulate 140:14

articulating 82:9

Ashley 2:8 6:18

110:1 127:4

132:9 135:5

137:15

142:15,21

143:10 147:15

149:20 152:15

162:1

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ASHRAE 86:18

130:4,7 143:20

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215:2

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as-needed 116:19

aspect 183:19

ASRAC 109:3

129:3,5,9

219:13,14

228:22 229:14

230:2,8,15

241:15 242:5

251:17 252:14

assembled 69:20

assembles 69:21

assembly 101:15

assessing 191:18

assessment 191:3

246:21

assign 223:4

assistance 115:3

associated 66:4

169:18 205:12

association 238:9

244:8

associations

210:15
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assume 125:21

128:5 129:20

165:11 166:3

182:12 184:17

188:9 191:16

233:15 236:5

assuming 129:6

166:9 230:12

250:14,15

251:18

assumption 188:1

195:14,22 234:4

assumptions 46:20

assurance 230:1

assurances 229:21

230:20

assure 174:7

asterisks 94:8

attempting 65:5

attended 242:7

attention 221:14

233:4

attribute 84:7

94:11 153:6

154:2

attributes 144:22

152:7,12 159:9

August 4:8 179:17

213:3,6,14

229:15 253:4

automatically 11:4

availability

20:13,20 28:19

34:6 35:6 107:20

available

8:2,6,17,18

9:11,19 11:11

19:5,7,10,12

20:3 24:1

28:12,22 29:8

45:8 47:16,19,22

55:18 61:21

84:12,14 125:10

128:10 153:13

159:21,22 172:1

240:9,15

Avenue 1:7

avoid 14:11 25:20

100:21

aware 146:5

217:15,16

222:10,18 225:2

233:3

awareness 62:2

223:2

away 105:18

116:11 199:21

255:12

B

background

167:15

backwards 193:1

bad 169:22 249:15

baked 232:20

ball 72:16

Ballo 2:9 5:17

36:20 56:16,20

58:14 59:15,19

61:7 70:4,20

72:2,11 74:16

98:19 121:1

134:9,13 147:6

156:1 169:12

174:15 188:19

216:6 217:2

246:9

bands 29:21,22

bar 245:12

Barhydt 2:10

6:5,19 7:11

8:5,21 12:3

13:3,11

49:7,11,14,18

58:5,10 59:6

61:11 63:15

64:2,10,13 65:16

66:3,9 67:12,14

68:14,19

69:1,17,20 70:19

72:8,22 73:10

93:22 95:7 114:7

115:17 123:2

147:20,22

148:7,10

152:2,15

170:17,20 171:2

180:20,22

189:13,18

190:9,15

191:10,18

192:20 193:7,10

194:9,14 195:6

197:4 198:6,9,13

201:2 202:12

203:19 205:10

210:9 230:2,8

231:5

233:10,14,21

236:18

237:16,21

245:11 246:14

247:5,9,22 248:2

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2 251:7,10

253:7,11,14

254:2,6,15

BARHYTE

248:22

base 11:1,10,15

13:15,18

15:2,5,8 16:2

17:16,21

18:4,8,11 21:9

24:18 30:21

31:1,4

32:13,15,19 33:6

35:19 51:18

118:21

119:8,13,19,21

124:16 242:19

based 19:11 35:21

36:2 39:1,16

41:6 44:14

46:6,13,17,20

49:4,5 94:16

96:20 98:11

106:7 127:12

129:5 147:16,17

155:10,17 158:4

177:7 184:7

189:17 191:22

192:7 207:15

208:3,6,11 234:3

baseline 20:17

26:11 53:4,14

basic 7:1 13:12

19:10,11,16

31:22 33:9,13

35:7 36:4 37:3

52:5 83:13 91:10

94:8 101:1

111:13,18,20

116:22 117:1

158:9 189:2

190:2 192:18

224:5 229:1

249:4 251:4,6

basically 9:17

18:16 38:12 62:6

90:18 99:11

123:6 145:15

146:3 195:9

243:7 246:21

247:2 255:10

basis 46:9 58:22
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73:4,11 185:14

187:15

become 125:21

165:18 244:6

becomes 28:18

53:5 66:8 87:4

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188:13,14

becoming 78:10

bed 186:14

beg 178:22

beginning 20:1

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245:12

begs 39:9

begun 207:15

behavior 249:3

behind 62:20

181:2 195:14

belief 39:22 71:11

believe 37:14

40:1,3 49:3 57:4

89:2 105:19

126:17 131:13

139:22 177:21

209:19 210:8

213:1,5

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57:13

belong 209:9

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benefit 104:6,16

155:11,12 158:1

160:2 168:12

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benefits 177:11

besides 206:3

best 13:8 92:9

96:15 101:21,22

161:21 176:18

181:12,14 202:6

215:4 225:8

bet 173:6 181:14

better 15:10 18:4

27:6 30:2 105:7

123:13 155:12

158:22 159:2

163:2 167:1

173:22 180:1

189:1 197:13

225:19 243:17

256:21

beyond 54:19

101:2 154:6

196:22 207:9

252:19

bigger 46:15

147:12 158:15

185:22 209:15

223:10

biggest 87:22

233:10,12

bit 8:11 9:10 42:21

62:13 96:1

154:17 156:2

161:7 171:6

173:1 180:6,13

203:20 214:14

231:20 254:4

255:9 256:9

bitter 122:4,5

blame 135:18

blank 68:11

blind 176:6

blowers 13:13

board 161:13

186:4

Bob 6:2 11:17

34:16 35:3,11

41:4 49:1 59:17

64:3 116:4 118:9

184:8 187:17

189:21 221:4

256:8

Bob's 189:16

bog 174:9

boiler 102:2

204:22 205:6,9

212:11

boilers 78:7

103:5,12 161:1

173:3 193:13

205:1 209:19

234:16

booked 222:15

books 38:7,8 182:5

229:5

border 70:8 72:14

borderline 39:6

248:9

borrow 253:20

bother 156:17

bottom 124:18

138:14,19 139:3

216:10 227:1

bought 65:2

77:13,15

box 70:1 72:8 73:7

94:2,4,10 143:14

brand 61:22

64:3,7 65:16

66:4,5 74:8,15

branding 67:20

brands 65:20

break 20:19 57:22

101:13 143:13

155:3 160:5,22

203:9

breaking 246:7

breakpoint 161:9

brief 58:1 160:6

bring 36:2 58:2

187:2 199:12

239:6

bringing 63:13

186:20 226:13

brings 127:2

130:17

broad 201:11

228:14

brought 19:3 42:1

btu 107:10

btus 102:16

150:13

btu's 90:19 102:9

145:8

bucket 83:9 85:4,7

144:21 152:17

buckets 152:16

budget 231:9,14

buffer 150:21

151:10

buffering 151:7

build 9:21 111:7

112:3,6 145:22

173:8 184:21

195:2 253:1,3

buildable 194:21

builder 63:17

building 1:8 20:3
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built 11:12 23:21

