1

 1 BEFORE THE

 2 UNITED STATES DEPARTMENT OF ENERGY

 3

 4 PUBLIC MEETING ON THE NOTICE OF AVAILABILITY OF A

 5 FRAMEWORK DOCUMENT FOR ENERGY CONSERVATION

 6 STANDARDS FOR RESIDENTIAL FURNACE FANS

 7

 8 EDITED TRANSCRIPT OF PROCEEDINGS

 9

 10

 11

 12

 13

 14

 15

 16

 17 18 June 2010

 Washington, D.C. USA

 18 ___________________________________________________

 19 BUNN & ASSOCIATES

 Registered Professional Reporters Worldwide

 20 Post Office Box 297

 310 South Main Street

 21 Lusk, Wyoming 82225 USA

 In USA 1-800-435-2468 Worldwide 001-307-334-2423

 22 Worldwide Telefax 001-307-316-0388

 E-mail: BUNNWORLDWIDE@aol.com

 23 Copyright 2010
 2

 1 MODERATOR:

 2 DOUG BROOKMAN

 Moderator

 3 Public Solutions, Inc.

 108 Newburg Avenue

 4 Baltimore, Maryland 21228

 USA

 5 PH 410-719-0580

 FX 410-719-0581

 6 publicsolutions@earthlink.net

 7 ATTENDEES:

 8 KARIM AMRANE

 Vice President

 9 Regulatory and Research

 Air-Conditioning, Heating, and Refrigeration

 10 Institute

 2111 Wilson Boulevard

 11 Suite 500

 Arlington, Virginia 22201-3001

 12 USA

 PH 703-600-0307

 13 FX 703-562-1942

 kamrane@ahrinet.org

 14

 JAMY BACCHUS

 15 Staff Engineer, Energy Program

 Natural Resources Defense Council

 16 111 Sutter Street

 Twentieth Floor

 17 San Francisco, California 94104

 USA

 18 PH 415-875-6100

 FX 415-875-6161

 19 jbacchus@nrdc.org

 20

 21

 22

 23
 3

 1 ATTENDEES (Continued):

 2 LANE WESLEY BURT

 Manager, Building Energy Policy

 3 Natural Resources Defense Council

 1200 New York Avenue, NW

 4 Suite 400

 Washington, D.C. 20005

 5 USA

 PH 202-513-6255

 6 FX 202-289-1060

 lburt@nrdc.org

 7

 CYRIL E. FOWBLE IV

 8 NPI Program Manager

 Lennox International

 9 1600 Metrocrest Drive

 Carrollton, Texas 75006

 10 USA

 PH 972-497-7806

 11 FX 972-497-6602

 cyril.fowble@lennoxind.com

 12

 TALBOT H. GEE

 13 Vice President

 Heating, Airconditioning & Refrigeration

 14 Distributors International

 3455 Mill Run Drive

 15 Suite 820

 Columbus, Ohio 43026-7578

 16 USA

 PH 614-345-4328

 17 FX 614-345-9161

 tgee@HARDinet.org

 18

 DIANE M. JAKOBS

 19 Rheem Heating and Cooling

 5600 Old Greenwood Road

 20 Post Office Box 17010

 Fort Smith, Arkansas 72917-7010

 21 USA

 PH 479-648-4114

 22 FX 479-648-6131

 Diane.Jakobs@Rheem.com

 23
 4

 1 ATTENDEES (Continued):

 2 BRIAN JAMES

 SCE

 3 6042 North Ivandale Avenue

 Suite B

 4 Ivandale, California 91072

 USA

 5 PH 626-633-7125

 brian.james.@sce.com

 6

 SAM JASINSKI

 7 Navigant Consulting

 PH 412-454-4141

 8

 MOHAMMED KHAN

 9 Project Manager

 Energy Conservation Standards for Residential

 10 Furnace Fans Rulemaking Project

 U.S. Department of Energy

 11 1000 Independence Avenue, SW

 Washington, D.C.

 12 USA

 13 ALEX LEKOV

 Energy Analysis Department

 14 Environmental Energy Technologies Division

 Lawrence Berkeley National Laboratory

 15 One Cyclotron Road

 MS 90-4000

 16 University of California

 Berkeley, California 94720

 17 USA

 PH 510=486-6849

 18 FX 510-486-6996

 ablekov@lbl.gov

 19

 20

 21

 22

 23
 5

 1 ATTENDEES (Continued):

 2 DAVID LIS

 Appliance Standards Program Manager

 3 Northeast Energy Efficiency Partnerships

 91 Hartwell Avenue

 4 Lexington, Massachusetts 02421

 USA

 5 PH 781-860-9177 x 127

 FX 781-860-9178

 6 djlis@neep.org

 7 JOANNA MAUER

 Technical Advocacy Coordinator

 8 Appliance Standards Awareness Project

 529 Fourteenth Street, NW

 9 Suite 600

 Washington, D.C. 20045

 10 USA

 PH 202-507-4034

 11 jmauer@standardsASAP.org

 12 MOLLY TROMBLEY-McCANN

 Project Manager

 13 Energy Solutions

 1610 Harrison Street

 14 Oakland, California 94612

 USA

 15 PH 510-482-4420 x 239

 FX 510-482-4421

 16 mmccann@energy-solution.com

 17 KAREN B. MEYERS

 Director, Government Relations

 18 Rheem Manufacturing Company

 5600 Old Greenwood Road

 19 Post Office Box 17010

 Fort Smith, Arkansas 72917-7010

 20 USA

 PH 479-648-4747

 21 FX 479-648-6125

 karen.meyers@rheem.com

 22

 23
 6

 1 ATTENDEES (Continued):

 2 JIM RANFONE

 Managing Director

 3 Building Codes and Standards

 American Gas Association

 4 400 North Capitol Street, NW

 Washington, D.C. 20001

 5 USA

 PH 202-824-7310

 6 FX 202-824-9120

 jranfone@aga.org

 7

 BRYAN ROCKY

 8 Product Manager

 Heating Products

 9 North America Building Efficiency

 Johnson Controls

 10 3110 North Mead

 Post Office Box 19014

 11 Wichita, Kansas 67204-9014

 USA

 12 PH 316-832-6431

 FX 316-832-6598

 13 bryan.rocky@jci.com

 14 TERRELL J. SMALL III

 CEO and Owner

 15 Mortex Products, Inc.

 501 Terminal Road

 16 Fort Wort, Texas 76106

 USA

 17 PH 817-624-0820 x 214

 FX 817-624-3694

 18 tsmall@mortx.com

 19 CHARLIE STEPHENS

 Adjuvant Consulting

 20 PH 503-786-7316

 cstephens@spiritone.com

 21

 22

 23
 7

 1 ATTENDEES (Continued):

 2 FRANK STANONIK

 Chief Technical Advisor

 3 Air-Conditioning, Heating, and Refrigeration

 Institute

 4 2111 Wilson Boulevard

 Suite 500

 5 Arlington, Virginia 22201-3001

 USA

 6 PH 703-600-0321

 FX 703-562-1942

 7 fstanonik@ahrinet.org

 8 CHARLES STEVENS

 9

 JOHN TALBOTT

 10 Talbott Consulting

 302 Overbrook Road

 11 Baltimore, Maryland 21212

 USA

 12 PH 410-377-0637

 jmtalbott@comcast.net

 13

 LISA THOMPSON

 14 Research Associate

 Environmental Energy Technologies Division

 15 Lawrence Berkeley National Laboratory

 One Cyclotron Road

 16 MS 90-4000

 University of California

 17 Berkeley, California 94720

 USA

 18 PH 510-501-0933

 FX 510-486-6996

 19 LMThompson@lbl.gov

 20

 21

 22

 23
 8

 1 ATTENDEES (Continued):

 2 JAMES T. VerSHAW

 Chief Engineer

 3 Trane Residential Systems

 Ingersoll Rand

 4 6200 Troup Highway

 Tyler, Texas 75707-1948

 5 USA

 PH 903-581-3233

 6 FX 903-581-3280

 jim.vershaw@trane.com

 7

 GREGORY P. WAGNER

 8 Engineering Manager

 Morrison Products, Inc.

 9 16900 South Waterloo Road

 Cleveland, Ohio 44110

 10 USA

 PH 216-486-4000

 11 FX 216-486-0631

 gwagner@morrisonproducts.com

 12

 MICHAEL WOODFORD

 13 Air-Conditioning, Heating, and Refrigeration

 Institute

 14 2111 Wilson Boulevard

 Suite 500

 15 Arlington, Virginia 22201-3001

 USA

 16 PH 703-600-0328

 FX 703-562-1942

 17

 ALSO PRESENT:

 18

 Ashley Armstrong

 19 Associate Director

 Navigant Consulting

 20

 Charles Stephens

 21 Adjuvant Consulting

 PH 503-786-7316

 22 cstephens@spiritone.com

 23
 9

 1 I N D E X

 2 ATTENDEE INTRODUCTIONS AND AGENDA REVIEW 10

 By Doug Brookman

 3

 INTRODUCTION 14

 4 By Mohammed Khan

 5 OPENING REMARKS FROM INTERESTED PARTIES 15

 6 REGULATORY AUTHORITY AND RULEMAKING OVERVIEW 17

 7 SCOPE OF COVERAGE AND TEST PROCEDURES 23

 By Sam Jasinski

 8

 MARKET AND TECHNOLOGY ASSESSMENT, SCREENING

 9 ANALYSIS, AND ENGINEERING ANALYSIS

 By Sam Jasinski

 10

 MARKUPS FOR PRODUCT PRICE DETERMINATION, 174

 11 ENERGY USE ANALYSIS, LIFE-CYCLE COST AND

 PAYBACK PERIOD ANALYSIS

 12 By Alex Lekov

 13 MANUFACTURER IMPACT ANALYSIS 241

 By Rob Carmichael

 14

 UTILITY IMPACTS, EMPLOYMENT IMPACTS, 250

 15 ENVIRONMENTAL IMPACTS, AND REGULATORY IMPACTS

 ANALYSES

 16 By Alex Lekov

 17 NEXT STEPS AND CLOSING REMARKS FROM INTERESTED 259

 PARTIES

 18

 ADJOURNMENT 268

 19

 20

 21

 22

 23
 10

 1 BEFORE THE

 2 UNITED STATES DEPARTMENT OF ENERGY

 3 PUBLIC MEETING ON THE NOTICE OF AVAILABILITY OF A

 4 FRAMEWORK DOCUMENT FOR ENERGY CONSERVATION

 5 STANDARDS FOR RESIDENTIAL FURNACE FANS

 6 Public Meeting was held pursuant to

 7 Notice at Room 8E-089, United States Department of

 8 Energy, 1000 Independence Avenue, SW, Washington,

 9 D.C., USA, commencing on the 18th day of June,

 10 2010, at 9:07 a.m. ET.

 11 TRANSCRIPT OF PROCEEDINGS

 12 MR. BROOKMAN: Okay, let's, let's start,

 13 shall we? Please take your seats.

 14 Good morning, everybody, and welcome.

09:08:24 15 This is the U.S. Department of Energy's Public

 16 Meeting on the Notice of Availability of a

 17 framework document for energy conservation

 18 standards for residential furnace fans.

 19 Today is Friday, June eighteenth. We're

09:08:37 20 in the, Washington, D.C., at the Department of

 21 Energy.

 22 My name's Doug Brookman from Public

 23 Solutions in Baltimore. Thanks for being here on
 11

 1 time.

 2 We have a full day ahead of you I think.

 3 Let's start off by doing introductions around the

 4 room, your name and organizational affiliation.

09:08:56 5 To use these microphones you need to

 6 push the button and see the little LED green light

 7 light up. So, let's start up over here.

 8 (Whereupon, self-introductions were had,

 9 after which the following occurred:)

09:10:29 10 MR. BROOKMAN: Thank you.

 11 I'm going to do a very quick Agenda

 12 review and then we're going to launch into the

 13 program for the day. I think all of you received a

 14 packet as you registered today.

09:10:38 15 In that packet is a copy of the

 16 PowerPoint slides that will be the focal point for

 17 presentation and for discussion. In addition,

 18 there is the framework document and the Federal

 19 Register and Notice.

09:10:50 20 So, a lot of detailed information for

 21 you surrounding this Public Meeting. Immediately

 22 following this Agenda review we're going to have an

 23 introduction of Mohammed, Mohammed Khan, and then
 12

 1 there's an opportunity for brief introductory

 2 comments, key issues that any person here wishes to

 3 raise here at the outset, issues that you may wish

 4 to emphasize.

09:11:25 5 In addition, then, we move on to an

 6 overview on the regulatory authority and

 7 rulemaking. Moving on from there, scope of

 8 coverage and test procedures.

 9 We'll take a break midmorning round

09:11:37 10 about 10:45 or so, then a description of, a, a

 11 continued description of test procedures.

 12 Following that, market and technology assessment,

 13 screening analysis, and engineering analysis.

 14 Take lunch midday, 12:30ish or so, and

09:11:53 15 then markups for product price determination,

 16 energy use analysis, lifecycle costs, and payback

 17 period analysis immediately following lunch. And

 18 then we'll move on to shipments analysis, national

 19 impacts analysis, LCC subgroup analysis, and

09:12:06 20 continue on manufacturer impact analysis.

 21 Then, utility impacts, employment

 22 impacts, environmental impacts, and regulatory

 23 impacts analyses. At the end of the day, around
 13

 1 about 3:00 o'clock or later today, we ex-, there's

 2 another opportunity for individuals to make closing

 3 remarks, other issues that they think they've not

 4 covered sufficiently during the course of the

09:12:25 5 meeting today.

 6 So, that's the plan for today. We --

 7 The agenda as written intends for us to adjourn at

 8 3:45.

 9 We'll go as quickly as we can, and as

09:12:35 10 efficient as we can. The Department sure does not

 11 wish to diminish anyone's capacity to comment.

 12 Okay? So, then that's all I had to say

 13 here at the outset except that I'd just ask for

 14 your cooperation.

09:12:49 15 Please speak one at a time during the

 16 meeting today. Please state your name for the

 17 Record.

 18 You don't need to say your organization

 19 each time because the Department knows who's here,

09:12:59 20 and at the end of the day it will distribute a

 21 listing, a photocopy of the business cards of the

 22 attendees. Please state your name each time you

 23 speak.
 14

 1 I wish to encourage follow-on comments

 2 in addition. That's helpful to the Department.

 3 If you can keep your focus here, please

 4 turn your telephones and other devices on "Silent"

09:13:22 5 mode. Please limit your sidebar conversations.

 6 If -- These microphones work well. If

 7 you're going to speak, please make sure the green

 8 light is on.

 9 And if you would, share the air time,

09:13:34 10 please. There's a lot to be said undoubtedly

 11 today, and we'll try and be concise with our

 12 comments.

 13 So, having said that, we'll turn it to

 14 Mohammed Kahn.

09:13:40 15 INTRODUCTION:

 16 MR. KHAN: All right. Thank you, Doug.

 17 Good morning, everybody. Let me first

 18 say that the Department of Energy is extra

 19 appreciative of your attendance this morning

09:13:56 20 because this is the first opportunity or the first

 21 effort that we've taken on any kind of regulation

 22 for energy consumption or energy use for

 23 residential furnace fans.
 15

 1 So, your comments and input today are

 2 going to be very, very important.

 3 Doug already covered the agenda.

 4 John Cymbalsky, who is the new Buildings

09:14:25 5 Technology Manager, is not able to attend today.

 6 He was going to say a couple of words, so I'm kind

 7 filling in, filling in for him right now.

 8 So, again I want to say thank you for

 9 your attendance, and your comments are going to be

09:14:41 10 very important. And what we're going to be

 11 covering today is the information that we provided

 12 in the framework document which has, or offers, or

 13 provides a discussion of the approaches that the

 14 Department expects to follow for its Standards

09:14:59 15 rulemaking for furnace fans, as well as all the

 16 analytical approaches and assumptions associated or

 17 affiliated with the development of a test procedure

 18 for those products.

 19 So, so again, thank you, and we're going

09:15:15 20 to be looking forward for all of your participation

 21 today.

 22 MR. BROOKMAN: Thank you.

 23 OPENING REMARKS FROM INTERESTED PARTIES:
 16

 1 MR. BROOKMAN: Now is an opportunity for

 2 anybody that wishes to do so to make brief summary

 3 remarks here at the outset.

 4 Diane first.

09:15:27 5 DR. JAKOBS: Hello. My name's Diane

 6 Jakobs, and I've been a (sic) active participant on

 7 the CSA C823 Committee from the beginning.

 8 And I'd just like to say one of the

 9 things that concerns me is how complex it is, and

09:15:46 10 how difficult it will be for anyone to make use of

 11 the information that we provide. Today in the AHRI

 12 Directory we have a, a little "e" designation for

 13 electrically efficient furnaces.

 14 And, and that's pretty straight-forward

09:16:04 15 because there's basically two classes of motors.

 16 And, and when you look at the efficiency of the,

 17 for furnaces, they kind of fall into two classes.

 18 And in the, the Directory, we have a

 19 little "e," and we have nothing. So, it -- So,

09:16:19 20 it's easy to differentiate, whereas with C823, they

 21 tried to do the annual energy consumption.

 22 And to look at a furnace for a whole

 23 year you have to consider what kind of
 17

 1 air-conditioning system is, it's used with, as well

 2 as the furnace operation. And furnaces are

 3 designed and operated with -- They have a, a lot of

 4 options.

09:16:45 5 So, you don't really know ahead of time

 6 how it will be installed, and it's very difficult

 7 to estimate what -- It depends on, you know, what

 8 part of the country, whether you, you're going to

 9 be in the north and have a small-capacity air

09:17:01 10 conditioner, or going to be in the south and

 11 high-capacity.

 12 So, my concern all along has been that

 13 we're going to have all of this data and no one

 14 will know what to do with it. So, that's my

09:17:13 15 comment.

 16 MR. BROOKMAN: Okay, thank you. Yeah.

 17 Other comments here at the outset? Yes?

 18 No? No?

 19 (Whereupon, no response was had.)

09:17:21 20 MR. BROOKMAN: That's it? That's all we

 21 -- Okay.

 22 Then we're going to move straight to the

 23 education slides of -- No, no.
 18

 1 REGULATORY AUTHORITY AND RULEMAKING OVERVIEW:

 2 MR. KHAN: Well, good morning again,

 3 everyone, and welcome. Thank you for participating

 4 in today's rulemaking.

09:17:51 5 Again, my name's Mohammed KHAN, and I'm

 6 the Department's Project Manager for this

 7 rulemaking activity. I'll be providing a brief

 8 overview of the rulemaking, and throughout the day

 9 we'll be hearing from analysts from Navigant

09:18:05 10 Consulting and from the Lawrence Berkeley National

 11 Laboratory on the proposed approaches and the

 12 various analyses the Department will be performing.

 13 Purpose of our meeting: Today's meeting

 14 serves multiple purposes. Mainly our goal is to

09:18:28 15 have a two-way discussion.

 16 We want to convey the key points and

 17 concepts associated with this rulemaking, as well

 18 as to hear and listen to your thoughts and

 19 potential concerns. First, the Department wants to

09:18:41 20 present the approaches and plans that it plans to

 21 implement in evaluating possible Standards for the

 22 furnace fans, and second, this is a forum for all

 23 interested parties to discuss and hear the issues
 19

 1 raised by DOE and by others.

 2 And because your feedback is very

 3 important, I encourage everyone on fully

 4 participate. And I urge you to submit and, submit

09:19:05 5 relevant data that will help the Department in this

 6 analysis.

 7 And lastly, we want to describe the

 8 steps in the rulemaking process.

 9 Comments: I said earlier it's very

09:19:15 10 important. This slide represents a sample of the

 11 call-out boxes that we'll use to identify certain

 12 issues the Department seeks certain information on.

 13 These boxes are in the framework

 14 document and will also be used throughout the day's

09:19:30 15 presentation to help elicit your thoughts.

 16 (Whereupon, Msrs. Burt and Bacchus

 17 conferred, out of the hearing of others and off the

 18 Record, during which the following occurred:)

 19 MR. KHAN: All right. Again, your

09:19:42 20 feedback is extremely important.

 21 I'm going to keep saying that. I hate

 22 to sound like a broken record, but it really is.

 23 I want to make sure that everyone is
 20

 1 clear on how to submit comments. This slide

 2 provides the postal, courier, and e-mail address

 3 which are appropriate for submitting.

 4 Please include the information at the

09:20:00 5 top of the slide so that it's properly identified

 6 and also catalogued. Also let me point out that

 7 the comment period closes July sixth, 2010.

 8 Okay, now I'll talk about, briefly about

 9 some relevant statutory language. The Energy

09:20:24 10 Policy and Conservation Act enacted in 1975

 11 provides the legal authority and guidelines DOE

 12 must follow to promulgate the Standards.

 13 The Energy Policy Act has amended EPCA

 14 to expand DOE's authority to specifically consider

09:20:40 15 and prescribe energy conservation Standards and

 16 energy use Standards for electricity used for

 17 purposes of circulating air through ductwork.

 18 In 2007, EPCA was amended again by the

 19 Energy Independence Security Act. EISA requires

09:20:57 20 that the furnace fan Standards will be published by

 21 December thirty-first, 2013.

 22 In addition, EISA requires that any new

 23 Standard after July first, 2007, must also address
 21

 1 standby mode and off-mode energy consumption.

 2 Rulemaking overview: Okay, EPCA

 3 requires the Department to consider seven key

 4 factors when promulgating new or amended Energy

09:21:30 5 Conservation Standards. This table lists those

 6 factors, and illustrates the pertinent, pertinent

 7 analyses the Department performs to address each of

 8 those factors.

 9 Throughout the day we'll be describing

09:21:40 10 the analyses in detail and should make clear the

 11 relevance and relationships between each of the

 12 analyses and the seven EPCA factors.

 13 Here we provide a chevron chart

 14 illustrating the primary steps in this rulemaking.

09:22:00 15 We're kicking off the rulemaking with the framework

 16 document and the public, and, and today's public

 17 meeting.

 18 The framework document is published, or

 19 was published on June third and is available on

09:22:10 20 line at the web URL at the bottom of the slide

 21 here. The document provides a discussion of the

 22 rulemaking process, and describes in detail the

 23 approaches, tools, and models DOE will use in its
 22

 1 analyses for Standards evaluations, and discusses

 2 approaches for the needed framework fan test

 3 procedure.

 4 Next steps: As shown in the chevron on

09:22:42 5 the previous slides, the next steps of the

 6 rulemaking is the Notice of Proposed Rulemaking,

 7 followed by the Final Rule. The NOPR will propose

 8 certain standard levels based on a completed

 9 analysis of the potential impacts on consumers,

09:22:56 10 manufacturers, and the Nation as a whole.

 11 The Department will also weigh the

 12 impacts against each other to determine the most

 13 appropriate proposed Standard level, and, of

 14 course, the NOPR will include a discussion of all

09:23:09 15 relevant comments that were received.

 16 In the Final Rule document DOE will

 17 discuss all comments received in the NOPR phase and

 18 will likely provide a revised or enhanced analysis

 19 stemming from any pertinent data that we receive.

09:23:24 20 Again, DOE will weigh the impacts and determine the

 21 appropriate Standard, and the Final Rule will, will

 22 prescribe a compliance date for the Standards.

 23 Any other questions?
 23

 1 (Whereupon, no response was had.)

 2 MR. KHAN: Okay.

 3 MR. BROOKMAN: Okay.

 4 MR. KHAN: Thank you.

09:23:45 5 SCOPE OF COVERAGE AND TEST PROCEDURES:

 6 MR. JASINSKI: Good morning. My name is

 7 Sam Jasinski, from Navigant.

 8 Navigant is assisting the Department in

 9 this rulemaking development of the furnace fan test

09:23:58 10 procedure and analyses that will be conducted for

 11 the Notice of Proposed Rulemaking, or the NOPR.

 12 I'll start by discussing the scope of coverage.

 13 The statutory language in EPCA provides

 14 DOE the authority to regulate any electrically

09:24:13 15 powered device used in residential central heating,

 16 ventilation, and air-conditioning systems for the

 17 purpose of circulating air through ductwork.

 18 Furnace fans or the HVAC systems in

 19 which furnace fans are used will be referred to as

09:24:27 20 "furnace fan products," and these include but are

 21 not limited to all kinds of residential furnaces

 22 such as gas-fired systems, oil-fired systems, and

 23 electric residential furnaces, split-system and
 24

 1 packaged air-conditioner and heat pump air

 2 handlers, and modular fan coils.

 3 Also is a preliminary list of devices

 4 DOE is tentatively considering to not be furnace

09:24:42 5 fans.

 6 The statutory listing in EPCA also does

 7 not specify which HVAC products utilize furnace

 8 fans, nor does it specify any range of

 9 characteristics such as rated air flow capacity or

09:24:55 10 rated fan motor horsepower to aid in defining the

 11 scope of coverage.

 12 As mentioned, throughout the

 13 presentation there will be items listed on which

 14 DOE seeks comment. The item numbers in the

09:25:05 15 presentation match those that are in the framework

 16 document for your reference, and since there are

 17 quite a few of them I'll just briefly summarize the

 18 groupings and turn over the discussion to Doug for

 19 more details.

09:25:16 20 This first list is items on which DOE is

 21 seeking comment related to the scope of coverage,

 22 as well as how DOE is approaching applying the

 23 statutory language in EPCA.
 25

 1 MR. BROOKMAN: Yes. So, you can see the

 2 comment boxes listed there.

 3 We won't read them. There are four of

 4 them.

09:25:38 5 Let's start with 1, scope of coverage, a

 6 very important issue.

 7 Karim?

 8 DR. AMRANE: Karim Amrane, AHRI.

 9 We don't have the same understanding of

09:25:48 10 what EPCA says, what it says about, about the

 11 coverage of, of, of this proposed Rule. For

 12 example, I mean, heat pumps and air-conditioner

 13 system with blower coils, as far as we know, I

 14 mean, the energy consumption of the fan is

09:26:05 15 accounted for in the SEER calculation or the HSPF

 16 calculation.

 17 So, I think it's clear to us that what

 18 Congress wanted DOE to do was to address the

 19 furnace fans, fan, and not the fan in the heat pump

09:26:21 20 or in the air-conditioning with a blower core. So,

 21 I'm not sure why DOE believes that it has that

 22 authority, but that's, that's a, that's not what

 23 EPCA says
 26

 1 MR. BROOKMAN: Thank you.

 2 Other comments on scope? Jim.

 3 MR. VerSHAW: This is Jim VerShaw.

 4 I agree that if you start including

09:26:45 5 things other than furnaces, then you start

 6 including the power that's already accounted for in

 7 the HSPF and SEER calculations. And you try to set

 8 a Standard around fan power at the same time you're

 9 setting a Standard for the whole system

09:26:57 10 performance, I'm not sure which one takes

 11 precedence.

 12 And seems like you're doubling, double

 13 putting Standards on two things that should be just

 14 one. So, that's why I agree with Karim that you

09:27:08 15 really need to focus it back on furnace fans, and

 16 not have blower fans and coils.

 17 MR. BROOKMAN: Diane.

 18 DR. JAKOBS: And even more than that

 19 note, just air handlers with the furnace in the

09:27:22 20 cooling mode. We -- When you have a match system,

 21 we're using that same air flow to complete SEER for

 22 the matched system.

 23 So, so it should even be limited further
 27

 1 into just the furnace in the heating mode. Other

 2 than that, in the air-conditioning mode it's

 3 already, the electricity is already taken into

 4 account for the SEER calculation.

09:27:45 5 It's only in the heating mode where

 6 there is a, a gap and it's not accounted for.

 7 MR. BROOKMAN: Okay, thank you.

 8 So, just to complete the Record if we

 9 can, do we have any counterpoint at this point?

09:28:05 10 Charlie Stephens.

 11 MR. STEPHENS: Charlie Stephens.

 12 I, I kind of agree with those

 13 observations, but I will note that I just came back

 14 from the field two days ago from inspecting one of

09:28:21 15 those very same air handlers that's installed

 16 without a heat pump, without an air-conditioning

 17 outdoor unit.

 18 It's feeding air to a water coil. Same

 19 unit, but it's not associated with the heat pump

09:28:34 20 outdoor unit or an air-conditioning outdoor unit.

 21 I guess I'm kind of wondering how you

 22 would account for its efficiency in that kind of

 23 application.
 28

 1 MR. BROOKMAN: Diane, you can respond if

 2 you wish.

 3 DR. JAKOBS: Actually, the way I read

 4 this I would assume it would be covered from this

09:28:53 5 point of view as a, as a (sic) air handler. But,

 6 you're right.

 7 If, if you assume that the scope of

 8 coverage isn't going to cover the air handler, then

 9 hydraulic air handler isn't covered anywhere

09:29:12 10 either. And the, the, the units that are out today

 11 don't have a (sic) energy guide label.

 12 And CSA C823, they also -- I'm on a

 13 committee for that one, too, for combo systems, and

 14 they're, they're looking at trying to calculate the

09:29:26 15 efficiency for a whole match system, a water heater

 16 and a (sic) air handler, and for the test you put

 17 in.

 18 And it's very -- It's a lot of testing

 19 for that product. But, you know, you're right;

09:29:43 20 it's not covered.

 21 MR. BROOKMAN: I want to make sure we're

 22 as complete as possible. Let me ask you to focus

 23 your attention on Item Number 3 and Item Number 4.
 29

 1 Karim, I wasn't sure you addressed these

 2 things, especially the interpretation of the

 3 relevant language of EPCA as excluding electricity

 4 used by draft inducer fans, exhaust fans, and

09:30:03 5 heat/energy recovery ventilators.

 6 DR. AMRANE: I didn't cover it, but I

 7 agree with your interpretation.

 8 MR. BROOKMAN: Yes. Okay.

 9 So, then we'll take other comments on 3

09:30:12 10 and 4, 4 being a comment whether DOE should include

 11 rated airflow capacity range or rated horsepower

 12 range to help define the test procedure

 13 applicability.

 14 Diane.

09:30:23 15 DR. JAKOBS: So, I think that the rated

 16 air flow really is a better descriptor of how the,

 17 the blowers are used. And if you're just looking

 18 at the motors, the horsepower would be good.

 19 But, the, the, the housing and the

09:30:39 20 impeller make a big difference, and the CFM is

 21 really, is more descriptive of the fan, furnace fan

 22 assembly.

 23 MR. BROOKMAN: Okay. Okay.
 30

 1 (Whereupon, at 9:30 a.m. ET, Mr. KHAN

 2 and Mr. Stas conferred, out of the hearing of

 3 others and off the Record, during which the

 4 following occurred:)

09:30:56 5 MR. BROOKMAN: I want to make sure we're

 6 complete here. This is important to the

 7 Department.

 8 Any additional comments or counterpoints

 9 on, on these issues? Because we're about to move

09:31:04 10 on.

 11 Ashley?

 12 MS. ARMSTRONG: I actually have a

 13 question. So, for Number 4, for, if DOE should

 14 include or shouldn't include a rated airflow

09:31:14 15 capacity, what would you see that rated air flow

 16 range being?

 17 MR. BROOKMAN: Diane?

 18 DR. JAKOBS: Well, if, if we're just

 19 doing residential, I think you had a range in there

09:31:23 20 like 800 to 2,200.

 21 MR. KHAN: Four-hundred.

 22 DR. JAKOBS: Four-hundred.

 23 MR. JASINSKI: Yeah, I think it was 400
 31

 1 to 2,200.

 2 DR. JAKOBS: Yeah. I think if it's

 3 residential, that's probably the range.

 4 MR. BROOKMAN: Okay, thank you. So,

09:31:39 5 now, now we're going to move on.

 6 MR. JASINSKI: Next I'll discuss the

 7 modes of operation for furnace fans to include

 8 active-mode operation, standby-mode operation, and

 9 off-mode operation.

09:31:44 10 Active-mode operation is the mode of

 11 operation during which the furnace is powered and

 12 the impeller is in motion.

 13 Standby mode of operation is during

 14 which the furnace fan is powered but the impeller

09:31:57 15 is not in motion. DOE believes that furnace fan

 16 standby consumption is indistinguishable from

 17 standby consumption of the furnace fan product

 18 because the furnace fan controls are typically

 19 well-integrated into the controls of the furnace

09:32:09 20 fan product.

 21 DOE also believes that this furnace fan

 22 standby consumption will be accounted for in the

 23 rulemaking for residential air-conditioning,
 32

 1 residential furnaces, and blowers.

 2 The third mode of operation, off-mode

 3 operation, is the mode of operation during which

 4 the furnace fan product is not powered. DOE

09:32:24 5 believes that consumers are unlikely to set their

 6 HVAC system, excuse me, to the "Off" mode.

 7 Therefore, there will be no off-mode

 8 furnace fan energy consumption.

 9 At this time DOE seeks comment on its

09:32:38 10 assumptions about the electricity consumption in

 11 each mode of operation.

 12 MR. BROOKMAN: Diane.

 13 DR. JAKOBS: Sorry. I just want to

 14 point out that this is one point where you're

09:32:49 15 different from C823, and it was something we talked

 16 about a lot.

 17 But, for the standby mode, the ECM

 18 motors, because their control is active, they

 19 actually have a standby mode, but it's kind of a --

09:33:04 20 You could look at the control as being part of the

 21 furnace, which is what I think you intended it as,

 22 and then it ended up, because it was actually

 23 attached to the motor, they wanted to find it
 33

 1 there.

 2 So, so I think that DOE's assumption

 3 makes more sense, but it's this contrast to what

 4 they, we did on C823.

09:33:29 5 MR. BROOKMAN: Okay. Thank you.

 6 Thank you. Thank you.

 7 Jim.

 8 MR. VerSHAW: Jim VerShaw.

 9 I agree with DOE that the standby power

09:33:37 10 of a component of a, of a, of a furnace which

 11 you're already going to do a standby of the furnace

 12 itself becomes irrelevant. Just do the furnace by

 13 itself.

 14 MR. BROOKMAN: Okay.

09:33:51 15 Yes, Charlie.

 16 MR. STEPHENS: Charlie Stephens.

 17 I'm still going to be a little bit

 18 confused, though, when you use these things when

 19 they're not associated with a furnace, per se, a

09:34:01 20 gas-fired furnace or a propane, for instance.

 21 Again, I'm, I'm seeing a lot of these air-handler

 22 units.

