Date: April 30, 2015

Case: Appliance Standards and Rulemaking Federal Advisory Committee 

Meeting

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Appliance Standards and Rulemaking Federal Advisory Committee Meeting

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 U.S. DEPARTMENT OF ENERGY PUBLIC MEETING

APPLIANCE STANDARDS AND RULEMAKING FEDERAL ADVISORY

 COMMITTEE MEETING

 U.S. Department of Energy

 Forrestal Building, Room 4A-104

 1000 Independence Avenue, SW

 Washington, DC 20585

 10:09 a.m.

 Thursday, April 30, 2015
Appliance Standards and Rulemaking Federal Advisory Committee Meeting

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1 Appearances for Department of Energy Meeting

2

3 John Cymbalsky, DOE

4 Ashley Armstrong, DOE

5 Michael J. McCabe

6 Dave Winningham, Allied Air Enterprises

7 John F. Caskey, National Electrical Manufacturers

8 Association (NEMA)

9 Jim Crawford, HVAC Regulatory Consultant

10 Andrew deLaski, Appliance Standards Awareness Project

11 (ASAP)

12 Tom Eckman, Northwest Power and Conservation Council

13 Charles Hon, True Manufacturing

14 David G. Hungerford, State of California, California

15 Energy Commission

16 Diana M. Jakobs, Rheem Manufacturing Company

17 John M. Mandyck, United Technologies

18 Andrew Allen, Navigant

19 Catherine Rivest, Navigant

20 Adam Darlington, Navigant

21 Christopher Lau, Navigant

22 Caroline Davidson-Hood, Air-Conditioning, Heating, &
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1 Refrigeration Institute

2 Nicholas Mislak, Air-Conditioning, Heating &

3 Refrigeration Institute

4 Amy Shepherd, Air-Conditioning, Heating &

5 Refrigeration Institute

6 Aykut Yilmaz, Air-Conditioning, Heating &

7 Refrigeration Institute

8 Frank Stanonik, Air-Conditioning, Heating &

9 Refrigeration Institute

10 Don Farrell, Oilheat Manufacturers Association

11 Victor Franco, Lawrence Berkeley National Laboratory

12 Alex Lekov, Lawrence Berkeley National Laboratory

13 Roger Marran, Energy Kinetics

14 Joanna Mauer, Appliance Standards Awareness Project

15 Sarah A. Medepalli, ICF International

16 Gary Hainley, U.S. Boiler Company

17 Christine Hazelbaker, ACCA

18 Richard D. Murphy, American Gas Association

19 John A. Roda, Burnham Holdings

20 Steven J. Rosenstock, Edison Electric Institute

21 Paul Sohler, Crown Boiler Co.

22 Gregory J. Stunder, PGW
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1 Cory Weiss, Fieldcontrols

2 Anurag Maheshwary, Department of Justice

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

2 (10:09 a.m.)

3 MR. deLASKI: On the record. Let's start. 

4 Why don't we start with introductions, and remember

5 that this is being broadcast as a webinar so we've

6 got participants who are members of the committee I

7 think on the webinar and also public who are

8 participating in the meeting as well via the webinar.

9 (Introductions were made.)

10 MR. deLASKI: I am Andrew deLaski, I'm one

11 of the co-chairs of ASRAC with the Appliance

12 Standards Awareness Project.

13 MR. MANDYCK: Good morning, I'm John

14 Mandyck with United Technologies and also I'm the

15 cochair of the ASRAC.

16 MS. MILLER: Hello, I'm Deborah Miller. 

17 I'm with Green Strategy Associates and I'm

18 representing NASEO.

19 MR. CASKEY: I'm John Caskey and I'm with

20 NEMA, National Electrical Manufacturers Association. 

21 MR. HON: Charlie Hon, True Manufacturing,

22 member.
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1 MR. WINNINGHAM: Dave Winningham, Allied

2 Air, Lenox International.

3 MR. McCABE: Michael McCabe representing

4 myself.

5 MR. CRAWFORD: Jim Crawford here on behalf

6 of Densel.

7 MR. HUNGERFORD: David Hungerford, a

8 member of the committee, representing the California

9 Energy Commission.

10 MR. ECKMAN: Tom Eckman, member of ASRAC

11 with Northwest Power and Conservation Council.

12 MS. JAKOBS: Diane Jakobs, Rheem

13 Manufacturing.

14 MS. ARMSTRONG: Ashley Armstrong, DOE.

15 MR. deLASKI: And do we have any committee

16 members on the phone?

17 MS. CLEARY: Jen Cleary with AHAM. 

18 MR. deLASKI: Hi, Jen. I hope your child

19 gets well soon. That's why you can't be here in

20 person, but glad you're able to join us by webinar. 

21 And thanks very much for your input via e-mail. 

22 MS. CLEARY: Thank you.
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1 MR. deLASKI: It's been printed out and

2 members of the Committee here have your e-mail in

3 front of them so -- which is in response to the list

4 that I had shared on Monday. 

5 So as an agenda for this meeting -- okay. 

6 Thanks. 

7 Jen's a little hard to hear. I'm not sure

8 if you can control that volume on there or not, but

9 it would be great if it's a little louder.

10 So I'll just kick us off here. John

11 wasn't at our last meeting so I'll do a little bit of

12 a restatement of sort of what we hoped to do, what I

13 thought I heard us say we wanted to do in this

14 meeting here today.

15 Let's start by -- and we're going to speak

16 informally. Actually John and I will do our best to

17 sort of advance things along here. As an agenda I

18 wanted to just suggest that we begin by approving the

19 minutes from the last meeting which was shared by

20 Jeremiah yesterday. I thought it would be useful,

21 before we get into the topics, to spend a little bit

22 of time on process and mechanisms, you know. John
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1 asked me this question earlier this week well, what

2 is this leading to, right? What are we -- we're

3 going to take on some topics, where does it

4 ultimately -- what are the mechanisms that we would

5 use to advance our recommendation? Then I thought we

6 would spend some time on the individual topics that I

7 had flagged in the e-mail. Again, this is just an

8 informal list I said I take on at the last meeting to

9 put out a list to the group. It's by no means a

10 comprehensive list. We should open it up to the

11 floor, to additional topics that could be added to

12 that list. Maybe we should do that first. But then

13 we perhaps spend a little bit of time on each of

14 those lists -- on each of those items.

15 Then I would -- what I am thinking would

16 make sense, and, again, this is open for discussion,

17 this goes back to the first agenda item, but that we

18 would form subgroups or subcommittees of the

19 committee who would volunteer to take on advancing

20 work on particular topics. Again, taking to mind

21 Deborah's, I think, warning in our last meeting that

22 we need to prioritize, we can't do everything, and
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1 set deadlines for ourselves and create a product that

2 would help advance the department's work in this

3 area.

4 And then I want to make sure we get time

5 to schedule next meetings. I think at the last

6 meeting there was a request that we maybe schedule

7 the week meetings for the rest of the year so people

8 can get them on their calendar so we aren't

9 scrambling to wedge it in amongst other things later

10 on. We should think a little bit about what time it

11 would make sense for next meetings and how many more

12 meetings we they want to have during calendar year

13 2015.

14 Does that agenda make sense to people?

15 Any additions or modifications to the

16 agenda?

17 (No response.) 

18 MR. deLASKI: Do you want to add, John?

19 MR. MANDYCK: No. I think that's a good

20 process. And maybe one other -- if there's time,

21 maybe just to quickly just to understand the state of

22 where we are with the working groups.
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1 MR. deLASKI: Okay. Actually that's

2 probably a quick one. So why don't we start with

3 that? 

4 Ashley, do you want to take that?

5 MS. ARMSTRONG: Sure. So let's see, DOE

6 recent -- well, ASRAC approved and DOE ultimately

7 formed three new negotiating committees, one for

8 commercial air conditioners and furnaces, one for

9 miscellaneous refrigeration products, and one for

10 commercial industrial fans. The first meeting for

11 commercial units, or air conditioners and furnaces

12 was this week. My understanding is that that meeting

13 went well and they've made some good progress.

14 I think that, you know -- I wasn't in the

15 meeting, but what I heard is that we have some

16 analysis work to do to help support the committee

17 before the next meeting. And I know that we've been

18 working through that. 

19 The miscellaneous refrigeration products

20 first meeting is next week. It's Monday and Tuesday

21 of next week, a two-day meeting, so that will kick

22 off that effort. And I think they had a four-month
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1 term, if I believe correctly. I'm looking at Charlie

2 because he's the ASRAC member on the committee. So

3 just to make sure I have my -- and then the

4 commercial fans and blowers meeting is also next

5 week. It's Wednesday and Thursday, a two-day

6 meeting. And they had a 

7 three-month term. And so that will kick off that

8 effort next week.

9 So that's kind of where we stand. They've

10 all been formed and they're all up and running. I

11 know commercial air conditioners has their schedule

12 for their remaining terms and I expect that at the

13 first meetings for the next two they will do the

14 same.

15 MR. deLASKI: Yeah, I'm the ASRAC rep on

16 the commercial AC working groups and we had, I think,

17 a very productive meeting the first day. Diane was

18 there on behalf of Rheem, and for Karen Meyers, who

19 couldn't be there, is on the committee. So I think

20 it was a very productive meeting and we were able to

21 get our ground rules worked out, I think, in record

22 time, we were done. Before morning break I think we
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1 had our ground rules worked out in a couple hours and

2 then we were moving on to the substance of the

3 analysis and our input as a committee to show the

4 revisions that we'd like to see to the analysis --

5 and good report back from the consultants on changes

6 there they're making a response to earlier

7 conversations and the written comments. So it seems

8 to be, I think, on a good glide path. We scheduled,

9 I think three two-day meetings over the next six

10 weeks.

11 It was very -- good -- minutes were sent

12 around yesterday. Are there any concerns with the

13 minutes?

14 (No response.) 

15 MR. deLASKI: They look fine to me. 

16 That's a good representation of our last meeting. I

17 think we can approve those minutes. Any objection?

18 [CHORUS OF AGREEMENT] 

19 THE REPORTER: Do you know what, when

20 people speak, they need to speak loudly. I only got

21 one person saying no. I didn't get any other nos or

22 yeses or anything. 
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1 MR. deLASKI: There were no nos, I don't

2 think. There were no objections.

3 THE COURT REPORTER: All right. Okay. So

4 I got one yes then, Diane.

5 MR. deLASKI: We asked were there any

6 objections and there were no objections.

7 THE COURT REPORTER: Okay. Thank you.

8 MR. deLASKI: For the record.

9 THE COURT REPORTER: Good, thank you.

10 MR. deLASKI: The next item I had on the

11 agenda was to -- at our last meeting we had

12 discussion around what are the cross-cutting topics

13 that the ASRAC could take on to help fulfill our role

14 in providing an advisory role to the department for

15 the appliance efficiency standards program? We

16 discussed a number of topics, and there was, I would

17 say, enthusiasm from the committee to take on a more

18 assertive role with regard to providing advice to the

19 agency. 

20 What I thought we should begin with is some

21 discussion about what form that advice would take or

22 how that advice would be advanced to the agency. So
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1 let's open that up for some discussion. I think that

2 the general topic, the general, I think, issue is,

3 you know, we create working group or subgroups to

4 tackle a topic, where ultimately does that lead to,

5 what ultimately is the audience and the mechanism to

6 convey that advice?

7 MS. JAKOBS: This is Diane Jakobs from

8 Rheems. In my past job I had to deal with new

9 regulations and I've been on committees for test

10 procedures and I think one of the -- the biggest

11 issue for me is that we don't generally spend a lot

12 of time looking outside of the test procedures. So

13 when it changes, we don't necessarily know what

14 happened. That's not to say if we are doing some

15 kind of new technology thing we'll spend more time

16 and try to understand what's going on, but if it's an

17 incremental change, we're pretty much sticking to

18 what -- we know what the test is. We're studying to

19 the test and we're collecting data to the test. 

20 So, when we have these two, like the

21 furnaces today, when we have a test procedure, NOPR

22 and an energy efficiency NOPR that are coming out at
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1 the same time, there is a lot of confusion. And I

2 spent the last week updating our program for

3 calculating the AFUE in response for this. And

4 talking to the lab and telling them why I need them

5 to collect data, even though the efficiency standard

6 is in the future and they're doing analyses and

7 they're designing and they have a test schedule, and

8 I want them to do another test so that we have the

9 data. So it adds a lot of confusion into the

10 process, it makes it very difficult where normally --

11 especially furnaces.

12 I mean, 80 percent of the time we spend is

13 on safety, not on efficiency. They have to be safe. 

14 And the decisions we make with respect to efficiency

15 may or may not affect the tests that we have to run

16 to be certain that the appliance is safe. So it just

17 -- it makes it very difficult. 

18 When we were talking earlier in the week

19 with the commercial HVAC, people we were talking

20 about these brilliant engineers who will come up with

21 new technologies, and blah, blah, blah, but if you're

22 so busy trying to just do the mandatory stuff -- you
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1 know, I don't know how much you can count on for

2 innovation if we're just constantly trying to make

3 these tiny steps. 

4 So I think it's very important people --

5 while in preparation for next week, I was reading the

6 transcript for the fans and blowers and people were

7 talking about loopholes. And there are loopholes in

8 the test procedures and people will find them. 

9 And then -- you know, so I don't think

10 it's something that really works well in parallel

11 with the energy efficiency. There shouldn't be a

12 NOPR for the test procedure that comes out within

13 days with the energy efficiency's NOPR, and that we

14 need to understand the test procedure. We need to

15 get the processes in place. We need to -- for the

16 AFUE test procedure we take like 30 pieces of data

17 and there's 100 pages of calculations. So we need to

18 have a program in place before we start doing real

19 work. So I think it's really important that these

20 things get in the correct timing, one to the other,

21 to be effective.

22 MR. deLASKI: This is Andrew. Thank you,
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1 Diane. I think this is a critical point. I think

2 it's our first item on the list that I created in

3 terms of this.

4 MS. JAKOBS: Right. That's what I was

5 going by.

6 MR. deLASKI: So what I want to spend a

7 few minutes on before we get into the topic -- 

8 MS. JAKOBS: Oh, sorry.

9 MR. deLASKI: -- is -- and maybe this is

10 more a question for Ashley. Which is how to

11 ultimately -- so we create these subgroups, we're

12 going to do work to better define these concerns or

13 these cross-cutting issues and then we're going to

14 ideally come up with some recommendations as to how

15 they could be better handled in a way that addresses

16 the kind of concern you're addressing. So how do --

17 what form should that take for it to be useful to the

18 department? You 

19 Know -- so I'll just throw out some ideas. 

20 For example, ASRAC, in my mind, could make

21 a recommendation that the department publish a

22 request for information, right, that might outline
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1 some of these concerns, cross-cutting issues, and ask

2 for public input to better define them, and then to

3 ask for public input on how things might be

4 sequenced, for example, or how sequencing could be

5 better -- how sequencing could be addressed in

6 testing the standards to address a problem. So a

7 request for information that would broaden that would

8 be one action that we could ask for. We could ask

9 the department to publish a guidance, right, that

10 would do X, Y and Z. These are sort of two actions

11 that occurred to me that we could be advising or

12 asking of the department. 

13 So I'll put it to you, Ashley. What kind

14 of things would be useful to you in terms of things

15 that we would provide to you or ask of you?

16 MS. ARMSTRONG: Let's see. So I think you

17 -- this is Ashley from DOE. I think you pretty much

18 hit the nail on the head. You could ask us to get

19 more information from the public about a specific

20 area or a process-type issues. If you had a new

21 process in mind specifically, you could ask that --

22 you could send us what that process might look like,
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1 and if we wanted to get a broader set of feedback on

2 it, we could put out draft guidance and ask for

3 feedback and then reconcile it and you could ask the

4 department its opinion about using that new process. 

5 Some of the issues here that we're going

6 to talk about this afternoon I think are larger than

7 simply guidance or process issues. And we can get

8 into the details of those, but I think some of those

9 may be potentially regulatory changes that you're

10 looking for, statutory changes, specifically. And

11 I'm not sure that's something that DOE specifically

12 -- I mean, there are avenues for DOE to do that, but

13 they're difficult, but they may give you ideas about

14 what you might want to do, together, and work

15 together. to do that.

16 So as we get through them, I think it

17 depends on the specific issue we're talking about. 

18 Certainly process-related issues I think should be

19 brought to the department. You know -- but stuff

20 that's actually pretty clear on our statute I think

21 is something for you guys to think about further and

22 brainstorm about, you know, what the solution might
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1 be or what the future might be there. 

2 MR. deLASKI: Right. So -- this is Andrew

3 again. So that's where you could provide us -- as a

4 person with the committee and a member of the 

5 committee -- 

6 MS. ARMSTRONG: We'll get there.

7 MR. deLASKI: -- you help us to identify

8 where -- what are the mechanisms you would need to

9 address, and then if there are regulatory or

10 statutory changes that are required to address a

11 particular 

12 cross-cutting concern, then perhaps this committee

13 produces a report or a white paper or something that

14 identifies them. That would seem to me to be another

15 sort of potential output. 

16 Now, the thing that I don't know about is

17 whether that's something that's actually within our

18 -- we can, you know, because you're a member of this

19 committee, and I'm not sure we can produce a white

20 paper or a report, right, so that's a question.

21 MS. ARMSTRONG: Right. So I think there's

22 going to be a list coming out of today of issues to
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1 tee up with legal --

2 MR. deLASKI: Okay. 

3 MS. ARMSTRONG: -- I'm pretty sure, to get

4 some answers both that will help inform the

5 committee's work going forward, but also help inform

6 what form it might ultimately end up in. And I'm

7 happy to take that back in and get some answers if we

8 need.

9 MR. deLASKI: I could see it being quite

10 constructive that at the end of this year or early

11 next year we have a report, some sort of output that

12 reflects the work that we intend to do here.

13 MS. ARMSTRONG: Sure.

14 MR. deLASKI: And that that output would

15 take, you know, the form of a report of some sort. 

16 That would be a way to memorialize what was discussed

17 and what was decided and for the agency to know what

18 they've been asked of -- what they've been asked to

19 do and to recognize that there may be other

20 additional process -- right, because we're -- there

21 has -- as Ashley points out would require a public

22 process to address, we can't just decide that.
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1 MR. CASKEY: This is John Caskey. I guess

2 I have two, I would say, pretty simple things. You

3 know, one is certainly as I understand it that John

4 Cymbalsky is like the project manager or whatever,

5 coordinator for the ASRAC; is that correct? He has

6 like a -- 

7 MS. ARMSTRONG: His official title is DFO.

8 MR. CASKEY: Okay. 

9 MS. ARMSTRONG: Yeah, designated federal

10 officer. 

11 MR. CASKEY: To me it seems like whatever

12 we would come up with as ideas or recommendations,

13 they would go to John and then we'd ask for John's

14 help in trying to figure out how to implement some of

15 those things. And with that being said, I think that

16 there are some things that are going to fall within,

17 you know, the rules and procedures within DOE and

18 there may be some other things that sort of fall

19 outside that or we still want to keep on a parking

20 lot that we still want to identify if those things

21 come up even though they may not be directly within

22 our charter as ASRAC or as DOE.
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1 But in addition to that, I think it would

2 be good that as we work through some of these ideas

3 and some of these topics, that maybe we would end up

4 with like a little project plan at the end to say

5 these are the next five steps. This is how we need

6 to move forward with this issue in order for this

7 issue to be successful. 

8 So I think the two main things would be a

9 report to John to say, you know, this is sort of what

10 we found. These are our recommendations, how can you

11 help us move this forward, you know, legally within

12 DOE. And then in addition to that like a little 

13 mini-project-plan on these would be the next five

14 steps to move that forward so it doesn't get lost.

15 MR. HUNGERFORD: This is David Hungerford

16 --is our purpose to simply identify issues and then

17 tee them up for a DOE process? Or is it actually to

18 engage in some level of analysis internally and then

19 feed that back into a DOE or a process? 

20 If we have an issue, something simple that

21 we have a question about, how could this -- or how

22 could test procedure setting work better? And then
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1 we approach it from a well, why does it work the way

2 it currently works? What are the statutory

3 organizational limits, what are the internal

4 administrative organizational limits? What are the

5 resource limits of doing those sorts of things? And

6 actually work -- is it our responsibility to work

7 through some of those issues given that in theory we

8 all have some level of expertise on doing these sorts

9 of things, and which is why we're here. And then

10 come up with some sort of recommendations that we

11 could put into a memo that we feed back into DOE

12 which then can go into a public process and be dealt

13 with in that way. Which direction do you see us

14 going, or are we limited in what we can and can't do?

15 MS. ARMSTRONG: My personal opinion?

16 MR. HUNGERFORD: I'm looking at Ashley and

17 at Andrew for their understandings of how we're

18 supposed to be doing this.

19 MS. ARMSTRONG: My personal opinion is

20 that you are an advisory committee and not only are

21 you to help with identification of problems, but

22 you're part of helping solve them, that you're meant
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1 to help provide input to the department to find

2 solutions. So if you -- I think it's worthwhile to

3 spend time thinking about -- put yourself in the

4 department's shoes for a second, and how would you

5 solve some of the problems that we're going to be

6 talking today. And if there's multiple potential

7 solutions, maybe those are the sets that ultimately

8 get passed to John and then we seek further public

9 comment. But I think the department would welcome

10 the solutions from this group, because that's really

11 what this group was formed to do, to advise, to help,

12 you know, guide the appliance standards program in

13 continuing its successful efforts.

14 I don't know if you have a different

15 opinion.

16 MR. deLASKI: No, that sounds right on to

17 me. 

18 MS. JAKOBS: This is Diane Jakobs again. 

19 That was kind of -- that was what I thought it would

20 be. And I'm probably na ve, I haven't done this

21 stuff, but I have participated in a lot of

22 rulemaking, and from my point of view -- I mean, it's
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1 difficult for us to send comments and then you hear

2 back six months later, you know, or nine months

3 later. But from Ashley's point of view, I wouldn't

4 want to be the one where you put something out and

5 this horde of angry people show up in person, you

6 know.

7 (Laughter.) 

8 MS. JAKOBS: So -- 

9 MR. HUNGERFORD: That's my job.

10 MS. JAKOBS: Yeah, I mean, in a way it's

11 kind of exciting, but I don't think it's that

12 constructive. You know -- and there was one about

13 certification and enforcement and, holy cow, we're in

14 this huge auditorium and there were people with like

15 hordes of attorneys and -- 

16 MR. HUNGERFORD: And pitchforks.

17 MS. JAKOBS: -- and pitchforks, and, you

18 know, many of them didn't read all the materials --

19 you know, they were standing up and saying things

20 that were inconsistent with what had been proposed,

21 so -- 

22 MS. ARMSTRONG: I vaguely remember being
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1 the one at the podium for that.

2 Yeah. Yeah. So anyway, yeah, so I think

3 it would be important to help with solutions, right,

4 I think both from your perspective. as you bring to

5 this committee your concerns on behalf of the

6 interest that you're representing, but also as being

7 advisers to the department and your appointment to

8 this committee, I think you're helping the department

9 implement or consider implementing different

10 processes or better processes to make this more

11 successful for both. 

12 So you're wearing two different hats. One

13 is, yes, you're bringing your interests, but you're

14 also doing it with that in mind of, you know, the

15 department, what the department has to do in terms of

16 this regulatory obligation. How can it meet those,

17 but align the interests a little better? Obviously

18 we welcome that.

19 MR. HUNGERFORD: This is Dave Hungerford. 

20 That's actually what I signed up for, I think. I

21 believe -- I mean, I'm sitting at a table where I'm

22 representing the state with the appliance efficiency
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1 program and regulatory program and I'm sitting next

2 to people from -- representing the major

3 manufacturers and major manufacturer organizations as

4 well as other state agencies and other advocacy

5 groups. And all of us sitting at the table trying to

6 work out something from our best experience and also

7 considering the perspectives of our different

8 organizations seems to 

9 be -- that seems to be where the value here is. 

