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Central Air Conditioning For Presentation at the Arthur D. Little, Inc. Public Workshop 12/9/99 955 L'Enfant Plaza, S.W. Rulemaking Suite 8600

Washington, DC Engineering Analysis 2W0 24-2119 U.S.A.

Internet: www.arthurdlittle.com

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.. ...... , EE-RM-STD-98-440 COMMENT 14EE

E£-Rtk/S 7D - ql( -ifL/l> 

Central Air Conditioning 

Rulemaking 

Engineering Analysis 

For Presentation at the 

Public Workshop 12/9/99 

1'-/ >1££ 

Arthur D. Little, Inc. 

955 L'Enfant Plaza, S.W. 

Suite 8600 

Washington, DC 

20024-2119 U.S.A. 

Internet: www.arthurdlittle.com 
EE-RM/STD-98-440 / Y E

Engineering Analysis Introduction

The Engineering Analysis explores the impact of a new efficiency standard

on equipment cost, design, and availability.

The Engineering Analysis asks ...

* How will equipment cost and price change with efficiency?

* What is the technological limit on efficiency level?

* What technologies will be available to improve efficiency or reduce the cost of

achieving higher efficiency?

* Are there any products with unique utility that could be impacted by a new

standard?

* Are there any other technical considerations that could affect whether a

standard level is "technologically feasible and economically justified".

WAS CAC EngAnalysis ANOPR wkshp 1

.. . ....... 

, EE-RM-STD-98-440 COMMENT 14EE

EE-RM/STO-9S-440 lyE E 

Engineering Analysis Introduction 

The Engineering Analysis explores the impact of a new efficiency standard 

on equipment cost, design, and availability. 

The Engineering Analysis asks . .. 

• How will equipment cost and price change with efficiency? 

• What is the technological limit on efficiency level? 

• What technologies will be available to improve efficiency or reduce the cost of 

achieving higher efficiency? 

• Are there any products with unique utility that could be impacted by a new 

standard? 

• Are there any other technical considerations that could affect whether a 

standard level is "technologically feasible and economically justified". 

WAS CAC EngAnalysis ANOPR wkshp 1 
EE-RM/STD-98-440

Engineering Analysis Reverse Engineering Introduction

We used Reverse Engineering techniques to estimate the relationship

between manufacturing cost and efficiency under potential new standards.

Why did the Department select this method?

* Results give the cost for each efficiency level (Efficiency Level approach), and

also provide design detail.

* There is an ample selection of equipment on the market at efficiency levels

well above the current standard level (10 SEER).

* Designs are fairly uniform across manufacturers.

* Residential central air conditioners and heat pumps have a manageable set of

components that impact efficiency.

WAS CAC EngAnalysis ANOPR wkshp 2

... :" . EE-RM-STD-98-440 COMMENT 14EE

EE-RM/STD-98-440 I c.f CC 

Engineering Analysis Reverse Engineering Introduction 

We used Reverse Engineering techniques to estimate the relationship 

between manufacturing cost and efficiency under potential new standards. 

Why did the Department se/ec( this method? 

• Results give the cost for each efficiency level (Efficiency Level approach), and 

also provide design detail. 

• There is an ample selection of equipment on the market at efficiency levels 

well above the current standard level (10 SEER). 

• Designs are fairly uniform across manufacturers. 

• Residential central air conditioners and heat pumps have a manageable set of 

components that impact efficiency. 

WAS CAC EngAnalysis ANOPR wkshp 2 
EE-RM/STD-98-440 q EE

Engineering Analysis Reverse Engineering Relation to Uncertainty

Reverse Engineering begins where uncertainty is lowest (today's

equipment) and moves to equipment where costs are more uncertain.

Costtoday

(lowest . uncertainty) s Cost under new

standard level (if l"lustration Only effective today)

(higher uncertainty)

o · Fewer features

)a · Cost-optimized, high

'r~L ~., volume production

-3doi~pl T L~tB~IIII~ · Conversion costs

cg~p- _~~lO Cost under a new

standard level (if

effective in 2006)

(highest uncertainty;

required for rulemaking)

* New technologies

* Increased productivity

* New material and labor costs

Efficiency

WAS CAC EngAnalysis ANOPR wkshp 3

EE-RM-STD-98-440 COMMENT 14EE

-

~ o 

C) 

c: 

EE-RM/STD-98-440 

Engineering Analysis Reverse Engineering Relation to Uncertainty 

Reverse Engineering begins where uncertainty is lowest (today's 

equipment) and moves to equipment where costs are more uncertain. 