111:3 112:2

170:4

bulb 95:9

bulk 174:7

bullet 110:4,12

123:7 160:22

bump 248:11

bunch 94:8,9

165:4

burden 117:3,7

189:5

burdens 169:18

burdensome

117:17 118:6

168:3 197:8

bureaucratic

184:13

bus 210:4

business 45:15

76:4 101:18

168:10 179:14

202:11 231:22

243:2 244:3

businesses 168:21

249:16

buts 83:11

buy 23:6,10

24:9,11,12 30:10

34:3,11,14 45:9

77:20 156:5

158:2,4,5

buying 65:8,11

67:16

buys 64:6

C

cake 232:19

calculate 18:19

calculated 52:19

160:14

calculation 51:21

calendar 252:20

candidate 215:2

capabilities 206:9

capability

242:11,22

capable 243:6

244:12

capacities 89:5

159:6 203:10

capacity 91:1 95:5

99:9 100:18

104:2 105:1

107:3,6,16

124:11 128:1

135:3 136:17

144:21

152:16,18,22

153:8 157:11

capacity-type

160:20

Capital 1:17

capture 145:12

capturing 152:13

carbon 104:11

cards 6:15

care 76:18 77:3

120:17,20

131:11

careful 76:6

Carrier 3:18 6:2

11:18 34:16

35:12 41:4 49:1

62:9

64:3,5,6,7,18

68:5 116:4 184:8

220:12 221:5

256:8

cascading 104:9

case 4:9 15:6 21:9

25:18 27:15

28:17 30:12

35:15,18 40:1,14

42:2 63:5,8 67:4

80:19 86:12

104:20 105:11

110:11

112:4,9,11 113:4

114:17 146:1

177:7

cases 28:12,22

29:6 41:8 42:4

61:18 64:17

111:7 113:4

114:16 196:1,3

catalogue 65:9

157:2 158:20

catch 9:3 22:12

130:9 152:11

245:11

categories 123:7

170:15

177:12,14,17

184:4 186:2

228:14

categorized

192:12

category 63:14

93:10 104:22

129:14 138:18

192:11,15

205:20

cause 39:4

caveat 246:10

CC 233:8

CCMS 191:4

CCV 233:7

cells 222:15

central 107:5

cert 48:14,19

228:21

certain 14:6 22:6

32:14 34:4 45:17

46:20 95:4 96:16

104:2 105:5

106:12 126:8

168:17 169:15

188:10 204:2

207:4,6 208:20

216:8,13 224:15

228:4 239:22

243:12 249:15

certainly 23:8

46:11 101:6

103:17 176:15

177:3,4 181:2,4

244:17

certainty 109:10

CERTIFICATE

258:1 259:1

certification

7:3,10 14:7,13

20:18,22 21:12

22:17 23:7 24:7

26:10 30:21 39:3

40:7 45:16,19

48:12 58:3

62:15,16,17

63:1,4 64:14,18

65:17,19 72:5

90:13 94:14

95:11 101:2

102:12 111:1,10

113:11 130:21

169:18 170:17
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171:7 175:1

187:18

189:2,18,20

190:3,9,17

191:1,4

193:18,21 194:4

195:5,16,20,21

198:7 206:19,21

215:17 240:5,10

249:2 253:1,3

certifications 94:2

95:16

certified 14:6

21:21 36:14

51:19 52:5

64:17,19 65:13

111:14 190:1

192:2 193:3

195:12 246:15

certify 14:10 17:22

22:3 26:10,12

31:12 75:14

111:18,19

112:1,16 116:21

187:18 198:1

204:7 240:7,8

246:11 258:4

259:2

certifying 21:7

46:6 79:3 195:7

cetera 29:2,5

75:13 81:10

171:19 183:11

203:11

CFM 24:17 133:13

CFR 56:3,4,16,18

150:8

challenges 185:22

chance 48:3 75:8

change 9:6 15:8

33:8,9 43:9,11

44:13 61:9 88:4

95:17 102:15

109:20 114:9

119:17 126:1,2

131:9,18 141:13

143:13 147:4

154:12 159:22

166:2 174:18,22

175:3 181:8,11

219:15,22

220:14 231:3

234:22 235:4

240:9 248:15

changed 114:6,13

124:12 133:1

161:3 192:17

198:16 201:7

226:15 234:16

247:20

changeover 122:8

changes 166:12

169:17 174:21

180:18 196:4

220:6 247:20

changing 84:4

148:13 187:19

channel 202:1

chapter 147:19

characteristic 81:6

94:19,20

characteristics

7:14 29:4 94:3

96:7,11,20

103:21

characterized 92:3

charging 113:3

114:1 124:15,19

Charles 2:17

Charlie 5:12 51:6

68:7 170:13

189:6 209:1

247:2 255:19

Charlie's 51:15

charter 218:13

check 95:19 100:3

113:12

checked 36:12

53:22

checking

183:10,18

Cheerios 109:8

cherries 162:12,19

chicken 97:5

chilled 128:19,20

chime 130:22

choice 155:10,17

157:3 158:22

159:3 193:21

choices 19:13

choose 19:11

61:19 158:3,14

chooses 99:10

choosing 19:17

chose 191:8 225:7

circumstance

63:20 67:7,17

civil 246:17

claim 25:22

clarification 8:2

11:18 110:3

131:21 132:5

187:22

clarified 69:16

clarify 9:10,13

12:1,7 87:9

111:22

class 24:14 28:7

39:9 93:6 98:21

104:21 114:10

120:19 127:12

160:10 171:4

201:4 210:7

211:10,22

classes 107:4

113:18 127:16

144:17

171:10,14 201:5

204:14,17

210:16,20

classification

101:9 110:9,18

124:16

classify 107:5

clean 8:11

clear 7:20 20:5

61:8 70:12,18

87:10 121:11

175:18 244:15

254:4

cleared 230:16

255:22

clearly 82:9 96:9

102:19

clients 242:18

clock 231:4 241:14

250:6,13

close 119:5 175:15

209:3

clothes 152:22

Co 2:21 3:6

coast 214:10

Coated 226:9

code 170:15

226:4,5

coil 145:15 201:21
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coils 226:4,5,9,16