10 MS. ARMSTRONG: Absolutely.

11 MR. HUNGERFORD: And then that's what we

12 should endeavor to try to actually do rather than be

13 purely reactive to things that are presented

14 necessarily as just DOE; right? And I think that's

15 where Andrew is trying to move us. It's just how do

16 we get there? And how to identify which issues to

17 deal with and in what order is the challenge. 

18 MR. deLASKI: Okay. That's a good

19 discussion. Any other thoughts on this process?

20 MR. HON: Charlie Hon. I think we have

21 another responsibility that isn't spelled out in the

22 charters or anything else, and that is carrying
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1 information out of this group back into industry

2 standards. Because that is a huge disjunct because

3 the standards committee can started modifying

4 standards which will be in direct opposition to how

5 DOE can function with the standard and that's a

6 problem. We have to understand as a group here how

7 DOE handles this test standard. And modification of

8 that test standard may have major implications to

9 DOE's functioning and they may end up going back and

10 saying, well, we're not going to accept the new test

11 standard because of that. And then all that time is

12 wasted, all that backlash and anger from it. We need

13 to be communicating not only into the group, but back

14 out of the group. 

15 MR. deLASKI: And I would add to that,

16 Charlie, that, you know, there need to be mechanisms

17 for communicating, you know, beyond simply the other

18 people in this room, right, so we're not -- although

19 most of the associations represented here are

20 manufacturers or connected to them there's not,

21 probably, universal coverage. So the mechanism for

22 communicating those kinds of concerns, I think are up
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1 for discussion. 

2 MR. HON: This is Charlie Hon again. 

3 There are a lot of companies who are really not

4 active in trade associations.

5 MR. deLASKI: Right.

6 MR. HON: A lot of independent and

7 especially private companies that are not, and as

8 such quite often things get lost in different areas. 

9 And so our communications out are maybe every bit as

10 important as our process within.

11 MR. deLASKI: Any final thoughts on this? 

12 Again, the topic of process and output.

13 Why don't we turn then to the list that I

14 started and why don't we start by asking for any

15 additional items or topics that might be -- people

16 would want to see added to that list.

17 MS. JAKOBS: This is Diane Jakobs. I

18 don't know if it would fall under number three, but

19 the interaction between ASHRAE and DOE standards, I

20 think that's something worth talking about. It says,

21 "other regulatory work" certainly EPA, but ASRAC as

22 another -- or ASHRAE as another organization that has
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1 interactions with that organization too.

2 MR. deLASKI: Okay. Why don't we add that

3 to item three?

4 MS. CLEARY: This is Jen Cleary. It's a

5 little hard to hear. Were you asking for additional

6 items to the list or for adding to what's already on

7 the list?

8 MR. deLASKI: We were starting with any

9 additions to the list and then after we had a full

10 list, I thought we would take time to talk about each

11 of the -- talk through each of the items some.

12 MS. CLEARY: Okay. Great. I do have one

13 potential item for the list, and it may not be one we

14 discuss today. But, Andrew, I think this is

15 something that you and I spoke about in the fall,

16 which is how the department should address test

17 procedures that impact -- test procedure changes that

18 impact measured energy. 

19 And particularly, I think it's pretty --

20 the department does a great job of dealing with those

21 changes in the context of the standard change. But

22 there have been some recent issues in the past couple
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1 of years with how to deal with those types of changes

2 outside of the standard development process. And I

3 think the clearest example might be clothes dryers

4 where a different test procedure wasn't even able to

5 be adopted because the department didn't feel that it

6 could adjust the standards to account for the changes

7 that measured energy. 

8 And so I think that's something that's

9 really important for ASRAC to consider. You know,

10 the department has voiced concerns over why it feels

11 that it's difficult for it to use the process that's

12 set forth in the standard, and one of those things is

13 the anti-back-lighting provisions. So I think it

14 would be useful for the members of the committee to

15 think about that issue to understand further from the

16 Department what it views its roadblocks would be and

17 then for us to make some recommendations how those

18 roadblocks might be overcome.

19 MR. deLASKI: Okay. Why don't we add it

20 to the list. I don't think we need to discuss it

21 right yet, but let's add it to the list for

22 discussion.
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1 Other additions to the list?

2 MS. MILLER: This is Deborah Miller. I

3 just wanted to add to Diane's, and that's simply the

4 Department -- or not only looking at ASHRAE, but

5 there are other bodies like the IEE, IECC and others,

6 so it goes beyond just ASHRAE that sometimes have an

7 impact on the standards. So, I would just keep it a

8 little more generic so that we look at others as

9 well.

10 MR. deLASKI: Okay. Any other additions

11 to the list?

12 MS. ARMSTRONG: I have one.

13 MR. deLASKI: Ashley?

14 MS. ARMSTRONG: I think from the 

15 department's -- I'm going to take a different

16 perspective here. The department's perspective, I

17 think I'd like to brainstorm about how do we get some

18 of the key elements of data that is most helpful in

19 our analyses and how do we work with industry better

20 in more of a partnership way to do that? I think

21 that at one point in time, especially when things are

22 going maybe at a slower pace it was a little easier
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1 to handle from both parties' perspective. And now we

2 find ourselves sometimes, I would say, not

3 necessarily with bad data, but we also know that

4 maybe more complete data out there exists. So I'd

5 like to hear ideas about what's a better way of maybe

6 information-sharing that obviously does bring about

7 it a level of trust, but I think it also brings us to

8 an ultimately better answer for everyone.

9 MR. ECKMAN: This is Tom Eckman. By that

10 are you speaking broadly across all the general

11 elements of the rulemaking process from the

12 engineering and technology assessment to market data

13 and all of those elements?

14 MS. ARMSTRONG: Right. I think that's 

15 open-ended, including testing. I mean, you know,

16 when test procedure changes and the idea that -- you

17 know, one of the issues that Jen brought up,

18 fundamentally driving that is what our test results

19 under new and different provisions -- so we can get

20 input. But I just think it's a higher level of

21 discussion. How do we encourage information-sharing

22 and get access to that information? 
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1 But also, I guess -- what's the best way

2 to say this? Also acknowledge the concerns that

3 exist with sharing some of that information across

4 boundaries. So I'm wondering maybe is there a better

5 way and what would that be?

6 MR. deLASKI: So in some ways it's a

7 corollary to item one. Item one is about approving

8 data, but this is a more specific issue that the 

9 data --

10 MS. ARMSTRONG: Well, I see them as

11 separate, but I think the data is broader in a sense

12 from my perspective.

13 MR. deLASKI: Right. 

14 MS. ARMSTRONG: But it does impact test

15 procedures and standards and other avenues. It's 

16 just -- it's really a trust factor, and I'm not sure

17 that I completely understand all the concerns. And I

18 don't think you guys -- you guys may not completely

19 understand what our avenues would be to handle

20 different types of data, and maybe we can come up

21 with a better way.

22 MR. deLASKI: I see. So maybe I'll try to
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1 summarize it in my mind. It's manufacturers and

2 associations have data that characterizes the market,

3 that characterizes their market. And to the extent

4 that that data can flow to the agency is going to

5 inform more accurate analysis. And if there are

6 barriers to that flow we need to understand them and

7 figure out how to bring them down because that will

8 ultimately get better analysis based on more accurate

9 characterization of markets and cost and what have

10 you, a whole number of issues that are separate from

11 test methods.

12 MS. JAKOBS: This is Diana Jakobs. I

13 think it's farther than that. When I've been here at

14 the public meetings, you know, it's the

15 manufacturers, we're here, but the people who use and

16 apply the equipment, we don't really know -- there

17 was a lot of discussion this week about economizers

18 and if they're used and if they're maintained and are

19 they installed and we just know what we ship. We

20 don't know what they do with it afterwards. And I

21 know in California you've done some testing and there

22 was a partial hunt and looking at how equipment ages,
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1 and that's not necessarily information that the

2 manufacturers have. I would say we're interested,

3 but, you know, it's not work that we've taken on

4 ourselves.

5 MR. deLASKI: So some of this is -- this

6 is Andrew again -- the issue is an economizer. There

7 are incidents in there. It gets pretty far into the

8 weeds; right? Some specific individual docket or

9 topic. But there's a broader issue which I was

10 trying to characterize in that number five -- which

11 is improved energy use data, you know, which is a

12 different kind of data that manufacturers aren't

13 going to have necessarily as an entity. But that --

14 you know, Tom's organization and others have done

15 significant studies historically to characterize good

16 energy consumption. There's new work in the

17 northwest, California IU is taking on a new -- a

18 major new good energy use study. 

19 So I think, you know, coordination around

20 those kinds of field energy consumption surveys that

21 help us to better characterize across sectors and

22 across the -- not just, you know a given product, but
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1 industrial, commercial, if that's possible industrial

2 sectors would be another source of data. 

3 That often has been a challenge. I know

4 that we in the ASRAC community often will put in a

5 comment to the department and say, well, we have this

6 study from Vermont that shows X, Y, and Z. Well,

7 that's fine and dandy, that's Vermont. But tell me

8 about whether I can use this as a national

9 representative study or note, right.

10 So I think that's a question that, you

11 know, can we come up with some recommendations? And

12 this is ultimately who acts in the power of

13 recommendations. There probably is a whole set of

14 entities that play a role in helping to improve

15 knowledge of good energy consumption. But that

16 strikes me as being item -- an accomplice to number

17 five.

18 MR. HUNGERFORD: This is David Hungerford.

19 I'd like to add one thing to that. Sometimes there's

20 a tendency to say that the solution to a data problem

21 is to collect more data and to somehow find a way to

22 get more data. And sometimes that is the solution,
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1 especially when you have a real lack of data in

2 certain areas. But sometimes the better solution is

3 to look for -- to try and choose an outcome, try to

4 find a way to get an outcome that is robust, even in

5 the absence of good data on some of the things you're

6 trying to measure. And I'll try to illustrate in a

7 second.

8 There is an implicit assumption generally

9 that a test procedure will somehow capture how a

10 device operates in a general way. And then there's

11 this implicit assumption that then that applies over

12 all kinds of -- if it's most efficient during test

13 procedure, then it's also going to be most efficient

14 in a wide variety of applications because there's a

15 lot of variety of applications, and across time. 

16 It's going to uniformly degrade. A more efficient

17 device now is going to degrade more efficiently than

18 the less efficient device. 

19 But we all know that those things are not

20 necessarily true, that sometimes a test procedure can

21 be designed in such a way that the devices perform

22 well under the test procedure, but you find the
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1 majority of applications, they don't perform nearly

2 as well, and a device with a different -- that's set

3 up differently, might perform better more generally,

4 or might degrade in a -- would lose less efficiency

5 over time. 

6 And so the ultimate question is, how do

7 you provide -- how do you develop a process and a set

8 of outcomes that are robust with regard to meet the

9 data from a number of -- from a number of various --

10 because you're never going to have really excellent

11 data from everywhere.

12 You're never going to have -- you're not

13 going to have necessarily great sales figures data

14 because that tends to be proprietary. It's difficult

15 to get use data because that requires very expensive

16 kinds of testing and observation or field work that

17 requires going out and talking to people and

18 observing how things are operating in people's homes

19 or in people's buildings. And those are all very

20 difficult to collect data. So the question gets back

21 to how do you develop a solution that is robust with

22 regard to lack of data rather than always depending
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1 on more data?

2 MR. deLASKI: I want to make sure -- right

3 now we're still trying to get the list complete

4 before we move into the list. So were there other --

5 MR. HUNGERFORD: Are we in the list? I'm

6 sorry. 

7 MR. deLASKI: John, you were starting to

8 raise your hand.

9 MR. MANDYCK: No, I just think Ashley has

10 hit on an important point. There are barriers to

11 sharing data and there are trust issues, and so I

12 think it would be good to have conversation about it.

13 MR. deLASKI: Anything else for the list?

14 (No response.) 

15 MR. deLASKI: So I also want to be

16 conscious that we as a committee are, you know, 13 or

17 14 people and so the idea here is that ultimately

18 what would come out of it today was the formation of

19 some subcommittees that will take on some tasks. We

20 probably can't do everything on this list, so we need

21 to, you know, at the end of the day be prepared to

22 pick. So with that background, maybe keep that in
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1 the back of your mind.

2 There may be -- maybe some of these topics

3 are there's some overlap and they could be combined. 

4 I think Jennifer in her e-mail had suggested that

5 items number -- 

6 MR. ECKMAN: One and five.

7 MR. deLASKI: One and five might have some

8 significant overlap and could perhaps be collapsed.

9 Do people have a preference for what order

10 we discuss these topics in?

11 MS. MILLER: No.

12 MR. MANDYCK: Can we just go through the

13 list?

14 MR. deLASKI: Right. Why don't we start

15 with item number one. 

16 MS. CLEARY: And maybe we can include item

17 number five in our discussion of item one because

18 there is some overlap if we think we might

19 potentially combine them. It seems more useful to

20 discuss them, if not at the same time, one right

21 after the other. 

22 MR. deLASKI: Sounds good. 
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1 Jen, do you want to start us off with this

2 since you reacted to this one?

3 MS. CLEARY: Okay. Sure. I think that

4 this is a really important thing for the committee to

5 address, so at least for me this one is a priority. 

6 You know, I think it was Diane who was speaking

7 earlier. I'm sorry if I get your the name wrong, not

8 being in the room, but agree with the points that she

9 was raising. You know, we've certainly seen recently

10 a lot of instances where proposed test procedures

11 being issued at the same time or within relatively a

12 short time frame of a standards proposal. 

13 Even if it's not a proposed rule, it's

14 something significant we'll need to respond to. And

15 the challenge there is that if you're just reacting

16 to a draft expert feature or test procedure

17 amendment, you know, there's a lot of work involved

18 in just that and then you provide data on -- you

19 know, the type of data that's needed for a standards

20 analysis with a test procedure that's in flux is

21 virtually impossible, particularly from a

22 manufacturer point of view. 
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1 And I think that's problematic not just

2 for the manufacturers, but also for the efficiency

3 advocates and for DOE because the result is that no

4 one really understands what the baseline -- what are

5 the -- you know, efficiency levels that should be

6 reviewed because the test is critical in evaluating,

7 you know, where the market is and where it can go. 

8 You know, sometimes a test procedure might impact the

9 design options that are used for example, what will

10 be measured by the test and what won't. 

11 So we're certainly basing this, as I

12 mentioned, in several rulemakings, and I think it has

13 certainly hamstrung us in many cases from being able

14 to provide data. And that's not a position that any

15 alliance members wants to be in, and I imagine it's

16 not a position that DOE wants to be in where it's

17 requesting data from us and we're basically saying,

18 that we can't give it to you because we have this

19 draft test procedure. In many cases we might

20 disagree with portions of it. 

21 And, you know, aside from the practical

22 issues of trying to, you know, teach the lab how to
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1 do the proposed test, everybody having a different

2 view of what the proposed test is, and we're trying

3 to work our those issues and also have the issue of

4 practically a lab may not want to do testing on a

5 particular test procedure because it's not viewed as

6 a good use of resources. For example, test all or

7 significantly all the basic models under the test

8 method could and likely will change, if not

9 significantly, at least in ways that would change the

10 results. 

11 So, you know, I think that's why it's

12 really critical that we figure out how DOE can view

13 this in a sequence that makes sense, you know,

14 following, I think, what's in the project improvement

15 rule, for example, but also how we can help the

16 department do this quickly. Because the feedback

17 from the department side, they're trying to meet

18 their statutory deadlines and they're trying to move

19 the process along quickly and finalizing the test

20 procedure before even issuing a proposal. I can

21 understand that more challenging side and would like

22 to hear from Ashley or others at DOE about those
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1 challenges and how we might be able to address those. 

2 You know, one potential way that we've

3 been thinking about at AHAM is kind of a fast-track

4 process. And this wouldn't address major test

5 procedure issues, but it could address kind of more

6 administrative-type changes that are not

7 controversial that are maybe necessary for testing to

8 even be able to continue, for example. 

9 And I cited an issue here of maybe

10 dishware where the dishwasher test procedure is no

11 longer available and it needs to be replaced. And

12 stakeholders suggest a replacement, and maybe there

13 could just be some quicker ways to move through that

14 process. But I think that is somewhat separate from

15 the larger issue of the sequencing proposal.

16 So I'll stop there before moving on to the

17 data piece, and maybe we'll talk about that next. 

18 But that's my view on the first part of it.

19 MR. deLASKI: This is Andrew. Let me be

20 the devil's advocate for a second because I -- you

21 know, I certainly agree that -- you know, if we were

22 -- the world that I think we would like to live in is
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1 a world in which before DOE even begins to test a

2 rulemaking, the test method is locked down and done

3 and not to be touched; right? So that would be kind

4 of an ideal thing, that the framework stage is all

5 set, it's all locked down, that way you've got tons

6 of data based on an existing test method and

7 everything is just -- you know, this is all locked

8 down. There's no reason to, as Jen just said, just

9 to try it. 

10 But what I've observed is that often it's

11 the standards -- beginning of the standards

12 proceeding that actually focuses the mind and that we

13 start to find that there are these issues, these

14 problems with the test method that come to the fore

15 because of the standard proceeding getting started. 

16 So it's sort of a chicken-and-egg kind of problem,

17 you know, and that there's not -- the effort to --

18 you know, there are so many test methods that I can

19 tell you, and I think we all have experienced, where

20 the guys who know it come up and say, oh, this one's

21 got all kinds of problems, because this one's got

22 this problem, this problem, and you know, there's no
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1 one really working to fix it until the standard

2 proceeding rolls around. It's not part of focus to

3 fix it. 

4 So to me there's a tension there because

5 we want a representative test method that gives us

6 accurate rankings of products and efficiency

7 performance. And then when you uncover the problems,

8 you want to fix them. And then I also think that we

9 often end up at the end of a rulemaking not having

10 fixed them. And then the momentum to fix them then

11 goes away. And then we're back several years later

12 and the same problems still exist, they haven't been

13 fixed. So, you know, there's a -- that's the

14 tension I see in this. And I certainly want to live

15 in that ideal world, but I'm curious what people see

16 as how can we get the update, get the improvements,

17 but get them in a sequencing capacity to make

18 everyone provide data and understand what's actually

19 happening.

20 MR. MANDYCK: This is John Mandyck. I

21 mean, that's certainly true, but there's also another

22 universal truth. There is no perfect test standard. 
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1 There is no perfect energy efficiency standard. So I

2 think we'll always find issues that we'll want to

3 nitpick. I think the issues that Jen is brining up

4 and the ones that I experienced are -- even goes to

5 the extreme. I think it was the off mode where we

6 had a standard before we had a test procedure. So it

7 has crept to the point of a little bit of

8 disfunctionality and the ability to manage the -- how

9 you comply. 

10 So I agree with you, I don't think it's

11 anybody's ideal state. I don't think it's

12 intentional, but we have gotten to the point where we

13 either get standards without test procedures or

14 standards on the heels of the test procedures that

15 are imperfect. And so there have to be reasons why

16 that is, and maybe those are the areas that we can

17 all try to focus attention. Because, again, I don't

18 think it's anybody's agenda or will to have it turn

19 out this way.

20 MR. deLASKI: Right. To have that be an

21 initial task -- 

22 (Simultaneous conversation.) 
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1 MR. deLASKI: -- subgroup is to identify -

2 - and I like the way you characterized it, which is

3 there have been some -- in these incidents that a

4 couple people have tossed out here, what are the

5 causal factors that have led to outcomes that I think

6 we all would agree are not the desired approach. And

7 you can't knock down the factors until you know what

8 they are.

9 MR. ECKMAN: This is Tom Eckman. I'm

10 picking up on that and a little bit of what Ashley

11 mentioned earlier about the broader data needs for

12 improving. IT seems to me we offer this, as you

13 said, focus the mind on the standard starts and we

14 find that the test procedure doesn't cover things

15 that we want to do that might be a technology that we

16 would apply differently, or in a sense of the

17 technology options. 

18 And so part of this is just figuring out

19 how to get in front of the test procedure with some

20 sort of scoping about what we expect to be engaged

21 upon with the type of technology improvement. 

22 Because some of the test procedures don't
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1 particularly -- as we've getting more and more going

2 forward with controls, the current test procedure are

3 woefully inadequate to address the controls that

4 might be invented and sent out and reprogrammed via

5 wireless at some point in the future so the equipment

6 operates entirely differently than it did when it

7 left the factory floor. 

8 Somehow or another we've got to get ahead

9 of that. So the next round of rulemaking is when

10 most equipment is going to have somebody out there

11 with a printed circuit board and logic that is really

12 different than what we've got today. And I'm

13 concerned that the test procedure's just not enough

14 capacity dealing with that going forward. There's a

15 lot of talk about system improvements, but really are

16 related to controlling the device better to do just

17 what needs to do, and not much else. And I think we

18 really haven't focused our minds around how the test

19 procedures -- we need a scoping exercise more

20 broadly, but to get ahead of the standard-setting

21 process so we have a test procedure that can actually

22 deal with these issues. 
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1 And there are lots of data requirements

2 that need to be derived compared to the current ones,

3 but I think that one is a completely different

4 frontier than we -- we're seeing that now in dryers. 

5 There are lots of ways to make a dryer more

6 efficient, one of which is to control it better. And

7 it's not really being able to capture that very

8 often. So I think that's the kind of thing that I'm

9 -- as we get through this big traunch of standards

10 right now, we've got to -- the next round six years

11 from now and all we just did in the lat five years

12 are going to show up again. I know exactly which

13 phase -- we're doing things right back to back, and

14 it's done after the test procedure, but only two

15 weeks. MR. deLASKI: And one of the things that

16 we asked DOE to do in our last meeting was to produce

17 a kind of schedule that would help us to understand

18 the timing, and Ashley and John have kindly done

19 that. They've just presented or shared with us here

20 -- 

21 (Simultaneous conversation.) 

22 MR. deLASKI: Kelly?
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1 MS. KLINE: Hi, sorry to jump in late

2 here.

3 MR. deLASKI: Welcome.

4 MS. KLINE: I was just going to add to

5 that. I think maybe one way to get at that in terms

6 of the forecasted schedule, it strikes me with some

7 of the test procedures you were noting about just the

8 need to focus the mind on things, right, that might

9 be a way to get at like if we were able to

10 collectively look at that schedule and say, you know,

11 pick any product, any existing test procedure,

12 outstanding issues need to be resolved by date X so

13 there's kind of a common understanding of when that

14 needs to happen so that that can then feed in at the

15 beginning of the next process the data and analysis. 

16 Because I really do think it drives a lot

17 of kind of downstream issues, because from the

18 manufacturers' perspective I know that when it is not

19 clear what test procedure we should be kind of

20 testing to and utilizing, it really does drive a lot

21 of -- kind of confusion and lack of data as we're

22 trying to respond to some of the rulemaking type of
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1 needs. So anything we can do to kind of drive

2 resolution of the test procedure issues through kind

3 of a focused understanding of that, you know, if not

4 resolved by date X, then you won't have it for the

5 specific rulemaking. I think that might be helpful

6 to the process. 

7 MR. deLASKI: I think that makes sense. 

8 And I think that that's something. To work on, what

9 would be the sequencing that we would like to see

10 sort of in an ideal world.

11 And I like Jen's notion that you have to

12 have a mechanism to do fixes that everybody agrees

13 on, perhaps after that date, you know, so that you're

14 not 

15 -- you know, if you complete it now in enough time,

16 you're going to test it for another seven or eight or

17 10 years. But then everyone knows that you've got to

18 fix something, and the consensus is you want to have

19 a mechanism to do that as well. There's the

20 intention in there because then you're back to some

21 of the same problems potentially, but knowing that

22 there's still ambiguity, but hopefully we can address
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1 those kind of issues too.