"Iu-t .. _·:o- 0-'" 

II ." a"" '"Y 

, Cost today 

(lowest 

~-~ 

" uncertainty) 

Efficiency 

Cost under new 

standard level (if 

effective today) 

(higher uncertainty) 

• Fewer features 

• Cost-optimized, high 

volume production 

• Conversion costs 

standard 

Cost under 

level 

a new 

(if 

~ 

effective in 2006) (highes~ uncerlaonffy; 

required for rulemakirng) 

• New technologies 

• Increased productivity 

• New material and labor costs 

WAS CAC EngAnalysis ANOPR wkshp 3 
EE-RM/STD-98-440 q

Engineering Analysis Reverse Engineering Costs Considered

We consider all the costs of producing the product when developing the

cost-efficiency relationship.

Reverse

Direct Direct Overhead Engineering Labor Material

DOE estimates

Tooling R&D Investment Marketing

Representative cost Top-down industry breakdown for nonbaseline equipment Selling eneral & R anaysis

Admin.

Full Cost of Product (dollars)

WAS CAC EngAnalysis ANOPR wkshp 4

EE-RM-STD-98-440 COMMENT 14EE

EE-RM/STD-98-440 

Engineering Analysis Reverse Engineering Costs Considered 

We consider all the costs of producing the product when developing the 

cost-efficiency relationship. 

Representative cost 

breakdown for nonbaseline equipment 

Full Production Cost 

L..-0_ire_c_t----l '---_o_ire_c_t----l I Ovemead I _ Labor .. Material 

----.- - --- - -_._-------- --- ~==_~_=__~~onversio~ eost-("01'!!-~!"~ ___ - _ 

I Tooling II R&D I Investment I Marketing I 

,_\~©[jij 0,: :O:li7@G]li:)~!1j@[7i! (~:Q@il 

I Selling I c::J I Interest I General & 

Admin. 

Full Cost of Product (dollars) 

Reverse 

Engineering I 

DOE estimates 

Top-down industry 

analysis 

WAS CAC EngAnalysis ANOPR wkshp 4 
EE-RM/STD-98440 1 EE

Engineering Analysis Reverse Engineering Approach

The Reverse Engineering approach used data from actual 3-ton

equipment...

Reverse Engineering Approach

Collect data from Collect data from continued .Tear down 3 samples EMs on 62 samples product literature on OEMs on 62 samples 6 samples 6 

* Disassemble and identify all OEM's selected representative Used to fill-in sample-set

parts equipment at each efficiency

* Deduce the fabrication and level and provided model

assembly processes used numbers and physical data for

key efficiency-related attributes

Equipment torn down: and parts, including: * 10 SEER split air conditioner

with fancoil * size

* 10 SEER packaged heat pump * weight

* 12 SEER split heat pump * compressor type

condenser * tube and fin type, size, and

spacing

* controls

* motor type

* fan type, no. of blades, and

diameter

WAS CAC EngAnalysis ANOPR wkshp 5

EE-RM-STD-98-440 COMMENT 14EE

EE_RM/STO-98-440 

Engineering Analysis Reverse Engineering Approach 

_....... _.. • - - _I _I ... II1II .... II1II I ne KeVerSe t:nglneenng approacn usea aata Trom actual ~-ton 

equipment ... 

_ Tear down 3 samples 

• Disassemble and identify all 

parts 

• Deduce the fabrication and 

assembly processes used 

Equipment torn down: 

• 10 SEER split air conditioner 

with fancoil 

• 10 SEER packaged heat pump 

• 12 SEER split heat pump 

condenser 

Reverse Engineering Approach 

Collect data from 

OEMs on 62 samples 

OEM's selected representative 

equipment at each efficiency 

level and provided model 

numbers and physical data for 

key efficiency-related attributes 

and parts, including: 

• size 

• weight 

• compressor type 

• tube and fin type, size, and 

spacing 

• controls 

• motor type 

• fan type, no. of blades, and 

diameter 

Collect data from continued 

product literature on 

6 samples 

Used to fill-in sample-set 

WAS CAC EngAnalysis ANOPR wkshp 5 
EE-RM/STD-98-440 / E

Engineering Analysis Reverse Engineering Approach (continued)

... to estimate the costs of the same equipment under new efficiency

standards.