cold 150:22

collect 69:6 74:12

93:5 97:1 152:7

214:18

collected 39:2

159:10

collecting 87:11

collection 155:22

Collin 3:17 6:8

color-coordinated

95:10,13

column 52:17

53:5,18,19 68:16

73:18 95:17

240:12

columns 68:10

74:8

comb 71:17

combine 171:17

250:3

comes 31:14 70:13

174:19 183:11

192:15 231:13

comfort 225:20

comfortable

40:11,15 55:21

61:17 117:20

146:13 156:10

178:14 199:14

238:15 241:4

244:18 246:19

coming 6:19 52:14

98:8 109:14

142:10 150:17

173:5,13 174:6

178:11,21

241:5,6 244:17

246:4 256:7

comment 9:2 61:5

116:5 119:18

155:7 160:3

180:21

181:2,9,14,19

183:4 229:18

233:21,22

242:13 243:21

comments 8:8

15:20 47:15

49:20 57:1 59:1

78:8 103:2

109:11 124:22

126:20 130:14

151:18 172:17

175:4 176:14

181:5 191:19

197:5 219:21,22

237:6,12

commerce 101:3

189:19

190:10,18

195:8,12

commercial 28:19

59:20 67:17,18

74:6 75:3,6,12

76:3 78:7

80:1,11 86:1

88:1,17 89:6,9

90:13 96:5,17

102:22 106:5

123:9 140:16

143:14 145:4,7,9

146:7 149:22

150:11 154:13

171:5 172:4

193:12 200:12

209:9,19

212:10,11,12,13

commercially

28:12

Commission

104:14

Committee 1:4

109:3 165:16

218:1,2 221:22

common 55:5,6,10

67:5 116:8 168:7

170:9 220:14

244:9

communicate

218:12,15,17

communications

221:13

companies 73:15

100:17 118:4

167:16 178:8

183:21 184:2,6

185:4,5,8,22

186:16 188:3

209:15 231:10

235:11 238:18

240:22 241:11

242:21

244:2,4,10 248:8

company 1:17

2:19 23:6 24:12

42:3 44:2 45:15

46:2 50:6 64:7,8

65:2 97:19,20

170:9 173:7

174:13 175:14

177:22 179:8,17

184:9 185:19

196:8 201:9

203:9 209:10

217:11 220:13

225:10 233:5

240:17 241:8

252:9

company's 97:16

196:14

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compelled 15:15

competitive

188:18

competitors

218:12 221:10

complete 91:14

196:5 215:16

259:7

completed 176:3

completely 22:2

53:12 94:9

111:14

completion 233:7

complex 96:2

compliance 106:21

136:12 152:14

179:6 203:17

206:13

compliant 38:18

39:7 100:2

228:10

complicated 186:2

comply 21:22 41:9

45:20 81:15,17

87:5 92:4 118:1

154:8 156:22

157:21 173:16

187:20 207:5

212:15 232:8

240:4 243:13

complying 21:1

87:4 90:15

178:21

component 43:8

137:4

components 33:8

124:8

comprehensively

228:9

compressor

124:13 135:6,7
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compressors

135:13

compromise

227:19

228:12,15

computer 127:2

201:15,17

206:10

concept 17:10,15

43:16 48:9

189:22 223:19

concepts 222:11

concern 12:8 30:7

31:14 71:3 72:12

87:22 93:17

104:20 125:2

141:6 194:17

236:11 242:9

concerned 31:16

97:6 122:7

205:22 210:13

252:3

concerning 109:5

concerns 48:7

50:19 57:11

58:13 62:9

73:3,15 78:5,20

114:4 116:1

120:13 121:6

122:11 141:6

concession 105:20

conclude 252:17

concluded 257:4

conclusion 52:2

255:6

condensed

52:10,11

condenser 127:15

128:22

condensing 104:8

110:3,12

113:1,5,9 137:2

205:1,8

condition 24:4

conditioner 40:4

176:17 177:1

conditioners 67:20

107:5,6 126:12

127:3 171:16

176:12 201:13

conditioning

184:21 212:12

conditions 21:8

22:18 23:15

24:2,11,13,21

32:18,22 39:1,3

40:22 46:8 106:7

136:17

confident 185:12

196:22 197:2

configuration

30:22 31:1,4

75:11,14,19,20

77:15,16,18

110:13 113:1

configurations

76:4

confirm 100:1

115:12

confirming 182:9

conflict 243:8

confused 156:2

226:18

confusion 4:3

148:5

consensus 50:17

109:3 121:5

146:19 176:10

241:3,6

consider 48:7

100:16 185:9

214:12 229:11

235:13 236:7

243:10

considerably

197:8

consideration

99:18 105:22

235:14

considered 115:16

considering 94:15

141:2

consistent 124:19

consolidate 110:21

constraints 46:3

176:18

constrict 256:6

consult 212:10

Consultants 2:16

Consulting 2:3

3:8,17 14:3

consumer 36:8

46:11 65:12

82:18 84:8 85:12

93:6

consuming 23:8

consumption

33:12

contacted 225:3

contain 146:1

contained

144:4,13

contemplate

126:18

context 32:9

continue 66:18

256:4

continuous 101:8

contract 69:4

contrast 150:5

control 33:12

190:20

controls 52:3

conventional

110:14

conversation

49:16 117:15

210:5 215:10

conversations

14:20 221:10

conversion 18:21

convince 250:4

cool-down 205:7

cooled 131:5,9,11

132:10 136:4

139:19,22

cooler 137:11

coolers 42:2

cooling 2:15

127:22 128:1

135:2 144:20

cooper 226:16

COP 121:8

122:1,8 135:2

140:5

copy 5:4 6:20 80:6

138:20 141:12

corner 220:16

225:5

Corporation

3:11,18

correct 16:6,7
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24:8 25:8 45:1

