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Energy Conservation Standards for Commercial and Industrial Air Compressors 04-01-2014

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1

DEPARTMENT OF ENERGY

ENERGY CONSERVATION STANDARDS FOR COMMERCIAL AND

INDUSTRIAL AIR COMPRESSORS

Tuesday, April 1, 2014

Department of Energy

1000 Independence Avenue SW

Forrestal Building

Washington, D.C. 20585

Reported by: Janel B. Folsom, RPR/CSR,

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

2 Doug Brookman, Public Solutions, Inc.

3 Jim Raba, U.S. Department of Energy

4 Jordan Doria, Ingersoll-Rand

5 Rick Stasyshan, Compressed Air and Gas Institute

6 Louis Starr, Northwest Energy Efficiency Alliance

7 Robert Bruce Lung, American Council for an

Energy-Efficient Economy

8

Andrew deLaski, Appliance Standards Awareness

9 Project

10 Laura Petrillo-Groh, Air-Conditioning, Heating,

and Refrigeration Institute (AHRI)

11

Alex Valenti, Energy Solutions

12

Johanna Hariharan, U.S. Department of Energy

13

Michael Kido, U.S. Department of Energy

14

Kurt Klinke, Navigant Consulting

15

Brian Coffey, Navigant Consulting

16

Chris Bolduc, Lawrence Berkeley National

17 Laboratory

18 Wayne Perry, Kaeser Compressors

19 Werner Rauer, Kaeser Compressors

20 Lane Burt, Ember Strategies

21 Chuck Foster, Edison Electric Institute

22

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1 A G E N D A

2 Welcome 4

3 Doug Brookman, Facilitator

President, Public Solutions, Inc.

4

Welcome 4

5

Jim Raba, Presiding Officer

6 Project Manager, U.S. Department of Energy

7 Opening Remarks, Introductions, and

Agenda Review 5

8

Regulatory History 14

9

Rulemaking Process Overview 15

10

Scope and Test Procedure 19

11

Market and Technology Assessment and

12 Screening Analysis 109

13 Engineering Analysis 146

14 Markups Analysis 189

15 Energy Use Analyses and Life-Cycle Cost and

Payback Period Analysis 205

16

17

Shipments Analysis and National

Analysis

Impact

239

18 Preliminary Manufacturer Impact Analysis 260

19 NOPR Analyses 260

20 Next Steps and Closing Remarks 274

21

22

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

2 MR. BROOKMAN: Good morning, everyone.

3 Welcome. This is the U.S. Department of Energy's

4 public meeting on Energy Conservation Standards

5 Framework for Commercial and Industrial Air

6 Compressors. Today is Tuesday, April 1st, 2014,

7 here in the Forrestal Building in Washington, D.C.

8 My name's Doug Brookman from Public Solutions in

9 Baltimore. Good morning, everyone. Welcome.

10 Glad to see you here. We're going to start off

11 this morning with welcoming remarks from Jim Raba.

12 MR. RABA: Well, good morning, everyone,

13 and welcome, whether you're attending today's

14 public meeting in person or via the webinar. This

15 is the U.S. Department of Energy's public meeting

16 about commercial and industrial compressors, where

17 we'll address the rulemaking framework for this

18 equipment.

19 The purpose of the framework document is

20 to describe the procedural analytical approaches

21 the Department of Energy anticipates using to

22 evaluate potential energy conservation standards

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1 for commercial and industrial air compressors and

2 invite public comments.

3 My name is Jim Raba. I'm the Project

4 Manager for compressors, and I will be today's

5 presiding officer. Moreover, the real expertise

6 behind this rulemaking process is from Lawrence

7 Berkeley National

8 Laboratory and Navigant Consulting:

9 Chris Bolduc, Brian Coffey, and Kurt Klinke.

10 General Counsel for the Department of Energy is

11 Michael Kido and Johanna Hariharan. The Appliance

12 Standards Program Manager is John Cymbalsky. Our

13 facilitator for today's public meeting is Doug

14 Brookman, President, Public Solutions, a mediation

15 company. Doug is our go-to guy for public

16 meetings such as this. Doug?

17 MR. BROOKMAN: Thank you. Let's start

18 by doing introductions around the room. I'll

19 start to my immediate left, and you can get used

20 to turning these microphones on and off, the

21 little button illuminated (ph), please.

22 MR. DORIA: Jordan Doria with Ingersoll-

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1 Rand.

2 MR. STASYSHAN: Rick Stasyshan,

3 Compressed Air and Gas Institute.

4 MR. STARR: Louis Starr, Northwest

5 Energy Efficiency Alliance.

6 MR. LUNG: Bruce Lung, representing the

7 American Council for an Energy-Efficient Economy.

8 MR. DELASKI: Andrew deLaski, Appliance

9 Standards Awareness Project.

10 MS. PETRILLO-GROH: Laura Petrillo-Groh,

11 AHRI.

12 MR. VALENTI: Alex Valenti, California

13 IOUs.

14 MS. HARIHARAN: Johanna Hariharan, G.C.

15 Department of Energy.

16 MR. KIDO: Michael Kido, Office of the

17 General Counsel, Department of Energy.

18 MR. RABA: Jim Raba, Department of

19 Energy.

20 MR. KLINKE: Kurt Klinke, Navigant

21 Consulting.

22 MR. COFFEY: Brian Coffey with Navigant.

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1 MR. BOLDUC: Chris Bolduc with Lawrence

2 Berkeley National Lab.

3 MR. BROOKMAN: Thanks again to all of

4 you for being here so we can get an early and

5 timely start on the day. All of you received a

6 packet of information as you checked in this

7 morning. I'm going to do a very brief agenda

8 review. Immediately following this agenda review

9 is an opportunity for anybody that wishes to to

10 make brief opening remarks about issues that

11 matter to you here at the outset.

12 Following that, we'll hear about

13 regulatory history and having a rulemaking

14 overview. Following that, scope of coverage and

15 test procedure -- procedures, plural. We'll take

16 a break mid-morning, roundabout 10:30 or so.

17 Returning from the break, market and

18 technology assessment screening analysis, and then

19 moving on from there, an engineering analysis and

20 then markups analysis. We'll take lunch midday.

21 Returning from lunch, energy use

22 analysis, life-cycle cost analysis, and then

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1 shipments analysis, national impacts analysis, and

2 then, finally, as we're moving towards closure,

3 NOPR analyses, and then closing remarks at the end

4 of the day by Jim Raba and anybody else that

5 wishes to make closing remarks. We intend to

6 close today probably no later than 3:30, so that's

7 the general timeline.

8 Questions and comments about the agenda?

9 Seeing none, I'd ask your consideration -- at the

10 front of this packet of slide -- PowerPoint

11 slides, some simple ground rules. Please speak

12 one a time and say your name for the record each

13 time you speak. There will be a complete

14 transcript of this meeting.

15 If you could be concise, share the

16 airtime. There's a lot to be said, I'm certain, as

17 the day goes on. If you'll turn your cell phones

18 on silent mode and limit sidebar conversations.

19 We've already gotten used to turning these

20 microphones on and off, so we're primed and ready

21 to do that.

22 And, webinar participants, welcome to

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1 you. We -- the Department of Energy's trying hard

2 to make these meetings accessible to all via the

3 Web. Please keep your telephones on mute so we

4 don't get feedback here in the room, and if you

5 raise your hand with the software you have

6 available, we probably -- it's worked in the past,

7 not a hundred percent of the time, but most of the

8 time, we can fit you into the conversation here in

9 the room, hear your question or comment.

10 And individuals that are joining us via

11 the Web, the Department would also encourage you

12 to submit written comments in addition to verbal

13 comments, anything that you think is relevant to

14 this rulemaking.

15 So that's all I have here at the outset.

16 Questions and comments before I hand it back to

17 Jim Raba? Jim Raba.

18 MR. RABA: Well, for openers, today's

19 public meeting will address the procedural and

20 analytical framework, models, and other analysis

21 tools that the Department of Energy would use to

22 evaluate efficiency standards for this equipment.

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1 As we move forward today, we encourage

2 you to consider and discuss the process and

3 approach the Department intends to take.

4 Throughout the rulemaking process, we encourage

5 you and other interested parties to submit any

6 pertinent information, data, and written comments.

7 Before we address the regulatory

8 history, steps in the standards rulemaking

9 process, market and technology assessment, the

10 engineering analysis, life- cycle cost analysis,

11 national impacts, and more, we want to hear from

12 you. During today's presentations, certain issues

13 will be prompted for discussion on slides such as

14 this; otherwise, comments about any part of the

15 presentation are welcome throughout.

16 So does anybody wish to make an opening

17 statement or brief comments at this time?

18 MR. BROOKMAN: Bruce, please. Please

19 say your name.

20 MR. LUNG: Thank you. My name is Robert

21 Bruce Lung, representing the American Council for

22 an Energy-Efficient Economy. We would like to

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1 make a brief opening statement for the record.

2 The American Council for an Energy3 Efficient Economy, ACEEE, as well as the Appliance

4 Standards Awareness Project, ASAP, are pleased to

5 participate in today's hearing and in the air

6 compressor rulemaking process. We welcome DOE's

7 exploration of this issue and look forward to

8 engaging the DOE, its contractors, compressor

9 manufacturers, associations, consultants, and

10 users and the energy efficiency advocacy community

11 in this important effort.

12 We believe that industrial compressed

13 air systems offer significant potential for energy

14 savings and that the DOE has done a substantial

15 amount of good work in assessing compressed air

16 system energy savings potential. In addition, the

17 Department has a strong track record of

18 collaborating with compressed air stakeholders to

19 develop tools, written materials, and trainings

20 that have yielded significant energy savings and

21 greater awareness of compressed air system energy

22 efficiency in U.S. manufacturing.

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1 There may be an energy efficiency

2 opportunity and other advantages to a component3 based approach for air compressors, which makes

4 this effort conceptually appealing to the energy

5 efficiency advocacy community. To this end, we

6 urge the Department to closely consult with the

7 manufacturers, as they have considerable

8 experience, including testing procedures and data,

9 in this particular area. We are very interested in

10 a potential for an air compressor standard that

11 yields energy savings without placing an undue

12 burden on compressor manufacturers or end users.

13 We would like to thank the Department

14 for the opportunity to participate in this very

15 important rulemaking, and we look forward to

16 continuing to work with the Department, the

17 compressor manufacturers, and other stakeholders

18 to develop an appropriate standard. Thank you.

19 MR. BROOKMAN: Thank you. Other

20 comments here at the outset? Yes. Rick?

21 MR. STASYSHAN: I'm Rick Stasyshan from

22 the Compressed Air and Gas Institute. We

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1 represent manufacturers of compressor products.

2 We did send a response on February 24th addressing

3 the initial rules document, but I'd like to just

4 comment on a few of the paragraphs from that memo.

5 We appreciate the Department of interest

6 -- the Department of Energy's interest in

7 compressors and compressed air systems. We look

8 forward to working with the Department to improve

9 efficiency and the effectiveness of our industry's

10 products in harmony with Objective 6 of our

11 mission, which is to cooperate with governmental,

12 Department, and agencies and other bodies in

13 matters affecting the industry.

14 In fact, CAGI's been working to achieve

15 the same goals for decades, working with the

16 development of standards that provide true

17 packaged extended product performance. We have

18 devoted significant resources, not only to the

19 development of the standards, but also the

20 development of training and educational materials

21 designed to educate users and purchasers regarding

22 the proper selection and operation of compressed

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1 air systems, compressors, and other compressed air

2 equipment.

3 To that end, we believe we can assist

4 the Department of Energy in this project on just

5 about all the talking points in the rules

6 document. Thank you.

7 MR. BROOKMAN: Thank you. Additional

8 comments here before we proceed to the slide deck?

9 Okay. Let's proceed.

10 MR. RABA: Here's a snapshot of the

11 topics we will address, including scope, test

12 procedures, market, engineering, generic price

13 determination, life-cycle cost, shipments,

14 national impacts, and the rulemaking process.

15 The Energy Policy and Conservation Act,

16 as amended, EPCA, covers various commercial and

17 industrial equipment, including compressors, but

18 the Act does not define the term compressor, nor

19 does it prescribe test procedures in energy

20 efficiency standards. Consequently, the

21 Department is today beginning the rulemaking

22 process for such matters. I invite Michael Kido,

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1 Department of Energy General Counsel, to make a

2 few remarks.

3 MR. KIDO: Thanks, Jim. Just to sort of

4 expand on that slide here, I just want to

5 emphasize that where we are in this whole process

6 is, really, we're trying to gather enough factual

7 information to help inform any rulemaking that we

8 actually initiated with the proposed standards as

9 well as potential test procedures for compressors.

10 Right now, as the slide indicates, we

11 have issued a Notice of Proposed Determination.

12 There has not been a notice of a final

13 determination as to the coverage of compressors.

14 So that is still something that is pending, but

15 along with that determination, in this meeting, it

16 would be helpful for the Department to get a lot

17 of feedback from folks in terms of the issues that

18 are presented in this framework document that

19 we've issued, and that would include issues

20 concerning the scope of coverage as well as how do

21 we define what a compressor actually is. We've

22 got three different options that we've laid out,

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1 so we're interested in everyone's feedback on

2 that. And I'm sure the folks at LBNL and Navigant

3 will lay out some additional pieces regarding the

4 types of data that we actually need to help us in

5 framing any potential regulatory requirements for

6 compressors.

7 So, like I said before, given that we've

8 -- we're in this sort of proposed determination

9 stage, along with having these various elements

10 that we've laid out for the framework document,

11 we're really interested in getting as much

12 feedback from everyone here as possible.

13 MR. BROOKMAN: Thank you. You have

14 questions for Michael? Okay.

15 MR. RABA: The energy conservation

16 standards and test procedures rulemakings are

17 separate processes that have integrated timelines;

18 test procedures, about one and a half years;

19 standards, about three years.

20 EPCA requires that the Department of

21 Energy, in sum, consider economic impacts, life22 cycle cost savings compared to increased

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1 efficiency, total projected energy savings, impact

2 on utility or performance, effect on competition,

3 and other factors.

4 The framework stage provides an overview

5 of a rulemaking process and invites interested

6 parties to participate. The preliminary analysis

7 is a first look at compressor designs,

8 distribution channels and markups, energy use,

9 life-cycle cost and payback period for the user,

10 shipments, national energy savings, and potential

11 impacts on manufacturers.

12 The Notice of Proposed Rulemaking

13 addresses comments it received in response to the

14 preliminary analysis and proposes energy

15 conservation standards. It encourages additional

16 comment from interested parties, and it gives

17 notice of a public meeting.

18 The final rule addresses comments

19 received as a result of the proposed rule and

20 revisions of the analyses and promulgates energy

21 efficiency standards levels. Note where it talks

22 about the establishment of the dates for new

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1 standards. The effective date, when it officially

2 enters the Federal Register, the clock starts.

3 The compliance date, when all equipment must meet

4 the new standards, that's when the alarm goes off.

5 The clock starts, and then the compliance date.

6 Effective date, compliance date.

7 The Notice of Proposed Rulemaking for

8 the test procedure takes a different route, but

9 similar. In view of the comments as a result of

10 today's meeting, DOE will examine the test

11 procedures for commercial and industrial

12 compressors and consider any updates or revisions.

13 The test procedure rule will provide opportunity

14 for comment, including at today’s public meeting.

15 Similar to the final rulemaking process

16 for energy efficiency standards, DOE will consider

17 comments received, make revisions to the proposed

18 rule as needed, establish an effective date, and

19 promulgate the test procedures that will be used

20 for compliance with the efficiency standards.

21 In summary, here is the projected

22 timeline, from the notice of today's public

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1 meeting to the compliance date.

2 Are there any questions? Kurt -- yes?

3 MR. BROOKMAN: Andrew deLaski.

4 MR. DELASKI: Hi. This is probably a

5 question for Michael. Michael, can you remind us,

6 is the time period within the final rule and the

7 compliance date, is that statutory for the new --

8 for the commercial products that are newly

9 covered?

10 MR. KIDO: Yeah. That -- Michael Kido,

11 DOE. That's a statutorily based revision. There's

12 a default provision that we would have to apply in

13 this instance, and that's a five-year spread.

14 MR. DELASKI: Thanks.

15 MR. BROOKMAN: Okay.

16 MR. RABA: Further questions? Thank

17 you, Andrew. Kurt Klinke, Navigant Consulting,

18 will cover scope and test procedures.

19 MR. KLINKE: So, again, to introduce

20 myself, my name is Kurt Klinke. I work for

21 Navigant Consulting, who's the technical assistant

22 to the Department of Energy in all of their

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1 rulemaking processes.

2 So first to start over -- to start

3 things, we want to go over the scope of coverage.

4 While the program is called the "commercial and

5 industrial air compressors," we only plan on

6 covering a subset of those. However, to start out

7 with, because this is a new product, there is

8 currently no statutory definition for compressors,

9 which is -- which there would be for a lot of the

10 other products that we cover.

11 As such, DOE is considering the

12 following definition for a compressor, which comes

13 from the International Organization for

14 Standardization

15 Technical Report 12942, and it is: "A

16 machine or apparatus converting different types of

17 energy into the potential energy of gas pressure

18 for displacement and compression of gaseous media

19 to any higher pressure values above atmospheric

20 pressure with pressure-increase ratios exceeding

21 1.1."

22 So that would be the basis for where we

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1 start with the compressors. And then as part of

2 covering only a subset, ISO Technical Report 12942

3 provides a means to further categorize and

4 classify compressors based on a variety of

5 equipment characteristics. We are considering

6 several different characteristics for further

7 classification. Those include the compression

8 principles, and I'll be going over each one of

9 these in a little bit further detail in following

10 slides, if you have any specific questions about

11 them. Go ahead.

12 MR. BROOKMAN: We've got a question

13 right here. Rick?

14 MR. STASYSHAN: Rick Stasyshan,

15 Compressed Air and Gas Institute. Are we to

16 comment now on --

17 MR. BROOKMAN: Why don't you wait until

18 he just covers a little bit --

19 MR. STASYSHAN: Okay. Very good.

20 MR. BROOKMAN: This -- at the bottom of

21 this slide would be the time to comment, I think.

22 MR. STASYSHAN: Excellent. Okay.

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1 MR. KLINKE: So compression principles,

2 input energy forms used, specifically electricity,

3 fossil fuels, et cetera, and the driver types, the

4 equipment capacity, and the equipment system

5 boundary.

6 So now the first item that was included

7 in the framework document for specific stakeholder

8 feedback is we request comment on our initial

9 compressor definition. In particular, DOE

10 requests comment about the pressure ratio of 1.1

11 specified in the definition.

12 MR. BROOKMAN: Rick?

13 MR. STASYSHAN: Rick Stasyshan,

14 Compressed Air and Gas Institute. You know, as we

15 reviewed the document, we think 1.1 may be too low

16 to start with the objection of the rulemaking

17 document. Some of the compressors with these

18 lower compression ratios fall outside the scope of

19 the three-phase electrics mentioned later on, and

20 while you included 1 to 500 horsepower in later

21 documents, many of the lower horsepowers are

22 single-phase electrics and would be eliminated

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1 automatically anyway. So we suggested

2 consideration of higher compression ratios.

3 Compressed Air and Gas Institute would be more

4 than willing to assist with those definitions.

5 MR. BROOKMAN: Would you suggest what it

6 is now?

7 MR. STASYSHAN: In our documentation, we

8 put -- suggested pressure ratios of 2.5, but,

9 again, we'd be prepared to provide additional

10 documentation if required.

11 MR. BROOKMAN: Thank you. Louis Starr?

12 MR. STARR: Louis Starr of Northwest

13 Energy Efficiency Alliance. One thing to consider

14 currently under the fan rulemaking, they defined

15 blowers between 1.1 and 1.2, and then the other

16 point is, is, depending on where you select that

17 next ratio, pressure ratio, whether it's 2.52 or

18 whatever, you probably want to think about -- in

19 terms of not leaving a loophole between a pressure

20 ratio that -- from the -- that's a blower to

21 something that's a compressor.

22 So perhaps defining a horsepower will

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1 help. In other words, you define the pressure

2 ratio, but then let the horsepower be a separate

3 limitation, and then it'll naturally take care of

4 some of that and prevent a loophole so it'll get

5 the outcome of having a reasonable metric to

6 measure the efficiency of the compressors with a

7 scope of coverage that's reasonable, but based

8 upon horsepower rating rather than on the pressure

9 ratio.

10 So set the pressure ratio wide, but then

11 set a secondary one, the horsepower, and then

12 you'll get the adequate coverage and make

13 everybody happy at the same time.

14 MR. BROOKMAN: Okay. Thank you.

15 MR. KIDO: Can I follow up?

16 MR. BROOKMAN: Yes. Michael Kido?

17 MR. KIDO: Michael Kido, DOE. Just to

18 follow up, do you have a particular combination in

19 mind, or is that just sort of a general suggestion

20 in terms of how we ought to approach this?

21 MR. BROOKMAN: Louis?

22 MR. STARR: I do, but I was thinking

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1 maybe we'd wait until we get to that part where we

2 start talking about single phase and the

3 horsepower coverage.

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

5 Yes, Andrew deLaski?

6 MR. DELASKI: Just a follow-up question

7 for Rick. Rick, you're referencing a document

8 that I haven't seen, and I'm wondering was that

9 submitted to the Department, and is it on the

10 record now, or is that something that

11 MR. STASYSHAN: Yes, we submitted it

12 according to the first written -- we were given an

13 opportunity to provide written comments. We did

14 so and met the February 24th deadline.

15 MR. DELASKI: Okay. I haven't seen it

16 on the docket. I checked it yesterday, and it

17 wasn't there, so

18 MR. KIDO: We'll check again.

19 MR. BROOKMAN: Yeah. Michael? Michael

20 Kido.

21 MR. KIDO: Yeah. We'll check into that

22 and make sure it's posted.

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1 MR. BROOKMAN: Thanks, Andrew. Okay.

2 MR. KLINKE: All right. Now we'll be

3 moving into a couple of these different

4 characteristics and doing a little bit -- talking

5 about them a little bit more. The first is the

6 compression principles. DOE is considering

7 covering positive-displacement, dynamic, and

8 combined compressors. Again, we're using the

9 definitions that are currently in the ISO

10 Technical Report.

11 As for positive-displacement compressor,

12 it's a compressor machine in which the admissions

13 and compression of successive volumes of the

14 gaseous medium are performed periodically by

15 forced expansion and diminution of at least one

16 closed space in at least one working chamber by

17 means of displacement of at least one moving

18 member or by the displacement and forced discharge

19 of the gaseous medium into the high- pressure

20 area.

21 Definition for dynamic compressor, a

22 compressor machine in which the gas pressure

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1 increase is achieved in continuous flow

2 essentially by increasing its kinetic energy in

3 the flow path of the machine due to acceleration

4 to the high velocities by mechanical action of

5 blades placed on a rapid rotating wheel and

6 further transformation of the kinetic energy into

7 the potential energy of the elevated pressure by

8 successive deceleration of the said flow.

9 Then moving on to combined compressor,

10 it's a compressor machine in which the compression

11 of gaseous medium or media is performed

12 simultaneously or successively by dynamic

13 positive-displacement compressors driven by a

14 common prime mover.

15 So those are the three types of

16 compressors based on compression principle that we

17 are currently considering covering, and now we

18 have some additional feedback requests. First,

19 DOE requests comments on whether it should cover

20 these three different kinds of compressors and

21 whether any other types of compressors should be

22 considered.

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1 MR. BROOKMAN: Rick?

2 MR. STASYSHAN: Rick Stasyshan,

3 Compressed Air and Gas Institute. Compressed Air

4 and Gas' comment is the types of compressors

5 proposed should be the ones considered for the

6 standard. Even those three broad technologies

7 will need to be broken into subsets based on type

8 application and pressure requirements. Compressed

9 Air and Gas Institute can assist DOE with this

10 effort. An alternative approach may be to look at

11 the application ranges to get customer-centered

12 perspective. This approach is based on the

13 rationale that a particular application will

14 justify the type of compressor technology that is

15 ultimately used.

16 MR. BROOKMAN: Thank you. Louis Starr?

17 MR. STARR: So this kind of goes -- it

18 looks like you're breaking it into classes here.

19 Another thought too is I guess there's been

20 discussion up here to extended product; in other

21 words, including things besides just the

22 compressor. If that is the intent, it seems like

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1 you may need to define your first definition of

2 compressors a little more broadly to capture some

3 of the other components you might be interested

4 in, similar to what they may have done in the pump

5 rulemaking or negotiated rule.

6 So just something to think about. If

7 you want to be more than just the compressor,

8 you're going to have to broaden your definition a

9 little bit to capture that.

10 MR. BROOKMAN: Offhand, do you know what

11 additional elements would be included in the broad

12 definition?

13 MR. STARR: Well, it would have to --

14 I'll have to look into that, but it would just be

15 very similar to the pump one. But it sort of

16 depends, first, whether you think you're going to

17 cover that or not, so if it seems like -- after

18 further discussion, if it seems like we want to

19 increase that category class, then you need to go

20 back and adjust the compressor, but it seems

21 premature, before we've had the discussion of

22 whether it makes sense to include that or not, and

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1 I think they're going to talk about the different

2 classes of pumps, whether that -- or, sorry, air

3 compressor, whether that makes sense or not.

4 MR. BROOKMAN: Okay.

5 MR. STARR: I'm sure there's a lot of

6 opinions on that.

7 MR. BROOKMAN: Rick, please.

8 MR. STASYSHAN: You know, too, his

9 comment, I think that'll be covered in Point 1.9.

10 MR. BROOKMAN: Yeah.

11 MR. STASYSHAN: So if we could hold off

12 until that point, I think it'll be addressed at

13 that point, where we talk about definition of

14 extended product.

15 MR. BROOKMAN: Great. Thank you.

16 Chris, did you --

17 MR. BOLDUC: Yeah, yeah.

18 MR. BROOKMAN: Comment? Question?

19 MR. BOLDUC: Chris Bolduc, LBL. This is

20 a question for Rick. I was hoping you could

21 expand upon your example, application ranges for

22 scope of coverage that you mentioned in your

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1 previous --

2 MR. STASYSHAN: You know, there are

3 different pressures that would have -- higher the

4 pressure, the higher the energy consumption. I

5 think if we start breaking into subsets, we may

6 want to look at that and not just paint, say, a

7 particular horsepower size by a broad brush

8 because a higher pressure compressor would consume

9 more energy. So, you know, whether it's covered

10 in application pressure ranges, subset of

11 definition of sub-products. I think we're going to

12 need to get into that as the process develops.

13 MR. BROOKMAN: Thank you.

14 MR. KLINKE: In reference to that

15 comment, right now, we're not going over equipment

16 classes, which seems kind of like what we're

17 discussing here is which -- how we should class

18 them once we do start setting standards. We'll

19 actually get into that a little bit later in the

20 presentation. Right now we're just trying to get

21 what is going to be covered, and then we'll

22 actually -- we do have some sections on how we're

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1 thinking about then further breaking them down in

2 regards to classing them for specific standards

3 and things like that.

4 MR. BROOKMAN: Jordan?

5 MR. DORIA: Yeah, I think that makes

6 sense with regard to pressure, and I was going to

7 sort of hold off for that reason, but at the same

8 time, they're not entirely divorced, because when

9 you start thinking about the actual product

10 categories, it's at least conceivable that there

11 might be some pressure ranges, whether it's a

12 very, very small amount of product, and it should

13 eventually actually then sort of flow back into

14 the actual definition and scope of coverage,

15 right?

16 So that's at least a possibility, so we

17 just want to sort of flag that, as we have that

18 discussion, to decide, well, is it every pressure

19 range, or is it just maybe a subset that

20 represents a majority of the market or something?

21 MR. BROOKMAN: Okay. Thank you. You

22 want to queue Item 1.3 and 1.4?

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1 MR. KLINKE: Right. So Item 1.3, DOE

2 requests comment on the scope of coverage for

3 compressors, whether it should be limited to only

4 air compressors, and the potential for

5 circumvention, in the realm of labeling something

6 as possibly just another gas compressor that could

7 be used just for air in a method of circumventing

8 any actual standards here.

9 And then Item 1.4, DOE requests shipping

10 data for compressor equipment based on the type of

11 gas compressed. DOE also seeks comment regarding

12 the technical and relative energy use differences,

13 if there are any, between air and non-air

14 compressors.

15 MR. BROOKMAN: Let's start with 1.3

16 first. Laura?

17 MS. PETRILLO-GROH: Yeah, hi. Laura

18 Petrillo-Groh, AHRI. While I don't have a

19 specific comment about whether it should be

20 limited to only air compressors, there is concern

21 that there's the possibility of covering, you

22 know, compressors used in HVACR equipment, which

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1 are already covered. So if there's a possibility

2 of excluding, you know, discharge fluids from this

3 or any new definition excluding HVACR equipment,

4 I'm not sure if the end use is the way to go, but

5 that's my comment.

6 MR. BROOKMAN: Okay. Rick?

7 MS. PETRILLO-GROH: Thank you.

8 MR. STASYSHAN: Uh-huh. Rick Stasyshan,

9 Compressed Air and Gas Institute. I'll start with

10 1.2 -- or, sorry, 1.3. The -- while the

11 technologies in manufacturing of compressors for

12 air and gas compression are indeed similar, there

13 are additional safety equipment utilized in gas

14 compression based on the types of gas to be

15 compressed. The DOE might consider initially only

16 air compressors. Compressors that have an inlet

17 open to the atmosphere should be the type

18 initially considered. Compression of other gases

19 require the inlet be piped in from a source of

20 that gas and not open to atmosphere.

21 Generally, air compressors convert

22 different types of energy into potential energy of

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1 compressed air or air pressure. Gas compressors

2 generally compress a particular gas for further

3 processing. If a compressor's inlet is open to

4 atmosphere, it would be very difficult to classify

5 it as anything else but an air compressor.

6 MR. BROOKMAN: Louis Starr?

7 MR. STARR: I think maybe something that

8 might help the DOE understand whether it makes

9 sense to just focus on air or something other than

10 air, maybe an understanding of what kind of the

11 marketplace looks like in terms of number of units

12 that are used strictly for air and what's the gas,

13 kind of understanding the market share and then

14 how that relates to energy, might be helpful.

15 Maybe you could comment on that, just a general

16 overall idea.

17 MR. BROOKMAN: Rick, and which also then

18 queues up Item 1.4 as well.

19 MR. STASYSHAN: That's correct. Again,

20 Rick Stasyshan, Compressed Air and Gas Institute.

21 CAGI should be able to develop statistics from its

22 members on this topic; for air compressors only,

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1 not gas compressors. Pulling this data will take

2 some time, resources, and expense, but we are

3 prepared to do that.

4 There are numerous gas compressor

5 packagers who purchase components, including bare

6 compressors, from a number of companies that are

7 not CAGI members. Obtaining this data may be --

8 prove to be a challenge to your organization.

9 We should note, while our membership

10 does not -- does include the major players in many

11 segments of the market, there are numerous air and

12 gas manufacturers that are not a part of CAGI. In

13 the case of reciprocating air compressors, there

14 are a number of small businesses known as

15 packagers or assemblers who package bare

16 compressor units with tanks and controls. Some of

17 those packagers produce sophisticated engineering

18 application; others are basic unit and often

19 imported compressor pumps, frequently selling to

20 an end user market under a brand name.

21 It is possible that there are more than

22 100 small companies that fall into that category.

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1 Despite many of these businesses being classified

2 as small, their collective market and share of

3 reciprocating compressors could be quite large.

4 Any regulation regarding reciprocating compressors

5 should consider the impact on these small

6 assemblers while recognizing that if a group is

7 excluded, it'll put (inaudible) manufacturers at a

8 disadvantage.

9 MR. BROOKMAN: Okay. Thank you. Do we

10 have additional comments on particularly 1.3 and

11 1.4? Okay.