2 Diane?

3 MS. JAKOBS: So one of the issues -- I'm

4 on test procedure committees and dealt with the

5 regulations, but one of the issues is that when you

6 change a test procedure your rating is going to

7 change on existing equipment. And you may or may not

8 -- even if it isn't at the minimum efficiency, it's

9 probably close to some efficiency where there's a

10 rebate or there's an Energy Star rating or something. 

11 So you don't want to be the person -- we can't

12 backslide, so, you know, that means maybe the

13 efficiency is going down and where you met a hurdle,

14 where you met, you know, an Energy Star rating maybe

15 then in the future you would want to -- there's this

16 whole thing about the existing equipment. And so I

17 think generally we kind of just try to avoid changing

18 the test procedures too much because, number one, you

19 don't know where you'll end up with this whole

20 offering of equipment.

21 And then number two, you probably don't

22 know where all your competitors are, but there's this
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1 -- it's awkward -- you know, the test procedures come

2 into effect 180 days and then -- for everything. So

3 it would be good if it was possible to kind of stage

4 it in or for the water heaters we have this

5 conversion vector, you know, thing for a year. Or

6 some kind of mechanism to phase things in. Because

7 every time when we go to talk about a test procedure,

8 then there's a lot of talk about, oh, we have all

9 these models we have to retest. And that's a big

10 expense and in general it's not really productive for

11 us to just pin another number on the same piece of

12 equipment. 

13 MR. deLASKI: John?

14 MR. CASKEY: Thanks, Andrew. John Caskey. 

15 Just sort of curious. Sorry to throw this out there. 

16 First of all, I think this is a very important topic

17 for me from our perspective. But the question really

18 deals with sort of procedures for today that I think

19 we can -- I mean, I would happily discuss this for a

20 couple hours if you wanted to, but then we've got

21 five or six other things on the list. 

22 MR. deLASKI: Right.
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1 MR. CASKEY: Is the goal of today just to

2 discuss a little bit and scope it out?

3 MR. deLASKI: I think so.

4 MR. CASKEY: And then figure out, do we

5 want to create a task force or something to work on

6 it, and do we want to set like a time limit for each

7 of the topics of a half hour or 45 minutes and then

8 we move on from there? Like what are the next steps? 

9 Because otherwise you might not give due credit to

10 the last two or three items.

11 MR. deLASKI: Right. Why don't we try to

12 wrap this one up in the next five minutes or so and

13 then move on to the next one.

14 MR. CASKEY: Okay.

15 MR. deLASKI: Thank you for that. 

16 MR. CASKEY: It's hard for me not to do

17 that.

18 MR. deLASKI: No, I appreciate that.

19 Keep this moving.

20 MS. ARMSTRONG: Do you want the

21 department's perspective?

22 MR. deLASKI: Yes. Ashley. 
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1 MS. ARMSTRONG: That might be a little

2 different. Okay. So what I tried to do here, you

3 guys have a list and you have a list of -- what I put

4 on there was active rules as well as one coming down

5 the pike with the caveat that I do want to get an

6 opportunity to take one more look at the statute

7 before we actually publish this in the docket. But I

8 wanted to give you guys something today to at least

9 react to.

10 What you see is that DOE has a lot of

11 active test procedures, and one of the reasons for

12 that is that when the energy bill in 2007 was passed

13 it created a look-back provision that requires DOE to

14 consider -- review and consider revisions to its test

15 procedures at least once every seven years. So we

16 were required to review every single one of our test

17 procedures by 2014, and revise if it's needed. And I

18 don't think there's anyone at this table that could

19 argue that at least some revision to any one of them

20 wasn't needed. So that's the current state of

21 affairs. 

22 I think I wholeheartedly agree with the
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1 sentiment that in an ideal world DOE would be

2 finishing test procedures, especially test procedures

3 which I would call an overhaul or a major change that

4 would impact the measures of consumption before the

5 standards rule. But I think there's also the hand we

6 were dealt in reality. So, you know, I think there

7 needs to be some consideration of bridging that gap. 

8 Where do we go from here? 

9 You know, John likes to remind me every

10 time he sees me about my one, you know, Achilles heel

11 test procedure regarding off-mode, and I acknowledge

12 that is never an ideal scenario. That is never a

13 situation the department wants to be in. And

14 obviously -- yes, we just don't want to go there. 

15 So wholeheartedly agree with that

16 sentiment. That being said, I have some

17 considerations that I'd like whatever committee comes

18 up with to keep in mind. I think we have issues that

19 are brought up in the context of rulemaking that we

20 defer because they will significantly change the

21 measures of consumption. But yet then they don't get

22 considered again until the next rule. 
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1 One of those good examples is static

2 pressure. It's a topic coming up a lot these days. 

3 And so then it comes up again and it's like, DOE,

4 you've known about this, you have to deal with this. 

5 We have real-world data that says things have

6 changed. You haven't done anything yet. So I don't

7 know how we bridge the gap between, you know,

8 initiating those discussions earlier because some of

9 these test procedures that DOE is incorporating by

10 reference, especially certain sections of them, are

11 actually industry committee standards. And we want

12 to work with industry to use theirs, but we also need

13 industry to initiate that process earlier, and ASHRAE

14 and others. And we know sometimes how that can be a

15 little bit of a challenge.

16 I think another thing we find is that for

17 newly regulated products some people don't try the

18 testing until they have to comply. And then all of a

19 sudden it's we can't do something. What do we do? 

20 We can't run your test procedure. And that's not

21 when we set standards. That's when they have to

22 actually comply with them. What do we do in those
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1 cases? Obviously we have to fix that problem. How

2 do we fix it?

3 And then I think there's a third bucket

4 which has really come to light in the latest -- you

5 know, since DOE has really stood up an enforcement

6 program. And that's DOE started testing products,

7 and people aren't doing it the same way. People

8 aren't seeking guidance. In some cases they're

9 finding specific loopholes. And people will always

10 find loopholes. There will always be a loophole. We

11 try to minimize it, but no matter what, they exist. 

12 There needs to be an acknowledgement of that. 

13 But when we know there's a major loophole

14 and we need to close it, in that case the intent of

15 the test procedure was always there. It's just that

16 they took that liberty. So I will say, there are

17 certain pieces which I will call -- they may not --

18 they should not change the measures of consumption. 

19 They should just be clarification to our regs. But

20 if somebody was doing it incorrectly in the first

21 place, they are going to change the regs, and that's

22 the reality.
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1 So I think, you know, from DOE's

2 perspective we have a situation that for 60 covered

3 products DOE had to do test procedures for in seven

4 years. Some of those were overhauled, some of those

5 were new, some of those were different. The more

6 testing we do, the more questions, I would say, not

7 necessarily issues, but questions come about

8 regarding clarification. The more enforcement we do,

9 the more clarity is sought.

10 So I don't know how you reconcile this

11 with what's reality versus -- I agree wholeheartedly

12 that in an ideal world this is what we'd move to. 

13 But this is the current state of affairs.

14 MR. MANDYCK: So, Ashley, thank you very

15 much. This is John Mandyck. So where are you in the

16 next seven-year cycle?

17 MS. ARMSTRONG: Well, I think that's what

18 you're starting to see, the next seven-year cycle is

19 starting to kick in. For any rules that we

20 finalized, you know, that's what you're going to see

21 on some of these dates especially with some of the --

22 some of Jen's products, some of the home appliances
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1 are going to start to kick in and kick off. We have

2 started a process of trying to kick them off like

3 early, but we're still at the point of pretty much

4 kicking them off concurrently with the hope of

5 finishing them much faster. We can certainly open

6 them up earlier. But a

7 lot of these that I'm looking at right now -- like

8 for example, we're triggered on your equipment, HVAC,

9 commercial, in 2016. Sure, we could start that

10 process now of working with AHRI to open up 34350,

11 and happy to do that. But they're off a little bit

12 with the standards and triggering. So, you know,

13 we're completely open to ideas here. But the

14 triggers are definitely kicking in and they kick in

15 every seven years at the very least. 

16 MR. MANDYCK: This is John Mandyck again. 

17 I think this is good illustration on why we need to

18 do some introspection on this other side of the table

19 because, to me, this is a matter of physics. So we

20 collectively, through advocacy and through the

21 Congress have expanded the incline sufficiency

22 program to cover 60 categories and then we've layered
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1 on top of that requirements that either weren't

2 thought through or misunderstood or unrealistic such

3 that it's physics, they can't get it done, and the

4 consequences, we're feeling that, and we're

5 resonating around the table in the discussion we're

6 having. So, you know, when these energy bills come

7 up, you know, they only come it's like a shooting

8 star, right, they only come for a comet more

9 realistically. Everybody throws everything on it,

10 but when that happens, this is what you get. And we

11 get to a situation that is starting to become

12 untenable. So I think we just need to recognize that

13 and understand that, the rest of us, around the

14 table.

15 MS. ARMSTRONG: Yeah. And I think from

16 DOE's perspective, I'm not sure that it can't be

17 done. I don't know that I'm willing to throw in the

18 towel yet and say that it cannot be done. But I

19 think that you would get far more accomplished

20 working with you, and finding a way to work with you,

21 than doing it -- I mean, right now we're reacting to

22 industry methods. ASHRAE may pop out something some
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1 time in ten years. As Charlie mentioned at the

2 outset, sometimes we adopt it, sometimes we don't. 

3 Sometimes they do things that we can't adopt legally. 

4 And I don't know how to -- you know, I do go to

5 ASHRAE, I do try to, when big issues come up, chime

6 in. Team at AHRI started engaging in that process. 

7 I'm happy to do the same for other organizations, Jen

8 at AHAM or whatever. But I think that you have to be

9 open to major -- a request for major changes earlier

10 too.

11 MS. JAKOBS: I know on the furnace fan

12 rule, but I really appreciated it when AHRI, we

13 actually proposed the change to the test method and

14 we provided data to support that change and obviously

15 it was considered and even probably improvements were

16 made on it. If stakeholders can respond with data, I

17 completely believe that the Department responds, and

18 that putting myself in their shoes, that's what I

19 would want. And Ashley and the contractors too, they

20 always seem so thankful for any tidbit you can give

21 them. I provided data, I don't even know what the

22 last one was, but it was the -- I tried to provide it
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1 as confidential business information. And then

2 according to the instructions it wasn't enough just

3 to do that, I had to have a document with it and then

4 a second document with what I thought was

5 confidential business information excluded, and it's

6 just a lot of time and effort. 

7 MS. ARMSTRONG: It is. It's difficult.

8 MR. deLASKI: I want to try to wrap this

9 one up in light of John's admonition that we cover

10 all seven topics. And it strikes me that, you know,

11 this is one that we do want to form a subgroup. 

12 There's an element to this that we spent less time on

13 which is a data element. You know, but I think

14 they're quite related and that we're getting data to

15 inform test method revisions. As you know, getting

16 time takes money, and you need to know what's going

17 to happen if you're going to make efforts to gather

18 that kind of data to inform a change.

19 I think that the reason the Congress put

20 in the seven-year lookback is because many test

21 methods were just kind of stuff, and never getting

22 looked at, and it was sort of a process where you
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1 kept rolling it over living with the errors that

2 everyone knew were there. And to put some effort on

3 the agency to get, in many instances the test methods

4 are controlled by the industry or by professional

5 associations.

6 The reasons that Diane I think described

7 quite well, often you get inertia. There's inertia

8 because, well, you know, it's working for me today

9 and I got my ratings and I changed the ratings, and

10 it upsets things. It upsets the applecart, you know. 

11 So we need to have a way to disrupt the inertia to

12 get needed changes to happen. We can do it in a way

13 -- in a sequence in a way that works for industry and

14 works for transparency purposes. I think that's a

15 charge to the subgroup, is to think those issues

16 through and the various tensions we all just

17 described. 

18 MR. ECKMAN: I think joining issue one and

19 five because they're part -- getting those test

20 procedures reflects real-world applications, is

21 really important, because you have both the test

22 procedure to get the energy efficiency method but
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1 then you take that test procedure data and you apply

2 in the life cycle cost analysis, and if we don't have

3 both of those pieces together, the test procedure, it

4 can't -- number of cycles per year is a real big

5 driver both on the metric and the life cycle cost. 

6 They are a conjoined problem and I think that -- so

7 taking one and five together as a scope for the

8 committee is probably best. 

9 MR. deLASKI: Let's not take subcommittee

10 volunteers quite yet. Let's go through the topics

11 and that way people will have a chance to think

12 through. John?

13 MR. CASKEY: Just a clarification. I

14 wouldn't have naturally put one and five together,

15 but it sounds like we're moving to that consensus. 

16 But with five, that also seems to get to what Ashley

17 was talking about relative to the input on analysis. 

18 MR. ECKMAN: I think that's a -- 

19 MR. CASKEY: Does that item that I was

20 counting as like number six or seven or eight, does

21 that get imbedded into this grouping also? Do you

22 think it's separate? Do you think one and five
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1 should be combined? 

2 Okay. 

3 MR. ECKMAN: I took Ashley's comments to

4 be more broadly -- market data, the cost data, you

5 know, and things that industry provides like weighted

6 average efficiencies and equipment or whatever,

7 things like that that we use in the growth of the

8 analysis and the technology assessments that --

9 (Laughter.) 

10 MR. deLASKI: Okay. So we're tackling

11 number two here. And, again, why don't we give

12 ourselves no more than say 15 minutes per topic so

13 we're sure to keep -- not to try to solve it, we're

14 trying to determine, you know, the need for a

15 subcommittee to spend time on it and the value. Need

16 and value, I think, are the issues here. 

17 MS. ARMSTRONG: This is John, right?

18 MR. deLASKI: John, you described this for

19 us a couple times, I'm not sure you can describe it

20 again. 

21 MR. CASKEY: This is near and dear to my

22 heart. 
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1 MR. deLASKI: Okay. 

2 MR. CASKEY: And just, I mean, to put it

3 in a nutshell -- and some of the things that I've

4 been directly involved with like transformers and

5 lighting and some other areas, maybe even part of

6 motors, but it seems like particularly in

7 transformers where it's sort of running out of the

8 cost-effective opportunities to improve energy

9 efficiency and getting up to 98 or 99 percent

10 efficiency. And in some of the product-oriented

11 things, which is I think we need to start looking at

12 systems and how things are controlled by systems and

13 to see if there are ways that we can get a little

14 more bang for the buck by having the controls and

15 things like that, that you were talking about for

16 lighting and other things that provide a lot more

17 energy efficiency improvements for a smaller amount

18 of money, than going from a relatively high

19 efficiency to a super high efficiency which just

20 becomes prohibitive for manufacturing.

21 MR. ECKMAN: You know, we sort of crossed

22 that bridge a little bit in the pump negotiation
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1 where we got basically a pump defined largely as an

2 extended product. So it has all three pieces that

3 control the pump itself and the motor and all of

4 those are a pump, and I think fans will be similar to

5 that. So if we start getting into these defining the

6 product, you need more than the element that it would

7 be eventually the product.

8 MR. deLASKI: But in that instance, Tom,

9 pump manufacturers can sell a bare pump. 

10 MR. ECKMAN: I'm just saying, we're moving

11 in that direction already in some products. I didn't

12 say that that's for sure, that's a first step, but I

13 think that we're seeing -- because that's where the

14 advantage is in the hydraulic efficiency improvements

15 are relative to what we could do in the motors and

16 drives and the controls.

17 MR. deLASKI: So essentially the standard

18 has two pathways, you can comply by selling a bare

19 pump that complies with the standard, or you can

20 comply selling this intended product that gets you

21 more of the system, and, indeed to get in a -- foster

22 the movement towards selling that or the market or
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1 the programs can then foster by selling the extended

2 product which gives or more -- 

3 (Simultaneous conversation.) 

4 MR. ECKMAN: Take advantage of, for market

5 full programs, to focus on the extended product so

6 that you go way ahead of the hydraulic efficiency

7 alone, you can improve upon it because it's kind of a

8 better motor control on it and incentive programs can

9 be driven -- that technology as opposed to just

10 hydraulic --

11 MR. HUNGERFORD: This is David Hungerford. 

12 The challenge, of course, with that is that when you

13 start developing system products you end up defining

14 -- you either multiply the number of unique product

15 configurations you're regulating instead, and --

16 that's a huge challenge, instead of the pump and the

17 control, three things, you're doing pool pumps, and

18 you're doing water recirculation pumps, and you're

19 doing pumps for different sorts of manufacturing

20 processes, all of which have very different duty

21 cycles, and very different loadings, very different

22 proportions or numbers in the population, very
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1 different change-out or rollover cycles and those

2 sorts of things. And it gets sort of mind-bending

3 pretty quickly. And so the sweet spot has to be

4 found there and some sort of way of defining what

5 that sweet spot looks like. Considering the system

6 issues while still making sure that they're broadly

7 applicable and that in general the efficiency flows

8 through to all of the different possible end use

9 categories and different configurations. I can't

10 imagine manufacturers want to test and deal with a

11 different standard for every single application of

12 the product. 

13 And I can speak from the regulator's point

14 of view, that we don't want to have to draw up

15 different regulations and run different rulemakings

16 for hundreds of different unique form factors. 

17 MS. ARMSTRONG: Can I make a suggestion

18 for this committee? Maybe this will help a little

19 bit. So I think maybe the first thing that this

20 subcommittee should do to the extent that we decide

21 to turn to a subcommittee to tackle this is to

22 actually identify the products for which the systems
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1 affect -- or system metrics may be most beneficial

2 and then compare that to the statutory definitions. 

3 Because I think that that will get you your -- that

4 will help inform your perspective work plan. 

5 MR. HUNGERFORD: Did we also bring up the

6 idea of identifying statutory definition problems?

7 MS. ARMSTRONG: I think I'm going to leave

8 it at that. But I think what you've seen from the

9 department is an interest in moving toward systems

10 where the AFUE is like pumps, like fans, but we also

11 have a statute that was created quite a bit ago and

12 is very specific with this other thing, so I think

13 this committee, as a first order of business, that

14 might be something to look at.

15 MR. MANDYCK: This is John Mandyck. I

16 agree with all the comments that have been said. You

17 know, a category you could consider in this box would

18 be furnaces. So today, you know, we have actually

19 three standards we have to meet. We have to meet the

20 gas efficiency standard, the off mode standard, and

21 the consumer furnace fan standard. And so, you know,

22 and the gas efficiency we're getting very close to
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1 what the maximum is. So this could be one area.

2 The statutory issues is a concern. The

3 broader concern I have is, if we move to a system

4 efficiency, then we have to agree to a system

5 efficiency and that's not a form efficiency metric. 

6 That it can't be an everything above approach, so it

7 has to be we're either going to move this system

8 efficiency in a certain category, and that is the new

9 metric, but it can't be I'm going to have AFUE, off

10 mode, furnace fan and system efficiency data.

11 MS. ARMSTRONG: And we have a backslide

12 issue.

13 MR. deLASKI: I think in the instance of

14 pumps, you know, that -- and that was an instance

15 where the DOE didn't have a definition, right. So

16 the agency was handed a pretty open hand by the

17 statute whereas in other instances, you know, a

18 fluorescent lamp is a fluorescent. And so even

19 though you might like to do something that was

20 suggested fluorescent lamp fixtures be shipped with a

21 control or something the AP doesn't have regulatory

22 authority to regulate fluorescent lamp fixtures, just
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1 to give you an example. That may or may not be

2 accurate. But that's the kind of thing I think that

3 you're suggesting that we have to take a look at and

4 see where are the systems opportunities.

5 MR. HUNGERFORD: Well, in California we're

6 finding we have to -- that that sort of comes into

7 play with our building efficiency standards. And

8 that's where those kinds of things are addressed,

9 where a light, a lighting system or control, is

10 separately regulated, but installation, in order to

11 install these things in a new building, they have to

12 be set up in a particular way and they have to be

13 tested, and they have to be signed off on how those

14 things are organized and put together, how the

15 systems are put together. But, again, that is

16 building efficiency standards, not compliance

17 standards.

18 MR. deLASKI: Other thoughts on this

19 topic?

20 (No response.) 

21 MR. ECKMAN: I agree. Just going through

22 a list of the products that are regulated to see
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1 which ones are amenable to that, but don't have a

2 statutory construction issue as the first step. 

3 There may be options there, there may not, but at

4 least you queue those up where they might be -- there

5 may be some of these where you've got an integrated

6 product that is a piece of laundry equipment that has

7 a component built in, and that's easy. But where

8 you've got a lighting system that's three or four

9 components that are already separately and regulated,

10 maybe it's not so straightforward. So it's worth

11 taking a look to see where there are options. That

12 may be inhibited by a test procedure or just the

13 efficiency metric we have now, but that's how we --

14 you have three things in a furnace that are

15 regulated. AFUE is a big number if you actually --

16 it's all energy in, energy out -- who doesn't that

17 encompass all the energy, you know, it says that in

18 the statute, but we should decide to put it into

19 pieces. Why isn't it all three components combined?

20 (Simultaneous conversation.) 

21 MR. deLASKI: -- from the 1970s or '80s --

22 MR. ECKMAN: but was it a DOE
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1 determination or was it Congress? 

2 MR. deLASKI: Okay.

3 MR. ECKMAN: Just how we defined the test

4 procedure. I've always wondered why Pan Energy

5 wasn't part of AFUE. Well, it isn't a heat pump,

6 it's not on a furnace. Why is that? It's an HSPF.

7 (Simultaneous conversation.) 

8 (Laughter.) 

9 MR. ECKMAN: I know.

10 MS. JAKOBS: This is Diane. So just --

11 we're talking about having -- well, components that

12 have been historically accounted for individually,

13 now we should do it as a system. The other thing,

14 we're doing the other thing too where we've looked at

15 the commercial HVAC and now there's talk, you know,

16 are we going to look at the blower by itself? So

17 we're kind of debundling and we're bundling, you

18 know, so we're doing both. But the more restrictive

19 it is, the more difficult it is to innovate. And I

20 think that's a portion of what we're all looking

21 towards, the future, what are we going to do next? 

22 And I just can't believe when we get to the 99
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1 percent for AFUE that that is the very best furnaces

2 will ever do, you know, it doesn't make any sense. 

3 It's just a limitation of that test procedure. So

4 what is the mechanism to get unstuck where we can

5 start? 

6 In our lab, the people working with the

7 equipment, they all want a heat pump and a gas

8 furnace. So they want the gas furnace instead of the

9 resistance heat for backup. That is what everyone is

10 thirsting for, you know, and that's not even a class. 

11 That's someone in -- has to be in the know to even

12 understand what the benefits of that are. So, how

13 are we doing people a disservice by not letting them

14 know that that is a possible option, you know. It

15 all depends on who your installer is and how up to

16 date they are. You know, is that part of the mission

17 too -- do we stick in these same classes that were

18 put into place when my dad was in, you know, my

19 position now? You know, or are we looking -- are we

20 learning from what we've done in the last 30 years? 

21 Are we moving forward and understanding that if ---

22 who are we trying to help? 
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1 MR. deLASKI: Okay. Anything else on this

2 topic?

3 (No response.)

4 MR. deLASKI: Okay. It strikes me that

5 there is some overlap with the prior topic, right. 

6 So if you can -- to the extent that you can address

7 controls and that you may be able to capture more

8 systems opportunities if you can expand the metric,

9 you may have some limits to what you can do within

10 the legal construct. Often capturing systems

11 opportunities, if you can capture them in the metric,

12 then you can capture them. 

13 Okay. The next topic. Let's make sure

14 there are folks on the phone, Jennifer and Kelley, do

15 you have any input on this one?

16 MS. KLINE: This is Kelley. I don't.

17 MS. CLEARY: Nor do I.

18 MR. deLASKI: The next one is interaction

19 of DOE standard with other regulatory work that I

20 commented on and Diane brought up, interactions with

21 ASHRAE and Deborah added IECC. 

22 MR. ECKMAN: Other organizations.
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1 MS. MILLER: I'm waiting for somebody to

2 bring up other agencies.

3 MS. ARMSTRONG: EPA, they were in there. 

4 FTC -- 

5 (Simultaneous conversation.) 