64:12 67:11 77:5

81:18 83:18

93:18,21 94:14

115:13 118:11

126:6,13 132:2

150:16

157:12,19 188:1

259:7

correcting 35:20

correctly 60:1

234:10,13

cost 101:17 220:2

223:7

Council 3:9

count 35:7

country 63:14

couple 17:19 20:14

29:6 47:14

122:17 126:7

167:3 176:7

188:19 224:20

225:18 227:3

229:6 243:21

course 27:1 45:14

84:20 216:18

court 5:3 6:16

60:14 258:1,2,15

259:3,5

cover 31:8

200:11,12

covered 31:15,19

96:10 138:16

169:16 196:2

207:7

covering 137:5

co-worker 120:7

Cracks 171:2

crazy 226:12

CRE 108:19

109:15 114:5,14

118:3 177:17

198:14 209:14

create 55:15

106:18 118:2

167:11 207:11

234:21

created 118:11

creative 246:6

credit 166:7

249:17

CRF 129:4

criteria 90:16

99:12 155:14

157:9 158:4

critical 57:17,19

cross 113:1,2

crushing 170:1

cuff 172:17

current 17:2

38:21,22 49:3

83:20 102:11

190:7 194:12

252:11,20

currently 63:15

90:14 98:20

119:20

curve 25:6 29:5

210:12 247:11

curves 32:19 46:4

custom 10:13,14

40:16 102:6,21

185:4

customer 9:20

33:2 111:8

112:3,6 155:9

238:8

customers 40:17

98:4

customer's 157:2

customer-specific

111:3

customization

177:14

customized 101:14

Customs

70:8,12,16 71:9

72:14 75:1

custom-type 102:7

cut 45:21 76:16

cutoff 101:19

102:13 149:16

cycle 179:16,17

207:6 231:8

cycles 236:4

Cymbalsky 2:12

6:6 17:9,12 33:4

34:19,22 74:1

85:12 107:22

108:3,13 109:8

175:17,20 248:4

249:1 255:16

256:2,14,18,22

D

D.C 1:9

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daily 178:4

damper 105:6

dampers

12:10,12,15

Dane 2:13 5:20

112:22

113:8,12,21

114:3 117:14

167:14 169:3,4

177:20

178:17,19

179:3,11 209:4

214:7

dare 100:7

data 29:15 46:18

52:11 71:16

91:14 100:20

103:16 106:15

159:10 171:19

172:2 183:2,11

188:10 192:19

201:14,17

202:17 203:15

204:6 207:8

214:19 215:18

217:1

225:9,10,19

226:2

245:5,16,20

249:2

database 70:14,21

71:13,22 74:6,13

85:13 106:19

189:2 216:11

239:16

date 4:13,14 7:7,8

49:5 56:17 118:1

163:8 164:2

165:20 166:14

169:21 173:16

174:20 178:15

181:8,16 182:5

184:17 186:3,18

187:3,4,7,8

189:17

191:7,21,22

192:7,16,17

193:3,17 194:13

211:6,11 213:16

214:2 215:15
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229:3,7,8

230:6,21 231:8

232:19 233:16

234:2,9

236:5,6,13

237:19 238:1

240:18 244:22

245:14

250:12,13

251:15,20 252:6

259:13

dates 4:4 163:12

170:22 177:12

213:10,19 214:2

229:21 230:1

231:21 252:1

datum 175:7

day 189:21 197:21

211:18 214:8

227:14,21 251:1

252:1 255:12

256:10

days 175:18 213:7

214:11 223:21

253:9

de 46:16

deadline 148:21

187:18

188:11,17

198:10 239:15

deadlines 210:14

232:3

deal 111:2 223:10

dealing 38:4

194:20

December 7:8

48:10 147:4,15

164:2,4 181:15

182:2,3,22 205:3

209:3 229:4

233:15,16

236:5,6 251:14

decide 62:14

88:3,4 100:17

104:6 111:17,20

189:8 240:7

decided 134:15,19

deciding 158:2

decision 219:7,17

226:11

decisions 45:15

225:9

declaration 105:17

113:19

declare 31:1 85:3

103:6 120:18

declared 30:22

31:3

dedicate 178:1,7

dedicated 77:19

172:11

default 32:16

236:15

defaults 108:3

defense 135:15

deficiency 151:22

define 169:3,4

228:14

defined 113:18

124:7 145:5

234:14

defines 251:4

defining 32:8

definite 25:14

53:15 135:8

definitely 37:5

definition 32:1

145:8 149:22

150:6 169:10

235:5

definitions 96:1

169:7 194:3

234:22

degree 130:3

degrees 121:8,15

delay 232:22

delaying 234:13

deleting 121:1

delineate 96:9

delineated

144:17,20

deliverables 210:8

delivered 98:1

demonstrating

32:12

den 123:22

denominator

168:8 170:9

244:9

department 1:1,6

2:8,10,12 3:4

11:14 28:8 48:15

65:14 66:20,21

78:22 79:4,15

83:21 84:11,20

87:19 90:4,6,10

142:13 153:15

156:9,17 163:10

185:18 191:2

227:4 228:17

229:1 235:12

237:4 245:16,18

Department's

197:4

depend 96:7 240:6

dependent 177:22

depending 201:19

209:14

depends 64:10,21

67:16 111:11

158:19 230:14

deplete 187:7

de-rate 40:20

describe 30:18

63:20

described 11:20

34:17 35:8 66:15

110:5

describing 29:13

description

14:4,22 157:1

218:11

descriptor 107:16

109:11 142:10

143:12

design 45:5

83:3,4,7 144:1

157:9

designated 189:7

designating 195:9

designation 110:5

113:17 114:10

designed 23:21

44:15 88:18

designer 69:5

designing 44:18

207:3

detail 208:5

detailed 236:14

237:2

details 36:7 50:7

57:14 79:8

determination

40:19 91:19
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152:13

determinations

224:5

determine 21:12

28:9 60:6 86:22

87:16 106:20

153:9 154:7

202:5

determined 18:15

97:17 143:22

determining 90:9

106:9

develop 198:18

207:9 216:2

224:7

developed 202:15

developing 198:21

199:5 206:10

development

174:2 207:5

218:16 252:8

devil 36:6

devote 231:15

diameters 202:1

Diane 2:21 6:12

19:3 44:10

difference 12:16

14:2,3 35:21

65:12

76:7,9,10,11,12,

14 77:8 115:9

127:8 157:20

178:20 213:21

222:9,17 223:1

240:12 248:12

different 7:13 12:1

30:5 32:22

37:2,12 40:4,18

44:16 45:22

54:19 55:13,14

63:7 69:12 77:17

81:4 94:9 98:1

102:2,6 106:3

119:1,13 124:5

131:6,21 132:10

135:6 136:22

141:3 149:21

165:4 166:11

168:2 170:22

171:11 180:9

184:4,5 185:22

192:11,18

194:2,3 197:7

198:16 200:3

201:22 204:12

211:16 212:20

220:6 224:6

225:4 232:18

236:10 238:18

240:22 241:2

244:16 246:13

249:13 252:16

differentiation

102:5

differently 55:14

192:3 203:20

218:21

difficult 27:10

87:5 97:8 165:8

168:22 178:13

182:11,14 192:6

difficulty 65:15

66:16

dig 50:7

Digital 258:15

digits 120:5

diligence 245:9

dimensions 121:2

directed 104:13

134:17

direction 47:1

50:16 220:4

258:6

directly 102:4

221:11

directory 46:18

119:4 157:5

disagree 42:21

119:10

disagreeing 77:12

disagreement

131:17

disclose 36:7

disconnect

86:15,16

discontinued

194:1,4,6,16

195:2 196:1

discourages 151:4

discuss 78:11

116:18 122:14

142:2 180:8

228:18

241:1,2,11

253:21 255:13

discussed 7:16

20:10 30:21 80:4

109:2,18 115:7

117:3 149:18

220:10 225:4

255:11

discussing 17:1

105:20 221:11

256:3

discussion 49:13

57:8 76:3 81:1

84:17 99:19

104:21 107:2

115:10 117:17

122:15 126:4

130:18

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203:7

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24:9,11,21 25:9

26:19 33:5,10

36:11

37:14,18,19

41:11 63:2 66:10
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28:3,5,6
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186:18

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enter 193:22
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entire 58:18

197:18 238:17

entities 168:19,20

entity 207:11

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107:17

experiences
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explain 51:17

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explicitly 32:6

expose 65:11

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finish 126:7

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143:2
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151:6

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firms 176:15

first 4:13 10:20

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gallon 88:17 92:11

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gallons
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82:14 83:2,17

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43:10,11 45:22

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guessing 13:3

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H

half 21:7 27:14

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35:13,14,19 36:1

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170:7

half-horsepower

21:18 23:13

Halley 2:16 5:13
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106:1,13 108:7