12 MR. KLINKE: Moving along, we'll move

13 into the second -- input energy form used. So

14 DOE's considering covering the following

15 compressor types based on the input energy form

16 used: electrically driven equipment that operated

17 on three-phase alternating line current -- we're

18 currently considering not including units

19 operating on single- phase current -- and fossil

20 fuel-driven equipment. That includes natural gas,

21 diesel fuel, and gasoline.

22 Some feedback request items, Item 1.6,

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1 DOE requests comment on its initial approach to

2 address all types of compressors regardless of the

3 input energy form used. In addition, DOE requests

4 comment on its initial approach for electrically

5 driven competitors that would address only those

6 that operate on three-phase alternating current.

7 And then an additional request, 1.7, DOE requests

8 shipment data for compressor equipment based on

9 the input energy form used.

10 MR. BROOKMAN: Rick?

11 MR. STASYSHAN: You know, to start with

12 1.6, limiting to three-phase will eliminate some

13 of the compression ratios below the 2.5 that I

14 mentioned earlier in Comment 1.1. One of the

15 lower pressure compressors and those with less

16 than 10 horsepower are indeed single-phase, so

17 that definition may take care of itself.

18 As for 1.7, requesting data on

19 compressors for the energy used, for electric

20 compressors, we are prepared to assist with the

21 data as we get down to the final definitions.

22 Data may be limited from our membership on fossil

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1 fuel or natural gas-driven compressors.

2 MR. BROOKMAN: Rick, did you want to

3 comment on the other fuel types and whether all

4 types of compressors, regardless of the input

5 energy form, are used? Do you want to comment on

6 that?

7 MR. STASYSHAN: When you look at energy

8 consumption, obviously electric-powered, electric

9 motor-driven compressors are indeed logical to

10 attack from this standpoint. If you look at the

11 fossil fuel- driven, natural gas-driven, diesel

12 gasoline-driven compressors, most of those are

13 intermittently used. Typically in construction, on

14 some standby applications, you know, they -- where

15 an industrial compressor typically runs a

16 production -- or a process on a consistent and

17 regular basis, typically many of these fossil18 driven fuel compressors are intermittent, and we

19 may consume a lot of time in this process, not to

20 get the benefit of the overall scope of the

21 project.

22 MR. BROOKMAN: Would the numbers that

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1 the -- the shipments data, the numbers that you

2 hope to compile, do you think it'll -- will it

3 break out those fuel types?

4 MR. STASYSHAN: We would have only a

5 partial, because many of the members that -- or

6 many of the companies that manufacture these types

7 of products are not members of the Compressed Air

8 and Gas Institute.

9 MR. BROOKMAN: I see. Okay. Louis

10 Starr?

11 MR. STARR: So one concern I might have

12 on Item 1.6 is the three-phase versus single13 phase. It sounds a good enough idea. The only

14 concern I might have is, is that oftentimes, it's

15 -- if you're pretty close and you can switch it

16 over to single-phase to avoid regulation and you

17 have a three-phase compressor, but if you switch

18 it to single-phase, you can avoid some of the

19 regulations, you might create a loophole there.

20 The idea that differentiating the market

21 between hobby compressors and commercials is good

22 enough in that concept, but something might be

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1 considered, and you might end up getting some

2 unintended consequences there, so I would kind of

3 think about that.

4 And then on the fossil-driven equipment,

5 I think it would be pretty important to figure

6 out, for the same reason, that we don't have

7 people moving over, selecting other type fuel

8 equipment in order to avoid regulation with the

9 same piece that's going to drive -- perhaps if

10 CAGI's just doing electrical- driven equipment and

11 the other ones are doing that, it could actually

12 shift your business from the product that you make

13 to something that someone else makes, and that

14 would be probably not a favorable thing for

15 anybody.

16 MR. BROOKMAN: Okay. Thank you.

17 Michael Kido?

18 MR. KIDO: Michael Kido, DOE. Just for

19 both of you, I wanted to follow up. Are there any

20 sources of data that you could refer us to on the

21 fossil fuel- driven compressor side? Because I

22 know, Rick, you said that CAGI has a number of --

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1 I guess a lot of data regarding the electrically

2 driven ones. Is there someplace that you all can

3 sort of recommend that we at least take a look at

4 for the fossil fuel-driven side?

5 MR. STASYSHAN: I don't have at this

6 time, but we'd be willing to try to come up with a

7 source.

8 MR. KIDO: Okay.

9 MR. BROOKMAN: Thank you, Rick. Louis?

10 MR. STARR: So Louis Starr with NEEA.

11 We are doing an industrial survey of 120 sites in

12 our service territory, our four-state area, and,

13 you know, I haven't actually see the database yet

14 to see what that has, but in theory, we were

15 trying to collect that kind of information, so I

16 am trying to work with LBNL, who's also interested

17 in that data, so the hope is, is that here in five

18 or six months, we may have the data collected, and

19 then we'll be able to see what information's

20 available based upon that.

21 MR. BROOKMAN: Thank you. Please say

22 your name.

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1 MR. PERRY: My name is Wayne Perry. I'm

2 a Technical Director for Kaeser Compressors.

3 MR. BROOKMAN: Uh-huh.

4 MR. PERRY: Concerning three-phase

5 versus single-phase, we worked with UL trying to

6 make a breakout similar to that for UL 1450, and

7 one of our suggestions was plug-connected. That

8 can be 220-volt or 120-volt, but if it's hardwired

9 in, that's where the break came. And I think

10 that's what CAGI is thinking as well as far as

11 breaking the single-phase and the three-phase. We

12 want to get the hobby compressors out of that.

13 They account for a huge number of unit sales and

14 less than 2 percent of the energy consumption.

15 And concerning the fossil fuels, you're

16 going to find, if industry is using these types of

17 fossil fuel compressors, they're on standby,

18 they're horribly expensive to operate. If they

19 could possibly operate on electricity, they're

20 going to operate on electricity.

21 Natural gas compressors, the ones that I

22 have seen have been strictly standby for plants

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1 that could not afford to have their compressed air

2 system down. If they lost electricity, these

3 simply operated until they got the electricity

4 back, and then shut down. That's been my

5 experience with the fossil fuel ones, in addition

6 to what Rick said about construction. Most of

7 it's really construction.

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

9 Thank you. Louis?

10 MR. STARR: Just one follow-up question.

11 So the ideal would be -- the distinction would be

12 a single-phase with a cord, or is it three-phase,

13 and then -- does it -- does the having a cord in

14 there help; in other words, a plug-in thing that,

15 if they're going to hardwire it, they're not going

16 to make the change (inaudible)?

17 MR. STASYSHAN: Having the cord helps.

18 I mean, it's -- but, again, I think as you look at

19 many of the compressors below 10 horsepower, most

20 of those are single-phase.

21 MR. BROOKMAN: Well, thank you, Rick.

22 that's helpful. Chris, do you want to

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1 question or a comment here?

2 MR. BOLDUC: No, it was answered by

3 Wayne.

4 MR. BROOKMAN: Answered -- okay. Thank

5 you. We have a comment -- someone joining us via

6 the Web. Bruce McFee says, "AEM has statistics on

7 diesel engine-driven compressors." So thanks,

8 Bruce, for providing that data. That'll be very

9 helpful.

10 Additional comments on this series of

11 questions here? A few individuals have joined us

12 that didn't get a chance to introduce themselves

13 at the outset. We'll start over here. Use the

14 microphone. Say your name and organization

15 affiliation. Wayne?

16 MR. PERRY: My name is Wayne Perry. I'm

17 the Technical Director for Kaeser, and I've worked

18 with DOE for a number of years and LBNL on a lot

19 of these types of projects.

20 MR. BROOKMAN: Thank you.

21 MR. RAUER: My name is Werner Rauer. I

22 also work for Kaeser Compressors. I'm the Product

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1 Manager for Compressors at Kaeser in

2 Fredericksburg, Virginia.

3 MR. BROOKMAN: Okay.

4 MR. BURT: Lane Burt with Ember

5 Strategies, Consultant to the Natural Resources

6 Defense Council.

7 MR. BROOKMAN: Thank you. We'll have to

8 get that microphone there next time.

9 MR. BURT: Should I do it again?

10 MR. BROOKMAN: No. Okay. Let's move

11 on.

12 MR. KLINKE: Moving on. As we've

13 referenced before, equipment size, DOE is

14 currently considering covering anything from 1 to

15 500 horsepower. DOE seeks comment on this current

16 proposal.

17 MR. BROOKMAN: One to 500. Rick?

18 MR. STASYSHAN: Okay. You know, many

19 compressors, less than 10 horsepower, as I

20 mentioned, are single-phase. Inclusion of those

21 lower HPs may contradict Items 1.6 and 1.1, but

22 this is a good range.

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1 MR. BROOKMAN: Okay. Jordan?

2 MR. DORIA: Jordan Doria with Ingersoll3 Rand. We don't have a firm recommendation at this

4 time as to a different range. We would just sort

5 of note that it's our understanding that this

6 range was largely selected to correspond to the

7 current range for motors, and I think we would

8 ultimately want a range that makes more sense for

9 compressors based on the market.

10 And specifically thinking about, you

11 know, the proposal to include centrifugal

12 compressors, there are centrifugal compressors

13 below 500 horsepower. A very significant portion

14 of the market is above that. So I think we would

15 just want to try and figure out does it make sense

16 to cover -- you know, or what is the interplay

17 between the horsepower coverage range and certain

18 compressor types that are proposed for coverage

19 here? So, again, not a sort of firm

20 recommendation at this time; just something we

21 think demands being revisited at some point.

22 MR. BROOKMAN: Okay. Thank you. Louis?

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1 MR. STARR: So this is more of, I guess,

2 a question for the Department of Energy. Does it

3 make sense to have a broad range of horsepower and

4 then the subclasses kind of exclude things that

5 don't make sense or set -- how would you

6 anticipate regulating, you know, if they have --

7 screw compressors or a certain range make sense,

8 yet maybe reciprocating, it's a different kind of

9 range. Would you define it broadly and then go

10 into subclasses to exclude, or what would be the

11 general thought on that?

12 MR. KIDO: Michael Kido, DOE. I don't

13 think the Department's actually come up with a

14 firm approach at this point, which is why we have

15 this framework meeting. So we're trying to sort

16 of figure out which way to go, and I guess,

17 depending on what the facts tell us, we'll move in

18 that direction. So we've got an open mind right

19 now.

20 MR. KLINKE: As a short add-on to that,

21 a lot of the things that we've -- the

22 considerations that we have right now are about as

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1 broad as we can make them so that we could then

2 get information from you and get facts and then

3 pare them down from there, as opposed to, at some

4 later date, possibly having to expand them, which

5 would then -- we wouldn't have the data,

6 necessarily, for it or anything like that. So at

7 this current juncture, we are kind of trying to

8 hit everything that we can so that we can then get

9 all the data possible and take it down from there.

10 MR. BROOKMAN: Additional comments here?

11 Yes, Jordan?

12 MR. DORIA: Just a comment that I think

13 it connects here and certainly to other carriers

14 we're going to discuss, just to sort of mention

15 for everyone's benefit that, as many of you

16 probably know, the EU Commission's going forward

17 with its Lot 31 regulations for air compressor

18 efficiency.

19 You know, we have a general view that,

20 for the industry, that we think it's beneficial to

21 try and have as much similarity in different

22 regulatory approaches and different markets as

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1 possible, considering that a lot of the OEMs,

2 including Ingersoll-Rand, sell globally. China's

3 the only country that has minimum standards today.

4 The EU will in the not-too-distant future.

5 You know, we think, in general, it looks

6 like the scope of coverage will be fairly well7 aligned, but there are other areas in terms of the

8 product categories as well as the actual

9 efficiency metrics used where we're not sure that

10 things are necessarily moving in the same

11 direction.

12 So we would just encourage the

13 Department to stay, you know, abreast of what the

14 EU's doing, and anything that we could do to

15 provide sort of some direct links there, even to

16 the form of something like a briefing on exactly

17 where the EU is in this process and what it's

18 proposing, we'd be happy to do that.

19 MR. BROOKMAN: Excellent. That's

20 helpful. Are you participating in the EU stuff?

21 MR. DORIA: As a company, we are. I'm

22 sort of tangentially connected to it, but we have

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1 some people that are very actively engaged through

2 PNEUROP, which is sort of the CAGI equivalent in

3 Europe.

4 MR. BROOKMAN: So for those of you that

5 are aware and participating in the EU efforts, I

6 think the Department would really benefit for your

7 interpretation of what's going on there in

8 considerable detail, because I know that that

9 alignment could matter a lot to the industry.

10 Rick, comment here?

11 MR. STASYSHAN: Compressed Air and Gas

12 Institute, as a trade association, and many of its

13 individual members are participating in those

14 discussions.

15 MR. BROOKMAN: Okay. Thank you. Wayne?

16 MR. PERRY: I would also like to add

17 that you can -- there are a number of study papers

18 that have already been published on Lot 31 that

19 outline how they intend to go about doing this,

20 and I might add that in trying to figure out how

21 to set efficiency standards in Europe, they're

22 using the CAGI data sheets as their basis. They

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1 said there's some difference between 50 hertz and

2 60 hertz and things like that.

3 But the Compressed Air and Gas Institute

4 is the only organization that has collected

5 verified efficiency data, and so they went to all

6 of the members' companies and downloaded the data

7 sheets to start compiling their list and figuring

8 out how they're going to start setting their

9 efficiency regulations.

10 MR. BROOKMAN: Okay. Thank you.

11 Additional comments here? Okay.

12 MR. KLINKE: All right. Moving on,

13 we'll start discussing the equipment system

14 boundary. In the first publication that we put

15 out, the Proposed Determination of Coverage, DOE

16 considered three different possibilities. They

17 were the bare compressor, which is just basically

18 the air end, which is only the compressor chamber

19 where air is compressed; the compressor package,

20 which is the bare compressor plus any driver --

21 for example, an electric motor -- and may include

22 other equipment, such as gears, drains, or on-

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1 board controls; and, finally, the compressed air

2 system, which is the -- all componentry that would

3 be attached to a compressor package, including

4 components starting from the air intake to the

5 final end point of use.

6 As part of this new framework document,

7 DOE is now considering covering only the

8 compressor package, for several reasons. The

9 myriad of unique installation configurations for a

10 compressed air system leads to testing and

11 certification issues, and there are potential

12 meaningful efficiency improvements for the

13 compressor package over just a bare compressor,

14 just the air end.

15 So Item 1.9, DOE requests comment on its

16 approach to cover compressors package rather than

17 either the bare compressor or the full compressor

18 -- compressed air system.

19 MR. BROOKMAN: Rick?

20 MR. STASYSHAN: You know, I think that's

21 a practical approach, to consider the package

22 versus the bare compressor. As noted elsewhere in

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1 our commentary that this industry is somewhat

2 different than others may be addressed by the DOE

3 and the fact that, you know, sometimes words are

4 used in the way of system, and that would include

5 the compressor air treatment piping, et cetera,

6 proper maintenance design, and which will generate

7 overall real improvements in efficiency, but

8 difficult to regulate.

9 In this industry, the package, from the

10 definition you've been given -- I've seen in other

11 documents related to the energy-efficient

12 industry, "extended product" has been used, often

13 sometimes by Lawrence Berkeley Labs. That would

14 include the drive, the compressor, unit, fans,

15 cooling systems, and controls, so the word in this

16 context, "package," and the word in some other DOE

17 called "extended product" would be the same. I

18 think we probably ought to come up with a common

19 vocabulary so that we don't confuse each other.

20 MR. BROOKMAN: Okay. Chris, you want to

21 follow on?

22 MR. BOLDUC: Chris Bolduc, Lawrence

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1 Berkeley National Lab. I'm going to respond

2 directly to Rick. We will come up with a common

3 nomenclature going forward. The -- because the

4 documents were published in different times.

5 MR. STASYSHAN: Okay.

6 MR. BOLDUC: The language wasn't

7 settled.

8 MR. BROOKMAN: Michael Kido?

9 MR. KIDO: Another follow-up question

10 for Rick. Do you have a particular recommendation

11 in terms of what you think should be included as

12 part of what that package is?

13 MR. STASYSHAN: You know, I think

14 "extended product" makes sense, and that would

15 include the compressor unit itself, the motor, the

16 drive, if applicable, the fan system, cooling

17 system, and controls.

18 MR. KIDO: Okay.

19 MR. STASYSHAN: Typically, they're

20 within a compressor box, so that makes sense.

21 MR. BROOKMAN: That's helpful. Thank

22 you. Can you return to Slide 26, please? Chuck

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1 has a comment on Slide 26.

2 MR. FOSTER: Chuck Foster, Edison

3 Electric Institute. Apologize for being late. I

4 hope you believe there was traffic out this

5 morning. The -- as I said, I represent the Edison

6 Electric Institute, and we're the trade

7 association that represents investor- owned

8 electric utilities. Today I also speak for the

9 National Rural Electric Cooperative Association

10 and the American Public Power Association.

11 So essentially 100 percent of the

12 generation, transmission, and distribution sector

13 is opposed to limiting this rulemaking to

14 electric-driven devices only. We're going to have

15 extensive comments. I won't take up your time

16 since you've already gotten past me. We'll have

17 extensive comments during -- that will follow in

18 written form, but there are significant large gas

19 compression systems used in the transmission and

20 distribution of natural gas, and maybe this has

21 already been covered.

22 We think that just the bare pump, bare

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1 compressor, if that's what you're going to be

2 looking at, should be either consider all prime

3 movers or consider no prime movers as part of the

4 efficiency metric.

5 And one last -- two last data points.

6 The natural gas industry has a trade association

7 that represents compressors, and it's separate and

8 apart from the -- from you, sir. And overtly, on

9 their page, on their website -- anybody can go

10 look it up and see -- one of their major goals is

11 the substitution of electric-driven compressors

12 for gas equipment. We have a competitive

13 interest. We think that that's legitimate. And

14 I'll leave it at that. Written comments will

15 follow.

16 MR. BROOKMAN: Thank you. Thanks,

17 Chuck. Okay. Louis, follow on?

18 MR. STARR: This is probably a question

19 for CAGI. Do you think in all cases -- you

20 described the extended product as compressor,

21 motor, drive, cooling system, and controls. Do

22 you think in all the classes, that that's an

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1 adequate way to look at things?

2 MR. STASYSHAN: Yeah. In some cases, I

3 would remove coolers.

4 MR. BROOKMAN: Wayne, please, go ahead.

5 MR. PERRY: Back when dirt was young,

6 when I started in this business, people would buy

7 a double- acting reciprocating compressor, and

8 then they would buy a motor, and then they would

9 buy pulleys, and they would buy an aftercooler,

10 and they packaged it up together to make a

11 complete compressor. That pretty much has gone

12 away. Basically now, our industry sells product

13 where you have a connection point where you

14 connect your air system to the compressor, you

15 have a connection point where you connect the

16 electrical system to the compressor. Everything

17 else is engineered to work properly together, the

18 controls, the coolers, be it intercoolers,

19 aftercoolers, drains, everything on that package.

20 What we do as CAGI for our performance

21 verification is we take power into that package

22 and air out of that package to determine its

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1 efficiency. When you get down to smaller piston

2 compressors, you will find some manufacturers who

3 sell a bare compressor. In other words, you can

4 buy a small, two- stage piston compressor that

5 will operate anywhere from five horsepower to

6 maybe 15 or 20 horsepower. You may be at single7 phase on the bottom end of it. You may be at

8 three-phase on the top end of it. And then they

9 either will have a distributor that puts that

10 together or maybe even an end user who has a tank

11 and a motor, and he just buys a bare compressor.

12 So there is the possibility that when

13 you get down into the piston compressors in these

14 smaller sizes that you're going to be looking at

15 bare pumps and not complete packages. But for the

16 most part, in industry, these people who may

17 package it themselves would be, you know, a one18 off cabinet shop or something trying to save a

19 little bit of money doing this, but in general,

20 industry buys a complete package. They don't

21 bother with trying to reengineer how all of these

22 components are going to fit together. They get a

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1 complete package, whether they get it from

2 Ingersoll-Rand or Sullair or Kaeser or whomever.

3 Now, I will say Ingersoll-Rand, I do

4 believe, still sells Type 30 bare pumps, small

5 piston compressors that you can do this with, but

6 for the most part, if you're talking about

7 something that's hardwired in, it's going to be a

8 package.

9 MR. BROOKMAN: Louis?

10 MR. RAUER: Add something to that --

11 MR. BROOKMAN: Please say your name and

12 get the microphone close. Yes?

13 MR. RAUER: Okay. One more -- the term

14 from wire to pipe --

15 MR. BROOKMAN: Please say your name.

16 MR. RAUER:-- meaning everything from - 17 -

18 MR. BROOKMAN: Please say your name.

19 MR. RAUER: I'm sorry. Werner Rauer

20 with Kaeser.

21 MR. BROOKMAN: Thank you.

22 MR. RAUER: From wire to pipe, meaning

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1 everything where the customer or the end user

2 connects the electric energy and where the

3 compressed air that they are intending to use

4 comes out, everything in between those points,

5 including all auxiliary equipment, whatever -- we

6 mentioned just a few. They are not 100 percent

7 complete. It depends on what package you're

8 looking at, but it's basically from those two

9 points would be considered a package.

10 MR. BROOKMAN: Okay. Thank you. Louis?

11 MR. STARR: So Louis Starr with NEEA.

12 It sounds like there's not a concern with

13 distributors; in other words, if you came up with

14 some things that described a packaged product, you

15 wouldn't be concerned with a distributor looking

16 at that and saying, "Oh, I can make that cheaper

17 if I put these pieces together myself."

18 It sounds like the scope of coverage

19 gets defined, you know, above three phase, that

20 there's not a problem with a distributor all of a

21 sudden starting up -- seeing a business

22 opportunity to make a product that negates -- gets

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1 around the regulations by starting up and then

2 putting these products together themselves. It

3 sounds like it's complex enough that that's not

4 going to happen.

5 MR. BROOKMAN: Wayne?

6 MR. PERRY: Well, there are always

7 exceptions to the rule, and I'll give you an

8 exception. Rogers Machinery in Portland, Oregon

9 manufactures oil-flooded rotary -- I say

10 manufactures -- assembled oil-flooded rotary

11 screws and oil-free rotary screws. They use

12 Quincy compressor air ends to build packages, and

13 have been for decades, and Kobelco for their oil14 free.

15 My thought was -- I mean, my assumption

16 was that these people would also fall under the

17 regulations and that whatever package they build

18 would have to meet these regulations and have to

19 take -- they would have to take part in the test -

20 - whatever testing program, verification program,

21 that goes on, so

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

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1 Other comments here?

2 MR. KLINKE: Okay. Next we'd be moving

3 on to the energy efficiency metrics that we would

4 use as part of any standards. DOE is considering

5 several energy efficiency metrics, and these would

6 be dependent upon what equipment system boundary

7 we use. For a bare compressor, we'd be looking at

8 either isentropic or isothermal efficiency.

9 For a compressor package, we'd be

10 looking at specific power requirement, which is

11 the specific power or kilowatt per cubic foot per

12 minute of air delivered. Or for a complete -- a

13 compressed air system efficiency, DOE is currently

14 unaware of any metrics for measuring the

15 efficiency of a compressed air system. And so if

16 we were to decide to use one of those, we would

17 request further feedback from stakeholders.

18 So Item 1.13, DOE seeks input regarding

19 whether the efficiency metrics listed effectively

20 characterize the efficiency for each equipment

21 system boundary. DOE also requests input on

22 whether any other efficiency metrics should be

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1 considered as part of its efforts in evaluating

2 whether to set standards for this equipment.

3 MR. BROOKMAN: Rick?

4 MR. STASYSHAN: Basically, you know, as

5 we looked at the rules document, you know, we

6 concurred that the ones referenced are the ones we

7 use, and we'd be prepared to assist you, because

8 we worked with PNEUROP and the International

9 Standards Organization, ISO, and so Compressed Air

10 and Gas Institute would be readily willing, and

11 its members, to assist the DOE in this definition.

12 MR. BROOKMAN: Thank you.

13 MR. RAUER: May I just add this? The

14 gentleman mentioned the kW per cubic foot, that

15 the current measurement in the United States is kW

16 per 100 CFM, in terms of the numbers being more

17 easily legible and understandable.

18 MR. BROOKMAN: Okay. Thank you.

19 Werner, thank you.

20 MR. PERRY: May I also make a comment?

21 MR. BROOKMAN: Please do, yeah.

22 MR. PERRY: Lot 31, right now --

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1 MR. BROOKMAN: Wayne.

2 MR. PERRY: -- is considering

3 isentropic, because that takes -- that makes it so

4 that you don't have to have different efficiency

5 numbers, basically, at different pressure levels.

6 So I'm not -- I personally like kW per 100 CFM,

7 but I would also keep an eye on what the EU is

8 doing, because it may be -- they may figure out an

9 easier way than we do, and I'm all for the easy

10 way.

11 MR. BROOKMAN: Okay. Great. Additional

12 comments here? Additional thoughts on efficiency

13 metrics? This can be a sticky (ph) point. Louis?

14 MR. STARR: So this is a follow-up --

15 Louis Starr, NEEA. This is a follow-up question

16 on what you were just talking about. Does that

17 mean in the EU, they're using two metrics to get

18 at it, so you look at the isotropic efficiency and

19 also the CFM per --

20 MR. PERRY: Specific power?

21 MR. STARR: Yeah. Is that no, or is

22 that just -- they're looking at -- maybe describe

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1 how that's working.

2 MR. BROOKMAN: Wayne, use the

3 microphone. Yeah.

4 MR. PERRY: Right now, they're taking

5 the CAGI data sheets into different pressures and

6 just plotting the isentropic efficiency based on

7 that, and that doesn't change a lot when you go

8 from 100 pounds to 110 pounds to 125 pounds of

9 discharge pressure. But the kW per 100 CFM will

10 change as you go up in pressure. The general rule

11 of thumb is for every two pounds of pressure, you

12 increase your discharge pressure, you increase

13 (inaudible) one percent.

14 So this just kind of takes that out and

15 reduces the number of data points that they have

16 to have to make it. And generally, you will have

17 one compressor package that's capable of several

18 different pressure ratings. We run into that all

19 the time because we have customers who, in our

20 industry, want to know, "Okay, what's the specific

21 power at this particular pressure?" That's not

22 something we test to on everything, but we do

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1 provide that kind of data to --

2 MR. DORIA: Yeah, Jordan Doria with

3 Ingersoll-Rand. Just to reiterate, they are

4 indeed using isentropic. Obviously this is all

5 happening in real time, so, you know, there are

6 not necessarily a lot of firm decisions right now.

7 They've completed -- the consultant has completed

8 his report. They're receiving public comment. In

9 the next month to month and a half, it'll actually

10 be delivered to the commission. So they haven't

11 even yet taken it up and answered a lot of these

12 questions, so just to make that clear.

13 One of the things that I have heard is

14 that there's some uncertainty as to whether they

15 have done the analysis using isentropic

16 efficiency, and then will also use it to develop

17 metrics or whether they have used isentropic

18 efficiency to do the shipment analysis and figure

19 out where to set the bar, but ultimately specific

20 power might still indeed be the metric they use

21 when creating efficiency metrics that would be

22 meaningful in the market and would actually apply.

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1 I can say that, you know, we don't

2 necessarily have a determined view just yet. I

3 think we're inclined to think specific power makes

4 sense, and our concern about using another metric

5 would be sort of creating marketplace confusion,

6 with specific power being the means by which we

7 articulate efficiency in the market. To have

8 another metric be the one used to measure it for

9 regulatory purposes, I think, in our view as a

10 company, that's not a -- generally not a desirable

11 outcome right now.

12 MR. BROOKMAN: Let's let Bruce

13 MR. LUNG: I think Jordan kind of

14 touched on my question, and the question I would

15 have is which metric would offer the most value to

16 the manufacturers as well as the end users in the

17 United States? Would it be specific power or some

18 other metric, like isentropic?

19 MR. PERRY: My preference is --

20 MR. BROOKMAN: Wayne.

21 MR. PERRY: -- specific power.

22 MR. BROOKMAN: Please, Wayne, go ahead.

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1 MR. PERRY: Yeah, my preference is

2 specific power.

3 MR. LUNG: What is the market accustomed

4 to?

5 MR. PERRY: Specific power. And that's

6 the whole reason we do that. And I will also add

7 that the people in the committee on Lot 31 are

8 asking a lot of questions of us about how this is

9 going, because they're trying to align with

10 whatever we're doing too. They know their

11 timeframe, how long it's going to take. They've

12 asked me particularly, "What's your timeframe on

13 this? Because if this is going to come out

14 earlier, we'd really like to align with you on how

15 all of this goes out." Most of our members market

16 -- manufacture and market internationally, and

17 we'd like to have a reasonably even set of rules

18 across the board.

19 MR. BROOKMAN: Sounds like we ought to

20 hold a joint meeting in someplace like Geneva.

21 MR. LUNG: I'd like to ask for a follow22 up on this point. We had heard that isentropic

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1 efficiency would favor a rule that applies only to

2 a bare compressor. Is that your understanding as

3 well?

4 MR. PERRY: No.

5 MR. LUNG: Okay.

6 MR. PERRY: No, you can take -- power it

7 -- you know, from a wire to the pipe and calculate

8 it as well.

9 MR. BROOKMAN: Thank you, Wayne. Now to

10 Louis.

11 MR. STARR: So what I think about the --

12 well, typically isentropic efficiency is

13 associated with just the bare compressor, but what

14 it sounds like you're suggesting is a definition

15 of a thing that includes more extended product,

16 and then isentropic efficiency would be related to

17 the specific power, that basically the specific

18 power, it generates the numbers that's isentropic

19 efficiency that then is associated with efficiency

20 of the extended product.

21 One thing I might suggest, and I think

22 we've found this on pumps now, is that we did sort

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1 of end up with a metric that doesn't mean much to

2 the marketplace, but the other aspect of it is

3 that you can have a label that does mean something

4 more to the marketplace. You could have an index

5 that is for efficiency and another one that

6 indicates specific power, so that way, the -- in

7 your marketing material, your aspect to the front8 facing market would be that specific power, but at

9 the index is how you rate it, and ideally, you

10 would just want it to be the specific power that

11 the marketplace is used to knowing is what is

12 communicated and is also a metric, but depending

13 on the analysis and how -- the regulatory scheme,

14 it may be necessary for the other one, so

15 MR. BROOKMAN: Thank you. Andrew

16 deLaski.

17 MR. DELASKI: I just wanted to follow up 18 --

19 MR. BROOKMAN: Andrew.

20 MR. DELASKI: -- as we're trying to

21 understand the differences here. Since you guys

22 have been involved in the European process, or

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1 some of your colleagues have, why have they -- do

2 you understand why they've gravitated in the

3 direction that they have?

4 MR. BROOKMAN: Wayne?

5 MR. PERRY: The answer to that is not a

6 clue. I think they're just trying to crunch a lot

7 of data, and that, to them, seemed the easiest way

8 to crunch it. And they're looking more at

9 different efficiency levels. You know, one

10 package may be able to perform at a number of

11 different power levels, different motors with the

12 same -- basically the same components. And I

13 think what Lot 31 is looking at is chopping off

14 those least efficient units of this, and this is

15 just -- it's just an easy way for them to crunch

16 the numbers.

17 MR. RAUER: And this is Werner. Can I

18 add something to that? The isentropic efficiency,

19 since the specific one is related to the pressure,

20 you would have to come up with all kinds of

21 numbers. You can use the isentropic to weed out

22 inefficient technology and give certain limits

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1 there, but still use the specific performance as a

2 more understandable and feasible measurement than

3 to label it, as, a gentleman, you mentioned, in

4 order for the people to understand it, because

5 that's what they're paying for is to (inaudible)

6 air they're getting. They really don't know much

7 about an isentropic efficiency, and why would they

8 care?

9 So it could be that the one could be

10 used as a tool to shave off certain inefficient

11 equipment in general, and not being offered on the

12 market, and then the labeling to allow the

13 customer to select out of this leftover range,

14 whatever they chose -- value for the money, so to

15 speak, a super-efficient one versus the not-so16 efficient, but still allowed (inaudible).