6 MR. deLASKI: Yeah, I think at the last

7 meeting someone -- I think it was -- not here now. I

8 agree with you, the FTC and the energy guide label

9 and reporting to FTC some appliances, many

10 appliances. 

11 MR. HON: This is Charlie Hon. There's

12 another issue that's coming into fruition here, and

13 that is possible grid control of appliances. That

14 can be a major impact because we're taking them if

15 they're controlled in certain ways and putting them

16 in a nonefficient --

17 MS. MILLER: This is Deborah. I mean, I

18 was thinking on the last thing too, I think, Tom, you

19 had talked about new technologies, and maybe I'm just

20 overenthusiastic about the future or not, but I just

21 think from looking at so many new products, I mean,

22 so many new technologies, I mean, just think about
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1 also not only with respect to the products, but also,

2 you know, off-grid applications, energy storage, I

3 mean, there's so much going on right now that can

4 affect whether this program will be effective or not. 

5 So there are broad issues, that I think one should

6 look into them. They're almost massive it's

7 difficult to put your arms around it. 

8 I think we will have to stay on the level

9 of -- as you were saying, things that are going on

10 with the state as well as other bodies whose

11 standards or methodologies affect these products. 

12 MR. deLASKI: In my experience in many DOE

13 dockets, you know, there typically is a section of

14 the -- or document or maybe a rule, that sort of does

15 this run-through of here's what else is out there,

16 you know, regulatory, in a regulatory world that

17 affects this product, including state standards,

18 including -- I guess an EPA program or not.

19 MS. MILLER: Does it get into -- and,

20 again, I haven't looked at one of these in a while,

21 but does it get into the actual real impacts of that? 

22 This is Deborah. 
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1 My sense was before we would sometimes

2 mention them. Again, this was many years ago. But I

3 wonder, other than ASHRAE and a few others, just

4 whether there's a way to evaluate the impacts.

5 MR. deLASKI: Maybe this is question for

6 Ashley to give us, you know, and like the last

7 question which -- what does the agency do now to look

8 at the gamut of regulatory action that's affecting a

9 given product and how that interacts with the

10 agency's work?

11 MS. ARMSTRONG: I don't think I can fully

12 answer that given the current state of affairs in

13 terms of what's going on with the Department with

14 regards to this issue. But I can tell you that we do

15 look at cumulative regulatory burden, and most cases

16 it's a qualitative-type assessment. In certain

17 limited cases we have done a more quantitative

18 assessment. With regards to certification, I think

19 we've made pretty great strides with FCC such that

20 you now only have to certify as one, which is DOE,

21 and that satisfies both. We're engaged in those

22 conversations with CEC actively to figure out
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1 something on that front as well. I know there's at

2 least a desire from both of our parts to find out a

3 more streamlined process that would work better for

4 manufacturers. So we're actively working it.

5 With regard to FTC, I think it's fair to

6 say that DOE and FTC work pretty closely together. 

7 You know, I've heard some timing issues in terms of

8 test procedure changes and labeling, but I think --

9 and for the most part Hampton is fairly engaged in

10 our process and engaged as early as you could want

11 him to be. So I'm not -- obviously it opens the

12 discussions there, but I think that was actually

13 working pretty well. Other than that, I think that's

14 pretty much -- 

15 MS. MILLER: So you're doing your more

16 than due diligence with other agencies. The question

17 is -- I'm putting words in your mouth you just raised

18 your eyebrows. I'm being kind, Ashley. You're doing

19 your due diligence as best as possible right now.

20 MS. ARMSTRONG: Well, so I think it's fair

21 to say that we do try actively to coordinate with

22 other federal agencies when we know either regulatory
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1 or voluntary programs will be impacted by what we're

2 doing.

3 Now, that being said, I think that some

4 people may contend that they would like to see it

5 taken a step further. And I think that's where --

6 there has been instances where that's happened. 

7 There have been other instances where, you know, DOE

8 has, within its purview, a certain thing and a

9 statutory authority to do a certain thing and

10 statutory responsibility to move forward in certain

11 instances. 

12 But I would say in my opinion the level of

13 coordination that's happening now is far greater than

14 when I first started, at least that I'm aware of. I

15 don't know if you guys have experienced that as being

16 on the other side, but we're trying.

17 MR. HON: This is Charlie Hon. There's a

18 couple things going on here that DOE has no control

19 over whatsoever. And just because DOE may be

20 functioning trying to engage with other groups

21 doesn't mean other groups are trying to engage with

22 DOE. So it's a two-way street that we bear on that,
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1 meaning we're talking fairly here, because DOE is --

2 I know that -- because I've seen interactions come in

3 several different directions. But sometimes it's the

4 other groups not necessarily having their direction

5 set which gives DOE fits. A typical example of that

6 right now was refrigerants, they're running hot,

7 because EPA SNAP program is in a major flux on what

8 they're approving and what they're not approving. 

9 The industry as a whole, because of global warming

10 information popping up left and right, and global

11 warming issues being faced by the State Department

12 and the EPA, are in flux as well. And DOE is stuck

13 with a situation where they're trying to regulate

14 products not knowing what refrigerants are going to

15 be available to the manufacturers, and the

16 manufacturer is in the same category, not knowing

17 which alternative refrigerants are going to be

18 available in the foreseeable future. Some of those

19 alternatives are more efficient, some of those

20 alternatives are less efficient. And as such, DOE,

21 if they regulate off a more efficient product, if

22 it's available, that doesn't hurt anything. But if
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1 it only fits into part of the category, then DOE is

2 trying to figure out what the less efficient product

3 is even though it's really not defined yet because

4 the product has not been field-tested over the long

5 term in equipment. So then the industry is running

6 around here going, oh, what do we do next? And

7 that's happening right now. It's a very, very

8 high-level problem for refrigeration and air

9 conditioning and we end up with, again, the cascade

10 issues because the new refrigerants do not fit the

11 old mold because of climatability issues, safety

12 issues. Suddenly local codes now become a roadblock

13 to manufacturers because they may not -- even though

14 they can meet federal standards for these products,

15 they may not meet local standards for these products

16 because local standards may be eight to ten years

17 behind on schedule. So the local standard says you

18 can't use an A3 refrigerant. Or the local standard

19 says you can't use an A2 or an A2L refrigerant in an

20 air conditioning system, yet there's no alternative

21 but that. 

22 So we're in a real quandary at that level.
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1 And I don't want to be critical. I'll

2 support DOE on this because DOE has reached out

3 extensively trying to figure out what's going on

4 there, but some of these other agencies don't even

5 know where they're going yet. So that leaves DOE in

6 a big lurch.

7 MR. deLASKI: I don't want to get too far

8 into this issue, I mean, other than, you know, we're

9 trying to scope it out for this topic. And I know

10 the sensitivity of the SNAP rules which I think you

11 can't comment on because it's something -- EPA's

12 proposed rule or final rule went to OMB this week.

13 MR. HON: The proposed finding.

14 MR. deLASKI: The proposed finding. It's

15 the final rule. So under -- OMB manages interagency

16 coordination. So that's why she can't comment

17 because they're in this phase of interagency

18 coordination which probably has been informal as I

19 understand it, it's an informal phase before now and

20 now it's in a formal phase. Deborah has been in this

21 seat so she can probably nod her head to the process

22 where the agencies comment on other agency's rules in
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1 the OMB process. We don't know what that final rule

2 says. I don't -- you guys have been deeply engaged

3 and Charlie, you and I have talked offline about

4 this. Many of you have been in D.C. a lot to work on

5 the SNAP regulations. 

6 So, you know, that train is kind of moving

7 along, right. So the question, I guess, for us is,

8 is there a role for this group on this kind of topic?

9 MR. MANDYCK: This is John Mandyck. That

10 train is moving along for a fraction of the products

11 covered by the appliance programs. The determination

12 has zero impact right now on air conditioning.

13 So it will be an ongoing issue. And I

14 think the two points I would make is, one, there's

15 the obvious technical impact of, okay, what

16 refrigerant do you choose and what efficiency does it

17 yield? So there's that. But then there's the

18 economic impact of -- is the industry forced to

19 redesign the same product twice in a too-short of a

20 period that doesn't make economic sense? So in other

21 words, every new minimum efficiency standard drives

22 an enormous investment in the industry. Any new
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1 refrigerant standard drives an enormous investment in

2 the industry. The issue is that if those happen on a

3 collision course, or ones that are back to back, now

4 you're placing significant economic burden on the

5 industry. So that coordination is what's important. 

6 And the good news is, at the White House event in

7 September where several manufacturers and trade

8 associations stood up and declared voluntary

9 commitments to reducing greenhouse gas impacts on

10 products, the secretary and the administrator were

11 both there, this issue -- Administrator McCarthy

12 said, "What can we do to make sure that we see more

13 of this progress?" And one of the participants said,

14 "We need better coordination between DOE and EPA for

15 this very reason." So it was heard at the highest

16 levels. And actually they both agreed publicly at

17 that meeting to examining a process to make sure that

18 they are coordinated. So it's an open door I think

19 that we can go back on. I'm not sure we can solve

20 it, but there is, at least at the highest levels some

21 receptivity to the issue.

22 MS. CLEARY: This is Jen. I think,
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1 Andrew, you asked whether this was something that the

2 group should continue to discuss. And I think in my

3 view, I agree with Ashley, I think they're working

4 hard on coordination and though I don't think that

5 this is something that ASRAC should continue to

6 pursue. I think that this is for comments and

7 individual rulemaking to indicate to DOE when they

8 think there needs to be increased coordination and I

9 think that because this also involves other agencies

10 that the comments should also be involved in getting

11 those other agencies to the table with DOE. So, you

12 know, I think the processes are already in place and

13 I don't really see much of a role for us here. I

14 think we have other more important topics on our

15 list.

16 MR. deLASKI: And, again, I don't work

17 myself on the SNAP regulations. So I'm relatively

18 novice on that particular topic. So -- and it sounds

19 like as you just described there's a sequencing that

20 we're going to see another SNAP rule coming down the

21 pike in some time frame to address HVAC refrigerants. 

22 What's the time frame for that?
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1 MR. MANDYCK: This is John Mandyck. We're

2 just going to continue to see several SNAP and this

3 is going to be an ongoing process. This is the first

4 one that we've seen in a while to this degree. It

5 may or may not get challenged. So that's an open

6 question mark, too. We don't know the schedules that

7 DOE -- EPA is going to follow by which product would

8 refrigerant -- but it is out there.

9 But I guess I would take a little bit of a

10 different view. I think this is something that the

11 ASRAC should look, please don't focus just on the

12 refrigerant issue that we just talked about. There

13 are much broader issues. FTC was mentioned. ASHRAE

14 was mentioned. I think it warrants at least a

15 subcommittee discussion to say, if nothing else, what

16 are all the coordination points that are important to

17 get good effective rules out the door and at least to

18 be cognizant of that road map, because I'm not sure I

19 even know what all of them are today.

20 MS. ARMSTRONG: This is Ashley from DOE. 

21 I don't necessarily have an opinion about whether

22 ASRAC should charter subcommittees or not. I think
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1 that, you know, we have a pretty high area of

2 coordination with regards to other agencies, both

3 their voluntary programs and their regulatory

4 programs are pretty tuned in right now. I obviously

5 welcome comments on that, but I think what I do see

6 lacking is how -- and this is more on the test

7 procedures side is engaging ASHRAE, AHRI, IEC, AHAM,

8 the bodies that -- the CFA, the bodies that actually

9 do develop industry consensus of base test procedures

10 for which then get passed to DOE for consideration

11 for review, proposal, and being essentially adoption,

12 I think that is completely disconnected right now.

13 And I really think that we could have a

14 much greater impact focusing on that, if you want my

15 personal opinion. 

16 MR. deLASKI: So say again, what's the

17 disconnect? What two things are disconnected?

18 MS. ARMSTRONG: I think -- well, I think

19 it's more than two, but I think the timing is

20 disconnected. I think content is disconnected. I

21 think what people think DOE can do and what DOE can

22 do are two different things. I think there is a lack
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1 of -- and this is not necessarily across the board. 

2 So I'm just rattling things off. But I think there's

3 a -- not necessarily a feedback group to some of the

4 wider-level issues that are brought up in the rules,

5 then keying them up into the next iteration of

6 industry test procedures. I think that -- you know,

7 I'm not sure how to get that process up and running. 

8 We're trying -- we have been trying to get

9 more involved in committees, you know, in industry

10 committees and going to them. There are some

11 limitations in terms of the feedback DOE can give

12 outside of its rulemaking processes. There are legal

13 limitations, but that being said, I still think our

14 involvement could have an impact and we could do this

15 better. 

16 MS. JAKOBS: This is Diane Jakobs. I'm on

17 a bunch of these committees and I think there's a

18 real lack of understanding about what the

19 interactions are. Someone mentioned before maybe we

20 could do a white paper. People on the committees

21 don't understand what the impact is. And I've been

22 on committees where, oh, we have to have this done by
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1 this and this date so DOE can use it. And it's I

2 guess way too late. So -- 

3 MR. deLASKI: You mean, they're too late

4 for the DOE process?

5 MS. JAKOBS: Yeah, we think we're working

6 for the DOE process and we are way off the mark. So

7 we feel like we're responding, but -- 

8 MR. deLASKI: If you could imagine some

9 sort of -- I don't know whether DOE and this gets

10 back to what your legal opportunities are, but what

11 constraints you have which is almost we want to like

12 publish or provide some sort of guidance to the test

13 bodies so that they know, for example, we've got to

14 have a single metric be would be an example. 

15 MS. MILLER: Or we would like you to work

16 on this or -- I don't know.

17 MR. deLASKI: Well, there could be

18 guidance that would be more from across the board. 

19 Here DOE's legal limitations, which, of course,

20 sometimes they don't want to put black-and-white ink

21 because then they're patting themselves down in the

22 future. We might not agree with interpretations, or
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1 you might not agree with interpretations. 

2 But then also to more specifics where a

3 given topic or a given review or a given technology.

4 MS. ARMSTRONG: I think those are all

5 fair. Feedback loops are definitely important. But

6 I just think more broadly a general understanding of

7 even the currency of DOE reps is not there by the

8 people that are writing these test procedures. And I

9 will say one of the examples that I was pretty

10 surprised by was something that you've already

11 brought up was at the furnace test procedure. I

12 mean, we mostly proposed to adopt a 2007-ish version

13 of an ASRAE standard and we got the book thrown at

14 us. I was like, Lord, because I just figured that --

15 I was very surprised, let's put it that way. You

16 know, people were like, we're not sure what this does

17 yet. Yeah, ASRAE did it, but we haven't used it yet. 

18 Really? I mean, so I was pretty surprised, let's put

19 it that way. That was an interesting, eye-opening

20 experience. So I think it would be worthwhile for

21 those that actually are involved in the manufacturing

22 community to have that conversation about, you know,
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1 how do we bridge this gap? 

2 MR. HON: This is Charlie Hon. There's

3 another issue that needs to be discussed, and that's

4 having been involved in a national committee that is

5 involved and is one of the discussions in this group

6 because it is a standard, I guess having been on that

7 committee for 12 years, we have never seen a written

8 request for change that's submitted by the public. 

9 The only change discussions come from within the

10 committee by the members of the committee. 

11 MS. MILLER: Who can understand it? I

12 mean, that's the problem, with all due respect.

13 MS. ARMSTRONG: Yeah, I know, she's

14 absolutely right though, DOE has never submitted

15 anything in writing to the committees. And that's

16 something I can take back and ask if we could do

17 that.

18 MR. HON: That's the first question I have

19 because there may be legal issues there.

20 MS. ARMSTRONG: Yeah, I don't know. I

21 mean, I can definitely take that back and ask, is

22 there a way. I know that I participated in
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1 committees and verbally emphasized areas for which I

2 think should be looked at definitely, you know, and I

3 think we've participated in committees and provided

4 feedback of drafts where we asked a lot of questions. 

5 But maybe we have not take a regulatory position on

6 it. And so I think those are definitely options for

7 us. But I'll see if we can formally write letters. 

8 We have written a couple letters in the

9 ASHRAE context with regards to 90.1 stuff, but not

10 necessarily what you and I are thinking of in terms

11 of our laundry list.

12 MR. HON: This is Charlie Hon again. The

13 reason I am suggesting that is because there is never

14 different processes. This comes in, in a verbal

15 comment. It can be discussed very quickly and wiped

16 off the table. If it comes in written comment it has

17 to be completely processed, responded to and reviewed

18 by higher level people in ASHRAE to verify what's

19 going on. And as such it will get much more scrutiny

20 and much more realistic review.

21 MS. ARMSTRONG: Thanks.

22 MR. ECKMAN: But as we look toward this
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1 comment of, I think, looking at list and we can

2 identify some test procedures that are early on in

3 the queue, having a work program at DOE that

4 identifies these test procedures we think where there

5 are needed changes that would be really helpful that

6 the industry is working on and here's the time frame,

7 by which we would need your sage advice as to how to

8 move on that and that in order to be in our process

9 so that when we can take the next step -- regulation. 

10 I think part of this is just getting the sequence of

11 what the private sector is doing and what DOE is

12 doing in a linear way instead of parallel processing

13 which tends not to work very well. 

14 MR. deLASKI: I'm wondering whether this

15 issue of better coordination with test method bodies

16 is something that belongs grouped back with item one? 

17 It's really a question of, you know, again back to

18 this question of sequencing and improving test

19 methods.

20 MS. JAKOBS: The problem is, one is

21 getting so large now that you're needing

22 subcommittees -- subcommittees on one, it's true.
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1 MS. ARMSTRONG: Our whole committee could

2 do one.

3 MS. MILLER: Yeah, yeah.

4 MS. ARMSTRONG: If you want to know the

5 outcome of today's meeting.

6 (Laughter.) 

7 MR. deLASKI: Well, maybe we're zeroing in

8 on what is a good work area for subcommittees.

9 MS. ARMSTRONG: I think that would be

10 great. Being the person at the Department who is in

11 charge of test procedures, I would welcome that.

12 MR. deLASKI: And we would have to support

13 doing that work. So -- 

14 MS. ARMSTRONG: I would.

15 And then your recommendation would come to

16 me.

17 THE COURT REPORTER: I have to change a

18 battery, if you don't mind, that will just take me a

19 minute.

20 MS. ARMSTRONG: We have two options, we

21 can have a break, we can break for lunch, it's noon. 

22 This might be a good time with her
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1 changing the battery.

2 MR. deLASKI: Great time.

3 (Simultaneous conversation.) 

4 (Whereupon, at 12:00 p.m., the meeting was

5 recessed to reconvene this same day at 1:00 p.m.)

6

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1 A F T E R N O O N S E S S I O N

2 (1:12 p.m.)

3 MR. deLASKI: I think we're going to get

4 started here. We had finished -- I think we had

5 gotten to number three, and we came to a

6 determination of what our action item was. I would

7 suggest that one action item on number three, before

8 we come back to this notion of we're going to create

9 subgroups to work to address. I think there was a

10 suggestion that this committee can play a role in

11 ensuring that if there are areas that DOE should be

12 coordinating with that they're not coordinating with

13 to identify additional areas they should be be

14 looking to coordinate with, that would be a useful

15 function for us. There's already lots of

16 coordination going on. But if something is not going

17 on, by all means, let's make sure it gets on the

18 table.

19 I don't know that we need to be -- is

20 there anything else that people are aware of that

21 agency think needs to coordinate with that wasn't

22 discussed in our prior conversations?
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1 (No response.) 

2 MR. deLASKI: And is there a need for sort

3 of -- maybe this is an ongoing check, it may be. Is

4 there a need for a committee on that task as there is

5 as this is an ongoing function perhaps for a future

6 agenda item. 

7 So let's move ahead then if there's no

8 further comment on three to item number four.

9 MR. MANDYCK: So I'm sorry. So you're

10 suggesting that we don't form a group or -- 

11 MR. deLASKI: I was suggesting on this

12 particular -- on that narrow issue of -- are there

13 additional areas that DOE needs to coordinate with,

14 that that -- it seemed that that itself needed a

15 group. That narrow question. 

16 MR. MANDYCK: Because there's an open

17 question about ASHRAE. 

18 MR. deLASKI: Okay. 

19 MS. ARMSTRONG: Perhaps we do one of two

20 things, either form a different group or lump it with

21 number one. 

22 (Laughter.) 
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1 MS. ARMSTRONG: Because, I mean, it's

2 going to be all about -- 

3 (Simultaneous conversation.) 

4 MS. ARMSTRONG: -- timing and engaging

5 other groups that, you know, have, I would say, the

6 primary responsibility for the industry side test

7 procedures and it's larger, I mean, we have AHAM test

8 procedures incorporated by reference. We have AHRI

9 test procedures incorporated by reference. Number

10 one is just blowing up.

11 MR. MANDYCK: Right. This is John

12 Mandyck. This is -- I guess what I was thinking of is

13 beyond this. So, for example, you know, we spend

14 ASHRAE and the people involved with it spend several

15 years getting to a point where we have commercial

16 rooftop standards and we're just starting to -- we're

17 just spinning the wheel again and doing it all over. 

18 So I think there is an issue about for covered

19 products. Is that the best way to do it? Is to

20 dedicate a ton of time that's ultimately just thrown

21 out the door and you start all over again. 

22 MR. deLASKI: Isn't that -- I think I
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1 understand what happened, but DOE is functioning

2 under specific statutory allegations for the ASHRAE

3 products. But I don't know what it is -- I understand

4 that that needs attention and that the -- over how

5 that process has been and to go into the next

6 iteration, you know, -- how that process works.

7 MS. ARMSTRONG: So I will say that I have

8 actively volunteered myself and John -- you didn't

9 know this -- to come to 90.1 and explain to them how

10 our process works. It has been tabled for their

11 response. So if you think that would be helpful to

12 get them to understand how many different products

13 work, how we are triggered, what our deadlines are,

14 kind of what's coming down the pike, how they can

15 engage in that process and what DOE's

16 responsibilities still are above and beyond what

17 ASHRAE does, I thought that would have been helpful

18 because that's what I see as the lack of

19 understanding kind of how it works. But you might

20 want to touch base with them. 

21 MR. deLASKI: I'm not on the ASHRAE 90.1,

22 but I'm not even on ASHRAE but 90.1 is 80 people, 100
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1 people -- it's huge. 

2 MS. JAKOBS: Yeah, it's huge. 

3 MR. deLASKI: It's huge. So, right, it

4 may be -- my point wasn't necessarily just DOE, but

5 the -- excuse me -- advocate community signed off on

6 90.1. Then when I got the DOE it's not enough to

7 trigger the thing and so that's my point, there seems

8 to be -- it's an imperfect and inefficient process if

9 we're going to spend all of our time and energy

10 trying to get the consensus on ASHRAE standards that

11 we think is sound with all the parties are at the

12 table and then when it kicks the DOE, people have a

13 change of heart and then we have to go through it all

14 over again. 

15 MS. ARMSTRONG: I don't want to take a

16 deep dive into what happened, but I will say that we

17 gave a presentation about five years ago to the

18 ASHRAE committee about -- it was right, I think

19 before some of the statutory language was changed

20 about what hasn't happened for a lot of products in a

21 while and kind of what DOE's triggering obligations

22 were. So there's a difference in opinion about DOE's
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1 triggering obligations. I think that's where -- and

2 so that being said, though, I think it's really about

3 education, in my opinion. The statute says what it

4 says. Our lawyers aren't going to be laboring on

5 that one. But we're happy to explain what we think

6 our interpretation is, or what our requirements are

7 and how we can facilitate that role and how we can

8 work better to march through the process together

9 which is what I offered to do.