141:9 147:14

151:19 154:3

180:4 209:18

234:1

locked 166:4

long 118:13

145:21 155:16

183:4 192:17

197:12

211:9,15,17

214:18 216:14

225:12,16

229:15,16,18

230:12 235:11

longer 21:2 39:6

88:13 175:20

194:22 195:9

241:14

looming 181:16

loops 232:22

loose 107:11

loosely 98:17

lose 214:8

loss 35:16 81:20

82:6,8,21

83:1,9,10

86:3,11 87:5

88:9 98:15 99:11

102:20 144:7

158:18

losses 15:11,17,18

17:22

18:4,14,15,16

29:5,16,22 30:3

53:9 77:10

158:11,13

lot 7:12 13:19,21

33:19 43:9,11

44:19 50:17 69:4

76:3 91:6 96:19

97:8 107:2 118:9

119:11 121:18

152:8 153:1

168:12

170:10,20 171:8

172:3,11,14

177:14

178:9,10,14

185:4 187:5

188:5 200:16

207:8 209:12

211:16 215:3

220:3 224:17

244:4,5

247:11,12 248:7

255:10 256:1,11

lots 91:1,2 184:1,2

206:21 232:2

loud 34:7

Louis 3:14 5:10

10:11 125:20

128:17 133:2

157:6 166:8

182:15 183:16

214:13 238:3

243:22

love 123:16

low 22:11 27:9

lower 15:11 21:21

23:8 24:4 30:14

34:3 35:16 39:5

lowest 168:7 170:9

244:8

lunch 108:18

109:7 122:16,17

130:18

lunchtime 7:5

M

magnitude 119:12

magnitudes 120:3

main 64:18 195:10

maintain 117:4

252:11

maintained 174:21

maintaining 81:14

major 67:18 141:5

154:4

majority 24:6

146:16 215:7

239:11

makers 219:17

makeup 136:10

MALE 66:7

122:19 134:22

164:4,20

manage 178:5

192:8 193:4

200:17

managed 78:14,17

management

186:15,16 223:6

man-hours 222:13

manpower 180:3

223:4

manual 124:20

manufacture 49:5

187:3,8 189:17

191:22 192:8

193:8,17

Manufactured

192:16

manufacturer

9:14 30:11 33:6

35:18 37:12

58:16

60:3,6,12,15

61:12,20

62:8,16,22

63:4,7,9,17

64:9,13,15,16,20

,22 65:3 66:5

68:8,16 69:6,8

70:22

72:3,6,7,10

73:6,14,18,21

74:3,11,17 84:17

87:3 92:16 95:4

99:10 158:3

168:3,8 177:4

190:18 191:3

193:2,22

194:1,5,6 201:20

205:19 206:9

222:3 234:6

manufacturers

29:21 30:13,19

38:13 40:9,15

61:11 65:18

66:18 75:7

97:6,10 100:15

101:4

104:6,10,17

116:7 117:3

127:21 145:17

146:13,19 151:1

166:11 167:6

168:12 176:16

177:2,11 191:8

196:4 198:17
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204:15

206:3,14,17,19

208:17 209:22

210:4,15

212:10,11,12,13

215:19,22 216:8

221:8 225:4

234:7 236:16

238:5 239:22

240:4 245:6

248:9 253:19

254:8

manufacturer's

65:21 73:8

manufacturerspecified 132:21

manufacturing

2:17,21 3:6,16

5:12 62:2,3

68:12 69:4

211:11

map 239:8

Marantan 3:4 6:7

margin 21:21

100:11

mark 2:15 3:5

6:10,11 16:15

21:4 26:21 33:17

41:17 72:9 132:8

137:1,10 165:21

184:15 196:13

237:13 251:2

market 29:21

42:15,19 145:4

159:6,9,14

marketing 65:14

marketplace 41:2

102:10 174:10

Marshall 2:19

60:18 61:2 82:15

84:6 91:5,17

100:20 101:11

103:3 108:10

122:6 125:1

137:6,7,8

140:20,22 141:1

162:14,16,18

Marshall's 100:13

104:19

Mary 2:13 5:20

112:22 117:14

167:14 169:4

171:9 177:20

209:4

massive 193:5

match 83:14 159:9

201:17

matching 94:13

maternity 233:19

math 53:21

matter 13:7 51:2

55:3 57:5,12

82:9 83:10 85:5

106:11 144:9,15

159:17 229:3

231:1 257:4

matters 230:22

max 27:15

maximum 86:2

87:5

may 7:6 9:11,21

21:16 27:9 29:9

37:12,13 41:7

42:14,21,22 43:9

60:10,14 61:16

62:14 75:9 113:9

114:22 119:1

136:10 171:13

172:5 185:6

192:2,6 200:2,18

201:20,22

205:20 214:3

218:13 220:14

223:6 229:10

234:5 240:12

245:21 247:7

maybe 8:11 10:12

19:18,22 20:21

30:6,7 37:2

40:11 45:8,9

50:8 93:16 95:19

111:22 115:1

118:17 121:15

130:1 149:20

166:15 167:10

180:8,13 183:20

184:4 186:13

190:5 192:1

200:20

203:11,19

213:15 214:22

215:12 221:18

226:16

227:17,19

228:3,12,14

229:22 234:19

239:12,13 245:7

249:15,16,17

250:1

McQuay 2:22 6:9

mean 9:11 10:17

12:2,11 20:5

21:19 25:5

26:9,19 31:17

37:20,21 40:8

43:6 45:7 46:18

50:5,14 55:11,15

58:15 61:8

63:2,3 64:1 71:6

72:2,12,19 74:5

77:5 78:16

84:6,12,22

85:1,20 87:11

88:2 90:1

93:7,12 94:7

96:4,14 104:19

105:11 108:4

109:9 111:15

112:15 114:1

117:7

118:8,17,18,19

119:22 120:3

121:10 125:17

126:1 133:7

138:13 140:7,14

144:16 149:19

153:5,17 157:8

158:8 159:19

166:12 167:2

169:6 170:3,21

175:13

178:19,22

179:14 180:20

181:2,9,20

182:2,10,18,19

184:9,16 185:18

186:5 187:20,21

188:5 194:20

195:10 197:16

198:4,20,22

200:5,6

212:4,17,21

213:4,12 214:9

215:7,9,11,13,22

216:4,20 221:9

222:16

223:14,22

224:7,14 226:22

227:1,6 228:16

234:3,5 235:22

236:1 239:12

240:21 241:1,6

245:4 247:12

249:1

251:12,13,20

252:7,20

254:9,10,17

meaning 88:10

187:3
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means 8:13

12:12,21 32:8

71:14 103:18

194:6 233:4

255:21

meant 8:3 95:20

measure 81:9 89:8

144:7 145:19

156:15

measured 80:6,12

81:4,14 82:7,22

83:9 94:16

103:16

148:4,6,8,12

161:5

measuring 76:5

77:10 156:17

mechanism 13:8

mechanisms 76:16

medium 127:15

128:22

meet 4:9 15:15

20:7 22:6,18

25:15 39:13 44:1

82:6 83:2,16

89:14 97:8,12

99:12 140:8

159:15 170:10

176:21 194:19

227:10,11,15

230:1 247:3

meeting 1:4

4:5,6,7,8,13,14

50:8 59:22 106:9

137:11 195:7

200:6 212:5,6,22

213:2,7,14 214:4

215:4 219:14

222:4 230:3

238:13 240:18

241:15 242:6

247:17 255:5,9

meetings 51:8

241:13 254:22

meets 22:17

159:20 204:8

member 202:18

225:13

members 175:9

184:21 202:22

215:7 217:22

218:2,8,14,18

221:21

239:11,19 241:5

242:6

membership

212:14 242:8

Men 176:19

mention 188:20

mentioned 56:9

72:20 122:7

173:2 174:16

188:3 221:5

226:3

Menzer 3:5 6:11

merely 89:13

met 10:20 229:22

Metcalf 1:16

258:2,15

method 87:19,20

93:3 95:6 134:1

metric 89:8,12

125:16 126:3

metrics 92:5 126:4

Meyers 3:6 5:15

8:1,7 9:13 10:6

31:13 36:18

42:20 43:20

44:3,5,8 50:2,5

54:2,5,9,11,15

57:7,15

84:11,13,16

85:9,17 88:20

108:9 142:6,15

153:17 162:7,9

172:22 189:16

190:13 191:20

192:13,22

193:9,11 194:18

200:5 222:9

229:12

230:10,17,19

231:1,7 233:12

240:2 244:22

245:14

MG-1 17:8

MG-1s 56:7

Mice 176:19

Michael 3:3,8

micro 202:1

middle 108:22

117:10 168:15

204:10 207:14

230:4 232:5

241:15 252:4

Mike 5:19 14:2

15:21 28:15

31:21 54:2 211:2

217:9 219:8

220:7

millimeter 201:21

millions 118:12,19

119:3,5,7,13,15

198:20 223:7

Mimic 138:7

mind 77:7 206:3,6

246:13

minds 125:19

mine 6:21 194:18

242:18

minimum 15:1,6

17:2 18:1,9,12

25:17

27:6,8,14,15

30:2 32:7

35:16,22 36:3,12

37:7 38:21 39:8

40:21 42:16 52:8