17 MR. BROOKMAN: Thank you, Werner. Thank

18 you. Additional comments here? I have a question

19 for Wayne. Wayne, you said that the EU, that

20 they've written papers, they've done studies, and

21 in your experience, when they -- that, to me,

22 indicated that they're sending a signal about

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1 where they are headed. Do you think that's

2 reliable, when they send signals?

3 MR. PERRY: Well, they think -- the

4 study right here for Lot 31 -- and I don't know --

5 you've probably read their reports as well. I

6 don't -- I have a difficult time understanding

7 where they're headed --

8 MR. BROOKMAN: Okay.

9 MR. PERRY: -- with this. They have

10 made several proposals that if we increase the

11 efficiency levels, you know, they're taking this

12 curve and saying, "This is where we are now, and

13 if we increase this" -- just for an example, I

14 think that the minimum increase -- in other words,

15 where they're going to start saying, "Okay, you

16 cannot produce machines that are less than this

17 particular efficiency," you're looking at, in

18 Europe, probably half of what was available in

19 2011 would be not be available when this product -

20 - when this regulation came into effect.

21 The study writers also put two or three

22 additional levels, where as much as 90 or 95

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1 percent of what was available in 2011 would not be

2 available when they hit these marks. Right now,

3 they're just trying to figure out is any of this

4 feasible, technically possible without bankrupting

5 the people that are trying to buy the equipment?

6 MR. BROOKMAN: Yes, please? Yes?

7 MR. COFFEY: This is Brian Coffey with

8 Navigant. This seems like a pretty important

9 decision, and one that would be better made

10 earlier in the process, and it's -- from what I've

11 heard, it sounds like that, you know, isentropic

12 efficiency offers kind the advantage of simplicity

13 in that it doesn't change as much based on the

14 mode in which you operate the equipment, whereas

15 specific power, kilowatts per 100 CFM, offers the

16 advantage of familiarity to the consumers. It's

17 how people think of what they need.

18 One question I would have is the

19 perspective from which DOE is forced to think is

20 in the case where the same equipment could have

21 different efficiency levels in terms of kW per 100

22 CFM, DOE is forced to really specify how that

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1 equipment is to comply with standards; in other

2 words, does it comply at its most efficient

3 rating, or does it comply at the average of all

4 modes for which it is rated to operate?

5 DOE has to establish a requirement on

6 that and certainly wouldn't want to create an

7 incentive for someone to market equipment in a way

8 that it wasn't going to be used. Right? In other

9 words, someone could buy an equipment -- a piece

10 of equipment that complies at some rating, but

11 then once they install it, it's used at another

12 rating that's much less efficient and where

13 there's no real energy being saved. So I just

14 wanted to add that perspective, that DOE is really

15 forced to take that into consideration when

16 thinking about how requirements may be written.

17 MR. BROOKMAN: Okay. Louis?

18 MR. STARR: This might be something for

19 the air compressor manufacturers to think about.

20 I don't know if this is true with compressors, but

21 your max speed that you not break a compressor,

22 usually efficiency tracks down from that.

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1 So if you set that -- to follow on with

2 what he's just saying, you can make the test point

3 be at the maximum, and that sets numbers so that

4 you don't have people gaming it based upon the

5 best efficiency point and then using another

6 application. If you run it to its max, you

7 determine what the efficiency is and let that

8 point be the regulation of it. I don't know --

9 that can work in fans. I don't know if that works

10 that way in compressors, but it's something to

11 consider.

12 MR. BROOKMAN: Wayne?

13 MR. PERRY: The big determiner in

14 specific power, when you're looking at it with one

15 individual compressor, is going to be the

16 discharge pressure. Where are you going to run the

17 -- where is the -- what is the pressure

18 requirement for that particular demand? Most of

19 the machines that are sold in the U.S. are fixed20 speed compressors. Even the variable- speed

21 compressors have a maximum speed on them. In our

22 Performance Verification Program, the things we

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1 verify on variable speed, we have to provide the

2 maximum speed, the minimum speed, and at least

3 three points in between and draw a curve so the

4 customer can see where -- you know, where is he

5 going to run this machine, and how efficient is it

6 going to be in that range that he's going to run

7 the machine?

8 If I have a compressor that is rated

9 capable -- let's say it's a fixed-speed

10 compressor, capable of 145 psi discharge pressure,

11 that customer can run that compressor at 100 psi.

12 If he gets a data sheet at 145 psi, it's going to

13 show very poor specific power compared to what it

14 would at 100. But chances are, he's not going --

15 if he just wants to run it at 100, he's not going

16 to buy a machine capable of 145, because you trade

17 off flow for pressure for the same power. So he's

18 going to want as much flow as he can get at 100

19 pounds. At 145 pounds, he's going to get much

20 less flow out of it. He's going to have to run it

21 at a slower speed to use that amount of power to

22 make that amount of pressure.

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1 MR. STARR: So this is Louis Starr with

2 NEEA. It almost seems, though, that would drive

3 the market to buy right-sized compressors, right,

4 which would be a good thing.

5 MR. PERRY: Oh, that has been --

6 Compressed Air and Gas Institute, Compressed Air

7 Challenge, Department of Energy, all of the power

8 companies, that's been the drive all along is --

9 MR. STARR: Well, just something to

10 think about, if you rate it at its max setting,

11 then it encourages people -- if you set the

12 efficiency rating at its maximum possible

13 pressure, then you sort of set the efficiency

14 rating there, and then the marketplace is looking

15 at that number to select their compressor, so

16 hopefully they wouldn't be sizing an oversized

17 compressor or for higher pressure than they would

18 need.

19 MR. PERRY: No, and you will have the

20 manufacturers have different sheets for different

21 pressures. So --

22 MR. STARR: For the same machine, right.

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1 MR. PERRY: For the same machine.

2 MR. RAUER: If I understand you

3 correctly -- I'm not so sure. Can you restate

4 what the original question was? I'm sorry.

5 MR. STARR: Well, the main thing is DOE

6 is trying to figure out, when they set a label on

7 the air compressor, they're trying to figure out

8 what point should they set that at; you know, what

9 operating point? So I suggested they look at the

10 maximum operating point to set what the efficiency

11 rating is. And so by setting that, the marketplace

12 is also then -- it's seen the most efficient

13 operation at that point so that they won't pick a

14 compressor that's larger than they need. They

15 pick the one that they need that meets with the

16 label.

17 MR. RAUER: Well -- this is Werner

18 again. Larger versus pressure, that is not always

19 -- you have -- Wayne mentioned variable-speed

20 drive machines. That's something -- what some

21 people call electronic gearing, where the machine

22 can go anywhere from 80 pounds to 175 pounds. The

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1 customer basically programs the actual pressure

2 they want, and then the machine automatically will

3 operate at that pressure at a efficiency at that

4 pressure. You always have to remember that

5 pressure and electric energy consumption is

6 directly related, and the maximum capacity and the

7 overall total package is determined by the

8 available power inside the electric motor in the

9 machine, so you have a certain limit there.

10 But the flexibility needs to be given

11 there, because when you then consider how the

12 machine is being used, you have the box, which we

13 call the package, which we've heard talked about

14 here today, and then you have other equipment for

15 clean air treatment. The point of use pressure is

16 what we're trying to educate the people, to keep

17 this as low as possible.

18 If you follow that train of thought,

19 that should translate also to the original package

20 equipment we're talking about. So there has to be

21 some leeway there, because you have pressure drops

22 across this clean air treatment, so you may have

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1 to have a 120-pound, 125-pound weight machine to

2 actually operate the system at 100 over an

3 extended period of time.

4 So going back to the gentleman over

5 there, with the isentropic, that would be just a

6 quick sweep in order to eliminate certain

7 technologies, but then when you look at the actual

8 application, I really don't see at the moment how

9 you can get over the specific performance based on

10 how the machine is applied. And you have to give

11 -- have to allow some leeway.

12 The goal we are all going for is to

13 operate at the lowest pressure. That means you

14 can buy here, but you can also get a certificate

15 for the very same machine if you then manage to

16 update or improve your system, operate it at a

17 lower, you should be able to also get a

18 certificate from the manufacturer for that

19 pressure or pressure rate you're now at. That

20 gives you, then, the confidence what you purchased

21 is really the best of what -- that's the one you

22 wanted.

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1 MR. BROOKMAN: Yeah. Thank you, Werner.

2 Yes, Chris?

3 MR. BOLDUC: Chris Bolduc, LBL. This is

4 a question from Werner, a follow-up. So when I

5 look at the CAGI data sheets for your compressors,

6 and I see you're telling -- just saying that

7 they're discrete pressure points, if I look at the

8 model number, it's the exact same compressor,

9 motor, intercooling -- everything in the box is

10 the same? You're just testing it at different

11 pressure points?

12 MR. RAUER: This is Werner. Yeah, when

13 you're talking about a fixed-speed machine?

14 MR. BOLDUC: Yeah.

15 MR. RAUER: Yes?

16 MR. BOLDUC: Yes.

17 MR. RAUER: And we also have the same

18 offering for variable speed or variable capacity,

19 you would -- as a manufacturer, you would also

20 have to be prepared to come up with verifiable

21 data if you changed the pressure on either the

22 fixed speed or the variable speed.

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1 MR. BOLDUC: My question was more in

2 relation to fixed speed. So when I'm looking at

3 the data sheets, I'm trying to interpret your

4 product line. You'll -- you might offer

5 compressors at 100 psi, 110, 125, all with the

6 same model number, but just a different pressure

7 rating on them. Is everything inside the package

8 the same, generally speaking?

9 MR. RAUER: This is Werner. Difficult

10 to answer. It's almost like a trick question. I

11 mean, seriously, because -- you're absolutely

12 correct. There is the box. The box can be -- like

13 in one case, there's a direct drive, no change for

14 any speed, or no change when the speed change.

15 That is really fixed. That means you have a fixed

16 displacement and the power goes up and down with

17 the pressure. So let's say it's 500 CFM at this

18 pressure. It may be 501 or 502. No significant

19 change.

20 Then you have package that have either a

21 belt drive, a gear drive, or even a specific

22 speed, a specific speed machine. You're selling

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1 it, and then you put either field modify -- that

2 is allowed. For example, if you move the machine

3 or you change the process. What this allows with

4 the gear is that by changing the gear ratio, with

5 the same available power, you can make more air at

6 the lower pressure as compared to the package you

7 either purchased or you were originally looking at

8 or you're preparing on the website. You can have

9 550 CFM at 100 and then 500 CFM at 125 and then

10 even less at 145 pounds. Does this answer your

11 question?

12 MR. BOLDUC: Yeah. Yeah.

13 MR. BROOKMAN: Okay. Additional

14 comments here? Louis?

15 MR. STARR: Maybe this'll -- maybe the

16 manufacturers know this. Maybe they've done it

17 already. On the label or the efficiency metric

18 they come up with, really, they can't look at the

19 application it's used in. So whatever you come up

20 with, it's basically whatever's sitting on the

21 shelf, you've got to stick a label on that, not

22 knowing how it's actually going to be used in the

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1 field.

2 And so that's why I'm suggesting coming

3 up with some operating point that makes sense that

4 establish -- that's very similar efficiency levels

5 that, you know, if something works at its maximum

6 thing, does it follow that lower CFM ratings or

7 delivery CFM ratings that the efficiency would

8 track down that way? That way, you can look at

9 something on the shelf and say what's at the

10 maximum rate and what is that? Does that

11 efficiency translate to how the user might

12 actually use it in the field (inaudible) being

13 that less volume, and so that's kind of what they

14 would be looking for. So maybe that's something

15 for you guys to think about.

16 MR. STASYSHAN: I think labeling's the

17 next topic, right?

18 MR. BROOKMAN: Yeah, right.

19 MR. STASYSHAN: So we might want to wait

20 until we get to labeling.

21 MR. STARR: Okay.

22 MR. BROOKMAN: Jordan, you want to

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1 comment here?

2 MR. STARR: Well, I was just going to

3 say I recognize -- and that -- that makes sense,

4 but the other side of that is if you think about,

5 you know, other products, there are sort of, I'll

6 say, assumed values for operating, you know, HVAC

7 being the prime example of temperature, right? I

8 mean, I think that we could potentially think of

9 temperature as analogous to pressure in this

10 context and say, well, there are ways, and these

11 are the -- how are we going to rate it, and

12 there's a finite number of them. That seems like

13 another possible approach, at least.

14 MR. BROOKMAN: Do you want to take a

15 break now or plug on for 15 minutes? Let's take a

16 break now. It's 10:30. We're at a logical

17 stopping point. It's 10:30. Let's -- we'll resume

18 at 10:45 in this room. Some of you are new, I

19 believe, to the Department's ruling process. You

20 must wear this badge visible in the building.

21 There are restrooms at both ends of the hall.

22 There's a coffee shop on the ground floor. If you

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1 go to the elevators and go down to the ground

2 floor, it's right around the corner, just about

3 directly underneath us, on the opposite side of

4 the hallway.

5 So thanks for a good start on the day.

6 The quality of the comments has been really

7 excellent. We'll see you back here at 10:45.

8 (Off the record.)

9 MR. BROOKMAN: During the break, I

10 received a comment from someone who's joining us

11 online. This is from Rob Hazeley (ph). Rob

12 Hazeley says, "Isentropic efficiency gets

13 confusing when you have multistage units, does

14 take into account intercooling." Okay. So thanks

15 for that comment, Rob.

16 We left off on Slide 32. Let's return

17 there and proceed.

18 MR. KLINKE: Okay. As Jim mentioned

19 before, we will also be doing a test procedures

20 rule -- or possibly are considering a test

21 procedures rulemaking. As part of that, EPCA sets

22 for generally applicable criteria and procedures

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1 for DOE's adoption and amendment of test

2 procedures. So DOE is considering developing and

3 amending test procedures necessary for equipment,

4 included in the scope of coverage.

5 Currently, we are looking at these test

6 procedures for positive-displacement compressors.

7 We're looking at existing industry test procedure,

8 and that would be ISO 1217 for displacement

9 compressors, the acceptance tests. For dynamic

10 compressors, again, it's another ISO existing test

11 procedure, 5389. And then for a combined

12 compressor, most like -- we're not currently aware

13 of any industry test procedures that apply

14 directly to combined compressors, so that would be

15 something that we would have to develop ourselves

16 and would most likely be some combination of ISO

17 1217 and 5389.

18 So hold your feedback requests on that.

19 Item 1.14, DOE requests comment on the use of ISO

20 1217 and 5389 as test procedures as well as any

21 other test procedures as a basis for the

22 development of a DOE test procedure, including any

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1 modifications or additions that may be necessary.

2 And Item 1.15, DOE requests comment on the scope

3 of each test procedure with respect to the

4 equipment for which DOE is considering standards

5 as well as any limitations of these test

6 procedures.

7 MR. BROOKMAN: Jordan?

8 MR. DORIA: Just sort of one general

9 comment on the test procedure process and then one

10 specific comment. The general comment would be we

11 understand that there will be two separate

12 rulemakings, and that's standard practice for the

13 Department, one for the actual efficiency

14 standards and one for the test procedure.

15 We just sort of want to call out that

16 it's really important to have the timing synced up

17 appropriately for the test procedure rulemaking

18 and the efficiency standards rulemaking.

19 And to give an example from another

20 rulemaking that's ongoing around furnace fans,

21 there was a significant modification from the

22 proposed rule to the final rule for the furnace

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1 fan test procedure, and we think that the changes

2 were so significant that it sort of invalidated a

3 lot of work that supported the actual efficiency

4 rulemaking. And I think that's a natural process

5 when there are significant changes during a test

6 procedure rulemaking. So that's why I said that

7 the timing's really important.

8 We do recognize that the Department

9 chooses to do them as two separate rulemakings,

10 but this is one of the challenges associated with

11 that approach, so we just want to make sure that

12 there's some sensitivity to that so we don't have

13 the same thing happen here, so that's the general

14 comment.

15 The specific one, I think, is that for

16 ISO 1217, I think -- and maybe, you know, Wayne or

17 others could speak to this, that it's sort of more

18 tailored, I think, for specific power, and there

19 might need to be some work done within the

20 standard itself if it were to support any kind of

21 metric around isentropic efficiency. So that's

22 just a connection, maybe, to be aware of, but I

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1 think as a general point, I think those are test

2 procedures that are appropriate.

3 MR. BROOKMAN: Okay. Thank you.

4 Additional -- yes, Rick?

5 MR. STASYSHAN: Currently, we use --

6 sorry, Compressed Air and Gas Institute members

7 use both 1217 for rotary positive and 5389 for the

8 dynamic compressors, so we'd like to -- I'll

9 review with our membership to see if we have any

10 comments on limitations of these tests and revert

11 back at a later date.

12 MR. BROOKMAN: Thank you. Additional

13 comments, any other test procedures that DOE

14 should be looking at as they consider these types

15 of pumps? These types of -- not pumps.

16 MR. STARR: Yeah.

17 MR. BROOKMAN: Yes, Louis?

18 MR. STARR: So this is Louis Starr with

19 NEEA. This is more a question. Are we --

20 MR. BROOKMAN: Compressors.

21 MR. STARR: -- going to get into

22 variable- speed ones on -- as it relates to these

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1 test procedure, or is that something we need to

2 talk about now?

3 MR. KLINKE: That would be something

4 that we could go into now. We don't have any

5 slides specifically for that.

6 MR. BROOKMAN: Wayne?

7 MR. PERRY: I can tell you the test

8 procedure for 1217 is the same for variable speed

9 as it is for fixed speed.

10 MR. RAUER: It is part of it.

11 MR. PERRY: Right.

12 MR. RAUER: It is part of --

13 MR. PERRY: ISO 1217 has instructions on

14 how you'd perform a test on variable-speed

15 machines, so it's in 1217.

16 MR. STARR: I think maybe the point I

17 was referring to is that I think on ISO 217 -- or

18 1217, you end up with a number of points. You get

19 multiple numbers, and I think you -- DOE's going

20 to be looking for a single metric, so it means

21 you're going to have to modify that test procedure

22 to reflect the output to change that into one

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1 single number.

2 So you're going to get ratings at

3 different percentage of load (ph), 25, 50, 75, or

4 100. So -- or operating points. They get

5 multiple operating points, and so they're going to

6 want one number, which either has to be one of

7 those operating points or a weighted average of

8 those operating points. And so that's what I was

9 referring to.

10 MR. PERRY: Well, but 1217 is just how

11 do I set up a test cell? What parameters do

12 I measure, and how do I measure them? What

13 results -- now, if you have a -- in this

14 rulemaking, if you want a lot of different points,

15 you can get a lot of different points, but 1217

16 just tells you how to do the test. It doesn't

17 tell you what points to measure. It just says,

18 whatever you're measuring, this is the way you set

19 up the apparatus. This is the tolerances you have

20 on your equipment that you're measuring with, and

21 this is how you're going to come up with a result.

22 MR. BROOKMAN: Going to the comment box,

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1 those test procedures and comment on the scope of

2 each test procedure with respect to the equipment

3 for which DOE is considering standards.

4 Additional comments on either of those? Nothing

5 additional?

6 MR. STASYSHAN: You know, as I mentioned

7 before, I'm going to go to our membership and see

8 if we see any limitations or concerns, but at this

9 point, we have no comment on --

10 MR. BROOKMAN: Okay. Thank you, Rick.

11 Okay.

12 MR. KLINKE: Moving on to the final

13 slides of this section, finally, we're talk -- we

14 -- Section 344 of EPCA, as amended, provides

15 labeling requirements for commercial and

16 industrial equipment.

17 To prescribe labeling requirements, DOE

18 must determine if three conditions are met:

19 labeling is technologically and economically

20 feasible, significant energy savings will likely

21 result from labeling, and labeling is likely to

22 assist customers in making purchasing decisions.

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1 So at minimum, labels must include

2 energy equipment -- equipment energy efficiency,

3 so labeling is one path that DOE is considering

4 taking as part of the standards rulemaking.

5 Some specific feedback that we'd like on

6 labeling, DOE seeks comment on whether a labeling

7 rule would be technologically or economically

8 feasible, result in significant energy savings, or

9 assist customers in making purchasing decisions.

10 And Item 1.17, DOE seeks comment on information

11 that it should consider requiring for display on

12 any prospective label, as well as factors DOE

13 should consider regarding the size, format, and

14 placement of any such label.

15 MR. BROOKMAN: Rick?

16 MR. STASYSHAN: Rick Stasyshan,

17 Compressed Air and Gas Institute. Start with

18 1.16. You know, the CAGI members are currently

19 measuring to specific power package performance

20 under rotary positive, and that was covered in

21 Point 1.4.2.3 of the rules document.

22 CAGI and its members feel our voluntary

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1 program and testing, the voluntary certification,

2 while representing a significant expense to our

3 member companies, has assisted in -- customers in

4 making better-educated purchase decisions. Energy

5 represents the most significant operating cost

6 over a product life cycle of a compressor, and

7 CAGI program has proven to be benefit to the

8 customers.

9 The label we currently use refers to the

10 CAGI program and the standard used. Customers

11 need to refer to the manufacturer's website or

12 CAGI's website for an individual manufacturer's

13 comparison data between the brands.

14 Our members assist the customers with

15 this process as a service. We'd like to use the

16 existing program, if possible, or work with you to

17 make sure that a mutual goal of efficiency

18 enhancement is achieved.

19 MR. BROOKMAN: Thank you. Jordan?

20 MR. DORIA: Yeah. We echo that

21 statement. Ingersoll-Rand supports the industry

22 view there, and we would also add that we've heard

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1 that -- recently that the Department does believe

2 the requirement around labeling can be viewed

3 perhaps a little more broadly than what we think

4 of with a label, that it's actually sort of

5 essentially a sticker affixed to a product or a

6 box.

7 We would say that, certainly for

8 commercial and industrial equipment such as

9 compressors, we think that sort of broader

10 definition of what constitutes a label is

11 appropriate, which we think -- and if that were

12 indeed the interpretation, we think that would

13 support the approach of leveraging existing

14 resources that industry and our customers use when

15 making decisions around efficiency.

16 MR. BROOKMAN: Okay. Louis?

17 MR. STARR: This is Louis Starr with

18 NEEA. We also -- the Northwest Energy Efficiency

19 Alliance has a lot of utility companies, and so a

20 label could be an avenue for utility rebate

21 programs and incentive programs to assist the

22 market in adopting an efficient technology. So we

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1 see it as a benefit.

2 MR. BROOKMAN: So 1.17 asks for the

3 information that it should consider displaying.

4 Comments there? Rick?

5 MR. STASYSHAN: Yes, I would like to

6 make a comment. Rick Stasyshan, Compressed Air

7 and Gas Institute. Industrial compressors are not

8 purchased like refrigerators, meaning one doesn't

9 walk down an aisle, looking at efficiency labels,

10 comparing features. Industrial compressors are

11 often not manufactured until an order is received.

12 Availability of performance data prior to

13 purchase, as facilitated through the existing CAGI

14 program, is generally viewed by the end customers

15 as more effective and relevant than a label that

16 would be affixed after the machine is

17 manufactured.

18 So, you know, building on Jordan's

19 comment, perhaps -- you know, we're not against

20 providing the data, but perhaps a data at the

21 point of the sale versus -- no one's going to look

22 at the compressor in the mechanical room and say,

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1 "Oh, I wonder what the label says."

2 MR. BROOKMAN: Yeah.

3 MR. STASYSHAN: The decision is going to

4 be made prior to that.

5 MR. BROOKMAN: Okay. Thank you. Yes,

6 Louis?

7 MR. STARR: Just a quick question. Are

8 there commodity items? Can I go down and buy

9 compressors off the Grainger shelf or some other

10 shelf, or is everything custom-made, pretty much,

11 or what's the typical market share of that?

12 MR. STASYSHAN: You know, there are

13 standard products or common products, generally,

14 in smaller horsepowers. Generally as you get

15 above 100 horsepower, 75 kilowatt, you get into

16 the machines that are more built to order versus

17 built to stock. But, again, you know, the purchase

18 decisions aren't made by looking at finished

19 product, generally. The products are made looking

20 at the specialty and the application.

21 MR. BROOKMAN: A comment from Rob

22 Hazeley online, which is, "Annex E gives max speed

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1 and min speed." Andrew deLaski?

2 MR. DELASKI: Yeah, a couple follow-up

3 questions, and mostly, I think, for Rick. Within

4 the existing CAGI program, do you have a feel for

5 what portion of compressors sold in, say, 10

6 horsepower and up, are currently CAGI -- in the

7 CAGI program?

8 MR. STASYSHAN: I'd venture to say it's

9 above 90 percent --

10 MR. DELASKI: Above 90 percent.

11 MR. STASYSHAN: -- with the packages

12 sold in the U.S. Uh-huh.

13 MR. DELASKI: Including those that are

14 sold by what you characterized earlier as

15 assemblers and sort of the regional (inaudible)?

16 MR. STASYSHAN: Okay. If you look at

17 the programs covered by our current labeling

18 process, that's rotary screw positive

19 displacement; also the rotary vane compressors are

20 included in that positive displacement category.

21 That's the program currently where we have

22 labeling, testing, and third-party verification.

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1 We do not have it in the double-acting recip --

2 MR. DELASKI: Okay.

3 MR. STASYSHAN: -- rotary positive

4 market yet.

5 MR. DELASKI: Okay.

6 MR. STASYSHAN: And that's where most of

7 those people that we talked about earlier are

8 falling into place.

9 MR. DELASKI: All right. So there's --

10 in the world -- in this universe of products that

11 are in the program, it's 90 percent.

12 MR. STASYSHAN: Yeah.

13 MR. DELASKI: But what we're talking

14 about here may be broader than what is currently

15 covered by the program?

16 MR. STASYSHAN: That's correct.

17 MR. DELASKI: Okay. Another -- I think

18 you're right, and I agree with you that the

19 primary purpose of a label should be to -- it to

20 provide information that would influence the

21 customer's decision so they end up choosing

22 something more efficient than they would otherwise

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1 choose. I think that's the primary goal, and I

2 think you're right to be focused on encouraging

3 the Department to provide data and information

4 through a label broadly construed, you know, what

5 that means in terms of information over the

6 Internet or information to the customer at time of

7 sale, I think is the right focus.

8 But there may be some -- another purpose

9 for a label is to enable someone after the fact to

10 say, "This thing complies," whether that someone

11 after the fact is the purchase or a code official

12 or a utility company that's paying a rebate or

13 something. There may be a goal for a label in

14 addition to that. So I would say sometimes it's a

15 secondary goal, but it's a potentially important

16 thing to consider.

17 And my last question was for the

18 Department. This is -- the Department's doing this

19 process for compressors. There's a process for

20 pumps, one for fans, going on, all of which have

21 their own different sort of features to them. And

22 labeling, I think, is part of the conversation in

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1 each of these proceedings. It's the first time the

2 Department has, I think, exercised the authority

3 to pursue labeling for commercial products, for

4 these types of products, so I'm curious what your

5 thought is to how that -- what the timing is, how

6 that would -- how the labeling conversation would

7 go forward. Is it at the same time? Would you do

8 a labeling rule proposal as part of the NOPR?

9 Back to that timeline at the beginning, where does

10 labeling come into that timeline?

11 MR. BROOKMAN: Jim Raba.

12 MR. RABA: Jim Raba, DOE. I recall from

13 the discussion I'm hearing now the motors

14 regulations that started back in -- well, before

15 '96, and became required in '99, and this is all -

16 - history repeated itself, if you will. And to

17 answer your question, the labeling was part of the

18 proposed rule and the final rule as well. The

19 labeling we called a nameplate, the permanent

20 nameplate for which the Department set up two

21 things. It was labeled nominal efficiency,

22 essential, and also the value, based on the table

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1 of efficiencies in the regulation or the

2 incorporation by reference to a standard, industry

3 standard.

4 Nonetheless, the labeling portion was

5 what you said, Andrew, over here too from Rick,

6 that the label or nameplate is where you have

7 verification that you got what you paid for. It's

8 identity that this machine, in fact, complies, so

9 it was tested and understood to be compliant by

10 the specifications, the design, the construction,

11 and the actual, in this case, witness testing,

12 perhaps.

13 So it's all right there. And I think

14 that what you're saying is right on target with

15 much of precedent. So it's all good to see this

16 again come back, and it's consistent with other

17 industry approaches too.

18 MR. DELASKI: So what I think I heard

19 you say is that we -- the labeling will be part of

20 the same docket. It's part of the same -- we'll

21 do it as part of the same proposed rule, in all

22 likelihood.

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106

1 MR. RABA: Yes.

2 MR. KIDO: Let me clarify that. The

3 agency hasn't --

4 MR. BROOKMAN: Michael Kido.

5 MR. KIDO: -- really made a decision as

6 to where to incorporate that particular

7 proceeding. It could happen within the context of

8 the proposed rule. It could happen, perhaps,

9 afterwards. It's still something that's sort of

10 in flux. So -- but it is something that's on our

11 radar screen that we'll consider.

12 MR. DELASKI: Okay. That makes sense to

13 me, and I think one of the things that -- I think

14 certainly sort of solving all these tough issues

15 at the same time, I think, is -- makes it a more

16 complicated problem --

17 MR. KIDO: Right.

18 MR. DELASKI: -- but it probably makes

19 sense to do it all concurrently.

20 MR. KIDO: Right.

21 MR. DELASKI: I also will submit that

22 there's a lot of time between the time the final

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1 rule is completed and the time that the rule goes

2 into effect. So if it ends up -- I wouldn't want

3 the labeling process to become a hindrance to

4 completing the final rule for standards, and that

5 it may become necessary to sequence them, in the

6 interest of completing -- of not getting in the

7 way of doing the standards rule.

8 MR. KIDO: Right.

9 MR. DELASKI: And I think there's enough

10 time, with that five-year lead time we talked

11 about earlier --

12 MR. KIDO: Uh-huh.

13 MR. DELASKI: -- you could still address

14 it.

15 MR. RABA: Jim Raba, DOE, again. To

16 modify what Michael Kido says -- who's most

17 correct, of course -- recalling in the motors

18 rulemaking, it was part of the proposal and the

19 final process, but it didn't become effective

20 until sometime later, when manufacturers could

21 adjust their product lines and bring things to

22 market with that label or nameplate on it,

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1 realizing that what was in -- on the warehouse, on

2 the distributor's shelves, whatever, would not be

3 retroactive. What was manufactured before is

4 before; what's after, after. They can catch up

5 with it too. So as you say, Michael says we'll

6 have to consider that as far as timing.

7 MR. BROOKMAN: Okay. Chuck Foster? All

8 set? Louis Starr?

9 MR. STARR: So one thing to think about

10 -- I think I would encourage the label thing as

11 part of this rule -- is just that, from our

12 earlier discussion, you can see that the

13 isentropic efficiency appears to be the way that

14 it's going, but that's not how the market's used

15 to buying the product. So it may be a good

16 metric, and I think it may be a good metric for

17 measuring efficiency, but it's not really

18 informing the purchaser of it.

19 The other aspect is, I think, again, the

20 variable speed, there's going to be -- the metric

21 will actually mean even less, so the label's going

22 to be the way that information is communicated

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1 effectively to the consumer and to rebate

2 programs.

3 MR. BROOKMAN: Okay. Thank you. I

4 think we're ready to move on.

5 MR. KLINKE: Okay. We'll now be moving

6 on to discussing the market and technology

7 assessment and the screening analysis. So the

8 market and technology assessment, the purpose is

9 to determine equipment classes and to identify

10 technology options to improve efficiency. So

11 going back to a discussion that we had earlier,

12 this part of the analysis is where we would

13 actually be looking at dividing products into

14 specific equipment classes and then setting

15 standards for each class.

16 The screening analysis would be used to

17 screen out technology options that DOE will not

18 consider in the engineering analysis based on

19 technological feasibility; practicability to

20 manufacture, install, and service; adverse impacts

21 on utility or availability to consumers; and

22 adverse impacts on health or safety.

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1 So Item 3.1, DOE requests information

2 that would contribute to the market assessment;

3 for example, current equipment features and

4 efficiencies, equipment-feature and efficiency

5 trends, and historical equipment and shipment

6 prices.