10 MR. deLASKI: Okay. 

11 MR. CYMBALSKY: This is John from DOE. So

12 I don't think that's the point where the schedule is

13 yet, but I mean, clearly we've laid out, you know,

14 there's -- the ASHRAE triggered and that's not magic,

15 right. The ASHRAE people on those committees know

16 when the next DOE obligation is or NOPR. So whatever

17 work they're doing on a particular product, I hope

18 they know when DOE's trigger to act if ASHRAE does

19 it. So those are the two mechanisms for DOE to have

20 to do a rule. Ashley mentioned there's some

21 difference of opinion on the lookback or whatnot.

22 Clearly we -- I think we stated our legal
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1 position.

2 MR. deLASKI: And I wonder to some extent

3 whether -- I guess I want to say a couple things. 

4 One is that I didn't participate in ASHRAE 90.1 and I

5 haven't -- I don't know -- I don't think there's

6 broad participation from people who I typically work

7 with. There is some participation. 

8 And the thing that occurs to me is that

9 there's need for education kind on all sides, meaning

10 that there may be advocates that need to be educated

11 as well as to what sort of -- you know, how this

12 works. No one has the book. No one seems to

13 understand the entire -- for the people who thought

14 that what they were doing to lead to a certain

15 outcome and didn't get to that outcome, that clearly

16 explains why people are disappointed; right? So

17 then, just to make sure it doesn't happen again in

18 the next iteration. And the best way to do that is

19 to understand what does the ASHRAE need to do in

20 order to get an outcome that people might be

21 interested in? A standard that doesn't meet the

22 statutory criteria is going to trigger -- people that
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1 can't know what DOE is going to determine what

2 triggers it. That it isn't like the advocates and

3 ASHRAE decide whether it triggers or not. 

4 What decides is the analysis of the number

5 -- is going to be their analysis. So we have to

6 understand that this is not some sort of -- ASHRAE

7 doesn't ever foreclose DOE obligation to do an

8 analysis that determines what the statute says. I

9 can't remember, but there is a standard that has to

10 be -- there's a little lower standard, I think, but

11 there's still a standard.

12 Clear and convincing evidence which is

13 different than the other standard. But, you know,

14 there's meaning behind all that that we can't be

15 willing to parse today, but will be useful to parse

16 if we're involved in the next iteration. I mean,

17 that's separate. 

18 It's somewhat -- it's bounded to the

19 ASHRAE and set of ASHRAE products. So it strikes me

20 that that's something that we want to recommend to

21 the ASHRAE, you know.

22 MS. ARMSTRONG: I don't know what's the
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1 best way to do it -- whether to do it through 90.1 or

2 do it through AHRI or or do it and DOE can host it

3 separately here. I mean whatever works. I'm sure we

4 can find a way to make it happen. I thought it was a

5 good idea.

6 MR. deLASKI: And the other thing that

7 occurs to me is that as we started this negotiation

8 which is now part of our working group dealing with

9 commercial air conditioners and furnaces, which is

10 two of the products in ASHRAE universe, that there's

11 been interest in that discussion about how do we --

12 is there -- there may be space in that discussion

13 that takes some of this on as part of that working

14 group. It's not our core mandate but this discussion

15 of how to do this better next time, I think is fair

16 game for that working group and that's where a lot of

17 the parties are already together. 

18 MS. ARMSTRONG: I do want to highlight one

19 thing and it has little to do with this discussion

20 other than I think Don would have an interest in this

21 if he looks at the standards. You know, there are

22 certain equipment in ASHRAE that are supposed to be
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1 initiated this year for DOE that are triggered. So

2 evaporated cooled, water cooled, VRS, and computer

3 room air conditioners and the ASHRAE process is not

4 necessarily -- you know, we go back and forth whether

5 DOE can do it faster or ASHRAE can do it faster.

6 MR. deLASKI: You're triggered by the

7 look-back provision? Jim.

8 MR. CRAWFORD: I'm going to make an

9 observation. Jim Crawford. I spent somewhere

10 between two and four decades in the standards area

11 between the ASHRAE, IEC, ISO, and various trade

12 associations. There is no such thing as an ASHRAE

13 product and very few ASHRAE standards define product

14 performance. They define lots of other things,

15 primarily test criteria and test procedures, but not

16 -- and 90.1 is fairly unique in that. 

17 And if I were sitting in your chair, thank

18 you, I don't want to, but if I were sitting in your

19 chair, I would be looking to trade associations. The

20 other focal point, they're the ones that have to

21 satisfy all applicable standards for the market that

22 they're serving. And I would look to the trade
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1 associations to be the interface for the standards

2 uniformity issue and there's a lot more discipline

3 and freedom to respond in the trade associations than

4 there is in ASHRAE. ASHRAE meets twice a year and it

5 may take them two or three meetings, or it may take

6 them two or three decades sometimes to settle on

7 something. And it's not driven by industry. It's

8 not driven by advocates. To a surprising degree,

9 it's driven by registered engineers and academics. 

10 And the academics, and I'm including certain

11 government laboratories who are associated with

12 universities, I won't name them.

13 (Laughter.) 

14 MR. CRAWFORD: What they're after is not

15 necessarily that which meets DOE's needs, and it's

16 not necessarily that which meets industry's needs, or

17 what the public's needs, but what meets their

18 academic idea as to what ought to be in a perfect

19 world.

20 MR. deLASKI: I think the point it raises

21 to me is, for the set of people that need to be

22 educated about process, it's not just the people who
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1 are in the working group.

2 MS. ARMSTRONG: I agree.

3 MR. deLASKI: This is a broader set of

4 people who are outside the manufacturers.

5 MS. ARMSTRONG: And that's absolutely why

6 I targeted the 90.1 committee because, in theory,

7 they're the ones voting on these continuance

8 maintenance proposals, while they my not be the ones

9 always bringing them to the people, they may reside

10 with some of the trade associations or whatever. 

11 Ultimately they're the ones voting for inclusion in

12 the next iteration of 90.1 and that's what's going to

13 trigger DOE or not, in which case DOE would do its

14 own analysis.

15 MR. MANDYCK: This is John Mandyck. I

16 just, as we were talking, sent a note to the 90.1

17 vice chair.

18 MS. ARMSTRONG: Okay. 

19 MS. MILLER: This is Deborah. I was

20 wondering, did they give you a reason why your

21 suggestion was tabled? Was it they didn't have

22 enough time or they just weren't interested?
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1 MS. ARMSTRONG: I don't think I know. I

2 think maybe he wanted to circle back with some people

3 and see if there was an actual interest. It wasn't

4 like, you know, the answer was no. But I think what

5 we hear from the regulated entities, from an

6 appliance standard viewpoint is very different than

7 what sometimes we hear from 90.1. They're not

8 necessarily one in the same.

9 MS. MILLER: This is Deborah. I think it

10 goes to what Jim was saying about who's on 90.1

11 versus industry.

12 MR. deLASKI: So do we need further action

13 items on this, John? Or this is -- 

14 What is your thought for what further

15 action is for ASRAC on this topic?

16 MR. MANDYCK: This is John Mandyck. Maybe

17 we let some offline action to see if we can take

18 place and then return to the item if we need to.

19 MR. deLASKI: Well, let's just make sure

20 it stays in our agenda and we return to it just to

21 say, you know, here's what happened and we need no

22 further action but let's keep it as an agenda item to
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1 our next meeting or two. 

2 Okay. John?

3 MR. CASKEY: I'm sorry. John Caskey. 

4 Just a clarification. Is that -- what you just said,

5 is that related to the ASHRAE connection or is that

6 related to all of item three?

7 MR. deLASKI: I was thinking it related to

8 the ASHRAE topic.

9 MR. CASKEY: Okay. 

10 MR. deLASKI: We're basically

11 disassembling item three. 

12 Item four. This part was teed up by Dan

13 Cohen's presentation discussion of the presidential

14 initiative on retrospective and regulatory review

15 which is, if we remember his presentation at the last

16 workshop and I think many folks of trade associations

17 have submitted comments and DOE has solicited

18 comments every year now for the past several years on

19 regulatory review and lookback, looking for places

20 where they can remove extraneous regulations and

21 consolidate and also look at evaluating the

22 effectiveness of existing regulations. 
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1 When I thought about this, I think of it

2 as a what could we learn, how can we look back at

3 what they've done to learn to improve what you do in

4 the future so that we improve analysis tools and

5 improve, you know, if you've learned how well you did

6 before then you can learn where you need to focus

7 your attentions so you can do better in the future. 

8 This is not what I would think, you know,

9 that we as a committee would do, lookbacks, but that

10 the potential actions, to me, would be to recommend

11 to the agency that they invest some of their

12 consulting analysis resources into doing reviews of a

13 select number of rules to see what actually happened,

14 do their best to assess what happened. I know it's

15 not an easy analysis task, desegregating what happens

16 -- would have happened anyway? There's no control

17 group. So it is not an easy analysis to do. But it

18 strikes me as being a potentially useful one and one

19 that would be a good use of departmental consulting

20 resources on a limited basis. I wouldn't want it to

21 become -- to blow up to be this thing that ends up

22 becoming a hindrance. It strikes me as being a
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1 useful potential for future analysis.

2 Jen commented here. We have Jen's comment

3 by e-mail. 

4 Jen, do you want to elaborate, or is that

5 sufficient?

6 MS. CLEARY: That's sufficient, although I

7 think in you -- I'm sorry, I'm having a little hard

8 time hearing people so I'm just want to make sure I

9 understand. Were you suggesting that part of the

10 retrospective analysis should be looking at the

11 actual impact the standards have and that that's

12 what's difficult -- that's what would have happened

13 anyway and what happened because of the standards?

14 MR. deLASKI: Yes, that's a useful

15 question to look at and acknowledging it's not an

16 easy analysis to do.

17 MS. CLEARY: Okay. I'm sorry, you guys

18 are coming out a little garbled after lunch for some

19 reason. But I agree with that, but I don't have

20 anything else to add to my other comment.

21 MR. deLASKI: Diane?

22 MS. JAKOBS: This is Diane Jakobs from
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1 Rheem. So to me this retrospective analysis, I don't

2 think it's as important. And if the consultants were

3 going to work on something, to me it would be more --

4 I keep hearing about leveraged tools from previous

5 rulemakings and data and the Grimm model was built on

6 Lotus 1-2-3, and before Windows, you know, so it

7 doesn't -- it seems like I would spend the time on

8 something more current. 

9 There are always a lot of projections

10 about how much energy you save. In the end I

11 understand that it's a projection and so what if it's

12 not right, really it's more important where are we

13 today and where do we want to go. So I don't think

14 that this is an important item either. I agree with

15 Jen.

16 MR. ECKMAN: This is Tom Eckman. There

17 are two aspects to this, particularly in the

18 evaluation and the process evaluation and the impact. 

19 Whether the impact evaluation is a high priority, I

20 think process, continuous improvement. The other

21 point good to have a review of some of the more or

22 less successful rulemaking enterprises to see what
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1 went wrong and what was right about those, whether

2 they were negotiated rulemakings or whether they

3 didn't go through negotiations or the standard

4 process to see that there are elements that improve

5 either the outcome -- the general acceptance of the

6 outcome of lawsuits that led to, you know, the

7 implementation on a schedule that -- where were the

8 errors so that we can limit those again and where can

9 we figure out how to streamline a process that would

10 do faster with less lift. That's a different kind of

11 evaluation -- a rulemaking process in and of itself

12 is what's under the microscope about the impact of

13 the standard. That might help us give better

14 guidance to the Department on things that could

15 change to improve these processes -- that way there's

16 less about refrigerators producing the savings we

17 thought.

18 I think that's a different tack on that

19 same question be it from a process standpoint. I

20 think part of our guidance here is to continue the

21 rulemaking processes.

22 MR. deLASKI: Has the agency done process
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1 evaluation in the past, Ashley, do you know?

2 Informally, I presume.

3 MS. ARMSTRONG: Yeah. I mean, I think

4 we've -- you know, there was a process overhaul a

5 long time ago. Since then I think there's been minor

6 tweaks to the process in response to the feedback and

7 some -- DOE announced a little bit of a departure and

8 new process for let's say not too long ago for -- in

9 certain situations. But I don't know that we've

10 necessarily reopened all aspects of process. 

11 Certainly I think we've been open in specific

12 rulemaking instances to holding extra meetings or

13 having analysis tools, tutorials or doing a second

14 set of interviews or doing, you know, more on a

15 one-on-one basis in response to the specific concerns

16 being brought up in that specific rule. But I don't

17 know if it's been, you know, take a step back and

18 look at every single aspect kind of thing. 

19 MR. McCABE: This Michael McCabe. Process

20 improvement, process improvement, process

21 improvement. And most everything in the analysis was

22 changed as a result of that.
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1 MS. ARMSTRONG: Yeah, but I think he's

2 asking since then.

3 MR. deLASKI: Yeah, and I also was asking,

4 you know, has there -- what Tom is describing is

5 there something different? Which is basically you

6 hire an outside consultant and they come in and take

7 a look at what's been done and provide a report. 

8 Let's sort of find the friction points, identify the

9 points that are working well and that are not working

10 well. It's more of outside professionals who can

11 look at process and, you know, who have that skill

12 set and it would basically be a contract for the

13 agency. 

14 MS. ARMSTRONG: We call that GAO and IG.

15 MR. deLASKI: Okay. 

16 MS. ARMSTRONG: We've been through several

17 of those.

18 MR. deLASKI: Okay. That was my question. 

19 So there are internal controls in the agency here

20 that make Ashley's life hell, apparently, as they ask

21 lots of questions, right?

22 MS. ARMSTRONG: Multi-year process.
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1 MR. deLASKI: Right. So the GAO is the

2 Government Accountability Office, and then the DOE's

3 own Inspector General. And are the outputs of those

4 -- are there public reports that come out of those

5 processes?

6 MS. ARMSTRONG: GAO is. I don't know if

7 IG is. I'll have to look. 

8 MR. deLASKI: That might be good too. You

9 can share that back with the committee.

10 MS. ARMSTRONG: Okay. 

11 MR. deLASKI: Other comments on this

12 topic?

13 MR. CASKEY: This is John Caskey. The

14 more I think about it, I like sort of Tom's idea, and

15 there might be opportunities for some sort of process

16 improvement. In terms of an analytical sort of

17 looking at what was in the regulation and what's

18 actually out there now and, you know, you realize the

19 improvements that we estimated and things like that,

20 it just seems like the whole process has changed with

21 time and I'm not sure what meaningful results you get

22 from that, not only the negotiated rulemaking process
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1 and I think, you know, at least some of the ones I've

2 been involved with, it seems like the discovery of

3 improvement opportunities in the modeling and the

4 analysis and things like that were made. So it's

5 like -- and you say there's no control group and it's

6 like, things evolve through time and technology is

7 evolved differently than what we expected, you know,

8 five or six years ago. So I'm just not sure what --

9 I'm not sure you get meaningful results, first of

10 all, and I'm not sure what in the world you would do

11 with those results once you got them.

12 I would rate it as sort of, for me

13 personally, a lower priority. 

14 MR. deLASKI: Okay. Anyone want to push

15 back on that assertion? That seems to be the growing

16 consensus, that this is a lower -- not without some

17 value but if we prioritize, it ends up being lower.

18 And then we can learn back from Ashley what the

19 process reviews -- what's been done recently under

20 normal government control, review processes.

21 Okay. Anything else on item four?

22 (No response.) 
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1 MR. deLASKI: Item five, improve energy

2 usage data. Did we tackle this when we hit on the

3 one, or are there remaining topics to discuss here?

4 MS. ARMSTRONG: Tom, you originally asked

5 me for the list. And I will say with one caveat, I

6 think it's all fairly accurate. I was going to take

7 another -- just before I put it in the bucket, I

8 wanted to take a chance to take a look at the

9 statutes just to make sure I captured some of the

10 lookbacks that may be further out, which I think

11 would help you in your long-term-type process. So, I

12 know obviously the active ones are accurate, and I

13 think the near-term ones are. And then

14 you had asked, I think, what -- are there certain

15 areas that both DOE could identify, and perhaps some

16 stakeholders may also have an opinion, about where

17 the greatest need might be for field use data that

18 would inform the test procedure provisions, and I

19 didn't do that on this sheet, but I do have some

20 ideas and I think we can talk about it as number one

21 in order. We could also put out an RFI and ask if

22 you wanted to get feedback from the greater community
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1 if you were actually interested in getting feedback.

2 MR. ECKMAN: I think that would be

3 --something like that would be real useful. I made a

4 list of questions that, you know, would be useful. 

5 You get a calendar and then you back up

6 from that and say, how long does -- what kind of data

7 do we need and how long does it take to collect that

8 data? Sometimes that determines whether you bother

9 because it's really great to have the data, but if

10 it's a year late because you can't just physically

11 get in the field with the data collection, because it

12 needs a year's worth of data before you have an

13 answer, then you know you've missed this round. And

14 you can start that process, but you might not want to

15 start right away. You might want to start it two

16 years prior to the next rulemaking as opposed to this

17 one. 

18 So I think that's -- those are the kinds

19 of things that should be in a written RFI. We might

20 be able to figure out which test procedures are most

21 subject to do the cycle information or other kinds of

22 neat parameters where we don't know if it's a life
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1 cycle process or a test department process, and get

2 feedback from parties that are familiar with each of

3 those test procedures about what needs to be --

4 what's missing right now, or what needs to be updated

5 and I'm sure your own staff have, and the consultant

6 staff have, use of those because they're dealing with

7 them up to their elbows now.

8 MS. ARMSTRONG: That's fine. And I think

9 the ones that come to mind with regards to test

10 procedure provisions are the ones that Jen is going

11 to be -- Jen in particular and perhaps Kelley would

12 be particularly interested in. They're the ones

13 where the filed use data seems to come up quite a

14 bit. 

15 For the test procedures, now obviously for

16 the scanner side and the energy use analysis, we do,

17 for most of the rules, do feel use kind of, and for

18 me, field use information to help inform that energy

19 analysis. And so, great, we'll work on it as the

20 best mechanism to get feedback, but I think we can

21 handle that one.

22 MR. MANDYCK: This is John Mandyck. 
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1 There's a corollary data point that is also elusive

2 and that's cost. 

3 MS. ARMSTRONG: We're happy to collect

4 costs from them.

5 MR. MANDYCK: At the consumer level, that

6 seems to also be imperfect. So I don't know if

7 there's a -- that's, you know, a private industry can

8 work together with DOE or to figure out how we

9 develop or get at or access some type of national

10 consumer cost database.

11 MS. ARMSTRONG: Yes. Happy to work with

12 you.

13 PARTICIPANT: Yeah, a lot of the utilities

14 collect cost information in their programs. But

15 their programs increase costs. So it's not clean

16 information.

17 MS. ARMSTRONG: Yeah, I think we've done

18 that. We bought some databases in certain rules with

19 retail price databases and we've done some

20 comparison, but it's also harder, you know, there's

21 the utility things that are going on, or Energy Star,

22 or tax rebates that are going on that kind of do
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1 shifts in the market. But also if you move the

2 standard to a certain level for which there's not --

3 for which volume pricing might significantly change,

4 then it's like how realistic is that comparison. And

5 so we can definitely talk about methods and what we

6 might look at and that kind of stuff. I think we're

7 open to that discussion and it's just we have tried

8 some of that both ways.

9 MR. deLASKI: One thing I would add, you

10 know, I think there are some new firms out there that

11 are doing -- you know, using web crawling technology

12 to gather cost data, you know, whether that ends up

13 being a new source for products that are sold at

14 retail. Now, part of the problem is that for many of

15 the products that particularly the HVAC companies

16 sell, they're sold through dealers and through

17 contractors so identifying retail prices is difficult

18 from public information. Or information readily

19 available without talking to a contractor and even

20 then how do you trust it?

21 Jeremiah, I hope people on the phone can

22 now hear me. And I usually have a pretty good voice,
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1 so I'm surprised they can't. So if you're getting it

2 or not, I wonder whether the microphone may be faulty

3 or something here. 

4 MS. ARMSTRONG: So it has to do with that

5 little thing for the phone. It is not -- the

6 microphone works great for her.

7 MR. deLASKI: I see.

8 MS. ARMSTRONG: But it's that thing that

9 you want to yell at.

10 PARTICIPANT: Can we pull that up a little

11 bit though, the main satellite or whatever?

12 (Simultaneous conversation.) 

13 MR. deLASKI: I'll just try to project

14 towards that little bug, I see, that -- 

15 PARTICIPANT: So it only goes this far?

16 MS. ARMSTRONG: Yeah, just yell at the

17 bug.

18 MR. deLASKI: The other thing I'd note in

19 terms of this field data collection issue, and I

20 thank Tom for putting it on the table, because I know

21 Tom -- in the Northwest there are ongoing efforts to

22 collect data on energy consumption. And as I
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1 understand it he's now got, you know, data collection

2 mechanisms in place in many homes. And my

3 understanding is that there's an emerging effort in

4 California to have a similar study underway that

5 would be longitudinal in nature and capacity, a major

6 investment on the part of the California ratepayers

7 to have that kind of data collection happening. So I

8 think it's an opportunity here to leverage those

9 kinds of research efforts underway, multi-million

10 dollar, multi-year effort to get better field data..

11 MR. ECKMAN: The fact is, I think with the

12 emergence of a smarter grid, we have the ability to

13 collect a lot of information that we thought was

14 really expensive like before, which won't be. And so

15 the new technologies will advantage this process

16 because we can get some insights into individual

17 components in buildings are doing that would

18 otherwise have to have a base sample design and

19 deployment and specific metering to do the work, but

20 maybe that's not necessary now with some of the

21 algorithms like pattern recognition algorithms that

22 people are developing. And it's being able to get
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1 into that space and see who is doing what. LBL is

2 working on some of this through their interval

3 metering and test bed and kind of stuff. And I think

4 there are other places where I'm sure -- I'm

5 absolutely certain Google is working on it. But, you

6 know, maybe there will be data sets that we can

7 access that reduce the burden and cost of getting

8 this information going forward because we have

9 technology that comes in and makes it cheap. And

10 we're hoping so because it's expensive to do this,

11 several million dollars a year to collect 100,000

12 worth of data.

13 MR. deLASKI: Ashley, you mentioned the

14 potential for an RFI. What did you have in mind

15 there?

16 MS. ARMSTRONG: I'm not sure of anything,

17 but if you want feedback from -- I would say our

18 interested parties as a whole about which test

19 procedures and/or -- just which products would

20 benefit the most, maybe, from field use studies, kind

21 of to help prioritize, we could do that. But that's

22 one avenue for getting that such information. But if
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1 we think the committee and/or DOE itself can handle

2 that, that's fine too. We're happy to provide

3 feedback either way.

4 MR. ECKMAN: I think it's good to get an

5 RFI out to see if other parties have different

6 opinions about what they think the more critical ones

7 -- I mean, you have 60 products out there that --

8 some of which are pretty nichey and the individual

9 market settings would say more or less about how well

10 they trust the data or test procedure or duty cycle.

11 MR. deLASKI: Diane?

12 MS. JAKOBS: So I think that's a big part

13 of it, though, that there are assumptions that were

14 made in the past that people disagree with to open up

15 the opportunity for them to provide contradictory or

16 supporting data. You know, things that were

17 controversial. So -- 

18 MR. ECKMAN: Yeah, I think it ought to be

19 open docket to say, I think the number is not right

20 and here's why. I've got data to prove it or I know

21 it was a guess. Everybody had to guess. We were all

22 in a room to guess this number and we didn't have any
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1 information. And that's perfectly fine too. But to

2 determine whether that guess is good enough, or we're

3 resolving with empirical information.

4 MR. deLASKI: This is Andrew. I just

5 wonder a bit if like a broad-based RFI we're going to

6 get the kind of response we're looking for. You

7 know, it's a bit of a fishing expedition. And do you

8 feel that people would -- are you going to get people

9 to spend the time and effort to respond to an RFI

10 that kind of looks like it could be a void. You

11 know, could be no harm in it, I guess I'm just

12 saying, I don't -- I'm concerned that, is it going to

13 drum up the response, you know, who do you want to

14 pay attention to this and how do you get them to

15 engage? Because you have people --

16 MS. KLINE: Just to chime in and answer

17 that if I could. I wonder if we -- I think that part

18 of the issue is, what is the most useful type of

19 information here? And, you know, it probably differs

20 by product, but how do we -- how do we go after or

21 even determine how you get, I think, representative

22 information in some of these categories? It just
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1 strikes me that we might ask a question and if you

2 have any information, but it might be totally off

3 point information. So I'm wondering what that all --

4 you know, how that will kind of get us farther down

5 the path, I guess. 