Reverse Engineering Approach (continued)

Collect material, Detailed production costs

continued Develop production aoera (in $ for 71 samples in

models costs four product classes, 10

SEER through 17 SEER

* Modeled four greenfield * Obtained the costs of every

facilities -- one for each cost element in the production

product class model (plant overhead and

* Facilities consisted of actual labor) and equipment samples

production equipment used (parts and materials)

in a modern facility * Sources included quotations,

* Production processes estimates, and top-down

based on information reports

deduced during the tear * Used multiple sources when

downs and plant visits possible

* Costs assume full production

volume

* Costs are present-day

WAS CAC EngAnalysis ANOPR wkshp

EE-RM-STD-98-440 COMMENT 14EE

" , EE-RM/STD-98-440 /'1 E£ 

Engineering Analysis Reverse Engineering Approach (continued) 

. ... .... oil.... ..... ... • III. ..... • 

.. . to estimate tne COStS OT tne same equipment unaer new enlclency 

standards. 

Reverse Engineering Approach (continued) 

continued Develop production 

models 

• Modeled four greenfield 

facilities -- one for each 

product class 

• Facilities consisted of actual 

production equipment used 

in a modern facility 

• Production processes 

based on information 

deduced during the tear 

downs and plant visits 

Collect material, 

labor, and overhead 

costs 

• Obtained the costs of every 

cost element in the production 

model (plant overhead and 

labor) and equipment samples 

(parts and materials) 

• Sources included quotations, 

estimates, and top-down 

reports 

• Used multiple sources when 

possible 

• Costs assume full production 

volume 

o Costs are present-day 

Detailed production costs 

(in $) for 71 samples in 

four product classes, 10 

SEER~rough17SEER 

WAS CAC EngAnalysis ANOPR wkshp 6 
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Engineering Analysis Reverse Engineering Production Cost Results

The results are detailed production cost estimates for each equipment

sample, aggregated across eight efficiency levels and four product classes.

Reverse Engineering Results (7/11/99) -- Unitary 3-ton

$1,300

$1,200 Split Air Conditioner:

$1,100 -- -- Cased coil

§ $1,000 -A - -- Fancoil

O o $900 $900 - .. ^ Split Heat Pump

' $800 "__/ -4e- Packaged Air Conditioner

$700 --- 2 ~$ -- Packaged Heat Pump

.$600 .

$500

$400

$300 - l l.

9 10 11 12 13 14 15 16 17 18

Efficiency Level (SEER)

Cost results by subassembly are available in the TSD and on the BTS

website.

WAS CAC EngAnalysis ANOPR wkshp 7

• I EE-RM-STD-98-440 COMMENT 14EE

EE_RM/STD-98-440 I L/ E. E: 

Engineering Analysis Reverse Engineering Production Cost Results 

The results are detailed production cost estimates for each equipment. 

sample, aggregated across eight efficiency levels and four product classes. 

$1,300 

$1,200 

$1,100 

-$1,000 U) 

0 

() $900 

c 

0 

; $800 u 

:::s $700 " 0 

~ 

0.. $600 

$500 

$400 

$300 

Reverse Engineering Results (7/11/99) -- Unitary 3-ton 

.. .. ~ 

:7 

".." 

,,/ ?*,,/ ~/ )K / 

• 

~ 

/ ~ 

...- ~ 

9 10 11 12 13 14 15 16 17 18 

Efficiency Level (SEER) 

Split Air Conditioner: 

-+- -- Cased coil 

-.- -- F ancoil 

Split Heat Pump 

--- Packaged Air Conditioner 

~ Packaged Heat Pump 

Cost results by subassembly are available in the TSD and on the BTS 

website. 

WAS CAC EngAnalysis ANOPR wkshp 7 
EE-RM/STD-98-440 l(E

Engineering Analysis Markups Introduction

We used the Markup approach to estimate the relationship between

manufacturing cost and the retail price paid by consumers.

Why did we select this method?

* There is no national, equipment-only retail price information available for

residential central air conditioners.

* Contractors rarely break out equipment prices from the rest of the installation

price.

* Equipment prices vary as a function of brand, location, weather, and level of

local competition.

WAS CAC EngAnalysis ANOPR wkshp 8

EE-RM-STD-98-440 COMMENT 14EE

) 

EE-RM/STD-98-440 (tf.ETC 

Engineering Analysis Markups Introduction 

We used the Markup approach to estimate the relationship between 

manufacturing cost and the retail price paid by consumers. 