7 MR. BROOKMAN: Okay.

8 MR. STASYSHAN: You know, good point. I

9 think the data that you reference in Point 3.1

10 will be a major undertaking for manufacturers to

11 pull together. This will require both time and

12 resources to compile (ph) the manner useful to the

13 DOE.

14 While the Compressed Air and Gas

15 Institute can coordinate and act as a

16 clearinghouse for many of the manufacturers in

17 gathering this data, it should be noted that there

18 are manufacturers that are not members of our

19 organization, but we stand ready to assist you in

20 compiling this data.

21 MR. BROOKMAN: Okay. Thank you, Rick.

22 Louis?

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1 MR. STARR: One thing that I've seen

2 that comes up pretty regularly is to split out the

3 horsepower categories. A lot of times, I'll see

4 the consultants for DOE. They'll send out a

5 request for information that may not split out the

6 categories appropriately.

7 So one thought is to have a little bit

8 of understanding what -- and this is the

9 manufacturer would -- what are appropriate bins

10 (ph) for data, like 1 to 5, 5 to 10, 10 to 25, to

11 see what those -- they have a general sense of

12 what those categories of motor sizes, or however

13 you end up breaking your potential classes out.

14 But sometimes I'll see the information.

15 It'll be like 25 to 50 or, you know -- or they'll

16 take a number like 1 to 100, and they'll divide it

17 into four and set the classes up that way, which

18 end up not providing a lot of information. So it

19 might be helpful to manufacturers to provide some

20 suggested categories of horsepower ranges that

21 make sense.

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

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1 Jordan?

2 MR. DORIA: One distinction we want to

3 call out as you're thinking about equipment

4 classes would be a distinction between oil-free

5 and oil-flooded products. We definitely think

6 that they need to be two different product

7 categories, obviously recognizing, you know, that

8 we're talking exclusively about different kinds of

9 positive displacement products.

10 We believe that the reason is that

11 there's a very -- a distinct consumer utility for

12 oil-free products. They are required in many

13 different kinds of industrial applications for a

14 number of reasons related to food safety and the

15 like. And there's also a very, very significant

16 cost difference between oil- free and oil-flooded

17 products. So we would definitely recommend that

18 that be a consideration when creating equipment

19 classes.

20 MR. BROOKMAN: Okay. Final comments

21 here?

22 MR. KLINKE: Okay. Just going a little

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1 bit more into equipment classes, in general, for

2 DOE rulemakings, DOE divides covered products into

3 classes by the type of energy used; capacity of

4 the product; or other performance-related features

5 that justify different standard levels, such as

6 features affecting consumer utility. And so oil7 free versus oil-flooded would actually be a very

8 good example of that. DOE establishes separate

9 energy conservation standards for each product

10 class.

11 Compressor equipment class factors that

12 DOE is currently considering, the size of the

13 unit, measured in horsepower; the capacity of the

14 unit as measured in the volume of compressed air

15 delivered in cubic feet per minute; the

16 compression principle used; the type of energy

17 used; the method, or lack thereof, of inter- and

18 post-cooling; the absolute gauge output pressure

19 of the delivered air; and the method of

20 lubrication.

21 So some feedback requests that we have

22 on that, Item 3.2, DOE requests input from

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1 interested parties about the design

2 characteristics and criteria that it is

3 considering using when creating equipment classes.

4 In particular, should additional or fewer criteria

5 beyond those identified above be used as a basis

6 for developing our equipment classes?

7 And then Item 3.3, DOE requests input

8 from interested parties about how commercial

9 compressors should be separated into equipment

10 classes using the listed design characteristics.

11 MR. BROOKMAN: Rick?

12 MR. STASYSHAN: Yeah. We're prepared to

13 assist -- you know, I think the list you have

14 there is excellent. I think if you add to that

15 the comment made earlier that we include oil-free

16 and oil-flooded on the rotary positive screw

17 compressors, very appropriate because of technical

18 differences in the manner in which the air is

19 compressed, even used in similar technology, but,

20 you know, we would be prepared to assist in

21 compiling the data based on you request.

22 MR. BROOKMAN: Okay.

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1 MR. DELASKI: Follow-up question for

2 Jordan. This is Andrew deLaski. Is there an

3 efficiency penalty for oil-free? Is there an

4 efficiency difference in performance?

5 MR. DORIA: Yeah, as a general point,

6 there is a slight efficiency degradation for oil7 free product.

8 MR. DELASKI: Okay.

9 MR. RAUER: Size (inaudible).

10 MR. DELASKI: Excuse me?

11 MR. RAUER: Has to do with size also.

12 MR. STASYSHAN: But if I could make a

13 further comment -- and he did make reference --

14 there are some applications required by law that

15 the air has to be free of any oil lubricants in

16 the way of oil carryover, so oil-free compressors,

17 in the way of pharmaceutical and medical industry,

18 some instrument air absolutely requires oil-free

19 air.

20 Manufactured silicone chips and some

21 premium electronic products require and demand

22 total lack of oil in the compression process, so

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1 that is the only means of providing a lot of work.

2 MR. BROOKMAN: Uh-huh. Okay.

3 MR. DELASKI: Right, and I -- that makes

4 good, intuitive sense to me that that would be the

5 case, and -- by my follow-up question is you only

6 need a separate class if you have to -- if you

7 need it for -- to protect that product, because it

8 has an efficiency penalty, so if it can compete --

9 if there's no efficiency penalty, then (inaudible)

10 separate class.

11 MR. DORIA: No, I don't -- I mean, I

12 think that that is a supporting reason why we need

13 a separate class, but I don't believe the -- that

14 -- I mean, to test a consumer utility is more

15 about whether or not it serves a very unique

16 function compared to other comparable products,

17 not whether it does that and also can be

18 comparable in terms of efficiency. So I think the

19 consumer utility test is more about the difference

20 in need for customers for oil-free versus oil21 flooded. As it happens, there is also an

22 efficiency penalty, generally, for (inaudible).

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1 MR. DELASKI: (Inaudible) question for

2 Michael, because I think it's -- or for DOE,

3 because I think, you know, DOE's task is to come

4 up with product classes that they have to do

5 analysis for to set efficiency standards. So

6 you're making their task potentially more

7 complicated for more purpose if there's not an

8 extra -- if there's not an efficiency issue at

9 hand.

10 MR. KIDO: Right. I'm going to respond

11 to that real quick. So the whole statutory

12 structure in terms of setting up different

13 classes, the way that DOE has applied it is in the

14 context of setting up different classes that, for

15 whatever reason, require -- maybe there's a

16 difference in energy efficiency or energy usage,

17 and in order to provide that additional utility,

18 then we would set up a particular class that would

19 account for that particular feature or utility.

20 And so I -- actually, I had a question

21 for you, Jordan, just to follow up to this

22 conversation. You mentioned that there is an

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1 energy efficiency for the oil-free compressors.

2 So how much of a penalty are we talking about?

3 Can it be generalized, or does it depend on the

4 size of the compressor?

5 MR. DORIA: Since I'm not a technical

6 person, I'll generalize and let the technical

7 people correct me, because they won't like that,

8 but, I mean, I've heard it's a couple percentage

9 points, but it can vary, and I think if we were to

10 think about different product, you know, classes

11 by horsepower and things like that, there would

12 likely be some variability there.

13 MR. BROOKMAN: Wayne, you want to add

14 on?

15 MR. PERRY: As a general rule -- as

16 Jordan said, it does vary, but we look at it as

17 probably 8 to 10 percent difference in efficiency

18 between oil- flooded and oil-free, so it's

19 significant enough that I think it needs to be in

20 a separate classification.

21 You have to be very careful here,

22 though, because what you don't want is to have so

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1 many classifications that you wind up with some

2 really poor technology that gets a platinum rating

3 because it's the best of the poor technology when

4 there's other technologies out there that can --

5 that are much more efficient. This is one of the

6 examples where you really do need to separate

7 those things. If you're --

8 MR. BROOKMAN: So, Wayne, while we've

9 got you on the mic, are there other potential

10 equipment classes that you would call out at this

11 point, other things -- other features,

12 characteristics that would separate them

13 logically?

14 MR. PERRY: Logically, I think you would

15 separate the reciprocating product from the rotary

16 screw, rotary vane product.

17 MR. BROOKMAN: Those last two, would

18 they be in the same class, or would they be

19 MR. PERRY: I would like to -- they

20 should be in the same class because they serve the

21 same market, they have the same -- a lot of the

22 same characters, operating characteristics. Their

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1 efficiencies are very, very similar. So rotary

2 screw and rotary vane, I think, probably should be

3 in the same class, unless I hear anything -- any

4 objections from my colleagues.

5 But I -- reciprocating compressors,

6 that's been a real -- that gets to be very, very

7 tough, getting the reciprocating in, because most

8 U.S.

9 manufacturers of double-acting

10 reciprocating compressors have stopped making

11 them. They're very specialized now. They're very

12 efficient, but they're very expensive to maintain,

13 they're very expensive to install, and the

14 customers have just not continued to buy that

15 particular product.

16 Now, you get down maybe to some of the

17 smaller sizes, where you've got, you know, small

18 single-acting, two-stage piston compressor or

19 single- stage piston compressor, and you've got a

20 whole range of different efficiencies in those as

21 well. So that needs to be separated from the

22 rotary positive.

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1 MR. BROOKMAN: Okay. Jordan?

2 MR. DORIA: The other would be, I think,

3 you know, variable speed versus fixed speed is a

4 distinction. We likely would want to see that

5 variable-speed products be treated or, you know,

6 compared to other variable speed and fixed

7 compared to other fixed.

8 MR. BROOKMAN: Uh-huh. Okay.

9 MR. PERRY: Not only variable speed, but

10 there are variable displacement machines out there

11 as well that need to be -- that are designed for

12 part load machines, not designed for base load

13 machines, and they need to be looked at in a

14 little different

15 MR. BROOKMAN: Okay. Thank you, Wayne.

16 Thank you. Louis?

17 MR. STARR: So Louis Starr with NEEA.

18 So on the reciprocals, it sounds like they

19 actually can compete, in terms of efficiency, with

20 rotary vane and rotary screw, except when they get

21 into the smaller horsepower classes, but it sounds

22 like those smaller horsepower classes may be

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1 eliminated based upon where -- in other words,

2 they're not in -- not -- probably single-phase

3 products or maybe smaller than 10 horsepower may

4 be excluded from the rulemaking anyway, so in

5 reality, it almost sounds like the recips could be

6 in the same class as the rotary -- I mean, it

7 sounds like they have higher efficiencies, so they

8 would compete, but, I don't know, maybe some

9 thoughts about that.

10 MR. BROOKMAN: Wayne?

11 MR. PERRY: Yeah, I think we really need

12 to take a better look at that data. For the last

13 several -- two, three decades, I've been involved

14 with the rotary screw and not the reciprocating.

15 Prior to that, it was the reciprocating, but I

16 haven't kept up with where the efficiencies are.

17 And right now, we don't have a verification

18 program for piston compressors, so we can't really

19 take a look at those things to tell.

20 MR. BROOKMAN: Okay. Yes, Werner?

21 MR. RAUER: We may want to add there

22 that the same differentiation between oil-free

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1 versus lubricated also applies for the pistons,

2 the efficiency differences, so that's still

3 (inaudible).

4 MR. BROOKMAN: Okay, great. Louis?

5

6

7

8 MR. STARR: So one other question about

9 -- you indicated on the oil-free, it's 8, 10

10 percent -- 8 to 10 percent efficiency hit. Is

11 that of the isentropic efficiency, or is that in

12 the specific power that that is reflected?

13 MR. BROOKMAN: Wayne?

14 MR. PERRY: It's going to show up in

15 both.

16 MR. STARR: Both? Okay.

17 MR. PERRY: Yeah. Right. There's no

18 sealing (ph) fluid inside the rotor chamber until

19 you get some bypass -- some air bypassing from the

20 higher- pressure side to the lower--pressure side.

21 Uh-huh. That's just the nature of that kind of

22 compressor.

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1 MR. BROOKMAN: Okay. Final comments

2 here?

3 MR. STASYSHAN: Comment in 3.3.

4 MR. BROOKMAN: Yes.

5 MR. STASYSHAN: Rick Stasyshan,

6 Compressed Air and Gas Institute. We'd be

7 prepared to work with the DOE in coming up with

8 the impetus separation of those products and

9 classes, and, you know, we're interested to see

10 how today develops as to timeline. It'll take

11 resources, time from our member companies. CAGI

12 will be a clearinghouse for its members of the

13 data, but we are prepared to assist the DOE.

14 MR. BROOKMAN: Thank you. Okay.

15 MR. KLINKE: Moving on to a little bit

16 more information about the technology assessment,

17 so DOE uses information about commercially

18 available technology options and prototype designs

19 as input in identifying technologies used to

20 attain higher efficiency -- higher energy

21 efficiency levels.

22 So DOE has identified the following

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1 efficiency enhancing design options. These

2 include improved controls; improved air end

3 efficiency; improved cooling fan efficiency;

4 improved part-load efficiency; improved drivers,

5 which include high- efficiency motors and

6 variable-speed drives; and inclusion of multi7 staged compressors.

8 Stakeholder feedback requests on those,

9 Item 3.4, of the technologies listed above, are

10 there any that DOE should not consider because of

11 their impacts on safety, performance, or consumer

12 utility? And Item 3.5, are there other

13 technologies that DOE should consider as design

14 options, and what, if any, impacts would those

15 design options have on safety performance and

16 consumer utility?

17 MR. BROOKMAN: Before we move on, a

18 comment from David Prator, who's joining us

19 online. David says, "The efficiency of oil-free

20 rotary compressors is dependent on size,

21 horsepower" -- paren, "(horsepower) and on

22 compression design. From a consumer point of

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1 view, oil-free services a specific application."

2 Okay. So now on to Item 3.4 and 3.5.

3 MR. STASYSHAN: I'd like to make a

4 comment on 3.4.

5 MR. BROOKMAN: Rick.

6 MR. STASYSHAN: You know, basically, you

7 know, different manufacturers with different

8 models and different models by the same

9 manufacturer incorporate some combination of the

10 various elements listed above. CAGI and its

11 members can assist the DOE in understanding a

12 relationship of these components and a potential

13 impact on energy efficiency, and we'd be prepared

14 to work with you on that project.

15 MR. BROOKMAN: Yeah, as referenced in

16 3.4, are -- any of those items listed above that

17 should not be considered? That's the question.

18 MR. STASYSHAN: No, I think they're --

19 it's a good list.

20 MR. BROOKMAN: Good list. Rick.

21 Werner?

22 MR. RAUER: This may be a stupid

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1 question, but earlier we talked about the package.

2 The package includes all of this, if you're

3 talking about buying a compressor, so I'm not so

4 sure why this is considered from a different

5 angle.

6 MR. BROOKMAN: Yeah.

7 MR. RAUER: What's the purpose of this

8 question? I guess if the DOE --

9 MR. BROOKMAN: Well --

10 MR. KLINKE: A portion of our

11 engineering analysis, which we'll go into a little

12 bit more later, but when considering all of these

13 types of equipment, we'll basically look at

14 different packages, and we'll try to define a

15 baseline, which would be basically the most simple

16 equipment that you could get with the -- within

17 that associated efficiency.

18 And then we will define other design

19 options that you can use and incorporate to that

20 increased efficiency. And we'll then take a look

21 at those and see how, basically, pricing then also

22 compares to then the efficiency gains that are --

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1 that come with whatever design options that you

2 then had selected. And so we will take a look at

3 how the two affect each other, and those will be

4 used in later analyses of -- on market impact and

5 things like that.

6 And so as part of the technology

7 assessment, we're trying to find -- we're trying

8 to find those data sheet options that you can use

9 to go from effectively a baseline to then increase

10 your efficiency. And, as you say, they're all

11 part of the package, but we understand that some

12 things are going to make things more or less

13 efficient as you add and take them off.

14 MR. RAUER: Okay. Thank you.

15 MR. KLINKE: And we'll go into that a

16 little bit more detail, thankfully, in the -- the

17 immediately next section.

18 MR. BROOKMAN: Louis?

19 MR. STARR: So Louis Starr with NEEA.

20 On the controls, are you referring to controls

21 that are internal to what we are thinking of as

22 the extended product, or are you thinking of

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1 controls that relate to -- maybe that are in the

2 system, so something that's varying the speed of

3 the compressor or the capacity of the compressor

4 based upon conditions outside of the package?

5 MR. KLINKE: Currently considering --

6 based on the consideration that we're going to be

7 looking at, the package, it would be those

8 internal to the package that -- the inner

9 workings, as opposed to something -- controls,

10 maybe, set up by the user or set up by a

11 technician that would be affected by circumstances

12 in the system.

13 MR. BROOKMAN: Louis?

14 MR. STARR: So one thing to think about

15 that -- and this kind of goes to the pump

16 rulemaking that's going on -- is that they're sort

17 of looking at the aspect that if you have a

18 variable load, then having the ability to kind of

19 count controls as an aspect of saving energy,

20 right?

21 And with compressed air systems, I'm not

22 sure how much the system's actually changing

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1 (inaudible) applicable, but that if there is a

2 changing system pressure requirements of an air

3 compressed system, then you might want those to be

4 external to the system in order to encourage the

5 marketplace to put in variable-speed drives when

6 you have varying conditions on your load.

7 So, actually, maybe the CAGI guys could

8 reflect on how important having VFD speeds or

9 adjusting the load of the compressor as it relates

10 to system pressure in the system.

11 MR. BROOKMAN: Wayne?

12 MR. PERRY: We do a lot of system

13 design, total system design, and we have some

14 software that models how particular machines, our

15 machines and competitive machines, are going to

16 operate in a particular system. Unlike what

17 California did with their new building code and

18 Title 24 that pretty much mandates a variable19 speed machine if you've got one compressor or at

20 least one variable-speed machine if you've got

21 multiple compressors -- also mandates master

22 controls that look at the system to tell which

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1 compressor to turn on and off.

2 It's possible to design a system that's

3 as efficient with fixed speed, load/unload (ph)

4 compressors, and storage, lots of storage, as it

5 is a machine -- a system with variable-speed

6 compressors or variable-capacity compressors. It

7 all goes down to system design. If you want to

8 put a CFL LED label on something, then everybody

9 gets a variable-speed machine.

10 The problem with variable-speed machines

11 if you've got, you know, 4 percent, 3, 4 percent

12 of drive loss constantly. You know, it doesn't

13 matter if it's making its full capacity or 20

14 percent of its capacity, you've got that line (ph)

15 loss. And we see utility companies that rebate

16 for variable-speed machines, and we'll see three

17 or four of them in a system, and you've got, you

18 know, three out of four running at full capacity

19 when that could be a fixed- speed machine without

20 that line loss. And you wind up with systems that

21 are actually less efficient because of the way the

22 rebate programs have been designed.

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1 So it's very complex. And when you get

2 into pumping systems, you don't have a

3 compressible fluid, and so you really have to look

4 at what's happening out there, where in compressed

5 air systems, you can actually push a little bit

6 more of that in there to use for a particular

7 demand event that's going to happen. You haven't

8 really wasted all of that energy. You've wasted a

9 little bit of it by over-compressing, but it

10 covers and makes sure that the machine doesn't

11 have to -- a different machine doesn't have to

12 start.

13 Our goal is to -- as an industry is to

14 keep machines from starting, you know. Let's

15 design systems that use the minimum amount of

16 compressors and keep the maximum amount off.

17 MR. BROOKMAN: Bruce?

18 MR. STARR: So what it sounds like is

19 that just a VFD is not an actual thing to save

20 energy in a compressed air system, and so trying

21 to drive the market that way is not necessarily

22 the best thing. A better design would be a better

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1 solution.

2 MR. BROOKMAN: That was Louis. Now back

3 to Wayne.

4 MR. PERRY: Yeah, that's true. That's

5 not to say a VFD is not a very, very good part6 load machine, but it has to be applied properly.

7 MR. BROOKMAN: Yeah. Now --

8 MR. PERRY: We've seen lots of times

9 where they're not applied properly.

10 MR. BROOKMAN: Now Bruce.

11 MR. LUNG: Thank you. Bruce Lung,

12 ACEEE. Looking at this list of, you know,

13 enhancements, one quick question I have for Wayne

14 and perhaps CAGI is what about including storage

15 with a pressure flow controller? Because that

16 would kind of get rid of the, you know, pressure

17 on the compressor room from the demand events.

18 MR. BROOKMAN: Can you take that?

19 MR. STASYSHAN: Yeah. Rick Stasyshan,

20 Compressed Air and Gas Institute. If we go back -

21 - and, gosh, I've lost track of our articles, but

22 when we were in the early definitions, we were

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1 talking about the package or extended product,

2 which was the compressor box.

3 When you start talking about system

4 storage, be it a master system storage or point of

5 use storage flow controllers, then we start

6 getting into the demand side of the equation and

7 the extended compressor system. So we either have

8 to revisit back to the original part of the

9 document or progress forward, but, you know,

10 we're, you know -- those would be outside the

11 extended product or package box.

12 MR. LUNG: Okay. Thanks.

13 MR. BROOKMAN: Wayne?

14 MR. PERRY: I deal with storage, flow

15 controls, variable-speed machines, fixed-speed

16 machines all the time, and, basically, if you're

17 going to have storage and flow controls, that

18 works when you have intermittent demand events.

19 When you have a sudden spike where you get a

20 sudden demand and a lot of compressed air, you

21 want that already in storage so that, as I said

22 before, you don't turn on another machine to meet

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1 that demand.

2 In systems that have just a smooth

3 variation in demand, you don't need nearly the

4 amount of storage, and you can do it just as

5 efficiently with a variable-speed machine trimming

6 -- right-sized variable-speed machine trimming in

7 that situation. So when we design systems, we

8 design them both ways. It just depends on -- the

9 first thing we have to get is a demand profile to

10 decide what's the right set of equipment to meet

11 that. But to what Rick said, that's system issues

12 and not compressor efficiency issues.

13 MR. BROOKMAN: Okay. Yes, Andrew?

14 MR. DELASKI: Just to follow up, I think

15 part of the reason that I think some of us may be

16 struggling a little bit with this question is that

17 -- is what -- Wayne is right, or Rick is right.

18 It's that we had this earlier conversation about

19 what is inside the compressor box, and Rick ticked

20 off a bunch of things, and I go, "Okay, that makes

21 sense." But, you know, I don't know, as a non22 compressor expert, you know, what's in the box.

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1 So we need to understand a little bit better

2 what's in the box to be able to work on this list.

3 I mean, there seems to be some at least

4 tentative understanding that that is a desire, I

5 think, amongst some stakeholders of what was on

6 this package that goes -- comes -- is in the box,

7 so to speak.

8 MR. STASYSHAN: Want me to comment on

9 that?

10 MR. BROOKMAN: Please.

11 MR. STASYSHAN: Rick Stasyshan,

12 Compressed Air and Gas. The items listed here are

13 inside the box. Basically, you have electric

14 input coming into the box. You have a controller

15 for the compressor. You have a driver, the motor.

16 You can have a drive system, which could be a

17 variable-speed drive. Then you would have the

18 compressor unit. It could be driven either

19 directly off the motor or with gears. Oil

20 management system. A cooler. There would be a

21 cooling fan motor, typically. And then a pipe

22 coming out of that box. Sometimes there's a

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1 condensate drain inside that compressor box.

2 So within that extended product or

3 package, as we've defined it here, is what we're

4 talking about as electric in, air at a volume and

5 pressure coming out, going into the system. Then

6 from there, the air is treated to the customer's

7 requirement, which is generally an ISO standard of

8 removing condensate and any other particulate to

9 an air quality, because the customer wants clean,

10 dry air at the end, and a demand profile of the

11 operation that dictates what happens with that

12 air.

13 But what we've been talking about so far

14 today is the box, the compressor box, which would

15 be extended product or package, based on the

16 definition or documents we've seen in the past.

17 MR. BROOKMAN: Bruce?

18 MR. LUNG: Bruce Lung again. One

19 follow-up question. If condensate drains could be

20 included in the box, would it make sense to

21 specify them as zero- loss drains versus float22 style drains?

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1 MR. STASYSHAN: Yes.

2 MR. RAUER: Absolutely. Uh-huh.

3 MR. BROOKMAN: What about Item 3.5? Are

4 there other technologies that DOE should consider

5 as design options that aren't on this list?

6 MR. STASYSHAN: Rick Stasyshan from

7 Compressed Air and Gas Institute. We don't have

8 any right now at this time. We'd reserve,

9 obviously, the ability to add if --

10 MR. BROOKMAN: Sure.

11 MR. STASYSHAN: -- something comes up.

12 MR. BROOKMAN: Any others come to mind?

13 MR. DELASKI: So that was really

14 helpful, Rick, and I think that'll give us

15 something to work off of as we work to comment on

16 this. And, you know, (inaudible).

17 MR. BROOKMAN: Okay.

18 MR. DELASKI: You know, the cooling fan

19 efficiency's on here. Is the cooling fan motor

20 part of the combination? Seems like that would be

21 a consideration as well.

22 MR. BROOKMAN: Thank you, Andrew.

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1 Louis?

2 MR. STARR: Louis Starr with NEEA. And

3 I think one other thing was the internal control

4 system that can probably drive efficiency in that

5 package as well, so that would be one other item

6 in there.

7 MR. BROOKMAN: Michael?

8 MR. KIDO: I just had one real quick

9 follow- up question, and I apologize. I was out

10 when you all were discussing the test procedures,

11 but in evaluating the performance of all these

12 different components, either as a single package

13 or individually, how is it that a manufacturer

14 would go about doing that? I mean, I assume that

15 someone is applying one of the available test

16 procedures, or they're running some sort of

17 computer simulation model based on that procedure.

18 If that was discussed earlier, I apologize, but I

19 just -- I don't know how one would go about doing

20 that in this instance.

21 MR. STASYSHAN: Why don't I start, and

22 then Wayne can comment further? Rick Stasyshan,

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1 Compressed Air and Gas Institute. It was not

2 discussed.

3 MR. KIDO: Okay.

4 MR. STASYSHAN: But, you know, typically

5 -- and in my past life, I was a manufacturer,

6 currently with the trade association, but

7 manufacturers look at marrying the components to

8 get an overall product performance, maximize

9 specific power package output, and meet customer

10 criteria for reliability, dependability,

11 serviceability, and various elements along those

12 lines.

13 But, you know, what they take into

14 account -- because it was mentioned by myself

15 earlier that the largest element of life-cycle

16 cost to an end customer of owning a compressor is

17 the energy consumption. So, first and foremost in

18 every design criteria and the job ticket would be

19 improve the compressor's efficiency, and so they

20 look at the marrying of these components, they

21 look at the motor technology that's available and

22 has been improving over time.

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1 We have the NEMA Premium efficient

2 motors now. We have variable-speed drives, which

3 have developed into a maturity where they're

4 dependable, reliable, and available on the

5 commercial markets, you know, big transition over

6 the last 15 years, to where you would incorporate

7 those items when they make sense by an end product

8 application. And so the manufacturers would use

9 all those elements in defining a job ticket for

10 research and development of a new product.

11 MR. KIDO: Okay.

12 MR. BROOKMAN: Wayne?

13 MR. PERRY: To your question about how

14 they do the test, most manufacturers have got a

15 lab set up with the ISO -- well, if they're

16 positive displacement, with ISO 1217 equipment --

17 you know, the equipment they need to run the test.

18 They do the job ticket, as Rick said, to make the

19 design. Then they'll test it in the lab before it

20 goes into production.

21 If it meets their expectations, they'll

22 start a production run, and they'll usually test

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1 the first ones out of that production run in the

2 lab. They'll have a simplified test on the floor,

3 and to my knowledge, everyone now tests every

4 compressor before it goes out the door. There may

5 -- it may not be to the full extent of the 1217

6 testing, but they will occasionally pull back a

7 machine, run it through the lab again, just to

8 make sure that nothing has changed in their

9 manufacturing process.

10 And what they're looking for, really, is

11 are we off tolerance anywhere, manufacturing the

12 rotors, manufacturing a housing, because that's

13 going to show up in a performance test, and

14 they're going to see it right away. But they do

15 testing to the full 1217 Annex C if it's a rotary

16 screw compressor in order to verify that the

17 performance that they published is what it's

18 actually doing.

19 And in the United States, we all have to

20 be very careful to make sure that our performance

21 is on the button because we know it's going to go

22 to a lab in Plano, Texas and somebody else is

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1 going to test it. Intertek is going to test it to

2 that same 1217 Annex C, and it better perform, or

3 it gets labeled on the CAGI website as a failure.

4 MR. KIDO: Okay.

5 MR. PERRY: And nobody likes that.

6 MR. BROOKMAN: Werner?

7 MR. RAUER: Werner here from Kaeser.

8 Just wanted to add that just because you can, that

9 doesn't mean that everybody does it. There are

10 definitely manufacturers out there that ignore

11 these efficiency ruling measures because they do

12 sell at a certain price, and there's also

13 manufacturers that have two offerings in a certain

14 size. One is the premium model, and the other one

15 could be 20 to 30 percent off the specific

16 performance of the premium model, just as

17 (inaudible).

18 MR. KIDO: Okay. And so just --

19 MR. RAUER: Just ignore.

20 MR. KIDO: Okay. And just a real quick

21 follow-up, in conducting those tests, we're --

22 you're actually conducting a physical test based

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1 on ISO 1217. It's not necessarily a computer

2 simulation, or are those also part of the mix,

3 computer sims?

4 MR. BROOKMAN: That was Michael Kido.

5 Now (inaudible).

6 MR. STASYSHAN: Yeah, the manufacturers

7 do perform actual tests.

8 MR. KIDO: Okay.

9 MR. STASYSHAN: And, like we mentioned,

10 Compressed Air and Gas members -- and it's open to

11 non-Compressed Air and Gas Institute members also

12 if they meet the criteria for the selection

13 process, testing process, and third-party

14 verification process. But on the rotary positive

15 product, screw compressors, and rotary vane from 5

16 to 200 horsepower, we actually send the product to

17 a lab, but most of the products, the manufacturers

18 test a product to that standard in their test

19 sells to assure customers are getting what they're

20 asking for.

21 MR. KIDO: Okay.

22 MR. BROOKMAN: Thank you, Rick. Other

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1 comments here? No additional comments on other

2 design options, other technologies to be

3 considered? Nothing additional there? Okay.

4 MR. KLINKE: Okay. We'll now be moving

5 into the engineering analysis. Here's an overview

6 of our general methodology. The first step is to

7 choose representative equipment classes. We will

8 choose -- we'll choose them to analyze the

9 engineering and life- cycle cost analysis. Then

10 for each one of those classes, again, as I was

11 describing earlier, we'll define baseline models.

12 So we'll define the characteristics of these

13 models in each of the equipment classes. We'll

14 then identify replacements, so we'll select more

15 efficient units for each baseline model, based on

16 the design options that we listed previously.

17 We'll then develop efficiency levels that range

18 from the baseline to the maximum technologically

19 feasible, so basically from whatever our baseline

20 is to the most efficient technology. And then

21 we'll scale to equipment classes that were not

22 specifically analyzed as part of this.

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1 Now, so representative product classes,

2 DOE chooses representative equipment classes to

3 concentrate its analytical efforts, so we try to

4 choose those classes that are most representative

5 of the entire market. We select representative

6 equipment classes primarily based, again, on their

7 high market volumes. We then choose baseline

8 models in each representative equipment class.

9 For equipment that do not have existing standards,

10 DOE selects the most common, least efficient

11 compressor sold, and that's just inclusive of all

12 compressors across the scope.

13 Specific stakeholder feedback request,

14 Item 3.6, DOE seeks input from interested parties

15 about the selection of representative equipment

16 classes and baseline models and their efficiencies

17 for the engineering and life-cycle cost analysis -

18 - analyses. In particular, DOE is interested in

19 receiving information on which types and sizes of

20 compressors are most common, and whose efficiency

21 levels would be most easily generalized and

22 applied to other categories.