53:3,13,16 86:2

100:19 106:9

150:10 172:21

182:1 201:10

208:16 247:18

minimums 247:3

minus 18:17 87:18

97:7,9 98:5

minute 10:6

minutes 155:4

253:15 255:4,22

256:19

missed 208:14

245:12

missing 204:10

mistake 247:8

misunderstood

190:5

Mitsubishi 2:14

5:21 8:10 123:5

137:16 180:12

187:9 208:8

213:13 223:20

mix 185:7

model 7:2,17,19

8:4 13:12,16

19:11,16 32:1

33:6,9,14,22

34:2 35:1,7,13

37:3 41:2 52:5

65:11 71:13

74:8,15 94:8,9

98:14 99:14
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101:5

111:12,18,20

112:1,2

116:20,22 117:1

118:21 119:13

135:7 189:22

190:2 192:1,18

202:22 203:2

224:5,16 251:6

models 10:13 18:2

25:22 36:4 65:19

68:2 92:4

111:2,6,13

118:12,19

119:8,19,21

147:8 172:2

183:10 191:2

196:1,18 205:4

224:13 229:2

249:4 251:4

modifications

139:15

modified 137:13

Moldy's 175:14

moment 90:18

92:12 137:5

175:13

momentarily

54:13

Monday 212:8

money 45:9 91:6,7

220:3

month 222:8

227:21 245:7

247:1

months 142:13

164:8,10,11,13,1

7 165:13,22

166:19

167:8,11,12

168:1,17 170:5

172:17,20

173:22 174:14

175:16 176:21

177:7,18

178:14,16

179:4,7,8,12,15,

19 180:5 182:1

183:1,5 185:10

186:6,11 187:12

188:7,12

191:6,9,21 192:2

193:8

196:12,20,21

197:6,15,22

198:2 199:10

200:22

204:16,18

206:6,12

207:13,17,20,21,

22 208:1,2,7

210:2,19 212:20

215:14,15,21

216:3,9,12,13,15

217:1,8,14 224:8

227:2 228:9

235:1,8,17,18,19

,20

236:3,7,8,9,22

237:7,11

239:9,15

243:13,18,19

244:20

245:1,4,15,19

246:1,2,16,19

247:13,18,19

248:3,12

249:9,11,14,18

250:7

morning 254:3

256:4,22

mostly 60:9

motion 220:1

motor 13:16,18

14:6,8,9,12,14,1

8,19 15:1,5,9,22

16:1,2,3,8

17:15,18,21

18:1,4,8,10

19:11,21 20:17

21:8,9,13,16,22

22:9,12,17

23:7,8,13,19,21

25:5,10,11,14

26:5,6 27:7

28:6,7,20,21

29:8,20 30:12,22

31:1,7,10

32:4,6,8,20

33:7,9,11,20,21

34:5 35:14,15,20

36:2,5,13,15

37:12,17

40:18,21 44:22

45:1,19 46:7,8,9

51:19,22

52:5,6,8,20

53:2,3,4,12,15,1

7 55:6,7,10

124:16 133:18

134:7

motors 13:13,16

14:8,21 15:12

16:5,9,17

17:3,13 18:7

19:4,10

20:14,18,21 23:2

24:1,6,20

25:1,11 26:13

28:18 29:21

30:9,15

31:9,15,19

32:16,22 36:10

37:2,14,15 38:4

41:8 44:13,16

45:20 46:14

52:16 54:6,21

55:3,16 56:9

163:11 224:11

226:3

motor's 35:21

move 7:5 108:1

192:10,14 220:4

235:1

moved 243:20

moving 46:22

102:21

multiple 166:19

205:21 220:3

Myers 3:7 6:13

27:21 30:8,17

31:6 38:20

39:15,19,22

40:3,14 57:19

61:14 62:6 63:19

64:6 65:1

66:1,15 80:3,16

81:13 82:11

83:13,19 87:15

88:8 97:13

101:21,22

102:15

143:10,18

145:3,11

148:16,19

149:1,5,8,11,15

154:16 155:6

156:8 157:17,18

158:16 159:18

160:18,21

161:11,14,16,18,

21 164:5 173:9

206:16 241:17

242:1 247:16

248:1

250:10,13,15,21

253:17 254:3,7

255:1 256:5

myself 100:13

173:11 225:3
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228:2

N

narrow 58:16

National 2:11 5:8

73:5 185:15

187:16

natural 91:8

nature 35:9

Navigant 2:3

3:8,17 6:7,8 14:2

Navy 42:6

necessarily 64:10

72:4 77:11

112:13 141:5

158:16 188:16

necessary 106:8

140:8

NEEA 125:20

128:17 133:2

157:6 166:8

182:15 183:16

214:13 238:3

negative 50:18

109:4

negotiate 48:12

181:12

negotiated 165:10

166:6 173:13

197:7 199:12

228:20,21 229:1

251:17,19

negotiating 166:21

197:17

negotiation 149:2

207:14 241:7

negotiations

126:10

Neil 2:3 5:6 108:16

114:7 163:7

183:20 212:3

221:4

neither 258:7

NEMA 16:18 17:8

36:21 37:5 47:17

52:14 56:2,5

nervous 186:19

net 127:22 128:1

134:6

netted 133:22

networking

224:22

next-generation

151:5

nice 8:20 122:16

211:18 242:7

niche 61:18

night-and-day

222:17

nobody 50:18

57:14,20 185:19

212:1 217:17

219:3

nod 222:19

nods 187:22

Nolan 67:19,20

68:2

nominally

99:16,17

nominate 250:10

none 219:11

non-issue 81:11

non-members

218:18

non-standard

120:16

NOPR 229:17

230:13,18 233:2

236:14,19,22

244:6

NOPRs 237:14

nor 258:8

normalized 134:4

normalizes 133:9

normally 21:17

Northwest 3:14

5:10

no's 83:4

note 58:19,21

notes 4:5,15 259:5

nothing 10:14

44:6,17 69:6

76:13,17 149:15

159:1 166:12

174:21 184:11

193:19

197:16,17,20

232:12

notice 14:1,3 55:2

180:22

181:8,14,18

183:4 186:7

190:22 205:2

242:13

noticing 166:20

notwithstanding

80:9 195:17

November 205:3

nowhere 119:5

nuance 16:7

O

object 9:6 51:3

57:4,12 58:15

61:2,11,13 63:11

70:6 85:17,18

88:21

108:5,6,7,8

122:12 125:18

221:3

objected 141:3

objecting 60:9,16

objection 58:18,22

60:21 74:22

141:2 154:4

162:17,21

objectionable

61:15,17

objections 8:9

10:4 59:4 60:21

61:4 74:21 75:1

78:5 79:21 80:2

106:2 108:12

114:5,14 116:2

120:14,21

126:21 130:15

131:18 136:1

137:13 139:14

141:8 143:6

162:11 163:3

objective 188:17

objects 57:14

108:10

obligated 241:18

obligation 64:20

observations

176:10

obsolete 142:11,12

198:18

obviously 53:22

71:2 73:1 77:5

165:3 171:21

249:4

occurs 24:5
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odd 178:17,18

OEM 63:17 66:9

offer 9:17

21:16,18 25:22

42:5 100:17

191:11,14,15

210:8

offered 42:15

117:21

offering 11:11

21:15 23:19,21

33:18 43:6 111:9

112:4

offerings 8:6 41:2

42:13,19

offers 160:2

officially 227:10

offline 210:7

offset 22:12

27:9,10,12

offshore 70:10

oh 5:2 95:19

103:11 134:14

146:6 148:10

213:17 216:5

oil-fired 86:10

older 130:5

OMB 232:22

one-day 4:14

one-month 189:10

one-of-a 111:6

one-of-a-kind

44:18 45:11

111:2,6

one-off 102:19

111:11,17

one-offs 101:14,20

111:16

ones 11:4 12:5

13:4 15:8 18:13

19:12 24:7 37:16

47:16 50:22

69:17,20 81:20

85:15,16 86:11

99:3 100:10

109:17,18 115:6

118:6 120:2

138:14 150:7

162:20 174:4

235:4

one-third 243:17

ongoing 96:13

online 68:20 74:14

178:11 219:1

225:1 232:20

onto 207:16

oops 245:6

open 52:15 55:9

109:14 121:19

126:16 164:3

openness 224:3

open-type 55:2

operate 39:11

153:9

operates 201:18

operating 71:15

operators 195:16

opinion 75:14

220:21

opportunities

177:16 225:1

opportunity

100:14 117:21

181:1 236:14

opposed 56:4

83:22

opposite 246:15

opt 83:7

optimize 168:13

optimizing 92:8

opting 83:2

option 19:19 30:18

99:10 213:9

219:15

227:10,13,14

optional 10:18,22

11:5,6 26:13

78:12 79:8 115:9

131:22

optionally 75:13

options 11:19

20:22 35:14

36:15 64:11

85:14 177:15

228:18 229:10

order 9:11,12,22