6 MR. deLASKI: Yeah, that's a good point,

7 Kelley. This is Andrew. And I know, for example, in

8 the case of the work that's been done in the

9 Northwest, there's a lot of dialogue with

10 manufacturers to answer precisely that kind of

11 question. And, you know, to ensure that the

12 information being gathered was in sync with what

13 manufacturers would expect or made sense or how it

14 was being gathered. And if information comes in

15 without that kind of interaction, you may end up with

16 what do you do with it?

17 MR. ECKMAN: My guess is what we've --

18 given regularly the home goes through this process to

19 look for data, I don't anticipate we're going to get

20 much new. We'll get people who've already collected

21 and telling you they've got it and you might already

22 know that. 
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1 Maybe there's information out there, but

2 every rulemaking we go out on a hunt for it and it

3 rarely shows up, which is disappointing, but that's

4 the truth. Maybe RFI does, but I'm not a part of it. 

5 DOE staff and consultants and industry and advocates

6 have a pretty good idea of where things -- have to

7 make professional judgment stretch pretty far.

8 MS. KLINE: It just strikes me too that it

9 might be a good -- a really good, productive

10 discussion that we might be able to structure would

11 be kind of the identification of where we think the

12 gaps would be most important or where there's

13 concerns about gaps in thinking about, you know, is

14 there any way to get at developing a different or

15 more credible set of information to fill those gaps. 

16 Because I think sometimes it's not so hard, the hard

17 piece of it is, you know, there's an issue -- we

18 think there may be an issue there, but we don't

19 really know how to get at making it better. 

20 MS. JAKOBS: This is Diane. For the heat

21 pumps and air conditioning -- residential heat pumps

22 and air conditioning that regulation went into effect
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1 January 1st and we're already participating in

2 manufacturer impact analysis. So maybe it's

3 something that would start, we would do an RFI as the

4 manufacturing impact analysis starts. So you're

5 looking for data from manufacturers, but maybe you're

6 looking for data from other organizations as well in

7 the same timeframe. So it would be more targeted

8 rather than 60 products at one time.

9 MR. ECKMAN: And I'm pretty sure there's a

10 schedule underneath this someplace that looks at some

11 products and doesn't look at others because the time

12 just isn't there. It takes two years to collect the

13 data.

14 MR. deLASKI: Maybe the action item on

15 this one is, you know, for us -- again, just to

16 review, Ashley is going to finalize this document,

17 this set of documents. We'll have time to review

18 them ourselves and take them back to our

19 organizations. And, Tom, I think we would ask you to

20 take the point on thinking about what some of the

21 next steps are. This has been one of your consistent

22 points of interest. You know, without creating a
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1 subgroup, maybe bring it back to the full committee

2 for their consideration what ASRAC's actions are. 

3 And, again, this is perhaps back -- continue with the

4 subgroup concept, you know, the task under Subgroup

5 1. 

6 MR. ECKMAN: I can work with Ashley with

7 what she has on her schedule here and then we can

8 talk about maybe getting information from you, Staff

9 and contractors about what they think are the top

10 priorities and why.

11 MR. deLASKI: And then we can broaden it,

12 as Kelley suggested. I think we need to identify

13 gaps and not just make it wide open and then you have

14 nothing.

15 It will be a bunch of nice-to-have

16 information, but it's not on the critical path to

17 rulemaking. 

18 All right. Anything further on item 5?

19 (No response.)

20 MR. deLASKI: Item 6. So I put this out

21 as -- I think the basic notion that I was trying to

22 drive at is you want to spend your time and effort
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1 where you're going to have the biggest impact; what a

2 concept. And recognizing that the DOE has legal

3 obligations to meet, and then I saw Jennifer's

4 comment, which I think is a good one, I agree with

5 it, that if you're going to do a rulemaking, you

6 don't want it, even if it's small, in terms of energy

7 savings for those manufacturers, you know, it's not

8 small, it's their rule, it's their standard, so they

9 wouldn't want to have any lesser level of rigor, even

10 though the savings may be smaller, they don't want

11 lesser rigor to get to an outcome that's going to be

12 -- you know, beneath the needs of that industry. So

13 I concur with her comment that -- I concur with her

14 comment. I would open it up for

15 further discussion.

16 MS. ARMSTRONG: This is Ashley from DOE. 

17 Perhaps I can just clarify. One point for

18 discussion, so the six-year lookback requires DOE to

19 either issue a notice of proposed rulemaking with the

20 associated analysis supporting amended standards or

21 issue a notice of determination showing that amended

22 standards are not economically justified,
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1 technologically feasible, et cetera, et cetera. So I

2 think, you know, that's something to keep in mind. 

3 And I think that's kind of what Jen is keying up

4 here. You know, our current -- we are trying to meet

5 all of our statutory deadlines. And so that

6 determination is a statutory deadline or a NOPR in

7 that timeframe. So maybe something just to keep in

8 mind as the discussion goes forward, if it does move

9 forward.

10 MR. deLASKI: And we're sort of early into

11 this process to be doing these six-year lookbacks. I

12 don't one's been completed yet. 

13 MS. ARMSTRONG: I don't know. If it

14 hasn't been completed, it's getting ready to be

15 completed. That being said, we haven't gone to

16 determination or it hasn't been ruled to this point. 

17 MR. deLASKI: Right. So, in essence, that

18 provision gives you an offramp of a sort to not do a

19 rulemaking if those criteria aren't met. 

20 MS. MILLER: That would have to be --

21 honestly, it would have to be pretty significant

22 considering the department has never done one before
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1 moving for an alternative.

2 MR. deLASKI: The off ramp hasn't -- my

3 point is that the off ramp hasn't been there for very

4 long. It's only been there since 2007. And the

5 lookback provision only has been implemented by the

6 Agency on a -- they're implementing it now across the

7 board. But we haven't had that many opportunities --

8 MS. MILLER: To use that?

9 MR. deLASKI: -- to consider using it even

10 yet. I think maybe about a handful. And in those

11 cases was pretty clear cut, I think, that there was

12 significant additional savings beyond what was

13 currently the standard, but we're going to see that

14 be implemented soon here. 

15 (Pause.) 

16 MR. CASKEY: This is John Caskey. So in

17 light of, you know, what Ashley just said, you know,

18 at first I was leaning towards, you know, you're

19 right, this isn't realistic for us to get in the

20 middle of, not a real bang-for-the-buck issue, but it

21 seems like we could at least talk about it and come

22 up with is there some threshold where if the total
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1 savings, total projected energy savings from a

2 particular product is going to be less than some

3 threshold is just not worth pursuing and to get it

4 all -- you know, and it may be only a 60-item list,

5 but maybe we can pare down that 60-item list.

6 MS. ARMSTRONG: Well, I don't think

7 consideration of a threshold is the right idea. 

8 Perhaps, though, maybe the collectively

9 considerations that the Department should consider

10 when it's trying to make a decision about

11 determination versus proposed standards. We shy away

12 from thresholds in terms of, you know, what a saving

13 -- you know, significant amount of energy savings may

14 be. And we've done very -- rulemakings are very

15 small. We've had rulemakings with very big impact

16 and off the board. So, I'm not so sure that folks

17 back at DOE collectively would be overly excited

18 about some type of threshold analysis. But I do see

19 some room for maybe some things that DOE should

20 consider in helping informing its decisionmaking

21 processing, maybe, if you want to go down this

22 pathway. It might be worthwhile for me to have -- we
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1 haven't really explored this very much within DOE

2 just because we haven't really had to use it yet. 

3 But it may be worthwhile me having a conversation

4 with the legal department to see, you know, what our

5 current thinking might be and then regroup on this

6 one in a bit. If that seems reasonable to you all.

7 MR. deLASKI: Well, I think any

8 department's guidance on what you're open to getting

9 guidance on would be helpful. So we spin our wheels

10 and waste our time.

11 I also want to raise a concern. You know,

12 I think if we could wave our wand and develop a

13 threshold that would be cool. I think us -- you

14 know, it would be very hard. That's a hard

15 discussion. 

16 I think what might be acceptable to some

17 may not be acceptable to others. And then you get

18 into a lot of tough issues around that. The statue

19 uses somewhat ambiguous language because that's how

20 statutes are written, to get compromise, to get

21 outcomes, to get enacted.

22 (Laughter.) 
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1 (Simultaneous conversation.) 

2 PARTICIPANT: But a number of products are

3 getting closer and closer to -- 

4 MR. deLASKI: Yeah, I don't dispute it. 

5 And also your point about AFUE not fully capturing

6 the consumption because 99 is not getting the story

7 right. So, you know, this all -- it kind of brings

8 it back to the discussion once again.

9 MS. ARMSTRONG: If we know what our

10 priority is, perhaps we should -- I mean, so let me

11 have this discussion and it can be on the radar

12 screen as kind of a placeholder for us going forward. 

13 But I think we kind of have to have that conversation

14 here first before we do a lot of work. And clearly

15 there are some very important things on this list

16 that could deserve a lot of love and attention now.

17 (Pause.) 

18 MR. deLASKI: So let's -- we had a few

19 items at the beginning of the day today, items 7 and

20 8. Item 7 that I captured this morning was Jen's

21 point, how to address test procedure changes that

22 impact measured energy consumption. In particular if
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1 you're working outside of a -- you're outside the

2 timeframe of a standards amendment, and it raises

3 tricky issues around backsliding and tricky issues

4 around -- that relate to programs that use the same

5 test method, and to Diane's point about if you start

6 changing the metric and then what qualifies for

7 Energy Star now doesn't qualify, or do you have to

8 true up Energy Star, and then there's this rippling

9 effect of -- once you change a test method, there's

10 just sort of a whole cascading effects that affect

11 programs, manufacturers and market, and is there a

12 way to manage those in a way that actually lets you

13 change a test method when we know a change is needed.

14 Is that a good summary of it, Jen, or

15 would you add something?

16 MS. CLEARY: No, it was a great summary. 

17 I think the only thing I guess that I would add is,

18 that we have -- together with Andrew we have talked

19 to DOE about this a little bit and so I don't know

20 since I'm just bringing it up now, you know, I'm sure

21 there hasn't been the opportunity to discuss how DOE

22 might respond to this in the ASRAC context, but this
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1 may be another one where we end up wanting to have

2 counsel give us a view, you know, I guess I would

3 see, if we decided to pursue this, that it would be

4 useful to have a discussion where DOE would present

5 to us their view and their interpretation of the

6 statute and how they perceived when they make a test

7 procedure change that impacts measured energy outside

8 of that standard rulemaking context. Because, you

9 know, I know I talked a little bit with Dan Cohen

10 about that and it was informative. But I think if we

11 do pursue this, that would be a useful starting

12 point.

13 MR. deLASKI: Questions from the committee

14 for Jen or for other clarification of the topic or

15 comment?

16 (No response.) 

17 MR. deLASKI: Reaction from Ashley?

18 (Laughter.) 

19 MS. ARMSTRONG: I'd be happy to go talk to

20 my counsel about this one and get back to ASRAC. I

21 don't -- while I'm pretty sure I know what they're

22 going to tell me, I don't think I'm ready to
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1 articulate that quite yet to the committee as a

2 whole. I know one answer is going to be DOE does not

3 backslide ever that will come out of Dan's mouth. 

4 But let me talk to Dan and perhaps table this one to

5 report back. It's just a general understanding of

6 kind of how we make that determination on a

7 rule-by-rule basis. And I think it gets at some of

8 the considerations I highlighted earlier about why

9 we're doing a past procedure rulemaking, why we're

10 doing more clarification rules, and I think, number

11 one, will help inform some of those, but I'll

12 definitely touch base with counsel and get back to

13 you guys.

14 MR. deLASKI: You can maybe bring Dan to

15 the next meeting and have him explain himself.

16 MS. ARMSTRONG: I will suggest that.

17 MR. deLASKI: All right. So that's the

18 action item on that one.

19 Item 8 that I wrote down this morning is

20 -- this was the one that, Ashley, you put on the

21 agenda.

22 MS. ARMSTRONG: Yeah.
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1 MR. deLASKI: And, John, you began to

2 respond to. But the need for better data flow

3 through trust and sharing of information so that we

4 can inform rulemakings, basically data, information

5 that manufactures have, cost data that you just

6 raised, but also sales volume, shipments data. In

7 many cases it's essential to a good analysis is

8 property of manufacturers and finding ways for

9 manufacturers to share that property with the agency

10 in a timely way I think will -- has often worked well

11 in the past, it's broken down sometimes recently. 

12 And I guess the question is, what can we do to

13 identify why it's broken down and how it can be

14 repaired because I think it's in all of our interests

15 to have it work better.

16 What the ASRAC task is on this, what would

17 be helpful?

18 MS. ARMSTRONG: From DOE's perspective, I

19 think it's a better understanding of the concerns and

20 then potential solutions for those concerns to help

21 facilitate whether ASRAC can help promote that idea

22 to help facilitate a better information sharing and
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1 overall collaborative process. I'm not sure of the

2 best way to get there and obviously I think

3 negotiated rules are a great tool in our toolkit to

4 help with that. But just in more traditional ruling

5 things, I do think there's a lot of information that

6 sharing and opportunities that could happen that

7 perhaps on both sides aren't fully taken advantage

8 of.

9 MR. MANDYCK: This is John Mandyck. So I

10 think it's definitely an issue and I think, just

11 quickly responding, and I can't speak for all of

12 industry, obviously, but through conversations that

13 I'm familiar with, I think there are a couple buckets

14 of concern. One is, DOE through contractors, is

15 always asking us through whatever rulemaking, to

16 know, exactly our cost, exactly our margin down to

17 the screw in the furnace. And those are the crown

18 jewels for any manufacturer, and we simply don't

19 trust anybody with that data. So it is not coming

20 out. 

21 And it's not that -- it's just a breakdown

22 in the computer somewhere and the data gets out and
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1 you're on business. I mean, it's very, very

2 difficult. So there's that set. And, you know, we

3 do our best to provide ranges, to give indications,

4 you know, we definitely want to help because we want

5 the models to be accurate and timely. There are

6 limitations to that. There's that concern.

7 The other concern frankly is, in not all

8 rulemakings, but people kind of drift to the extreme

9 in rulemaking where the industry has felt like it's

10 been complied or has complied with a request to

11 provide data that data has been ignored and DOE

12 pushes its standards to areas not justified by the

13 data industry as provided. So then there's a point

14 of saying, okay, well, why did I spend all of that

15 time collecting all that data and turning it in when

16 the whole exercise was to justify Maxtech or

17 something else.

18 So I think there are some trust issues

19 related to that where, you know, I think the industry

20 is at the point of saying, well, let's -- it doesn't

21 matter what data we provide, the outcome is

22 predetermined, so let's just not provide data. 
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1 MR. CASKEY: This is John Caskey. But

2 certainly I think I agree with some of the things I

3 hear, but in addition to that, it seems like when we

4 were working on the transformer stuff, it's not like

5 it's involved in other parties, that the

6 manufacturers know like their costs and whether they

7 divulge it or not, it's still part of their costs. 

8 But in the next question, we're dealing with

9 installation costs and dealing with how it's

10 installed and is it installed properly? Are they

11 truly going to reap the benefits? Is DOE inspecting

12 and things like that? Instead of limiting this to

13 just manufacturers, I mean, should it be -- should

14 there be like the engineering community, the

15 consulting and contracting community, the

16 installation community or dealers or other people

17 involved with the process to make sure that we're

18 getting the best cost assumption, materials

19 assumption and other things out there? 

20 MR. deLASKI: Kelley or Jen, anything to

21 add to this one?

22 MS. KLINE: No, I don't think so, not
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1 right now. This is Kelley.

2 MR. deLASKI: So the trust issue that John

3 raises, it's hard for me to solve that problem. You

4 know, if you don't think your data is going to be

5 used, then I understand, why would you take the time

6 to submit it, it's like me, I understand that it's

7 not like it's free to collect this data, it takes

8 time, it takes some of your best people, like in

9 commercial HVAC. It's costly to be able to collect

10 it. Spending time with consultants is significant

11 person-days. 

12 You know, it strikes me that -- 

13 MS. KLINE: Andrew, this is Kelley, I do

14 have more now that you're talking through this. So,

15 I didn't mean to interrupt.

16 MR. deLASKI: Please. Please go ahead.

17 MS. KLINE: Well, you know, I'm just

18 thinking about some of our experiences in recent data

19 gathering efforts. And I think one of the struggles

20 we've had and some of the -- and some kind of do

21 circle back to some of the test procedures and other

22 issues that we talked about a little bit earlier. 
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1 But we've struggled with some of the data collection

2 where some were requested, you know, put on levels

3 which for instance were particular technology options

4 when we looked at them just really don't line up with

5 kind of how we would have or data we would have in

6 those lanes because that's not how we would think

7 about designing the product or necessarily would be

8 reflective of, you know where we think the baseline

9 of the product would be or how to get there. So at

10 times we've had kind of more fundamental disconnects

11 that have really hamstrung our efforts on the data

12 collection, which I think is a little more kind of

13 fundamental issue and does kind of go back to some of

14 the test procedure things. 

15 So sometimes it's not just that we don't

16 want to; it's that we really are struggling with how

17 to get at it. 

18 MR. deLASKI: And I have heard that point

19 before too, Kelley. And as someone in this room who

20 is not a manufacturer and who has never had to fill

21 out one of these data requests, I don't have that

22 sort of window into that experience. But what I have
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1 had some experience is in some of the areas where

2 we've been involved in negotiations early on to have

3 an opportunity to contribute toward the data requests

4 and how the data request is developed. And I know

5 it's a question for industry and for DOE which is, is

6 there typically some iterative process where sort of

7 the survey form or the survey tool is developed,

8 shared, back to the survey tool, to then -- or is it

9 just, here it is, it's the consultants who develop

10 it, and there are supervisors who review it, then

11 industry says, well, you asked the wrong question. 

12 Now I have to answer the wrong question. And I'm

13 still going to answer the wrong question because

14 there is no one who is giving me a chance to suggest

15 to you what the right question might have been. I

16 don't know how it's typically done, if there is any

17 sort of interaction, an iterative process, or is

18 there one offer.

19 MR. MANDYCK: This is John Mandyck. My

20 experience with them is they are full day on-site

21 interviews. So the consultant team comes to your

22 office, comes to your factory, sits down with you,
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1 starts going through the questionnaire, which is

2 provided in advance, and it's a discussion. So,

3 yeah, we -- in some cases we told the consultants,

4 you're asking the wrong question or you're phrasing

5 it the wrong way, or you're looking for the wrong

6 data. So it's a discussion that we provide. But we

7 don't know what happens to the data after we give it

8 to the consultant. That's the way it's done. 

9 I think on the flip side, as Ashley had

10 noted, you know, I think the more that we're doing

11 the negotiated rulemakings the better that we're

12 seeing the data being used and it's better that we're

13 using the right data that has been collected. So I

14 mean, I think we're moving in a positive direction. 

15 I wouldn't want to leave the meeting or the record

16 thinking we're not moving in a positive direction

17 because we are.

18 But the circumstances I was talking about

19 before are ones that are in people's memory from

20 recent rulemakings or ones in the past that are

21 issues to be cognizant of and to try to address. 

22 MS. JAKOBS: This is Diane. And I have
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1 been on a bunch of those interviews, too. Recently

2 they have come back and asked more questions and

3 we've talked with the engineers and they said coils

4 it's this much square feet as like they made

5 assumptions based on that. But we said, oh, that

6 area is too large for a single rope coil, you have to

7 have a double rope coil, that means you need more

8 manifold egg, so it would be more expensive,

9 blah-blah-blah. So we're trying to -- they gave us a

10 list of numbers that we looked through like the

11 flyers, you know, and what maybe were wrong

12 assumptions. But there's -- I mean, at different

13 companies, I just know that when we've had someone

14 come from one company to our company there's like the

15 Rheem way to do things and I'm sure there's the

16 Carrier way to do things, and we don't do them all

17 the same. And -- 

18 MR. deLASKI: So what John thinks is the

19 right question, you might think it's the right

20 question but a different question? 

21 MS. JAKOBS: We would mainly have no idea

22 what you were talking about. So it's not easy at
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1 all.

2 MS. ARMSTRONG: You just explained why DOE

3 has a really hard time in certain instances. What

4 we're trying to do is create an industry-aggregated

5 curves, to the extent that means something. You

6 know, everyone does things different ways and we're

7 not just pulling the information out of thin air. I

8 mean, we are buying, testing, tearing down equipment. 

9 And I used to visibly do it in my prior life. I've

10 been to many of your facilities. 

11 With that being said, you know, I think

12 there is data that you guys have access to that may

13 not be as sensitive that could be very valuable. 

14 There is earlier conversations that could be had and

15 we could be engaged with whether it's asking the

16 right questions or just having a better understanding

17 of what's coming down the pike. You know, when DOE

18 does go on these interviews, the collective DOE, goes

19 on these interviews, we are willing to share the data

20 we have, whether right, wrong or indifferent, about

21 your companies and their products. Obviously we're

22 not going to cross-share that information, that's
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1 something that we just won't do. But at the same

2 time, I think we have had some success with sharing

3 information that's specific to your products and

4 getting that feedback loop. And so I think that, to

5 the extent that those avenues stay open, I think it's

6 very helpful to the Department. I understand that it

7 takes a lot of resources, but it takes a lot of

8 resources also if you get to a proposed rule or a

9 finer rule for which you don't like the outcome and

10 we're stepping back from that one way or the other. 

11 So I don't know, it just depends, do you frontend the

12 resources or do you backend the resources. And I

13 think it's better to frontend them for a variety of

14 different reasons which may get to a negotiated rule

15 quicker. 

16 MR. deLASKI: So I don't hear a hesitance

17 to the time. What I heard was a hesitance to the

18 time if it wasn't going to get used. And I think

19 that was the frustration that Tom was voicing.

20 MS. KLINE: I wonder, just throwing an

21 idea out here too because I heard John reference kind

22 of the old egg, you know, the interview and the egg
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1 and that's been our experience as well. But I wonder

2 if one idea might be for a work group to kind of get

3 some feedback on the standard interview process or do

4 the thinking around that and think about how we might

5 be able to, you know, get at a more -- you know,

6 whether it's asking questions a different way or more

7 targeted. And I just know from our experience,

8 there's some we perennially struggle with and it

9 might be -- that might be one way to kind of get some

10 feedback on just that first step of the approach. 

11 That's just a thought.

12 MR. deLASKI: That sounds quite -- if I

13 was DOE, that would sound very appealing to me, the

14 notion of getting a bunch of manufacturers who have

15 been through the process numerous times in the room

16 with you and your contractors to provide lessons

17 learned, here's what's worked, here's one that's

18 really painful, and, you know, I don't think it's

19 ever going to be a little fun, but you can make it

20 less painful, you know, feel like you're getting

21 heard, then I think that would be a great. I don't

22 know what the timing is, but -- 
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1 MS. ARMSTRONG: I think that's more of a

2 question of willingness. I think DOE is open to

3 that. Maybe the manufacturers that are on the

4 committee could think about whether they think that

5 is a worthwhile effort. 

6 MS. KLINE: I would think it would be. I

7 mean, just speaking for GE here, but I think that

8 would certainly be something we would support and I

9 would think others would be interested as well.

10 MS. JAKOBS: So from my point of view, I

11 just facilitated one of these, and this idea of a big

12 event where people have to be in the room on one day,

13 I mean, that -- it's a struggle. And the people who

14 aren't being discussed, their area is not being

15 discussed, they don't want to be there. They don't

16 want to sit through somebody else's stuff.