Why did we select this pethod? -' 

• There is no national, ~quipment-only retail price information available for 

residential central air conditioners. 

• Contractors rarely break out equipment prices from the rest of the installation 

price. 

• Equipment prices vary as a function of brand, location, weather, and level of 

local competition. 

WAS CAC EngAnalysis ANOPR wkshp 8 
EE-RM/STD-98-440 l E z

Engineering Analysis Markups Approach and Results

In the Markup approach, retail price is derived from production cost by

applying a series of markups along the distribution chain.

Production

Cost Source Markup Data Used Data Source

5 year average gross margin ('93- Manufacturer SEC 1-K

Manufacturer 1.18 '97), less EBT, plus assumed

1 percent profit margin filings (1993-1998)

Median gross margin for ARW's 1998 Profit

0.) Distributor 1.37 wholesalers selling HVAC

O |____| equipment Re

. Combined gross margins from

.a ontraor i*^ Residential/Light Commercial Q ;Contractor 1.55 Analysis for the HVACR dealers engaging in retrofit (66%) Industry (1995)

o and new (34%) installationsndustry (15)

Federal Trade

Sales Tax 1 07 State sales tax rates weighted by Administration (1998); unitary shipments in each state Sales Tax Institute

(1999)

Retail Price Total 2.68 Same markup applied to all four product classes

* Markup does not vary with efficiency standard level

* Triangular distributions defined for each markup

except Distributor (point value)

WAS CAC EngAnalysis ANOPR wkshp 9

EE-RM-STD-98-440 COMMENT 14EE

EE-RM/STD-98-440 It} E~ 

Engineering Analysis Markups Approach and Results 

In the Markup approach, retail price is derived from production cost by 

applying a series of markups along the distribution chain. 

Production 

Cost 

c .-ftS 

.c 

o 

c 

o 

+=i 

~ 

.a 

'i: 

... 

. !! 

c 

Retail Price 

Source 

Manufacturer 

Distributor 

Contractor 

Sales Tax 

Total 

Markup 

,f 

1.18 

1.37 

1.55 

1.07 

2.68 

Unitary Equipment Markups 

Data Used Data Source , 

5 year average gross margin ('93- Manufacturer SEC 10-K '97), less EBT, plus assumed filings (1993-1998) 1 percent profit margin 

Median gross margin for ARW's 1998 Profit wholesalers selling HVAC Report equipment 

Combined gross margins from ACCA's Financial Residential/Light Commercial Analysis for the HVACR dealers engaging in retrofit (66%) 

and new (340/0) installations Industry (1995) 

Federal Trade 

State sales tax rates weighted by Administration (1998); 

unitary shipments in each state Sales Tax Institute 

(1999) 

• Same markup applied to all four product classes 

• Markup does not vary with efficiency standard level 

• Triangular distributions defined for each markup 

except Distributor (point value) 

WAS CAC EngAnalysis ANOPR wkshp 9 
EE-RM/STD-98-440

Engineering Analysis SEER-EER Relationship

We examined how compressor and fan modulation correspond to the

relationship between SEER and EER in over 3,000 unitary systems.

14 - :

Single Speed Compre

13 Indoor fan Outdoor fa.n

^^^ Modulating Compressor

speeds '~: _: speeds .

Minimum EER Available = 8.65 (includes dual compressors

tl~ 1 1-Models

-- --------- - -- ------ - ------------ ,--

10 11 12 13 14 15 16 17 18 19

L SEER not //( _

Source: ARI Unitary Directory, Feb-Jul 1998 SEER

WAS CAC EngAnalysis ANOPR wkshp 10

EE-RM-STD-98-440 COMMENT 14EE

I Lf 8£ 

EE-R M/STD-98-440 

Engineering Analysis SEER-EER Relationship 

We examined how compressor and fan modulation correspond to the 

relationship between SEER and EER in over 3,000 unitary systems. 

14 - --....... _ .. __ ... - -_.... "._--.--._+- -- --... -------

. Single Speed 

13 Indoor fan Outdooffan 

12 

D! 11 

w 

w 

speeds speeds 

Models 

below 12 

SEER not 

,', 

10 examined 

9 Minimum EER Available = 8.65 

,-. 

Modulating Compressor 

(includes dual compressors) 

---------------------------------- 8 

10 11 12 13 

Source: ARI Unitary Directory, Feb-Ju11998 

14 

SEER 

15 16 17 18 19 

WAS CAC EngAnalysis ANOPR wkshp 1 0 
EE-RM/STD-98- 44 0

Engineering Analysis SEER-HSPF Relationship

Suggested SEER-HSPF pairings for each standard level are based on the

pairings in available heat pumps.