10:20,21 11:13

12:15 23:22 38:9

76:16 112:11

114:16 129:7

157:11 159:14

167:2 172:18

204:13 253:2,3

ordering 112:9

organization

59:21 178:2

219:11,18 220:2

original 85:21

originally 197:8

origins 99:6

others 57:10

175:21 214:6

242:1 256:5

otherwise 40:6

47:18 94:17

160:2 181:15

236:19 244:4

ought 186:2

ours 170:16

ourselves 62:4

254:20

256:10,16

outcome 48:18

outdoor 124:6

outliers 237:9

242:9

output 18:17

76:18,20 104:12

outset 31:3

outside 33:1 40:10

129:18 223:6

overall 168:10

239:10

overarching 14:5

overhauls 196:5

overlap 130:9

overload 76:16

overloads 76:15

overlooks 212:1

overnight 216:22

overseas 69:10

oversized 13:13

overthinking

85:20

P

p.m 257:3

Pacific 2:19

package 77:15

78:7 251:17
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packages 249:13

page 34:8 115:8

124:2,3

137:17,19,21

138:1,11,12

239:6,7

paid 45:10

paper 222:12

paradigm 204:12

parallel 110:13

196:15 252:12

parameter 92:11

parameters

155:21 156:20

paraphrasing

235:20

pardon 178:22

218:6

parens 15:9

parse 224:4

PARTICIPANTS

2:5 3:1

participate 221:17

225:7 241:22

participated 222:1

participating

184:22 185:5

221:17 222:6

particular 19:10

50:22 51:18 60:8

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104:2 146:10

150:8 156:20,22

157:3 159:6

169:10 170:1

206:9 233:6

test 10:21

11:4,9,20

12:4,6,7,8,12,15

13:5 22:18 23:7

24:3,11,21 25:12

33:1 39:1,3

40:21 75:8,15,18

76:13,17,22

77:2,3,6

78:18,22 79:2,5

82:16

87:15,19,20

88:2,6 92:22

93:2 95:5,6

96:3,12 98:11

107:2,8 118:11

121:13 124:7

132:10 134:5

136:12,14 161:5

171:19 172:2
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189:8 196:18

200:14

201:14,17

202:17,21

203:15 204:6

205:8 207:7

222:14 226:2

testable 114:16

tested 12:19 13:15

14:17 28:6

118:22 226:5

testing 8:3

9:9,18,20

12:14,18 21:12

25:10 38:6 43:12

78:13 79:2,4,8

94:13 95:8

112:10 124:18

172:2 178:12

188:6 191:3,18

196:17,21,22

197:1 199:16

201:6 202:18,20

205:11 207:4,8

208:10 209:11

223:7 245:3,9,19

246:2,13,21

253:1,3,5

tests 99:12 107:16

134:2 201:3,10

204:1,2

208:11,13,16

210:1

text 141:12 143:4

thank 8:7 13:10

36:9 54:11 60:22

70:2 91:15 103:1

112:20 113:5

115:14 116:15

123:14 132:5

133:20 134:13

137:9 147:21

163:2

thanks 16:14

139:11 182:18

187:21

Tharp 3:16 6:1

55:8

56:1,8,13,19

115:11,14

123:15,17

130:20 131:12

132:20 134:11

135:17 153:7

163:13,18,21

168:4 171:3

179:5 190:21

191:16 201:8

203:6 211:21

225:22

226:9,12,16,19

240:16

that's 9:15 10:3

11:5 12:16 15:8

16:7 18:17 19:14

23:4,16 25:1,19

26:15,18 27:4,17

29:18 30:6,7,17

31:3 34:1,19

37:21 39:17,20

40:1,22 41:1,5

45:6 48:10

49:14,15

53:14,22 56:3

58:17,18 60:16

62:6 66:11,17,18

67:21,22 68:18

69:11,13,14,18

72:11,12,17 74:4

77:4

81:4,6,10,18,19,

22 83:11 88:2

96:15 101:11

104:16 105:10

109:22 110:11

114:11,12

116:10

121:14,15 122:2

125:21 126:9,11

127:12 128:7

129:11 132:4

135:12,13

136:11,13

139:6,10 140:7

141:15

142:10,13,18

145:19 146:9

149:14 151:12

152:20,21

153:11

155:17,18

156:7,13 158:5

160:11 162:3,9

164:8

165:2,4,5,12,19

172:4,16 178:17

179:2,21 184:1

185:8 190:4,8

194:20 198:8

200:17 208:3

210:18 213:18

217:6,10 219:2

220:21

221:12,18,19

223:10,13,16,17,

18 224:7

226:16,17,20

227:13 228:15

230:8,16 232:14

235:22 236:21

239:8,13

240:19,20

241:1,9 243:10

245:15 246:6,13

248:18 249:14

254:10 256:5

Theirs 239:2

theme 10:20

themselves 222:6

theoretical 104:21

theoretically 17:17

theory 158:12

238:21 239:1

thereafter 258:5

thereby 189:11

therefore 65:3,4

68:11 92:10

therein 246:17

there's 38:3

129:13 152:22

163:7 184:10

186:22 200:8

255:22

thermal 76:5,20

96:21 105:9

209:20

they're 4:16 6:18

12:3 36:16 37:9

47:16 55:13 64:9

67:22 95:5 96:10

123:20 125:22

126:3 138:13

144:22 150:8

159:21 173:16

175:22 225:7

240:14 250:2,4

they've 238:21

243:3 246:2

third 60:19 61:20

78:14,17 170:5,6

240:8

Thirty-day

233:21,22

thoughts 173:10

thousand 120:10

three-phase

126:17

three-phased 21:6
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threshold 90:8

throughout 45:20

throw 171:4 179:5

210:3 232:22

256:11

thrown 189:15

tie 174:5

tied 89:8,13

ties 82:11

Tim 5:17 36:20

58:13,14 59:8,15

61:7 65:20 71:6

74:14,22 98:19

147:6 156:1

216:5,16 244:17

246:9

timeframe 165:8

187:11 197:15

200:21 228:13

229:6 239:10

timeframes 225:16

timeline 166:18

167:11 211:6

223:3 231:17

232:22 233:8

timelines 231:11

Timothy 2:9

Tim's 171:4

235:16

today 4:5 7:1 21:3

39:5 41:5,6

43:5,22 55:19

103:6 108:4

118:11 119:4,21

120:2 121:21

136:13 152:8

156:14 184:17

186:22 190:5

224:10,12,15

226:4 227:7

235:8,10 250:8

256:3,10

today's 255:6

to-face 254:19

token 168:11

tolerance 88:5

93:3 97:11

98:6,22 99:8,19

107:9,16 203:1,2

205:13

tolerances 99:3

205:14 253:6

Tom 2:22 6:9

133:11,21

tomorrow 4:6

122:1 186:22

212:5 227:10

254:10,13,20

255:5,9,17,20

256:12

ton 23:11

107:6,7,11

200:21

201:13,14

tonight 240:13

tons 67:6

tools 206:10

top 75:10 76:2

142:8 160:22

214:8 243:3

topic 49:2

topics 255:13

totally 212:4,9

221:16

toward 116:12

towards 56:21

179:20 199:2

trace 60:5

track 66:22

tracked 165:5

tracking 174:11

trade 210:15 238:9

244:8

training 151:15

248:5

Trane 2:18 28:11

35:5 59:13 76:12

118:7

transcript 258:6

259:4,6

transcription

259:1,7

Transcriptionist

259:13

transfer 3:15

201:21

transition 20:10

192:5

translates 129:4

Traulsen 2:13

5:20 112:22

117:14 167:14

169:4 177:20

209:4

travel 214:8,10

tremendous

204:19

tremendously

225:16

trigger 68:12

triggers 87:2

trillions 119:15

trouble 20:4

151:14 187:14

troubled 222:1

true 2:17 5:12

20:12 24:14

115:15 132:6

171:9 181:6

258:6 259:7

truly 43:5

trusting 72:16

truth 15:4

try 30:1 55:19 58:8

149:21 163:1

175:18 180:6

191:8 212:14

243:18

251:21,22

trying 13:7 14:11

25:20 31:18 33:5

47:6 59:21 69:15

74:19 106:12

107:13 116:14

145:12 149:5

159:5,7,9,16

161:22 176:6

177:19 186:1

200:16 221:6

224:20 231:7

242:19

tube 145:15,16

151:6 202:1

tubes 144:3,5,9

145:16,20 146:1

tube-type 144:4

145:14 146:7

Tuesday 212:8

214:11

turn 6:15 77:17

93:22 108:14

turns 53:4 57:8

tweaks 201:16

twice 109:12
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two-month 189:10