17 (Simultaneous conversation.) 

18 MS. JAKOBS: Other than teleconferences, I

19 mean, we're generally sitting in a big -- 

20 MS. ARMSTRONG: Sure.

21 MS. JAKOBS: -- room with coffee. You

22 know, there's no reason people have to fly, you know,
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1 unless they're going to visit the factory. And even

2 now our engineers aren't necessarily at the same

3 location where the production line is. We could do

4 better than this one face-to-face meeting where you

5 have to say everything you need to say, you know.

6 MS. ARMSTRONG: Right. I think that would

7 be great.

8 MS. KLINE: Just throwing out another

9 thought here because I think that's a good comment. 

10 What it made me think of is and this may be unique to

11 our company, but we have very -- we have our experts

12 in each product line engaged in each of the

13 discussions, but there's usually a common thread who

14 cuts across all the discussions and that would be,

15 you know, me for us, but there would be others for

16 other companies. And I think that's -- to me that's

17 what we want to get at, kind of the common thread

18 type of issue that companies see. And whether it's

19 kind of trying to identify those right people, and so

20 we're not trying to target our huge group here, or

21 whether it may even be engaging the trade

22 associations so that they can work with their members
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1 to kind of, you know, target a list of questions, get

2 feedback on those particular questions and then maybe

3 trying to narrow the group a little bit. That

4 strikes me as maybe being -- getting us farther down

5 the path to some useful inputs here.

6 MR. deLASKI: That makes sense to me as

7 well, Kelley. I like that. There are people like

8 yourself, or like Diane who may be able to pool a

9 common thread together from their companies without

10 getting into the weeds in any particular -- and, of

11 course, the trade associations as well, so you don't

12 get into the weeds of, you know, you don't get

13 involved with one product once, that was the first

14 time ever at a standard, you know, that might take

15 you to the weeds on that product. 

16 MR. McCABE: I'd like to endorse John

17 Caskey's comment that because for some products,

18 probably as much as half of the costs of the

19 consumers are costs that are outside of the

20 manufacturer. Recognize distributor markup, dealer

21 markup, installation costs. Focusing just on the

22 manufacturer costs on these products, we may be
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1 missing an awful lot in the process policy and then

2 you harm the consumer.

3 MR. deLASKI: Other thoughts on this

4 data-sharing issue? We've got a couple of action

5 items coming out of this. I think for the

6 manufacturers to think about -- perhaps to think

7 about webinars or teleconferences or maybe even what

8 makes the most sense to provide DOE feedback in

9 general that data-gathering process. 

10 And we've been mostly talking about the

11 manufacturer costs, data, or engineering decisions. 

12 But also the other issues around shipment data, which

13 is typically gathered through the trade associations

14 by shares -- not provided because I'm curious whether

15 -- 

16 Were you raising your hand or were you

17 just typing with flourish?

18 MS. ARMSTRONG: I'm just typing my to-do

19 list.

20 MR. deLASKI: On the shipment side of

21 things is that data generally being shared these days

22 or is that an area where there's been -- where
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1 there's tensions that would be helpful for us to talk

2 about. 

3 MR. HON: This is Charlie Hon. There's a

4 couple different things. Not everybody and when that

5 happens, those pieces are going to fall apart. 

6 That's what is in our industry. So you can talk

7 about the trade association giving their permission,

8 but until some of the majors who are not --are

9 willing to give up information and unfortunately a

10 lot of the majors that are not are companies. 

11 They're very protective of data. 

12 MR. deLASKI: So how does DOE handle it? 

13 You don't? Any ideas? A manufacturer could provide

14 it under NDA but you're suggesting that there to do

15 so that they'll have to.

16 MR. HON: In today's society, everybody is

17 worried about that.

18 MR. deLASKI: Yeah. The trade

19 associations they have their rules that protect.

20 MR. HON: Trade associations are still not

21 immune to acting.

22 MS. ARMSTRONG: Well, may I suggest that
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1 this is one that we all think about. Maybe not right

2 for action yet, but, you know, I think we've got a

3 way to do it now, I need to do our estimates, we put

4 them out for an open comment. People do comment on

5 them regularly, some of them have a lot of hard data

6 behind them, some of them have more partial sets of

7 data that have been aggregated behind them. We do,

8 do our best with what's available and we do put it

9 out for comment. So -- 

10 MR. deLASKI: Right. And in my experience

11 I've seen plenty of shipment numbers, change from the

12 PPSP to the proposals and often by pretty significant

13 margins.

14 MS. ARMSTRONG: I think it's fair to say a

15 lot of things change between the to the rulemakings.

16 MR. deLASKI: In response to the input

17 that's being received as the process rolls forward.

18 MS. ARMSTRONG: Absolutely. Which is a

19 good thing. 

20 MR. ECKMAN: This is Tom Eckman. I would

21 just note that in the rulemakings where we've --

22 before they've been negotiated rulemakings, I think
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1 that there are actually other parties with a better

2 data set than the standard rulemaking time to go back

3 to clarify, no, that's not what I meant. I know you

4 think I said that, but I didn't. This column is over

5 here. And I think that was particularly in the we

6 got a lot of -- in that phase of development the

7 manufacturers and trade associations before us.

8 MR. MANDYCK: Maybe just a final comment

9 on that. This is John Mandyck. I also wouldn't want

10 to miss the opportunity to say there's the

11 opportunity to be transparent on both sides. Because

12 while DOE may be frustrated that manufacturers may be

13 perhaps not as transparent as I wished they would be

14 with data, manufacturers are the same as with DOE

15 analysis that comes out when very complicated and

16 sophisticated that are locked down and you can't

17 understand the basis for which assumptions are made,

18 et cetera, et cetera, et cetera. So I think there's

19 plenty for both sides to think about.

20 MS. ARMSTRONG: I could respond, I'll

21 refrain.

22 (Laughter.) 
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1 MR. deLASKI: But it does strike me that

2 there's this issue -- I thank you for bringing that

3 other side to it out there on the table discussed

4 elsewhere. And I think it's continuing friction and

5 to the degree that we can think about methods to

6 reduce these friction points that will help the

7 program do the job to the Department.

8 You know, I don't know what the central

9 task is -- some time today to identify more

10 specifically. We need to be specific in identifying

11 the example then we can talk about it. But as an

12 assertion, right, wouldn't get me very far because I

13 am probably -- put it back on you and others on this

14 table to describe, you know, where is it that you're

15 not seeing the transparency? Example of transparency

16 and where you want to see transparency. Because, you

17 know, I think we all like transparency. I like

18 transparency. So how do we define where it's lacking

19 specifically so we can address it?

20 MS. JAKOBS: Are you asking that?

21 MS. ARMSTRONG: Can we think about it? 

22 Can that be our homework?
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1 MR. deLASKI: I put the homework on the

2 team to think about, you know, what -- how would you

3 define it? How would you be more specific about what

4 you want to see?

5 As an assertion, sure, we all want better

6 transaparency. Absolutely.

7 MS. JAKOBS: Can I just say on the

8 equipment life and then the life of the savings and,

9 I mean, the horizon keeps moving on and on and the

10 amount of energy that you're saving on these tiny

11 changes sometimes is for the commercial furnace. So

12 they're thinking about 2 percent in thermal

13 efficiency and it's so big where to me, I mean, a lot

14 of the commercial gas furnaces don't really run that

15 much because they're all in buildings that generate

16 their own heating bills. Some of those types of

17 assumptions and they're not -- they're more

18 economical to me. I don't really -- it's not the

19 manufacturer beyond and I don't even know how you

20 come up with these long lives when we're just only

21 been building these certain technologies for five

22 years or something. They haven't been out on the
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1 market -- to me the lifetime center in some of the

2 NOPRs is kind of mysterious.

3 And as much as I can in those

4 spreadsheets, I can change that number and it seems

5 like it makes a way big difference. 

6 MR. deLASKI: I guess I don't want to get

7 too bogged down in any lifetime because it strikes me

8 initiatives.

9 I know what the ASHRAC has to be, because

10 again but I don't see us as sort of specific

11 rulemaking.

12 MS. JAKOBS: No.

13 MR. deLASKI: Publishes the source.

14 MS. JAKOBS: And it is another area like

15 you know, you come out in a big way and say, oh, no,

16 it won't last 30 years, it will only last 20 years. 

17 That's not likely going to happen. Someone will

18 pushback on that.

19 MR. deLASKI: Yeah, to me this is one of

20 these examples -- if someone's got data that. 

21 Otherwise the Department has the data they have. And

22 usually if you got the sales, you got the stock, you
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1 know the growth of housing, you got the lifetime.

2 MS. JAKOBS: I think that's one area it

3 was kind of mysterious for there was a paper that Jim

4 Lusk did. 

5 MS. ARMSTRONG: Forgive me for that one. 

6 The working group to discuss all of that. So that

7 can all be teed up for that working group. But, no,

8 I mean, it's for -- we try to be as transparent as

9 possible. I'd like to say that we're way more

10 transparent than we ever have been to the extent

11 that, you know, there's a couple reasons why we. I

12 think it depends on what you're talking about, but I

13 think 99.9 percent of the ones that I can think of

14 right now are not hidden, everything is in there. So

15 it's not an issue of hiding or transparency. It's an

16 issue of model functionality. And we believe that

17 that model should function the way that it was

18 intended to be functioning by the Department. To the

19 extent you want to create a different model with

20 different functionalities, you can. So, you know,

21 with that in mind, I think we table this one and

22 start wrapping up because we are almost at our thing
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1 and I can see people kind of packing up. So it would

2 be good to at least figure out where we're going,

3 including myself. 

4 MR. deLASKI: Well, let's do that. I

5 think it is important that we talk about our next

6 steps. We're down to our last 20 minutes or so here

7 and I do want to schedule our next meeting and

8 perhaps our next two meetings. So let's talk about

9 -- the group's thoughts on how to do the work going

10 forward. We've talked about creating a couple of

11 subcommittees. So I guess let me open it up to the

12 group for thoughts on how to do the work going

13 forward.

14 MS. JAKOBS: Are you asking for volunteers

15 now?

16 MR. deLASKI: Well, I guess the question

17 that we have, are we going to -- I started this

18 morning with the concept that we form perhaps a

19 couple of subgroups to tackle a couple of different

20 issues. Is that where we're ending up today? Or are

21 we ending up with, did you want just one subgroup

22 suggested earlier a few items have been identified to
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1 a couple of things identified, one to Tom and one to

2 put off to Ashley for further and also to the

3 manufacturers in general on further investigation.

4 PARTICIPANT: And the other one is. 

5 MR. deLASKI: Yeah.

6 Right. 

7 So let me just open it. Are there

8 volunteers who have heard particular tasks that have

9 been gestating in your minds today that you'd like to

10 volunteer on to advance before our next meeting?

11 John?

12 MR. CASKEY: This is John Caskey. I mean,

13 if there is interest from other members I would be

14 happy to do something on the system at least to scope

15 it out and see where we can go with that if there is

16 a path to move forward or whether just over a dead

17 issue. I would certainly be happy to work.

18 MR. deLASKI: Who wants to join John in

19 that subgroup?

20 David, are you volunteering?

21 MS. MILLER: I can do that. I volunteer

22 for everything. 
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1 (Laughter.) 

2 MR. deLASKI: Well, I think having the two

3 of you guys work on that to advance it before our

4 next discussion to sort of see is there, you know, as

5 you suggested define the project and what are the

6 four or five steps or whatever, three steps that

7 might need to be taken to advance it before our next

8 meeting would be fantastic. 

9 MR. CASKEY: Okay. 

10 And Diane will join you.

11 David as well. So David, Diane, and John.

12 Okay. Are there other things that people

13 heard today that they wanted to step up and volunteer

14 to take the lead on?

15 MS. CLEARY: This is Jen. I think the

16 test procedure issues that we talked about kept

17 coming back to that and adding to it. But I think

18 that maybe the first step there is for us to identify

19 some concrete areas for discussion that might be able

20 to be divided into a subgroup. So under -- I would

21 like to volunteer if maybe someone else wants to work

22 with me to figure out how that can be broken down and
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1 then maybe identify some specific needs and then

2 maybe we could at our next meeting talk about that

3 and get some volunteers for each of those groups.

4 MR. deLASKI: So that makes sense. So

5 what I'm hearing you say is that the things that we

6 kept lumping into number one need to be advanced and

7 that you're volunteering to be part of a subgroup

8 that would work with this to better take the notes

9 from today, the transcript, your own independent

10 thoughts and develop a more specific next steps?

11 MS. CLEARY: Yes, that's what I'm

12 suggesting.

13 MR. deLASKI: Who would join Jen in this

14 group?

15 MR. ECKMAN: I will be working on that

16 anyway, so -- 

17 MR. deLASKI: Essentially tackling the one

18 in five combined along with what we put in there with

19 respect to coordinating with test methods developed

20 by trade associations and professional organizations.

21 Charlie Hon agreed joining you in that

22 group. 
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1 MS. KLINE: And Kelley Kline, too.

2 MR. deLASKI: Kelley and Diane and Tom,

3 Tom Eckman.

4 So just checking off our list here, that

5 checks off items one, two, -- 

6 MS. ARMSTRONG: Three and five.

7 MR. deLASKI: -- part of three, three and

8 five. I didn't decide that four was -- that we're

9 not going to pursue.

10 MS. ARMSTRONG: Right.

11 MR. deLASKI: And we decided that item six

12 -- 

13 MS. ARMSTRONG: Six and seven are with me.

14 MR. deLASKI: -- are on Ashley to consult

15 with her counsel and then eight also was something

16 for Ashley and the manufacturers to think about in

17 terms of is there some process there that would

18 enable a better understanding an improved

19 manufacturing process and data sharing. So eight was

20 also with Ashley and also individual manufacturers

21 from the trade groups.

22 (Simultaneous conversation.)
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1 (Laughter.)

2 MR. deLASKI: Let's look at our calendars. 

3 How much -- what kind of timeframe would make sense

4 until our next meeting? 

5 MR. MANDYCK: This is John Mandyck. When

6 do we have working group reports required back to us?

7 MS. ARMSTRONG: Yeah, mid-June. 

8 MR. deLASKI: June 15th is the deadline

9 that we set for the commercial -- 

10 MS. JAKOBS: So sometime after that,

11 please. 

12 MR. deLASKI: Webinar -- 

13 MS. JAKOBS: Oh, okay. Okay. 

14 MS. ARMSTRONG: Conceivably that week

15 would be good so go ahead and pass it to DOE.

16 MR. deLASKI: So you are the person to

17 handle that. Fine, you do that. That will give us

18 enough time to advance this work? That's only a

19 month and a half? Does that seem reasonable to you,

20 Jen and Kelley, a month and a half from now to meet

21 again?

22 MS. CLEARY: Fine with me.
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1 MS. KLINE: Me too.

2 MR. deLASKI: So the week of June 15?

3 MS. ARMSTRONG: The 15th is a Monday, the

4 16th is a Tuesday, the 17th is a Wednesday. 

5 MS. JAKOBS: The 16th, 17th, or 18th

6 works.

7 MS. ARMSTRONG: Okay. Can you call in?

8 MR. MANDYCK: I don't know that yet.

9 MS. ARMSTRONG: Okay. 

10 MR. ECKMAN: The 18th would be much better

11 for me.

12 MS. ARMSTRONG: The 18th does work better

13 for you? Does the 18th work for everyone else?

14 PARTICIPANT: No, that's the one day I 

15 can't -- 

16 MS. ARMSTRONG: Okay. 

17 MR. deLASKI: The 18th or 19th works. 

18 Well, we can do the 19th, but finish up early enough

19 that you can fly out. 

20 (Simultaneous conversation.) 

21 (Laughter.)

22 MR. deLASKI: Was there an objection to
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1 the 17th?

2 MR. ECKMAN: I could make the 17th, but

3 I'd have to --

4 MS. ARMSTRONG: Can you call in?

5 MR. ECKMAN: I can. I can do that.

6 MR. deLASKI: Is that better, to call in

7 on the 17th?

8 MS. ARMSTRONG: The 17th, it is.

9 MS. JAKOBS: Is there too many people

10 calling in? Could we all just call in?

11 MS. ARMSTRONG: You can call in?

12 MS. JAKOBS: When we get closer?

13 (Simultaneous conversation.) 

14 MS. ARMSTRONG: You will never be the only

15 one here. 

16 (Laughter.) 

17 MR. deLASKI: We had the discussion at our

18 last meeting that, you know, we had done a number of

19 meetings. I didn't make a lot of progress. We had a

20 couple people on the phone today. You know, I think

21 that the problem -- 

22 MR. deLASKI: I thought we were zeroing in
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1 on the 17th?

2 MS. ARMSTRONG: Can we go off the record

3 for this?

4 (Whereupon, at 2:38 p.m., the meeting was

5 adjourned.)

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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A

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32:13

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117:13 173:16

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3:14 5:11 13:15

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20:6,21 21:3,13

22:7,9 24:15,19

26:22 28:10 33:12

33:14 34:14 35:10
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35:14 57:20 58:1

62:17 64:15 66:7

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100:21

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bring 27:4 34:6

36:7 74:5 81:2

137:1 146:14

bringing 27:13

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166:2

brings 34:7 143:7

brining 49:3

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cascade 87:9

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case 61:14 113:13

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140:16,16 150:1,1

171:12,12 172:9

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categories 63:22

73:9 133:22

category 74:17 75:8

86:16 87:1

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causal 50:5

caveat 58:5 124:5

CEC 83:22

center 168:1

central 166:8

certain 15:16 39:2

60:10 61:17 75:8

81:15 83:16 85:8

85:9,10 108:14

110:22 112:10

120:9 124:14

127:18 128:2

131:5 156:3

167:21

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30:21 43:9 44:11

44:13 46:21 48:14

48:21 63:5 120:11

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certification 26:13

83:18

certify 83:20

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165:18,18,18

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chair 111:17,19

113:17

challenge 28:17

38:3 43:15 60:15

72:12,16

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challenges 46:1

challenging 45:21

chance 68:11 124:8

153:14

change 14:17 31:21

45:8,9 55:6,7 59:3

59:20 61:18,21

65:13,14 66:18

97:8,9 100:17

106:13 119:15

128:3 144:9,13,13

145:7 164:11,15

168:4

change-out 73:1

changed 60:6 67:9

106:19 120:22

122:20

changes 12:5 14:13

19:9,10 20:10

31:17,21 32:1,6

34:16 46:6 65:9

67:12 84:8 99:5

143:21 167:11

changing 55:17

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characterization

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charter 22:22 92:22

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child 6:18

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choose 39:3 89:16

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circumstances

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cited 46:9

clarification 61:19

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clarify 138:17 165:3

clarity 62:9

class 79:10

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clear 19:20 53:19

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clearest 32:3

clearly 107:13,22

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co-chairs 5:11

cochair 5:15

codes 87:12

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cognizant 92:18

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coil 155:6,7

coils 155:3

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collapsed 42:8

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inputs 161:5

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17:2 31:3,13 35:7

35:7 38:16 42:15

42:16,17 68:19

99:16 102:6,7

103:6,8 114:18,22

115:6,11,12

118:14 123:21

124:1 136:14

137:18,20 143:20

146:18,19 174:11

items 8:14 30:15

31:6,11 42:5

57:10 114:13

143:19,19 162:5

170:22 174:5

iteration 94:5 105:6

108:18 109:16

113:12

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J

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14:7,7 17:4,8

25:18,18 26:8,10

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65:11 78:10 94:16

94:16 95:5 99:20

106:2 117:22,22

132:12 135:20

154:22 155:21

159:10,18,21

166:20 167:7

168:12,14 169:2

170:14 175:10,13

176:5 177:9,12

January 136:1

Jen 6:17,18 31:4

34:17 43:1 47:8

49:3 65:7 90:22

117:2,4 118:15

126:10,11 139:3

144:14 145:14

150:20 172:15

173:13 175:20

Jen's 7:7 54:11

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143:20

Jennifer 42:4 80:14

Jennifer's 138:3

Jeremiah 7:20

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jewels 148:18

Jim 2:9 6:5 111:7,9

114:10 169:3

Joanna 3:14

job 14:8 26:9 31:20

166:7

John 2:3,7,17 3:19

5:13,19 7:10,16

7:22 9:18 22:1,3

22:13 23:9 25:8

41:7 48:20 52:18

56:13,14 59:9

62:15 63:16 68:12

69:17,18 74:15

89:9 92:1 104:11

105:8 107:11

113:15 114:13,16

115:2,3 122:13

126:22 140:16

147:1 148:9 150:1

151:2 153:19

155:18 157:21

161:16 165:9

171:11,12,18

172:11 175:5

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join 6:20 171:18

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63:2,14

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17:16 18:13 25:19

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52:17 53:13,17,19

53:21 54:1,2 55:1

55:17 56:3,6

66:18,21 72:7

76:2 78:17 84:18

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106:21 108:9

119:10 120:18

125:6 126:17

127:22 128:6

130:7 131:3,20

133:6,10 134:4,10

134:15 135:11

139:3 143:7,12,13

146:6 149:8

151:20 152:5,10

152:12,13 157:21

158:2,9 160:17,19

161:1 168:2 169:3

170:1 175:3

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39:12 40:16 47:21

76:8 125:18,21

130:9

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Kline 53:1,4 80:16

133:16 135:8

150:22 151:13,17

157:20 159:6

160:8 174:1,1

176:1

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know 7:22 10:14,17

11:11 12:19 14:3

14:13,18 16:1,1,9

17:19 19:19,22

20:16,18 21:15,17

22:3,17 23:9,11

25:12,14 26:2,6

26:12,18,19 27:14

29:16,17 30:18

32:9 34:3,15,17

36:14,16,19,20,21

37:3,11,14,19,22

38:3,11 39:19

41:16,21 43:6,9

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44:21,22 45:11,13

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48:13 50:7 52:12

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April 30, 2015

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language 106:19

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largely 71:1

larger 19:6 46:15

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Laughter 26:7 69:9

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172:1 175:1

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laundry 77:6 98:11

Lawrence 3:11,12

lawsuits 119:6

lawyers 107:4

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LBL 131:1

lead 14:4 108:14

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leaning 140:18

learn 116:2,3,6

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learned 116:5

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learning 79:20

leave 74:7 154:15

leaves 88:5

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legal 21:1 80:10

94:12 95:10,19

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lesser 138:9,11

lessons 158:16

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14:1 18:16 32:21

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103:7 114:19,22

120:8 121:8

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letters 98:7,8

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level 23:18 24:8

34:7,20 82:8

85:12 87:22 98:18

127:5 128:2 138:9

levels 44:5 90:16,20

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leverage 130:8

leveraged 118:4

liberty 61:16

life 68:2,5 121:20

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lifetime 168:1,7

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light 61:4 66:9 76:9

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limitation 79:3

limitations 94:11,13

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limited 24:14 83:17

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limits 24:3,4,5 80:9

line 152:4 160:3,12

linear 99:12

list 7:3 8:8,9,10,12

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30:16 31:6,7,9,10

31:13 32:20,21

33:1,11 41:3,4,5

41:13,20 42:13

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76:22 91:15 98:11

99:1 124:5 125:4

141:4,5 143:15

155:10 161:1

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lists 8:14

little 7:7,9,11,21

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27:17 31:5 33:8

33:22 49:7 50:10

57:2 58:1 60:15

63:11 70:13,22

73:18 92:9 109:10

110:19 117:7,18

120:7 129:5,10,14

144:19 145:9

151:22 152:12

158:19 161:3

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lives 167:20

living 67:1

loadings 72:21

local 87:12,15,16,17

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locked 47:2,5,7

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logic 51:11

long 87:4 120:5,8

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long-term-type

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longitudinal 130:5

look 12:15 18:22

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58:6 74:14 76:3

77:11 78:16 82:6

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98:22 111:22

115:21 116:2

117:15 120:18

121:7,11 122:7

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175:2

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138:18 140:5

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looked 66:22 78:14

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19:10 24:16 33:4

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111:19 115:19

117:10 122:17

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loophole 61:10,13

loopholes 16:7,7

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louder 7:9

loudly 12:20

love 143:16

lower 109:10 123:13

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maintained 36:18

maintenance 113:8

major 28:2,3 29:8

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majors 163:8,10

making 12:6 73:6

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manages 88:15

mandate 110:14

mandatory 15:22

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march 107:8

margin 148:16

margins 164:13

mark 92:6 95:6

market 34:12 36:2

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markup 161:20,21

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massive 82:6

materials 26:18

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matter 61:11 63:19

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Mauer 3:14

maximum 75:1

Maxtech 149:16

McCabe 2:5 6:3,3

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McCarthy 90:11

mean 15:12 19:12

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34:15 48:21 56:19

64:21 70:2 81:17

81:21,22 82:3

85:21 88:8 95:3

96:12,18 97:12,21

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109:16 110:3

120:3 132:7

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154:14 155:12

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meaningful 122:21

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meant 24:22 165:3

measure 39:6

measured 31:18

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mechanism 14:5

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meet 27:16 40:8

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meeting 1:1,3 2:1

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memory 154:19

mention 83:2

mentioned 44:12

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microscope 119:12

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middle 140:20

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minute 100:19

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missing 126:4 162:1

mission 79:16

misunderstood 64:2

mode 49:5 74:20

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model 118:5 169:16

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modeling 123:3

models 45:7 56:9

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modification 29:7

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modifying 29:3

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momentum 48:10

Monday 7:4 10:20

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month 175:19,20

months 26:2,2

morning 5:13 11:22

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motor 71:3 72:8

motors 70:6 71:15

mouth 84:17 146:3

move 23:6,11,14

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46:13 57:8,13

62:12 75:3,7

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128:1 139:8

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movement 71:22

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74:9 79:21 89:6

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154:14,16 167:9

multi-million 130:9

multi-year 121:22

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multiple 25:6

multiply 72:14

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mysterious 168:2

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nail 18:18

name 43:7 112:12

narrow 103:12,15

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NASEO 5:18

national 2:7 3:11,12

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naturally 68:14

nature 130:5

Navigant 2:18,19
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66:16 67:11 69:14