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1 MR. BROOKMAN: Rick?

2 MR. STASYSHAN: Yes, I have a comment on

3 that. The data requested in 3.6 would be a major

4 undertaking for the compressor manufacturers; will

5 require time and resources to compile the data for

6 the materials in a manner that is consistent and

7 useful to the DOE. While the CAGI can prepare

8 such materials for its members, it should be noted

9 that any of the manufacturers who are not members

10 of CAGI -- obviously, there are a number of them -

11 - wouldn't be included in this material.

12 Also, for this information, it would be

13 -- while it may be difficult to accumulate, we

14 want to definitely work with the DOE to make sure

15 that we're accumulating this data in a fine method

16 and a format that is consistent and useful for the

17 project. So, you know, we just don't want to

18 start on this path and then you come back, say,

19 "Oh, we'd like it in this format." We'd like to

20 establish a format, you know, at the onset.

21 MR. BROOKMAN: Thank you. Thoughts on

22 establishing a format? No?

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1 MR. KLINKE: That will be something

2 that we will have to develop as we go through the

3 analyses. Again, with this being a new product,

4 we're still figuring out what it -- exactly what

5 formats that we're going to want, exactly what

6 data we need, so that will be something that we

7 will have to develop as part -- as we move along.

8 MR. STASYSHAN: Okay. Well, we are

9 prepared to assist as required.

10 MR. BROOKMAN: Those manufacturers that

11 aren't a part of CAGI, do they produce a full

12 range of compressors, or are they kind of in

13 distinctive niches that might not show up in your

14 data sort?

15 MR. STASYSHAN: Yes and no. You know,

16 there are some that are just niche players and

17 just focus on a particular portion of the line.

18 We had mentioned single-acting recip compressors.

19 There are hundreds of people in that market. The

20 comment from the -- Edison Electric gentleman made

21 there, some gas compression people that are not

22 members are Compressed Air and Gas Institute.

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1 When it gets to the dynamic and rotary

2 positive products, other than the single-acting

3 piston, we have fairly good representation, but,

4 again, we don't want you to think we represent 100

5 percent of the market.

6 MR. BROOKMAN: Right. Louis?

7 MR. STARR: So this is Louis Starr with

8 NEEA. I've seen it done at other rulemakings, is

9 that if CAGI understands what their market share

10 is in each one of the markets, they sort of apply

11 a factor to your numbers. So if you're 50 percent

12 of the market, we will take your market numbers

13 and multiply by 2. Although, from what I've just

14 heard, it sounds like in the thing other than

15 electrically -- motor-driven equipment, you

16 probably don't really have a lot of information on

17 a single recip one, so trying to leverage those

18 numbers is probably not going to work, is what I'm

19 thinking.

20 MR. BROOKMAN: Additional comments here?

21 Did we cover this one? Yes, please, Brian?

22 MR. COFFEY: This is Brian Coffey with

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1 Navigant. In response to the question of data

2 collection, we could certainly help develop some

3 sort of a template in advance so that we were sure

4 that we were asking for the required information,

5 but no more, just to be respectful of everybody's

6 time and resources, if you would find that

7 helpful.

8 MR. STASYSHAN: Yeah. And further

9 comment on that, I mean, obviously, we'd give you

10 feedback if we thought your format was good or

11 bad. And, you know, our goal is to do it once to

12 make it useful to the project and not do it

13 multiple times.

14 MR. BROOKMAN: Right. That's what I was

15 hoping for. Thank you, Rick, and also Brian.

16 Okay. Now we're moving on.

17 MR. KLINKE: Okay. The next step would

18 be to identify replacements. So DOE selects more

19 efficient compressors for each baseline model by

20 considering the technologies that we listed before

21 and others that may not have been listed that are

22 not eliminated as part of the screening analysis.

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1 DOE plans to utilize a database of commercially

2 available equipment as part of this effort.

3 DOE would then plan to develop

4 efficiency levels based on two factors: the design

5 options associated with specific equipment types

6 being studied as well as the maximum

7 technologically feasible efficiency level, or we

8 frequently refer to that as the just mass tech --

9 the max tech.

10 DOE plans to use catalog data on

11 commercially available compressors to categorize

12 relationships between efficiency and technological

13 design options. And then, finally, standards for

14 non- representative equipment classes are

15 determined by scaling the standards from the

16 equipment that we did analyze to the rest of the

17 market, or at least the rest of the market that's

18 covered in our scope.

19 DOE plans to develop scaling factors by

20 comparing the efficiency level of representative

21 equipment classes to efficiencies of commercially

22 available compressors from non-representative

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1 equipment classes.

2 We now have -- and as part of this

3 engineering, we had a large number of specific

4 stakeholder feedback requests, so I'm going to go

5 through a couple of them at a time, and then -- a

6 couple on each slide, and we can refer to each one

7 and then move along.

8 So Item 5.1, DOE seeks input on the

9 methods and approaches used by manufacturers to

10 improve the efficiency of compressors and, in

11 particular, how frequently equipment redesign

12 would be the only method employed. Item 5.2, DOE

13 seeks input on appropriate baseline unit

14 efficiencies for commercial air compressors. Item

15 5.3, DOE seeks information regarding the specific

16 technological characteristics of the baseline

17 model for each equipment class, including the

18 technologies described in Section 3.3.

19 MR. BROOKMAN: Rick, you want to start

20 us off?

21 MR. STASYSHAN: Yeah, sure. Let's start

22 with -- we going to start with Item 5.1?

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1 MR. BROOKMAN: Yeah.

2 MR. STASYSHAN: Okay. You know, again,

3 we've committed to improve partial and potential

4 efficiencies of our products to maximize the

5 customer benefit, and each of our manufacturers,

6 members, have their own engineering and technology

7 roadmaps. Redesigns can be used to reduce

8 manufacturing costs by improved manufacturing

9 efficiency, lower material costs, improved

10 manufacturing flow, or simply to simplify the

11 service for the customer at the end customer

12 installation.

13 Most manufacturers have ongoing research

14 and development projects, and energy efficiency is

15 part of all our job tickets. So, I mean, we're

16 not exactly sure what the DOE is looking for in

17 5.1, but we're prepared to, from our member

18 companies, provide that input.

19 MR. BROOKMAN: Okay.

20 MR. KLINKE: Okay.

21 MR. BROOKMAN: Okay. 5.2, appropriate

22 baseline unit efficiencies, input on that?

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1 MR. STASYSHAN: Again, Rick Stasyshan,

2 Compressed Air and Gas Institute. We have some --

3 or we will be able to pull together, again, with

4 time and resources, baseline performance

5 information on the products that we currently have

6 within our datasheet and test programs. Somewhat

7 cumbersome, but it can be pulled together.

8 Some of the other products we're looking

9 to expand into, and along those lines, I'd be

10 talking about the dynamic compressors, and then

11 the single- acting piston, we don't have that

12 information, although we -- we're having

13 discussions and comments as we go on that. So it

14 could be somewhat of a burden and a resource

15 requirement. We'll look to you for guidance on

16 format, but we'll -- we're prepared to pull that

17 together.

18 MR. BROOKMAN: Okay. So based on your

19 other comments, it seems like Item 5.3, you would

20 not be able to comment on the characteristics of a

21 baseline model for each equipment class at this

22 time.

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1 MR. STASYSHAN: Well, I think if we can

2 come up with some more further clarification as to

3 what exactly we're looking for, we can come up

4 with that on many of the products.

5 MR. BROOKMAN: Okay. Louis?

6 MR. STARR: So to some extent, I think

7 some of those baseline characteristics are in what

8 you described in the extended product as what the

9 equipment is. So maybe you mean the associated

10 numbers with those rather than what the technology

11 is, because it sounds like those technologies are

12 some of the efficient things, efficient controls,

13 some of the other items in there, as I think I

14 heard over here at Kaeser, they were -- or Kaeser?

15 MR. RAUER: Yes.

16 MR. STARR: That there's some products

17 sold out there without these products on that save

18 in the price point by that, so just by having a

19 product in there, you're getting more efficiency,

20 but it costs a little more price. And so the

21 baseline -- I think the baseline technology and

22 the numbers associated with how much savings are

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1 associated with each one of those efficient pieces

2 that make it a more efficient product are not

3 clear, but the items that make it efficient are

4 clear.

5 MR. BROOKMAN: Wayne?

6 MR. PERRY: I have a comment that's

7 vaguely related to 5.1, 2, and 3, and that's just

8 the DOE needs to be very careful when we're

9 setting up equipment classes not to keep new

10 technologies out. Since I've been in this

11 business, there really hasn't been much new

12 technology in compressors. You have dynamic

13 compressors, you have rotary screw compressors,

14 you have piston compressors. We need to be very

15 careful that we don't keep some as yet

16 undiscovered new compression technology out by

17 writing the rules so tightly that you can't bring

18 a new product to market as well.

19 MR. BROOKMAN: Okay. Let's move on to

20 the next items.

21 MR. KLINKE: Okay. Item 5.4, for each

22 equipment class, DOE seeks comments on methods and

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1 approaches that DOE -- on the methods and

2 approaches that DOE intends to employ to determine

3 potential energy efficiency improvements for air

4 compressors. Detailed information on air

5 compressor performance and the related incremental

6 manufacturing costs -- for example, material

7 costs, labor, overhead, building conversion

8 capital expenditures, capital expenditures for

9 tooling or equipment conversion associated with

10 more efficient designs, R&D expenses, and

11 marketing expenses -- would be useful.

12 Item 5.5, DOE seeks comment on the

13 markup approach it plans to use when developing

14 estimates on manufacturer selling prices. And

15 Item 5.6, DOE seeks comment on its initial

16 approach for determining the relationship between

17 manufacturer selling price and air compressor

18 efficiency.

19 MR. BROOKMAN: Jordan?

20 MR. DORIA: Jordan Doria with Ingersoll21 Rand. This is something I think that is more

22 directly to the OEMs than probably the trade

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1 associations, so I can say that, you know,

2 Ingersoll-Rand would be willing to provide this

3 information, you know, under an NDA with, you

4 know, Navigant or other party working with the

5 DOE.

6 I do think, though, that as I look at

7 it, it seems like a lot of the other items we've

8 been discussing here, specifically on what are the

9 metrics, what are the definitions, what are the

10 product categories, would need to be -- I don't

11 want to say determined. We'd need a little bit

12 more clarity to -- you know, what could we do

13 around improving efficiency? Well, of what,

14 right?

15 So I think for us to meaningfully answer

16 this, we would need at least a little more

17 clarity, if not an actual final determination, to

18 provide something that would be useful in the

19 analysis.

20 MR. BROOKMAN: Okay. Additional

21 comments on these issues? Okay.

22 MR. KLINKE: Okay. Item 5.7, DOE seeks

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1 comment on appropriate transportation and shipping

2 costs to include in the analysis and whether those

3 costs are likely to vary for higher-efficiency

4 equipment. Item 5.8, DOE seeks comment on the

5 conversion costs required to improve the effective

6 of the air compressors to various levels as well

7 as what portion of these costs would be passed on

8 to the consumer.

9 Item 5.9, DOE seeks comment from

10 interested parties about the range and efficiency

11 levels that should be examined as part of its

12 analysis. And Item 5.10, DOE seeks comment from

13 interested parties about a methodology that would

14 be appropriate for determining the max-tech models

15 for each compressor analyzed.

16 MR. STASYSHAN: Okay.

17 MR. BROOKMAN: Rick?

18 MR. STASYSHAN: I'll start with the

19 shipping cost. You know, typically, shipping

20 costs vary, and they're based on weight

21 dimensions, the urgency by which the equipment is

22 expedited, and the distance shipped. Some more

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1 efficient models on the market may weigh a little

2 bit more or less than the others. It is our

3 experience that end customer decisions are rarely

4 based on freight costs, shipping costs. So it's -

5 - you know, because it's not determined by the

6 equipment itself.

7 MR. BROOKMAN: Okay. You want to -- can

8 you comment on conversion costs?

9 MR. STASYSHAN: Okay. I don't have any

10 pre- prepared comments on conversion costs, but,

11 obviously, it's -- you know, the end customer

12 would have to evaluate, you know -- because the

13 cost would be at his level, whether he wanted to

14 purchase new equipment, more efficient equipment,

15 and that's generally based on a system assessment

16 and audit at the facility.

17 A lot of the end customers, in

18 cooperation with the utilities -- and are utility

19 incentive packages available out there for

20 customers to take a look at this, because energy

21 is the number one life- cycle cost of a compressor

22 system -- has become a big part of our industry,

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1 and, generally, it's the operating divisions and

2 the analysis shown as to is it more efficient for

3 them to keep existing equipment or replace?

4 MR. KLINKE: What's up, Brian?

5 MR. BROOKMAN: Brian?

6 MR. COFFEY: This is Brian Coffey. I

7 can provide a little bit of context. I think that

8 this question is asking more about the costs that

9 would be incurred by the manufacturers, both in

10 terms of any capital that they would need to

11 purchase to produce more efficient units or just

12 even time spent, you know, doing more engineering

13 for the new units, anything like that. Obviously,

14 a little bit tough to quantify, but I think the

15 DOE makes a habit, or a practice, rather, of

16 including these costs in the analysis. So insofar

17 as they're able to be quantified and articulated -

18 -

19 MALE SPEAKER: Yeah.

20 MR. COFFEY: -- I think the Department

21 is interested is --

22 MR. BROOKMAN: It may be hard to

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1 anticipate that now.

2 MR. STASYSHAN: I guess to further

3 comment -- you know, and I speak for our industry

4 members -- I mean, first and foremost, on every

5 one of the technology roadmaps and job tickets of

6 our member companies, energy efficiency, on all

7 engineering projects, is the number one item

8 stated, because it's the number one customer

9 driver.

10 And so, you know, when we look at it,

11 you would have to look at the total R&D of all

12 ours, but the focus in recent years has, number

13 one item, energy efficiency; number two,

14 reliability, dependability, and in the energy

15 efficiency, we look at the specific power package

16 performance of the extended product or package.

17 And, you know, that's been a big driver and a big

18 part of our industry and the communication we've

19 made to the end markets.

20 So I don't know how to quantify it, but,

21 you know, as we look to improve efficiencies,

22 there's obviously expensing cost, and over the

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1 years, we've made significant costs, some of those

2 costs in the way of machine tooling and whatnot

3 and how we cut like screw compressors. The

4 machine tools that were made available in the last

5 20 years, in the way of grinding technology versus

6 (inaudible) technology that historically have been

7 done enables our member companies, in their

8 manufacturing, to cut these screws to very

9 complicated, asymmetrical designs to the tightest

10 of tolerances.

11 Huge, huge investment. Machines have

12 cost in excess of $1 million each, but the rest

13 has been significant improvements in specific

14 power package performance of our compressors of

15 the bare unit that is produced. That's one

16 element, and the members have made those

17 investments to provide the benefit of energy

18 efficiency to our customers.

19 So the cost can be very significant, and

20 based on the volume and the number of screws, that

21 a particular manufacturer may be, I mean, having

22 multiples of these million-dollar-plus machines in

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1 their machine shops.

2 MR. BROOKMAN: Okay. Yes, Wayne?

3 MR. PERRY: If you're talking about, in

4 5.8, the cost required to improve the efficiencies

5 of the air compressors to various levels -- let's

6 say you've got a machine that's at this level and

7 you want it to be at this level. From a design

8 standpoint, you may already have the air end. It

9 may be as tight a tolerance that the bare

10 compressor itself as is efficient, as practical to

11 make it.

12 Then you start looking at, okay, the

13 inlet valve design, is there a way I could flow

14 through the inlet valve differently? Could I come

15 up with a different inlet valve? Could I come up

16 with a different discharge piping? Is the oil

17 separation costing me too much pressure drop

18 across that?

19 That is -- those kinds of improvements

20 can get you from this level to this level, and

21 they are expensive to do. You may be talking

22 about having to do new castings, maybe even having

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1 to find new foundries who could do those castings.

2 There is some expense to do that. There's a lot

3 of engineering redesign to do. There's a lot of

4 computer modeling, fluid dynamics to figure out

5 what's the best way to do that. And you may do

6 all of that and find out you're already at the

7 best.

8 But all of these -- and you said how

9 much of the cost would be passed on to the

10 consumer? Traditionally, that's a cost of

11 business, and that cost of business is factored in

12 to the price of the machine, so all of it gets

13 passed along at some point. The companies don't

14 want to take a loss for doing these efficiency

15 improvements, so it does eventually get passed on

16 to the consumer.

17 MR. BROOKMAN: Wayne, can you talk --

18 can you address 5.9, about the range of efficiency

19 levels that should be examined?

20 MR. PERRY: Well, I could except I'm not

21 really sure what you mean about the range of

22 efficiency levels that should be examined. If I

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1 could get a little more clarification on that --

2 are you talking about setting three different

3 levels? Are you talking about what's out there

4 today? Because there's a huge range difference in

5 efficiency --

6 MR. BROOKMAN: Michael Kido.

7 MR. PERRY: Huge is a bad word. There

8 is a difference in --

9 MR. BROOKMAN: Yeah.

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10 MR. PERRY: -- in efficiency of what's

11 out there today.

12 MR. STASYSHAN: And if I could make one

13 comment. In the preliminary documents, in the

14 response that we sent back in February, you know,

15 we didn't answer 5.8, 9, or 10 in the preliminary

16 document because we weren't quite sure what was

17 being asked.

18 MR. BROOKMAN: I figured that, yeah.

19 Rick. That was Rick. Now to Michael.

20 MR. KIDO: Right. So the agency,

21 obviously, doesn't have any specific efficiency

22 levels in mind at this point, but I think this

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1 question is geared towards just the general

2 principle of, you know, what is it -- what would

3 be the additional costs that are involved in

4 moving from one level to another? I mean, what

5 types of -- are there certain types of costs that

6 we need to take into account that are outside of

7 what we laid out here, or--

And, really, it's -- and I'm going to look to

8 Brian here. I think it's -- like I said before,

9 it's really the general principle in terms of what

10 are the types of things that we have to take into

11 account when factoring in the potential costs that

12 are involved in setting up a potential standard

13 for compressors?

14 MR. BROOKMAN: Louis?

15 MR. STARR: I think maybe what would

16 help DOE is probably an understanding in your

17 various anticipated classes, but it would be the

18 isentropic efficiency changes and specific power

19 changes for given packages. So one would focus

20 typically more on the compressor, and the other

21 one would be the other parts of the extended

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1 product. So with those two, that would help them

2 sort of identify the cost and efficiency gains, so

3 it would sort of identify what opportunities there

4 exist in the actual compressor itself and then in

5 the packages, the specific power.

6 And then also, since the EU is doing

7 stuff based on a specific -- or, I'm sorry, on the

8 isentropic efficiency, then that could help align

9 some of the work that they've already done over

10 there in helping to prepare the markets.

11 MR. BROOKMAN: Werner?

12 MR. RAUER: Yeah. Since you mentioned

13 the Europeans, let me add something there. That

14 is completely different way they're looking at it.

15 They're looking at it from the application point

16 of view. For example, they are not diverting the

17 compressor classes, but they're saying there's

18 oil- free air as an application, and then they're

19 developing something in that range for that

20 application. And then there's the standard air,

21 not oil-free, and then develop standard for that.

22 So they're not going from the equipment

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1 on down, they're coming from the point of views --

2 a complete different approach than what you're

3 talking about here today. In order to do that,

4 though, however, they have to also do similar

5 evaluations and what's on the market; for example,

6 if you have an air compressor technology

7 (inaudible), if the DOE would say -- acknowledge

8 there's a certain principle, but the principle,

9 basically, is no good in terms of efficiency, but

10 they would still allow them to be in that range,

11 that would not be, in my opinion, a good idea. If

12 there's other technologies out there that are way

13 better and they're readily available, then maybe

14 it's time for that technology to die, so to speak.

15 So, again, the Europeans have a complete

16 different approach than what we're discussing here

17 today on the Lot 31, application versus product.

18 MR. BROOKMAN: Louis?

19 MR. STARR: Does the European Union have

20 a data collection tool that they're kind of

21 requesting from the manufacturers? I don't know

22 if that would--

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1 MR. RAUER: This is Werner again. I

2 think Wayne mentioned this earlier, that they

3 basically use the only database, quote, unquote,

4 that's available on the world market, which is the

5 CAGI data sheet, which is published information.

6 And let me also make a comment here. Earlier

7 there was something about catalog data. What you

8 have on catalog data is a piece of paper. There

9 is no oomph behind it. (Inaudible) motor on there,

10 but that doesn't mean that the flow they state

11 there, that the pressure state there, there's

12 nothing behind it unless there is a specific

13 statement made that it meets the either ISO

14 standard or any other standard or has been third15 party-verified.

16 So I just warn you, from just looking at

17 catalog, it gives you maybe an overview, but I

18 would not take the data for granted that this is

19 actual performance data. The only one we know of

20 is the CAGI data sheets that are published on the

21 manufacturers' websites, and that's also the data

22 that the Europeans were collecting in order to get

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1 a apple-to-apple comparison of certified data

2 (ph).

3 MR. BROOKMAN: So additional comments

4 here? How about 5.10, methodology that would be

5 appropriate for determining the max-tech models

6 for each compressor analyzed? Rick, go ahead.

7 MR. STASYSHAN: We had no comment at

8 this point. Again, I think we're -- as we work

9 through this process, it will help us to find what

10 we're looking for --

11 MR. BROOKMAN: Yeah.

12 MR. STASYSHAN: -- and that -- but I

13 think we're a couple meetings down the road before

14 we'd have a comment in that area.

15 MR. BROOKMAN: Okay. Nothing additional

16 there. 5.11?

17 MR. KLINKE: Okay. 5.11, are there

18 proprietary designs or technologies of which DOE

19 should be aware for any of the commercial air

20 compressors under consideration as part of its

21 efforts in evaluating whether to set standards for

22 commercial and industrial air compressors? If so,

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1 how should DOE acquire the cost data necessary for

2 evaluating these designs?

3 Then Item 5.12, are there outside

4 regulatory issues that DOE should consider in its

5 analysis of commercial air compressors?

6 MR. BROOKMAN: Proprietary designs,

7 Rick?

8 MR. STASYSHAN: Rick Stasyshan,

9 Compressed Air and Gas Institute. You know, each

10 of our manufacturers has some level of proprietary

11 designs in their compressor systems, whether it's

12 the -- in the screw compressors, the profile of

13 the air end control systems, oil management

14 systems, oil separation systems, et cetera. So,

15 you know, it's -- there are many proprietary

16 designs out there, and that's what separates, you

17 know, our manufacturers and our members in the

18 commercial market in the way of product

19 performance.

20 And so there are many, and I suppose we

21 could, you know -- we further define what we're

22 specifically looking for there. We could gather

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1 or have our individual members provide that

2 material to the Department of Energy.

3 MR. BROOKMAN: Okay.

4 MR. STASYSHAN: Concerning 5.12 -- and

5 I'll answer that while I'm on the microphone --

6 you know, the Compressed Air and Gas members work

7 to meet the standards in the United States,

8 Canada, the EU, and for that sake, the global

9 markets. And we made (ph) close liaisons with the

10 regulatory groups, whether it's the CSA in Canada,

11 the EU, in its various elements, and PNEUROP in

12 Europe, ASME, UL, OSHA, and the EPA here in the

13 United States. So, you know, we made (ph) close

14 liaisons, and I guess we could list those by

15 compressor type for the DOE; again, looking for a

16 format to pull that information together.

17 MR. BROOKMAN: Yeah, and I guess in this

18 case, maybe they're referring to not the agencies

19 so much as the things that they are asking the

20 manufacturers to comply with that would be a

21 constraint or limitation. Wayne?

22 MR. PERRY: If you're talking about a

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1 constraint or limitation to improving efficiency,

2 I don't think -- you know, I've racked my brain.

3 I can't think of any safety regulations or EPA

4 regulations, MSHA regulations, any regulations

5 that would impact these incremental improvements

6 in efficiency that we're talking about.

7 MR. BROOKMAN: Okay. Yes, Louis?

8 MR. STARR: Just one suggestion. I

9 don't think, necessarily, people understand what

10 max tech applies to in terms of what that actually

11 defines. To us, I know what that means, but maybe

12 --

13 MR. BROOKMAN: Yeah.

14 MR. STARR: -- you might explain that a

15 little bit more.

16 MALE SPEAKER: Please.

17 MR. COFFEY: Yeah, I mean -- this is

18 Brian Coffey with Navigant. Basically, that's

19 just the maximum technologically feasible level,

20 so, really, the best you could do if you kind of

21 pulled out all the stops. That's not to imply

22 anything about whether it's cost-effective or

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1 available in the market today, but if you built it

2 out of unobtanium (ph) at $1,000 a kilogram, how

3 far could you take it? (Inaudible) being asked

4 there.

5 MR. BROOKMAN: Yeah. Go ahead, Rick.

6 MR. STASYSHAN: Thank you. Rick

7 Stasyshan, Compressed Air and Gas Institute. And,

8 you know, in regards to some of the discussion

9 that's gone on here, I think, because we haven't

10 ruled out fossil fuel or other types of

11 compressors, those compressors are currently under

12 EPA regulation for the diesel engine emission

13 standards and are now required to either hit Final

14 Tier 4 or Interim Tier 4 regulations.

15 When you look at the bigger horsepower

16 in those sizes, that was a very significant change

17 in the way of design, heat rejection, of these

18 packages, and, as a result, to hit an emissions

19 standard may not be the best from energy

20 efficient, and it definitely had a significant

21 financial impact to both the manufacturers

22 designing these products, the diesel engine

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1 manufacturers supplying these products, and the

2 end customers buying these products.

3 MR. BROOKMAN: That's a good

4 illustration of the kind of information that DOE's

5 seeking. Yeah. Okay. Other comments here?

6 Andrew deLaski.

7 MR. DELASKI: So I want to come back to

8 the prior slide, if I could. So, you know, I

9 think that normally, under Item 5.9, when DOE goes

10 to develop levels to analyze, what you would

11 typically do is gather data on the marketplace,

12 and you would look at the spread of data, and you

13 would pick levels that were -- typically are --

14 cover the range, characterize specific

15 technological jumps. Is that what you would do in

16 this case? That would be the general approach?

17 MR. KLINKE: Yes. We would look at what

18 is available on the market as well as any -- and,

19 as Brian said, our max tech goes up to something

20 that's not necessarily available on the market.

21 It's just what if you could theoretically possibly

22 get to -- so we will take a look at those, and, as

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1 you said, we'll take a look at where we look at

2 primary technological levels, and we'll see how --

3 or primary technological designs. We'll look at

4 ranges for those.

5 And if you were to say include, then,

6 this next technology design, we'd look at the

7 range there. And so, yes, that is how we will --

8 we'll take a look at what is on the market and the

9 energy efficiency values for units that have these

10 different types -- design options and look at the

11 efficiency ranges there.

12 MR. DELASKI: Well, it strikes me that

13 the data that's been gathered by the EU's that's

14 been described earlier, you know, could be an

15 excellent starting point --

16 MR. KLINKE: Right, uh-huh.

17 MR. DELASKI: -- for -- and one approach

18 is to look at the design options; the other is

19 just to do with -- similar to what the EU's done

20 is just look at levels, what happens if you go

21 with certain levels, just to top 20 percent, top

22 50 percent by efficiency and look for

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1 discontinuity in the data too.

2 So that strikes me that that's going to

3 be a pretty straightforward task for those

4 products that are part of the CAGI program, but

5 for other products that aren't part of the CAGI

6 program, we just heard earlier that you can't

7 trust the catalog data, so I guess I would just

8 sort of open it up that there's a -- that you

9 probably have a good data source for perhaps a

10 large portion of the market, but for that portion

11 of the market that there's not -- there's not a

12 CAGI program, there may be some serious data gaps

13 that are going to make it difficult.

14 I don't have an answer to that. And I

15 guess I throw it back to the industry guys. You

16 know, and if you can't trust the catalog data,

17 what do you look to for these products for which

18 there is no CAGI program?

19 MR. BROOKMAN: Rick?

20 MR. STASYSHAN: Rick Stasyshan,

21 Compressed Air and Gas Institute. Our members,

22 when we went to the standards, we agreed to -- all

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1 our published data from all our members would be

2 in compliance with the standard, testing to the

3 standard, and when verification was expanded to

4 that product, participate in the verification

5 process. And right now, we're doing that in

6 rotary positive screw and vane compressors, 5 to

7 200 horsepower, and for refrigerated air dryers.

8 For the members -- people that are not

9 members of CAGI, you know, one of the things that

10 we feel that our program did was gave us some

11 market traction with serious buyers and customers

12 that are looking for energy efficiency and

13 performance, and we see the participation as, you

14 know, a competitive advantage.

15 But, you know, we know there are people,

16 as was mentioned in some of the earlier dialogue

17 and discussion from people in participation, that

18 there are people selling in the price market that,

19 you know, decide not to participate in such

20 programs and, you know, as one comment was made,

21 you know, their performance is a piece of paper,

22 not necessarily known or not known whether they're

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1 standing behind the performance on their sheets.

2 But the membership to CAGI stand behind the

3 performance on their printed material.

4 MR. DELASKI: So just to follow on, I

5 think one of the challenges for the Department --

6 and it's definitely a challenge I don't have the

7 answer -- is going to be to characterize the

8 baseline, because what we're hearing, I think, is

9 that the data that's published in the CAGI data

10 sheets maybe is going to represent a portion of

11 the market, but it's not going to capture the

12 bottom of the market in terms of performance,

13 perhaps, you know, because who wants to publish --

14 why would you publish it if it's -- if you're

15 competing on price, you're not going to get beat

16 on performance.

17 So we need to be careful, when

18 characterizing the market, that we're not limiting

19 it to just the CAGI data, even though that's the

20 best data, but it's not going to characterize the

21 full market, particularly for that important

22 question of what's the baseline.

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1 MR. BROOKMAN: Brian Coffey.

2 MR. COFFEY: This is Brian Coffey with

3 Navigant. Two strategies come to mind to me that

4 DOE has done in the past for other products. One

5 is that DOE sometimes actually physically

6 purchases, tests, and tears down products so that

7 it's not fully relying on what manufacturers claim

8 their product can do, right, or if the information

9 isn't complete, DOE will actually try -- attempt

10 to do its own physical validation.

11 There are limitations to that, of

12 course. Number one, it's expensive and time13 consuming. Usually you're dealing with a smaller

14 sample size, so there is some uncertainty on the

15 result, but it's at least a way to gather some

16 primary data.

17 The second way is with some sort of

18 computer modeling or extrapolation. If DOE can

19 say, you know, based on these parameters, we're

20 able to see this sort of a trend, and, you know,

21 if we're able to extend the trend, here's what we

22 would get, and ordinarily DOE will attempt to seek

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1 comment on that approach. Is it consistent with

2 what manufacturers see? Is it of an accuracy

3 level that's useful in this sort of rulemaking

4 context?

5 There may be others as well, but I think

6 if there are ideas about how DOE might go about

7 gathering such data using those two strategies, I

8 think we'd be really eager to hear about it.

9 MR. BROOKMAN: Okay.

10 MR. DELASKI: And I just -- I'll follow

11 on. I think -- it strikes me that, based on what

12 I've heard today, that, you know, some tear-downs

13 (ph) to characterize the baseline would be

14 necessary in this market.

15 MR. BROOKMAN: Wayne? Thank you,

16 Andrew, and now to Wayne.

17 MR. PERRY: One other little comment on

18 this is that the market share of those people who

19 are not CAGI members is relatively small, so when

20 we're talking about extrapolating numbers, number

21 one -- and being a technical guy, I can't really

22 put my thumb on it, but I'm in a lot of plants, I

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1 see a lot of machines, and I don't see non2 members' machines -- or I see non-members'

3 machines very rarely, so I don't think that that

4 represents a large portion of the market, and

5 correct me if I'm -- if you guys have a

6 (inaudible).