10

Each band represents 20 percent of available models

9.5 - 10 Q

ARI "most likely" combination

6.5

9 80%

6 - I I I 

10 11 12 13 SEER 14 15 16 17

Source: ARI Unitary Directory, Feb-Jul 1998

WAS CAC EngAnalysis ANOPR wkshp 11

EE-RM-STD-98-440 COMMENT 14EE

14EE 

EE_RM/STO-9S-440 

Engineering Analysis SEER-HSPF Relationship 

~ 

Suggested SEER-HSPF pairings for each standard level are based on-the 

pairings in available heat pumps. 

10 ~--------------------------------------------------------

Each band represents 20 percent of available models 

9.5 +-----------------------------~~~----------------------

ARI "most likely" combination . 

9 +-----------------------~ 

8.5 -I-------------;r" 

7 

6.5 r-------------------------------------------------------~ 

6 T-------~------~------~------~------~--------._----~ 

10 11 12 13 SEER 14 15 16 17 

Source: ARI Unitary Directory, Feb-Jul 1998 

WAS CAC EngAnalysis ANOPR wkshp 11 
EE-RM/STD-98-440 q EE

Engineering Analysis Potential Efficiency Improvements

By 2006, we estimate that residential air conditioners could attain

efficiencies as high as 20 SEER.

Carnot

Efficiency

(123 EER) 'er~O

20 SEER

* Efficiency limit with

dehumidification Pote

(41 EER) IProt I

al T ati 

Irreversibilities and eI ent Today's Best

parasitics (30 EER) (18 SEER,

Losses due to residential 14.5 EER)

operating constraints

(16 EER, 20 SEER) * Compressor, coil, and fan

improvements (16 EER, 20 SEER)

The cost of a 20 SEER system is unknown, but would be at least 18 percent

more costly than the 17 SEER system (20/17 = 1.18).

WAS CAC EngAnalysis ANOPR wkshp 12

EE-RM-STD-98-440 COMMENT 14EE

EE_RM/STO-98-440 ,l/ EE 

Engineering Analysis Potential Efficiency Improvements 

By 2006, we estimate that residential air conditioners could attain 

efficiencies as high as 20 SEER. 

Carnot 

Efficiency 

(123 EER) 

• Efficiency limit with 

dehumidification 

(41 EER) 

\ 

• Irreversibilities and 

parasitics (30 EER) 

20 SEER 

• Losses due to residential 

operating constraints 

(16 EER, 20 SEER) 

loday's Best 

(18 SEER, 

14.5 EER) 

• Compressor, coil, and fan 

improvements (16 EER, 20 SEER) 

The cost of a 20 SEER system is unknown, but would be at least 18 percent 

more costly than the 17 SEER system (20/17 = 1.18). 

WAS CAC EngAnalysis ANOPR wkshp 12 
EE.-R/STD-98440 r"

Engineering Analysis Emerging Technologies Approach

We used the results of the Reverse Engineering analysis and additional

manufacturer design and cost information to estimate the cost of

systems utilizing emerging technologies.

* Advanced compressors * Advanced fan motors

* Microchannel heat * Advanced compressor

exchangers motors

Substitute

Conventional System components and costs Advanced System Cost

Cost based on manufacturer

projections and tests

(from Reverse Engineering

estimates)

* Cost improvements due to

technological advance and

scale economies

* Changes in the cost of

other components

* Elimination or addition of

other components

WAS CAC EngAnalysis ANOPR wkshp 13

EE-RM-STD-98-440 COMMENT 14EE

EE_RM/STD-98-440 

Engineering Analysis Emerging Technologies Approach 

We used the results of the Reverse Engineering analysis and additional 

manufacturer design and cost information to estimate the cost of 

systems utilizing emerging technologies. 