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needing 99:21

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negotiated 119:2

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negotiating 10:7

negotiation 70:22

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new 10:7 14:8,15

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news 90:6

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nichey 132:8

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nitpick 49:3

nod 88:21

nonefficient 81:16

noon 100:21

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normal 123:20

normally 15:10

northwest 2:12 6:11

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noted 154:10

notes 173:8

notice 138:19,21

noting 53:7

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number 13:16

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56:11 68:4,20

69:11 72:14 77:15

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104:9 109:4

116:13 124:20

132:19,22 143:2

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numbers 72:22

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nutshell 70:3

O

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objections 13:2,6,6

obligation 27:16

107:16 109:7

obligations 106:21

107:1 138:3

observation 40:16

111:9

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observing 40:18

obvious 89:15

obviously 27:17

34:6 59:14 61:1

65:14 84:11 93:4

124:12 126:15

148:2,12 156:21

occurred 18:11

occurs 108:8 110:7

off-grid 82:2

off-mode 59:11

offer 50:12 153:18

offered 107:9

offering 55:20

office 122:2 153:22

officer 22:10

official 22:7

offline 89:3 114:17

offramp 139:18

oh 17:8 47:20 56:8

87:6 94:22 155:5

168:15 175:13

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21:2 22:8 28:18

31:2,12 32:19

33:10 43:3 57:14

58:2 69:2,10 70:1

78:2 80:1,4,13

89:15 103:18

107:10 113:18

115:2,9 117:17

121:15,18 122:10

123:14,21 149:14

172:9,12 175:13

175:13 176:7,9,16

old 87:11 157:22

OMB 88:12,15 89:1

on-site 153:20

once 58:15 123:11

143:8 144:9

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one's 47:20,21

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one-on-one 120:15

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90:3 111:20 113:7

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124:12,13 126:9

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154:19,20 169:13

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satellite 129:11

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scrutiny 98:19

seat 88:21

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secretary 90:10

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sections 60:10

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sectors 37:21 38:2

see 10:5 12:4 18:16

21:9 24:13 30:16

35:10,22 48:14,15

54:9 58:10 62:18

62:20 70:13 76:4

76:22 77:11 85:4

90:12 91:13,20

92:2 93:5 98:7

105:18 114:3,17

116:13 118:22

119:4 129:7,14

131:1 132:5

140:13 141:18

142:4 145:3

160:18 166:16

167:4 168:10

170:1 171:15

172:4

seeing 52:4 71:13

154:12 166:15

seek 25:8

seeking 61:8

seen 43:9 74:8 86:2

92:4 97:7 164:11

sees 59:10

select 116:13

sell 71:9 128:16

selling 71:18,20,22

72:1

send 18:22 26:1

sense 8:16 9:11,14

35:11 45:13 50:16

54:7 79:2 83:1

89:20 134:13

161:6 162:8 173:4

175:3

sensitive 156:13

sensitivity 88:10

sent 12:11 51:4

113:16

sentiment 59:1,16

separate 35:11

36:10 46:14 68:22

109:17

separately 76:10

77:9 110:3

September 90:7

sequence 45:13

67:13 99:10

sequenced 18:4

sequencing 18:4,5

46:15 48:17 54:9

91:19 99:18

serving 111:22

set 9:1 19:1 32:12

38:13 40:2,7 47:5

57:6 60:21 76:12

86:5 109:19

112:21 113:3

120:14 121:12

135:15 136:17

149:2 165:2 175:9

sets 25:7 131:6

164:6

setting 23:22

settings 132:9

settle 112:6

seven 54:16 58:15

62:3 63:15 66:10

68:20 174:13

seven-year 62:16,18

66:20

share 122:9 147:9

156:19

shared 7:4,19 52:19

153:8 162:21

shares 162:14

sharing 35:3 41:11

147:3,22 148:6

157:2 174:19

sheet 124:19

Shepherd 3:4

shifts 128:1

ship 36:19

shipment 162:12,20

164:11

shipments 147:6

shipped 75:20

shoes 25:4 65:18

shooting 64:7

short 43:12

show 12:3 26:5

52:12

showing 138:21

shows 38:6 135:3

shy 141:11

side 45:17,21 63:18

85:16 93:7 104:6

126:16 154:9

162:20 166:3

sides 108:9 148:7

165:11,19

signed 27:20 76:13

106:5

significant 37:15

42:8 43:14 90:4

139:21 140:12

141:13 151:10

164:12

significantly 45:7,9

59:20 128:3

similar 71:4 130:4

simple 22:2 23:20

simply 19:7 23:16

29:17 33:3 148:18

Simultaneous 49:22

52:21 72:3 77:20

78:7 81:5 101:3

104:3 129:12

143:1 159:17

174:22 176:20

177:13

single 58:16 73:11

95:14 120:18

155:6

sit 159:16

sits 153:22

sitting 27:21 28:1,5

111:17,18 159:19

situation 59:13 62:2

64:11 86:13

situations 120:9

six 12:9 26:2 52:10

56:21 68:20 123:8

174:11,13

six-year 138:18

139:11

skill 121:11

slower 33:22

small 138:6,8

141:15

smaller 70:17

138:10

smarter 130:12

SNAP 86:7 88:10

89:5 91:17,20

92:2

society 163:16

Sohler 3:21

sold 128:13,16

solicited 115:17

solution 19:22

38:20,22 39:2

40:21

solutions 25:2,7,10

27:3 147:20

solve 24:22 25:5

69:13 90:19 151:3

somebody 51:10

61:20 81:1 159:16

someone's 168:20

someplace 136:10

somewhat 46:14

109:18 142:19

soon 6:19 140:14

sophisticated

165:16

sorry 17:8 41:6 43:7

53:1 56:15 103:9

115:3 117:7,17

sort 7:12,17 18:10

20:15 21:11,15

22:18 23:9 24:10

47:16 50:20 54:10

56:15,18 66:22

70:7,21 73:2,4

76:6 82:14 95:9

95:12 103:2

108:11 109:6

121:8 122:14,15

122:16 123:12

139:10,18 144:10

152:22 153:6,17

168:10 172:4

sorts 24:5,8 72:19

73:2

sought 62:9

sound 106:11

158:13

sounds 25:16 42:22

68:15 91:18

158:12

source 38:2 128:13

168:13

space 110:12 131:1

speak 7:15 12:20,20

73:13 148:11

speaking 34:10 43:6

159:7

specific 18:19 19:17

35:8 37:8 54:5

61:9 74:12 105:2

120:11,15,16

130:19 157:3

166:10 167:3

168:10 173:1,10

specifically 18:21

19:10,11 166:10

166:19

specifics 96:2

spelled 28:21

spend 7:21 8:6,13

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17:6 25:3 69:15

104:13,14 106:9

118:7 133:9

137:22 149:14

Spending 151:10

spent 15:2 66:12

111:9

spin 142:9

spinning 104:17

spoke 31:15

spot 73:3,5

spreadsheets 168:4

square 155:4

staff 126:5,6 135:5

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standard-setting

51:20

standards 1:2 2:10

3:14 5:12 13:15

18:6 25:12 29:2,3

29:4 30:19 32:6

33:7 35:15 43:12

43:19 47:11,11

49:13,14 52:9

59:5 60:11,21

63:12 74:19 76:7

76:16,17 82:11,17

87:14,15,16

104:16 106:10

110:21 111:10,13

111:21 112:1

117:11,13 138:20

138:22 141:11

144:2 149:12

standing 26:19

standpoint 119:19

Stanonik 3:8

star 55:10,14 64:8

127:21 144:7,8

start 5:3,4 7:15 10:2

16:18 30:14 42:14

43:1 47:13 63:1,9

70:11 71:5 72:13

79:5 104:21

125:14,15,15

136:3 144:5

169:22

started 29:3 30:14

47:15 61:6 63:2

65:6 85:14 102:4

110:7 170:17

starting 31:8 41:7

62:18,19 64:11

104:16 145:11

starts 50:13 136:4

154:1

state 2:14 9:21

27:22 28:4 49:11

58:20 62:13 82:10

82:17 83:12 86:11

stated 107:22

static 60:1

statue 142:18

statute 19:20 58:6

74:11 75:17 77:18

107:3 109:8 145:6

statutes 124:9

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statutory 19:10

20:10 24:2 45:18

74:2,6 75:2 77:2

85:9,10 105:2

106:19 108:22

139:5,6

stay 82:8 157:5

stays 114:20

step 71:12 77:2 85:5

99:9 120:17

158:10 172:13,18

stepping 157:10

steps 16:3 23:5,14

57:8 136:21 170:6

172:6,6 173:10

Steven 3:20

stick 79:17

sticking 14:17

stock 168:22

stood 61:5 90:8

stop 46:16

storage 82:2

story 143:6

straightforward

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Strategy 5:17

streamline 119:9

streamlined 84:3

street 85:22

stretch 135:7

strides 83:19

strike 166:1

strikes 38:16 53:6

66:10 80:4 109:19

116:18,22 134:1

135:8 151:12

161:4 168:7

structure 135:10

struggle 158:8

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struggled 152:1

struggles 151:19

struggling 152:16

stuck 86:12

studies 37:15

131:20

study 37:18 38:6,9

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studying 14:18

stuff 15:22 19:19

25:21 66:21 98:9

128:6 131:3 150:4

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Stunder 3:22

subcommittee 68:9

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subcommittees 8:18

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subgroup 50:1

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subgroups 8:18

14:3 17:11 102:9

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subject 125:21

submit 151:6

submitted 97:8,14

115:17

substance 12:2

success 157:2

successful 23:7

25:13 27:11

118:22

sudden 60:19

Suddenly 87:12

sufficiency 63:21

sufficient 117:5,6

suggest 7:18 46:12

102:7 146:16

153:14 163:22

suggested 42:4

75:20 137:12

170:22 172:5

suggesting 76:3

98:13 103:10,11

117:9 163:14

173:12

suggestion 73:17

102:10 113:21

summarize 36:1

summary 144:14,16

super 70:19

supervisors 153:10

support 10:16 65:14

88:2 100:12 159:8

supporting 132:16

138:20

supposed 24:18

110:22

sure 7:7 9:4 10:5

11:3 19:11 20:19

21:3,13 35:16

41:2 43:3 63:9

64:16 69:13,19

71:12 73:6 80:13

90:12,17,19 92:18

94:7 96:16 102:17

108:17 110:3

114:19 117:8

122:21 123:8,9,10

124:9 126:5 131:4

131:16 136:9

141:16 144:20

145:21 148:1

150:17 155:15

159:20 167:5

surprised 96:10,15

96:18 129:1

surprising 112:8

survey 153:7,7,8

surveys 37:20

SW 1:8

sweet 73:3,5

sync 134:12

system 51:15 71:21

72:13 73:5 74:1

75:3,4,7,10 76:9

77:8 78:13 87:20

171:14

systems 70:12,12

73:22 74:9 76:4

76:15 80:8,10

T

T 102:1

table 27:21 28:5

58:18 63:18 64:5

64:14 91:11 98:16

102:18 106:12

129:20 146:4

166:3,14 169:21

tabled 105:10

113:21

tack 119:18

tackle 14:4 73:21

124:2 170:19

tackling 69:10

173:17

take 8:3,8,19 10:4

13:13,17,21 16:16

17:17 21:7,15

31:10 33:15 41:19

58:6 68:1,9 72:4

76:3 92:9 97:16

97:21 98:5 99:9

100:18 106:15

112:5,5 114:17

120:17 121:6

124:6,8,8 125:7

136:18,20 151:5

161:14 172:14

173:8

taken 37:3 85:5

148:7 172:7

takes 66:16 110:13

136:12 151:7,8

157:7,7

talk 19:6 31:10,11

46:17 51:15 56:7

56:8 78:15 124:20

128:5 137:8

140:21 145:19

146:4 163:1,6

166:11 170:5,8

173:2

talked 81:19 89:3

92:12 144:18

145:9 151:22

155:3 170:10

172:16

talking 15:4,18,19

16:7 19:17 25:6

30:20 40:17 68:17

70:15 78:11 86:1

113:16 128:19

151:14 154:18

155:22 162:10

169:12

target 160:20 161:1

targeted 113:6

136:7 158:7

task 49:21 57:5

103:4 116:15

137:4 147:16

166:9

tasks 41:19 171:8

tax 127:22

teach 44:22

team 65:6 153:21

167:2

tearing 156:8

technical 89:15

technologically

139:1

technologies 2:17

5:14 15:21 81:19

81:22 130:15

167:21

technology 14:15

34:12 50:15,17,21

69:8 72:9 96:3

123:6 128:11

131:9 152:3

tee 21:1 23:17

teed 115:12 169:7

teleconferences

159:18 162:7

tell 38:7 47:19

83:14 145:22

telling 15:4 134:21
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tendency 38:20

tends 40:14 99:13

tension 48:4,14

tensions 67:16

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term 11:1,7 87:5

terms 11:12 17:3

18:14 27:15 53:5

83:13 84:7 94:11

98:10 122:16

129:19 138:6

141:12 174:17

test 14:9,12,18,19

14:19,21 15:7,8

16:8,12,14,16

23:22 29:7,8,10

31:16,17 32:4

34:16,18 35:14

36:11 39:9,12,20

39:22 43:10,16,20

44:6,8,10,19 45:1

45:2,5,6,7,19 46:4

46:10 47:1,2,6,14

47:18 48:5,22

49:6,13,14 50:14

50:19,22 51:2,13

51:18,21 52:14

53:7,11,19 54:2

54:16 55:4,6,18

56:1,7 58:11,14

58:16 59:2,2,11

60:9,20 61:15

62:3 65:13 66:15

66:20 67:3,19,21

68:1,3 73:10

77:12 78:3 79:3

84:8 93:6,9 94:6

95:12 96:8,11

99:2,4,15,18

100:11 104:6,7,9

111:15,15 124:18

125:20 126:1,3,9

126:15 131:3,18

132:10 143:21

144:5,9,13 145:6

151:21 152:14

172:16 173:19

tested 76:13

testing 18:6 34:15

36:21 40:16 45:4

46:7 53:20 60:18

61:6 62:6 156:8

tests 15:15

thank 6:22 13:7,9

16:22 57:15 62:14

111:17 129:20

166:2

thankful 65:20

thanks 6:21 7:6

56:14 98:21

theirs 60:12

theory 24:7 113:6

thermal 167:12

thin 156:7

thing 14:15 20:16

38:19 43:4 47:4

52:8 55:16 56:5

60:16 73:19 74:12

76:2 78:13,14

81:18 85:8,9

106:7 108:8 110:6

110:19 111:12

116:21 120:18

128:9 129:5,8,18

144:17 164:19

169:22

things 7:17 9:9

16:20 18:3,14,14

22:2,15,16,18,20

23:8 24:5,9 26:19

28:13 30:8 32:12

33:21 39:5,19

40:18 50:14 52:13

52:15 53:8 56:6

56:21 60:5 65:3

67:10 69:5,7 70:3

70:11,12,15,16

72:17 73:2 76:8

76:11,14 77:14

82:9 85:18 93:17

93:22 94:2 103:20

108:3 111:14

119:14 122:19

123:4,6 125:19

127:21 132:16

135:6 141:19

143:15 148:5

150:2,12,19

152:14 155:15,16

156:6 162:21

163:4 164:15

171:1 172:12

173:5

think 5:7 8:21 9:5

9:10,19 10:14,22

11:16,19,21,22

12:8,9,17 13:2

14:1,2,10 16:4,9

16:19 17:1,1

18:16,17 19:6,8

19:16,18,20,21

20:21 22:15 23:1

23:8 25:2,9 26:11

27:2,4,8,20 28:14

28:20 29:22 30:20

31:14,19 32:3,8

32:13,15,20 33:14

33:17,20 34:7,14

34:20 35:11,18

36:13 37:19 38:10

41:9,12 42:4,18

43:3,6 44:1,12

45:11,14 46:14,22

47:19 48:8 49:2,3

49:5,10,11,18

50:5 51:17 52:3,8

53:5,16 54:5,7,8

55:17 56:16,18

57:3 58:18,22

59:5,6,18 60:16

61:3 62:1,17

63:17 64:12,15,19

65:8 66:13,19

67:6,14,15,18

68:6,11,18,22,22

69:16 70:11 71:4

71:13 73:19 74:3

74:7,8,12 75:13

76:2 78:20 81:6,7

81:18,21,22 82:5

82:8 83:11,18

84:5,8,12,13,20

85:3,5 88:10

89:14 90:18,22

91:2,3,4,6,8,9,12

91:14 92:10,14,22

93:5,12,13,18,18

93:19,20,21,21,22

94:2,6,13,17 95:5

96:4,6,20 98:2,3,6

99:1,4,10 100:9

102:3,4,9,21

104:18,22 105:11

106:11,18 107:1,2

107:5,12,22 108:5

109:10 110:15,20

112:20 114:1,2,4

114:9 115:16

116:1,8 117:7

118:2,13,20

119:18,20 120:3,5

120:11 121:1

122:14 123:1

124:6,10,13,14,20

125:2,18 126:8,20

127:17 128:6,10

130:8,11 131:3

132:1,4,6,12,18

132:19 133:17,21

135:11,16,18

136:19 137:9,12

137:21 138:4

139:2,3 140:10,11

141:6 142:7,12,13

142:16 143:13

144:17 145:10,22

146:7,10 147:10

147:14,19 148:2,5

148:10,10,13

149:18,19 150:2

150:22 151:4,19

152:6,8,12 154:9

154:10,14 155:19

156:11 157:2,4,5

157:13,18 158:4

158:18,21 159:1,2

159:4,4,6,7,9

160:6,9,10,16

162:5,6,6 164:1,2

164:14,22 165:4,5

165:18,19 166:4,5

166:17,21 167:2

169:2,12,13,13,21

170:5 172:2,15,17

174:16 177:20

thinking 8:15 25:3

46:3 81:18 98:10

104:12 115:7

135:13 136:20

142:5 151:18

154:16 158:4

167:12

thinks 155:18

third 61:3

thirsting 79:10

thought 7:13,20 8:5

13:20 25:19 31:10

64:2 66:4 105:17

108:13 110:4

114:14 116:1

119:17 130:13

158:11 160:9

177:22

thoughts 28:19

30:11 76:18 162:3

170:9,12 173:10

thread 160:13,17

161:9

three 10:7 12:9

30:18 31:3 57:10

71:2 72:17 74:19

77:8,14,19 102:5

102:7 103:8 112:5

112:6 115:6,11

172:6 174:6,7,7

three-month 11:7

threshold 140:22

141:3,7,18 142:13

thresholds 141:12

throw 17:19 56:15

64:17

throwing 157:20

160:8

thrown 96:13

104:20

throws 64:9

Thursday 1:12 11:5

tidbit 65:20

time 7:22 8:6,13 9:4

9:10,20 11:22

14:12,15 15:1,12

25:3 29:11 31:10

33:21 39:15 40:5

42:20 43:11,12

54:15 56:7 57:6

59:10 65:1 66:6

66:12,16 69:15

91:21,22 99:6

100:22 101:2

104:20 106:9

110:15 113:22

117:8 118:7 120:5

122:21 123:6

133:9 136:8,11,17

137:22 142:10

149:15 151:5,8,10

156:3 157:2,17,18

161:14 165:2

166:9 175:18

timeframe 136:7

139:7 144:2 175:3

timely 147:10 149:5

times 69:19 152:10

158:15

timing 16:20 52:18

84:7 93:19 104:4

158:22

tiny 16:3 167:10

title 22:7

to-do 162:18

today 7:14 14:21

20:22 25:6 31:14

41:18 51:12 56:18

57:1 58:8 67:8

74:18 92:19

109:15 118:13

143:19 166:9

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today's 100:5

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told 154:3

Tom 2:12 6:10 34:9

50:9 71:8 81:18

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136:19 157:19

164:20 171:1

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Tom's 37:14 122:14

ton 104:20

tons 47:5

too-short 89:19

tool 148:3 153:7,8

toolkit 148:3

tools 116:4 118:4

120:13

top 64:1 137:9

topic 14:2,4 17:7

30:12 37:9 56:16

60:2 69:12 76:19

80:2,5,13 88:9

89:8 91:18 96:3

114:15 115:8

122:12 145:14

topics 7:21 8:3,6,11

8:20 13:12,16

23:3 30:15 42:2

42:10 57:7 66:10

68:10 91:14 124:3

tossed 50:4

total 140:22 141:1

totally 134:2

touch 105:20

146:12

touched 47:3

tough 142:18

towel 64:18

trade 30:4 90:7

111:11,19,22

112:3 113:10

115:16 160:21

161:11 162:13

163:7,18,20 165:7

173:20 174:21

traditional 148:4

train 89:6,10

transaparency

167:6

transcript 16:6

173:9

transformer 150:4

transformers 70:4,7

transparency 67:14

166:15,15,16,17

166:18 169:15

transparent 165:11

165:13 169:8,10

traunch 52:9

tricky 144:3,3

tried 58:2 65:22

128:7

trigger 106:7

107:18 108:22

113:13

triggered 63:8

105:13 107:14

111:1,6

triggering 63:12

106:21 107:1

triggers 63:14 109:2

109:3

true 2:13 5:21 39:20

48:21 99:22 144:8

truly 150:11

trust 34:7 35:16

41:11 128:20

132:10 147:3

148:19 149:18

151:2

truth 48:22 135:4

try 14:16 28:12

35:22 39:3,3,6

47:9 49:17 55:17

57:11 60:17 61:11

65:5 66:8 69:13

84:21 129:13

154:21 169:8

trying 15:22 16:2

22:14 28:5,15

37:10 39:6 41:3

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