7 MR. BROOKMAN: Go ahead, Rick.

8 MR. STASYSHAN: Rick Stasyshan,

9 Compressed Air and Gas. That would be true in the

10 rotary positive --

11 MR. PERRY: Right.

12 MR. STASYSHAN: -- or the dynamic

13 compressors, where, you know, obviously, the cost

14 of entry is -- and the barriers to entry are

15 significant, so the major players are already

16 members of our trade association. When you get to

17 the single-acting recip market, that's where,

18 again -- and when you get to gas compression and

19 when you get to the fossil fuel markets, while

20 some of our members participate in some of those

21 segments, we wouldn't represent the representative

22 classification of the total market.

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1 MR. BROOKMAN: Jordan?

2 MR. DORIA: Yeah, Jordan Doria with

3 Ingersoll-Rand. I sort of feel that what we need

4 is some attempt to do some sort of just side by

5 side of what CAGI covers today and what percent of

6 the market, both by volume and sort of efficiency,

7 that covers, and then what is DOE proposing, and

8 to try and look at exactly how much overlap we

9 have or do not have and try and figure out, you

10 know, where the gaps are there, where we should be

11 focusing our attention, and that's (inaudible) --

12 MR. BROOKMAN: Louis?

13 MR. DORIA: -- we need to do.

14 MR. STARR: So clarification. It sounds

15 -- in the single-acting reciprocating compressors,

16 is that going to mean the range 10 to 100

17 horsepower, or are there going to be single-acting

18 compressors in that area?

19 MR. STASYSHAN: They can go up in higher

20 horsepowers. They can go up to 50 horsepower --

21 MR. STARR: Okay.

22 MR. STASYSHAN: -- up to 100 horsepower,

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1 really, so

2 MR. STARR: Okay, so that's one --

3 MR. BROOKMAN: Thanks, Rick.

4 MR. STARR: The other question that I --

5 the other thing is, is this kind of goes back with

6 the things that are not driven by electric

7 equipment that are required to meet the EPA Air

8 Quality Standards. I think one of the things that

9 has happened is that what they end up doing is

10 they shift back. They make it so that the motor -

11 - they meet the air quality, but it actually hits

12 the efficiency quite a bit by that, so in order to

13 meet one standard, they sacrifice efficiency to

14 meet that, so that's not a very desired outcome.

15 MR. BROOKMAN: Okay. Final comments on

16 this series of questions? Let's do one more

17 slide.

18 MR. KLINKE: Okay. So product price

19 determination, so the purpose of the engineering

20 analysis and the product price determination is to

21 provide a relationship between increases in energy

22 efficiency and then increases in cost, both for

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1 the manufacturers and for the end users. As part

2 of the manufacturing costs, we use a traditional

3 manufacturing cost process, which has equipment

4 costs, so recurrent costs associated with

5 manufacturing, and then conversion costs,

6 investments to bring production facilities and

7 equipment designs in compliance with the new

8 regulation.

9 So these are then used in the downstream

10 analyses of market impact and national impact to

11 determine, based on what our proposed levels may

12 be, how that would then affect both manufacturing

13 and consumer costs and then just the national

14 impact analysis further on.

15 MR. BROOKMAN: There's no comment box

16 here. Do you want to pose a specific question?

17 MR. KLINKE: No, we don't have any

18 Specific questions.

19 MR. BROOKMAN: So this is just a

20 description of how the Department would approach

21 this. Questions and comments on this slide? Yes?

22 MR. STASYSHAN: Rick Stasyshan,

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1 Compressed Air and Gas. From a trade association

2 standpoint, we would stay clear of this topic,

3 but, you know, individual members would be

4 prepared to provide this data if required.

5 MR. BROOKMAN: Thank you. Yes, Jordan?

6 MR. DORIA: Jordan Doria with Ingersoll7 Rand. Just a sort of clarifying question. I'd

8 said before that, you know, Ingersoll-Rand would

9 be willing to provide some of the information that

10 can support this under an NDA. Is this something

11 that you would just -- we would just simply enter

12 into an NDA with you? Is this part of a

13 manufacturing impact analysis? That's how we've

14 done this in the past, so I'm -- you know, we're

15 open, but I'm just asking.

16 MR. BROOKMAN: Michael Kido?

17 MR. KIDO: Yeah, I think past is

18 prologue in this case, so the practice that we

19 followed earlier with respect to the submission

20 and acceptance of that information, I think would

21 be similar.

22 MR. BROOKMAN: Yeah. Brian, do you have

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1 anything to add?

2 MR. COFFEY: No, just exactly that. DOE

3 and/or some of its contractors would typically

4 reach out to manufacturers to initiate that sort

5 of process.

6 MR. BROOKMAN: Okay. So we've made a

7 lot of progress here this morning, covered a lot

8 of ground, and I think the quality of comment from

9 everybody in the room has been really excellent;

10 very, very helpful to the Department.

11 I'm going to suggest we go to lunch.

12 It's just about almost 12:30. So it takes an

13 hour, if you don't go anywhere, to have lunch

14 around here, typically. And for those of you that

15 are new, you can follow the pack, but basically,

16 you go down to the ground floor and go about a

17 hundred yards that way to the cafeteria. There's

18 also a Subway shop right there, adjacent to the

19 coffee shop, ground floor in the other direction,

20 which is also pretty quick.

21 So let's resume at 1:30 here. Please

22 make sure to wear your badge. You might need a ID

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1 to get back through the security cordon (ph) on

2 the -- at the big cafeteria. And also, this room

3 will be secured, so you can leave your stuff here.

4 There will be someone watching this room in your

5 absence.

6 So good start on today, good progress,

7 good responses. We'll see you back here at 1:30.

8 (Off the record.)

9 MR. BROOKMAN: Okay, let's resume. As I

10 said, we -- as we went to lunch, we had a very

11 productive morning, and I really appreciate the

12 quality of the contribution and the comment that's

13 been received so far. Now we're going to pick up

14 where we left off, and we're going to hear from

15 Chris.

16 MR. BOLDUC: Yeah.

17 MR. BROOKMAN: Markups.

18 MR. BOLDUC: Hi, there. My name's Chris

19 Bolduc. I work for Lawrence Berkeley National

20 Lab. I'll be representing the Department on the

21 economic analysis.

22 Up to this point, we've heard

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1 presentation on the physical equipment and how

2 it's going to be characterized in the future rule.

3 From this point forward, we're going to first look

4 at how a possible rule will affect consumers of

5 the new, improved efficiency compressors, and then

6 look at how this may benefit the nation.

7 So the first step, the Department will

8 characterize markups. So the purpose of this

9 analysis is to determine customer air compressor

10 cost based on manufacturer selling price for both

11 the baseline and higher-efficiency equipment. The

12 markups relate to the price of -- to the cost of

13 goods sold. And the other purpose of this

14 analysis is to characterize the distribution

15 channels for compressors.

16 DOE calculates markups as an average

17 ratio of MSP to customer cost. Baseline markup

18 relates the price to the cost of baseline

19 equipment. And this covers all of a retailer's or

20 distributor's expenses plus profit, and this

21 excludes manufacturer profit. All right? So this

22 would be in addition to it.

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1 Further, the incremental markup relates

2 the incremental change in customer cost for more

3 efficient equipment to the baseline. And this

4 will -- it's a very small amount.

5 On the following page, on the next

6 slide, we have the distribution channels. Now,

7 this is DOE's guess of the current -- at the

8 moment of the different channels for the different

9 types of compressors, how they make their way from

10 the manufacturer to the ultimate end user. And

11 when we go into the preliminary analysis, DOE will

12 estimate a baseline markup and an incremental

13 markup for each of these channels.

14 So comment -- Item 6.1, DOE seeks

15 comment on the distribution channels and their

16 share of industry shipments for each distribution

17 channel shown here as it applies to the range of

18 compressors that DOE is considering regulating.

19 MR. BROOKMAN: Yes, please?

20 MR. STASYSHAN: Okay. Rick Stasyshan,

21 Compressed Air and Gas Institute. Each

22 manufacturer maintains a closely guarded channel191

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1 to-market information due to the extreme

2 competitive nature of our industry. This data is

3 not publicly available.

4 Manufacturers who use a wide variety of

5 approaches to market, such as direct sales,

6 company- owned retail outlets, Internet sales

7 companies, authorized distributor networks, sub8 distributor networks, catalog houses, sales

9 agents, national account programs, and OEM

10 accounts are used by the compressor manufacturers.

11 Some employ all or part of this list to solicit

12 sales.

13 CAGI and its members can assist the DOE

14 in this area. I think there are -- you know, I --

15 we haven't done a validation as to the split that

16 you're suggesting here by the various products,

17 but, again, we're prepared to work with you on

18 that.

19 MR. BOLDUC: Thank you. I'm wondering

20 if the manufacturers in particular could comment

21 if there are any missing agents on our list.

22 Right now it's a very short distribution chain.

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1 We have the manufacturer going through one --

2 here, a single agent between manufacturer and

3 final consumer.

4 MR. BROOKMAN: Louis?

5 MR. STARR: Seems like you haven't

6 identified the channels, just distributors in

7 there, and that wouldn't necessarily be an

8 authorized dealer.

9 MR. BOLDUC: Right. What we have lumped

10 into this, I believe, in the framework document,

11 on authorized dealers, we put in the retail

12 channel. We don't --

13 MR. BROOKMAN: Authorized --

14 MR. BOLDUC: We don't anticipate there

15 being that many or -- maybe I'm being naive, but

16 MR. BROOKMAN: Wait -- and maybe I -- go

17 ahead.

18 MR. STASYSHAN: Rick Stasyshan,

19 Compressed Air and Gas. I think, you know,

20 sometimes -- oh, I'm sorry. Sometimes people

21 flip-flop the word "dealer" and "distributor," you

22 know, in different connotation. Some cases, they

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1 often mean the same. Most of our members,

2 distributors or dealers, are full outlets in which

3 they provide sales, service, and support of the

4 product on its services and, you know, provide

5 technical services to the customer in the way of

6 support. So that -- you know, in the case of like

7 rotary screw is the primary channel to market,

8 whether they're independently owned or company9 owned.

10 MR. BROOKMAN: That's what I wanted to

11 ask about. Okay. So no additional comment at

12 this time, especially from the manufacturers

13 present? Jordan?

14 MR. DORIA: Yeah, Jordan Doria with

15 Ingersoll-Rand. We'll look to try and respond to

16 this and maybe, you know, try and provide that,

17 perhaps through CAGI, so it could be done on sort

18 of an aggregated basis.

19 I think the one distinction, I think,

20 was touched on is within these channels as well as

21 some of those that Rick mentioned, I don't know to

22 what extend the Department cares about sort of

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1 nuances of whether or not -- you know, maybe we're

2 selling through a particular -- excuse me. We, as

3 an OEM, may still be involved in the design and

4 install process, so it can get a little sort of

5 muddied in that regard.

6 I guess the point is are we totally

7 divorced from the final customer, or are we

8 involved in the sales process, and to what extent

9 does the Department care about that distinction

10 for the purpose of trying to get information here?

11 MR. BOLDUC: In relation to this

12 analysis, what we're looking for is what different

13 markups, really, are going to be used? So if

14 you're involved through one of your distributors,

15 is the markup on the MSP to the final consumer

16 different than it would be if you were, say,

17 involved with a retail merchant? Right?

18 MR. DORIA: Okay.

19 MR. BOLDUC: That's kind of -- that's

20 the nut we're looking at here.

21 MR. DORIA: So, really, the number of

22 (inaudible) is really the same as the number of

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1 markups that we have, right?

2 MR. BOLDUC: Yeah, within a certain, you

3 know --

4 MR. DORIA: Reason, yeah.

5 MR. BOLDUC: We can get crazy with it,

6 but

7 MR. DORIA: Okay. Okay, that helps.

8 Thank you.

9 MR. BOLDUC: Yeah.

10 MR. BROOKMAN: Louis?

11 MR. STARR: This is Louis Starr with

12 NEEA. Part of this, the size of the channels I'm

13 looking at there, and I see authorized dealer at

14 90 percent, 48, and 50 for the three categories

15 you have, you know, in terms of the efficiency

16 label, is that going to be -- you know, at that

17 point, the manufacturer that actually makes the

18 compressor no longer has it. Is the intent of the

19 distributor going to be putting the label on the

20 equipment? Is that how DOE sees that?

21 MR. BOLDUC: Well, first, I don't think

22 DOE's agreed to put a label on anything.

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1 MR. STARR: Or --

2 MR. BOLDUC: If DOE were to put a label

3 on -- I'm going to defer to Mike on this.

4 MR. BROOKMAN: Michael Kido.

5 MR. KIDO: Yeah, I think Chris has got

6 it right. I mean, we -- at this point, you know,

7 we're not sure how a labeling scheme would

8 actually work at this point, but typically, our

9 authority extends in terms of ensuring that

10 there's compliance with whatever standards that

11 end up being covered as a result of this process.

I would

12 imagine that it would be a label that would be

13 applied at the manufacturer level, but that's

14 something that can be discussed. And we'll have

15 to look at that and look at the different

16 variables.

17 MR. BROOKMAN: Louis?

18 MR. STARR: Okay. So not so much about

19 the label. I should have said who has to meet the

20 efficiency requirements of the final product? So,

21 in other words, essentially it's being

22 manufactured at the dealer. There may be a bare

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1 compressor that comes from one of the suppliers,

2 but then the other pieces may get put on, and so

3 someone has to say this is going in the

4 marketplace, and someone has to make a

5 determination that it's meeting the efficiency

6 requirements, so the manufacturers, in this case,

7 aren't really putting the final product out that

8 could be tested. The person that's really putting

9 the final product out is the authorized dealer.

10 MR. KIDO: Right.

11 MR. STARR: And so that's kind of what I

12 was referring to.

13 MR. KIDO: Right. So if I could just

14 respond to that real quick. So the issue of, you

15 know, who's the manufacturer is really -- I

16 understand that's the crux of the issue here. And

17 so I think that particular question is going to

18 require some thought on DOE's part. I mean, there

19 is a statutory definition, and I think we're all

20 familiar with what it says. It's a matter of

21 implementation, and I'm not sure how DOE is going

22 to do that at this point.

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1 MR. BROOKMAN: Bruce McFee, who's

2 joining us online, writes in, "Sales of some

3 reciprocating air compressors have become almost

4 like the wild, wild West. You can bid for full

5 units or bare pumps on eBay, et cetera." Yes,

6 Rick?

7 MR. STASYSHAN: An additional comment.

8 Rick Stasyshan, Compressed Air and Gas. I think

9 when -- to address the comment made earlier,

10 rotary positive and centrifugal pretty much are by

11 the manufacturers building the complete extended

12 product or package. The reciprocating, like Mr.

13 McFee commented over the phone, would be one of

14 the areas where you have the distributor dealer

15 doing some local packaging in some cases.

16 MR. BROOKMAN: Okay. That's useful,

17 that discrimination there. Louis?

18 MR. STARR: Just one other thing also

19 about the categories. It's not clear to me that

20 there's actually specific utility with the

21 reciprocating one that couldn't be provided by the

22 other two, so I'm not really clear that there

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1 necessarily needs to be separate classes.

2 So the only utility seems to be a lesser

3 price, and so if there's -- it almost seems like,

4 in your scope of coverage, you could determine a

5 horsepower rating or some range that indicates

6 that you're selecting that piece of equipment

7 because it has substantial run hours and uses

8 substantial equipment that perhaps the split-out

9 of the classes no longer makes sense, and they

10 should all be competing in the same class. I

11 would encourage DOE to take a look at that.

12 MR. BROOKMAN: Wayne?

13 MR. BOLDUC: Thanks, Louis.

14 MR. PERRY: I'd like to comment to that

15 point. Let's take 15 horsepower application. And

16 you could do that with a piston compressor. You

17 could do it with a rotary screw compressor. And

18 the rotary screw compressor may be more efficient

19 than the piston, or the piston may be more

20 efficient than the rotary screw, but let's say the

21 rotary screw happens to be more efficient than

22 this particular one that you're looking at.

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1 The choice of whether to do a piston

2 compressor or a rotary screw compressor

3 (inaudible) many sizes, is very much application4 dependent. If you're using a compressor a couple

5 of hours a day, it's absolutely the wrong

6 application for a rotary screw compressor, no

7 matter how efficient it is, because the rotary

8 screw compressor needs to get up to temperature,

9 stay at temperature, and be there. They like to

10 run a hundred percent of the time, fully loaded,

11 at -- that's the way they operate best. If you're

12 operating them a couple of hours a day, what

13 you're going to wind up is water condensing inside

14 of the unit, wiping out the bearings, wiping out

15 the air end.

16 So in that application, if you're just

17 using it a couple of hours a day, it doesn't

18 matter what the efficiency is. The piston

19 compressor is going to be the right choice, not a

20 rotary screw, so you have to be real careful on

21 (inaudible).

22 MR. BROOKMAN: Louis?

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1 MR. STARR: So when you say that's real

2 -- I mean, I would think someone buying in that

3 horsepower range seems like they're planning to

4 use it a lot, but is there applications where

5 you'd say that, you know, realistically, we're

6 only going to use that two hours a day, and maybe

7 we have certain pressure requirements such that we

8 need that kind of a piece of equipment? Is that

9 kind of the idea on that?

10 MR. PERRY: Well, we sell rotary screws

11 in that size range and smaller, and we have them

12 continuously misapplied, and we have problems with

13 those misapplications. So, no. Somebody watched

14 Gas Monkey, and they see -- Gas Monkey Garage, and

15 they see a Kaeser compressor off in the corner,

16 and they think, "Ah, that's what I want for my

17 shop."

18 And so they go buy one, and then they

19 only use it a few hours a day, and it turns out to

20 be a disaster. Could be my machine, it could be a

21 Sullair machine, it could be an Ingersoll-Rand

22 machine. We all face that same issue, so

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1 MR. BROOKMAN: Did they not -- they

2 didn't go through a qualified rep, or

3 MR. PERRY: Of course they did.

4 MALE SPEAKER: And he made the sale.

5 MR. PERRY: And that -- and he made the

6 sale at about twice what the piston compressor

7 would have cost, so

8 MR. BROOKMAN: Okay. Okay. Louis?

9 MR. STARR: Well, it sounds like there's

10 -- I think, to me, it sounds like there is a

11 utility here, that it didn't -- it wasn't clear to

12 me until I had this conversation, so

13 MR. BROOKMAN: Okay.

14 MR. BOLDUC: Just to follow up -- sorry.

15 MR. BROOKMAN: Yes, please.

16 MR. BOLDUC: If the results of the scope

17 work -- scoping work that we do, and if equipment

18 class definitions substantially change or, when we

19 have them defined, that may influence how this

20 table looks. What I'm most concerned about is

21 that we're capturing all the agents involved in

22 the sale of a compressor.

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1 One thing that sticks in my mind is in

2 the case of, say, new construction, where you have

3 design/build engineers come in, who buys the

4 compressor? Does the building contractor buy it?

5 Do they take a margin? Something we don't know.

6 MR. BROOKMAN: Yeah. Rick?

7 MR. STASYSHAN: Rick Stasyshan,

8 Compressed Air and Gas. Any one of a number of

9 ways. I mean, in some cases, the end customer

10 buys it direct; in some cases, a, you know,

11 mechanical contractor or building contractor may

12 specify -- you know, the customer says, "I want

13 this much air at this much pressure," and he

14 selects the compressor.

15 MR. BOLDUC: Okay.

16 MR. STASYSHAN: And any combination in

17 between. I mean, it's -- you know, some cases,

18 they do an assessment, an audit, and come in with

19 a recommendation and (inaudible) recommendation.

20 So there's lots of -- it's difficult to nail it

21 down, say, "X percent of the time, this is how

22 it's bought."

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1 MR. BOLDUC: Sure. Okay.

2 MR. BROOKMAN: Okay?

3 MR. BOLDUC: So following this, the

4 Department will then move on to estimating the

5 energy use for the compressor and then figuring

6 out or trying to estimate a customer's life-cycle

7 cost. So the purpose of the energy use is to

8 identify the annual energy consumption of

9 equipment in order to assess the energy savings

10 potential of energy efficiency improvements.

11 DOE will develop a statistical model to

12 describe the expected range of end-use air demand

13 profiles for compressors for a variety of -- in a

14 variety of applications; plan to use manufacturer

15 performance data to determine the energy use of a

16 compressor under the expected deviation from peak

17 efficiency. And DOE uses the annual energy

18 consumption and energy savings potential in the

19 LCC and payback period analysis to establish

20 savings in the customer operation costs at various

21 efficiency levels.

22 So we have a lot of comments here.

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1 Compressors seem to be a piece of equipment that

2 has the widest range of energy use that pretty

3 much I've seen while working at DOE. So Item 7.1,

4 DOE requests comment and recommendations for

5 identifying high sales volume and large installed

6 base application segments corresponding to

7 specific applications for which compressors used

8 may have similar end-use air demand profiles.

9 Item 7.2, DOE seeks recommendations on

10 sources of data or analysis methods that would

11 provide end-use air demand profiles for each of

12 the equipment classes of compressors falling

13 within the major application segments that are

14 under consideration as potentially regulated

15 equipment.

16 Item 7.3, DOE requests input on the ways

17 to characterize compressor sizing and selection

18 practices for different equipment classes and

19 applications. Item 7.4, DOE requests comment on

20 the degree of equipment oversizing that is

21 prevalent in different application segments.

22 So I think -- yeah?

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207

1 MR. BROOKMAN: Let's just start with

2 those.

3 MR. BOLDUC: Yeah.

4 MR. BROOKMAN: Okay.

5 MR. STASYSHAN: Okay. Let me -- this is

6 Rick Stasyshan, Compressed Air and Gas. I'll

7 start with 7.1.

8 MR. BOLDUC: Uh-huh.

9 MR. STASYSHAN: Again, it'll take time

10 and resources and expense, but we can assist you

11 in coming up with the (inaudible) of the sizes by

12 the classification of product. That will be

13 pretty much for the products that Compressed Air

14 and Gas Institute represent, a very good sample

15 for the market.

16 MR. BROOKMAN: And just to be clear,

17 you're not collecting that data presently?

18 MR. STASYSHAN: We have data in

19 different formats. Again, you know, like

20 different sections and different manners.

21 MR. BROOKMAN: Uh-huh.

22 MR. STASYSHAN: But, obviously, we'd

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1 want to have something that was uniform and

2 consistent, regardless of the product, to pull

3 together for this, but

4 MR. BROOKMAN: Okay.

5 MR. STASYSHAN: Do you want me to

6 continue?

7 MR. BROOKMAN: Please do.

8 MR. BOLDUC: Yeah.

9 MR. STASYSHAN: Okay. 7.2, end user

10 demand profiles, while some CAGI members or

11 distributors and independent compressor auditors

12 conduct end user compressed air energy audits,

13 these reports are usually confidential between the

14 user and the auditor. Special permission would be

15 required to share the demand profile with an

16 outside source. It should be noted that these

17 audits would not be close to a representation of

18 the total market by compressor class. Also, each

19 application and operation is indeed unique, and

20 even audits among and conducted at different

21 plants by the same owner, the demand profiles will

22 most likely differ.

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1 This reinforces our general feeling that

2 the current programs in training and education are

3 indeed the best approach to continuing energy

4 efficiency in this market. We think coming up

5 with an end user demand profile is going to be

6 difficult.

7 MR. BOLDUC: We agree, and so we'll be

8 talking about it a lot in future meetings.

9 MR. STASYSHAN: Great. And we know

10 you're aware of that, so -- you want me to

11 continue?

12 MR. BROOKMAN: Yes, I do.

13 MR. STASYSHAN: Okay. 7.3, size and

14 selection, you can refer to the Compressed Air and

15 Gas Handbook, which is referenced in the DOE

16 document, the Best Practices Handbook, which is

17 also referenced in the DOE document. That's a

18 Compressed Air Challenge document. The

19 information is -- from the Compressed Air and Gas

20 Institute is downloadable for free to anybody at

21 www.cagi.org. The Compressed Air Challenge

22 material is available -- and, again, I listed the

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1 website, www.compressedairchallenge.org.

2 There are many factors that contribute

3 to the sizing and selection decisions of a

4 specific job. Some are very simple, others

5 extremely complex. CAGI and its members recommend

6 a comprehensive compressed air audit or compressed

7 air system assessment to be conducted when

8 feasible to properly size this equipment and the

9 support components, as noted in the Compressed Air

10 Challenge and CAGI material. CAGI and its members

11 are prepared to assist DOE in some of the

12 criteria, but, again, we think it's difficult to -

13 - just carte blanche that comment.

14 MR. BOLDUC: Yeah, sure.

15 MR. STASYSHAN: And then continuing on

16 to 7.4 on potential oversizing, the demand of an

17 operation dictates whether an installed system is

18 adequate, inadequate, or oversized. A significant

19 change in production demand can cause numerous

20 outside influence. For an example, a recession

21 might cause a system that was perfectly sized at a

22 time of the installation to be oversized in the

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1 peak of a recession.

2 Again, CAGI and its members will assist

3 the DOE in compiling this information, but, again,

4 we don't think there's data as to the number of

5 systems that may be potentially oversized at the

6 point of sale.

7 MR. BROOKMAN: Okay.

8 MR. BOLDUC: So there's no rule of

9 thumb, margin of error that's applied when buying

10 -- that engineers will use when they buy a new

11 compressed air system?

12 MR. STASYSHAN: I think it's more

13 critical to the application of a customer. I can

14 give you some examples.

15 MR. BOLDUC: Sure.

16 MR. STASYSHAN: If the compressed air in

17 a manufacturing -- or manufacturing process is

18 absolutely critical, the owner might buy redundant

19 products so that in the event of an unplanned

20 scheduled turn of events, an unscheduled

21 maintenance event or repair event, production

22 continues, where the cost of having redundant

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1 equipment sitting there, standby equipment, is

2 cheaper than having the factory go down.

3 MR. BOLDUC: Understood. The cost of

4 (inaudible) necessitates buying a second piece of

5 equipment. But quite often, with other products,

6 I've heard of consumers buying equipment with the

7 eye on growth, future growth, so

8 MR. BROOKMAN: I see Wayne is able to

9 comment here.

10 MR. PERRY: I go into a lot of plants in

11 the U.S. and other parts of the world, and I often

12 see oversizing. I often see multiple units

13 running at varying efficient part-load levels,

14 simply because they don't want to get a call from

15 the floor saying, "Hey, I don't have enough air,"

16 so they turn everything on. It's very difficult

17 to get them to turn things off. It's very scary

18 for them to turn things off.

19 I'm trying to convince one particular

20 plant right now that they could turn a 600-

21 horsepower compressor off because all its doing is

22 blowing off (inaudible). It's not doing anything

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1 at all. But they're afraid. The people in charge

2 of supplying compressed air to the plant, since

3 it's a critical utility, don't want to be blamed

4 for having off- quality product because the

5 pressure went down or having a shutdown in the

6 system, so they tend to run everything they've

7 got.

8 The issue is not whether they bought too

9 many compressors. It's really how they're

10 controlling them. And it goes back to being a

11 system issue and not a compressor issue. They can

12 have the most efficient compressors out there when

13 they're running at their design point, and all of

14 them are running off of their design point, so --

15 and that's a case where you'd look at the system,

16 and you look at a master controller that says,

17 "Okay, I can turn these machines off, and when the

18 need comes on, I can turn them back on."

19 But in my experience, 50 percent or

20 greater of the applications have more compressors

21 than they actually need, and they're running those

22 compressors when they don't really have a need to

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1 run them. So I -- that's a real issue in the U.S.

2 MR. BROOKMAN: Thank you. Rick, I

3 wasn't sure you were finished.

4 MR. STASYSHAN: Yeah. No, and to add to

5 Wayne's comment, it's a control sequence

6 discussion, which really gets into demand cycle

7 management versus the supply side, which the

8 discussions today have centered around. It's how

9 the customers are using -- you know, and a good

10 example would be automobiles. You can have the

11 most fuel-efficient automobile, but if someone

12 jackrabbit starts and slams on the brakes between

13 traffic lights, you know, revs the engine at high

14 RPMs while they're idling at a traffic light,

15 their fuel consumption isn't going to be anywhere

16 close to the EPA sticker on the window.

17 And same thing happens in air

18 compressors. And so I think that's a good analogy.

19 It's a question of managing the system properly,

20 which is education of the users.

21 MR. BROOKMAN: Louis?

22 MR. STARR: It's been a while, but it

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1 seems like there was kind of some basic rules of

2 thumb. It was like three times the air volume so

3 that your compressors are cycling only 20 minutes

4 every hour or something, so that may be some

5 really broad things, but it seems like there was

6 kind of some really basic ones, because I think

7 they're going to have to assume some stuff about

8 the energy use profile (inaudible), because it

9 doesn't operate a hundred percent of the time, and

10 it doesn't operate zero, so I'm wondering if

11 they're -- they're probably looking for that

12 number that helps them dial in the energy usage

13 for given horsepower and bins of data.

14 MR. BROOKMAN: Wayne. Or, no, Werner,

15 go ahead.

16 MR. RAUER: I'd like to -- this is

17 Werner. I'd like to comment on what you earlier

18 asked. Almost every single system that does not

19 run 24/7, meaning if you go home at five and then

20 you're running just leakages (ph) or anything you

21 shut down -- you do not shut down on the weekend

22 is completely oversized or misapplied happens all

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1 the time. That's a little bit out of our control,

2 because a customer says, "I have limited space. I

3 need that much air during production." Then he

4 will get two of those big-sized machines, and then

5 when he comes to go home on the weekend, it's that

6 big machine operating a minimal leak (ph), because

7 he cannot shut the pressure down.

8 So that's prevalent all over the

9 industry, and some of it out of our control. We

10 can only give advice. We could certainly --

11 technically it's possible to design a system that

12 is suitable for all of these applications 24/7,

13 including a recession. You cannot anticipate more

14 air to be used, of course. You have to buy more

15 equipment, but you could design a system that is

16 overall, as a system, energy-efficient no matter

17 what happens to the industry or to your production

18 over the course of the day, week, or year. So it's

19 absolutely possible, but it's a little bit outside

20 of the package. Now we're talking system design

21 and system controls.

22 MR. BOLDUC: Thank you very much.

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1 MR. BROOKMAN: Wayne wants to add on.

2 MR. PERRY: Yeah. To what you said

3 about -- Louis, about some general rules, if you

4 were using air-cooled piston compressors, there

5 are absolutely rules on duty cycle and how long

6 you can -- you know, how big of storage you have

7 to have, because the compressor has to have time

8 to cool. And you're talking about bigger systems

9 with centrifugal compressors or rotary screw

10 compressors, those -- and some piston compressors,

11 they're designed to run a hundred percent duty

12 cycle, so those rules don't apply to those

13 machines.

14 MR. BROOKMAN: Okay. Thank you.

15 MR. BOLDUC: Thanks. I just want to say

16 thank you. We understand that it's outside of the

17 scope of the manufacturer to control how the

18 compressor's used once it leaves the floor, but

19 this analysis, what we're interested, really, in

20 seeing is what the energy use profile looks like

21 in the wild, so to speak. Like when it gets out

22 there, what do people do, and how does it work?

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1 Moving on, a few more comments. Item

2 7.5, DOE seeks comment on methods of determining

3 nominal, non-market segment specific, end-use air

4 demand profiles for compressor equipment classes

5 under consideration in this document.

6 Item 7.6, DOE seeks comment on the

7 current penetration level of variable-speed

8 drives, VSDs, in the installed base of equipment

9 in each application segment for the various types

10 of compressors that DOE is considering regulating.

11 DOE also seeks comment on the baseline conditions

12 for applications without VSDs, such as running at

13 full load, use of controls.

14 Item 7.7, DOE requests comment and

15 recommendation on the range and numbers of sizes

16 over which the analysis should be carried out for

17 each specific compressor capacity in cubic feet

18 per minute and rated air pressure.

19 And Item 7.8, DOE requests comment and

20 estimates to establish the mean value and the

21 ranges of likely values for transmission, motor,

22 motor control, and compressor control efficiencies

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1 as well as the impact of a control on compressor

2 and motor performance and efficiency.