 23 I don't want to name brand names, but I
 34

 1 -- Fact is, there's a lot in my part of the world,

 2 variable-speed units that are going in just as a

 3 standby air handler feeding a third-party water

 4 coil, and there it is.

09:34:24 5 And when, --

 6 (Whereupon, at 9:34 a.m. ET, Msrs. Burt

 7 and Bacchus conferred, out of the hearing of others

 8 and off the Record, during which the following

 9 occurred:)

09:34:28 10 MR. STEPHENS: -- when the consumer puts

 11 it in the "off" position, "off" mode, the

 12 transformer in that thing is humming away, and it

 13 is using electricity, some electricity. And, no,

 14 that won't be captured in some other Standards for

09:34:41 15 that unit.

 16 So, I don't -- I, I think you're not

 17 going to meet the statutory requirement if you

 18 don't at least test these things and give them some

 19 sort of a mode, recognizing that that will also be

09:34:53 20 subsumed in another rating if it's used with a

 21 (sic) air-conditioning or heat-pump system.

 22 Or, if it's in a gas furnace it may have

 23 the very same rating, but these things are used in
 35

 1 other places besides just air conditioning and heat

 2 pumps. And when they're out there, hundreds of

 3 them where I am use that way.

 4 And that -- and it's growing fast. You

09:35:22 5 have to account for these somehow, in my opinion.

 6 MR. BROOKMAN: Thank you.

 7 Diane?

 8 DR. JAKOBS: I agree with you. But,

 9 what area are you from?

09:35:29 10 MR. STEPHENS: Pacific Northwest.

 11 DR. JAKOBS: Yeah, okay.

 12 MR. BROOKMAN: Pacific Northwest, says

 13 Charlie.

 14 Go ahead.

09:35:37 15 DR. JAKOBS: But, those systems they

 16 have also have a pump, and to keep the water from

 17 getting stagnant, periodically the pump will run.

 18 So, it's not just the transformer.

 19 So, it's -- Yeah, the hydraulic systems.

09:35:50 20 Yeah.

 21 MR. BROOKMAN: So, Diane, what would you

 22 suggest the Department do in this case?

 23 DR. JAKOBS: The -- Well, what's really
 36

 1 hard about all this is that the fan is part of a

 2 system, and it's really hard to say, like, separate

 3 it from -- You know, it -- And it's not even just

 4 the air movement. It's part of the heat transfer

09:36:23 5 system.

 6 So, it's doing more than just moving air

 7 through ducts. And there's a lot of this overlap,

 8 so, so it's difficult.

 9 Like I've said before, I thought the

09:36:34 10 hydraulic air handlers would be covered, but till

 11 this second I, I forgot about the pump. So --.

 12 MR. BROOKMAN: Yeah, at this early stage

 13 in these proceedings it's helpful for the

 14 Department if people can offer up prospective

09:36:48 15 solutions. That's the reason I'm asking.

 16 Yes, Jim.

 17 MR. VERSHAW: Yes. Jim VerShaw.

 18 Sounds like we're talking about a system

 19 where somebody's bought a water system and bought a

09:36:58 20 coil and bought an air handler, and they're making

 21 a furnace out of it. Now, what is the energy

 22 conservation standard for that system?

 23 Because it's not a lot of power that a
 37

 1 blower's going to use. It's maybe two to three

 2 percent of the total amount of energy that that

 3 water heater's going to use to heat the residence,

 4 and that water heater was probably purchased with

09:37:18 5 80 percent steady-state, with an energy factor of

 6 .8, .6, something like that.

 7 What is it as a furnace? I mean, I

 8 think there's a gap.

 9 There's a real gap in the way that the

09:37:31 10 Department is handling that particular system. And

 11 I think that the key for this is for the Department

 12 to look at this system, make sure that those things

 13 are really operated in the right way.

 14 If, if it's being used as a furnace,

09:37:41 15 then, then I don't think it's an 80-percent

 16 steady-state report because it has a much higher

 17 stability. So, that efficiency goes way down.

 18 Plus, it's using indoor air for

 19 combustion, not outdoor air. The whole thing is,

09:37:56 20 has got a problem; needs to be --

 21 MR. BROOKMAN: Diane, follow-on. Then

 22 to Charlie.

 23 Go ahead, Diane. Go ahead.
 38

 1 DR. JAKOBS: No, I've just -- I agree.

 2 I mean, it's, it's, it's a gap, and no one has

 3 suggested those systems should be 80-percent

 4 efficient, so --.

09:38:13 5 MR. BROOKMAN: Charlie.

 6 MR. STEPHENS: Charlie Stephens again.

 7 I think people are misinterpreting the

 8 kind of system I'm talking about here. I'll name

 9 some brand names; just no offense to anybody else,

09:38:23 10 because there are other brands out there.

 11 But, I know the brands because I, like I

 12 said, two days ago I was inspecting it in the

 13 field. It was a Carrier FV4 air handler,

 14 variable-speed air handler running off a hydraulic

09:38:39 15 coil, third-party hydraulic coil with a hot- and

 16 chilled-water supply by a heat pump system, an

 17 air-to-water heat pump system.

 18 So, that's what's going on here.

 19 There's no, you know, no combustion of anything

09:38:53 20 here.

 21 It's just hot water and chilled water

 22 being supplied to a water coil on top, mounted on

 23 top of a variable-speed air handler, a standard
 39

 1 off-the-shelf Carrier FV-4 air handler.

 2 So, you know, these things are, are

 3 happening out there more and more. And so the -- I

 4 think, you know, the FV-4 has to have some kind of

09:39:15 5 a rating in order to be able to be used there.

 6 MR. BROOKMAN: Okay.

 7 Frank Stanonik.

 8 MR. STANONIK: Frank Stanonik.

 9 Is this a residential application?

09:39:25 10 MR. STEPHENS: And small commercial.

 11 MR. STANONIK: Okay. But, this -- Right

 12 now we're looking at, at the moment, at a Rule that

 13 would cover -- My words here. -- a residential

 14 furnace or, or arguably a residential heat pump or

09:39:40 15 residential air conditioner.

 16 This, to me, sounds like a -- Again, I

 17 wasn't there, but sounds like maybe a multi-family

 18 kind of application, or something where you've got

 19 this central system feeding either cooled or heated

09:39:54 20 water to maybe multiple air handlers. I don't

 21 know, but I don't think it's, I don't think it's

 22 currently within our scope of discussion.

 23 MR. BROOKMAN: Charlie, go ahead.
 40

 1 MR. STEPHENS: No, it's a

 2 3,000-square-foot house with -- I mean, an FE-4 is

 3 a residential product. I mean, it's a single-phase

 4 residential product.

09:40:13 5 It, it normally is associated with a

 6 heat pump, an outdoor unit with a heat pump, but

 7 not always. You can use it in other cases.

 8 MR. BROOKMAN: Frank, go ahead.

 9 MR. STANONIK: Frank Stanonik.

09:40:26 10 Where is the unit at that's providing

 11 the chilled or heated water? Is it a --

 12 MR. STEPHENS: It's a heat pump. It's

 13 outside.

 14 MR. STANONIK: It's --

09:40:35 15 MR. STEPHENS: How's that different?

 16 MR. STANONIK: And --

 17 MR. STEPHENS: And it's a, a fan. It

 18 supplies hot water or chilled water to a module or

 19 a tank, which is then routed to the air handler.

09:40:44 20 I mean, it's --

 21 MR. BROOKMAN: Charlie, it seems as

 22 though you're describing something that's sort of

 23 an exception to this general description.
 41

 1 MR. STEPHENS: Except not where I live.

 2 I mean, where I live it's actually becoming,

 3 becoming rather common.

 4 And it, it's growing. So, I think it

09:40:59 5 needs to be considered.

 6 MR. BROOKMAN: Okay, thank you.

 7 Let me go to Greg.

 8 MR. WAGNER: Greg Wagner.

 9 When I'm looking at this whole set of

09:41:10 10 discussion, the thing that's missing -- And you're

 11 asking for solutions, Doug. -- is you're, it's,

 12 it's talking about components versus talking about

 13 systems.

 14 And what happens when you look at just

09:41:23 15 components? You get some optimal system solutions.

 16 And even in the case like this perhaps

 17 there needs to be a special rule for these type of

 18 systems that are outside of the scope of what

 19 exists today as far as rules and laws. And this

09:41:36 20 kind of goes back to the original question of:

 21 What are, what are we doing here as far

 22 as scope?

 23 MR. BROOKMAN: Scope. Right.
 42

 1 Diane, do you want to follow on?

 2 DR. JAKOBS: (Nodded no.)

 3 MR. BROOKMAN: Okay.

 4 DR. JAKOBS: Not this time.

09:41:48 5 MR. BROOKMAN: Okay. One additional

 6 comment.

 7 I'm thinking we've covered this. Maybe

 8 we've covered it more than once, so we're about to

 9 move on.

09:41:54 10 You're next. Say your name, please.

 11 MR. SMALL: Terry Small, Mortex.

 12 I'd just like to point out that, much in

 13 the same way, on a large commercial job you have

 14 sort of the field and straw, different

09:42:06 15 combinations. I've seen residential jobs where

 16 you're taking a regular residential heat-pump air

 17 handler, you're putting a chilled water coil, a

 18 heating coil in it.

 19 You've got an ice bank that, a tank for

09:42:24 20 chilled or ice-melt water. You've got a solar

 21 collector feeding the tank for solar-collected

 22 water.

 23 It's all sort of fabricated and
 43

 1 installed on site in a, in a house. There are

 2 systems like this out there.

 3 So, I think I agree with Greg. We've

 4 got to be careful here.

09:42:43 5 That's -- What's been described is

 6 almost something that's sort of a field-applied

 7 system, and I think it's going to be a very

 8 difficult area if you're going to get into that at

 9 this point. I mean, I think this -- We should

09:42:56 10 stick strictly to the conventional furnace and the,

 11 the fan once used by conventional furnaces.

 12 MR. BROOKMAN: You okay?

 13 Yes, ma'am.

 14 (Whereupon, no response was had.)

09:43:08 15 MR. BROOKMAN: Okay, we're moving on.

 16 Lane, please.

 17 MR. BURT: Sorry. Lane Burt.

 18 Just to be clear, I mean, the Statute

 19 says that DOE's supposed to find significant energy

09:43:17 20 savings that are out there, are technically

 21 feasible and economically justified. And if there

 22 is a segment, a large application somewhere in the

 23 country that's using things, even though they are
 44

 1 somewhat strange, it is up to the Department to

 2 assess that and set the Standards according to the

 3 Standards.

 4 And just because it's a difficult

09:43:35 5 problem doesn't mean it shouldn't be undertaken.

 6 And I appreciate that's --

 7 MR. KHAN: Doug, Mohammed KHAN, DOE.

 8 Before we move on I'd like to just

 9 revisit a point that Diane had mentioned. I just

09:43:48 10 want to get some clarification, please.

 11 We were talking about the issue of, I

 12 guess, characterizing standby mode, off mode in the

 13 context of the fan and, and the associated or

 14 affiliated controls. I, I, I think I heard you say

09:44:04 15 that in Canada, with some of the, the furnace fans,

 16 the controls are built or are integral to the, the,

 17 the fan itself.

 18 And, and if that's true, I just want to

 19 make sure that is that, or is that not also the

09:44:20 20 case in the United States? Are we talking about

 21 something different here, or not?

 22 DR. JAKOBS: No, actually it's the same

 23 products in Canada and the United States. It is
 45

 1 just on the committee for C823 we, we decided to

 2 account for this standby with the fan assembly,

 3 where I think here we're talking about there

 4 wouldn't be a standby mode.

09:44:46 5 If, if you just hooked up the, an ACM

 6 motor by itself and had it energized, there would

 7 be standby losses. But, the way the control --

 8 There's a -- You know, you -- The -- There's two

 9 control boards, or three.

09:45:05 10 MS. ARMSTRONG: That's what I --

 11 DR. JAKOBS: And one's stuck over here

 12 and one's stuck over here (indicating). Do you

 13 lump them all together, or do you parse it out?

 14 MR. BROOKMAN: Ashley.

09:45:14 15 MS. ARMSTRONG: Yeah. I was just going

 16 to clarify.

 17 I think what she means, for certain

 18 types of motors, those motors themselves have their

 19 own control boards in addition to the furnace

09:45:24 20 control board. When the system is hooked together,

 21 and when the furnace standby is in "Off" mode, test

 22 procedure is run, you can pick up both.

 23 So, it's not that necessarily DOE is not
 46

 1 accounting for them somewhere.

 2 DR. JAKOBS: Right.

 3 MS. ARMSTRONG: It's just that we are,

 4 we are arguing that for furnace fan standby, that

09:45:39 5 they'll be accounted for with the furnace and not

 6 the fan.

 7 DR. JAKOBS: Right. And I agree with

 8 that.

 9 MR. BROOKMAN: Karim?

09:45:44 10 DR. AMRANE: Right. And we agree with

 11 that.

 12 MR. BROOKMAN: Thank you.

 13 Frank, you okay?

 14 MR. STANONIK: (Nodded yes.)

09:45:48 15 MR. BROOKMAN: Okay.

 16 Okay, so now we're moving in --

 17 Oh, yes. Molly.

 18 MS. TROMBLEY-McCANN: Molly

 19 Trombley-McCann.

09:45:54 20 I wanted to ask some clarifying

 21 questions. So, in the case of an air-handling unit

 22 with an ECM and air-conditioning controls that

 23 isn't part of the furnace, the standby modes, the
 47

 1 furnace would not be captured anywhere.

 2 Is that true? I'm wondering about

 3 systems and actual --

 4 MR. VerSHAW: Well, -- Jim VerShaw.

09:46:14 5 You don't count an air handler with the

 6 furnace because the furnace has the blower in it.

 7 MS. TROMBLEY-McCANN: Sorry. So, what

 8 I'm trying to ask is:

 9 In the case where you have a system with

09:46:24 10 a (sic) ECM fan that is not coupled with a furnace,

 11 where does that control board go? And, is it

 12 captured in the standby modes?

 13 MR. VerSHAW: It's in the product that

 14 has the motor in it. And when the, when the -- At

09:46:37 15 least for the product that's, that we sell, when

 16 the, when the Department goes and talks about

 17 supply losses for those systems, it will be

 18 involved in that.

 19 DR. AMRANE: Right.

09:46:50 20 MR. BROOKMAN: Thank you, Jim.

 21 Now Karim.

 22 DR. AMRANE: Right. Last week we talked

 23 about it, and I believe what DOE has proposed it
 48

 1 will account for what you have.

 2 MR. BROOKMAN: Okay. We ready now?

 3 (Whereupon, no response was had.)

 4 MR. BROOKMAN: Okay.

09:47:00 5 MR. JASINSKI: Next I'll be discussing

 6 the development of the furnace fan test procedure.

 7 Initially DOE is reviewing two approaches to

 8 develop a test procedure.

 9 The first is to use the December, 2009,

09:47:11 10 draft version of Canadian Standard Association C823

 11 as a framework. Please note that this, the, the,

 12 the Draft that we refer to is available on the

 13 Department of Energy web site.

 14 In addition, this, please be aware that

09:47:25 15 the development of this procedure or this Standard

 16 is still in, in progress.

 17 The second approach that DOE is

 18 reviewing is to use the blower electricity

 19 measurement, BE, which is specified in the

09:47:39 20 Department of Energy's residential furnace test

 21 procedure.

 22 To begin, I'll go into a little bit more

 23 detail about CSA C823. The purpose of this
 49

 1 Standard is to develop an annual electricity

 2 consumption rating, or AECR ratings for air

 3 handlers that are, include that procedure.

 4 Methodology to do so is a bit complex,

09:48:03 5 and the following, the, the slides to follow will

 6 go into that in a little bit more detail. Also

 7 listed are the multiple existing industry test

 8 procedures referenced within CSA C823.

 9 At this time DOE welcomes any comments

09:48:18 10 on the use of CSA C823 as a framework, as well as

 11 any information about other existing industry test

 12 procedures that may be applicable to rating furnace

 13 fan performance.

 14 MR. BROOKMAN: Diane?

09:48:36 15 DR. JAKOBS: I think I, I talked a

 16 little bit about it in my opening remarks, but one

 17 of the things with C823, we are very specific about

 18 the climate and the heating hours. And they have a

 19 little different way of doing heating hours.

09:48:54 20 I've -- We have different names, but

 21 the, we have maps. And the ASHRAE 103 or AHRI

 22 210-45 show heating and cooling hours.

 23 And the way they're computing that in
 50

 1 Canada is different, so, so that that, that there

 2 will have to be that adjustment. But, the thing

 3 that's difficult is that you get an -- Today for

 4 ASHRAE, ASHRAE 103 with the AUFE Standard, we

09:49:25 5 calculate a use of AE.

 6 And it's, it's a kilowatt-hour number, I

 7 guess, but they're all different. And you -- It

 8 depends on the capacity, and it's difficult to

 9 compare one unit to the other.

09:49:38 10 So, in my mind, this will give you more

 11 numbers just like that. And, and we're, we're not

 12 against -- We are -- I want to provide information

 13 that our customers will be able to use and will

 14 help them make the right application so they're

09:49:55 15 happy with our products, but ASHRAE doesn't seem to

 16 be a useful number.

 17 MR. BROOKMAN: Well, when you say "this"

 18 will give you better numbers, what, what, what are

 19 you -- What -- Be specific. What are you --

09:50:08 20 DR. JAKOBS: The idea of, like, 13 SEER,

 21 people seem to understand that; or 80 percent AUFE.

 22 And it doesn't matter what capacity furnace.

 23 It doesn't matter, you know, if it's
 51

 1 upflow or down-flow, or -- You know, it's something

 2 that people can understand. And they can look at

 3 our ledger, and they can look at Ingersoll Rand

 4 ledger, and they can make a comparison, whereas

09:50:33 5 using this C823, it's going to be very difficult to

 6 make any comparisons.

 7 You're going to have to -- We make a, a

 8 number of assumptions about the cooling capacity

 9 and heating capacity, and how the installation is.

09:50:52 10 And you -- We'll have to make that same number of

 11 assumptions to compare two units.

 12 You can make kind of broad comparisons,

 13 but, but there are easier ways to do that, to make

 14 a, a broad comparison. If you want to be so

09:51:06 15 specific, it would really take a knowledgeable

 16 person to use the data that we're thinking about in

 17 CSA CA823 producing.

 18 MR. BROOKMAN: Okay, thank you.

 19 Okay? Karim.

09:51:21 20 DR. AMRANE: Karim Amrane, AHRI.

 21 As Diane stated, we have some concerns

 22 about, about the CSA Standard. And several things

 23 -- the process, the content, everything else that,
 52

 1 that the Committee has produced, we have concerns

 2 with that.

 3 And as an industry, we, we are exploring

 4 writing new test procedure for, for, for the air

09:51:46 5 handler. And we going to be starting the process

 6 probably next week.

 7 We going to have initial meeting next

 8 week, and based on that meeting we make a decision

 9 on whether we can move forward with the, with a

09:52:01 10 Standard Project Committee. And if we do, we'll

 11 make announcement to, to everybody who is

 12 interested to participate in that committee.

 13 So, it's going to be open to DOE, to

 14 anyone who is interested in that subject. So, more

09:52:13 15 to follow within a week or so.

 16 MR. BROOKMAN: Thank you. And how long

 17 might that take, do you think?

 18 DR. AMRANE: Well, that's going to be a

 19 good question. And, actually, I have a question

09:52:21 20 for DOE, because initially there was some

 21 discussion within DOE to combine the furnace

 22 efficiency Standard, the air-conditioning

 23 efficiency Standard, and the furnace fan efficiency
 53

 1 Standard into one mega rulemaking.

 2 And we are on record to saying we

 3 shouldn't. We shouldn't include the fans within

 4 the furnace efficiency rulemaking because,

09:52:43 5 according to EISA, DOE has until 2013 to issue the

 6 final Rule.

 7 So, you have, you have more time than if

 8 you, if you combine the three together, which will

 9 force you to finish this, the test procedure and

09:52:56 10 the efficiency Standard, before May of next year,

 11 and we don't believe that you have enough time to

 12 do that. So, so we would like you to decouple the,

 13 the furnace efficiency and the central AC

 14 efficiency from this rulemaking.

09:53:09 15 In doing so, you'll have more time and

 16 we will be then working with you and, and others to

 17 try to come up with a test procedure that is

 18 acceptable to industry and to everybody else.

 19 MR. BROOKMAN: Okay, thank you.

09:53:21 20 Diane?

 21 I would note that Karim's comment is

 22 responsive to Item Number 8, which requires about

 23 the existence and applicability of other industry
 54

 1 test procedures.

 2 So, Diane.

 3 DR. JAKOBS: Can I -- I want to go back

 4 to the second half of Item 7, where you talk

09:53:36 5 about --

 6 MR. BROOKMAN: Yes, please do.

 7 DR. JAKOBS: -- AMCA 210 and ASHRAE -5.

 8 And CSA C823 does use those Standards, so the

 9 actual test procedure is something we've used for a

09:53:47 10 long time.

 11 And we all have equipment and we know

 12 how to run the test and we all have, we have data.

 13 So, that part of C823 is really good, and I would

 14 commend, you know, I would suggest that any

09:54:02 15 Standard we have, we would continue in that, with

 16 that idea.

 17 It would be consistent with this testing

 18 that we do for SEER, and that part of it makes a

 19 lot of sense to me.

09:54:14 20 MR. BROOKMAN: Okay, thank you. That's

 21 helpful.

 22 Frank?

 23 MR. STANONIK: Frank Stanonik, AHRI.
 55

 1 I've also got a question relative to

 2 this general question of the Canadian Standard or

 3 some other Standards. Does this necessarily have

 4 to be an either/or?

09:54:35 5 And what I'm thinking is the, a, a

 6 traditional gas or oil furnace. We have been

 7 measuring some electrical consumption of that fan

 8 since the first AUFE test procedures, and so this

 9 certainly has, let's say, some historical inertia

09:55:02 10 or whatever you want to call it to see if we can

 11 possibly amend that to make it fit what DOE's been

 12 asked to do.

 13 But, on the other hand, there are some,

 14 for lack of a better word, separate air handlers

09:55:15 15 that, that aren't necessarily part of an

 16 air-conditioning system or not necessarily part of

 17 a, a manufactured heat-pump system or whatever.

 18 And in that case, maybe a Canadian-like test might

 19 be a fit or something.

09:55:37 20 And I -- And the reason I raise that is

 21 because when we, at least when I first heard about

 22 this, this activity up in Canada, my first thought

 23 is, well, okay, you know, I tried to get
 56

 1 clarification: Is, is a furnace an air handler?

 2 Because in my own mind, the answer was

 3 no. I mean, since, since the dawn of furnace

 4 efficiency Regulations, gravity furnaces went out

09:56:07 5 the window.

 6 So, for the last, whatever, 30 years,

 7 furnaces have had fans. And to somehow say, "Well,

 8 we're only going to look at -- We're going to

 9 reclassify it as an air handler," it's like, "Wait

09:56:21 10 a minute. It's a furnace, the whole system."

 11 And so I guess I'm just thinking.

 12 Again, things have evolved.

 13 We have other kind of systems. There

 14 are things out there that are nothing more than a

09:56:30 15 box and a motor and a blower in it, and other

 16 things get added in the field.

 17 And, and maybe other, a possible path is

 18 you have two procedures, one that just deals with

 19 what we've been doing on furnaces for 40 years,

09:56:46 20 whatever number, and one that addresses the fact

 21 that this, this box out here that is now in use at

 22 the moment, and it has a blower in it and uses

 23 electricity.
 57

 1 And, and, I mean, the endpoint of this

 2 is to save energy, right? And at this point that

 3 box is unregulated, as far as I know.

 4 I guess I'm, just want to maybe plant

09:57:10 5 the seed that maybe, maybe it's not an either/or,

 6 but two procedures.

 7 MS. ARMSTRONG: You going to answer

 8 that?

 9 MR. BROOKMAN: Hang on. Okay, Jim.

09:57:26 10 Yes.

 11 MR. VerSHAW: Yeah. Jim VerShaw.

 12 I think, I think the CSAl Standard

 13 started in the right place and then went awry. I

 14 think starting with ACRE was right, but then became

09:57:37 15 a flawed and cumbersome procedure.

 16 Then I think, I think as we get into

 17 various issues, as we get into various comments,

 18 you can see that there are quite a few things that

 19 are problematic.

09:57:47 20 MR. BROOKMAN: Okay. And that's an

 21 opportunity that you will be able to comment on

 22 later on.

 23 Okay, I want to make sure we capture
 58

 1 that completely.

 2 Jim Ranfone.

 3 MR. RANFONE: Jim Ranfone, AGA.

 4 Just a question about 823. And I think

09:57:59 5 this is part of the confusion.

 6 Are electric resistance furnaces

 7 included as air handlers in that document?

 8 MR. JASINSKI: (Nodded yes.)

 9 MR. RANFONE: Okay. So, the --

09:58:08 10 MR. BROOKMAN: Wait. Let's get an

 11 answer.

 12 Were they?

 13 MR. JASINSKI: Yes.

 14 MR. BROOKMAN: Yes.

09:58:15 15 MR. RANFONE: Okay. So, they would be

 16 covered under 823.

 17 How about the fans and motors from a

 18 fossil fuel? Were they covered in 823?

 19 MR. JASINSKI: (Nodded yes.)

09:58:26 20 MR. RANFONE: So, that's all-inclusive

 21 then. And how do they distinguish the difference

 22 between an electric resistant furnace and an air

 23 handler that has electric resistance air handler?
 59

 1 MR. BROOKMAN: Let's let the Department

 2 respond.

 3 MR. JASINSKI: I don't know that there's

 4 any distinction in CSA C823.

09:58:43 5 Diane, you can correct me if I'm wrong.

 6 DR. JAKOBS: No, it -- For the test, we

 7 only operate the blower, so it doesn't matter where

 8 the heat or cooling is coming from. The only thing

 9 that's ac-, you know, activated during the test is

09:58:54 10 the blower.

 11 MR. KHAN: I'll, I'll just add I think

 12 it's important to make, I think it's important to

 13 understand that, -- And, again, Diane, you can

 14 correct me if I'm wrong. -- that CSA C823 has made

09:59:09 15 it very clear that they're trying to, they're

 16 setting this performance standard separate from any

 17 -- It's entirely about the performance of moving

 18 air.

 19 MR. RANFONE: Right. This is Jim

09:59:20 20 Ranfone.

 21 And I think we get back to the original

 22 statements about the scope of this work. I thought

 23 that's exactly what DOE was saying was covered by
 60

 1 legislation.

 2 I think we're maybe, you know, going off

 3 from, from different mechanisms here, or different

 4 methods, and I think we focus back on what DOE's

09:59:39 5 interpretation of the law is, that all these

 6 products are covered.

 7 Now, we may find out that that's not

 8 true, but, I mean, at this point in time, 823

 9 covers all that, and they're only looking at the

09:59:50 10 blower components, whether it's an air handler,

 11 furnace, gas, electric, or oil. That would seem to

 12 me to be the scope of the work that DOE's looking

 13 at, or what the legislation is intended.

 14 Again, I don't -- I'm not an expert on

10:00:03 15 what the legislation says, but that would keep

 16 everybody on the same footing.

 17 MR. BROOKMAN: Okay. Do you want to

 18 respond?

 19 MR. JASINSKI: I think Ashley --

10:00:11 20 MR. BROOKMAN: Ashley does?

 21 MS. ARMSTRONG: I don't want to respond

 22 to that one, but I want to go back to Frank's point

 23 about whether DOE could use something in the
 61

 1 existing test procedures.

 2 And I'm assuming you're, you're going

 3 down the road of the BE, like the blower

 4 electricity. That, that, that's coming in about

10:00:28 5 eight slides.

 6 And DOE could do something like that.

 7 They could use components for CSA.

 8 They could use something in between.

 9 So, if anyone has, you know, recommendations for

10:00:38 10 something other than these two alternatives, this

 11 was just a preliminary review. We're obviously at

 12 this point --

 13 MR. BROOKMAN: Yeah. Do you want to get

 14 them now, or in eight slides?

10:00:46 15 MS. ARMSTRONG: No, in, in a couple

 16 slides we'll talk about BE and a couple of

 17 modifications that temporarily could be.

 18 MR. BROOKMAN: Okay.

 19 I saw Greg first, and then back to

10:00:54 20 Diane.

 21 MR. WAGNER: Greg Wagner again.

 22 The goal is to achieve maximum energy

 23 efficiency. One of the problems with the C823
 62

 1 proposed Standard is that it separates the function

 2 from the performance of the fan.

 3 So, therefore, to a consumer, how would

 4 you know what you're getting for your use of

10:01:18 5 electricity? You don't know how much cooling or

 6 heating capacity go along with that electrical

 7 consumption.

 8 The separation of those two functions

 9 will not necessarily result in the maximum energy

10:01:33 10 savings.

 11 MR. BROOKMAN: Diane.

 12 DR. JAKOBS: I just wanted to say that

 13 in Canada they have another mode of operation

 14 that's common, and for -- They, they tighten their

10:01:47 15 homes and they need ventilation of air. And

 16 they'll duct a duct to the outside, and they'll use

 17 a continuous fan mode.

 18 So, really, in Canada they'll use a

 19 furnace where the only thing they'll run it in

10:02:00 20 continuous fan, so the only thing operating is that

 21 fan motor. And the -- You know, you're, you're not

 22 generating heat.

 23 So, that's less common here. And so, so
 63

 1 from their point of view, you know, it's a valid

 2 mode of operation.

 3 MR. BROOKMAN: Okay. I think I've got

 4 that.

10:02:21 5 Okay. Are we ready to move on?

 6 Yes, Jim.

 7 MR. BACCHUS: Jamy.

 8 MR. BROOKMAN: Jamy.

 9 MR. BACCHUS: Jamy Bacchus.

10:02:29 10 I'll just tack onto Diane's comment that

 11 in newer homes, sealed homes where you have better

 12 control of infiltration, we're seeing more of that

 13 latter case where you're running the fan in just

 14 continuous mode rather than cycling it on and off.

10:02:48 15 MR. BROOKMAN: Okay, thank you.

 16 MR. JASINSKI: Okay, thank you. Now

 17 we'll get into a little bit more detail about the

 18 methodology that CSA C823 specifies.

 19 The initial steps of CSA C823 specify

10:03:04 20 measurements of air flow and electricity

 21 consumption at various external static pressures

 22 for each available fan motor speed control setting.

 23 Once these measurements have been taken, CSA then
 64

 1 specifies to plot external static, and the results

 2 are performance curves as shown here.

 3 Note that there's one for each

 4 speed-control setting. As has been mentioned, I

10:03:27 5 think, DOE believes that this in, to some extent is

 6 already in, being used by manufacturers, by furnace

 7 fan manufacturers.

 8 At this time DOE seeks comment on the

 9 methodology specified by CSA C823 to develop

10:03:43 10 performance curves, as well as some of the

 11 operating criteria used to take those measurement.

 12 MR. BROOKMAN: You can see the comment

 13 boxes listed there.

 14 Diane.

10:03:51 15 DR. JAKOBS: Yeah, I agree that, that we

 16 do follow that methodology. There are -- We all

 17 have it in our specifications to give to the

 18 installer, give information to the installer.

 19 We, we typically do it on the same

10:04:08 20 increment of points. There is one difference:

 21 that PSC motors, at least for Rheem, generally go

 22 up to seven-tenths of an inch static, and some of

 23 the ECM motors, we've, we've gone further and given
 65

 1 information up to an inch of static.

 2 So, there's, there's differences on --

 3 We still recommend that you design the ductwork in

 4 the same way, but we recognize that people, the ECM

10:04:41 5 motor will speed up, and if you have restricted

 6 ductwork you can get the air flow. And our

 7 customers have asked for information, and we

 8 provide it.

 9 So, there's a little bit of variation

10:04:52 10 there, but performing the, or providing the

 11 performance curve, that part's pretty

 12 straight-forward.

 13 MR. BROOKMAN: Jim?

 14 MR. VerSHAW: Yeah. We -- Performance

10:05:04 15 curve generation is fine.

 16 The, the number of points that, that CSA

 17 -- They're requiring increments of .1 inches of

 18 water power, and that's, that's twice as many as

 19 you need. You can go every two-tenths and be just

10:05:21 20 fine.

 21 And we've been doing that -- Well, 40

 22 years ago my dad actually got a stoker, and he was

 23 pleased. So, -- But you don't get anomalies that
 66

 1 small amount.

 2 Look at an ECM motor where it, there

 3 will be ability to go with three different

 4 air-conditioning capacities, and each of those has

10:05:42 5 three different air flows, 300, 400, 350 CFM per

 6 ton, plus you've got heating. And if it's a

 7 multiple-modulating or two-speed, you've got a lot

 8 of points.

 9 And so you've got to make sure that, you

10:05:56 10 know, you're not overly burdening. We take it

 11 every two-tenths and we have data that shows all of

 12 our operation.

 13 And I don't think that adding, adding

 14 double number of points I don't think is going to

10:06:07 15 add any, any value at all.

 16 MR. BROOKMAN: Two-tenths, two-tenths is

 17 based on your, your practical company experience?

 18 MR. VerSHAW: Right.

 19 MR. BROOKMAN: Thank you. Actually, --

10:06:19 20 MR. KHAN: Mohammed KHAN.

 21 DOE appreciates the recommendation on

 22 the interval, but for the Record, I was wondering

 23 if we could hear from you maybe what you think that
 67

 1 range ought to be, as well.

 2 MR. BROOKMAN: Jim.

 3 MR. VerSHAW: We, we go -- We start at

 4 .1 inches static pressure and we go to whatever

10:06:38 5 the, the system will provide. Now, on, on a PSC

 6 motor, eight-tenths, and depending on the system,

 7 on an ECM motor it's around an inch; not too much

 8 over that because the power just falls off in,

 9 in --

10:06:52 10 MR. BROOKMAN: Diane, do you want to

 11 comment?

 12 DR. JAKOBS: Yeah. One of the -- We did

 13 some examples for C823, and we're fitting quadratic

 14 curves to do it.

10:07:03 15 So, theoretically you only need three

 16 points. The important part is to get the end

 17 point, the high point, the low point, and one in

 18 the middle so, so you're not extrapolating. But,

 19 --.