type 18:1

55:5,6,10 102:22

134:7 135:3

151:1 160:14,20

180:9 188:14

191:16 201:20

202:9 235:16,18

241:3

typed 259:4

types 32:22 48:1

55:16 119:1

152:12 180:10

203:10 223:22

234:15

typewriting 258:5

typically 27:4

136:18 144:3

184:12 185:8

U

U.S 2:8,10,12 3:4

65:4 70:8

U-bend 95:12

Uh-huh 12:22

149:4

UL 5:19 211:2

217:9 219:8

ULE 123:7

ultimate 20:11

219:16

ultimately 96:12

unacceptable 28:7

unanimous 109:3

121:4 122:13

126:22 130:16

136:2 163:4

unanimously

115:5

uncertainty

205:16,17 206:1

unclear 9:15

uncomfortable

72:17

uncommon 95:15

underlying 10:20

understand 25:8

28:15 37:10,11

40:10,17 43:5,18

44:9 45:22 46:2

74:21 83:19

91:18 93:13

104:19 106:17

112:7 145:1,10

146:17

157:17,18

158:17 159:8

167:6,10,13

176:6 177:21

184:7 197:13

198:1 204:9

206:13 232:21

251:21

understanding

34:17 37:8 41:6

67:2 75:17

106:19 173:12

180:17 184:3

185:21 208:4

209:6 225:20

234:13 238:14

understood 26:20

234:10

undertaking

119:10

Underwriters 3:3

unfired 89:6 106:5

148:7 154:14,21

156:5 160:12

unfortunately

94:1 199:3

uniform 109:11

142:10 143:12

unique 33:1 43:16

112:2 173:1

unit 7:18 10:21,22

11:10

12:11,14,17

13:18 15:2,5,8

17:21 18:5

21:6,10 22:4,16

23:6,11,21

24:7,13 25:13

30:14 31:4 32:15

33:19,22

34:10,11 44:15

45:19 51:18 52:4

64:4 77:14,15,18

89:8 94:13 104:7

107:10 110:4,12

113:1,5,9 124:12

unitary 123:9

124:5 125:14

126:16 144:20

units 10:14 11:6,7

13:15 15:3 21:20

24:10 25:14 32:9

39:10 99:14

101:5 106:4,14

124:6 136:20

137:3 156:15

226:6

unknown 224:1

unless 24:13 26:4

42:16 92:4

140:11

unlikely 71:19

unpopular 252:9

unrealistic 218:19

unreasonable

207:20

unscrupulous

248:7 249:3

update 164:19

updated 36:22

upfront 118:10

upload 183:7

227:21

uploading 182:21

uploads 183:12

upon 129:5 166:10

186:13 189:17

191:22 218:17

useful 41:18 184:6

user 155:9

Utilities 104:13

utility 33:2 151:8

V

valid 88:13 191:4

194:3

validate 14:18

151:21

validated 39:2

validating 207:9

validation 152:3,4

validity 87:16

valuable 58:22

value 22:21 23:2,7

101:8 132:21

134:6 147:10

152:20

156:3,5,10

157:1,4,19

values 94:15

variable 101:9

135:6
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variables 205:21

variation 207:6,7

variations 40:19

47:21

varies 169:14

variety 65:19

97:22 98:2 164:6

217:4

various 7:13 11:19

65:19 181:4

202:1 203:10,13

250:3

vary 170:20

vast 24:5 210:12

VCTRC 110:9

verification 7:5

93:8 122:18

140:19 142:5

163:5 178:12

202:18 208:10

209:11 245:3,18

246:1 252:18,22

253:2 254:13,22

verified 65:13

verify 92:21,22

93:3,20 106:21

196:17 245:8

verifying 14:17

verse 147:19

versus 12:17 36:14

45:16,17 101:15

107:3

VFD 135:12

VFDs 11:7

view 68:12 93:7

157:19,20 175:7

199:17 222:3

viewpoint 191:20

views 115:20

217:4 219:1

220:9,13

221:7,20 222:5

249:8

violate 71:2 72:15

violates 70:15

violations 248:15

visibility 180:2

visual 100:8

visualizing 20:4

void 107:19

voltage 24:16

volume 19:16,17

22:7 80:6,12,21

81:2,6,8,14

82:3,4,13,17

83:1,5,17 84:4

85:4 86:4,6,13

87:1,17 88:6

89:4,7,10,12

92:3,5 93:1,8

94:12,16 96:8

98:4 99:13 100:3

101:16

103:8,14,22

104:7

105:10,12,17

106:4 141:11,13

142:1 143:17

144:12,18

145:19 146:10

147:3,9

148:3,6,14

149:11 153:19

154:13,15,19,21

155:19 157:7

160:11,13,14,15,

16 161:3,6 162:5

volumes 84:9 89:5

91:19 94:16,17

98:2 106:13

147:16

volunteers 95:4

vote 7:2,3,22 43:4

50:8,9 51:1

58:11 79:21

105:18 108:1

109:19 114:5

116:2 120:14

121:12

122:11,13

126:21 130:15

134:14,19,20

141:17,19 142:2

143:8,9 154:12

155:1 163:4,19

211:5 226:11

229:9 230:9,11

voted 166:6

167:20 199:12

230:16

votes 143:7

voting 109:12

229:11

VRF 123:1,6

137:16,18,19,21

138:12 139:3,4

163:14

VRFs 139:8

W

wait 10:6 57:7

173:18 179:11

189:9 216:15

227:20 241:13

waiting 179:4

waive 248:16

waiver 79:9,15

175:9,11 176:1

waivers 175:17

244:10 249:16

walk 13:20 50:15

54:2 123:3

229:13,20

wall 121:1

warehouses

190:19

warm 75:3 171:6

warranty 62:20

washer 152:22

Washington 1:9

wasn't 67:8 71:21

95:7 135:16

148:5

wasted 198:20

water 80:1,11 86:1

89:6,10

90:13,21,22

92:22 94:20

95:22 96:5

102:1,2

103:4,5,12

104:22 105:1,22

106:5,6

128:19,20

130:21

131:8,13,14

132:9,18,19

133:4,5 134:1,21

136:7,11,15

137:16,18,19,22

138:3,7,8,21

139:3,8,15,20,21

140:16 141:13

143:14

144:1,2,12,13

145:3,4,7,9,13,1

5,19 146:7 147:8

150:1,12,22

151:6

154:14,20,21
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156:6 157:14

158:13 159:13

160:7,12

161:1,3,6 162:5

173:2,5 193:12

200:12,20

203:11 212:10

232:7 234:16

water-cooled

127:15

131:4,10,15

132:10 136:4,6

139:17,18

watts 35:21

ways 45:22 219:9

249:12

weak 191:13

Weber 3:17 6:8

webinar 123:12

website 66:12,14

84:10,22 85:2

93:19 106:14

125:11 217:21

we'd 88:3 92:17

104:11 255:8

Wednesday 1:11

Wednesday/

Thursday 212:7

week 4:6 30:21

50:6,12,13,20

51:9 55:22 57:5

58:13 81:12

84:17 87:14 96:2

109:18 115:7

163:11 180:11

210:6,22

211:4,19

212:4,6,7,18

213:5 214:6,10

227:8,15 230:5,7

236:4 238:6,10

241:12,13

weeks 81:1 225:18

229:6

week's 50:8

240:18

welcome 241:21

we'll 12:4 42:5

54:16 77:5

122:17 140:13

164:3 241:12

254:13

well-advised

255:20

we're 4:11 30:5

31:18 33:5,10

34:8 49:2 50:16

78:4 92:7,12

104:13 114:8

120:1

135:11,19,20

137:4 148:13

151:15 152:18

160:17 162:7

165:12

166:3,21,22

168:18 175:12

178:13 186:9,12

191:18 194:20

199:20 203:17

208:19 214:11

220:7,8 221:6

223:17 229:5

232:14,15 241:9

244:21 246:20

252:5 253:4

256:2

we've 70:5 91:3

96:18 109:11

119:6 122:12

141:10 167:3

172:3,11 181:22

184:16 185:17

187:21 196:17

211:15 221:20

223:15

228:19,20,21

229:1 236:13

252:17

whatever 11:14

12:8 19:7,20

28:4 30:11

31:1,2 34:1 35:2

68:3 83:5

121:9,10 124:17

146:8 158:3

175:8 181:5

187:11 188:11

189:19 190:10

195:17 211:6

213:1 219:15

229:6 232:22

234:8,9 244:11

254:21

whatnot 92:6

104:3

whenever 30:12

Whereupon 58:1

122:21 160:6

257:3

whether 9:19,20

11:12,13 47:15

50:16,17 51:1,3

61:3 62:10,19

64:21 71:9 81:9

85:6 87:1 90:14

95:17 101:3

107:10,18

113:19 127:9

128:19 129:1

131:8 135:12,13

144:13,18 151:6

153:18 160:13

166:18 171:15

201:19

243:11,14

244:10,16

249:21

Whitwell 3:18 6:2

11:17 12:20

13:1,10 15:21

16:12,14

26:4,8,12,17

34:16 35:3,11

36:9 37:10

38:1,12,16,19

41:4 47:7,11,13

49:1,9,12,17

59:17 61:13,18

62:13 63:3 64:11

116:4,15 117:7

119:14,19 120:5

125:16 136:6

184:8,14 187:1

190:6,12 221:4

233:17

256:8,15,20

257:2

whoever 9:1

whole 24:18 33:13

34:19 36:8

45:2,5 46:19

49:15 85:1 92:8

115:21 138:20

168:17 214:8

241:1 255:12

wholeheartedly

40:12

whom 258:3

whose 52:2

wide 21:20 164:6

212:13

widely 225:14

wider 102:11

willful 248:22

willing 49:17

144:22
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163:12 236:8

wind 151:4

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withdraw

162:17,21

withheld 60:16

65:22

withhold 106:12

witness 253:5

wonder 72:18

177:16 253:18

wonderful 210:9

wondering 68:18

78:12 98:20

147:8 188:22

214:15

wording 81:21

82:12 139:1

work 8:15 10:13

13:6,20 20:2,4

29:10 53:20

63:12 69:3 81:21

82:19 109:6

138:6 141:15

142:9 166:11

174:8 183:8,18

185:12 193:1

195:4 214:9

223:17 224:18

231:21 232:4

234:6 237:1

244:16 247:7

252:12

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workable 41:11,14

43:4,16 54:1

57:13,16 170:8

199:15

worked 199:19

working 83:10

116:12 117:10

167:8 172:15

186:8 218:11

227:14 232:21

240:21

works 11:5 22:16

31:18 219:9

220:22

world 88:17 102:6

173:14 185:3

233:3

worry 246:3

worrying 99:3

161:22

worse 18:11,14

87:6

worst 177:7

worth 45:8

wounds 121:19

Wow 76:1

wrap 7:1,3

write 105:7,13

159:15 189:9

229:17

writing 163:22

211:13

written 147:17

151:20 211:3,18

wrong 47:1 60:2,3

95:17 205:21

X

XYZ 64:7,8 65:2,8

XYZ's 65:10

Y

Yep 38:16,19

47:12 54:10

79:19 120:20

133:10 135:2

138:5 147:20

247:22

yes/no 84:5

85:11,17

89:5,11,14 99:21

106:3 141:11

yes/no's 80:20

82:2

yet 38:3 56:10

84:21 91:4 132:7

144:21 164:22

171:7 201:7

205:7

you'll 14:1,3 17:17

55:17 131:16

yours 134:18

yourself 83:8

170:8

yourselves 155:4

240:7

you've 6:14 66:15

79:14 125:3

128:22 133:13

139:9 143:9

163:18

228:19,20,21

229:1 230:19

238:22 239:19

249:20

Z

zero 133:7,8