3 MR. BROOKMAN: Rick?

4 MR. STASYSHAN: Okay. This is Rick

5 Stasyshan, Compressed Air and Gas, and I think we

6 should add world peace.

7 MR. BOLDUC: Sure.

8 MR. STASYSHAN: Let's start with 7.5.

9 Yeah, we can assist in coming up with some rules

10 of thumb. It's going to be difficult based on the

11 variety of applications, but Compressed Air and

12 Gas can assist there. Data on VSD versus standard

13 motor -- induction motors, we can provide that

14 data and provide, you know, some rules of thumb on

15 full load, base load, and use of controls.

16 On 7.7, also, again, we can provide that

17 data, and as we've mentioned in all the items

18 where we're going to be asked for data is coming

19 up with some uniform consensus to the format, run

20 it by our members, make sure it's right so we do

21 it once, because it's obviously a lot of work.

22 The Point 7.8, you know, as a trade

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1 association, we probably would not do that. When

2 you start talking about the specifics of a given

3 manufacturer and that, we'd have to rely on the

4 member companies providing that data to the DOE on

5 an individual basis.

6 MR. BOLDUC: Thank you.

7 MR. BROOKMAN: Yes, Werner?

8 MR. RAUER: This is Werner. I'd like to

9 have a clarification on Item 7.6, where it say,

10 "DOE also seeks comment on the baseline condition

11 for applications without VSDs, such as running in

12 full load, use of controls, et cetera." What

13 exactly do you mean by that?

14 MR. BOLDUC: We touched on it in the

15 previous conversation. I'd like information on

16 how the load level of a single-speed compressor,

17 under normal load conditions, if possible, if that

18 could be correlated with control type or control

19 strategy at the compressor level.

20 MR. BOLDUC: Moving on?

21 MR. BROOKMAN: Yes.

22 MR. BOLDUC: The next step in the

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1 analyses for the preliminary is we will try -- the

2 Department will try and estimate the life-cycle

3 cost and payback periods for customers with air

4 compressors. The LCC analysis establishes the

5 total cost of an appliance over its lifetime --

6 the appliance in this case would be an air

7 compressor -- including the purchase price and

8 operating costs from the customer's perspective.

9 LCC equals customer purchase price plus

10 the sum of operating annual costs -- energy,

11 repair, and maintenance -- discounted to a

12 particular base year. The payback analysis

13 calculates the amount of time required for the

14 energy cost savings to pay back any increased cost

15 of efficiency -- of higher-efficiency equipment.

16 DOE plans to conduct an LCC and payback

17 analysis for the equipment identified in the

18 engineering analyses. And DOE determines the LCC

19 and payback periods for particular standard levels

20 of efficiency related to the base case equipment

21 efficiency.

22 So moving on to the next slide, we have

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1 an overview of the model. So we can see up in the

2 top right, we have the engineering analysis coming

3 in and the test of baseline MSPs with standard

4 level MSPs, and for the markups analysis, we have

5 the distributor, contractor, and sales tax. This

6 is a generic spreadsheet, so distributor and

7 contractor, we'd replace with the channels that

8 were shown on the previous slide. From the energy

9 use analysis, we have energy consumption, and we

10 can see how it just feeds on out, right?

11 I'm going to go over the variables in a

12 little more detail, but if you have any questions,

13 fire.

14 Okay. So installation costs includes

15 labor, overhead, and other miscellaneous materials

16 and parts. Energy prices, with -- DOE will use the

17 latest version of EIA's Annual Energy Outlook to

18 estimate future electricity prices, and DOE will

19 develop marginal prices for 13 geographic areas --

20 the nine census divisions plus four large states,

21 New York, Florida, Texas, and California, -- as

22 they see different energy costs in relation to the

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1 rest of the nation.

2 Maintenance and repair costs, DOE

3 expects small incremental changes in equipment

4 efficiency to incur no or -- little or no change

5 in these costs. For equipment with significant

6 energy efficiency improvements over the baseline,

7 there may be increased repair and maintenance

8 costs.

9 As a side note, DOE is looking at the

10 maintenance schedule outlined in the Compressed

11 Air Challenge in Appendix 2A as the basis going

12 forward. I believe that's an hourly schedule.

13 MR. BROOKMAN: Let's just pause there.

14 Chuck Foster?

15 MR. FOSTER: Chuck Foster, EEI. Chris,

16 under energy prices, the second bullet is

17 "Marginal prices will be developed for the 13

18 geographic areas." Can you elaborate a little bit

19 on what marginal price you're thinking about here?

20 MR. BOLDUC: Yeah. Because we're

21 looking at commercial and industrial equipment

22 primarily, the electricity prices tend to be

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1 structured as block rates. So if we take the --

2 if we manage to reduce X amount of kilowatt hours

3 a year, well, that'll have a different price than

4 it would if you were looking at it from the -- I

5 guess the bottom of the block rate. It's just to

6 capture the difference in prices between when you

7 --

8 MR. FOSTER: Average versus marginal.

9 MR. BOLDUC: Exactly.

10 MR. FOSTER: Yeah.

11 MR. BOLDUC: Thank you.

12 MR. FOSTER: And it would be -- you're

13 looking at using last block pricing,

14 assuming that any energy saved would be

15 at the margin there.

16 MR. BOLDUC: Yeah, the savings --

17 MR. FOSTER: I'm asking --

18 MR. BOLDUC: The savings would come off

19 the top, generally, with the absence of knowledge

20 of any other efficiency improvements that the

21 customer was facing.

22 MR. FOSTER: Thank you.

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1 MR. BROOKMAN: Thank you. Bruce McFee

2 online responds regarding 7.6. "VSDs are not used

3 by reciprocating compressors, and due to their

4 start/stop nature, they are not needed for

5 reciprocating models." Thank you, Bruce.

6 MR. BOLDUC: Moving on, Slide 66,

7 product lifetime, DOE plans to use information

8 from catalogs and various literature sources and

9 input from stakeholders to establish compressor

10 lifetimes. DOE believes the average air

11 compressor lifetime in the field is between 10 and

12 20 years, depending on the type and size. A

13 European study -- source is below -- has air

14 compressor lifetimes between -- sorry -- the air

15 compressors between 13 and 147 horsepower to be 13

16 years, and those between 147 to 495 horsepower to

17 be 16 years. During the Title 24 work, California

18 estimated the lifetime to be 15 years.

19 So discount rates, DOE will derive

20 discount rates by estimating the cost of capital -

21 - the capital costs for commercial and industrial

22 companies that purchase air compressors, and this

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1 will be used to discount any energy -- the value

2 of any energy savings in the analysis.

3 MR. BROOKMAN: What about those product

4 lifetimes? Do you think they're in the ballpark?

5 MR. STASYSHAN: You know, again, it's

6 difficult to put it down. I mean, we know of

7 compressors that, you know, are operating that are

8 30, 35 years old. And, you know, we know there

9 are other customers that recognize the efficiency

10 of newer products and update their products in

11 shorter time windows if they can justify the

12 payback based on energy consumption if they're

13 cost-conscious. So it goes by the user, but, I

14 mean, probably a start point.

15 MR. BROOKMAN: Yeah.

16 MR. BOLDUC: A counterpoint to -- when

17 the compressors are engineered, are they

18 engineered with a certain number of run hours for

19 their lifetime?

20 MR. STASYSHAN: Again, Rick Stasyshan

21 from Compressed Air and Gas Institute. I mean,

22 compressors are generally viewed as a fourth

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1 utility in a manufacturing operation or

2 manufacturing process. Like electricity and the

3 other utilities, the end customer wants to wake up

4 in the morning and not think about compressed air.

5 The manufacturers and the Compressed Air

6 and Gas Institute members have basically built

7 dependability, reliability into the life of our

8 products, and if they are maintained, the

9 customer's using genuine consumables, maintained

10 in the product -- or the recommended maintenance

11 schedule, modified that maintenance schedule if

12 the conditions are harsher than normal, and doing

13 all the right things and perhaps maybe even having

14 a service contract by a reputable and authorized -

15 - fully authorized service, you know, machines

16 that are 30, 40 years old are not uncommon, and,

17 you know, it gets down to, you know, maintenance,

18 much like it is in any kind of machinery.

19 And generally the customers, you know,

20 because compressed air is an important part of

21 their operation, do follow good maintenance.

22 There are other customers that are horrendous.

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1 Don't get me wrong. But, you know, as we educate

2 more and more people, we're seeing compressor life

3 lasting very long.

4 MR. BROOKMAN: Thank you. Wayne?

5 MR. PERRY: To what Rick said, you

6 absolutely do see some very, very old equipment

7 out there. You also see some five, six, seven,

8 eight- year-old equipment that's dead, and it goes

9 back to maintenance and operating environment.

10 MR. RAUER: Misapplication.

11 MR. PERRY: Misapplication. Then you

12 also have to get really focused on efficiency.

13 You have to keep in mind that rotary screw

14 compressors, for example, generally don't lose

15 efficiency over time. There's no valves that are

16 part of it. There's no rings that are part of it.

17 Unlike piston compressors -- piston compressors

18 reach their peak efficiency when their valves and

19 rings seat, which is a few weeks after they start

20 operating, and from that point, the efficiency

21 starts to slowly go down to the point where they

22 have to be -- you have to put new rings, new

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1 valves in and get that efficiency level back up.

2 So those are issues. These numbers,

3 however, for a lifetime would be reasonable for

4 average over the entire market, I think. But

5 you're going to see a wide variation in that as

6 well. When we do life-cycle cost, generally, we

7 look at life- cycle cost over the first ten years,

8 simply because it's easier to do than try to

9 extend out 15 years and try to figure out whether

10 even parts are going to be available beyond 15 or

11 20 years, because that's an issue as well.

12 MR. BROOKMAN: Okay. Thank you. That's

13 helpful. Let's move to the comment boxes.

14 MR. BOLDUC: Sure. So Item 8.1, DOE

15 seeks comment on whether installation costs for

16 air compressors increase with higher-efficiency

17 equipment. Item 8.2, DOE invites comment on

18 whether repair costs may change for more efficient

19 air compressors. Item 8.3, DOE seeks comment on

20 appropriate air compressor lifetimes for the

21 equipment under consideration as well as data

22 regarding the correlation between compressor hours

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1 of use and air compressor lifetime. Item 8.4, DOE

2 seeks input on the proposed approach for

3 estimating discount rates for air compressors.

4 MR. BROOKMAN: Yes, Rick?

5 MR. STASYSHAN: Okay. Rick Stasyshan,

6 Compressed Air and Gas. Let me start with the

7 installation cost. You know, first a general

8 comment on installation cost. Compressed Air and

9 Gas Institute and its members can assist the DOE

10 in this area, but installation can be charged as a

11 flat sum or charged on an hourly basis, based on

12 the type of compressor, size of the installation,

13 et cetera. Sometimes it's included in the overall

14 price, and sometimes it's a separate line item.

15 Sometimes the end customer installs the compressor

16 unit themselves. Sometimes a mechanical, erection,

17 general, or electrical contractor is employed as a

18 primary or subcontractor.

19 The costs can vary also based on new

20 installation in addition to an existing

21 installation or the replacement of existing

22 equipment. The location, the requirement of

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1 special material handling equipment, modifications

2 to the building, and other matters all play a key

3 part. Every job is unique and different.

4 Concerning whether energy-efficient

5 equipment would be more expensive or not, should

6 be noted that the installation of some energy7 efficient equipment could sometimes be higher than

8 -- like with VSD, higher than a fixed machine if

9 there are issues concerning the electrical supply

10 and possible isolation or filtering of input power

11 issues. So

12 MR. BOLDUC: Right. So the --

13 notwithstanding -- okay. Thank you very much.

14 MR. STASYSHAN: You know, I think,

15 basically --

16 MR. BOLDUC: Yeah, yeah. Yeah.

17 MR. STASYSHAN: -- the same issues would

18 exist for energy-efficient equipment --

19 MR. BOLDUC: Or non --

20 MR. STASYSHAN: -- versus standard

21 equipment.

22 MR. BOLDUC: Right.

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1 MR. STASYSHAN: So you'd be looking at

2 the delta, and then it would be whether it's

3 filtering or modifying electrical input to make

4 sure that the product would perform functional --

5 MR. BOLDUC: Right, so what we're

6 looking for here is specific reasons why your

7 installation costs would be more expensive if you

8 were, say, on a new installation, buying a

9 baseline piece of equipment or a higher-efficiency

10 piece of equipment. And it -- I don't get the

11 impression from your response that, really, there

12 would be.

13 MR. STASYSHAN: Yeah, unless it's

14 electrical filtering of noise or whatever, due to

15 control issues or whatever. I'm not sure what the

16 efficiency -- how we'll get the efficiency.

17 MR. BOLDUC: Right.

18 MR. STASYSHAN: So there could be

19 issues.

20 MR. BOLDUC: Okay.

21 MR. BROOKMAN: Wayne, you want to add on

22 --

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1 MR. BOLDUC: Thanks, Rick.

2 MR. BROOKMAN: -- here, or Werner?

3 Either one.

4 MR. RAUER: Just --

5 MR. BROOKMAN: Werner?

6 MR. RAUER: Yeah. Just to clarify this

7 about the variable-frequency drive, are you

8 talking about the box again in terms of

9 efficiency, or then again the application because

10 it is a variable-speed drive? Suddenly (ph) if

11 you choose a variable-speed drive compressor that

12 is more efficient in terms of part load, you will

13 have to pay more for the equipment itself.

14 MR. BOLDUC: Uh-huh.

15 MR. RAUER: But I'm not so sure whether

16 you're just focusing on the extra cost --

17 MR. BOLDUC: Installation cost

18 only.

19 MR. RAUER: Certainly, a variable-speed

20 drive could have a major impact on the customer's

21 electrical system, and that may require either

22 extra filtering, isolation transformer, but that

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1 is entirely on how poor or how good the customer's

2 overall electrical design is, and it also requires

3 you cannot just put a variable-speed drive for the

4 outside. That would cost extra money. It's

5 usually recommended, like your computer, you put

6 it indoors (inaudible). So, yes, there certainly

7 are some extra questions that should be

8 considered.

9 MR. BOLDUC: Okay. Thank you.

10 MR. BROOKMAN: I have a comment from

11 Bruce McFee, who's online. "Product lifetime,

12 many organizations shut down or change

13 ownership/application change before the air

14 compressor wears out." Okay. Thanks, Bruce.

15 What about repair costs for more

16 efficient air compressors?

17 MR. LUNG: Can I --

18 MR. BROOKMAN: Bruce?

19 MR. LUNG: I'm sorry. Bruce Lung.

20 MR. BROOKMAN: Yeah?

21 MR. LUNG: Can I ask one quick question?

22 This may be obvious, but I want to just make sure.

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1 The installation costs, would those also include

2 commissioning activities?

3 MALE SPEAKER: Should.

4 MALE SPEAKER: Yes.

5 MR. LUNG: Yes? Okay.

6 MALE SPEAKER: Yes.

7 MR. PERRY: Could I make a comment on

8 8.1 as well, please?

9 MR. BROOKMAN: Yes, please do, Wayne.

10 MR. PERRY: We've installed -- I looked

11 back just to gather some data on hundreds of

12 installations where we did the installation, where

13 we sold the equipment, and we did the

14 installation, and just to get a ballpark, I looked

15 at what the percentage of the installation cost

16 was compared to the cost of the equipment.

17 MR. BOLDUC: Uh-huh.

18 MR. PERRY: And on average, it was about

19 42 percent of the cost of the equipment. So

20 that's normally -- it can vary all over the board,

21 but as an average, that's what it turned out to be

22 over about 200 installation jobs that I looked at.

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1 MR. BROOKMAN: Wow. That's helpful.

2 Thank you.

3 MR. BOLDUC: That's great. Thank you.

4 MR. RAUER: New installation.

5 MR. PERRY: Yeah. New installation.

6 Well, some of them were removing old equipment, so

7 -- and I will tell you some of the installation

8 jobs came to two or three times the cost of the

9 equipment. It just depends on the installation.

10 Cost of repair for more efficient

11 compressors, again, it depends on whether you're

12 looking at fixed speed or variable speed or

13 whether you're replacing a fixed speed with a

14 variable speed, because if you are, then, yes, you

15 have higher repair costs on variable-speed

16 machines than you do fixed- speed machines, simply

17 because the variable-speed drive is another

18 component that requires maintenance and requires

19 motherboards and capacitors and things like that

20 that wear out.

21 So, yes, if you're comparing more

22 efficient fixed speed to less efficient fixed

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1 speed, no, there's no variation, but if you

2 compare installing variable speed instead of a

3 fixed speed, then, yes, you do have higher

4 maintenance and repair costs.

5 MR. BOLDUC: Thank you.

6 MR. STASYSHAN: Okay. 8.3 next?

7 MR. BROOKMAN: Yeah.

8 MR. STASYSHAN: Okay. Rick Stasyshan,

9 Compressed Air and Gas. You know, again, from our

10 manufacturers, you know, we build robust and

11 durable compressors that are built to stand up to

12 the harshest of operating environments.

13 For users who regularly follow the

14 manufacturer operating and maintenance procedures,

15 use high-quality manufacturer OEM parts, use the

16 highest- quality air inlet oil filters as well as

17 factory- recommended compressor lubricants and

18 coolers, perhaps contract a factory-trained

19 maintenance technician to do this work or use a

20 factory-authorized service organization or the

21 service maintenance contract, then lifetimes that

22 have spanned decades have been realized.

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1 Items that could affect life would

2 include temperatures, both highs and lows, of

3 where the compressors are installed, installation

4 in a temperature-controlled environment or

5 being outside; air inlet quality, the air quality

6 coming in and the point of compression; the

7 atmosphere where the installation's taking place;

8 operating hours per period, 24/7/365; use of

9 genuine parts versus well-fit parts; qualification

10 of the person performing the maintenance and

11 repair; was the unit new or used at the time of

12 the install all could impact compressor life,

13 although we believe we can provide insight to the

14 DOE on this matter, but there are a lot of

15 variables to be considered.

16 MR. BOLDUC: Yeah. That's great.

17 Thanks, Rick. Ideally, what I'd like to be able

18 to do is, on an hourly basis, be able to correlate

19 the maintenance schedule from the Compressed Air

20 Challenge to a hypothetical lifetime in hours for

21 a compressor.

22 MR. STASYSHAN: And we worked with the

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1 Compressed Air Challenge on coming up with those

2 numbers. I mean, they didn't just pull those

3 numbers out of a hat, so we're intimately involved

4 in that.

5 MR. BOLDUC: Great. Thank you.

6 MR. STASYSHAN: The last comment on

7 discounts, if I could continue -- again, Rick

8 Stasyshan, Compressed Air and Gas. You know, the

9 purchase price and discounts are impacted by many

10 factors. As a manufacturer organization, we would

11 not be able to comment on that. You'd have to

12 rely on our individual members to provide that

13 input to you.

14 MR. BOLDUC: Thank you.

15 MR. BROOKMAN: Okay. Thank you.

16 Comments on discount rates, since we're on it? No

17 additional comments.

18 MR. BOLDUC: Thank you. At this point,

19 we've just finished the life-cycle cost analysis

20 that -- for the consumer, costs and benefits.

21 We're going to move on now to look at some of the

22 national-level analyses, and the first one is the

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1 shipments analyses. It's to estimate compressor

2 shipments in the base case and standards case.

3 DOE plans to use an economic model to

4 project shipments in the standards case as

5 compared to the base case, and DOE typically does

6 this over a 30- year period, beginning on the

7 expected compliance date of the standard. As

8 inputs, DOE uses historical shipments data and

9 trends from the Census Bureau and published

10 literature and stakeholder input. And we also

11 take the equipment lifetimes from the LCC.

12 So Item 9.1, DOE seeks comments on the

13 shipments forecast methodology. DOE invites

14 comments regarding the selection of an appropriate

15 economic drivers for compressor shipments. DOE

16 requests historical shipments data for the

17 equipment proposed in this framework, with further

18 breakdowns where available, including, but not

19 limited to, delivered air volume, air pressure,

20 motor horsepower, and/or efficiency.

21 And Item 9.3, DOE seeks comment on how

22 an efficiency conservation standard for air

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1 compressors might impact future compressor

2 shipments.

3 MR. BROOKMAN: Rick?

4 MR. STASYSHAN: Okay. Again, Rick

5 Stasyshan, Compressed Air and Gas Institute.

6 Let's start with 9.1, the shipping forecast.

7 MR. BOLDUC: Sure.

8 MR. STASYSHAN: You know, every

9 manufacturer has their own proprietary and

10 confidential forecasting model.

11 MR. BOLDUC: Uh-huh.

12 MR. STASYSHAN: Some manufacturers

13 employ economists to assist them in forecasting

14 and business planning. Complicated regression

15 analysis, combined with economic indicators with

16 historic data and the overall state of the economy

17 and perhaps data on individual segments can play a

18 role.

19 Some of the forecasting models used

20 include government-provided leading indicators.

21 There are a number of economic indicators and

22 drivers that could impact end demand. Just a few:

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1 overall state of the economy, incentives from the

2 utilities and others to upgrade and improve

3 manufacturing investment and capital expenditures,

4 the health and growth of a particular segment of

5 the market. An example, good used car sales and

6 truck sales might trigger capital expenditures in

7 upgrades at auto manufacturers.

8 The value of the U.S. dollar can help or

9 hurt exports based on the current trend. In

10 mining, the commodity prices can stimulate

11 activity. End user demand levels by segment, such

12 as high fuel usage, might trigger equipment

13 upgrades at a refinery. Interest rates can have an

14 impact on some of the users' financing on an

15 upgrade or potential expansion. Stimulus from

16 local government markets and development boards

17 can impact local investment in levels of

18 government contracts; i.e. large defense contracts

19 could stimulate defense contractor investment.

20 CAGI and its members are prepared to

21 assist the DOE in this matter to better understand

22 it, but it's, in many cases, a complicated

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1 forecasting model.

2 MR. BOLDUC: Thank you.

3 MR. BROOKMAN: Yes, Jordan?

4 MR. DORIA: Just -- Jordan Doria with

5 Ingersoll-Rand. One recommendation on 9.2 would

6 be to add oil-flooded versus oil-free products to

7 the breakdown. You know, we tend to think that --

8 you know, and certainly evidence shows that there

9 is some shift in the market in that regard, and,

10 you know, considering broader industrial trends

11 about what industries are going to grow and what

12 their needs are around clean air could sort of

13 further inform this, and we'd just recommend

14 adding that in.

15 MR. BOLDUC: Thank you. And one of the

16 things that came up earlier that I wanted to ask

17 about is what about water- versus air-cooled?

18 MR. STASYSHAN: You know, okay, and I'll

19 continue on 9.2 and 9.3, but you're right. I

20 think, first of all, the comment on oil-free and

21 oil-flooded would be one to add to 9.2. You know,

22 air-cooled, water-cooled, you know, based on

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1 horsepower ranges -- and, again, we're prepared to

2 work with you on that -- the majority of the

3 compressors under, say, 100 horsepower, which, you

4 know, some of the data's going to show that they

5 represent a fair portion of the volume sales --

6 are more air-cooled; very small percentage, water7 cooled.

8 So you get into the big compressor sizes

9 that are built to customer specification, the

10 percentages increase a little, but we're prepared

11 to assist you on the air-cooled and water-cooled

12 question.

13 MR. BOLDUC: Thanks.

14 MR. STASYSHAN: And last point on 9.3,

15 that's a difficult one for the Compressed Air and

16 Gas Institute to answer at this time without

17 knowing what the potential standards might be.

18 You know, again, compressed air's often viewed as

19 industry's fourth utility, which I already

20 mentioned. Regardless of the regulations,

21 compressed air will be required.

22 Some users may elect to repair, rather

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1 than replace, based on the potential cost impact

2 of proposed regulations. We're prepared to work

3 and assist you based on when that comes down and

4 what the potential impact might be.

5 MR. BOLDUC: Sure. To your knowledge,

6 do you guys see -- or have you seen a displacement

7 of new compressor purchases to refurbished units,

8 ever?

9 MR. BROOKMAN: Wayne?

10 MR. PERRY: Yes. When the economy goes

11 down, they repair; when it's good, they replace.

12 MR. BOLDUC: So they extend the life of

13 existing equipment?

14 MR. PERRY: Yeah.

15 MR. BOLDUC: Okay. Thank you.

16 MR. BROOKMAN: Thank you. Yes, Werner?

17 MR. RAUER: I just want to add something

18 about his comment about the water, whatever.

19 MR. STASYSHAN: Yeah.

20 MR. RAUER: There's also -- on the oil21 free side, there's also a water-injected oil-free

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1 cooled of the package, but the actual compression,

2 just to clarify that there's also water-injected

3 oil-free compressors.

4 MR. BOLDUC: So the national shipments

5 and national impacts analysis -- excuse me -- the

6 purpose is to determine the projected national

7 energy savings, or NES, and consumer net present

8 value, NPV, associated with air compressor

9 efficiency standards.

10 Now, (inaudible). DOE plans to use the

11 shipments analysis and the LCC to calculate total

12 installed cost and energy use per unit in any

13 year. The aggregate -- aggregate the costs and

14 energy use for all years in the analysis period.

15 DOE will develop an annual series of national

16 energy and economic impacts, and it will report

17 the cumulative national energy savings in terms of

18 site, primary, and full-fuel-cycle savings. And

19 DOE will further report the cumulative change in

20 national consumer NPV in constant-year dollars.

21 So we have a couple comments here. Item

22 10.1, DOE seeks comments on how efficiency of air

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1 compressors is likely to change over the long run

2 in the absence of standards. And Item 10.2, DOE

3 seeks comment on the likelihood of increased air

4 compressor usage as a direct result of improved

5 air compressor efficiency.

6 MR. BROOKMAN: Yes, Rick?

7 MR. STASYSHAN: Okay. Again, Rick

8 Stasyshan, Compressed Air and Gas Institute. Let

9 me start with 10.1.

10 MR. BOLDUC: Sure.

11 MR. STASYSHAN: CAGI and its members

12 have been proactive in the past. We believe

13 strongly that our existing programs have benefited

14 end users and have improved efficiency. Without

15 regulation, we can expect these trends to continue

16 as we expand our programs to cover additional

17 types of equipment.

18 There are some examples that I'd like to

19 cite that support this fact. CAGI manufacturers

20 have incorporated premium efficient NEMA class

21 motors as both the primary motor and fan motor as

22 standard in their product offerings. Second, CAGI

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1 offers variable-speed drives as an option, again,

2 as a primary and on the fan motor. This took some

3 level of engineering, expense, and R&D to

4 accomplish.

5 Our members haven't stopped there.

6 Others have also developed products achieving

7 variable output with options to assist customers

8 to match compressor output with end user demands.

9 CAGI and its members are very active with both

10 financial and human resource commitment to the

11 Compressed Air Challenge, the CAC, and our efforts

12 to educate end users on the most efficient and

13 energy use of the compressed air products.

14 CAGI and its members have provided

15 numerous collateral education materials to the

16 CAC, and a number of the members employ qualified

17 and certified trainers to support the CAC's

18 training activities.

19 CAGI is active in initiatives with the

20 ACEEE and the CEE in working with the utility

21 members to have the most energy-efficient

22 incentive programs concerning compressors

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1 available, and this will assure that energy

2 efficiency is maintained over time. Our members,

3 at a considerable engineering and R&D expense,

4 have developed state-of-the-art microprocessor

5 control panels and master compressor controls to

6 assure optimum performance of newly installed

7 compressor installations.

8 CAGI and its members have made the

9 Compressed Air and Gas Handbook available as a

10 free download to compressor users via our website.

11 CAGI, both its members and staff, support the

12 Compressed Air Best Practices magazine with

13 articles and article inputs educating end users on

14 the energy-efficient and safe use of compressed

15 air.

16 CAGI members have invested in developing

17 compressor system audit tools, data-logging

18 equipment, compressed air energy audit system

19 reviews, and training for their distribution

20 staff. Many of CAGI members' employees and their

21 authorized distributors have attended the CAC

22 Level 1 and 2 training, and many of them are now

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1 AIRMaster certified.

2 CAGI members have invested in state-of3 the- art machining tools, a grinding method which

4 ensures cutting the asymmetrical male and female

5 rotors, which allow the metal cutting of the

6 complicated rotary screw profiles to the tightest

7 of tolerances with repeatable performance. This

8 technology cost the manufacturers millions of

9 dollars, but gives the end customers optimum

10 specific power package performance.

11 CAGI members have worked with lubricant

12 suppliers, filter suppliers to couple the OEM

13 components which contribute to the lubrication

14 management, assisted in providing clean compressed

15 air to end users with optimum specific power

16 package preference. CAGI members have also

17 incorporated zero- loss condensate drains, again,

18 improving the overall specific power package

19 performance.

20 Several sections of CAGI are now

21 publishing specific power package performance of

22 their products, giving end users a kilowatt per

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1 hundred CFM generated comparison. This data is

2 available both on the CAGI and member websites.

3 CAGI's not limited to inclusion of this product --

4 program to its members, but opens the program so

5 all manufacturers are prepared to meet all the

6 quails of the program. CAGI also has third- party

7 verification for the rotary positive products.

8 All of the above were done in the spirit

9 of assisting customers in achieving optimum

10 performance from their compressed air system,

11 lowering the life- cycle cost, and reducing the

12 energy cost of their compressor equipment.

13 CAGI and its members are committed to

14 improving the efficiency of compressors and the

15 method in which these products are utilized, with

16 or without regulations. This supports the view

17 that regulations may not be necessary; however, as

18 we've previously noted, we are willing to

19 collaborate to improve or modify programs to meet

20 the needs that we have not addressed, or they may

21 not be addressed by -- sufficiently in the minds

22 of the interested other stakeholders. We also

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1 stand ready to work with the Department of Energy

2 on this initiative.

3 MR. BROOKMAN: Okay. Thank you. Bruce

4 McFee has a comment. He'd like to join us in the

5 room. So, Bruce, unmute your phone, and speak

6 clearly. We'll see if we can hear you. We can't

7 hear you yet.

8 FEMALE SPEAKER: I don't know where he

9 went.

10 MR. BROOKMAN: Okay. Well, it didn't

11 work, Bruce. If you can hear us, try back in a

12 little bit; see if we can get you in the room

13 here.

14 So thank you, Rick.

15 MR. STASYSHAN: And can I further

16 comment on

17 10.2?

18 MR. BROOKMAN: Unless Wayne wants to

19 comment on 10.1.

20 MR. PERRY: Just a quick comment on

21 10.1. In the absence of standards, compressor

22 manufacturers are going to continue to improve the

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1 efficiency of air equipment, for a good reason.

2 Several years ago, General Motors did an

3 engineering exercise to design an assembly plant

4 that did not use compressed air, because

5 compressed air is expensive. Running compressors

6 are expensive. If you can do it direct electric,

7 it's a lot more efficient.

8 We're well aware of how inefficient

9 compressed air is as an energy course. We're well

10 aware of how much energy in the U.S. goes to just

11 compressed air. We're well aware of how much of

12 that is wasted. And all of the manufacturers

13 really are looking at ways to improve energy

14 efficiency, as much to maintain a market for us to

15 sell product in as anything else. So even in the

16 absence of standards, you're going to see some

17 improvement in compressor efficiency, simply

18 because we want to keep business going.

19 MR. BROOKMAN: Jordan?

20 MR. DORIA: Yeah, I would sort of build

21 on that a little and say that, yes, I mean, but

22 maybe to clarify, I would say air compressors, I

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1 think we're talking here specifically about sort

2 of the package or extended product definition.

3 And it is true that Ingersoll-Rand and others are

4 going to continue to make improvements there in

5 the absence of standards; however, I think, across

6 the industry, there's an increasing awareness that

7 the real opportunity doesn't lie in that package.

8 It lies in, you know, the demand side, and which

9 ultimately gets something beyond what the

10 Department can readily regulate, at least through

11 appliance standards. That's where a lot of the

12 opportunity is, and that's really where a lot of

13 the value for customers in energy savings is.