10:07:11 20 MR. BROOKMAN: Bryan, you want in here,

 21 Bryan?

 22 MR. ROCKY: Yeah, Bryan Rocky.

 23 To kind of counterpoint Jim as far as
 68

 1 the, the, the system curve performance, there is a

 2 little bit of an issue again, as our view is that

 3 C-, CSA C823 is very complex. And based on the

 4 control systems that are used with the furnace

10:07:33 5 boards, especially as you get into modulating

 6 furnaces, you don't have necessarily three or four

 7 operating speed points.

 8 Actually, in, in our designs you can

 9 have up to 100 individual calculated blower curves

10:07:46 10 following this procedure. And that's a significant

 11 difference because of the way the furnace operates.

 12 For PSE motors it's a three- or

 13 four-speed, or two-speed. No problem at all.

 14 You get in with someone with the

10:08:01 15 standard OCM, it gets more complex. And you get

 16 into the modulating furnaces, this, this approach

 17 starts to fall down really quickly just from the

 18 complexity.

 19 From the size of the increments, I think

10:08:16 20 I agree with Diane and Jim as well. You know,

 21 two-tenths should be very adequate for the

 22 application, and no more; with a maximum of no more

 23 than one itch for a residential application at any,
 69

 1 by any means, as far as the using, using them in

 2 this procedure.

 3 MR. BROOKMAN: Okay, thank you.

 4 Looking to the comment boxes, please do

10:08:38 5 so. Please look at Slide 25 and make sure we've

 6 covered it sufficiently.

 7 Anything else?

 8 MR. JASINSKI: Doug, I'd just like to

 9 add.

10:08:49 10 MR. BROOKMAN: Please do.

 11 MR. JASINSKI: Speaking to something

 12 that Jim VerShaw said about anomalies, I think

 13 that's something very important for our

 14 stabilization static pressure, electricity

10:08:59 15 consumption, and air flow.

 16 Does anyone that you know performs these

 17 tests have any input on what adequate stabilization

 18 criteria for those measurements should be so that

 19 if you are only taking two or three points, that

10:09:12 20 you can have, that you can be very confident in

 21 those points?

 22 MR. BROOKMAN: Jim?

 23 MR. VerSHAW: Off the top of my head I
 70

 1 don't remember what it is, but there is, there is,

 2 and it's not 45 minutes. I mean it steadies out

 3 reasonably quickly.

 4 MR. JASINSKI: Okay. I'll mention --

10:09:31 5 MR. VerSHAW: I'll put it in written

 6 comments. I'll --

 7 MR. BROOKMAN: Yeah.

 8 I see both Greg and Diane ready to

 9 respond.

10:09:33 10 MR. WAGNER: I was going to say,

 11 typically air flow measurements are made in, like,

 12 a-half minute to minute window, taking 30

 13 measurements every so often and averaging them.

 14 Because of fluctuations in pressure you have to do

10:09:45 15 a time average, or sampling average, I should say.

 16 DR. JAKOBS: Yeah.

 17 MR. BROOKMAN: Diane.

 18 DR. JAKOBS: We've done -- We have, we

 19 have some testing centers that are computer

10:09:57 20 operated and some manually operated. And I think

 21 we wait two inches for the one that no one is

 22 watching, to be sure.

 23 MS. ARMSTRONG: Two, two minutes?
 71

 1 DR. JAKOBS: Two, two minutes. Thank

 2 you.

 3 MR. BROOKMAN: Thank you.

 4 DR. JAKOBS: Yes. And so if, if a

10:10:12 5 person is watching it and can see, you know, the,

 6 level it out, they can go faster.

 7 MR. JASINSKI: And how much are those

 8 measurements allowed to vary in two minutes? Do

 9 you know?

10:10:22 10 DR. JAKOBS: I don't remember exactly.

 11 MR. JASINSKI: Is it based on a

 12 percentage or on, you know, a, a, a static pressure

 13 tolerance perhaps?

 14 DR. JAKOBS: Well, they're watching CFM

10:10:33 15 to find out.

 16 MR. JASINSKI: Well, those are the

 17 things we're looking for in the written comments.

 18 MR. BROOKMAN: In your written comments.

 19 Okay.

10:10:40 20 That would be helpful for the

 21 Department. Anything else on Item 9, 10, and 11?

 22 MR. JASINSKI: I think, I think it's

 23 important to also focus on 11. I know that I think
 72

 1 we had some -- The, the gentleman from Johnson

 2 Controls mentioned that ECM motors have, when, when

 3 the manufacturer of the furnace fan gets them, the,

 4 the possibility of over 100 speeds.

10:11:01 5 Now, once, once these motors can be

 6 implemented into furnace fan products, do they

 7 still have 100 speeds, or, or --

 8 MR. ROCKY: Let me, let me clarify.

 9 Bryan Rocky.

10:11:14 10 MR. BROOKMAN: Sure.

 11 MR. ROCKY: In our particular design,

 12 we, our modulating furnace actually has 100 stages

 13 of modulation of heat. And in every case of that

 14 modulating and heat input, we are adjusting the fan

10:11:28 15 curve --

 16 MR. BROOKMAN: Okay.

 17 MR. ROCKY: -- to provide optimal

 18 performance.

 19 Now, the other manufacturers who do

10:11:35 20 modulating furnaces do something similar, but not

 21 necessarily to that extent. But, for our product,

 22 that is defined as the way the system operates, and

 23 so in calculating the furnace operating point you
 73

 1 are going to have to calculate, we are going to

 2 have to calculate 100 operating curves for blower

 3 panel performance.

 4 DR. JAKOBS: Actually, for, say, if it

10:11:55 5 -- The way C823 is, it would only be the maximum

 6 and minimum for heating mode, and it would --

 7 MR. BROOKMAN: Thanks, Diane. Yeah.

 8 DR. JAKOBS: Cooling, if you had multi

 9 speeds, it's the maximum/minimum.

10:12:08 10 MR. BROOKMAN: Okay. Okay.

 11 MR. JASINSKI: Thank you.

 12 MR. BROOKMAN: Yes?

 13 MR. JASINSKI: Um-hum.

 14 MR. BROOKMAN: Okay.

10:12:14 15 MR. JASINSKI: Next after development of

 16 the performance curves, CSA C823 specifies

 17 derivation of the reference system load curve. The

 18 reference system load curve determines performance

 19 at common operating conditions to allow for

10:12:28 20 comparison across products.

 21 It's based on the governing equation Ps

 22 equals K time Q-squared, shown, as well as

 23 specified reference system operating criteria. The
 74

 1 governing equation describes the external static

 2 pressure piece of S as the function of the physical

 3 characteristic of the system, K, and air flow,

 4 Q-squared.

10:12:47 5 Reference system operating is the

 6 criteria specified in CSA C823, the achievement of

 7 125 or equivalent, half-inch water column in the

 8 default heat speed setting. Uses these operating

 9 criteria, the specified operating criteria, and the

10:13:04 10 air-flow measurements that were used in developing

 11 the performance curves.

 12 A value for K can be derived, and once

 13 the value for K is known, the reference system load

 14 curve can be plotted as shown.

10:13:15 15 (Whereupon, at 10:13 a.m. ET, Msrs. Burt

 16 and Bacchus conferred, out of the hearing of others

 17 and off the Record, during which the following

 18 occurred:)

 19 MR. JASINSKI: Diana has a question.

10:13:22 20 DR. JAKOBS: One of the, the issues with

 21 this is in Canada it's a good assumption that the

 22 ductwork was designed based on the heating flow of

 23 the heating design. That -- And that's not such a
 75

 1 good assumption here.

 2 It might be a good assumption in Chicago

 3 or Minneapolis, but certainly not in Arkansas where

 4 I live. And, actually, you know, my first

10:13:52 5 impression would be that ductwork would be designed

 6 for the cooling mode.

 7 That -- But, what we, we would -- You'd

 8 do a load calculation and you would determine what

 9 your cooling capacity was, what your heating

10:14:05 10 capacity was, what the associated CFM was, and

 11 whichever one was the highest, that was, if you

 12 were starting from scratch, that's what you would

 13 design your ductwork for.

 14 So, the problem with this is that you,

10:14:18 15 we, we, the, the only point that is determined is

 16 on the heating curve, and then the rating curves

 17 are just kind of where you end up for the cooling.

 18 And what happened in the examples that I ran was

 19 that we ended up at statics that were beyond the

10:14:38 20 manufacturer's recommended operation of the

 21 equipment.

 22 And we had lots of arguments about what

 23 was the ductwork, you know, when you go out and you
 76

 1 test it. There's a lot of restrictive ductwork out

 2 in the world, and, or in North America, but it,

 3 it's a matter of: What, what are you trying to do?

 4 Are you trying to describe efficiency

10:15:05 5 when people don't follow the rules and don't have a

 6 good installation? Or, you know, are you trying to

 7 look at what's the efficiency when, when it's a

 8 good installation?

 9 So, the half-inch, that would not be a

10:15:21 10 good installation.

 11 (Whereupon, at 10:15 a.m. ET, Mr. Rocky

 12 and Mr. Fowble conferred, out of the hearing of

 13 others and off the Record, during which the

 14 following occurred:)

10:15:24 15 DR. JAKOBS: We recommend two-tenths of

 16 an inch for the static.

 17 MR. BROOKMAN: Knowing you're also

 18 implicitly recommending a default for the

 19 development, aren't you?

10:15:36 20 DR. JAKOBS: Yeah.

 21 MR. BROOKMAN: So, state it plainly.

 22 DR. JAKOBS: Oh, am I?

 23 MR. BROOKMAN: Yes.
 77

 1 DR. JAKOBS: Yeah. Yeah.

 2 If the Department would like to know

 3 what I thought, yes. And, actually, for C823,

 4 since the, the, the Committee has gone on and we

10:15:52 5 decided to use two static points, we, we actually

 6 did .3 and .6.

 7 And we are going to show data from a

 8 recommended installation and the poor installation.

 9 So, we want to show people that it matters, you

10:16:07 10 know, and what, what is the difference in you,

 11 based on your installation.

 12 So, that, that's a real issue. People

 13 can -- They're taking our wonderful equipment that

 14 we designed, and they're misusing it.

10:16:20 15 And they -- It's, costs them money and

 16 energy.

 17 MR. BROOKMAN: Yeah. Got you.

 18 DR. JAKOBS: And, you know. So, okay.

 19 MR. WAGNER: I would also agree with

10:16:29 20 Diane on that point. Part of it, part of the

 21 recommendation is that you start codifying poor

 22 installations by recommending high static.

 23 That's, that's, that's not a good
 78

 1 direction to go. We should be going in the other

 2 direction to force, or to help people understand

 3 that they need to use good installations, good

 4 practices.

10:16:51 5 Second thing, -- And this really has to

 6 do with, really, Item 13, I guess it would be, the

 7 system load curve. The problem is not all systems

 8 are the same.

 9 AHRI reported recently back to the C823

10:17:05 10 Committee that, for example, in the cooling mode,

 11 that the CFM is between 400 and 290 CFM per ton.

 12 That's a one-and-a-half times swing.

 13 If you use that squared function curve,

 14 you get significant increase in the amount of

10:17:21 15 pressure required, and up to three and a-half times

 16 the energy required, depending upon which end of

 17 that CFM-per-ton scale you're on. So, depending

 18 upon what the system is, you may have totally

 19 different ratings that would mislead the customer

10:17:36 20 as far as how they would use that product.

 21 MR. BROOKMAN: Let's hear from Jim

 22 first, and then --

 23 MR. VerSHAW: Yeah, Jim VerShaw.
 79

 1 The heating default doesn't match with

 2 any of the other conditions that we have to test

 3 furnaces under. And then it would inherently,

 4 because almost all furnaces that are installed with

10:17:58 5 lower, or lower air flow or heating than cooling

 6 would inherently be above what we test air

 7 conditioners at.

 8 And seems like if you're going to have

 9 it, seems you would not create different test

10:18:13 10 points.

 11 MR. BROOKMAN: What would you suggest?

 12 MR. VerSHAW: Well, I'd like to see us

 13 match up with test performances for furnaces, which

 14 manufacturers watch static pressures they should be

10:18:22 15 operated on if you retest. And that would be the

 16 condition that you would, you would run the blower

 17 at.

 18 MR. BROOKMAN: Okay. Charlie?

 19 MR. VerSHAW: And, in fact, take BE,

10:18:30 20 which I think is appropriate way to do this, and,

 21 and have a watt, a watt, a watt number rather than

 22 a more complicated thing.

 23 MR. BROOKMAN: Charlie Stephens.
 80

 1 MR. STEPHENS: Charlie Stephens.

 2 We -- I've personally done quite a bit

 3 of testing of installed systems out there, most

 4 with air conditioning, but some without it. As I

10:18:51 5 recall -- I don't have the data with me, but I

 6 don't think we found any systems that were

 7 operating under .4 inches.

 8 The coil in an air-condition system adds

 9 about .15 to .2 just all by itself, external to the

10:19:06 10 furnace. So, most -- The range we found most often

 11 was .4 to .8.

 12 And a lot of them did cluster right

 13 around .5. So, I don't find that, at least out

 14 where I live, I don't see that a .5 is an

10:19:21 15 unreasonable number to be using for this sort of

 16 thing.

 17 That's pretty much a weighted average of

 18 what we found. I find it in the field.

 19 MR. BROOKMAN: When you say out where

10:19:29 20 you live, are you talking about Pacific Northwest,

 21 or all --

 22 MR. STEPHENS: Pacific Northwest and,

 23 and a little bit of data in California that we've
 81

 1 been doing.

 2 MR. BROOKMAN: Okay, let's hear from

 3 Molly.

 4 MS. TROMBLEY-McCANN: Molly

10:19:37 5 Trombley-McCann.

 6 I do want to point out that I agree with

 7 Jim. That is, it doesn't make a whole lot of sense

 8 to have a different external static test point for

 9 a furnace fan and then a furnace fan operating with

10:19:51 10 a furnace.

 11 It seems a little bit of a disconnect.

 12 However, to Charlie's point, I think that a higher

 13 level than what is currently used in the furnace

 14 test procedure is more appropriate.

10:20:00 15 And while I do sympathize with the

 16 desire to not codify a bad duct design, the purpose

 17 of the Standard is to allow consumers to compare

 18 equipment as it will, will operate in their homes,

 19 and determine which is more efficient.

10:20:14 20 And if what we're seeing is that in

 21 actual operation there's high static, higher than

 22 what they're using in the test procedure, then that

 23 needs to be changed.
 82

 1 MR. BROOKMAN: Is it Cyril?

 2 MR. FOWBLE: Cyril.

 3 MR. BROOKMAN: Cyril, please.

 4 MR. FOWBLE: Cyril Fowble, Lennox

10:20:22 5 International.

 6 I disagree with that. The purpose of

 7 the Standards and the work we're doing, I think

 8 we're getting into the weeds -- Not the weeds, but

 9 a lot of detail here.

10:20:32 10 This is, to use an automobile mileage

 11 analogy here, specifically I don't mean to be

 12 comparing, but you're not going to get 97 or 96 or

 13 80 mpg in every engine in every car. Every engine

 14 depends on how they are each built and driven and a

10:20:46 15 lot of other things.

 16 I agree with Jim that maybe we should

 17 have a, you know, a common set, and if we're using

 18 Standard for heating, for example, saying we're

 19 going to be, to have .2 or 2 or 12, whatever the

10:21:00 20 numbers are to be matched up to a furnace here,

 21 because all of this system we're doing with this is

 22 getting us, you know, it's like we're providing

 23 data.
 83

 1 And you'll need about a million points

 2 for every single application in, for the consumer.

 3 And the purpose of the Standard is not necessarily

 4 to give, you know, rating points for all the

10:21:16 5 consumers, but to give them the ability to compare

 6 one model to another model, and, again, a specific

 7 set of conditions.

 8 MR. BROOKMAN: Greg, and then Diane.

 9 MR. WAGNER: To talk to -- What's your

10:21:29 10 name again? I apologize.

 11 MR. STEPHENS: Charlie Stephens.

 12 MR. BROOKMAN: Charlie.

 13 MR. WAGNER: Charlie. Said it enough

 14 times.

10:21:33 15 The, the issue of the higher static

 16 application --

 17 (Whereupon, at 10:21 a.m. ET, Ms.

 18 Trombley-McCann and Mr. Burt conferred, out of the

 19 hearing of others and off the Record, during which

10:21:36 20 the following occurred:)

 21 MR. WAGNER: -- is often due to

 22 oversizing of equipment. In the Canadian

 23 rulemaking process it was reported that on average
 84

 1 the typical furnace is 80 percent oversized in

 2 application.

 3 MR. BROOKMAN: Wow.

 4 MR. WAGNER: With that 80-percent

10:21:56 5 oversize, you take the numbers that these guys test

 6 their systems to -- We're just talking about the

 7 low static pressure. -- and it converts up, using

 8 that P equals K-Q-squared to get you to that .7, .8

 9 in the field.

10:22:11 10 Changing people's behavior is not going

 11 to happen through trying to do laws that regulate

 12 the electricity. It's got to happen through other

 13 mechanisms.

 14 So, just by rating it, you're not

10:22:22 15 necessarily going to help the consumer in that way.

 16 You're helping the consumer to say, "This is good

 17 practice. This is what I should be doing."

 18 And at the end of the day, that's what

 19 the DOE's telling us.

10:22:33 20 MR. BROOKMAN: Okay.

 21 Diane.

 22 DR. JAKOBS: I just wanted to say that,

 23 well, during the development of the Standard I
 85

 1 wanted to put some numbers to some of this. And I

 2 used some examples.

 3 Carrier had offered to be an example,

 4 but then a PSA motor. And I used, I used someone

10:22:53 5 else's that we had tested in our lab.

 6 And it was kind of innocent, but we

 7 usually have this second curve as our heating

 8 speed. And I used that, and then it was pointed

 9 out that that didn't make sense.

10:23:08 10 But, it completely changed with the

 11 intersection with the other curves. So, it --

 12 Someone could specify the heating curve that didn't

 13 really make sense, and control, you know, their

 14 rating points as it intersected the other curve.

10:23:24 15 So, this idea of it being realistic and,

 16 you know, is kind of like in the field and you get

 17 what you get. It, it might give more varied, and,

 18 and something that people could take advantage of.

 19 So, I think we would really prefer a

10:23:42 20 specific rating point.

 21 MR. BROOKMAN: Okay.

 22 DR. JAKOBS: You know. And part of all

 23 the calculations, I had to do curve fitting so I
 86

 1 could find the intersection of the lines.

 2 And it's just a lot of complexity that

 3 wasn't really beneficial, I don't think.

 4 MR. BROOKMAN: Jamy, let me hear from

10:24:00 5 Terry Small, and then I'll come back.

 6 MR. SMALL: Terry Small, Mortex.

 7 The consumer has a lot of choices in, in

 8 reality in what's installed, including the indoor

 9 air quality devices, et cetera. So, you can, like,

10:24:13 10 load up the static on the system, depending upon

 11 what the consumer's wanting in their system.

 12 I really agree with several other

 13 comments, that we want a basis to compare these

 14 products. And I'd like to point out that

10:24:30 15 three-tenths is used when testing a coil only in

 16 the cooling mode as an example of static in a

 17 system.

 18 So, I think something like three-tenths

 19 makes sense to me.

10:24:42 20 MR. BROOKMAN: Thank you.

 21 Jamy.

 22 MR. BACCHUS: Jamy Bacchus.

 23 I heard some comments made referring to
 87

 1 external static and to total static. Can we get

 2 confirmation that CSA C823, Section 89.2, is

 3 referring to total statics or external?

 4 MR. BROOKMAN: I believe it's external.

10:25:04 5 DR. JAKOBS: Yeah, it's external.

 6 MR. BROOKMAN: Yeah, I believe Diane

 7 says it's external, also.

 8 DR. JAKOBS: Yes. For everything.

 9 MR. BROOKMAN: Okay. Have we covered

10:25:13 10 this now?

 11 (Whereupon, no response was had.)

 12 MR. BROOKMAN: We're going to move on.

 13 MR. JASINSKI: Okay. I'd just like to

 14 maybe ask Diane a quick question.

10:25:18 15 I know you said something like

 16 two-tenths is the --

 17 DR. JAKOBS: That's what we're

 18 operating.

 19 MR. JASINSKI: Well, it might be more

10:25:31 20 appropriate in the United States to use the cooling

 21 as the criteria. Are you saying two-tenths for the

 22 cooling, or for the heating?

 23 DR. JAKOBS: No, I was talking about
 88

 1 two-tenths for cooling.

 2 MR. JASINSKI: For cooling?

 3 DR. JAKOBS: No.

 4 MR. JASINSKI: Sorry.

10:25:41 5 DR. JAKOBS: Two-tenths for heating is

 6 what I was talking about.

 7 MR. BROOKMAN: Yes, Molly.

 8 MR. TROMBLEY-McCANN: Molly

 9 Trombley-McCann.

10:25:45 10 I just wanted to clarify, because I

 11 think what I said earlier might be misinterpreted.

 12 I'm not arguing against a single rating point.

 13 My point was that the rating point

 14 should try to reflect as much as possible what most

10:25:59 15 customers will require for higher standards.

 16 MR. BROOKMAN: Yes. Diane first.

 17 DR. JAKOBS: Well, and the thing is, you

 18 get into all these details and you talk about this,

 19 and really there's just two classes of motors. And

10:26:11 20 it's only going to matter if you get an ECM motor

 21 or PSC motor.

 22 And the rest is just kind of -- Someone

 23 said we were lost in the trees or the bushes or
 89

 1 something. I don't know.

 2 But, you know, in the effort to be

 3 realistic, there's, there's so many variations that

 4 you have to account for before you can come up with

10:26:34 5 a number that I don't -- It's not helpful.

 6 MR. BROOKMAN: What Molly's trying to

 7 achieve is not doable, given the existing pieces

 8 that might fit together?

 9 DR. JAKOBS: No. No, I think what Molly

10:26:47 10 was saying, that we could just take a, a static

 11 point and that would be good for comparison, and it

 12 doesn't really matter if it's applicable in 85

 13 percent of homes in the United States, or if it's

 14 in the north or the south.

10:27:00 15 If you have an efficient motor, you'll,

 16 you'll, you'll use less electrical energy. And it

 17 may -- Maybe I'm misinterpreting what Molly said.

 18 MR. BROOKMAN: I'm trying to understand

 19 this myself.

10:27:13 20 Molly, please.

 21 MS. TROMBLEY-McCANN: So, I think we

 22 agree on the principle of a single rating point.

 23 If we have to pick a rating point, what I'm saying
 90

 1 is we should try as best as possible to make it

 2 reflective of what the majority of costumers are

 3 going to experience.

 4 I really -- There's no way to nail that

10:27:30 5 down, because there is a lot of variability. But,

 6 to the degree that we have information about what

 7 that point is, we should be using it.

 8 And the information that I'm seeing and

 9 hearing is that it's higher than .2.

10:27:39 10 MR. BROOKMAN: Diane, go ahead, and then

 11 Charlie.

 12 DR. JAKOBS: The thing is, about

 13 choosing higher, higher points, is we go up to

 14 seven-tenths in our equipment on our airflow charts

10:27:48 15 and then people want to know what, what is just

 16 beyond? And then we go up to one inch, and then

 17 people want to know what's -- You know, "I have

 18 this innovation. I want to go a little bit beyond

 19 that."

10:27:58 20 You know, "what happens then?" And, and

 21 in order to comply with, with what people want from

 22 the field, they want to use smaller diameter ducts,

 23 so, because they cost less.
 91

 1 And they want the air to blow and come

 2 out their register, so they want stronger motors.

 3 And as we give credibility to these points that are

 4 beyond where the equipment should be operating,

10:28:22 5 it's going to be part of the specifications for a

 6 new design that the blower has to provide this much

 7 air flow at these higher statics.

 8 And I think that's contrary to what

 9 we're trying to accomplish, and we'll use more

10:28:34 10 energy that way.

 11 MR. BROOKMAN: Got-cha.

 12 Charlie.

 13 MR. STEPHENS: Charlie Stephens.

 14 I just wanted to clarify what we were

10:28:42 15 doing out there, measuring all this stuff. In a

 16 lot of cases we were looking at what the real

 17 variations were from ECM motors.

 18 So, we went out there to find out how

 19 they were really operating, because we were finding

10:28:53 20 out that the savings were not what we expected.

 21 And the reason, the main reason they were not what

 22 we expected was because of external static in most

 23 cases.
 92

 1 If you could outlaw flex duct, and if

 2 you could outlaw these fans, outlaw the add-on

 3 filtration systems, which is also a lot of the

 4 reasons why a lot of these things are run 24/7, and

10:29:18 5 you could eliminate bad duct designs, then you

 6 could probably find a lot of systems operating down

 7 in the .3, .4 range.

 8 But, that's not what we found out there,

 9 and that's why we found that the statics from these

10:29:31 10 variable-speed motors were not what they were

 11 expected to be. They were working pretty darn hard

 12 because they were working against all of these

 13 factors most of the time.

 14 So, that's -- Whatever point we, we find

10:29:39 15 here should represent reality. And, quite frankly,

 16 reality was not entirely what we expected.

 17 But, when you think about it, I guess it

 18 makes sense.

 19 MR. BROOKMAN: I think we're working our

10:29:51 20 way towards a basket of solutions I think.

 21 Karim.

 22 DR. AMRANE: Just to follow up on this,

 23 on Charlie's point, yes, we understand that, you
 93

 1 know. And field installations have higher static.

 2 But, that's where the focus should be.

 3 Let's make, let's make those ducts right.

 4 Let's design them correctly. Let's

10:30:11 5 design the static, reduce the static pressure.

 6 We're always focusing ones on the

 7 equipment, but that's not where the focus should

 8 be. It should be on the duct itself.

 9 Let's work towards reducing static

10:30:24 10 pressure on the ducts.

 11 MR. BROOKMAN: All right.

 12 Greg.

 13 MR. WAGNER: And I wanted to emphasize

 14 that that extra static pressure is due to this

10:30:31 15 oversizing that often occurs, as much as anything

 16 else. And I'd like to see, you know, size

 17 comparison as to what's needed, you know, rather

 18 than just saying, "Hey, it had high static

 19 pressure," because, as I said, the study out of

10:30:43 20 the, Canada was that they were running typically

 21 80-percent oversize.

 22 MR. BROOKMAN: Okay.

 23 MR. WAGNER: In fact, the return time
 94

 1 above 50 percent of the capacity was in .05 percent

 2 of the time. So, it's, it's running, you know, at,

 3 at the, at that needed level of high demand very

 4 infrequently.

10:31:00 5 So, that extra energy that's being used

 6 is not, is not typical of how it operates, --

 7 MR. BROOKMAN: Okay.

 8 MR. WAGNER: -- or needs to operate.

 9 MR. BROOKMAN: Final comment, Diane?

10:31:09 10 DR. JAKOBS: (Nodded no.)

 11 MR. BROOKMAN: No?

 12 DR. JAKOBS: No, thank you.

 13 MR. BROOKMAN: Okay, we all set? Yeah?

 14 (Whereupon, no response was had.)

10:31:14 15 MR. BROOKMAN: Boy, we're really getting

 16 into some depth here, I think.

 17 MR. JASINSKI: Once the, the reference

 18 system load curve has been developed, CSA C823

 19 specifies that it be superimposed on the

10:31:25 20 performance curves as shown here. The

 21 intersections of the performance curves and the

 22 load curve are references to operating points.

 23 These operating points represent the
 95

 1 expected airflow performance of a system that meets

 2 the reference system criteria, and they are used to

 3 determine which electricity consumption

 4 measurements to use to calculate AECR.

10:31:44 5 (Whereupon, at 10:31 p.m. ET, Mr. Burt

 6 left the room, after which the following occurred:)

 7 MR. JASINSKI: At this time DOE seeks

 8 comments on here. And that's a, a pretty complex

 9 graph, so if people want me to go back so they can

10:32:06 10 look at it a little bit longer, I can do that.

 11 MR. BROOKMAN: Let's do go back. Yeah.

 12 Yes, Diane.

 13 DR. JAKOBS: All right, this is for a

 14 PSC motor, and one of the things that came up a lot

10:32:20 15 in the CSA C823 was that our rating points were too

 16 low. And, actually, for a PSC motor, that's a

 17 conservative assumption, because if you look at the

 18 higher static, you'll end up with a lower, lower

 19 CFM, and then you'll end up with less watts.

10:32:43 20 More, more watts.

 21 MR. WAGNER: Less watts. More CFM, less

 22 static, less watts.

 23 MR. JASINSKI: I'll just make a comment
 96

 1 that this is not based on any data. This is just a

 2 representation of how they are used in comparison

 3 with electrical.

 4 So, you know, it's not actually data.

10:33:02 5 It's just sort of a, of a walk-through of how the

 6 curve is superimposed.

 7 MR. BROOKMAN: Let's let Greg follow on.

 8 MR. WAGNER: I was going to say, those

 9 are representative -- They're not representative of

10:33:17 10 ECM blower time curves.

 11 MR. JASINSKI: Okay, thank you.

 12 MR. BROOKMAN: Is -- I thought you

 13 expected more than that in terms of comment.

 14 MR. JASINSKI: Well, I think I can -- I

10:33:31 15 think --

 16 MS. ARMSTRONG: I think we kind of hit

 17 it.

 18 MR. WAGNER: I was going to say, we've

 19 been commenting on this, but I'll go one more, in

10:33:36 20 that the CFM varies by the product's capacity,

 21 also. So, therefore, these rating points vary by

 22 manufacturer, and you'll get a variety of energy

 23 consumption to meet different heating and cooling
 97

 1 demand points.

 2 So, --

 3 MR. JASINSKI: I think I can ask.

 4 MR. WAGNER: -- it's not helpful to the

10:33:53 5 consumers to understand those differences, I guess.

 6 MR. JASINSKI: Sure. I think the

 7 important question here is:

 8 Should we identify operating points by

 9 the performance curves, regardless of what they

10:34:04 10 look like? Is that, is that an adequate --

 11 MR. WAGNER: I've --

 12 MR. VerSHAW: I guess the question is

 13 why, you know, if you've got, if you've got a

 14 furnace or an air handler, you want to go that way.

10:34:16 15 And you've got the blower in there, and you say you

 16 want a single rating point.

 17 Well, you've got one point. Why go

 18 through all this, all this?

 19 I mean, -- And if you get to the next,

10:34:26 20 next box that you're going to show in a minute, --

 21 MR. JASINSKI: Okay.

 22 MR. VerSHAW: -- it really gets

 23 complicated. And, boy, the consumer's really going
 98

 1 to get confused.

 2 How many people in this room have bought

 3 a furnace in their lifetime?

 4 (Whereupon, a response was had.)

10:34:39 5 MR. VerSHAW: Quite a few. You probably

 6 won't buy another one in your lifetime.

 7 So, -- And we're all fairly technical.

 8 Imagine, imagine most people out there trying to

 9 buy a furnace, and you give them all of this stuff.

10:34:52 10 I mean, give them, give them a number.

 11 This one's higher; this one's lower.

 12 MR. BROOKMAN: Jim, do the counterpoint.

 13 Why, why would the Department wish to do it this

 14 way?

10:35:03 15 MR. VerSHAW: That way?

 16 MR. BROOKMAN: Yeah.

 17 MR. VerSHAW: I don't know.

 18 MR. BROOKMAN: I thought there was some

 19 logic that --

10:35:09 20 DR. AMRANE: Because I believe the

 21 Department is looking at what CSC has done, which,

 22 again, may not be the right ways.

 23 MR. BROOKMAN: Got you. Well, I thought
 99

 1 that was a good question.

 2 MR. KHAN: It was good. Thank you.

 3 DR. JAKOBS: The people on the committee

 4 who proposed this, they were trying to be

10:35:27 5 realistic. They don't like the static points we

 6 have.

 7 They wanted realistic static points, and

 8 that, that's -- You get into all this --

 9 (Whereupon, at 10:35 a.m. ET, Mr. Burt

10:35:32 10 entered the room, after which the following

 11 occurred:)

 12 MR. JASINSKI: If you want to try to

 13 describe the energy consumption of a (sic) actual

 14 installation, this is, this is what you need in

10:35:44 15 order to do that.

 16 MR. BROOKMAN: Molly, you want in here?

 17 Yes, Molly.

 18 MS. TROMBLEY-McCANN: Molly

 19 Trombley-McCann.

10:35:51 20 Just in an attempt to answer your

 21 question, the, the issue is that, you know, a

 22 system doesn't operate at a single speed or a

 23 single load point for the entire year.
 100

 1 MR. BROOKMAN: Right.

 2 MS. TROMBLEY-McCANN: So, to do this is

 3 to try to capture the fact that the speed and load

 4 vary over the year. Now, whether or not that

10:36:08 5 exercise and complexity is worth it is a valid

 6 question, but that's why.

 7 MR. BROOKMAN: Yeah. Got it.

 8 Okay, Charlie.

 9 MR. STEPHENS: Charlie Stephens.

10:36:17 10 This, I don't know how this is going to

 11 come out when we finally do the written comments

 12 here, but I, we have some fundamental issues with,

 13 with just electricity consumption at all, and why

 14 you would, --

10:36:24 15 (Whereupon, at 10:35 a.m. ET, Mr. Stas

 16 left the room, after which the following occurred:)

 17 MR. STEPHENS: -- why you would rate

 18 this product using electricity consumption like a

 19 refrigerator, given that it doesn't operate like a

10:36:36 20 refrigerator.

 21 I mean if you come up with a number at

 22 one operating point, or, or multiple, even, the

 23 numbers you come up with will be only relevant to a
 101

 1 small subset of the consumers out there. They

 2 won't accurately reflect what the real consumer in

 3 Arkansas is going to see versus somebody in Montana

 4 using the same furnace.

10:36:57 5 (Whereupon, at 10:36 a.m. ET, Mr. Fowble

 6 and Mr. Rocky conferred, out of the hearing of

 7 others and off the Record, during which the

 8 following occurred:)

 9 MR. STEPHENS: And so I don't, I don't

10:37:01 10 know that it's useful to come up with electricity

 11 number. I think it might be useful to come up with

 12 CFM per watts, or watts per CFM, or whatever you

 13 want; a rate that rates efficiency in trying to

 14 move air.

10:37:17 15 But, trying to interpret that on into a

 16 number I don't think is useful.