• Advanced compressors • Advanced fan motors 

• Microchannel heat 

exchangers 

Conventional System 

Cost 

(from Reverse Engineering 

estimates) 

• Advanced compressor 

motors· 

Substitute 

components and costs 

based on manufacturer 

projections and tests 

• Cost improvements due to 

technological advance and 

scale economies 

• Changes in the cost of 

other components 

• Elimination or addition of 

other components 

Advanced System Cost 

WAS CAe EngAnalysis ANOPR wkshp 13 
EE-RM/STD-98-440 I EE

Engineering Analysis Emerging Technologies Results

The preliminary assessment suggests that emerging technologies can

lower system cost beginning at the 12 SEER level.

wilsdu* A * * * i

VS Compressor Advanced Microchannel Advanced Fan

Motors Compressors HX Motors Combined

Impact on

Certainty of Commercial Viability by 2006 System Cost

10% 50% 20% 90%

10 + + + + +

11 + + + + +

tt 12 + -1% + + -1%

13 + -4% -0% -3% -7%

14 + -10% -0% -6% -15%

. 15 + -12% + -5% -16%

LU

16 -2% -7% -0% -4% -11%

17 -2% -5% + -4% -9%

WAS CAC EngAnalysis ANOPR wkshp 14

EE-RM-STD-98-440 COMMENT 14EE

EE-RM/STO-9S-440 14 EE 

Engineering Analysis Emerging Technologies Results 

The preliminary assessment suggests that emerging technologies can 

lower system cost beginning at the 12 SEER level. 

Likely Impact of Emerging Technologies on the Production Cost of 3-ton 

Unitary Split Air Conditioners by 2007 -

VS Gompressor Advanced Microchannel Advanced Fan 

Motors Compressors HX Motors Combined 

Impact on 

Certainty of Commercial Viability by 2006 System Cost 

10% 50% 20% 90% 

10 + + + + + 

11 + + + + + 

-

0::: 

w 

w 12 + -1% + + -1% 

f/) 

-

Gi 13 + -4% -0% -3% -7% > CI) 

..J 

>- 14 + -10% -0% -6% -15% u 

c 

CI) 'u 15 + -12% + -5% -16% IE 

w 

16 -2% -7% -0% -4% -11% 

17 -2% -5% + -4% -9% 

WAS CAC EngAnalysls ANOPR wkshp 14 
EE-RM/STD-98-440

Engineering Analysis Niche Products

There are at least four niche products that appear to face especially difficult

constraints when moving to higher efficiency levels.

* Ductless split

* High-velocity, small duct

* Vertical packaged, wall-mounted

* Split, through-the-wall condenser

Is this assessment correct? Should some products be excluded or others included?

What physical definitions can the Department use to identify these products?

At what efficiency levels do these products cease to be viable as unique products?

These products may require separate classification if the Department

determines that they possess unique utility and may not be competitive at

the standard levels that would be warranted for other products.

WAS CAC EngAnalysis ANOPR wkshp 15

EE-RM-STD-98-440 COMMENT 14EE

• . . . . . 

Engineering Analysis Niche Products 

11.(£13 

EE_RM/STO-9S-440 

There are at least four niche products that appear to face especially difficult. 

constraints when moving to higher efficiency levels. 

• Ductless s~lit 

• High-velocrty, small duct 

• Vertical packaged, wall-mounted 

• Split, through-the-wall condenser 

.) 

) 

Is this assessment correct? Should some products be excluded or others included? 

What physical definitions can the Department use to identify these products? 

At what efficiency levels do these products cease to be viable as unique products? 

These products may require separate classification if the Department 

determines that they possess unique utility and may not be competitive at 

the standard levels that would be warranted for other products. 

WAS CAC EngAnalysis ANOPR wkshp 15 
EE-RM/STD-98-4401 q EC

Engineering Analysis Next Steps

The Engineering Analysis is essentially complete, although the Department

seeks comments regarding its methods and assumptions.

* Comments should be submitted to the Department during the comment period

following this workshop

* The Department will review the comments and assess their implications on the

Engineering Analysis conclusions.

* If significant changes are warranted based on comments received during the

comment period, the Department will adjust the Engineering Analysis and use

it as the basis for the remainder of the rulemaking.

WAS CAC EngAnalysis ANOPR wkshp 16

..... • .... c'''' EE-RM-STD-98-440 COMMENT 14EE

EE-RM/STD-98-440,LJ E£ 

Engineering Analysis Next Steps 

The Engineering Analysis is essentially complete, although the Department 

seeks comments regarding its methods and assumptions. 

• Comments should be submitted to the Department during the comment period 

following this workshop 

• The Department will review the comments and assess their implications on the 

Engineering Analysis conclusions. 

• If significant changes are warranted based on comments received during the 

comment period, the Department will adjust the Engineering Analysis and use 

it as the basis for the remainder of the rulemaking. 

WAS CAe EngAnalysis ANOPR wkshp 16