14 The fact is, you know, not considered

15 oftentimes in these impact analyses is sort of the

16 opportunity cost to manufacturers. Resources we

17 need to dedicate to improving package efficiency

18 to meet efficiency standards for the products are

19 dollars that we cannot spend on the services side,

20 on the aftermarket side. So there's an

21 opportunity cost that prevents us, maybe, from

22 getting at some of the deeper savings that could

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1 be had outside of what's going to be regulated

2 here.

3 So, you know, I understand that's

4 something that's a little outside the scope, but

5 that is a real cost that we all sort of face, by

6 focusing so much on the pure sort of package side

7 of this.

8 MR. BROOKMAN: Okay. Louis?

9 MR. STARR: So this is Louis Starr with

10 NEEA. One thing to think about is certainly in

11 the recip market, 10 to 100 horsepower, which

12 doesn't seem like there's a lot of participation

13 in the CAGI certification program kind of

14 identifying efficiency, so that market is, as they

15 described, the wild, wild West. So it sounds like

16 standards definitely could help in that market.

17 The other aspect to it too is we're

18 talking about, essentially, an extended product,

19 which probably a lot of the people in CAGI,

20 essentially their test procedure incorporates

21 that. But for the people that don't do that test

22 procedure, you're -- that's lost opportunity that

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1 could be had. So the standards, basically, would

2 make sure everybody's kind of doing those best

3 practices.

4 And then it would be -- you know,

5 outside the people that probably participate in

6 the CAGI programs, the efficiency -- the

7 opportunity may not be as great for people that

8 don't participate as opposed to the people that do

9 participate. I think there's a substantial

10 opportunity there, and I think that'll maybe be,

11 you know, once you start doing some of the market

12 analysis.

13 But I think a lot of times -- I think

14 there's a market share that is going to want to

15 create more efficient products, but I think in the

16 10 to 100 horsepower, those things could be

17 somewhat of the commodity type, and over 100,

18 they're engineered, and I think the engineered

19 product, there's probably a good drive for

20 efficiency, but in that intermediate market,

21 there's not so much so, and that's where the

22 opportunity for standards to save energy in the

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1 U.S.

2 is available, I believe.

3 MR. BROOKMAN: Okay. Thank you.

4 MR. STASYSHAN: Okay.

5 MR. BROOKMAN: Please, yes.

6 MR. STASYSHAN: 10.2 -- again, Rick

7 Stasyshan, Compressed Air and Gas Institute. The

8 comment on compressed air usage, compressed air,

9 as I stated, is often referred to as industry's

10 fourth utility. There are manufacturing, mining,

11 and industrial process application where

12 compressed air is the most viable means of

13 accomplishing this work. Demand in these

14 application will exist with or without improved

15 energy efficiency. However, many end users, as a

16 result of marketing materials and professional

17 sales presentation, have been alerted to the

18 benefits of the energy-efficient compressed air

19 systems.

20 As for the points covered in 10.1, CAGI

21 and its members have been, continue, and will in

22 the future make every effort to match compressed

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1 air equipment to the end user application with

2 optimum performance. This is not only an ethical

3 approach, but in the best interest for users to be

4 satisfied with their compressed air systems.

5 By the same token, if efficient means

6 too costly, customer may elect to repair versus

7 replace. It's clearly an economic decision. We

8 feel there is a zero likelihood of increased

9 compressed air usage as a result of demanded

10 increased efficiency.

11 CAGI and its members, through activities

12 with groups like the Compressed Air Challenge,

13 have established the goal to reduce the energy

14 consumption of compressors and to limit compressed

15 air usage to those applications that are most

16 suitable. We are educating end users to the end -

17 - on the inappropriate use of compressed air.

18 This has been the goal of our education and

19 outreach program. CAGI and its members can assist

20 the DOE as we review this particular section.

21 MR. BOLDUC: Thank you.

22 MR. BROOKMAN: Okay. Thank you. We

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1 have additional comments on either 10.1 or 10.2?

2 Louis?

3 MR. STARR: This is Louis Starr with

4 NEEA. I'll make some brief comments on 10.2 You

5 know, typically, what I think DOE's looking for

6 here is -- a good example would be if you had a

7 light bulb that went from an incandescent to a

8 CFL, it's like, "Well, now I can leave that on

9 24/7, and I don't have to worry about turning it

10 on and off, because I'm saving energy."

11 And I think in the case of air, it's

12 really -- it's decoupled from that because you

13 have a certain amount of demand that you need in

14 your factory, and some people aren't going to use

15 air more because there's -- it's cheaper or

16 something. It's something that's looked at as a

17 utility that's necessary to accomplish a job, so I

18 don't anticipate that, by improving efficiency,

19 you'll have more unintended consequences of people

20 using more with the savings that you were trying

21 to get at.

22 MR. BROOKMAN: Okay. Thank you. I

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1 think we're ready to move on.

2 MR. BOLDUC: Thanks. So this concludes

3 the analyses that we'll be performing for the

4 preliminary analysis, which is the next phase.

5 The phase thereafter is called the Notice of

6 Proposed Rulemaking, and DOE will expand the scope

7 of its analyses. The first one is going to be --

8 I'm going to turn the floor over to Kurt, who's

9 going to discuss the manufacturer impact analysis,

10 and then we'll move on to the other analyses that

11 are in the NOPR.

12 MR. KLINKE: Again -- excuse me. My

13 name's Kurt Klinke. I work with Navigant

14 Consulting. So as he said, these are going to be

15 analyses that we're describing here that will be

16 sort of two stages further from here in the NOPR.

17 We kind of have a road map here, so the next thing

18 we have coming up is the preliminary analysis,

19 then following that is the NOPR, and we would

20 actually propose a rule.

21 As part of this new proposed rule, we

22 would revise the preliminary analysis based on any

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1 comments that we received from the publication of

2 that document in, most likely, another public

3 meeting similar to this one. We would revise

4 analyses based on any further data we received or

5 just further information that you were able to

6 provide.

7 We would then go into a life-cycle cost

8 and subgroups analysis, a manufacturer impact

9 analysis, which I'll go into in a little bit,

10 utility impact analysis, employment impact

11 analysis, emissions analysis and monetization, and

12 regulatory impact analyses. So a lot of these are

13 actually more downstream compared to the ones that

14 we've just described, so that's why they happen

15 later on in the process.

16 So when it comes to the manufacturer

17 impact analysis, the purpose is to assess the

18 impact of standards on manufacturers, identify and

19 estimate impacts on manufacturer subgroups that

20 may be more severely impacted than the industry as

21 a whole, and examine the direct employment

22 impacts, manufacturing capacity, and cumulative

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1 regulatory impact on the manufacturing industry.

2 So part of the reason that we want a lot

3 of the information that we do about how increasing

4 energy efficiency affects capital costs or cost of

5 goods sold is so that we can then go downstream

6 and say, "How will a standard that we create

7 affect manufacturers on all those cases?"

8 Our proposed methodology for that is to

9 analyze industry cash flow and industry net

10 present value through the use of a Government

11 Regulatory Impact Model and to interview

12 manufacturers to refine inputs to the GRIM,

13 develop subgroup analyses, and address qualitative

14 issues.

15 Let's move along. Here's, again,

16 another roadmap as to how specifically the

17 manufacturer impact analysis occurs. So during

18 the preliminary analysis stage, we will construct

19 an industry profile to get an image of how the

20 industry looks, who are the major players,

21 distribution channels, things similar to that. We

22 will then try to conduct initial manufacturer

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1 impact analysis interviews, so we'll be contacting

2 manufacturers with questions that we hope to get

3 initial information on.

4 Then in Phase 2 and Phase 3, which will

5 be in the NOPR, we will develop a strawman GRIM,

6 which, again, is the Government Regulatory Impact

7 Model, and we'll develop a very in-depth interview

8 guide. And then in Phase 3, we will conduct more

9 in-depth and longer interviews and industry

10 subgroup analyses. And then, finally, we'll

11 assess direct employment, competition, and

12 cumulative burden.

13 So the specific stakeholder feedback

14 requests we have for the manufacturer's impact

15 analysis is DOE -- is, Item 12.1, DOE seeks

16 comment on appropriate manufacturer subgroups, if

17 any, that DOE should consider in a manufacturer

18 subgroup analysis for commercial and industrial

19 compressors.

20 Item 12.2, DOE seeks comment on small

21 businesses that could be impacted by energy

22 conservation standards for commercial and

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1 industrial air compressors and what the impacts on

2 small businesses flowing from those standards

3 might be. And Item 12.3, what other regulations

4 or pending regulations should DOE consider in its

5 examination of cumulative regulatory burden?

6 MR. BROOKMAN: Rick?

7 MR. STASYSHAN: Okay. Rick Stasyshan,

8 Compressed Air and Gas Institute. Starting with

9 12.1, CAGI represents a large array of

10 manufacturers of compressor types. This includes

11 the rotary positive and the dynamic centrifugal

12 compressors. Information on our membership is

13 available on our website. Plus, we can also

14 assist when -- in guiding you to particular people

15 and individuals, key executives, when you decide

16 to do your investigations and interviews.

17 MR. BROOKMAN: Great. Thank you.

18 MR. STASYSHAN: You want me to continue?

19 Go to 12.2, the small business potential impact,

20 many of the compressor manufacturing companies

21 employ multiple channels to market. Channel

22 partners' value proposition can include, but not

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1 be limited to, selling, renting, leasing,

2 servicing, installing, auditing, or maintaining

3 compressed air systems.

4 In many cases, they are the face of the

5 manufacturer to the customer in specifying,

6 quoting, procuring, analyzing, and installing the

7 system. They number in the thousands. There are

8 also many small businesses that are suppliers to

9 the manufacturing (ph) compressors that also could

10 be potentially impacted by regulation. CAGI and

11 its members stand ready to assist DOE in defining

12 this segment.

13 MR. BROOKMAN: Okay.

14 MR. STASYSHAN: And then the last point,

15 12.3, other regulations to consider, as I also

16 mentioned, if fossil fuel compressors were to be

17 considered as part of the potential regulations,

18 the current manufacturers are required to meet EPA

19 operating noise requirements as well as EPA

20 emissions requirements currently for all products,

21 Interim Tier 4 or Final Tier 4, which definitely

22 could impact pressure efficiency.

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1 MR. BROOKMAN: Thank you. Wayne, do you

2 want to comment here? Yeah. Okay. Additional

3 comments on 12.1, 12.2, and 12.3? No? Okay.

4 MR. KLINKE: If not, I'll hand it back

5 over to Chris.

6 MR. BOLDUC: So DOE looks at the -- they

7 perform a customer subgroup analyses. The purpose

8 is to analyze the economic impacts of energy

9 conservation standards on subgroups of compressor

10 end users who are likely to be disproportionately

11 impacted compared to the general population. To

12 do this, we use a modified LCC spreadsheet, alter

13 the input variables to better represent the

14 subgroup in question.

15 Item 11.1, DOE seeks comment on what, if

16 any, user subgroups would be appropriate in

17 considering standards for air compressors. A

18 little background information, DOE usually

19 considers small business owners for -- these are

20 for residential products or low-income for

21 residential, small business for commercial

22 products. Is there an equipment for air

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1 compressors?

2 MR. BROOKMAN: Do you have a comment on

3 that?

4 MALE SPEAKER: No.

5 MR. BOLDUC: Oh.

6 MR. BROOKMAN: Wayne?

7 MR. PERRY: Yeah. As far as subgroups

8 go, but these aren't small businesses. You might

9 consider the gas generation people. The people

10 who generate nitrogen, generate oxygen, use air

11 compressors to supply the raw material. They may

12 be, you know, Air Liquide, Praxair -- these kinds

13 of people may be impacted by this regulation

14 because they have some very specific requirements

15 for how that air gets delivered to their process.

16 For example, we in the industry all know

17 modulation control is probably the least efficient

18 control method there is, but to feed a nitrogen19 generating system that's based on a nitrogen

20 demand in the plant, that's the most common

21 control system that they use, simply because they

22 have to have a particular pressure. They can't be

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1 fluctuating. They can't shut the machine off.

2 They can't unload it. It has to be ready to go

3 anytime.

4 MR. BOLDUC: And so -- sorry to

5 interject here, but somebody use your piece of

6 equipment, like a rotary screw compressor, to

7 generate nitrogen?

8 MR. PERRY: Sure.

9 MR. BOLDUC: Same piece of equipment,

10 just different operating circumstance?

11 MR. PERRY: Right.

12 MR. BOLDUC: Okay.

13 MR. PERRY: Right. Yeah, no, they've

14 got 78 percent nitrogen in the air that we're

15 breathing, so they just strip the oxygen off and

16 provide the nitrogen, or they strip the nitrogen

17 off and provide oxygen.

18 MR. BOLDUC: Okay.

19 MR. PERRY: But that may be a subgroup -

20 - those are the types of subgroups I would see you

21 would kind of want to consider in this, because

22 they have very specific applications, and changes

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1 in compressor design may affect them more than it

2 would affect the general industrial population.

3 MR. BOLDUC: Off the top of your head,

4 could you -- what regulations or what procedures

5 would they be operating under so we can file that

6 away for future -- do you know, or am I on my own

7 here?

8 MR. PERRY: Yeah, I'll have -- I have --

9 MR. BOLDUC: Okay.

10 MR. PERRY: -- no idea.

11 MR. BOLDUC: That's fine. Thanks,

12 Wayne. Okay. Next is the utility impact analyses.

13 It's to assess the overall effects on domestic

14 energy supplies that would result from the

15 adoption of an energy conservation standard. DOE

16 proposes the use of the EIA's National Energy

17 Modeling System -- we call it NEMS-BT -- as the

18 basis for the utility impact analysis. The output

19 to the utility impact analysis include projections

20 of electricity generation and avoided capacity

21 resulting from a comparison of the base case and

22 standards cases.

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1 Item 13.1, DOE seeks comments from

2 interested parties about its planned use of NEMS

3 and NEMS-BT to conduct utility impact analyses.

4 Okay. Employment impacts analysis, to

5 assess the overall indirect employment impacts and

6 effects on national employment from the adopted

7 energy conservation standard at various levels.

8 DOE intends to use the Impact of Sector Energy

9 Technologies, or ImSET model for the evaluation of

10 these indirect employment impacts.

11 So when we say indirect employment

12 impacts, we are referring to employment impacts

13 that are not directly related to compressor

14 manufacturers. That's -- those compressor

15 manufacturer employment impacts will be handled in

16 the MIA. So

17 MR. BROOKMAN: Rick?

18 MR. STASYSHAN: Yeah, in these sections

19 -- Rick Stasyshan, Compressed Air and Gas -- you

20 know, we didn't have any guidance or input on

21 that, so we did not comment.

22 MR. BOLDUC: Thank you, Rick.

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1 MR. BROOKMAN: Additional comments on

2 employment impact analysis, if any? No? Okay.

3 MR. BOLDUC: Emissions analysis, to

4 report environmental impacts of amended energy

5 conservation standard. The method, in estimating

6 physical reductions of emissions, DOE intends to

7 use the emissions effects projected, again, using

8 the National Energy Modeling Systems to conduct

9 this analysis.

10 DOE plans to consider, to the extent

11 feasible, reductions in power sector emissions of

12 carbon dioxide, nitrogen oxides, sulfur dioxides,

13 mercury, methane, nitrous oxide, and particulate

14 matter.

15 DOE seeks input about its emissions

16 analysis approach for the equipment that DOE is

17 considering for their regulatory coverage.

18 MR. BROOKMAN: No comments here? Okay.

19 MR. BOLDUC: Next, these emissions

20 estimates are then monetized in the monetization

21 of CO2 and other emissions reductions. The

22 purpose is to report monetary benefits from the

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1 reductions of emissions of CO2 and NOX from

2 amended energy conservation standards. In

3 estimating the monetary value of reduced emission,

4 DOE intends to use the most current social cost of

5 carbon values developed by the government's

6 interagency reviews.

7 DOE multiplies the CO2 emissions

8 reductions by the social cost of carbon values and

9 then discounts the values to calculate its present

10 value.

11 DOE estimates the potential monetary

12 benefit from the reduction of NOX emissions based

13 on the environmental impact estimates found in the

14 relevant scientific literature. These values are

15 then discounted to obtain present values at 3 and

16 7 percent. And this is in accordance with OMB

17 guidance.

18 DOE requests comments about the approach

19 it plans to use for estimating monetary benefits

20 associated with emissions reductions.

21 MR. BROOKMAN: Louis?

22 MR. STARR: So this is Louis Starr with

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1 NEEA. I think an important thing the

2 manufacturers realize there is the cost of the

3 carbon and all that doesn't actually figure into

4 your life-cycle cost analysis under standard

5 levels or anything else, so it's essentially a

6 number that's just reported for other purposes.

7 MR. BOLDUC: Thanks, Louis.

8 MR. BROOKMAN: Okay. Thank you. No

9 comments here? Okay.

10 MR. BOLDUC: The regulatory impact

11 analysis, the purpose of this analysis is to

12 investigate the national effects of non-regulatory

13 alternatives compared with the mandatory energy

14 conservation standards.

15 We modify an NES spreadsheet model to

16 consider non-regulatory scenarios. We estimate

17 the effects of non-regulatory scenarios based on

18 experience with considered policies. The output

19 will include national energy savings and national

20 present value for these non-regulatory

21 alternatives.

22 Now, this is the analysis where we'll

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1 take a look at the Compressed Air Challenge to see

2 how it stacks up against other -- see if it stacks

3 up against the rule itself. It will be difficult

4 because the piece that we'll be comparing is --

5 trying to look at just the increment and

6 efficiency improvement for the compressors.

7 But, again, if there are other programs

8 that the members here are aware of, we'd like to

9 know about it.

10 MR. BROOKMAN: Okay. Okay, then. As we

11 promised this morning, now there's an opportunity

12 for anybody that wishes to to make closing remarks

13 to cover any material that you don't feel that

14 you've had the chance to cover sufficiently during

15 the course of this meeting.

16 Oh, we do have someone -- David Proctor

17 (sic) has a comment. Yes. "Regarding 10.1, Atlas

18 Copco, our company, as many CAGI companies, has a

19 strategic vision to improve the efficiency of air

20 compressors, and this has in the past and

21 continues to be a leading driver in the

22 development of our products. This important" --

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1 FEMALE SPEAKER: KPI.

2 MR. BROOKMAN: -- "KPI is reported to

3 our board on a regular basis. We are anxious to

4 participate." So thank you, David.

5 MALE SPEAKER: Other closing remarks?

6 MR. BROOKMAN: Yeah, yeah. Concluding

7 remarks? Any things anybody wishes to add here as

8 we move towards closure? Go ahead, Chris. Rick?

9 Rick.

10 MR. STASYSHAN: Again, Rick Stasyshan

11 from the Compressed Air and Gas Institute. I'd

12 like to make a closing remark.

13 First of all, we appreciate the

14 opportunity to be here today and give our input.

15 We appreciate the Department of Energy's interest

16 in compressors and compressed air systems and look

17 forward to working with the Department to improve

18 the efficiency and effectiveness of our industry's

19 products in harmony with the objections of our

20 mission, which we outlined in our letter of the

21 24th.

22 In fact, CAGI has been working to

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1 achieve the same goals for decades, working with

2 the development of standards that provide true

3 packaged extended product performance. We have

4 developed and devoted significant resources, not

5 only to the development of standards, but also to

6 the development of training and education

7 materials designed to educate purchasers and end

8 users regarding the proper selection and operation

9 of compressed air systems, compressors, and other

10 compressed air equipment.

11 We continue to believe that the best

12 improvements in efficiency relative compressed air

13 system lie outside the actual equipment; that is,

14 the way in which the equipment is used. The

15 industry has been striving to increase the

16 efficiency of its products for many years.

17 This effort to improve efficient (sic)

18 was accelerated as CAGI and its members have

19 performed product performance information on

20 standard formats. In addition, the existence of

21 the Performance Verification Program provided

22 confidence in that data that is published by the

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1 manufacturers. These programs have increased

2 competition within the industry, to the benefits

3 of all parties.

4 We urge the Department take all these

5 existing projects into account as it deliberates.

6 We further urge that the Department use existing

7 and well-accepted standards, means of reporting

8 performance, and programs for verifying

9 performance, since these existing programs and

10 materials already meet the goals of the

11 Department.

12 CAGI and its members have demonstrated a

13 willingness and ability to work with all the

14 affected stakeholders. We are willing, again, to

15 collaborate, to improve and modify programs to

16 meet the needs we have not addressed or may not

17 have been addressed sufficiently in the minds of

18 the other interested stakeholders.

19 The information we have provided prior

20 to and during this hearing, we feel provides the

21 details on all the pertinent topics. In addition,

22 we've attempted to provide some guidance from our

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1 perspective on the various issues raised by the

2 Department.

3 Compressor performance and the nature of

4 its subjects being addressed by the Department are

5 extremely complex, and, therefore, we believe that

6 it is likely a negotiated rulesmaking (sic) may

7 provide the best avenue for achieving additional

8 improvements in the efficiency in a timely and

9 effective manner. We request that DOE permit

10 interested stakeholders to undertake a negotiated

11 rulesmaking, perhaps, and that CAGI and its

12 members would like to participated in a negotiated

13 rulesmaking, if so permitted by the Department.

14 CAGI and its members will continue to

15 work on the work that we've been pursuing since

16 our organization's founding. We stand ready to

17 enhance the efficiency and effectiveness of

18 compressed air products, compressed air systems,

19 and hopefully by building a foundation on one

20 that'll -- a stronger building on a strong

21 foundation that already exists.

22 CAGI is prepared to undertake the

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1 efforts, gather and provide the information in

2 response to questions asked by the DOE in its

3 framework document, and will act promptly as

4 feasible to do so. The Institute welcomes any

5 assistance the Department and other stakeholders

6 can provide in helping us to reach these mutual

7 goals.

8 MR. BROOKMAN: Thank you very much.

9 Wayne, did you wish to comment here?

10 MR. PERRY: Just to say that CAGI has

11 held a number of conference calls and meetings on

12 this particular subject, in which negotiated

13 rulemaking was discussed at length, as was, thanks

14 to a presentation by Ingersoll-Rand, how involved

15 that would be timewise from CAGI members, and the

16 members committed that if that's the way DOE would

17 like to go, that we, as manufacturers, would also

18 make the commitment of time and effort to be

19 involved with that.

20 MR. BROOKMAN: Thank you. Yes?

21 MR. DORIA: Yeah, this is Jordan Doria

22 with Ingersoll-Rand. (Inaudible) just to

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1 reiterate that, that we do believe, fundamentally,

2 in negotiated approach to addressing some of the

3 fundamental issues within this rulemaking is

4 really best, yeah, as a general point, and then

5 general point that we believe holds here, we think

6 the sheer volume of issues and the complexity, as

7 well as the interdependencies, don't really lend

8 themselves to a notice and comment rulemaking.

9 MR. BROOKMAN: Uh-huh.

10 MR. DORIA: So with that in mind, we

11 believe a somewhat negotiated approach is best. A

12 negotiated rulemaking definitely is, you know, at

13 or near the top of the list of possible

14 approaches. So the question, then, is what is the

15 process by which the Department would ultimately

16 decide on whether or not to engage in a negotiated

17 rulemaking for this particular rule?

18 MR. BROOKMAN: Michael Kido?

19 MR. KIDO: I know that there are going

20 to be a number of decisions that have to be made

21 regarding whether a negotiated rulemaking would be

22 appropriate. I don't know the exact steps that we

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1 would have to consider, other than I believe that

2 we already have the structure set up to allow for

3 a negotiated rulemaking, but I'll have to get back

4 to you on the specific steps.

5 MR. BROOKMAN: Okay.

6 MR. DORIA: Yeah, thank you. I mean, I

7 think, as a general point, we've seen the

8 Department recently use the Appliance Standard

9 Regulatory Advisory Committee, so if there could

10 be some, you know, mechanism of following up

11 there, but in terms of what the process will look

12 like as well as the timing and how it intersects

13 with the timing that's been outlined for the test

14 procedure as well as the efficiency NOPR (ph),

15 that would be, I think, useful for industry and

16 other parties that I think have expressed a

17 general interest to try to, you know, achieve some

18 sort of negotiated approach through some process.

19 MR. BROOKMAN: Yes. Thank you. Louis

20 Starr?

21 MR. STARR: So this is Louis Starr with

22 NEEA. You know, a thought is, is that, you know,

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1 in this case, it seems like CAGI and the

2 manufacturers in general seem to be on board. You

3 know, the standard rule process might work very

4 well (inaudible) Navigant and LBNL. The

5 consultants seem pretty primed in terms of it.

6 One of the things I actually talked with

7 Andrew a little bit about this before he left, and

8 it's really whether, you know, in this case, the

9 advocates (ph) would add value to that process or

10 not. So one thing is I'm thinking the normal

11 rulemaking process in this case may be adequate

12 because there doesn't seem to be much contention

13 there about it. So it would probably be something

14 we need to think about, but it sounds like

15 everybody's sort of on board. It sounds like the

16 consultants are pretty primed for the information,

17 and a lot of that ends up being them talking with

18 the manufacturers on a lot of the process.

19 So there might be -- I'm not sure that,

20 necessarily in this case, a negotiated rulemaking

21 will add value, but if there's value to be added,

22 then we'd certainly consider it. That's something

282

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1 we'll have to think about.

2 MR. BROOKMAN: Okay. And Bruce McFee

3 writes to us, "I believe this meeting shows there

4 is a group of people willing to cooperate with the

5 DOE in a positive way. This is a highly complex

6 subject and which requires more dialogue to write

7 effective rules." Okay. So thank you, Bruce.

8 And thanks all of you that have joined us via the

9 Web. And I'll turn it back to Jim Raba.

10 MR. RABA: Jim Raba, Department of

11 Energy. We conclude today's public meeting with

12 great appreciation from the Department of Energy

13 for your participation. Thank you for a very

14 productive meeting. We also thank our presenters,

15 Kurt Klinke, Chris Bolduc, and our facilitator,

16 Doug Brookman, and our technical crew backstage,

17 Emily Marchetti, who made this possible. We look

18 forward to receiving your written comments. Safe

19 travels.

20 (Whereupon, at 3:15 p.m., the

21 meeting was concluded.)

22

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1 CERTIFICATE OF NOTARY PUBLIC 

2 I, Janel B. Folsom, the officer before whom the 

3 foregoing deposition was taken, do hereby certify that 

4 the witness whose testimony appears in the foregoing 

5 deposition was duly sworn by me; that the testimony of 

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7 to typewriting under my direction; that said deposition 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

is a true record of the testimony given by said 

witness; that I am neither counsel for, related to, nor 

employed by any of the parties to the action in which 

this deposition was taken; and, further, that I am not 

a relative or employee of any counsel or attorney 

employed by the parties hereto, nor financially or 

otherwise interested in the outcome of this action. 

My commission expires: 

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1 CERTIFICATE OF TRANSCRIPTION 

2 I, MARY E. YOUNG, hereby certify that I am not the 

3 Court Reporter who reported the following proceeding 

4 and that I have typed the transcript of this proceeding 

5 using the Court Reporter's notes and recordings. The 

6 foregoing/attached transcript is a true, correct, and 

7 complete transcription of said proceeding. 

8 

9 

10 

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12 

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18 

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134:2,7

135:12,19,22

136:15,18

complete 8:13 compressed 2:5 276:9,10,12 137:1,14 140:16

58:11 59:15,20 6:3 278:18 142:4,16 146:11

60:1 61:7 63:12

169:2,15 181:9

199:11 285:7

completed 67:7

107:1

completely 168:14

215:22

completing

107:4,6

complex 62:3

132:1 210:5

278:5 283:5

complexity 280:6

compliance

18:3,5,6,20

19:1,7 179:2

186:7 197:10

240:7

compliant 105:9

complicated

106:16 117:7

11:12,15,18,21

12:22 13:7,22

14:1 21:15 22:14

23:3 28:3,8

33:11 34:9,15

35:1,20 40:7

44:1 51:11

52:3,19

53:1,10,18 61:3

63:13,15 64:9

79:6 92:6 96:17

99:6 110:14

113:14 114:19

124:6 129:21

130:3 132:4,20

133:20 134:20

136:12 138:7

140:1 144:10

148:22 154:2

172:9 173:6

175:7 178:21

183:9 187:1

191:21 193:19

199:8 204:8

compressible

132:3

compression 20:18

21:7 22:1,18

23:2 26:6,13

27:10,16

34:12,14,18

38:13 56:19

113:16 115:22

125:22 148:21

156:16 183:18

238:6 246:1

compressor 11:6,8

12:10,12,17 13:1

14:18 15:21 17:7

20:12 22:9 23:21

26:11,12,21,22

27:9,10 28:14,22

29:7,20 30:3

31:8 33:6,10

35:5 36:4,16,19

37:15 38:8 39:15

40:17 41:21

147:4 157:5,17

159:15 160:21

164:10 167:21

168:4,17 169:6

171:6 172:11

173:15 190:9

192:10 196:18

198:1

200:16,17,18

201:2,4,6,8,19

202:15 203:6,22

204:4,14

205:5,16 206:17

208:11,18

212:21 213:11

217:7

218:4,17,22

219:1 220:16,19

221:7

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228:2 229:20,22

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233:11 234:14

237:17

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35:1,22

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40:21

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44:19 45:7 46:19

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76:20

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92:8 98:9

99:7,10 100:9

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114:9,17 115:16

118:1 120:5,10

122:18 125:7,20

130:21 131:4,6

132:16 144:15

146:12,20

148:12,18

150:19

151:11,22

152:10,14

154:10

156:12,13,14

157:4 159:6

163:3,14 164:5

167:14

171:20,22

172:5,12 175:11

179:6 183:13

184:15,18

190:5,15

191:9,18 199:3

205:13 206:7,12

213:9,12,20,22

214:18 215:3

217:4,9,10

218:10 221:4

225:3,15,22

226:7,17,22

228:14,17

229:16,19 230:3

234:16 236:11

237:11 238:3

241:1 244:3

246:3 247:1

248:22 251:14

253:5,22 258:14

263:19 264:1,12

265:9,16 266:17

267:1,11

274:6,20 275:16

276:9

compressor's 35:3

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Compressors 1:6

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34:16 43:2 45:22

46:1 92:20 206:1

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144:1,3 165:4

181:18 234:5

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concern 33:20

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68:4

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203:20

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43:4,15 173:4

231:4,9 248:22

concerns 95:8

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conclude 283:11

concluded 283:21

concludes 260:2

Concluding 275:6

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concurrently

106:19

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137:1,8,19

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129:4 130:6

218:11 220:17

227:12

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221:16 262:22

263:8 270:3

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276:22

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193:22

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14:20

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263:22 266:9

269:15 270:7

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252:22 254:4

257:21 264:18

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274:21

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202:12

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188:3

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125:3 136:21

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226:12 258:14

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216:1,9 217:17

218:22 219:1

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226:13

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221:9 224:21

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13:8,14,15 26:16

66:1 158:4 206:3

248:20

275:17,22 276:1

workings 129:9

works 77:9 86:5

134:18

world 102:10

170:4 212:11

219:6

worry 259:9

Wow 236:1

write 283:6

writers 74:21

writes 199:2 283:3

Y

yards 188:17

year-old 228:8

yesterday 25:16

yet 42:13 48:8

67:11 68:2 102:4

156:15 252:7

yielded 11:20

yields 12:11

York 222:21

you'll 8:17 24:12

84:4 259:19

young 58:5

285:2,10

you've 54:10 56:16

74:5 85:21

120:17,19

130:19,20

131:11,14,17

132:8 164:6

274:14

Z

zero 137:21

215:10 250:17

258:8

201:1 210:17

213:8

229:9,15,18

231:4 232:2

233:15

236:11,13

280:16,21 282:8

witness 105:11

284:4,6,9

wonder 100:1

wondering 25:8

192:19 215:10

work 11:15 12:16

writing 156:17

written 9:12 10:6

11:19 25:12,13

56:18 57:14

73:20 76:16

283:18

whole 15:5 69:6

117:11 120:20

19:20 42:16

45:22 58:17 77:9

wrong 201:5 228:1

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