 17 MR. BROOKMAN: Frank, I saw you. Let me

 18 go to Greg.

 19 He's going to comment on Charlie.

10:37:25 20 Go ahead.

 21 MR. WAGNER: Couple of things. First, a

 22 refrigerator is a stand-alone unit.

 23 There's two fans inside a refrigerator,
 102

 1 blowing air, plus compress, compressors. We don't

 2 rate those components, and that's a good analogy

 3 for what we're trying to do here.

 4 It's not looking at individual

10:37:46 5 components to try to figure out how to make a

 6 suboptimal total system by optimizing individual

 7 components. And I think you can get a better way

 8 of achieving that.

 9 By looking at that entire box as the

10:38:01 10 refrigerator analogy was a useful one, but the

 11 person in Arkansas has different hours than the

 12 person elsewhere, so their energy use are going to

 13 be totally different based upon their hours of use

 14 in any house.

10:38:13 15 (Whereupon, at 10:38 a.m. ET, Mr. Stas

 16 entered the room, after which the following

 17 occurred:)

 18 MR. WAGNER: So, the numbers are not

 19 going to apply to every single residence of every

10:38:21 20 single region of the country.

 21 MR. BROOKMAN: Okay.

 22 Frank.

 23 MR. STANONIK: We'll try and make this
 103

 1 quick. I haven't been involved greatly in the 283

 2 stuff, but in my other, some of my other

 3 experiences there, there seems to be a, a general

 4 approach in Canada that they want test procedures

10:38:38 5 that, in fact, do somehow estimate what is going to

 6 be consumed in the field.

 7 We would strongly urge DOE not to fall

 8 into that trap. That's not even a trap; that's a

 9 quagmire.

10:38:52 10 The, the, the, the thing that should be

 11 done, and what we have historically done is you

 12 have test procedures that give rating points that

 13 establish relative merits of equipment.

 14 In this particular case, this particular

10:39:05 15 case, well, ultimately what's going to come out of

 16 this is a Regulation that's going to ask

 17 manufacturers to develop, at least design products

 18 that also have the potential to use less

 19 electricity to move air around, okay?

10:39:21 20 But, but the other -- You know, the

 21 significant factor in the field is the ducting.

 22 And the size of that is, the manufacturers have no

 23 control over that.
 104

 1 To write a test procedure that's going

 2 to ask them to try and somehow address and, and,

 3 and anticipate if, the variations and, in, in what

 4 actually is out there and somehow design for all of

10:39:43 5 that, and, and then at the end of the day run these

 6 tests, -- and keep in mind, these furnaces, I mean,

 7 not to downplay, but we're only talking about the

 8 electrical consumption of the furnace.

 9 The much bigger consumption is the

10:39:57 10 fossil fuel, okay? So, we've got to keep this in

 11 perspective.

 12 But, this is -- It is -- I don't know

 13 how to put it, but, but to start down the path of

 14 trying to write a test procedure that's going to

10:40:12 15 predict what this appliance is going to do in my

 16 house or your house, or anybody's house, is, is

 17 just wrong.

 18 It, it, it will not benefit anyone.

 19 MR. BROOKMAN: Bryan, you want --

10:40:23 20 MR. ROCKY: Yeah. Frank just actually

 21 said, stated much better what I was going to state,

 22 some of the comments.

 23 But, to come back to Charlie's
 105

 1 viewpoint, if you were to take one of our furnaces

 2 or air handlers in the Pacific Northwest, and you

 3 had the one neighbor that lived in a manufactured

 4 housing unit, and next to the neighbor that lived

10:40:47 5 in a modular home, that, next to the neighbor that

 6 lived in a hundred-year-old home that was not built

 7 for air conditioning, versus the guy who happens to

 8 have a brand-new house, this approach can give me

 9 four different, very different results because just

10:40:58 10 of the application of the same furnace or the same

 11 air handler, regardless of what Greg was talking

 12 about of oversizing factors; just from how the

 13 whole thing was put together.

 14 And my test point is not going to cover

10:41:12 15 those differences. Not under this approach.

 16 At least I don't, we don't believe that.

 17 MR. BROOKMAN: Okay. Have we covered

 18 this sufficiently?

 19 (Whereupon, no response was had.)

10:41:21 20 MR. BROOKMAN: I think so. Okay.

 21 MR. JASINSKI: Shown here is the

 22 equation for AECR. Again, it's a time-weighted sum

 23 of the electricity consumption measured in each
 106

 1 speed control setting's operating point.

 2 So, first term of the equation, AHeatH,

 3 for example, is the annual heating hours. This is

 4 the number of heating hours in a year that the

10:41:45 5 furnace fan product per-, per-, spends performing

 6 the heating function in the default heat speed

 7 control system.

 8 The next term, ECh, is the electricity

 9 consumed by the furnace fan while the furnace fan

10:41:59 10 performs the same function in the same

 11 speed-control setting. This is continued to

 12 account for all functions of the furnace fan,

 13 including reduced heating, cooling, circulation,

 14 and standby.

10:42:12 15 And the end result, of course, is the

 16 AECR, which is the annual, the total annual ener-,

 17 electricity consumed by the furnace fan.

 18 At this time DOE seeks any comments on

 19 the AECR equation, as well as the methodology that

10:42:28 20 is used in CSA C823, or should be used to calculate

 21 those annual hourly multipliers.

 22 MR. BROOKMAN: Jim.

 23 MR. VerSHAW: I agree with Charlie that
 107

 1 there, you shouldn't be doing annual calculations.

 2 Not only does it include air-conditioning costs of,

 3 of energy, which is already part of another,

 4 another descriptor, but it, it, it, it -- You need

10:42:58 5 to have a, a one-to-one comparison of CFM per watt

 6 or total watts for a given static point, because,

 7 you know, whether or not you have air conditioning

 8 or not, the house will exchange your static.

 9 Sun load, what part of the country it's

10:43:13 10 in, how old your house is, and all those things

 11 vary the operating, and you wouldn't be able to

 12 give a number that would make any sense.

 13 MR. BROOKMAN: Diane, do you want to

 14 follow on?

10:43:23 15 DR. JAKOBS: Well, just kind of the

 16 details of the hours; that in Canada, they did a

 17 study of commercial loading, so when they talk

 18 about "annual hours," it's compressed. So, they

 19 don't talk about cycling.

10:43:38 20 We talk about our heating hours, and

 21 then we apply a (sic) oversized factor and a

 22 cycling steam, and then we come up with a real

 23 number of hours. This is already supposed to
 108

 1 include that, so when they talk about "heating

 2 hours," it's continuous heating hours.

 3 And I, I agree with Jim. I mean, I was

 4 part of this, but I don't see how anybody would use

10:44:05 5 it.

 6 So, -- .

 7 MR. BROOKMAN: Okay. Okay.

 8 MR. JASINSKI: Thank you. Now we'll get

 9 on to the second approach, which is to use the BE

10:44:18 10 measurement specified in the DOE test procedure for

 11 residential furnaces.

 12 The purpose of this approach is to use

 13 metric, a metric and methods that are used in

 14 existing DOE test procedures to minimize the burden

10:44:33 15 on manufacturers for tests and rating their

 16 products.

 17 If necessary, the methodology to do so

 18 may include additional assumptions, assumptions and

 19 calculations to overcome some of the limitations of

10:44:45 20 a BE-based rating, which we'll go into in this next

 21 slide. Also listed here is the Standard that's

 22 referenced in the DOE test procedure incorporated

 23 by reference in ANSI/ASHRAE Standard 103.
 109

 1 DR. JAKOBS: I have a question.

 2 MR. BROOKMAN: Diane, go ahead.

 3 DR. JAKOBS: We already published EAE.

 4 Why, why did you pick BE?

10:45:08 5 I mean, that's something that's part of

 6 the test, testing, something we measure, but EAE is

 7 already available.

 8 MR. BROOKMAN: That is -- You think

 9 that's equivalent to BE?

10:45:21 10 DR. JAKOBS: Yeah. It has a few things

 11 thrown in there, but it essentially is the blower

 12 one.

 13 MR. BROOKMAN: That's Lane.

 14 MR. BURT: I just wanted to ask if you

10:45:30 15 could give an explanation of that.

 16 DR. JAKOBS: It includes the user fan

 17 and the control. Is that, is it --

 18 MR. BURT: Okay. So, it's the three?

 19 DR. JAKOBS: So, EAE includes all the

10:45:43 20 electrostatic components?

 21 MR. JASINSKI: Right. So, as mentioned

 22 early, during the scope-of-coverage discussion,

 23 the, the inducer fan system was excluded from the
 110

 1 rulemaking, and it's my understanding that EAE is

 2 calculated with that, uses the BE measure, as well

 3 as the electricity consumption of the inducer fan

 4 motor system.

10:46:05 5 So, I think that this is just, this is

 6 just a portion of the measurements used to

 7 calculate EAE.

 8 MR. BROOKMAN: So, you need to

 9 characterize it differently. Go ahead.

10:46:15 10 DR. JAKOBS: Well, EAE is another

 11 attempt at yearly consumption, but B sub-, BE is

 12 just a steady state.

 13 MR. KHAN: Correct.

 14 MS. ARMSTRONG: Correct.

10:46:29 15 MR. BROOKMAN: Keep going, Sam.

 16 MR. JASINSKI: Okay. As mentioned, BE,

 17 there are some limitations that may need to be

 18 taken into consideration if necessary.

 19 The first one listed here, the BE

10:46:39 20 measurement is only specified for residential

 21 furnaces, not the other furnaces and products

 22 listed earlier. Another limitation is that BE is

 23 only measurable on a residential furnace, period,
 111

 1 the heating function.

 2 This is while the burner is on, and does

 3 not account for electricity consumed by other

 4 functions such as circulation. Also, BE is only

10:47:04 5 measured at minimal external static pressures for

 6 residential furnaces, and in only one or two

 7 speed-control settings.

 8 So, this would exclude electricity

 9 consumed at other typical operating conditions,

10:47:17 10 under other typical operating conditions as well as

 11 other available speed-control settings. Lastly, BE

 12 is a power measurement taken in watts, and should

 13 DOE decide to use an annualized metric, additional

 14 calculations would be necessary to convert this

10:47:34 15 into an annualized metric in kilowatt hours.

 16 At this time DOE seeks comment on the

 17 merits of using a BE-based rating, as well as

 18 whether or not and how you feel it can use methods

 19 to overcome the limitations listed.

10:47:48 20 MR. BROOKMAN: Diane.

 21 DR. JAKOBS: One of the issues of

 22 looking at the fan by itself is that we're in the,

 23 we're trying to transfer heat, and turbulent flow
 112

 1 is good for heat transfer. It burns watts.

 2 But, what we're really trying to, to do

 3 is get the heat out of the gas, the combusting gas

 4 or whatever the fuel gas. And if we have turbulent

10:48:14 5 flow, we can make it a more compact heat exchanger.

 6 We can get more heat for the natural gas

 7 that we're burning, and maybe we're using a few

 8 more watts. So, if you looked at a condensing

 9 furnace versus as noncondensing furnace there's

10:48:30 10 more stuff packed into the knot, into the

 11 condensing furnace.

 12 You're going to get higher furnace fan

 13 watts than for the condensing fan. No, I'm mixing

 14 it up.

10:48:44 15 But, anyway, I think you know what I'm

 16 trying to say; that a higher-efficiency furnace,

 17 because we have more heat exchanger in there, we're

 18 blowing air, you know, past a lot more stuff, we're

 19 going to burn more electric, we're going to use

10:48:58 20 more electrical energy, but overall we're saving

 21 energy.

 22 MR. BROOKMAN: Got you.

 23 Jim?
 113

 1 MR. VerSHAW: Jim VerShaw.

 2 I think if you go back to the four

 3 points on, on the previous slide, number one, first

 4 point would be we ought to be talking about

10:49:13 5 furnaces only here, --

 6 (Whereupon, at 10:49 a.m. ET, Dr. Amrane

 7 left the room, after which the following occurred:)

 8 MR. VerSHAW: -- and makes that, then, a

 9 moot point.

10:49:18 10 The second one, we only ought to be

 11 talking about the heating force of, of a furnace,

 12 so that, that makes that go away. Again, if you're

 13 looking at, at a descriptor like BE, which is a,

 14 was a certain amount of power and certain

10:49:34 15 condition, we could argue -- It's been argued about

 16 what static point that is.

 17 Well, okay. If you don't, you change

 18 the static point, or you keep what it is, it, you

 19 still, you still have a number and, and it gives

10:49:44 20 you a, a, a, a, an indicator where that's going to

 21 be.

 22 (Whereupon, at 10:49 a.m. ET, Dr. Amrane

 23 entered the room, after which the following
 114

 1 occurred:)

 2 MR. VerSHAW: And I'm not sure why.

 3 Again, we've talked about not doing the annual

 4 calculations because the broad variations of things

10:49:56 5 that, that happened.

 6 So, therefore, a descriptor like watts

 7 or OCFM per watt, or something makes more sense to

 8 me on this.

 9 MR. BROOKMAN: Okay, thanks. And I

10:50:05 10 appreciate you referring back to the bulleted

 11 points on 33.

 12 Let's leave those up there and take

 13 additional comments on --

 14 MR. KHAN: Hold off, Doug.

10:50:19 15 MR. BROOKMAN: -- BE.

 16 MR. KHAN: And I just want to revisit a

 17 point again with Diane. It might be helpful to the

 18 Department if such data's available that

 19 characterizes -- You had said that, I guess, I

10:50:36 20 guess for a given capacity of a furnace, comparing

 21 a condensing versus as noncondensing, the CFM

 22 requirement for the condensing is typically higher.

 23 And so I was just wondering if there is
 115

 1 such data that, that we would be able to look at

 2 and, and characterize, I guess, the, the number of

 3 cases, or exactly how different that requirement is

 4 for the number of furnaces and models that are out

10:51:04 5 there. That, that also might be helpful to us if

 6 such data is available.

 7 MR. BROOKMAN: Diane?

 8 DR. JAKOBS: We'll see if I can share

 9 with -- It's not data that we publish right now.

10:51:19 10 MR. VerSHAW: Is this -- This is Jim

 11 VerShaw.

 12 It doesn't take more CFM.

 13 DR. JAKOBS: Not CFM.

 14 MR. BROOKMAN: Bryan, also.

10:51:29 15 MR. ROCKY: Yeah. Bryan Rocky.

 16 Basically it's the impact of the

 17 secondary heat exchanger. More resistance to flow

 18 to maintain the same CFM to cooling or heating

 19 performance.

10:51:39 20 You have more resistance. Therefore you

 21 have to have more energy to get the, the same

 22 airflow.

 23 You can look at the AEA calculations in,
 116

 1 that are already existing as part of the program

 2 and give you a, a, a basic comparison of the impact

 3 of electrical energy uses for condensers versus a

 4 noncondensing furnace today.

10:52:00 5 MR. BROOKMAN: Okay. Yeah?

 6 MR. KHAN: That's it.

 7 MR. BROOKMAN: You okay?

 8 Terry.

 9 MR. RANFONE: I thought maybe, as

10:52:11 10 somebody else has said, just expanding it to be a

 11 watts per CFM or CFM per watt. That way I think

 12 you'd pick up the, the differences between

 13 condensing and, rather, a conventional furnace.

 14 MR. BROOKMAN: Jim.

10:52:28 15 MR. VerSHAW: Jim VerShaw.

 16 One other comment. If you look at AEA

 17 you'll realize a, fewer operating hours of a given

 18 house if it's 95 percent, it will, versus a (sic)

 19 80-percent furnace.

10:52:40 20 Therefore, the BEs may be higher for the

 21 one furnace than the other, but the number of hours

 22 is definitely lower because it's satisfying the

 23 same heat in the same-sized house.
 117

 1 MR. BROOKMAN: Molly.

 2 MS. TROMBLEY-McCANN: Molly

 3 Trombley-McCann.

 4 For all the reasons just stated, we

10:52:57 5 think a watts-per-CMF or opposite is a better

 6 metric than an annualized metric.

 7 I did want to ask, are there technical

 8 reasons why the existing BE couldn't be applied to

 9 an air-handling unit compared to --

10:53:12 10 MR. JASINSKI: In fact, there may be. A

 11 manufacturer may be better able to answer this.

 12 I don't think there are any technical --

 13 MR. VerSHAW: Well, we don't measure --

 14 When you do an air-conditioner or heat pump, the

10:53:23 15 amount of watts of the indoor fan is required to

 16 do, to give you the, the, the CFM per ton. Air

 17 conditioning at the, at the conditions we're

 18 operating at to give you the control and all that's

 19 a, all part of the SEER calculation.

10:53:38 20 MS. TROMBLEY-McCANN: Right. I'm just

 21 -- It's listed as a limitation, that these test

 22 procedures aren't applied to that equipment.

 23 But, my understanding, there's no
 118

 1 technical reason why it couldn't. They're

 2 increasing, but it's not that they were applicable.

 3 MR. JASINSKI: Not -- I don't know there

 4 are any technical reasons, but they are specified.

10:53:56 5 MR. VerSHAW: It would be the same as

 6 asking for a generator or alternator on your car to

 7 have a certain efficiency when you've got a

 8 miles-per-gallon rating already.

 9 MR. BROOKMAN: Karim.

10:54:07 10 DR. AMRANE: We're getting now to a

 11 point where we are regulating components you have

 12 to, that are already regulated. You have SEER.

 13 Now on top of that you want to regulate

 14 consumption of the fan, which is not what you do,

10:54:20 15 which is why we believe that it shouldn't apply to

 16 the air-conditioning part.

 17 MR. BROOKMAN: Charlie.

 18 MR. STEPHENS: Charlie Stephens.

 19 I, I, I still think, however, that most

10:54:35 20 of the time you're not going to sell the, the, the

 21 alternator for the car separately and just use it

 22 all by itself. And in this case we've got a number

 23 of these products that are sold, in fact, without
 119

 1 the outdoor unit, and used all by themselves.

 2 And they -- And what DOE is proposing

 3 here to do is rate their efficiency. I don't see a

 4 problem with that.

10:54:55 5 The fact that you use this thing that

 6 has a certain rated efficiency as a component of

 7 another system and they contribute to the rating of

 8 the system, I don't see a problem with that either.

 9 All the system has a rating, and it won't change.

10:55:09 10 You know, either this system qualifies

 11 or it doesn't. The effect would have been if you,

 12 if you set a Standard for this component that was

 13 more stringent than some of them could meet, well,

 14 then the number of combinations, outdoor and indoor

10:55:24 15 systems, would change.

 16 There would be fewer. But, the ratings

 17 would not change.

 18 They would be the same. So, I'm not

 19 seeing that there's a, that real big problem here

10:55:35 20 in rating these things, and I don't see that you're

 21 rating something that is a subcomponent.

 22 These things are sold stand-alone and

 23 they're used stand-alone. You can use -- And, you
 120

 1 know, a furnace uses two kinds of fuel, two kinds

 2 of energy.

 3 I don't see a problem with figuring out

 4 the efficiency about, with which it uses each

 5 other.

 6 (Whereupon, at 10:55 a.m. ET, Mr. KHAN

 7 and Mr. Stas conferred, out of the hearing of

 8 others and off the Record, during which the

 9 following occurred:)

10:55:56 10 MR. STEPHENS: So, I don't see anything

 11 inherently wrong with the direction, but I think

 12 the metrics could be much better without disturbing

 13 some of the other ratings that go on when some of

 14 these things are actually used as part of the

10:56:08 15 system.

 16 MR. BROOKMAN: Okay. Thank you.

 17 You can see -- Go back to the comment

 18 box. You've got it.

 19 Thank you. Look at Slide 34, if you

10:56:16 20 would, please, and make sure that you've covered

 21 them all.

 22 See if there's anything else we need to

 23 cover at this point. We'll just pause for a
 121

 1 moment.

 2 There are four separate boxes.

 3 MR. KHAN: John TALBOTT.

 4 MR. BROOKMAN: Yes, John.

10:56:45 5 MR. TALBOTT: John TALBOTT, representing

 6 NIST.

 7 And the test procedures, there are some

 8 details in the test procedures that DOE would

 9 greatly like to hear industry's views and others'.

10:56:58 10 The BE as a measurement in the test procedure is

 11 pretty straight-forward.

 12 It can be -- It's analyzed in the test

 13 procedures. And it's not just watts.

 14 It's watt hours. And it has formulas

10:57:13 15 for getting to the, an annual and looking at that

 16 annual.

 17 Could that be sufficient to regulate or

 18 to have an accurate rank order? The other idea is

 19 you're looking for something like an efficiency

10:57:25 20 measure in lieu of a bin-weighted annual

 21 consumption number.

 22 The efficiency that's suggested is watts

 23 per CFM. You need -- CFM is not reported as a
 122

 1 result currently, so you need to think:

 2 Do you want to take on the report of CFM

 3 as part of a test procedure amendment? And also

 4 think about: How is this going to work if you

10:57:52 5 change the static pressure, which is a general

 6 consensus?

 7 Let's change the static pressure. Well,

 8 in the existing test procedure the static pressure

 9 is specified and may be artificially low, but

10:58:05 10 there's a temperature rise spec that everybody has

 11 to meet.

 12 Then you're affecting AUFE,

 13 theoretically. So, think about how, if you were to

 14 change the test procedure, make it a little better

10:58:21 15 so that you can handle this issue, think about

 16 maybe there's -- You don't want to test all the

 17 units all over again for AUFE.

 18 You need to think about a grandfathering

 19 provision, and perhaps all new units go to a new

10:58:35 20 test procedure. But, you need to get the

 21 relationship between AUFE -- You don't want to muck

 22 that up with a change in pressure on BE.

 23 Thank you.
 123

 1 MR. BROOKMAN: Just to use a technical

 2 term there, right? Yes.

 3 Go ahead, Diane.

 4 DR. JAKOBS: No, I agree with -- I mean,

10:58:56 5 we have tons of data on AUFE. People understand

 6 it.

 7 So, when you start changing it, you just

 8 make it more confusing for people. And, and what

 9 is the benefit?

10:59:09 10 So, going back to in the directory for

 11 AHRI, we designate which ones are electrically

 12 efficient. And, and actually, the, the rebates

 13 are, are based on that.

 14 The, the electrical energy is only two

10:59:25 15 percent of the total energy use.

 16 MR. BROOKMAN: Yeah. Okay. Okay.

 17 DR. JAKOBS: You know. And that's

 18 straight-forward.

 19 MR. BROOKMAN: I would imagine, yes.

10:59:36 20 MR. KHAN: Yeah. Before we take a break

 21 let me just be clear on one thing.

 22 We have no intention to, to use a

 23 technical term, muck up AUFE at all. But, you
 124

 1 know, we introduced the concept of, of BE because

 2 it is something that's already established.

 3 It's something that's already

 4 recognized. And to John's point, it doesn't mean

10:59:59 5 that we couldn't, you know, maybe use some variant

 6 of the, of the protocol in measuring what BE

 7 actually is, but it's just something that we, you

 8 know, provide for in consideration.

 9 MR. BROOKMAN: Okay. Final comments on

11:00:11 10 this segment?

 11 Because we're about to take a break, and

 12 I think, in fact, we're overdue for a break. Let's

 13 take a break now for 15 minutes, which means we'll

 14 resume at 11:15.

11:00:19 15 (Whereupon, at 11:00 a.m. ET, those

 16 present took a brief recess and returned at 11:21

 17 a.m. ET, after which the following occurred:)

 18 MR. BROOKMAN: Let's start back up.

 19 Okay, we're going to resume.

11:21:35 20 We're going to hear again from Sam.

 21 MR. JASINSKI: Okay, I'll pick up where

 22 I left off and we'll continue by discussing some of

 23 the analyses that will be conducted for the NOPR
 125

 1 phase.

 2 Here you'll see a graphic that

 3 illustrates where the NOPR falls in the rulemaking

 4 schedule, as well as the chevron that lists the

11:21:55 5 analysis that will be conducted for the NOPR.

 6 First I'll discuss the market and technologies.

 7 The purpose of the market and technology

 8 assessment is to characterize the residential

 9 furnace fan industry and any measures that can be

11:22:10 10 used to increase furnace fan efficiency.

 11 The market assessment characterizes the

 12 current market, manufacturers of furnace fans,

 13 historical shipments, commercially available

 14 products, and any existing regulatory or

11:22:24 15 nonregulatory programs related to furnace fans,

 16 while the tech-, technical assessment is, the

 17 purpose of the technical assessment is to identify

 18 technologies that manufacturers can use to meet or

 19 exceed energy conservation standards.

11:22:41 20 At this time DOE requests comments

 21 whether the manufacturers of the furnace fans are

 22 also the manufacturers of the HVAC systems that

 23 utilize furnace fans, as well as any input that you
 126

 1 may have on some of the themes related to the

 2 markets, the furnace fan markets and the tech-,

 3 furnace fan technology.

 4 MR. BROOKMAN: Who would like to start?

11:23:05 5 DR. JAKOBS: Someone else. Jump in.

 6 MR. BROOKMAN: You've been doing really

 7 well. Keep going.

 8 DR. JAKOBS: Okay. Rheem, Rheem does

 9 both.

11:23:16 10 We have -- We build our own housings and

 11 we purchase the impeller, many of them from

 12 Morrison, and motors, and, and put the combination.

 13 We've bought the housing and the impeller and

 14 applied the motor.

11:23:30 15 And, and I think even for some package

 16 equipment we buy the whole assembly. So, --

 17 MR. BROOKMAN: Okay.

 18 DR. JAKOBS: -- we do a whole variety of

 19 things, based on the cost, probably.

11:23:46 20 MR. STANONIK: But, the motor's a

 21 purchased component, right?

 22 DR. JAKOBS: Yeah, generally we buy the

 23 motor separately.
 127

 1 MR. BROOKMAN: Frank, you want to follow

 2 on this, in this? We're looking for a

 3 characterization here, aren't we?

 4 MR. STANONIK: Well, yeah. Frank

11:24:01 5 Stanonik, AHRI.

 6 I mean, I'm trying to understand the

 7 question in Item 21. I mean, I think Diane kind of

 8 covered it.

 9 You've got the impeller.

11:24:10 10 MR. BROOKMAN: Is that, is that kind of

 11 a standard configuration? Is that what you're

 12 suggesting?

 13 MR. STANONIK: Well, I guess I'm

 14 trying -- I'm actually trying to understand the

11:24:18 15 question in terms of what you consider the

 16 manufacturer, because the furnace fan is basically

 17 the impeller, the housing, and the motor. And, I

 18 mean, ultimately they have to be put together to

 19 create the furnace.

11:24:31 20 So, you can say, yeah, the furnace

 21 manufacturer's manufacturing the furnace fan, but

 22 in many cases they may not have made any of the

 23 pieces. So, -- .
 128

 1 MR. JASINSKI: I think it's important.

 2 MR. BROOKMAN: Go ahead, Sam.

 3 Elaborate.

 4 MR. JASINSKI: I think the, it's

11:24:45 5 important. The importance of this question is to

 6 figure out who the burden of certifying and rating

 7 the furnace fan will be, the manufacturer --

 8 MR. STANONIK: That's the manufacturer.

 9 The answer is "furnace manufacturer."

11:24:57 10 MR. BROOKMAN: Ashley? Go on.

 11 MS. ARMSTRONG: To going further, who

 12 actually specs out the design of the furnace fan?

 13 So, does the furnace manufacturer spec the design

 14 of the motor, or do they say, "I want these specs"?

11:25:11 15 Or, it's treated just as a purchased

 16 part? That's what we're trying to understand, not

 17 the relationship between these.

 18 MR. VerSHAW: Jim VerShaw.

 19 If you look at the competitive premise I

11:25:22 20 saw out there, you'll see almost identical wheels

 21 for, in almost every one of them. And the

 22 difference would be width and diameter.

 23 And that, that particular wheel is
 129

 1 chosen because of its stability, its breadth of

 2 operating conditions, and the fact that you don't

 3 have to have really, really tight tolerances, and

 4 you can run it at, at RPMs that make sense for the,

11:25:43 5 the application.

 6 You do get differences from manufacturer

 7 to manufacturer on housings. Many of us make our

 8 own housing.

 9 Some of us don't. Some of us do both,

11:25:54 10 buy and make.

 11 And now I forgot your question, so,

 12 sorry.

 13 MS. ARMSTRONG: Motors.

 14 MR. VerSHAW: Okay. So, so what we --

11:26:01 15 So, everybody -- So, so we, we will, we will, we

 16 will spec the speed torque curve on a motor based

 17 on performance that we determine because we know

 18 how.

 19 We know how much air we need and we know

11:26:13 20 how. So, we'll spec a speed torque curve, but

 21 we'll do tests to get there.

 22 MR. BROOKMAN: Bryan.

 23 MR. ROCKY: Yeah, Bryan Rocky.
 130

 1 There is one exception to this, that in

 2 the manufactured housing market there are blower

 3 kits for sale that are different from an

 4 application. It doesn't matter what furnace is

11:26:31 5 actually used or initially implied to that

 6 installation.

 7 But, based on add-on air conditioning

 8 typically that wasn't part of the original

 9 manufactured housing unit, the option to have a

11:26:43 10 different blower housing can occur where the blower

 11 kit, the motor, the wheel, the impeller, as Jim's

 12 talking about, is designed as a separate assembly

 13 and may be what, manufactured by us, and may be put

 14 in a competitor's furnace, and vice-versa.

11:27:01 15 So, again, in that case you're defining

 16 the design to a set condition, not to the -- And

 17 relative the Application, not as part of the actual

 18 furnace eventually for air.

 19 MR. BROOKMAN: Is it all specified how

11:27:14 20 these components fit together?

 21 MR. VerSHAW: Can you be, be more --

 22 DR. JAKOBS: Yeah. Yeah.

 23 MR. BROOKMAN: I'm just curious. Pardon
 131

 1 me. I'm taking us off course probably, but --

 2 MR. VerSHAW: Well, in the design of a

 3 furnace, you, -- This is Jim VerShaw. -- you

 4 determine the amount of air flow you need at what

11:27:36 5 static pressures you need to overcome total static,

 6 and it kind of determines the width and the

 7 diameter of the wheel.

 8 And then from that you know what, what

 9 torques you need to run to get to certain

11:27:47 10 conditions to keep inside the normal operating

 11 conditions. So, I mean, with respect to the speed

 12 torque curve or with an ECM motor, it's more of a

 13 program you need to get in, put in the motor to get

 14 there, and you know how much power it will take.

11:28:01 15 MR. BROOKMAN: Okay. Okay, do you think

 16 we covered this?

 17 MR. JASINSKI: Yeah, I think one

 18 additional thing I, might be useful. Like Diane

 19 said, that for some packaged units you do purchase

11:28:10 20 the whole assembly separately if you -- Maybe you

 21 could list some of the manufacturers of these

 22 assemblies.

 23 Not necessarily which ones you use in
 132

 1 particular, but, you know, that may be something

 2 that would be useful for the Department for this

 3 particular assessment.

 4 MR. BROOKMAN: Charlie Stephens.

11:28:26 5 MR. STEPHENS: Charlie Stephens.

 6 There was one mention made here, but I

 7 think the manufactured-home market is peculiar,

 8 and, and I'm thinking you need to focus a little on

 9 that. They have some constraints that other people

11:28:40 10 don't necessarily have.

 11 And they're -- They don't have as many

 12 as they used to have for the new product, but

 13 there's a ton of stuff out there that, a ton of

 14 these buildings out there that have a very

11:28:51 15 constrained space where all this stuff goes. And

 16 there's only a limited fraction of the

 17 manufacturers who are HUD certified to put that

 18 stuff in, and the new product.

 19 And it's a peculiar market, is what I'm

11:29:01 20 saying. And I think you need to pay a little bit

 21 of special attention to that, or at least explore

 22 it so you understand what you're doing there.

 23 MR. BROOKMAN: Okay. Jim.
 133

 1 MR. VerSHAW: Along that line as the

 2 requirements on SEER have gone up. The size of the

 3 coils required to make those numbers have gotten

 4 bigger, and the size of the house and the location

11:29:20 5 that these things are installed hasn't changed.

 6 So, what we're finding is you, the

 7 furnaces used to be 48 to 52 inches tall. And a

 8 few years back they went to 40.

 9 Now 40's too tall for some applications

11:29:37 10 because the coils are so tall. So, now, as we move

 11 forward to 14 and 15 and whatever on, on

 12 requirements, the furnaces are pushing down towards

 13 30 now.

 14 If you're going to put the same air flow

11:29:47 15 through a small package than you are through a

 16 large package, it sometimes becomes very difficult

 17 to keep the same fan efficiency.

 18 MR. BROOKMAN: Um-hum.

 19 Okay, Terry.

11:29:59 20 MR. SMALL: Charlie's point I guess

 21 bears a little bit further explanation. We've been

 22 talking about furnaces in general, but, you know,

 23 we have all these different classes of furnaces;
 134

 1 you know, nonweatherized, weatherized.

 2 And, you know, one of the classes is a

 3 mobile-home gas furnace, mobile-home oil furnace.

 4 And I think that the different styles of furnaces

11:30:20 5 are going to have some different, probably, values

 6 in operating characteristics.

 7 So, I'd like to make sure that, you

 8 know, DOE takes that into account when they look at

 9 these, at this, this rulemaking. Thank you.

11:30:37 10 MR. BROOKMAN: Thank you.

 11 MR. JASINSKI: Thank you. One of the

 12 important outcomes or goals of the market

 13 assessment is to develop product classes.

 14 DOE divides covered products into

11:30:54 15 classes by the type of energy used, the capacity of

 16 the product, or any other performance-related

 17 characteristics that affects consumer utility.

 18 Based on these criteria, DOE could possibly use

 19 rated air flow capacity or motor, rated motor

11:31:09 20 horsepower for the fan motor to differentiate

 21 between product classes.

 22 DOE believes that rated air flow

 23 capacities for typical commercially available
 135

 1 furnace fan products, range from 400 CFM, cubic

 2 feet minimum, to 2,200 CFM in the highest feet

 3 settings. DOE believes that that rated horsepower

 4 of the fan motors used in commercially available

11:31:35 5 furnace fan products ranges from approximately

 6 a-fifth horsepower to, to a single horsepower.

 7 At this time DOE seeks comment on the

 8 characteristics listed, as well as any others that

 9 could be used to differentiate between product

11:31:50 10 classes, as well as any additional information on

 11 how those characteristics can be applied, based on

 12 the product class criteria.

 13 MR. BROOKMAN: Bryan.

 14 MR. ROCKY: I'll go first this time,

11:32:04 15 Diane.

 16 DR. JAKOBS: Great.

 17 MR. ROCKY: Starting with the discussion

 18 of rated motor horsepower versus air flow, I think

 19 motor horsepower becomes an absolutely worthless

11:32:17 20 measurement as applied with any products, whether

 21 air handlers or furnaces in this case. The design

 22 of the equipment, as Jim was talking about with

 23 the, the system approach, would define the motor
 136

 1 horsepower needed at minimum, and most

 2 manufacturers will try to minimize that just

 3 because of the cost of the motor assemblies as you

 4 go up in horsepower.

11:32:35 5 So, air flow capacity of those two would

 6 be much better.

 7 MR. BROOKMAN: Um-hum.

 8 MR. ROCKY: Product classes, there are a

 9 lot of different comments already been made. One

11:32:45 10 obviously is, as Terry was following up, more

 11 home-manufactured housing applications have already

 12 been considered different product classes under DOE

 13 rulings on efficiency.

 14 And I would propose that that is the

11:32:58 15 same situation for this ruling as well, just, just

 16 because of the application constraints, and also

 17 would say that a product class, as we have already

 18 discussed, condensing versus noncondensing, if

 19 we're driving towards a product class, CFM-type

11:33:14 20 approach could be justifiable as a product class

 21 just because of the offset of the higher efficiency

 22 on the combustion side versus higher watts to get

 23 that efficiency, as compared to the total energy
 137

 1 usage of the condensing furnace versus

 2 noncondensing.

 3 MR. BROOKMAN: Thank you. Okay.

 4 MR. JASINSKI: Okay. I think for

11:33:36 5 clarity I'll just add a follow-on question.

 6 I think that, as Bryan said, in the past

 7 for other rulemakings the product classes are

 8 application based. In this particular case, when

 9 you're dealing with a component that can be used in

11:33:49 10 a lot of different HVAC products, I think it would

 11 be nice if we, we can receive comment on whether or

 12 not manufacturers of furnace fan products

 13 potentially use these same blower assemblies

 14 between applications; if, for instance,

11:34:07 15 Manufacturer X uses the same blower assembly within

 16 one of their air-conditioner air handlers as they

 17 do in a gas-fired furnace.

 18 Is that, is that the case?

 19 MR. WAGNER: Usually they're

11:34:23 20 different --

 21 MR. ROCKY: They're different.

 22 MR. WAGNER: -- because of design. And

 23 I do agree with what Rocky, --
 138

 1 Sorry.

 2 -- with what Bryan said.

 3 MR. ROCKY: Either/or.

 4 MR. WAGNER: The horsepower rating, the

11:34:34 5 horsepower nameplate ratings are, are selected not

 6 necessarily as specifics, but a number that's put

 7 on the nameplate. Just recently ran across a-half

 8 horsepower motor that was stronger than a

 9 three-quarter horsepower motor.

11:34:51 10 So, not a good, useful rating.

 11 MR. BROOKMAN: Thank you, Greg.

 12 And, Jim?

 13 MR. VerSHAW: Jim VerShaw.

 14 The furnaces are all 115-volt,

11:35:00 15 single-phase. Air handlers are all, mostly 220

 16 single-phase.

 17 So, you'll have difficulty right there.

 18 You've got different housings.

 19 You've got similar wheels. But, between

11:35:11 20 furnace to furnace to furnace you have -- Somebody

 21 might use 11-inch diameter, somebody else might use

 22 a ten, somebody might use nine.

 23 And the widths will vary. So, it's a
 139

 1 variation, but they're not the same.

 2 MR. BROOKMAN: Thank you very much.

 3 Diane?

 4 DR. JAKOBS: If you just think of a heat

11:35:30 5 pump with a, all you'd have is a, cooling coils in

 6 the system, whereas with, with a furnace you have

 7 the gas heat exchanger plus you have the cooling

 8 coil. So, the motors need to be more, be stronger

 9 for a furnace than for a (sic) air-handler system.

11:35:48 10 MR. BROOKMAN: Thank you. Very helpful.

 11 We have one more.

 12 MS. MAUER: Joanna Mauer.

 13 MR. BROOKMAN: Yes.

 14 MS. MAUER: Is there a reason you

11:35:56 15 couldn't describe, use an equation to describe

 16 efficiencies as a function of air flow as opposed

 17 to trying to come up with a different product

 18 class?

 19 MR. JASINSKI: Well, I think it, it's

11:36:06 20 important --

 21 Diane? Did you --

 22 DR. JAKOBS: (Nodded no.)

 23 MR. JASINSKI: I think it, it's
 140

 1 important, what Diane, like Diane said, that the

 2 components that go into the, into the housing of

 3 the air handler or furnace have an effect on that

 4 which, I guess, would not be, would not be

11:36:19 5 accounted for in a, in an equation like that.

 6 MS. MAUER: So, then maybe within

 7 product classes, based on the type of equipment,

 8 you could describe an engine use as a function.

 9 DR. JAKOBS: Yeah. Well, except we do

11:36:31 10 different things inside our box, so I'm not sure

 11 that that would be --

 12 MR. BROOKMAN: You're just, you're

 13 saying that product classes are not, you do enough

 14 different things that the product classes are not

11:36:42 15 easily describable or discernable.

 16 Ashley.

 17 MS. ARMSTRONG: I guess the question for

 18 you, are you trying to say, like, you want an

 19 equation to characterize, like, watts over the full

11:36:53 20 range of air flows? I mean, I'm confused as to

 21 what your two variables would be in your equation.

 22 MS. MAUER: Well, either describing

 23 efficiency, some kind of efficiency metric or
 141

 1 energy use based on air flow, that it would change

 2 as -- And I don't know how it would change, or

 3 whether that it be possible to develop that type of

 4 equation.

11:37:13 5 MS. ARMSTRONG: I think -- This is

 6 Ashley.

 7 It would depend on the metric based on

 8 the test procedure that DOE ultimately uses. But,

 9 if DOE finds that there's a reason to distinguish

11:37:22 10 product classes based on the number of factors, you

 11 could do it by fins, by single points.

 12 You could do it by the equations. And

 13 it just depends on how the DOE is involved in

 14 there.

11:37:34 15 MR. WAGNER: And I would also add that

 16 as a heat transfer equation changes, the air flow

 17 changes. So, that's a another variable in this

 18 process.

 19 MR. BROOKMAN: Okay.

11:37:44 20 MR. WAGNER: So, you've got mass flow

 21 equation.

 22 MR. BROOKMAN: That was Greg. Now let's

 23 hear from Bryan.
 142

 1 MR. ROCKY: Yeah. Just one other

 2 comment was that in the framework document right

 3 before this discussed about high-efficiency furnace

 4 fans and the current usage, PSE versus ECM.

11:38:00 5 And it was stated that 95 percent of

 6 furnace fans were PSC motors, and as a result of

 7 the impact of the federal tax credits, utilities

 8 rebates, weatherization programs, the

 9 high-efficiency motors, the ECM usage has grown

11:38:20 10 tremendously and will differ based on which

 11 manufacturer you talk about.

 12 But, in general, to meet higher, higher

 13 efficiency requirements, we are using ECMs to the

 14 point of it's not the majority yet, but it's headed

11:38:37 15 that way. I mean, we're well along the curve.

 16 MR. BROOKMAN: Ashley.

 17 MS. ARMSTRONG: No, I think that's okay.

 18 MR. BROOKMAN: Okay.

 19 Diane, do you want to add in here?

11:38:44 20 MS. ARMSTRONG: I --

 21 MR. BROOKMAN: Go ahead, Ashley.

 22 MS. ARMSTRONG: I guess the question

 23 would be, is: Are you using high efficiency? Is
 143

 1 that, is that distribution the same if we're

 2 talking about just the furnace, or if we're talking

 3 about the heat-pump markets?

 4 MR. ROCKY: It -- As based as a

11:39:02 5 percentage of sales, it is. It's applying to both

 6 air handlers for AC, and heat pumps, as well as

 7 furnaces.

 8 And the, the distribution is completely

 9 skewed as the impact of the last two years versus

11:39:16 10 what it was in the product-mix segment.

 11 MS. ARMSTRONG: Um-hum.

 12 MR. ROCKY: And I, I can't say if I can

 13 judge a, an industry standpoint, but I think you'd

 14 probably be safe to say somewhere, instead of five

11:39:30 15 percent being in ECM, it could be anywhere from 15

 16 to 35 percent, based on the product families and

 17 the manufacturer and the type of equipment.

 18 And that's the market segment that is

 19 growing for all of the manufacturers. It's not the

11:39:43 20 PSE motor applications.

 21 MR. BROOKMAN: Terry?

 22 MR. SMALL: I'd like to echo what Bryan

 23 just said. The differential costs between the PSC
 144

 1 motor and a brushless DC-, or an ECM motor is, is,

 2 is narrowing to the extent that, you know, I, I

 3 wouldn't think there are going to be any PSC motors

 4 of this type of application in ten years.

11:40:06 5 So, maybe by the time the rulemaking

 6 goes into effect there may not be any PSC motors

 7 being used, possibly.

 8 The other, the other comment is that,

 9 remember that, particularly in furnaces or, or

11:40:19 10 really in air handlers, if they have strip heat,

 11 that the airflow, the safety operation of these

 12 devices is very dependent on the airflow. And the

 13 manufacturers will make their designs depending on

 14 the, the electric heating elements or the, the heat

11:40:42 15 exchangers.

 16 It's not just about -- It's not always

 17 about optimizing the, the energy efficiency of the

 18 motor. There may be some safety concerns.

 19 You know, you've got to be able to

11:40:53 20 design the product so that the limits work properly

 21 so if you have a motor fail, the limits operate

 22 properly and shut the whole system down.

 23 MR. BROOKMAN: Thank you.
 145

 1 Bryan.

 2 MR. ROCKY: Yeah. One other -- Bryan

 3 Rocky.

 4 One other thing to, to note on this:

11:41:10 5 that at low loads or partial-load conditions is

 6 where an ECM really gains its strength because of

 7 its efficiency. But, at the high condition, load,

 8 high-load condition such as full air-conditioning

 9 load, especially with the larger-sized units and

11:41:30 10 four- and five-ton, for instance, you're already

 11 maxing out.

 12 The ECM is not going to gain you that

 13 much more at those maximum conditions as a relative

 14 percentage as it will for the partial-load

11:41:42 15 operation. So, it gets to be another interesting

 16 discussion about appropriate air flow and

 17 conditions when you're trying to put this towards

 18 the no impact on the system.

 19 You can only spin these wheels so fast,

11:41:56 20 and when you get to that maximum speed, you can't

 21 do anything more. You can't deliver that air, any

 22 more airflow than those wheels will deliver.

 23 At that point it doesn't matter, almost
 146

 1 doesn't matter what motor is driving that system.

 2 MR. BROOKMAN: Okay.

 3 Yes, Jim.

 4 MR. VerSHAW: I'm not sure what, what

11:42:16 5 Terry was saying. We haven't seen the price

 6 differential between permanent magnet motors and,

 7 and PSCs declining.

 8 It's still a pretty substantial three-

 9 or four-time multiplier on motor costs. So, I'm

11:42:33 10 not sure that, that I've seen that fall off at this

 11 point.

 12 It's a much more complicated motor. It

 13 has electronics built into it.

 14 It's got responsive magnets in it. And

11:42:43 15 at the same time, we have, we still have seen lower

 16 failure rates on PSC motors than we do with, with,

 17 with ECM motors, so that the homeowner then, when

 18 he has to, if it's out of warranty when the ECM

 19 fails, has substantial costs to replace that motor.

11:42:58 20 That wouldn't normally happen with PSC.

 21 MR. BROOKMAN: Terry.

 22 MR. SMALL: Just clarify what I said.

 23 Some of the brushless motors, obviously you have
 147

 1 the very high-end motors.

 2 I believe one brand has gone to Version

 3 5 now, with specialized wheel that goes with it.

 4 But, some of the ECM motors have been dumbed down

11:43:20 5 with, with sort of fixed taps.

 6 X-13 is, is one of the, one of the model

 7 numbers of one of the brands.

 8 (Whereupon, at 11:43 a.m. ET, Dr. Amrane

 9 left the room, after which the following occurred:)

11:43:31 10 MR. SMALL: And it's those lower-end

 11 variations that I think have --

 12 MR. VerSHAW: The high-end motors are

 13 still more expensive. They're fully programable.

 14 But, there's an, been an effort to try

11:43:46 15 to dumb down some of the motors to have something

 16 that's closer to PSC. And I think you'll see some

 17 of these lower-end ECM motors ultimately replace

 18 the motors at some point.

 19 MR. BROOKMAN: Yes. Thank you.

11:44:00 20 Yes, Alex.

 21 DR. LEKOV: Just, the speaker's

 22 indicated that the ECM motors are starting to

 23 take --
 148

 1 MR. BROOKMAN: Alex, turn your

 2 microphone on. Thank you.

 3 DR. LEKOV: The speaker's indicated that

 4 the ECM having larger and larger market share, so

11:44:19 5 it's important for the DOE calculations to

 6 understand what are the control schemes,

 7 particularly the replacement situations, when you

 8 go to put a new furnace in the house that has

 9 characterize as a bad duct system with the very

11:44:42 10 high pressure loss.

 11 And aren't there any controls limitation

 12 that's essentially rule out the deficiencies of the

 13 ECM working at very high pressure loss?

 14 (Whereupon, at 11:45 p.m. ET, Dr. Amrane

11:44:53 15 entered the room, after which the following

 16 occurred:)

 17 DR. JAKOBS: I --

 18 MR. BROOKMAN: Diane.

 19 DR. JAKOBS: Sorry. Thank you.

11:45:03 20 We don't -- I don't think we have a

 21 limitation. Some of our higher-end equipment will

 22 offer diagnostics so the installer can see what

 23 airflow they're getting, but we don't, we don't,
 149

 1 like, shut down because the, the ductwork is too

 2 restrictive.

 3 MR. BROOKMAN: Go ahead, Jim.

 4 MR. VerSHAW: The next -- Jim VerShaw.

11:45:29 5 In terms of control schemes, if, if

 6 there, if there's so much pressure drop that the

 7 motor is trying to, it will, it will, it will, it

 8 will, it will try to, it will start ramping up in

 9 power usage, there's a point where it will start

11:45:44 10 falling off and you can't get any more out of it.

 11 It's kind of a self-protecting thing so

 12 you don't get too many amps that, through the

 13 motor. But, the goal is to install a furnace and

 14 make sure it operates within the rise unit of the

11:45:59 15 furnace, because that's a safety issue.

 16 Otherwise it won't operate

 17 appropriately. If they can't get within the rise

 18 range, then they shouldn't have that furnace in

 19 there.

11:46:07 20 But, there isn't -- I don't, I don't --

 21 Typically you don't check the, the temp drop.

 22 Well, it, it has to be within the limits of the, of

 23 the, of the circuit breaker, but that's, that's as
 150

 1 far as it goes.

 2 DR. LEKOV: So, to summarize, so there

 3 are no special controls that limit the CFM if the,

 4 for ECM motors if the pressure loss existing in the

11:46:37 5 system is very high.

 6 MR. WAGNER: There's, there's built-in

 7 protection. This is Greg Wagner.

 8 There's built-in protections in the

 9 motor itself. The controls have power-limiting

11:46:47 10 features that prevent them from going beyond a

 11 certain power drop.

 12 So, whether it's a three-quarter or

 13 one-half, it has a watt limit that protects the

 14 motor.

11:46:57 15 DR. LEKOV: Okay, thank you.

 16 MR. BROOKMAN: Okay?

 17 MR. JASINSKI: Thank you. Next I'll go

 18 into a little bit more detail about the technology

 19 assessment.

11:47:06 20 The technology assessment uses

 21 information about existing or past technology

 22 options, as well as prototypes to, to identify

 23 technologies that manufacturers can use to meet or
 151

 1 exceed energy conservation standards. Note that

 2 DOE will only consider options that increase the

 3 efficiency of furnace fans.

 4 However, here are the preliminary list

11:47:27 5 of technology options which include high-efficiency

 6 furnace fan motors as well as improvements to

 7 impellers.

 8 At this time DOE seeks comments on this

 9 preliminary list, as well as any other technology

11:47:38 10 options that may be available for manufacturers to

 11 improve the efficiency of that furnace fan.

 12 MR. BROOKMAN: Diane.

 13 DR. JAKOBS: So, someone already

 14 mentioned the X-13 motor. I had asked that.

11:47:50 15 So, it has a brushless permanent-magnet

 16 motor, but it has speed caps like a PSC motor. It

 17 doesn't have the coil.

 18 MR. ROCKY: Diane, I think, I think on

 19 the definitions ECM from those motor suppliers as

11:48:05 20 long as it's supplied to PCM, that they will cover

 21 both?

 22 DR. JAKOBS: That they're considered

 23 equivalent.
 152

 1 MR. BROOKMAN: Thank you, Bryan.

 2 Yes, go ahead.

 3 MR. WAGNER: I say he was, I was just

 4 going to comment on the text. In 3.271 there's a

11:48:18 5 number of errors in the description of motors.

 6 MS. ARMSTRONG: I'm sorry, which --

 7 MR. WAGNER: The CP motors are not

 8 brushed motors.

 9 MR. JASINSKI: Greg, before you start, I

11:48:28 10 think we're aware of those technical inaccuracies

 11 and there's a new, there's a new version of the

 12 framework posted. It should be -- Maybe the wrong

 13 version got printed, but --

 14 MR. WAGNER: I didn't review today's.

11:48:43 15 The one I wrote my notes on, I didn't have time

 16 between 9:00 and 9:15, when we started.

 17 But, I was going to say, there's a huge

 18 problem with that whole section of --

 19 MR. JASINSKI: Right. Well, there's an

11:48:52 20 updated section on, version on the web, and I

 21 believe Ashley may be able to provide an updated --

 22 MS. ARMSTRONG: I'd -- I don't encourage

 23 -- You must have gotten it within 24 hours of it
 153

 1 coming out or something, the documents.

 2 DR. JAKOBS: Of course we did.

 3 MS. ARMSTRONG: Yeah. Yeah, you were

 4 waiting, weren't you?

11:49:10 5 There's a new version, and I would

 6 encourage you to look at that.

 7 MR. VerSHAW: So, the June first is the

 8 most latest version?

 9 MS. ARMSTRONG: June first is a version.

11:49:21 10 I can look at it and tell pretty easily.

 11 MR. WAGNER: That's the one we got.

 12 MS. ARMSTRONG: The one we got today is

 13 right. It's --

 14 DR. JAKOBS: Well, there was a section

11:49:31 15 missing, and I looked at it, like, a line. But

 16 then I looked again and it was there.

 17 So, maybe it has a same date.

 18 MR. WAGNER: How do I tell the

 19 difference?

11:49:43 20 MS. ARMSTRONG: I'll come by and show

 21 you at lunch.

 22 MR. WAGNER: No, I mean, they're both

 23 dated --
 154

 1 DR. AMRANE: The one-to-one is the only

 2 way.

 3 MS. ARMSTRONG: The one is, they have on

 4 the web is correct. It --

11:49:56 5 MR. STANONIK: And the one they passed

 6 out today is correct.

 7 MS. ARMSTRONG: Yes.

 8 MR. STANONIK: So, your stapled one; not

 9 the one with the holes.

11:50:03 10 MR. BROOKMAN: Okay. Just to reiterate,

 11 comments on the most current version.

 12 All right, Diane, go ahead.

 13 DR. JAKOBS: Well, the other item on

 14 there, improved impellers. And there's been some

11:50:13 15 work on back-ordered wheels in, in the larger

 16 ranges.

 17 Ingersoll Rand maybe has a ten-ton, but

 18 that, that hasn't really been shown to be as

 19 effective in the smaller diameters. And Ian Walker

11:50:32 20 did some work and had some, some good results, but

 21 the part of what Ian did was to make the clearances

 22 tighter.

 23 And that will work with a forward-curved
 155

 1 wheel, too. You can do better if you pay more

 2 attention to how the air comes into the, into the

 3 fan and how close the walls are.

 4 And so some other things that Ian had

11:50:57 5 has, as highlighted in the papers he's written are

 6 applicable to both styles of motors.

 7 MR. BROOKMAN: Okay.

 8 Charlie Stephens.

 9 MR. STEPHENS: Charlie Stephens.

11:51:07 10 I was going to echo that. I think

 11 there's, needs to be some third category here that

 12 has to do with the airflow path design, something

 13 along what Diane was saying, a whole new category.

 14 MR. JASINSKI: Okay, thank you.

11:51:23 15 MR. WAGNER: Well, that would get into a

 16 system. This is Greg again.

 17 MR. BROOKMAN: Yeah.

 18 MR. WAGNER: That gets into the system;

 19 you know, the overall system as a box, not just a

11:51:33 20 piece and rate it as a component. As I looked at

 21 your new version real quick, the last comment I'll

 22 make is on the PSC motors.

 23 They're typically, like, 55-, 60-percent
 156

 1 efficient, not 34, 39.

 2 MS. ARMSTRONG: Okay. Okay.

 3 MR. BROOKMAN: Okay. Thank you.

 4 MR. JASINSKI: Thank you.

11:51:53 5 Next I'll discuss the screening

 6 analysis. After completion of the market and

 7 technology assessment, DOE uses the screening

 8 analysis to eliminate technology options for

 9 downstream.

11:52:07 10 It eliminates it based on the four

 11 criteria listed here specified in Code of Federal

 12 Regulations. They're technical feasibility;

 13 practicability to manufacturer to install and

 14 service; impacts on utility or availability to

11:52:18 15 consumer; and finally, impacts on health or safety.

 16 DOE welcomes comments on how to apply

 17 the listed criteria to the technology options

 18 discussed.

 19 MR. BROOKMAN: Yes, Charlie.

11:52:37 20 MR. STEPHENS: Charlie Stephens.

 21 One thing -- I, I don't know whether

 22 people are thinking about it, but new Standards for

 23 the motors for, for the PSC for actually horsepower
 157

 1 motors were just published in February, so you can

 2 -- You know, some of the motors will fall in those

 3 categories and you'll find minimum efficiencies

 4 there.

11:52:59 5 MR. BROOKMAN: Karim.

 6 DR. AMRANE: Karim Amrane, AHRI.

 7 But, it's my understanding that those

 8 motors do not, are not -- The motors used in HRC

 9 equipment are not regulated by DOE. Correct?

11:53:11 10 MR. JASINSKI: I'll refer to Ashley, but

 11 I believe that's correct.

 12 MR. BROOKMAN: Ashley.

 13 MS. ARMSTRONG: It is my preliminary

 14 understanding that Karim is correct, but we should

11:53:24 15 verify and, just to make sure. But, it was my

 16 understanding that the ones under the scope of this

 17 were not, were not affected by the small electric

 18 motor centers, but I could be wrong.

 19 I'm not a motor person, so -- .

11:53:40 20 MR. BROOKMAN: Okay. Eric Stas.

 21 MR. STAS: I'll check with Michael Kido

 22 --

 23 MS. ARMSTRONG: Yeah.
 158

 1 MR. STAS: -- over lunch and try to

 2 clarify that.

 3 MR. BROOKMAN: Thank you.

 4 Okay, I --

11:53:49 5 DR. JAKOBS: One, one -- I've been

 6 working on comments, and when I looked at that it

 7 was, like, "Where's cost?" And I thought maybe it

 8 was under "product utilities," but then you go on

 9 and talk about cost separately. So --

11:54:03 10 MR. JASINSKI: Yeah. Cost, cost

 11 efficiency relationship will be developed in the

 12 engineering, which I'll discuss briefly.

 13 MS. ARMSTRONG: Yeah, cost is not one --

 14 This is Ashley.

11:54:13 15 Cost is not one of the criteria for

 16 which DOE considered in the screening, but cost

 17 justification is something that will be dealt with.

 18 MR. BROOKMAN: Okay.

 19 Other comments on this? Okay.

11:54:25 20 MR. JASINSKI: Thank you. Next I'll

 21 discuss the engineering analysis.

 22 The engineering analysis is a key factor

 23 in setting the standards to estimate the increased
 159

 1 cost to manufacturers to produce higher efficiency

 2 products. The engineering analysis determines the

 3 relationship between cost and efficiency.

 4 And these results are used in downstream

11:54:47 5 analyses such as the life-cycle cost and payback

 6 period, manufacture impact analysis, and employment

 7 impact analysis. The engineering analysis begins

 8 by when DOE defines baseline models.

 9 Typically baseline models are models

11:55:04 10 that meet current energy conservation standards.

 11 However, because of no current energy conservation

 12 standards exist for furnace fans, DOE will select

 13 baseline models that are typical of the

 14 least-efficient, the furnace fans used in the

11:55:18 15 least-efficient commercially available furnace fan

 16 product.

 17 Once baseline models are defined, DOE

 18 then identifies, uses the market, market

 19 information from the market and technology

11:55:31 20 assessment to identify efficiency levels that

 21 should be analyzed.

 22 Then DOE performs tear-down, tear-downs

 23 of products at these efficiency levels to develop
 160

 1 Bills of Materials which act as inputs for a cost

 2 model that DOE uses to develop manufacturer

 3 production costs.

 4 A little bit more detail on the

11:55:53 5 tear-down portion of the engineering analysis. For

 6 -- During a tear-down, DOE physically disassembles

 7 a selected product during which it compiles

 8 information about the characteristics of each

 9 component, which include the, the process needed to

11:56:10 10 manufacture or fabricate that, that component, and

 11 this information is compiled into Bills of

 12 Materials.

 13 Listed here are the selection criteria

 14 DOE uses to decide which models of furnace fans to

11:56:25 15 tear down. At this time DOE seeks comment on the

 16 approach used to determine the cost efficiency

 17 relationship, as well as the selection criteria

 18 used to decide which models to tear down, as well

 19 as any, any comments that you can, you can provide

11:56:46 20 about energy efficiency trends based on the

 21 characteristics of furnace fans.

 22 Some are listed here.

 23 MR. BROOKMAN: Sam, which slide do you
 161

 1 think will provoke the most comment, 49 or 50?

 2 MR. JASINSKI: Probably 49. I think it

 3 might be beneficial for them to see --

 4 MR. BROOKMAN: That's what I think.

11:57:08 5 MR. JASINSKI: -- criteria.

 6 MR. BROOKMAN: I'm hoping individuals

 7 can refer to it as, as they're making their

 8 comments.

 9 Karim?

11:57:16 10 DR. AMRANE: Karim Amrane, AHRI.

 11 I guess with respect to the cost

 12 efficiency curves, in order to, to derive them you,

 13 you need a test procedure first, right?

 14 MR. JASINSKI: Yes.

11:57:27 15 DR. AMRANE: So, that's going to happen

 16 later in the process?

 17 MR. JASINSKI: Yes. The test procedure

 18 rulemaking will be a separate rulemaking from the

 19 energy conservation standard rulemaking.

11:57:37 20 And typically they are scheduled so that

 21 a test procedure does exist before the engineering

 22 analysis occurs.

 23 MS. ARMSTRONG: Whoa. Whoa.
 162

 1 MR. BROOKMAN: Ashley.

 2 MR. JASINSKI: I said "typically."

 3 MS. ARMSTRONG: There will be a, some

 4 type of proposal coming out, hopefully before, but

11:58:02 5 if not, concurrently with, right? At the same

 6 time.

 7 But, yes, the, the engineering has to be

 8 based on a metric, as does the rest. So, yes, some

 9 type of testing procedure with a metric has to be

11:58:17 10 semi-determined or at least proposed, or for public

 11 comment in order to also do the analysis for the,

 12 for the proposal.

 13 Yep.

 14 MR. BROOKMAN: Greg.

11:58:26 15 MR. WAGNER: Yeah. I was just going --

 16 I don't know how you get the one without the other.

 17 I mean, it's like a circular kind of

 18 thing.

 19 MS. ARMSTRONG: Yeah. Um-hum.

11:58:34 20 MR. WAGNER: We're trying to determine

 21 what that should be, but how do you get that

 22 baseline without knowing what testing should be?

 23 MS. ARMSTRONG: Okay.
 163

 1 MR. BROOKMAN: Yeah. Okay.

 2 So, I would refer you to the slide which

 3 is up there, 49, and you can see the various

 4 characteristics, considerations that the Department

11:58:54 5 would like comment on.

 6 Yes, Bryan.

 7 MR. ROCKY: Bryan Rocky.

 8 I guess my comment back to DOE is: How

 9 many different representative classes are we

11:59:10 10 looking at here?

 11 From the discussion we already had

 12 relative to applications, even such minor things as

 13 electrical power to, to, 220, 230 volt versus 115,

 14 if you're trying to come up with one or two

11:59:26 15 baseline models, I could easily see that generating

 16 to ten or 12 or whatever.

 17 The, the furnace fan assembly, as we've

 18 already discussed, is going to vary so widely

 19 between motors and wheels and blower housings as an

11:59:45 20 assembly from manufacturer to manufacturer to

 21 applications. I'm not sure how, how you're going

 22 to try to narrow all this down.

 23 What are you looking for for a, as
 164

 1 tear-down? What is the target number, I guess, as

 2 a representative baseline starting point?

 3 MR. JASINSKI: Well, at this point DOE

 4 does not have, does not specify a certain number of

12:00:06 5 tear-downs. Based on these criteria, we'll use the

 6 information from the market assessment to try to

 7 determine, you know, what, what is a sufficient

 8 number to meet these criteria and also represent

 9 the market.

12:00:17 10 To your other point, it's not

 11 necessarily -- DOE in the past has used

 12 representative product classes should sufficient

 13 scaling capabilities be developed. So, it's not,

 14 it's not certain whether or not DOE will directly

12:00:31 15 analyze each product class.

 16 MR. BROOKMAN: Diane.

 17 DR. JAKOBS: Thank you. You had said it

 18 was a least-efficient.

 19 One of the things is there, for, in

12:00:47 20 packaging, is there are belt-driven blowers. So,

 21 you wouldn't take a belt-driven blower -- Would

 22 you? -- because it would be very inefficient,

 23 associated with the belt, --
 165

 1 (Whereupon, at 12:01 p.m. ET, Ms.

 2 Armstrong and Mr. Stas conferred, out of the

 3 hearing of others and off the Record, during which

 4 the following occurred:)

12:00:59 5 DR. JAKOBS: -- compared to the

 6 direct-drive.

 7 Or would you? I mean, it seems like the

 8 worst may be very uncharacteristic of the whole

 9 market.

12:01:10 10 And, is there a limitation, maybe, to

 11 what --

 12 MR. JASINSKI: So, I think, I think that

 13 that -- I think the selection of the proper product

 14 class criteria is, is what we use to try to avoid

12:01:23 15 situations like that.

 16 (Whereupon, at 12:01 p.m. ET, Mr. Stas

 17 and Mr. KHAN conferred, out of the hearing of

 18 others and off the Record, during which the

 19 following occurred:)

12:01:27 20 MR. JASINSKI: And it's important to

 21 recognize that efficiency -- Going back to

 22 technology options, you look for, you look for

 23 technologies that substitute, that do not diminish
 166

 1 the utility to the consumer.

 2 So, in the instances you bring up, and

 3 you may be able to correct me if I'm wrong here,

 4 but the application is such that you wouldn't be

12:01:51 5 able to drop in a belt-driven to replace that

 6 direct-drive motor without compromising the utility

 7 or the application.

 8 So, I think that that would definitely

 9 be considered in determining those technology

12:02:04 10 options.

 11 MR. BROOKMAN: Terry.

 12 MR. SMALL: Just to point out as the

 13 importance of, of, you know, basically following

 14 product classes, if what you're saying, the

12:02:17 15 baseline model is typically the least-efficient

 16 model in the market, for manufactured housing, very

 17 often the, the, the entry-level furnace might have

 18 a shaded pull motor for heating.

 19 And, and if the consumer's in an area

12:02:37 20 where there's heavy air conditioning, that would be

 21 replaced by one of these blower conversion kits,

 22 which would be a PSC motor, which would be

 23 obviously more efficient for heavy cooling usage.
 167

 1 So, I think your, your study needs to

 2 take that into account.

 3 MR. JASINSKI: Thank you.

 4 MR. BROOKMAN: Jim.

12:02:59 5 MR. VerSHAW: On, on the chart behind

 6 you there it says from the same manufacturer and

 7 product series. Is that saying you're going to use

 8 one manufacturer and product to --

 9 MR. JASINSKI: No, no. We'll choose

12:03:14 10 difference models from different manufacturers.

 11 Its also a criteria for models from

 12 manufacturers usually with large market shares and

 13 who would account for large shipment volumes.

 14 MR. VerSHAW: You're probably not going

12:03:30 15 to see when you -- When you take the blowers out

 16 of, blower systems out of the furnaces, you're

 17 going to find you've got a bunch of sheet metal and

 18 you've got a motor. And you weigh the sheet metal

 19 and it's all going to weigh about the same for a

12:03:45 20 given capacity.

 21 And the motor's cost can be different.

 22 And -- Unless there's some new things out there I

 23 haven't seen on residential-sized equipment.
 168

 1 MR. BROOKMAN: So, that would be a

 2 limited number of product classes.

 3 MR. VerSHAW: Yeah. You're probably

 4 going to look at the difference of the motors.

12:04:07 5 MR. BROOKMAN: Cyril.

 6 MR. FOWBLE: Cyril Fowble.

 7 A little bit of kind of a process

 8 question here, kind of piggybacking on the, Karim's

 9 in regard to the test procedure to start evaluating

12:04:18 10 this. It sounds like we're in a rush to, to find a

 11 test procedure here, and I'm kind of curious on

 12 what the timing for this whole thing is, because

 13 according to the Regulations, you know, 2013 is the

 14 furnace fan, you know, Rule publication date.

12:04:32 15 So, you know, we -- Is that the date?

 16 Are we accelerating this?

 17 I guess it's kind of, of -- I guess I'm

 18 worried about we're going to -- I guess my concern

 19 is we're rushing on making a decision on test

12:04:45 20 procedures so we can do a, an evaluation, versus

 21 getting a better answer, taking the time to get a

 22 better answer.

 23 MR. KHAN: Mohammed KHAN, DOE.
 169

 1 We will have a test procedure in place

 2 before the Standards Rule is complete. And, you

 3 know, we certainly recognize the difficulties

 4 involved trying to get a test procedure done in

12:05:11 5 advance enough of a standards process, but I, I

 6 guess the short answer is there will be a test

 7 procedure before the Standards.

 8 MR. BROOKMAN: Let me refer you back to

 9 Slide 49 and additional comments on these criteria.

12:05:45 10 Comments on how they might relate to DOE's

 11 construction of product classes?

 12 (Whereupon, no response was had.)

 13 MR. BROOKMAN: No additional comments.

 14 MR. JASINSKI: Good. Thank you.

12:06:06 15 I'd also like to point out that during

 16 the engineering analysis, DOE does account for

 17 proprietary designs. Any tech -- Any efficiency

 18 level or standard level that can only be achieved

 19 with the use of a single proprietary design will be

12:06:22 20 eliminated or rejected.

 21 At this time DOE seeks any comments on

 22 information about the existence of proprietary

 23 designs that may meet this criteria.
 170

 1 DR. JAKOBS: I was just curious if it

 2 meant single motor design or if that was --

 3 MR. JASINSKI: Well, I think, I think

 4 if, I think if there's a single motor design that

12:06:46 5 there's no other motor design that can, can be used

 6 as a replacement to achieve the same efficiency,

 7 that could potentially be something that we should

 8 be, we, we need to be aware of.

 9 So, if you know of a single-motor

12:07:01 10 technology that DOE should account for related to

 11 proprietary designs, --

 12 DR. JAKOBS: No, it was just

 13 Regal-Beloit provides a majority of the brushless

 14 permanent-magnet motors to our products.

12:07:19 15 MR. BROOKMAN: Nothing proprietary.

 16 That is so broad in its application -- Explain it.

 17 DR. JAKOBS: Well, I mean, there's a

 18 motor part of it, but then there's also the

 19 software.

12:07:32 20 MR. BROOKMAN: Uh-huh.

 21 DR. JAKOBS: And we don't really program

 22 the motor. We use the Regal-Beloit software, and

 23 the input we put in is more related to our
 171

 1 application, and not really controlling the motor.

 2 So, where I've had, I've had vendors

 3 come from overseas and, you know, they say, "We can

 4 sell you this motor really inexpensively. All you

12:07:57 5 have to do is design the control."

 6 That was outside of our, our area of

 7 expertise, to design the motor control. So, that's

 8 a significant aspect of these brushless

 9 permanent-magnet motors, is the control.

12:08:17 10 Did I explain that okay?

 11 MR. BROOKMAN: Yeah, I'm -- Yeah, I'm,

 12 I'm, I'm trying to -- I think it's --

 13 Describe why you're asking this question

 14 one more time, Sam.

12:08:30 15 MR. JASINSKI: The reason for asking

 16 this question is to determine if there are

 17 proprietary designs that, that enable a certain,

 18 gain an efficiency that cannot be accomplished

 19 using any other technology or any other similar

12:08:46 20 comparable design.

 21 MR. BROOKMAN: And so far Diane has said

 22 not that she knows of.

 23 MR. JASINSKI: Basically, a technology
 172

 1 that has no competition.

 2 MR. BROOKMAN: Karim.

 3 DR. AMRANE: But, you mean it exist, but

 4 we don't want one designed specially.

12:09:03 5 MR. JASINSKI: Exactly.

 6 MR. BROOKMAN: Jim.

 7 MR. VerSHAW: We, we could have one. We

 8 have a housing design that's patented that we use

 9 on air handlers, and that would be the type of

12:09:17 10 thing probably looking for here.

 11 And that's readily available through the

 12 chain of commerce.

 13 MR. JASINSKI: Okay, thank you.

 14 MR. BROOKMAN: Okay. Additional

12:09:24 15 comments on this, on Item 31 as you see listed

 16 there?

 17 (Whereupon, no response was had.)

 18 MR. BROOKMAN: Okay. So, I think we're

 19 looking to lunch.

12:09:34 20 Yeah. Shall we break for lunch?

 21 MR. KHAN: Yeah.

 22 MR. BROOKMAN: Yeah, let's do that.

 23 We've really made progress with a -- We're pretty
 173

 1 much on, right on time; perhaps a little bit ahead

 2 of schedule.

 3 It's now 10 minutes after 12:00. It

 4 takes just about an hour.

12:09:50 5 (Whereupon, remarks were made off the

 6 Record, after which the following occurred:)

 7 MR. BROOKMAN: We'll resume at 1:10 in

 8 this room.

 9 (Whereupon, at 12:10 p.m. ET, those

12:10:14 10 present took a brief recess and returned at 1:14

 11 p.m. ET, after which the following occurred:)

 12 MR. BROOKMAN: Okay, let's start. Okay,

 13 let's, let's resume.

 14 And first off, Mohammed KHAN has an

13:18:22 15 answer to an earlier question from this morning.

 16 MR. KHAN: Yeah, Mohammed KHAN, DOE.

 17 There was a question earlier regarding

 18 the, I guess the scope of coverage of the recent

 19 small-motors Rule, and I got some information

13:18:39 20 regarding that. And according to the information I

 21 have, the motors that, that that includes are

 22 capacitor start and CS/CR, capacitor

 23 start/capacitor run, CS/CR, and polyphase motors.
 174

 1 DR. JAKOBS: Now, what were those?

 2 MR. BROOKMAN: Those would be the ones

 3 that are --

 4 MR. KHAN: These are the ones that are

13:19:05 5 covered in the small-motors Rule.

 6 MR. WAGNER: He was saying the, the

 7 designation. Now, those would not be typically

 8 used in furnaces of this nature.

 9 This is Greg Wagner.

13:19:16 10 Those type of motors would not typically

 11 be used in residential type of applications.

 12 MR. KHAN: Mohammed KHAN, DOE.

 13 Just for clarification, I want to make

 14 sure that that's a statement; not a question to us.

13:19:29 15 MR. WAGNER: That's a statement. I'm

 16 sorry.

 17 MR. BROOKMAN: That's helpful. That

 18 would test all of our knowledge of motor types.

 19 MR. STEPHENS: Charlie Stephens.

13:19:38 20 MR. BROOKMAN: Charlie Stephens.

 21 MR. STEPHENS: Yeah, Charlie Stephens.

 22 I was the one that made the comment, but

 23 at the time the topic wasn't the kind I was trying
 175

 1 to suggest that those motors would be regulated,

 2 but that the evolution of those motors after the

 3 Standard would likely have some cost and/or

 4 efficiency impact on other motors that were

13:19:57 5 similar, based on my conversations with the, some

 6 of the motor manufacturers during the motors

 7 rulemaking.

 8 So, they, they didn't say that they were

 9 the same motors, but they did say that they tend to

13:20:08 10 do things the same in some ways, regardless of, you

 11 know, whether it's covered or not.

 12 MR. BROOKMAN: Okay. So then we're

 13 going to proceed.

 14 We are moving on where we left off,

13:20:18 15 which is Slide 52. Alex Lekov.

 16 MARKUPS FOR PRODUCT PRICE DETERMINATION, ENERGY USE

 17 ANALYSIS, LIFE-CYCLE COST, AND PAYBACK PERIOD

 18 ANALYSIS:

 19 DR. LEKOV: Alex Lekov, Lawrence

13:20:26 20 Berkeley National Laboratory.

 21 So, finishing engineering analyses and

 22 starting consumer impacts. So, for the life-cycle

 23 cost analysis there are several components.
 176

 1 We'll start with mark-ups. So, what's

 2 the purpose?

 3 Determine consumer furnace fan prices

 4 based on manufacturing costs. Characterize furnace

13:20:50 5 fan distribution channels and market segments.

 6 The method DOE plans to apply: Estimate

 7 the consumer prices by applying mark-ups consisting

 8 of distribution channel mark-ups and sales tax to

 9 manufacturer sales-price estimates.

13:21:11 10 Just to put this in front, the method is

 11 very much the same as most you heard related to

 12 previous rulemaking and meetings you attended. So,

 13 the inputs for development of the mark-ups will be

 14 based on financial statements for wholesalers who

13:21:35 15 will be using the most current available HARDI

 16 Profit Survey Report, and for contractors who will

 17 be using the, who'll be using the ACCA Financial

 18 Analysis for the HVACR Contracting Industry.

 19 In addition, DOE will use the U.S.

13:21:54 20 census data mentioned here. The mark-ups

 21 themselves will be defined in two categories,

 22 baseline and incremental mark-up.

 23 And the baseline mark-ups relate price
 177

 1 to costs prior to a change in efficiency, and the

 2 incremental mark-ups relate the incremental change

 3 in consumer price to the incremental change in cost

 4 of goods sold.

13:22:33 5 This slide shows the distribution

 6 channels that DOE plans to assess. The upper part

 7 relates to the replacement market; the lower part

 8 to the new-construction market.

 9 Basically we have furnace fan product

13:22:57 10 manufacturer, distributor, and mechanical

 11 contractor. Similarly, for the new-construction

 12 market, instead of mechanical contractor, looking

 13 at the general contractor.

 14 And with that, DOE requests comments on

13:23:16 15 the planned distribution paths; also some feedback,

 16 as well as the feedback on the other mark-ups.

 17 MR. BROOKMAN: So, you can see on the

 18 preceding slides, 53 and 54, the content that DOE

 19 would like comments on.

13:23:40 20 Bryan, you want to start? You gave me

 21 that look.

 22 MR. ROCKY: Sure. Bryan Rocky.

 23 As a distribution channel for the
 178

 1 furnace or an air handler, no com-, no questions,

 2 no discussions that need to be made. I think the

 3 model is appropriate.

 4 As distribution channel for furnace air

13:24:02 5 handler fan assembly, there are several things that

 6 have to come up. And there's -- That can make a

 7 huge difference to a cost to a consumer.

 8 And that can be as -- Generally

 9 speaking, a consumer is only going to purchase a

13:24:18 10 fan assembly when they have a failure and the unit

 11 is out of warranty, generally speaking.

 12 There are appliances, or, excuse me,

 13 blower assemblies, fan assemblies that are sold in

 14 our industry from a motor manufacturer as a

13:24:34 15 replacement or a fan kit, but that, relatively

 16 speaking, is very low volume, versus the entire

 17 product that's sold that uses furnace fans, either

 18 air handlers or furnaces.

 19 And so now you're talking about a

13:24:53 20 distribution channel that, if you're in a warranty

 21 situation, doesn't matter what the cost is because

 22 the manufacturer's going to replace it under

 23 warranty. And if you're in a nonwarranty
 179

 1 situation, the homeowner has very little choice.

 2 Because of the design parameters, as

 3 we've already talked about, with motors, wheels,

 4 blower assemblies structured to the particular

13:25:15 5 design of the equipment, you can't usually just go

 6 get a generic assembly to be replaced or to be

 7 bought to be used.

 8 So, in those situations you're not going

 9 to go to use, you know, to Lennox to buy any fan

13:25:34 10 assembly for a York furnace.

 11 MR. BROOKMAN: There's another stop

 12 between the distributor and the mechanical

 13 contractor?

 14 MR. ROCKY: It's -- You know, you're

13:25:44 15 looking at distribution channels. And if it's a

 16 warranty replacement, it's to the manufacturer.

 17 If it's a nonwarranty, it's still back

 18 to the original manufacturer. And cost of that

 19 component, it's up to what the market bears, not to

13:26:02 20 a relative measurement because it's more efficient

 21 or less efficient.

 22 It's: This is what has got to go into

 23 that product. So, your distribution parameters are
 180

 1 slightly modified.

 2 Your cost parameters are slightly

 3 modified. You know, this becomes irrelevant in a

 4 lot of applications.

13:26:20 5 MR. BROOKMAN: You go ahead, Molly,

 6 please.

 7 MS. TROMBLEY-McCANN: Molly

 8 Trombley-McCann.

 9 So, I just wanted to try and clarify.

13:26:26 10 Does that mean that essentially your fan breaks,

 11 you go to a mechanical contractor and the

 12 mechanical contractor goes directly back to the

 13 manufacturer to get replacement parts?

 14 MR. ROCKY: Yes.

13:26:38 15 MS. TROMBLEY-McCANN: Okay.

 16 MR. ROCKY: I mean, you're going to -- A

 17 homeowner isn't going to purchase this. You're

 18 going to go to your contractor, to your -- The path

 19 is correct, but there's no choice.

13:26:49 20 There's very limited -- I mean, I can't

 21 go and, and for the most part get a complete fan

 22 assembly. You can get a replacement motor that are

 23 universal replacement motors.
 181

 1 You can buy wheels from different

 2 manufacturers, and generally they're going to be

 3 fairly close to the performance. But, we're

 4 talking about the fan assembly, the entire

13:27:08 5 component: blower, motor, wheel, capacitors, the

 6 whole package.

 7 There aren't a lot of choices out there,

 8 what's available. You go to the manufacturer; you

 9 pay what they charge you.

13:27:18 10 MR. BROOKMAN: Alex.

 11 DR. LEKOV: Just so -- So, to highlight

 12 that, you emphasized -- And on the, in the

 13 replacement market you emphasized the case when

 14 basically the blower assembly will be replaced

13:27:34 15 only. But, it also includes the case when the

 16 entire furnace product will be replaced.

 17 So, as such, the furnace fan is, as part

 18 of the product, will go through the, this

 19 replacement channel.

13:27:53 20 MR. ROCKY: The -- Alex, the channel is

 21 correct, but the impact on it is, is almost

 22 nonsensical for a furnace fan assembly. People

 23 don't replace furnace fans because it's a more
 182

 1 efficient furnace fan, with very, very few

 2 exceptions, one being mobile-home add-on air

 3 conditioning that wasn't part of the original

 4 design being about the only application that I'm

13:28:18 5 aware of.

 6 MR. BROOKMAN: Okay, thank you.

 7 Please say your name.

 8 MR. GEE: Talbot Gee, with HARDI.

 9 I wanted to just explain on this, and

13:28:26 10 represent a distribution channel. I'd agree that

 11 the channel itself doesn't change.

 12 I think the finer point on it is the

 13 mark-up analysis won't carry over like it would for

 14 other products here because, for example, if a York

13:28:40 15 dealer, for example, is called in on a service call

 16 for a Carrier system and the furnace assembly is,

 17 needs to be replaced, that dealer may still be able

 18 to do the replacement, but that -- And they may be

 19 able to resource it from their traditional

13:28:58 20 distributor.

 21 However, the distributor probably had to

 22 go source that product from the original Carrier

 23 and, and work it that way. There's not the sort of
 183

 1 negotiated price, and, like you would have on a

 2 regular stocked product.

 3 I think the channel is correct. I'd

 4 point out that if you're talking about "general

13:29:15 5 contractors" meaning more like builders, they're

 6 not going to be playing in this market.

 7 This is an after-market replacement

 8 mechanical contractor.

 9 MR. BROOKMAN: Okay.

13:29:26 10 Jim.

 11 MR. VerSHAW: Jim VerShaw.

 12 If you get a failure on a replacement, I

 13 mean, most, most furnace manufacturers don't allow

 14 a different fan assembly to be put into their

13:29:41 15 furnace because we're not sure the safeties will

 16 work. So, fundamentally, if you have got a PSC

 17 motor, you can get a PSC motor replaced, and that's

 18 pretty good.

 19 But, if you have the other, you have to

13:29:54 20 get the one that the manufacturer designed and

 21 programmed, because otherwise it's not going to

 22 work the same. So, it's going to be -- It's not

 23 quite straight-forward in that respect.
 184

 1 MR. BROOKMAN: Terry, go ahead.

 2 MR. SMALL: I'd just like to point out

 3 that, again, the product class can be important

 4 here. As Bryan said, on mobile-home products, they

13:30:12 5 go through a completely different channel.

 6 The furnaces come out of a furnace

 7 factory like Bryan's with a heating blower in.

 8 They're installed in a mobile-home factory that

 9 builds the home.

13:30:26 10 They go out to the site, and if air

 11 conditioning is added, there could very well be a

 12 conversion blower kit that is coming from a

 13 distributor, along with maybe an air-conditioning

 14 coil and an outdoor air-conditioning unit.

13:30:43 15 So, just a point that I think the, the

 16 distribution channel can be quite different,

 17 depending on the product.

 18 MR. BROOKMAN: Okay.

 19 Diane.

13:30:52 20 DR. JAKOBS: I just wanted to say I

 21 heard a complaint from, that distributors don't

 22 always, because of the large number of motor

 23 programs, they don't always stock all of the
 185

 1 possible programs. We might, like, over the years

 2 probably have, like, 35 or something.

 3 And then you'll have to have something

 4 sent air freight if you want to replace your motor

13:31:19 5 for, you know, or wait a week or two. So, there's

 6 a complaint that they're expensive.

 7 But, also you have to take this motor,

 8 you have to take, pay for freight, air freight to

 9 get it replaced in a timely manner.

13:31:33 10 MR. BROOKMAN: Okay. Other comments on

 11 these, these two slides?

 12 Take a look at 53 and 54. You, you will

 13 note that the Department also requested comment on

 14 the mark-up slide, 53.

13:31:47 15 I guess if -- What would you say about

 16 that having the page that is missing? Okay.

 17 DR. LEKOV: So, the next components are

 18 the energy use analysis. The purpose: To identify

 19 the energy use of furnace fans in the field, and

13:32:16 20 the energy savings potential of energy-efficient

 21 improvements.

 22 So, here in four steps are outlined the

 23 preliminary methods placed essentially on the
 186

 1 furnace case. They -- DOE plans to estimate the

 2 household heating and/or cooling load using

 3 adjusted heating/cooling equipment energy use for

 4 RECS 2005; with the calculated heating/cooling load

13:32:49 5 will determine that heating/cooling equipment

 6 operating hours.

 7 The equipment operating hours means

 8 furnace end-product operating to estimate furnace

 9 fan operating hours at each active mode and with

13:33:08 10 the fan operating hours, the fan electricity

 11 consumption will be determined for each considered

 12 efficiency level.

 13 MR. BROOKMAN: Yes, Diane.

 14 DR. JAKOBS: I was wondering. To do

13:33:24 15 that, I would think you'd need to make some kind of

 16 assumption about the ductwork, what kind of static.

 17 And also, we've been selling ECM motors for many,

 18 many years, so I'm kind of split in the

 19 distribution of motors.

13:33:40 20 I look at the RECS 2005, and they talk

 21 about heating and cooling loads, and square feet.

 22 And I didn't see anything like that.

 23 DR. LEKOV: Those components, the
 187

 1 analysis you mention will be applied. In fact, if

 2 you look back in the 2007, the Rule, those were

 3 part of it.

 4 DR. JAKOBS: Oh, okay.

13:34:03 5 DR. LEKOV: We'll -- The DOE will apply

 6 all those considerations.

 7 DR. JAKOBS: Okay.

 8 MR. BROOKMAN: Okay.

 9 Jim.

13:34:12 10 MR. VerSHAW: Jim VerShaw.

 11 Once again, I don't think you ought to

 12 be looking at cooling as part of the energy you're

 13 saving, because if you switched motors, you

 14 switched furnaces, and therefore you'd probably go

13:34:26 15 to the, the Ratings Directory and find out the

 16 rating of that furnace with ECM, because those are

 17 usually rated because they're, they have a, they,

 18 they give you a higher rating than you can with a

 19 PSC motor.

13:34:40 20 So, again, I feel like you're, you're

 21 double-counting on the cooling side. You just want

 22 to focus on, on the heat.

 23 MR. BROOKMAN: Okay.
 188

 1 Charlie Stephens.

 2 MR. STEPHENS: I've -- Somebody can tell

 3 me if I'm wrong, --

 4 Charlie Stephens here.

13:34:59 5 -- but I think the, the way I understood

 6 this is that you would have a diminished number of

 7 combinations for cooling for a heat pump system,

 8 say, or an air-conditioning system to choose from

 9 if, if a certain number of the indoor units were

13:35:15 10 too low in efficiency to qualify under the furnace

 11 fan Standard.

 12 So, your choices as a replacement or as

 13 a new-construction piece of a system would not

 14 include combinations that had certain fans

13:35:29 15 associated with them. So, I think the savings

 16 would probably show up there.

 17 Cooling, certainly, for a heat pump,

 18 because you, you can no longer select a system that

 19 -- I mean, you can take your savings however you

13:35:45 20 want, but it, it changes the range of savings.

 21 There's some interaction here that I --

 22 And this is why I think people can correct me if

 23 I'm wrong, but I don't think we've necessarily
 189

 1 established what the ratings would be for a heat

 2 pump or a, or an air-conditioning system if we used

 3 the actual performance of the air handler instead

 4 of the default values in the ratings that are

13:36:09 5 currently used there.

 6 MR. BROOKMAN: Jim.

 7 MR. VerSHAW: The amount of power that

 8 the air, air handler uses in a, an air conditioner

 9 or, either heating or cooling mode, is included in

13:36:21 10 the SEER. So, if you, if you assume that you're

 11 going to change a furnace fan, just put a furnace

 12 fan efficiency standard is going to safe

 13 electricity in the furnace fan, then are you going

 14 to increase the SEER requirements as a result?

13:36:35 15 Because you, you, we've got a minimum

 16 SEER that you have, and I think that's, as sold,

 17 meets that. So, the -- So, I think you, you'd be,

 18 be double-counting if you start looking at cooling.

 19 MR. BROOKMAN: Karim.

13:36:50 20 DR. AMRANE: Karim Amrane, AHRI.

 21 I guess, according to Charlie, I mean,

 22 for a heat pump and for, for an air conditioner

 23 with a blower core it's not the default value that
 190

 1 you use to calculate the SEER. You use the actual

 2 power of the, of the, of the fan.

 3 So, so, it's not, it's not the default

 4 value.

13:37:11 5 MR. BROOKMAN: Charlie?

 6 MR. STEPHENS: Charlie Stephens.

 7 No, I actually wasn't speaking about the

 8 SEER rating. I go -- I was thinking about the

 9 hours.

13:37:21 10 And if you were calculating the actual

 11 energy use, like in a gas furnace, for instance,

 12 you have an EAE that's based on defaults.

 13 MR. BROOKMAN: Okay.

 14 MR. STANONIK: National average.

13:37:33 15 MR. BROOKMAN: Okay. So, any additional

 16 comments on this method that is described in Slide

 17 57?

 18 Yes, Cyril.

 19 MR. FOWBLE: Cyril Fowble.

13:37:43 20 Only concern is similar to one that

 21 we've raised previously in other rulemakings about

 22 the, as -- I won't say "accuracy," but the, the

 23 reasonableness of that, of the RECS 2005 data.
 191

 1 There's been a lot of programs, tax, tax credits in

 2 2005, -six, -seven.

 3 We've had the big ones in the last

 4 couple of years with the significant dollars. I

13:38:06 5 think, you know, that data's not going to include

 6 the shipments of high-efficiency blower systems of

 7 furnaces or air-handling devices.

 8 So, we talked about the RECS 2009 data,

 9 whatever, but certainly a more recent version. Or

13:38:20 10 look at HRI shipments or something like that to

 11 determine the increase to actually reduce the

 12 amount of energy consumed today for furnace fans.

 13 MR. BROOKMAN: Okay, thank you.

 14 Greg.

13:38:30 15 MR. WAGNER: Greg Wagner.

 16 There was discussion here that the

 17 remaining hour's going to be assigned to the

 18 continuous-run, continuous ventilation. If you do

 19 have that, then I guess what's the point of standby

13:38:46 20 power?

 21 And, and probably it was in the, in 7.2.

 22 It's not on the slide, but it was under the

 23 description of how the evaluation was going to be
 192

 1 undertaken; that there will be heating hours,

 2 cooling hours, and the remaining would be

 3 ventilation.

 4 If you do that, then there's no time for

13:39:07 5 standby, I guess.

 6 DR. LEKOV: And as I explained this

 7 morning, DOE does not plan to assess the standby

 8 power.

 9 MR. WAGNER: Okay. So, the rest of it

13:39:17 10 will be in continuous run?

 11 What portion --

 12 DR. LEKOV: That's in --

 13 MR. WAGNER: What portion of the

 14 population does operate in continuous mode?

13:39:25 15 DR. LEKOV: DOE plans to determine this.

 16 MR. WAGNER: So, that will be part of

 17 the Rule, to identify the portion of that?

 18 DR. LEKOV: Obviously, yes.

 19 MR. BROOKMAN: Final comments?

13:39:36 20 (Whereupon, no response was had.)

 21 DR. LEKOV: So, those are the DOE's

 22 comments, requests for comments. So, one of the

 23 comment was the planned approach for determining --
 193

 1 I believe we got some comments, and the other one

 2 is:

 3 Usually for this type of equipment DOE

 4 also looks at potential rebound effect, and

13:40:12 5 wonders, in the case of furnace fan, whether such,

 6 such thing as a rebounded effect should be

 7 considered separately for this product, just to

 8 remind that it's going to be applied for the

 9 furnaces and for the central AC.

13:40:31 10 MR. BROOKMAN: Frank?

 11 MR. STANONIK: Just a, a quick comment

 12 on that. I mean, the, the, in the case of the

 13 furnace, the rebound effect is theoretically driven

 14 because the consumer wants to be more comfortable,

13:40:50 15 and so, since they have perceived that they're

 16 using less energy, they turn up their thermostat to

 17 be warmer.

 18 I think the question that somehow the

 19 consumer's going to react because their blower is

13:41:00 20 using less electricity and somehow be some rebound

 21 effect is, it, there's no connection there. I

 22 think in this particular analysis there isn't.

 23 You know, the idea of rebound doesn't
 194

 1 fit.

 2 MR. BROOKMAN: Diane.

 3 DR. JAKOBS: I, I found a report from

 4 Wisconsin, and it was April, 2009. But, but they

13:41:19 5 said that there was a rebound effect in respect

 6 that people go from not having, using continuous

 7 fan, to using continuous fan.

 8 So, they were saying that the, if you

 9 replace a PSE furnace with an ECM furnace, and you

13:41:38 10 switch it to continuous operation, you're entirely

 11 negating the energy use, and energy use actually

 12 increases.

 13 DR. LEKOV: If this is --

 14 DR. JAKOBS: So, if that's --

13:41:49 15 DR. LEKOV: Just a question. If this is

 16 related, Wisconsin report relates to the entire fan

 17 product, or to the fan itself?

 18 DR. JAKOBS: They had -- They were just

 19 monitoring furnaces with ECM motors.

13:41:57 20 MR. BROOKMAN: Right.

 21 DR. LEKOV: I remember the earlier

 22 version of the report, the, the 2003, and all the

 23 assessments were related to the furnace fan as
 195

 1 opposed to the entire furnace. So, I wonder about

 2 this.

 3 DR. JAKOBS: Oh, I, I --

 4 MR. WAGNER: Either way, it's part of

13:42:18 5 the furnace and its use, and the report was about

 6 use of the furnace in, you know, people's homes,

 7 and what they've done. And that gets back to the

 8 question I asked a moment about, ago about

 9 continuous run.

13:42:32 10 If you're considering them to be

 11 continuous run, there won't be any rebound effect

 12 because there's no more hours to be run in a year.

 13 And so it's another -- One way or another, I guess,

 14 I really need to have an understanding of what the

13:42:46 15 percentage of folks do use continuous-run versus

 16 noncontinuous-run users, --

 17 MR. BROOKMAN: Okay.

 18 MR. WAGNER: -- because it's 2,000

 19 hours, more or less, heating/cooling; 6,000 hours

13:43:00 20 continuous run outside of that, or --

 21 (Whereupon, at 1:43 p.m. ET, Mr. Wagner

 22 and Dr. Jakobs conferred, out of the hearing of

 23 others and off the Record, after which the
 196

 1 following occurred:)

 2 MR. BROOKMAN: Okay. Okay.

 3 DR. LEKOV: Focus on the entire scope of

 4 the life-cycle costs and payback period analysis.

13:43:14 5 So, here is a slide explaining the general

 6 approach.

 7 So, the purpose is to assess the next

 8 life-cycle cost impact and the payback for the

 9 consumers of residential furnace fans under the

13:43:27 10 considered efficiency levels. And the method

 11 essentially is what it does is equals the cost to

 12 install, plus the sum of operating cost was

 13 discounted to the particular base year.

 14 (Whereupon, at 1:43 p.m. ET, Msrs. Burt

13:43:40 15 and Bacchus conferred, out of the hearing of others

 16 and off the Record, during which the following

 17 occurred:)

 18 DR. LEKOV: Analysis will model the

 19 uncertainty and variable input using the Monte

13:43:49 20 Carlo approach and probability distribution, and

 21 implemented in an MS Excel format combined to the

 22 Crystal Ball software.

 23 That's -- This slide shows the entire
 197

 1 flow of DOE's LCC analysis. So, the bottom -- The

 2 top part is explaining the parameters that are

 3 needed to determine the total install costs, and

 4 the bottom part is related to the operations costs.

13:44:26 5 I'll very quickly say that yellow boxes

 6 are inputs. The green boxes are intermediate

 7 calculations, and the final rounds that are

 8 reported in blue.

 9 Some of the parameters I'll be

13:44:44 10 discussing in the next slides. Starting with

 11 energy prices, as you see here, energy prices in

 12 combination with energy consumptions, which has

 13 been explained, are used to determine the annual

 14 energy costs.

13:45:08 15 So, DOE will use the monthly energies

 16 price from the most recent EIA data for each of the

 17 census division to establish appropriate energy

 18 prices for each sampled household.

 19 The -- In addition to this, DOE will use

13:45:26 20 projections of national average residential energy

 21 prices to forecast the future energy prices. And

 22 usually it comes with the most current version of

 23 the EIA's annual energy outlooks.
 198

 1 And, again, it does not differ from what

 2 you know from previous meetings related to furnaces

 3 and central AC. Another important component of the

 4 life-cycle costs are the determination of the

13:46:07 5 discount rate.

 6 The discount rates are used to determine

 7 the present value of the lifetime operating

 8 expenses. The way DOE determines the discount rate

 9 is from the estimates of the fi-, finance cost to

13:46:25 10 purchase the products.

 11 The main tool to do this is the Federal

 12 Reserve Board's Survey of Consumer Finances.

 13 That's a tri-annual survey.

 14 DOE uses multiple versions, starting

13:46:43 15 from 1989, up to the most current one. I also say

 16 this each workshop.

 17 The costs were taken from over 200 data

 18 points. Very solid.

 19 Used by many organizations. And it's,

13:47:01 20 actually allows to determine the financial cost of

 21 any debt incurred.

 22 Also has the opportunity, cost of any

 23 equity used. And with that, DOE arrives with the
 199

 1 real interest rates that are used in this

 2 calculation.

 3 MR. BROOKMAN: Yes, Jim.

 4 MR. VerSHAW: Jim VerShaw.

13:47:36 5 I guess I'm having a bit of a problem

 6 with the Monte Carlo approach on, on the life-cycle

 7 costs and payback. Usually when you do a Monte

 8 Carlo approach you're determining the effect of

 9 variability in a, in a dimensional fit on, for, on

13:47:51 10 performance on something.

 11 But, you're starting with, with

 12 something you've guessed at, and through, through

 13 analysis. And so I'm sure -- I'm trying to figure

 14 out how, how you know the Monte Carlo approach is

13:48:03 15 verifying that you had the right numbers up front.

 16 It seems like it's, it may not be worth

 17 the effort on this, but, because it, it doesn't

 18 really tell you whether or not you had your

 19 initial, your initial estimates were in the right

13:48:16 20 range. It just tells you how much variability in

 21 your, in your initial estimates does to what your

 22 final answer is.

 23 DR. LEKOV: Let me try to summarize,
 200

 1 essentially starting with basic sort of route. DOE

 2 uses RECS, Residential Energy Consumption Survey,

 3 which, --

 4 MR. VerSHAW: Which, which, which --

13:48:41 5 DR. LEKOV: -- which provides household

 6 characteristics and some characteristic of the HVAC

 7 systems for representative number of households;

 8 let's say roughly 3,000.

 9 That three percent of million U.S.

13:49:01 10 household with this type of equipment.

 11 MR. VerSHAW: Isn't, isn't RECS

 12 fundamentally basically through States?

 13 DR. LEKOV: Not true.

 14 MR. VerSHAW: Umm.

13:49:08 15 DR. LEKOV: It's a statistical example.

 16 So, starting from there, and as well as on other

 17 multiple sources that usually explain how it is

 18 this, there are all the parameters in the

 19 calculation, or most of the parameters are

13:49:35 20 presented by probability distributions with, each

 21 of them with specific references.

 22 And from there, basically you derive

 23 different cuts of the population impacts. So, the
 201

 1 answer to your question is the math that has been

 2 applied to multiple products over the years.

 3 It went through multiple reviews,

 4 including high-level government reviews and third

13:50:17 5 parties. So, --

 6 MR. VerSHAW: Okay.

 7 DR. LEKOV: -- that's for now.

 8 MR. VerSHAW: Okay.

 9 MR. BROOKMAN: Okay.

13:50:26 10 MR. VerSHAW: The, the other problem I

 11 have is on discount rates. And I don't see -- You

 12 say you're going to calculate one, and usually they

 13 come out low based upon the amount of credit the

 14 people had, and if they needed to buy a new

13:50:43 15 furnace, if they had to put it on a credit card.

 16 So, I think you need to look at that.

 17 DR. LEKOV: So, there are two points to

 18 bring. First, it's based on a real representative

 19 example.

13:50:54 20 For example, the rates are coming higher

 21 than they were the last six years. Also, the

 22 second point to bring is those, the numbers you see

 23 not for this, not developed for this product yet,
 202

 1 but usually -- Not usually.

 2 They are real, so they don't account for

 3 the inflation, so basically are much higher than

 4 the numbers you, you see.

13:51:23 5 MR. VerSHAW: Umm.

 6 DR. LEKOV: Very -- Another big part of

 7 the LCC analysis are the installation, maintenance,

 8 and repair. In the case of furnace fans, the DOE

 9 does not plan to estimate installation costs

13:51:42 10 because they considered are part of the

 11 manufacturer cost of a furnace.

 12 And in terms of maintenance and repair,

 13 DOE will evaluate how maintenance and repair costs

 14 change with increased efficiency for furnace fans.

13:52:02 15 They are -- DOE plans to look at how it's made;

 16 manufacturer literature, specialty consultants.

 17 As for products, DOE will account for

 18 regional differences in labor costs. And one

 19 component that DOE plans to look at is to include

13:52:20 20 the installation of a replacement furnace fan --

 21 (Whereupon, at 1:52 p.m. ET, Msrs. Burt

 22 and Bacchus conferred, out of the hearing of others

 23 and off the Record, during which the following
 203

 1 occurred:)

 2 DR. LEKOV: -- and the appropriate

 3 methods and data sources for assessing changes in

 4 installation costs and repair for more efficient

13:52:35 5 furnaces.

 6 MR. BROOKMAN: Bryan.

 7 (Whereupon, at 1:52 p.m. ET, Dr. Amrane

 8 and Mr. Stanonik conferred, out of the hearing of

 9 others and off the Record, during which the

13:52:40 10 following occurred:)

 11 MR. ROCKY: First, I think there is no

 12 cost differences for furnace fan efficiencies.

 13 It's a blower, a motor, and a wheel.

 14 All you ever do with it is basically

13:52:52 15 clean the wheel as a maintenance aspect in the

 16 field. We don't oil motors, for the most part,

 17 anymore.

 18 We don't do anything with it on. So,

 19 maintenance costs are zero.

13:53:03 20 MR. BROOKMAN: And no differences,

 21 difference between different types of motors?

 22 MR. ROCKY: Doesn't matter. The motor

 23 type, the blower type, the manufacturer type --
 204

 1 It's not a factor anymore.

 2 Now, the repair costs, again, is a huge

 3 different question, and I'll take it back to the

 4 previous testimony, in warranty versus out of

13:53:23 5 warranty. And take the higher costs of a higher

 6 efficiency ECM motor can go from double to triple

 7 to four times the cost of the replacement of a PSC

 8 motor.

 9 It's the design of the whole assembly.

13:53:39 10 It's the programming of the motor.

 11 It's all these other things that we've

 12 talked about that impact the cost of a replacement

 13 fan assembly out of warranty. That's what the

 14 market bears.

13:53:50 15 It's not what the cost is. It's what

 16 the contractor chooses to charge that homeowner.

 17 We have nothing to do with that.

 18 MR. BROOKMAN: Okay.

 19 DR. LEKOV: A question?

13:54:02 20 MR. ROCKY: Yes, sir.

 21 DR. LEKOV: If there is a case when

 22 this, the consumer will decide, "Okay, replacing

 23 this motor looks very expensive. Shall I replace
 205

 1 the furnace outright?"

 2 MR. ROCKY: Yes, that actually can

 3 happen with today's product. But, that has -- That

 4 is now tied in generally with a replacement on an

13:54:28 5 efficiency basis for the furnace, or a system

 6 replacement basis for a higher SEER, higher HSPF

 7 unit.

 8 It's, it's not going to be the same

 9 situation as saying, "I have to spend $600 for a

13:54:43 10 few fan assembly. Should I spend 1,200 or 2,000

 11 for a new furnace?"

 12 Homeowner, if he's going to get into

 13 that situation, they're most likely to go to the

 14 least-cost option. And they'll pay 650 for the

13:55:02 15 replacement fan assembly rather 2- or $3,000 for a

 16 new furnace.

 17 MR. BROOKMAN: Okay. Okay, any other

 18 comments on, on this slide?

 19 (Whereupon, no response was had.)

13:55:14 20 MR. BROOKMAN: Okay.

 21 DR. LEKOV: The next component you put

 22 to LCC and the furnace lifetimes, DOE plans to use

 23 information from various literature sources and
 206

 1 industry experts, and input from manufacturers and

 2 other interested parties to determine a range for a

 3 lifetime for these fans.

 4 Comments?

13:55:40 5 MR. BROOKMAN: Lifetimes.

 6 DR. JAKOBS: Numbers?

 7 MR. ROCKY: This is Bryan Rocky.

 8 In general, a furnace fan is going to

 9 last the life of a furnace. So, using the same

13:55:55 10 standard number as used in other rulemakings for

 11 lifetime of furnaces or any of those others would

 12 seem appropriate.

 13 However, I would add there's one caveat

 14 to that. If you are in an area that the power grid

13:56:09 15 has severe fluctuations or is susceptible to

 16 lightning strikes, it is known statement in our

 17 industry that ECM motors, because of the complexity

 18 of the controls, have a lesser expected life due to

 19 variations in the power grid and lightning strikes

13:56:27 20 and other things, because of the things that are

 21 there.

 22 MR. BROOKMAN: Jim.

 23 MR. VerSHAW: Yeah. I think the
 207

 1 approach is appropriate.

 2 MR. BROOKMAN: Okay. Diane?

 3 DR. JAKOBS: The only other thing I

 4 could think of that the same restrictive ductwork

13:56:46 5 is bad for the life of the motors. So, generally

 6 it's bearing life.

 7 And so if it's oversized and it's

 8 starting and stopping a lot, that's bad for the

 9 bearings. If it's over-temperature it's bad for

13:57:03 10 the bearings and that will shorten the motor life.

 11 MR. BROOKMAN: Okay. Okay.

 12 DR. LEKOV: DOE will also develop an

 13 energy efficiency base case so the, the developing

 14 of the projected market share of products for

13:57:22 15 market efficiency under the base case will be

 16 determined in this analysis, and DOE will use data

 17 on the recent market trends in residential furnaces

 18 and air-conditioner and impacts of the Energy Star

 19 program and other policies that may impact demand

13:57:41 20 for more efficient furnace fans.

 21 As some -- Well, just to enhance the

 22 slide here, this morning was a pretty extensive

 23 discussion of the increased penetration of ECM
 208

 1 design models over the last five, of the last two

 2 years. Very different from what DOE did in 2007.

 3 MR. BROOKMAN: So, comments on

 4 appropriate distribution rates for residential

13:58:16 5 furnace fans in the absence of amended energy

 6 conservation standards?

 7 Yes, Greg.

 8 MR. WAGNER: Well, I was just going to

 9 say again, if you don't have a, a way to establish

13:58:27 10 what the base case is, I'm, I'm still -- We're

 11 trying to establish what the test parameters are.

 12 How do you do the distribution without

 13 understanding the base case?

 14 MR. BROOKMAN: Diane.

13:58:38 15 DR. JAKOBS: I found another -- There is

 16 a place in Wisconsin, they were keeping track of

 17 ECM furnaces --

 18 (Whereupon, at 1:58 p.m. ET, Mr. Burt

 19 left the room, after which the following occurred:)

13:58:46 20 DR. JAKOBS: -- and they, they said it

 21 was 28 percent market share.

 22 MR. BROOKMAN: Oh, okay. Good.

 23 So do you have that data?
 209

 1 DR. JAKOBS: (Nodded no.)

 2 MR. BROOKMAN: Okay.

 3 Okay, other comments?

 4 Charlie.

13:58:58 5 MR. STEPHENS: Charlie Stephens.

 6 I'll just add that it's going to be

 7 pretty variable, depending on where you go in the

 8 country. Three years ago, or four years ago, in

 9 Oregon, it was 83 percent variable-speed, 90s in

13:59:13 10 replacement, and 14 percent new construction.

 11 And now it, it's about 80-some percent

 12 in new construction as well. So, you're going to

 13 find a huge range, I think, when you go out and

 14 look.

13:59:26 15 And, and, and, and I believe it would be

 16 a big help to the manufacturers to be, ultimately

 17 to put some kind of cross-section of what's

 18 happening. If the shippers are only shipping 40

 19 percent, the data you add up is going to be 60.

13:59:43 20 So, at the very least I'd hope that the

 21 manufacturers help with the cross-check to make

 22 sure that what is arrived at sounds appropriate.

 23 DR. LEKOV: Just to let you know that
 210

 1 DOE provides the opportunity to do this by census.

 2 So, in case DOE retains information that indicates

 3 the regional differences for the energy

 4 distribution, those will be definitely considered.

14:00:12 5 MR. BROOKMAN: Okay.

 6 DR. LEKOV: From impacts on the

 7 consumers, they're going to switch to the national

 8 impacts, starting with the shipment analysis that

 9 will, I'll say, change components of the initial

14:00:31 10 impact analysis.

 11 So, DOE plans to estimate the furnace

 12 fan shipment in the base case and the all-standard

 13 cases. The method will apply accounting

 14 methodology to determine several market segments.

14:00:50 15 At this time DOE thinks about a

 16 replacement in kind. It means replacement with the

 17 same equipment type; new housing installations;

 18 conversions from noncentral heating to central

 19 heating; and then retrofitting into existing

14:01:09 20 furnaces and cooling products if the fan fails.

 21 DOE intend to evaluate whether standards

 22 that require more efficient furnace fans would have

 23 an impact on the number of fans shipped. DOE can
 211

 1 also see the application of this parameters that

 2 relate to changes in shipment quantities to changes

 3 in the install costs for products.

 4 MR. VerSHAW: Question.

14:01:36 5 MR. BROOKMAN: Jim.

 6 MR. VerSHAW: Jim VerShaw.

 7 When you say "fan retrofits into

 8 existing furnaces," are you talking about just a

 9 straight in-kind change-out, or are you talking

14:01:45 10 about changing it from one fan type to another, or

 11 one fan efficiency to another one?

 12 Because fundamentally I don't think any

 13 furnace manufacturer would want a different motor

 14 or different fan put in their furnace because of

14:02:00 15 all the safeties that are involved.

 16 DR. LEKOV: The issue here is over the

 17 analysis period may be needed to replace the

 18 furnace before the, the entire period. All the

 19 parameters are calculated at distrib-, as probably

14:02:20 20 distributions.

 21 So, you have the lifetime of the entire

 22 furnace product. You have a lifetime distribution

 23 of the furnace fan.
 212

 1 So, the, this one, the replacement in

 2 kind, it's essentially --

 3 MR. VerSHAW: No, I was talking to the

 4 fourth one down.

14:02:39 5 DR. LEKOV: That relates, the fourth one

 6 is directly the replacement situation in case of

 7 failure, like I was explaining, the replacement

 8 slide.

 9 That case, whatever is available, either

14:02:50 10 the same kind, PSC with PSC, or if the analysis

 11 determined that the existing product that's allow

 12 the switch, the switch will be considered.

 13 MR. VerSHAW: There won't be many of

 14 those.

14:03:10 15 MR. BROOKMAN: Greg.

 16 MR. WAGNER: Yeah. I was going to say I

 17 think that the concept of somebody building a fire

 18 in your basement is what your furnace is, and

 19 there's a lot of strict controls over those

14:03:22 20 products, including the safety features Jim was

 21 just talking about.

 22 So, there's not going to be a lot of

 23 difference of rated changes occurring within
 213

 1 retrofits, for safety reasons.

 2 DR. LEKOV: Do I understand it to the

 3 answer is that DOE will investigate whether

 4 products, kits exist for replacements, let's say,

14:03:43 5 from PSD to ESM? If not, we feel --

 6 MR. BROOKMAN: Talbot Gee.

 7 MR. GEE: Talbot Gee.

 8 First of all, I apologize I have to

 9 leave so I won't get to hear the scintillating head

14:03:59 10 to these arguments. But, I think this is the way I

 11 look, I try to look at any of these rulemakings to

 12 figure out how any of my members would implement,

 13 market, or install, or lead to the installations of

 14 whatever the outcomes.

14:04:16 15 I have to admit, I'm failing to

 16 understand the value of this exercise. I

 17 understand you're under Statute to do so, but you

 18 know our members who are responsible for training

 19 and educating most of their contractors really

14:04:33 20 focus on the whole program's reliance on AHRI

 21 Directory.

 22 And that would be what would determine

 23 what replacements you would do in these failure
 214

 1 situations. And if you can't make the match, it's

 2 probably because the system's so old it really

 3 should be replaced in its entirety anyway.

 4 So, it seems to me, just in my limited

14:04:52 5 technical knowledge, which is very limited, but let

 6 me just say it seems to me that the AHRI rating

 7 method for the matched systems kind of already

 8 accomplishes what I think we're trying to do here

 9 if you're trying to properly match system

14:05:07 10 installations.

 11 So, that's my global perspective on

 12 this. But, we welcome the opportunity to

 13 participate and thank you.

 14 So, ask.

14:05:16 15 (Whereupon, at 2:05 p.m. ET, Mr. Gee

 16 left the room, after which the following occurred:)

 17 MR. BROOKMAN: Okay.

 18 DR. LEKOV: So, here are some more

 19 details about how the shipments forecast will be

14:05:30 20 evaluated for. In case of replacement, DOE will

 21 develop retirement functions from the lifetime

 22 estimates and apply them to the existing products.

 23 The existing stock of products that,
 215

 1 will be developed from historical shipments data.

 2 In the case of new constructions, DOE will estimate

 3 or forecast new-housing construction and saturation

 4 rates of various furnace and cooling products types

14:05:57 5 in new housing.

 6 In projecting the future housing

 7 situation rate, DOE will consider expected trends

 8 in builder and consumer preferences, including

 9 competition among space heating and cooling

14:06:14 10 products. So, talking about equipment switching.

 11 In the case of first-time owners, DOE

 12 planned to derive a historical rate of product

 13 adoption for the noncentrally heated market. Plans

 14 to project future adoption rates by considering

14:06:32 15 historical trends as well as market situation

 16 indicates that retrofits will estimate the shipment

 17 from the lifetime distribution.

 18 And there are a few sources listed at

 19 the bottom.

14:06:59 20 With that, DOE seeks input on the

 21 historical shipments data for furnace fans,

 22 including the distribution of shipments by

 23 efficiency.
 216

 1 DOE will welcome comments on the

 2 methodology described to forecast shipments of

 3 furnace fans.

 4 And DOE welcomes comments on whether

14:07:18 5 energy conservation standards might affect

 6 shipments of furnace fans.

 7 DR. JAKOBS: I, I, I have a question.

 8 MR. BROOKMAN: Diana. Diane. Pardon

 9 me.

14:07:28 10 DR. JAKOBS: That's all right. The --

 11 Are you talking about furnaces? I mean, or --

 12 DR. LEKOV: Furnace fans.

 13 DR. JAKOBS: Well, we don't really -- I

 14 mean, we only ship furnace fans as a replacement,

14:07:41 15 so do you really want all this information just

 16 about replacement for failed furnace fans, or are

 17 you really talking about furnaces?

 18 DR. LEKOV: You, you could structure

 19 your comment even to the impact of whether improved

14:07:57 20 or proposed or considered improved efficiency of

 21 the fans will impact the shipments of furnaces, the

 22 furnace products. Let me use the term.

 23 MR. BROOKMAN: Yeah. Okay.
 217

 1 Karim?

 2 DR. AMRANE: Karim Amrane, AHRI. Again,

 3 I don't think we want to recapture furnace fans

 4 shipments, per se. But, of course, we have

14:08:28 5 shipment data for furnaces, so that's something

 6 that is what I recalled with the Department.

 7 But, as far as the replacement market,

 8 I, I don't know where we could get the data.

 9 MR. BROOKMAN: The, the, the replacement

14:08:41 10 fans, they still come from the manufacturers of

 11 furnaces largely?

 12 DR. AMRANE: Maybe. Maybe they do, but,

 13 but as, at least as an industry, as AHRI, we don't

 14 capture that data.

14:08:55 15 So, so we won't be able to share

 16 anything with, with you, because we don't, we don't

 17 have it.

 18 MS. ARMSTRONG: Yeah.

 19 MR. BROOKMAN: Ashley.

14:09:04 20 MS. ARMSTRONG: Yeah. I guess if you

 21 don't have that type data as far as the actual

 22 shipments, and just the, maybe furnace fan assembly

 23 that goes into replacement applications only, if
 218

 1 you know the, if you have some estimate, or a good

 2 idea based on your American experiences, maybe the

 3 percentage of the market that might fix upon fail,

 4 rather than replace the whole system as a whole,

14:09:28 5 that would also get to a similar effect.

 6 Does that make sense?

 7 MR. WAGNER: I know. But, that's

 8 changing --

 9 MS. ARMSTRONG: It's a cost thing, but

14:09:37 10 --

 11 MR. BROOKMAN: Bryan's earlier comment

 12 suggested the price is problematic.

 13 MS. ARMSTRONG: I understand. I

 14 understand.

14:09:46 15 MR. WAGNER: I was going to say -- This

 16 is Greg Wagner.

 17 One thing that's happened with SEER

 18 implementation is more people are repairing than

 19 replacing because of the higher cost of new

14:09:56 20 installation. So, I don't know.

 21 MS. ARMSTRONG: Sure.

 22 MR. WAGNER: I don't know. That's a

 23 dynamic thing.
 219

 1 That's been changing dramatically over

 2 the last few years with changes in legislation. I

 3 don't know that there's going to be a single source

 4 that will provide you with clarity on that data.

14:10:11 5 But, back to the replacement part of it,

 6 they do put a lot of safety controls in these

 7 devices to keep them from causing problems for the

 8 homeowner, and so they are designed for the

 9 application. And it is highly recommended that the

14:10:24 10 exact replacement part is the same as the one that

 11 was in there, for safety reasons.

 12 (Whereupon, Msrs. Burt and Bacchus

 13 conferred, out of the hearing of others, during

 14 which the following occurred:)

14:10:32 15 MR. BROOKMAN: Frank, did you --

 16 MR. STANONIK: Frank Stanonik.

 17 I was just going to pick up on that

 18 point. Again, in terms of at least what I know,

 19 past analysis, analyses, the, this particular

14:10:45 20 question of what might be the mix of shipments of

 21 the replacement furnace fans, I really question if

 22 it, it's going to be any value because in terms of

 23 where it is being a replacement, it, it should be a
 220

 1 like for like.

 2 So, it's not, it's not like a homeowner

 3 is going to pull out a 70-percent AFUE furnace and

 4 put in a 95- or 90- or whatever. And that, that

14:11:13 5 becomes a relevant piece of analysis.

 6 In this little segment of trying to say,

 7 "Well, what happened, what happens in terms of the

 8 number of fans, furnace fans that get shipped as

 9 repair parts?" I don't know that it matters.

14:11:27 10 MR. BROOKMAN: Is it possible to just

 11 generally estimate?

 12 MS. ARMSTRONG: Wait.

 13 MR. BROOKMAN: Go ahead, Ashley. Go

 14 ahead.

14:11:33 15 MS. ARMSTRONG: And Alex may be better

 16 able to articulate this than I, but I guess I ask

 17 you: Is it a fair assumption that the Department

 18 looks at, once we have a test procedure, that the

 19 Department looks at various efficiency levels, and

14:11:47 20 after effective date of the Standard, you know, if

 21 we went to, something that was higher efficiency

 22 than what the consumer already had, would that make

 23 them replace the system as a whole because they
 221

 1 couldn't find a replacement that was exactly like

 2 what they had previously?

 3 Is that a fair assumption?

 4 MR. WAGNER: They might not be able to

14:12:10 5 supply it because them controls, they're building a

 6 fire in, in your basement.

 7 MS. ARMSTRONG: So, in which case

 8 they'll replace the system as a whole.

 9 MR. BROOKMAN: Yes. Great.

14:12:19 10 DR. AMRANE: If that's true, then this

 11 has to be accounted for in the analysis.

 12 MS. ARMSTRONG: Okay.

 13 MR. BROOKMAN: Okay, thank you.

 14 That was Greg, followed by Karim.

14:12:25 15 Mohammed?

 16 MR. KHAN: Mohammed KHAN, DOE.

 17 I appreciate the many comments we've

 18 heard already about the importance of trying to

 19 maintain matching to ensure that whatever safety

14:12:39 20 systems are in place are going to be working as

 21 they are intended. Maybe you can just elaborate on

 22 that just a little bit so I have a better

 23 understanding.
 222

 1 My understanding is that when we talk

 2 about furnaces, you generally have some limit

 3 temperature switches that basically control when

 4 and, when, when the burner should turn off and

14:13:06 5 when, when it's okay for it to turn on.

 6 If the temperature limit switch exceeds

 7 X amount, burner goes on, blower stays on until the

 8 temperature's reduced. Is there anything else

 9 that, that we should know about in terms of safety

14:13:23 10 control?

 11 MR. BROOKMAN: I'm seeing two different

 12 reactions there, one, "No," and one, "Yes," from

 13 the manufacturer.

 14 MR. WAGNER: I'm not, I'm not --

14:13:29 15 MR. BROOKMAN: Greg.

 16 MR. WAGNER: I'm saying yes, they do

 17 have limit switches. And Jim is certainly more

 18 versed in what those limit switches do than I am,

 19 but in essence they make sure that it doesn't get

14:13:40 20 into an overheat condition.

 21 So, they do cut off when it gets over

 22 temperature.

 23 MR. VerSHAW: That's all, all limit
 223

 1 switches do today is make sure it doesn't overheat.

 2 The blowers are all, all electronically controlled

 3 and after the flame has been sensed, there's a

 4 delay time for the blower determined by the

14:14:05 5 manufacturer.

 6 The blower comes on, and when the heat

 7 has ended, then the blower goes off. And if

 8 there's some kind of fault in there, for instance,

 9 if it gets too hot, it turns off, the blowers keeps

14:14:17 10 them running until that recloses.

 11 There's also rollout switches and

 12 pressure switches and all kinds of things in there

 13 that have different reactions. But, in normal

 14 operation it's, it's, it senses that the flame is

14:14:29 15 running and then it delayed, there's a delayed

 16 start.

 17 And then when the flame goes out, it

 18 goes off by itself. If the flame doesn't go off

 19 for some reason the, the gate states open, then the

14:14:44 20 system keeps the blower running.

 21 MR. BROOKMAN: I'd like to address Item

 22 44. I think Ashley was addressing this, at least

 23 in part.
 224

 1 What do you anticipate is going to

 2 happen with shipment should Energy Conservation

 3 Standards be put in place for furnace fans?

 4 (Whereupon, at 2:15 p.m., Mr. Wagner and

14:14:57 5 Mr. VerShaw conferred, out of the hearing of others

 6 and off the Record, during which the following

 7 occurred:)

 8 MR. BROOKMAN: Do you see it there, Item

 9 44?

14:15:06 10 Yes, Jim.

 11 MR. VerSHAW: This is Jim VerShaw again.

 12 I think if you look back over the years

 13 of what happened as higher efficiency Standards

 14 were put in place, I think we're seeing increase

14:15:17 15 in, in repairs and a decrease in furnace or, or in

 16 HVAC sales. I think SEER is a good indication of

 17 looking at what shipments have been since 13 SEER

 18 went in.

 19 And you look at the parts revenue of the

14:15:32 20 various companies, that they've gone up. That I

 21 think's a similar risk here.

 22 If somebody's got an older furnace but

 23 yet now the price has got even that much higher,
 225

 1 that the push for them to repair that and not

 2 actually get a higher efficiency furnace could be

 3 higher. And so we want, we want to make sure that

 4 we don't get to a point where we ought to replace

14:15:51 5 the equipment when it ought to get replaced, and

 6 just keep repairing because the cost of new gets

 7 too high.

 8 MR. BROOKMAN: Diane?

 9 DR. JAKOBS: I was thinking that if

14:16:05 10 Energy Efficiency Standards on the AC side are

 11 already moving furnaces in the direction of more

 12 efficient fans because it's part of the calculation

 13 for zero, and that's, that's where the advantage

 14 is, so we're, we're already seeing this shift with

14:16:25 15 the rebates and, and, you know, going -- Some, some

 16 of our equipment, we have a version in the PSE

 17 blower to get 13 SEER.

 18 We have the X-13 that brings you up to

 19 14 SEER. You know.

14:16:38 20 So, so it's already being pushed in that

 21 direction. I don't know, I don't know if this

 22 would make any difference.

 23 It, it's already kind of moving that
 226

 1 way.

 2 MR. BROOKMAN: Umm.

 3 Bryan, I thought you were going to

 4 comment. Any thoughts on how Standards might,

14:16:55 5 might affect shipments?

 6 MR. ROCKY: Yeah. Again, Bryan Rocky.

 7 I, I'm agreeing with what Diane just

 8 said. The driver from a system standpoint AC and

 9 heat pump higher SEER, higher HSPN ratings is a

14:17:11 10 significant ten-times multiplier versus the impact

 11 of just efficiency of a furnace fan.

 12 The reason we're selling more ECM motors

 13 and air handlers and furnaces is to meet the '15,

 14 '16, '18 zero weatherization programs, tax credits,

14:17:30 15 all the things that the consumers can get money

 16 back that offsets the cost of that product.

 17 And there is -- Unless there is some

 18 incentive for just a furnace fan, there's, this,

 19 this part of it is going to be very insignificant

14:17:46 20 to the whole overall market impact.

 21 MR. BROOKMAN: Okay, thank you.

 22 DR. LEKOV: With that, going to a

 23 national impact analysis. The purpose is to assess
 227

 1 aggregate impacts at the national level potential

 2 energy conservation standards for each of the

 3 product classes, and those are presented as net

 4 present value of total consumer, consumer economic

14:18:12 5 impacts and the national savings.

 6 DOE calculates the annual equipment

 7 expenditures by multiplying the price per the unit

 8 by the forecasted shipments. Have been explained.

 9 The difference between base and standard

14:18:25 10 case gives the national energy bills savings and

 11 increased expenditures. The difference each year

 12 between energy bill savings and increased equipment

 13 expenditures is the net savings or net cost, and

 14 this is illustrated in a better way here.

14:18:45 15 So, there's -- This chart is for the

 16 national energy savings, and there is a similar one

 17 for the net present value. So, DOE determines the

 18 shipments from the base case, the base case annual

 19 energy consumption for the entire analysis period.

14:19:14 20 Does the same thing for each of the

 21 standard cases, develops cumulative values, comes,

 22 uses the site to source factor, and arrives at the

 23 national energy savings. And this is what you're
 228

 1 seeing on the summary page of the DOE's

 2 spreadsheet.

 3 Similar fashion, the calculation of the

 4 nets, net present value, essentially the dollar

14:19:43 5 value of those savings. It's determined for the

 6 base case basically to operating costs, which

 7 includes the energy cost of operating, savings, and

 8 the maintenance installation cost is included in

 9 this in both base case and standard case.

14:20:02 10 Separately the product cost is

 11 determined. The base case and the standards case,

 12 develop the total operating cost.

 13 The total cost increase, a discount cost

 14 is arrived at; arrived at the net present value of

14:20:22 15 the savings. So, this is just outline of the

 16 methodology as used in every single rulemaking the

 17 last years.

 18 Next point relates to the standard case

 19 efficiency distribution. DOE usually uses either

14:20:58 20 roll-up or shift scenarios for estimating the

 21 impact of Standards and product efficiency

 22 distribution.

 23 Roll-up scenario essentially, here are
 229

 1 the basic. Assumes that the product efficiency in

 2 the base case do not meet the standard level under

 3 consideration would roll up to meet the new

 4 Standards level, and the levels above the standard

14:21:20 5 level are not going to be affected.

 6 In the shift scenario, DOE retains the

 7 pattern of the base case efficiency distribution

 8 but reorient the distribution at and above the new

 9 minimum Energy Conservation Standard, which means

14:21:38 10 that essentially everything below the Standard is

 11 distributed at the Standard and above.

 12 And for this rule for the next case DOE

 13 will evaluate whether one of these approaches is

 14 more reasonable for furnace fan, or whether it, it

14:21:56 15 would be preferable to use both scenario as a

 16 combination of those in the calculation of the

 17 national impacts.

 18 And DOE seeks comment on the appropriate

 19 assumptions to use regarding long-run changes in

14:22:16 20 furnace fan energy efficiency independent of the

 21 standards, and DOE seeks comment on, on the use of

 22 roll-up and shift scenarios.

 23 MR. BROOKMAN: What about roll-up and
 230

 1 shift?

 2 Yeah, Diane.

 3 Or, Frank first.

 4 DR. JAKOBS: Frank first.

14:22:39 5 MR. BROOKMAN: Yeah.

 6 MR. STANONIK: Well, this is -- It's a

 7 bit of a strange circumstance, I mean, because in,

 8 in, in terms of what we know today as far as

 9 furnace fans, you either have the traditional motor

14:22:56 10 or you have the, the brushless magnet. I mean,

 11 that's it.

 12 I mean, those are the two things that

 13 are the biggest factors in how much electric energy

 14 your furnace fan uses. And so I'm -- Unless this

14:23:14 15 analysis or, or technology evolves and DOE finds

 16 some other variations, if, if you're stuck with

 17 basically the, the, the, let's call them the two

 18 options, then the only thing that makes sense is

 19 roll-up.

14:23:29 20 There is no shift. You know, if, if we

 21 stay -- If this is kind of where we end up or where

 22 things stay, then if there's a subsequent

 23 Regulation, then it's only going to be a roll-up.
 231

 1 I mean, there isn't anything else. So,

 2 I mean, you know, this is certainly the framework

 3 DOE has used for a lot of analyses, but at least

 4 in, in my experience this is the first time we're

14:23:51 5 trying to analyze the component and not the

 6 finished product.

 7 It's a little weird.

 8 DR. JAKOBS: I just --

 9 MR. BROOKMAN: Diane?

14:24:01 10 DR. JAKOBS: Sorry. The -- A couple

 11 weeks ago one of the, the guys from the lab, he

 12 came up and, and the gas utilities in our area,

 13 they had a little brochure and they talked about

 14 how electrical energy is really only 30-percent

14:24:19 15 efficient when you consider -- I mean, they were

 16 talking about source efficiency versus site, you

 17 know.

 18 And if there was an awareness of that, I

 19 think that it would become more important. People

14:24:34 20 seem to be more aware of energy efficiency, and if

 21 they understood it maybe a little better -- But I

 22 agree with, with Frank that it, it, it's a matter

 23 of just rolling up.
 232

 1 It's a funny thing of, you know, you can

 2 have a hundred-percent AUFE resistance for it, you

 3 know.

 4 MR. BROOKMAN: Okay. Other comments on

14:25:02 5 these two issue boxes?

 6 DR. LEKOV: DOE also usually looks at

 7 life-cycle costs of group impacts, and here is the

 8 core of such analysis, to analyze the economic

 9 impacts of Standards on consumers, including some

14:25:32 10 subgroups who may be disproportionally impacted

 11 compared with the general population, such as

 12 low-income or senior citizens usually.

 13 (Whereupon, at 2:25 p.m. ET, Msrs. Burt

 14 and Bacchus left the room, after which the

14:25:42 15 following occurred:)

 16 DR. LEKOV: And the method is, basically

 17 extends analysis in order to specifically examine

 18 those defined subgroups, and uses input specific to

 19 each of the considered consumer subgroups. So, any

14:26:01 20 comments on which, if any consumer subgroup,

 21 subgroup should be considered for when developing

 22 Standards for furnace fan?

 23 MR. BROOKMAN: And you can see a couple
 233

 1 of them that are noted, low-income consumer, senior

 2 citizens as possible examples.

 3 Terry.

 4 MR. SMALL: I hate to, to push the

14:26:31 5 manufactured housing thing too much, but, you know,

 6 the, the, the stratum of people that are, that are

 7 in the low-income, low-cost housing such as

 8 manufactured housing have some special challenges

 9 and they want efficient systems. They want

14:26:49 10 inexpensive operating costs.

 11 They need it probably really more than

 12 most. But sometimes the up-front cost of putting

 13 in advanced systems, advanced motors, ECM motors

 14 and all that, particularly tough on people, say,

14:27:07 15 that would live in, in a manufactured home.

 16 And I don't know whether in the

 17 procedure you do in your economic analysis maybe

 18 you could consider that group as a subgroup in

 19 terms of looking at the economics of, you know,

14:27:23 20 the, the, the rulemaking you're proceeding with.

 21 MR. BROOKMAN: Okay.

 22 DR. LEKOV: Okay. So, you correct me if

 23 you want.
 234

 1 So, we are -- You are recommending for

 2 the manufactured home to create a separate product,

 3 --

 4 MR. SMALL: Well, I think --

14:27:43 5 DR. LEKOV: -- separate evaluation of

 6 the population types?

 7 MR. SMALL: I think if you'll look at

 8 the housing types, normally manufactured housing is

 9 your least expensive per square foot housing in the

14:27:56 10 U.S., and so it tends to cater to people that, you

 11 know, that, that can least afford housing. And so

 12 in, in a manufactured home is a heater, a furnace,

 13 maybe an air-conditioner.

 14 So, a lot of times I think that the cost

14:28:16 15 of these things relative to somebody at that level

 16 of housing is, is overlooked.

 17 MR. BROOKMAN: Thank you.

 18 Diane.

 19 DR. LEKOV: Probably one sentence. RECS

14:28:29 20 actually provides the means of household income,

 21 and also provides information whether the home is a

 22 manufactured home.

 23 So, this is --
 235

 1 MR. SMALL: This is the RECS, the RECS

 2 data?

 3 DR. LEKOV: Two-thousand-five. So, this

 4 will allow to extract this information.

14:28:49 5 MR. SMALL: You know, and I've talked

 6 about this product class. I think it's very

 7 important here that just one size does not fit all.

 8 You have some different product classes

 9 that some of these product classes are aimed at a

14:29:01 10 different economic group, and the, the installation

 11 costs are different. The distribution is

 12 different.

 13 Everything is different. Everything is

 14 aimed at value and, and, you know, inexpensive

14:29:16 15 where possible.

 16 And, you know, if the economics of that

 17 aren't paid attention to, then this subgroup would

 18 be effected.

 19 (Whereupon, at 2:29 p.m. ET, Ms.

14:29:23 20 Armstrong and Mr. Stas conferred, out of the

 21 hearing of others and off the Record, during which

 22 the following occurred:)

 23 MR. BROOKMAN: Bryan.
 236

 1 MR. ROCKY: Yeah, Bryan Rocky.

 2 I would just add to that, to what Terry

 3 said, because I'm really cautious going back to the

 4 RECS data from 2005 or earlier, based on the

14:29:39 5 tremendous change in the housing market the last

 6 few years with the, the bubbles, everything else

 7 that have collapsed.

 8 But, manufactured housing in particular

 9 is a vastly different market today than it was even

14:29:53 10 in 2005, as far as new-home construction versus

 11 replacement. Go back and look at the numbers that

 12 were available from, like, Manufactured Housing

 13 Institute.

 14 Currently, 2010, there will only be

14:30:09 15 something like 42- or 45,000 new homes built in

 16 North America, versus even five years ago it might

 17 have been 120,000 homes. And it definitely drives

 18 the economic point, as Terry was making, that in

 19 that market segment they are not buying new

14:30:27 20 products.

 21 They are replace -- Not replacing. They

 22 are repairing.

 23 And they are not replacing with higher
 237

 1 efficient product unless they absolutely have to.

 2 MR. BROOKMAN: And did the manufactured

 3 housing sector, does it pick up that difference, or

 4 is that, do you not know?

14:30:42 5 MR. ROCKY: I'm sorry. As pick up the

 6 difference, Doug, in what?

 7 MR. BROOKMAN: The decline in housing

 8 starts.

 9 MR. ROCKY: The decline in housing

14:30:50 10 starts is, is -- They're not selling the product.

 11 MR. BROOKMAN: Okay.

 12 MR. ROCKY: People -- Home -- Homeowners

 13 are not replacing mobile homes or manufactured

 14 homes. They're repairing older products.

14:31:00 15 MR. BROOKMAN: I got you.

 16 MR. ROCKY: And they're repairing older

 17 equipment in those products.

 18 MR. BROOKMAN: Okay, thank you.

 19 MR. ROCKY: Even with tax credits and

14:31:08 20 everything else that are available.

 21 MR. BROOKMAN: I've got you.

 22 Go ahead, Terry.

 23 MR. SMALL: Go ahead, Frank.
 238

 1 MR. STANONIK: No, no. I'll fish it

 2 out.

 3 MR. SMALL: Well, what I was going to

 4 say, unfortunately I didn't come up to the furnace

14:31:23 5 NOPR, I guess a month or two ago, but I notice just

 6 in looking back in the history of the, what is it,

 7 the, the TSLs, I guess that a good example is

 8 there's a proposal to maybe carry in the northern

 9 region of the United States the minimum furnace

14:31:40 10 efficiency to 90 percent of condensing furnace.

 11 And I'm assuming that if that is to be

 12 the final rulemaking, that would mean that you

 13 could be living in a $10,000 mobile home that had

 14 a, you know, a 20-year-old mobile home that had a,

14:31:59 15 a 20-year-old 75-percent AUFE furnace, and you'd be

 16 forced to putting, installing a condensing furnace

 17 which could end up costing you, you know, a-third

 18 of the cost of the home, or the value of the home;

 19 you know, two-, $3,000, because you're going to

14:32:18 20 have to change the venting.

 21 You've got to do something with the

 22 condensate, which may have some little acidicy in

 23 it. And these people are, at this level, I think
 239

 1 it just isn't going to happen.

 2 So, what are they going to do as an

 3 alternative? Probably go out to WalMart and buy

 4 some floor furnaces or, or portable furnaces or,

14:32:45 5 you know.

 6 In other words, the country is going to

 7 save nothing in terms of, of, of energy, and it may

 8 even create some safety situations. So, I -- The

 9 point I'm making is I think that something like

14:32:58 10 manufactured housing is its own product class and,

 11 you know, somebody needs to carefully look at the

 12 true installation cost, as Bryan said, of going

 13 back.

 14 People are not going to buy a new mobile

14:33:12 15 home if they have to buy a new furnace. I'm not

 16 sure it's justified to make them buy the most

 17 advanced technology to include this fan furnace

 18 and, and ECM motor, et cetera.

 19 MR. BROOKMAN: Eric Stas.

14:33:27 20 Thank you.

 21 MR. STAS: Eric Stas, DOE.

 22 Just try to clear up a little here.

 23 While it's appropriate under EPCA to analyze the
 240

 1 different consumer subgroup impacts when we are

 2 setting product classes, it's not based on, on

 3 economics. It's based on the criteria in 6295 such

 4 as that the product consumes a different type of

14:33:50 5 energy not consumed by other covered products

 6 within the type or class, or has the capacity or

 7 performance-related feature to distinguish the

 8 product classes.

 9 This, this type of thing with who the

14:34:03 10 consumer is, and their, their economic situation is

 11 maybe considered in how to set the overall levels,

 12 but not product classes based on that use basis.

 13 MR. BROOKMAN: Charlie.

 14 MR. STEPHENS: Charlie Stephens again.

14:34:19 15 I've got about 20 years of history

 16 working with a mobile home/manufactured home

 17 manufacturers out where we are, four states plus

 18 California markets, but nobody buys furnaces

 19 better, cheaper. Has anybody ever seen the Invoice

14:34:36 20 on a, on a furnace for a manufactured home?

 21 (Whereupon, no response was had.)

 22 MR. STEPHENS: I have. You'd be shocked

 23 at how cheap they are.
 241

 1 Most of them come with electric

 2 forced-air furnaces. Most of them do not have

 3 fossil furnaces because most of them are rural and

 4 all they have is electricity or, or propane.

14:34:53 5 Some of them do have propane furnaces,

 6 that's true, but most of them do come with electric

 7 forced-air furnaces. That's absolutely the

 8 cheapest thing you can put in to heat it.

 9 You can put a heat pump to some of them.

14:35:09 10 However, they are more like -- They actually meet

 11 or exceed building codes.

 12 They're two-by-sixes, 21R, 35R home.

 13 You know, these are good homes.

 14 They're still making quite a few of

14:35:21 15 them. They're not trailers.

 16 They're a double-wide 1,300-square-foot

 17 building that is quite energy efficient to start

 18 with. HUD regulates those, and they're already a

 19 separate class.

14:35:32 20 The furnaces in there, the mobile-home

 21 furnaces are already a separate class and a

 22 separately selected product under NAICA. So, they

 23 probably would bear looking at as a separate class
 242

 1 here as well.

 2 But, I -- Again, I think what we regard

 3 where we are, low-income and seniors who are, who

 4 live in manufactured homes are a subset of

14:35:54 5 low-income and seniors. So, they are large -- They

 6 are significantly occupied by low-income and senior

 7 people.

 8 But, there are other people in those

 9 categories up there that don't live in manufactured

14:36:05 10 homes, but I think those are appropriate categories

 11 of consumer subgroups. Some of them live in

 12 manufactured homes, and those may be considered a

 13 separate class.

 14 They are already a separate class for

14:36:21 15 regulation. So, I don't know how this rulemaking

 16 will look at them, but if it's similar to the

 17 furnace rulemaking, then they will be a separate

 18 class.

 19 MR. BROOKMAN: I see. Okay, thank you.

14:36:31 20 Additional comments?

 21 (Whereupon, no response was had.)

 22 MR. BROOKMAN: Okay.

 23 DR. LEKOV: To Rob Carmichael.
 243

 1 MANUFACTURER IMPACT ANALYSIS:

 2 MR. CARMICHAEL: Good afternoon. My

 3 name's Rob Carmichael.

 4 I'm with Navigant Consulting, and I'm

14:36:57 5 going to take us over the, the manufacturing impact

 6 analysis and the methodology for that.

 7 Just real briefly, the, the purpose of

 8 the manufacturer impact analysis, or the MIA, is to

 9 really cover three broad, broad topics.

14:37:10 10 (Whereupon, at 2:37 p.m., Mr. Wagner and

 11 Dr. Jakobs conferred, out of the hearing of others

 12 and off the Record, during which the following

 13 occurred:)

 14 MR. CARMICHAEL: The purpose is to

14:37:15 15 assess the impacts of new energy standards on

 16 manufacturers of, of these products that, that,

 17 that we're covering here. We do that both

 18 qualitatively and quantitatively.

 19 Second purpose is to identify and

14:37:28 20 estimate the impacts on any subgroups of

 21 manufacturers that may be differently or, or more

 22 adversely affected than the industry as a whole.

 23 And then lastly -- I'll talk about this
 244

 1 a little bit later, but we're trying to look at the

 2 cumulative regulatory burden. So, what other

 3 Regulations are manufacturers of this, these

 4 products subject to?

14:37:47 5 And we try to take into account the

 6 consequences of those Regulations.

 7 There are two -- Moving to, to

 8 methodology, there are two main tools, primary

 9 tools that DOE uses in conducting the MIA. The

14:37:59 10 first is the Government Regulatory Impact Model, or

 11 the GRIM.

 12 It's a (sic) industry cash flow model,

 13 so what it does basically is project cash flows out

 14 through the entire analysis period and discount

14:38:15 15 those back to the present value, both in the base

 16 case and in the standards case, and come up with a,

 17 a change or a (sic) impact to the industry.

 18 The second major tool there are the

 19 interviews that we, that we conduct with the

14:38:28 20 manufacturers themselves. We use these to refine

 21 those inputs that are going into the cash-flow

 22 model, and use those and, to identify and to

 23 develop any subgroup analyses.
 245

 1 So, for instance, small-business

 2 manufacturers, perhaps. And, and to address other

 3 qualitative issues such as the impact on

 4 competition in the marketplace, manufacturing

14:38:50 5 capacity, and employment.

 6 And then obviously the key output of the

 7 Manufacturing Impact Analysis is the change in

 8 industry net present value. And then we'll also

 9 come up with the change in, in net present value as

14:39:09 10 it relates to a particular subgroup that we, that

 11 we choose to analyze, and then the employment

 12 impacts and the impact on capacity that I mentioned

 13 for some other more qualitative outputs that come

 14 from this analysis.

14:39:21 15 So, down into, a little deeper into the

 16 methodology, the MIA consists of three phases. In

 17 the first phase we'll create a (sic) industry

 18 profile, and this builds for market and technology

 19 assessment, takes what we've learned here today

14:39:36 20 and, and what we've learned and, from your

 21 comments, and, and tries to, to build a market

 22 characterization of the what the manufacturers are

 23 facing in the marketplace.
 246

 1 Then the next, the next stage, when we

 2 move on to the Phase 2, is build just a straw man

 3 GRIM. So we're going to take, like, the

 4 engineering.

14:39:58 5 We'll take the manufacturing costs that

 6 manufacturers are facing, as well as the shipment

 7 analysis, take the annual shipments, and throw them

 8 into the straw man GRIM to get a general

 9 understanding of, of how, of what sort of impacts

14:40:13 10 the manufacturers will be facing.

 11 And that helps us move on to that next

 12 box there, develop the energy guide which we use to

 13 guide, obviously, the interview with, with

 14 manufacturers which begin in Phase 3. And so

14:40:27 15 we'll, we'll conduct those interviews and use those

 16 to refine the, our initial analysis our straw man

 17 GRIM and come up with more precise, more precise

 18 inputs than some people may have outputs than from

 19 the government model.

14:40:47 20 And then lastly, after those discussions

 21 and further research using mostly publicly

 22 available information, so, industry reports, SEC

 23 10Ks, manufacturer Annual Reports, we'll be able to
 247

 1 look at the direct, assess the direct employment

 2 impacts as well as impact on competition.

 3 So, as I mentioned before, DOE

 4 recognizes that there may be differences or more

14:41:19 5 adverse impacts on small businesses, and as, as

 6 part of that, DOE always looks for, looks at this

 7 in particular.

 8 The Small Business Administration has

 9 set a, a threshold for what constitutes a small

14:41:35 10 business in this industry at about, at 750

 11 employees or fewer. Now, there, there can be other

 12 subgroups, and at this time DOE would like to ask

 13 for comments on what, any subgroups that DOE should

 14 look at, including whether or not to look at

14:41:54 15 small-business manufacturers.

 16 MR. BROOKMAN: Comments to subgroups?

 17 (Whereupon, no response was had.)

 18 MR. CARMICHAEL: Okay, and then on

 19 cumulative regulatory burden. Again, this is the

14:42:13 20 other federal regulations, other regulations to

 21 which manufacturers of furnace fan products are,

 22 are also subject.

 23 And the two clear, clear ones here that
 248

 1 we have listed are the Energy Conservation Standard

 2 Rule on furnaces and boilers, and the Energy

 3 Conservation Standards for central, CAC and, and

 4 heat pumps.

14:42:33 5 DOE welcomes comment on any others that

 6 DOE should consider.

 7 MR. BROOKMAN: Karim.

 8 DR. AMRANE: Karim Amrane, AHRI.

 9 Well, there are several others that DOE

14:42:45 10 is currently doing, like the standby power

 11 rulemaking on both the furnaces and, and central

 12 AC, or the test procedure on central AC air

 13 conditioners. And, yeah, so those are a few.

 14 But, but, again, you need to look also

14:43:06 15 at what's going on at EPA; what's going on in

 16 legislation. For example, like, they going to be

 17 impact on industry not related to furnaces but

 18 related to, for example, refrigerant that may

 19 impact, that will impact manufacturers of furnaces.

14:43:24 20 MR. BROOKMAN: Thank you.

 21 Diane?

 22 DR. JAKOBS: Rheem as an individual

 23 company. We make water heaters, too, so we're
 249

 1 affected by that.

 2 Also there's emissions requirements in

 3 California on furnaces. We were going to be

 4 affected on that.

14:43:39 5 MR. BROOKMAN: Okay. Okay.

 6 Bryan.

 7 MR. ROCKY: Yeah, Bryan Rocky again.

 8 You're talking about several things.

 9 Since the manufacturers of most residential

14:43:47 10 furnaces, central air conditioners, also make

 11 commercial products, there is a, a regulatory

 12 burden of the addition of all the commercial

 13 product Regulations that are coming onto this.

 14 Karim said, you know, EPA. So, Energy

14:44:02 15 Star changes, has an impact on us.

 16 The proposed Home Star legislation will

 17 have an impact on us as builders. There are other

 18 efforts in Canada that are continuing to go.

 19 Refrigeration, refrigerants is an

14:44:20 20 obvious one of these two. The AC and heat pump

 21 criteria changes will be the most impactful.

 22 That will be the thing that will drive

 23 an indoor site air handler or furnace will be more
 250

 1 than anything else. Low NOx emissions;

 2 weatherization programs; utility requirements.

 3 I mean, there's just so much going on.

 4 Building Code changes like Title 24 in California

14:44:46 5 that are now spreading to other parts of the

 6 country where it's not just the efficiency as we've

 7 talked about in a test condition, but as verified

 8 performance in the application itself will change,

 9 could change how manufacturers design furnaces, air

14:45:02 10 handlers, air conditioners.

 11 So, the, the accumulation of all this

 12 makes it a really interesting time to be a

 13 manufacturer.

 14 MR. BROOKMAN: Karim.

14:45:12 15 DR. AMRANE: Karim Amrane, AHRI again.

 16 Well, in the past, DOE has always asked

 17 the question. DOE has always looked maybe how deep

 18 that you look at the regulatory burden.

 19 But, I'm, I'm, I'm here at DOE almost

14:45:27 20 every week now. So, there are rulemakings all the

 21 time.

 22 And that is just at the federal level.

 23 They are also, you know, like Bryan mentioned, at
 251

 1 the state level.

 2 So, I think more and more now this is

 3 something that DOE needs to look at, needs to

 4 seriously look at the impact on manufacturers.

14:45:47 5 MR. BROOKMAN: Okay, thank you.

 6 Other comments?

 7 (Whereupon, no response was had.)

 8 MR. BROOKMAN: Back to Alex Lekov.

 9 UTILITY IMPACTS, EMPLOYMENT IMPACTS, ENVIRONMENTAL

14:45:57 10 IMPACTS, AND REGULATORY IMPACTS ANALYSES

 11 DR. LEKOV: There are four, four

 12 downstream analyses that we'll briefly explain.

 13 Each of them is about one slide.

 14 So, starting with the utilities impacts,

14:46:19 15 essentially the purpose is to assess the impacts on

 16 energy supply, on the national energy supply. And

 17 DOE uses a standard model called NEMS, National

 18 Energy Modelling System.

 19 And the way it's done, this is a pretty

14:46:37 20 complex model. It's evaluated in the case of no

 21 standards and furnace, in the case of standard

 22 furnace standards.

 23 The differential essentially is reported
 252

 1 mostly as avoided capacity, utilities capacity,

 2 like in gigawatts. And this is what DOE plans to

 3 present.

 4 MR. BROOKMAN: Comments on utilities

14:47:15 5 impact analysis? Anything additional to what Alex

 6 has just described?

 7 (Whereupon, no response was had.)

 8 DR. LEKOV: There is another, I would

 9 characterize standard type of analysis DOE does

14:47:28 10 which is employment impact. Just to bring here the

 11 topic that's focused on indirect employment.

 12 In fact, Rob just mentioned about the

 13 direct employment factor which is on the

 14 manufacturer. This is overall on the nation.

14:47:51 15 It -- Essentially it's look of a

 16 potential of how the savings, the consumer will

 17 have expenditures will be used for other equipment

 18 and, and energy costs. And the method to be used

 19 is standard methodology used in the different

14:48:15 20 branches of the federal government called ImSET

 21 model.

 22 And DOE seeks comment on this approach

 23 of assessing potential employment impacts.
 253

 1 MR. BROOKMAN: Bryan.

 2 MR. ROCKY: Yeah.

 3 Alex, I think the, the process and the

 4 approach is just fine. Unfortunately, the, the

14:48:36 5 direct impact of all this is we're talking of

 6 something that is in the neighborhood of two to

 7 four percent of the total energy usage of these

 8 appliances, and as far as changing consumer use, or

 9 impacts on the, a consumer, this will have almost

14:48:58 10 zero impact, this whole process, this whole study.

 11 We're in a situation where reality is

 12 for most homeowners these days they spend more

 13 money on cell phone bills than they do on heating

 14 and air conditioning in their homes. And if we're

14:49:12 15 talking about a change that might be a two- to

 16 three-percent savings in total energy use by an

 17 HVAC system, it's insignificant, versus additional

 18 cell phone or plasma TVs are, or all these other

 19 things impact the house.

14:49:28 20 Your methodology is fine.

 21 MR. BROOKMAN: Okay.

 22 MR. ROCKY: I think the results are

 23 going to be very disappointing.
 254

 1 MR. BROOKMAN: Thank you.

 2 Okay.

 3 DR. LEKOV: Environmental impact: So,

 4 DOE would report environmental impacts resulting

14:49:44 5 from standards, including changes in power plant

 6 emissions and the way it's going to be done is very

 7 similar to what just described for the utilities

 8 analysis, basically comparing a base case versus a

 9 standard case.

14:50:04 10 The result is an estimate of national

 11 emission reduction of CO2 and NOx and mercury.

 12 Important component of it, relatively new for

 13 industry partners, is essentially the monetization

 14 of these emissions, those that have been presented

14:50:31 15 during the several rulemakings this year.

 16 In summary, for this particular product

 17 DOE plans to use the most current social cost of

 18 carbon values developed by interagency reviews.

 19 This is -- The methodology and the values used by

14:50:48 20 DOE are developed outside of DOE.

 21 So, those values will be used to assign

 22 a, a monetary value, the green, potential green

 23 card house gas emissions, including but not limited
 255

 1 to different productivity loss, health effects,

 2 property damage, and rank changes in the ecosystem.

 3 This is what, this social cost of carbon, and, and

 4 those are the values that are going to be reported

14:51:20 5 in DOE's documentation for this product.

 6 Basically, DOE also will estimate the

 7 potential benefit of reduced NOx emission for the

 8 considered standard levels.

 9 The questions are input on its plans to

14:51:43 10 use NEMS-BT again for to conduct environmental

 11 assessment, and request comment on the approach it

 12 plans to use for estimating the monetary values.

 13 MR. BROOKMAN: Yes, Karim.

 14 DR. AMRANE: Karim Amrane, AHRI.

14:52:04 15 Are you thinking about energy

 16 consumption, are you going to be, or did I miss

 17 that, the energy consumption of those? But,

 18 anyway, my, my -- First of, of all, as I said

 19 before, we don't believe that this rulemaking

14:52:17 20 should apply to, to heat pumps and to, to air

 21 conditioners as well, at least those that have

 22 cores.

 23 Now, let's say that the, talk about this
 256

 1 split system. And, and, and you estimate the

 2 energy consumption of those fans, but again, the,

 3 the zero rating on the cooling side will account

 4 for, for the energy transfer fan as well.

14:52:38 5 So, now we are going to account for the

 6 CO2 emission that, that, that either the air

 7 conditioners will emit or will contribute, and at

 8 the same time it will double-, it will double-count

 9 the, the CO2 emission that the fan itself is, is

14:52:52 10 accounting for.

 11 So, I think DOE has to be very careful

 12 here, because, as I said, you are mixing something

 13 that is already accounted for in a SEER calculation

 14 or HSPF contemplation with this, with this new

14:53:06 15 energy, you know, thing, energy efficiency standard

 16 that you're trying to, to develop here.

 17 So, I think you need to account to, to,

 18 to, to make sure that you're not double-counting

 19 here.

14:53:20 20 MR. BROOKMAN: Okay.

 21 Any other comments, particularly on the,

 22 what they list here as cost of carbon, for example?

 23 (Whereupon, no response was had.)
 257

 1 MR. BROOKMAN: No additional comments on

 2 that? Okay.

 3 DR. LEKOV: And DOE also performs

 4 regulatory impact analyses, which essentially

14:53:51 5 investigate the national impacts of nonregulatory

 6 alternatives compared with mandatory efficiency

 7 standards. And usually this is the least of the

 8 policies that, nonregulatory alternatives that DOE

 9 analyzes.

14:54:11 10 I'll read them. Consumer rebates,

 11 consumer tax credits, manufacturer tax credits,

 12 voluntary efficiency targets, earlier replacement,

 13 and bulk government procurement.

 14 Usually DOE develops a separate national

14:54:28 15 impact analysis spreadsheet model for these

 16 policies, and estimate those based on existing

 17 experience with such policies. And output is very

 18 similar to the output from the national standard.

 19 You'll see a saving from the policy, and

14:54:51 20 you'll see net present values. In the case of, of

 21 furnace fans there are some incentives out there

 22 that are driving the market to a large extent, so

 23 this is here as appropriate place to assess the
 258

 1 history of those incentives and how they

 2 potentially could be considered.

 3 So, welcome comments on what the

 4 existing Regulations or pending Regulations should

14:55:27 5 consider in its examination of cumulative -- Oh,

 6 this is the correct one.

 7 DR. AMRANE: We were only going to

 8 answer it, it once.

 9 DR. LEKOV: Or --

14:55:38 10 MR. BROOKMAN: They're still paying

 11 attention, we've proven.

 12 MR. ROCKY: This is Bryan Rocky.

 13 I cannot overemphasize enough on the tax

 14 credits on the product mix that our industry's had

14:55:50 15 for the last two years. And while ECM motors and

 16 blower assemblies have been part of both

 17 manufacturer rebate levels as well as tax credits

 18 and utilities rebates, the vast majority of this is

 19 being driven by the zero HSPF and AUFE connection

14:56:13 20 as far as the tax credits for these rebates.

 21 And depending upon -- Without speaking

 22 for the rest of the manufacturers, depending on the

 23 product category from 2008 to 2010, those
 259

 1 high-efficiency products for us might have grown

 2 anywhere from 200 to 500 percent of the volume in

 3 two, that we built in those products in 2008.

 4 MR. BROOKMAN: Wow.

14:56:38 5 MR. ROCKY: That's a tremendous shift

 6 for us as a manufacturer. It's been a great value

 7 for the customers that have bought our products,

 8 and it has changed our business model going

 9 forward.

14:56:51 10 MR. BROOKMAN: Wow.

 11 MR. ROCKY: It is, it is the reality of

 12 it. And I think there will be a tremendous lag in

 13 our industry from the consumers if we don't

 14 continue as a nation to have more stimulus-type

14:57:04 15 packages and more consumer rebates and tax credits,

 16 because our customers are getting used to now

 17 having those available.

 18 MR. BROOKMAN: Like the automobile

 19 industry, for example.

14:57:14 20 Karim.

 21 DR. AMRANE: Karim Amrane, AHRI.

 22 Based on just what Bryan said, you don't

 23 need the rulemaking at all. Stop it.
 260

 1 Tax incentives should be what we, what

 2 the Government should do.

 3 MR. ROCKY: Yeah. I wasn't really

 4 actually trying to say that, but in the reality is

14:57:33 5 I would be all for a 95-percent AUFE motor Standard

 6 for the -- Because we would make a whole lot more

 7 money and sell product that our customers would be

 8 happier with in all these variations, and be more

 9 comfortable with.

14:57:48 10 Now, the cost of doing that, most

 11 homeowners will not enjoy that part of it. But, if

 12 they get tax credits, if they get utilities

 13 rebates, they get weatherization project money from

 14 their state and local governments, hey, it's free.

14:58:04 15 I'll buy this stuff. But we're all

 16 paying for that somehow.

 17 MR. BROOKMAN: Yeah. Okay. Thank you.

 18 Thank you, Alex.

 19 NEXT STEPS AND CLOSING REMARKS FROM INTERESTED

14:58:12 20 PARTIES

 21 Lets put up the, the final comment

 22 slide. And while he's doing that, now is an

 23 opportunity for anybody that wants to to make final
 261

 1 comments surrounding other issues that they wish to

 2 raise, or questions.

 3 Molly.

 4 MS. TROMBLEY-McCANN: Molly

14:58:26 5 Trombley-McCann.

 6 I actually have more of a process

 7 question, so maybe, Mohammed, this might be to you.

 8 But, in the slides it showed you going

 9 directly from the framework to the number stage.

14:58:36 10 I'm wondering if, for the Standards rulemaking at

 11 least, there's going to be preliminary technical

 12 support documents released, and if you plan on

 13 having any hearing time period for those documents.

 14 MR. KHAN: No different from the other

14:58:53 15 analyses that we do in our rulemaking goes. There

 16 would -- There will be technical support documents

 17 and everything provided.

 18 And, you know, after the NOPR's

 19 published we'll also have another public Hearing.

14:59:04 20 MR. BROOKMAN: Yeah. Let me -- While

 21 individuals in the room are formulating their

 22 comments, let me hand out this evaluation form.

 23 It takes about 30 seconds. The
 262

 1 Department reads them carefully.

 2 They like to receive feedback on these

 3 meetings, so, as I said, now is an opportunity for

 4 anybody that wishes to do so to make additional

14:59:37 5 comments, summary comments.

 6 Frank?

 7 MR. STANONIK: Frank Stanonik with AHRI.

 8 This particular rulemaking, I think it

 9 is critically important that perspective be

14:59:56 10 constantly maintained on this issue. We're talking

 11 about furnace fans.

 12 We're talking a lot, as Bryan mentioned,

 13 that from, from the worst to the best, at least as

 14 measured by DOE test procedures, that it's only,

15:00:12 15 that consumption is anywhere between four percent

 16 to something maybe a little less than two percent.

 17 And, and we've also made some comments

 18 that there's a potential to add a significant

 19 testing burden if you get carried away with this.

15:00:27 20 And, and so I, I think, again, it, somehow DOE and,

 21 and the, and their contractors need to keep this in

 22 perspective as far as what they're regulating and

 23 what it means to the overall picture of the, the,
 263

 1 let's say the overall consumption of the furnace,

 2 or in the case of, as we've said with the, with the

 3 heat pumps and air conditioners really shouldn't be

 4 applied because it's already been accounted for.

15:00:58 5 And so I just think that, that that's

 6 really critical in this situation.

 7 MR. BROOKMAN: Okay, thank you.

 8 Diane.

 9 DR. JAKOBS: Just to add onto what Frank

15:01:07 10 just said, we all have airflow data, but it's

 11 provided to our customers for their design of the,

 12 the complete system. If, if it was going to be

 13 data that had to be certified, typically for us, we

 14 do one sample.

15:01:26 15 But, if it was going to be certified to

 16 a certain confidence level, we would want two

 17 samples, three samples. And that would be a big

 18 burden to go back and, and take our existing stack

 19 of, you know, our offering, and go back and get

15:01:44 20 additional airflow data.

 21 MR. BROOKMAN: Okay.

 22 Karim.

 23 DR. AMRANE: Karim Amrane, AMRI again.
 264

 1 This is an excellent point that Diane's

 2 bringing. You know, there is this new enforcement

 3 of DOE.

 4 DOE is now thinking of, for example,

15:02:01 5 mandating educational programs. If this -- When

 6 this will be completed, manufacturers will have to

 7 certify their ratings.

 8 And that's going to be additional test

 9 burden on manufacturers that DOE eventually will

15:02:15 10 have to, to assess. So, all this, we were talking

 11 about rulemaking and rulemakings.

 12 And we are complicated test procedures

 13 involved in AC test procedures and everything else.

 14 And that has an impact on the manufacturers.

15:02:29 15 So, I hope that when you do these

 16 analyses, that you will account for all this,

 17 because it will show the way this industry, the way

 18 we are going probably is going to go bankrupt in

 19 the next 20 years just on the burden what have the

15:02:44 20 Federal Government is putting on manufacturers to

 21 test and to certify and to verify and everything

 22 else.

 23 MR. BROOKMAN: Okay, thank you.
 265

 1 Bryan.

 2 MR. ROCKY: Yeah, Bryan Rocky.

 3 Just as a last comment, I guess

 4 complexity of certified data gets to be a real

15:02:58 5 interesting discussion that in the case where we

 6 haven't had certified data before, and that always

 7 brings a question, and I guess I would comment,

 8 offer the last comment of appreciating the, the

 9 opportunity to be here to, to give comments, and we

15:03:13 10 will be providing written comments as well.

 11 But, the discussion with, with Charles,

 12 among other things, the speculation I think from a

 13 lot of groups is going to come out that this is not

 14 going to be something that's just a laboratory

15:03:24 15 comparison; that this might read, lead to a (sic)

 16 efficiency rating value that will directly

 17 correlate to something consumers would be able to

 18 use and say, "This is how much electricity my HVAC

 19 system is going to use."

15:03:43 20 And that, that is not this direction. I

 21 mean, it -- We're talking back to EPA

 22 miles-per-gallon in standard situations.

 23 I'm really concerned that where we're
 266

 1 going with this process, where DOE wants to take it

 2 is not going to lead us to a realistic test method

 3 or procedure that is good for comparing products

 4 from one manufacturer, one application to another,

15:04:04 5 but rather leads us towards something that we're

 6 not ready for yet, which is an applied energy

 7 descriptor that accounts for the vast variations in

 8 applications of homeowner styles and usage and

 9 maintenance and all these other things we've talked

15:04:22 10 about.

 11 MR. BROOKMAN: Okay, thanks.

 12 Yes, Diane.

 13 DR. JAKOBS: Well, the, the other side

 14 of a taking into account all those things is to

15:04:32 15 ignore them, you know, and maybe just having a, a

 16 standard rating point and a setup where you're

 17 comparing the same thing across products, and, you

 18 know, forget about trying to account for everything

 19 that happens in the installation.

15:04:51 20 That, that might be really more

 21 effective.

 22 MR. BROOKMAN: Molly.

 23 MR. TROMBLEY-McCANN: Molly
 267

 1 Trombley-McCann.

 2 This is actually another question, but

 3 I'm not as familiar with the case where there has

 4 not been Standards previous. And so I'm wondering,

15:05:06 5 for something that hasn't had a test procedure

 6 previous to this point, -- Our only new products

 7 that are introduced to the market required to be

 8 tested or are all products that are on the market.

 9 -- do manufacturers have to go back and test them

15:05:21 10 manually?

 11 MR. KHAN: Mohammed KHAN, DOE.

 12 It would apply to products that were

 13 manufactured after the compliance date.

 14 DR. JAKOBS: Manufactured, not designed;

15:05:30 15 right?

 16 MS. ARMSTRONG: Well, and she's got it

 17 right.

 18 MR. KHAN: Manufactured. Yeah

 19 MS. ARMSTRONG: Yeah.

15:05:41 20 MR. BROOKMAN: Okay. So, then thanks

 21 for these, this last round of comments.

 22 From my perspective, I'll turn it back

 23 to Mohammed KHAN. I really appreciate the level
 268

 1 and depth of the exchange.

 2 I think the Department got a lot of

 3 useful information. Thanks to all of you for that.

 4 Mohammed.

15:05:57 5 MR. KHAN: Thanks, Doug.

 6 Doug is right. We received a lot of

 7 very useful information and comments here today,

 8 and I want to thank you for that.

 9 And appreciation is doubled because,

15:06:09 10 like I said at the onset this morning, this is the

 11 first time the Department of Energy has embarked on

 12 rulemaking for a, a product that, well, which is

 13 basically, I guess, a sub-, sub-, subcomponent of

 14 a, of a, of a current product that's covered

15:06:29 15 already.

 16 So, it's important to, to get your

 17 information up front, and thoughts and suggestions

 18 on that. We covered a lot.

 19 We talked about -- We've got the

15:06:42 20 responses to the questions that we raised in our

 21 call-out boxes, and I think we also got some

 22 information, or touched on some points that were

 23 outside of the things that we are looking at.
 269

 1 And, for example, I think one of the

 2 ones that came up that I remember right off the bat

 3 was how long, or what the duration of the fan

 4 motors are actually operating at. And I think

15:07:08 5 someone here earlier mentioned that in the case of

 6 the newer homes that are being built, because

 7 they're more tightly built, homeowners are using

 8 these fans more liberally and making them, or

 9 allowing them to run without any cooling or heating

15:07:25 10 function going on as well.

 11 So, in providing us data and

 12 information, you know, things that we talked about

 13 in the call-out boxes in particular, we're looking

 14 to get -- And if there's information that's also

15:07:39 15 relevant that aren't specifically addressed or

 16 called out in the, in the presentation, that's also

 17 going to be welcome.

 18 And, again, just to make clear, comment

 19 period closes July sixth. And these are the ways

15:07:54 20 that, that you can send them to us.

 21 And again, thank you for your time

 22 today.

 23 MR. BROOKMAN: Safe travels.
 270

 1 (Whereupon, at 3:08 p.m. ET, the above

 2 Hearing was concluded.)

 3 The foregoing ASCII transcript

 4 has been edited and was, at

 5 the time of delivery, a

 6 certifiable Transcript of the

 7 proceedings, barring any

 8 post-delivery edits.

 9 CERTIFICATION

 10 I, D. I. Bunn, a Registered

 11 Professional Reporter, Certified Conference

 12 Reporter, and Notary Public, do hereby certify that

 13 the foregoing testimony was duly taken and reduced

 14 to writing before me at the place and time therein

 15 mentioned. I further certify that I am neither

 16 related to any of the parties by blood or marriage,

 17 nor do I have any interest in the outcome of the

 18 above matter.

 19 In witness whereof, I have hereunto set

 20 my hand and affixed my official seal, at

 21

 22

 23
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 1 Washington, D.C., USA, this 20th day of June, 2010.

 2

 E-signature: D. I. Bunn

 3

 Notary Public

 4

 5 My Commission expires January 5, 2012.

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