202-234-4433

Neal R. Gross & Co., Inc.

Page 1

 UNITED STATES OF AMERICA 

 + + + + + 

 DEPARTMENT OF ENERGY 

 + + + + + 

 PUBLIC MEETING ON TEST PROCEDURES FOR 

 RESIDENTIAL CLOTHES DRYERS 

 + + + + + 

 WEDNESDAY 

 FEBRUARY 6, 2013 

 + + + + + 

 The meeting convened in Room 1E245, 1000 Independence Avenue, Washington, 

D.C., at 9:00 a.m., Doug Brookman, Meeting 

Facilitator, presiding. 

PRESENT 

DOUG BROOKMAN, Meeting Facilitator, Public 

 Solutions 

ASHLEY ARMSTRONG, DOE 

BETSY KOHL, DOE 

STEPHEN WITKOWSKI, DOE 

JENNIFER THORNE AMANN, American Council for 

 an Energy-Efficient Economy 

JAMES BATTAGLIA, Navigant Consulting 

MICHAEL BROWN, Hydromatic Technologies 

 Corporation 

CHRIS CALWELL, Ecova 

JENNIFER CLEARY, Association of Home 

 Appliance Manufacturers 

ABIGAIL DAKEN, EPA 

TOM ECKMAN, Northwest Power and Conservation 

 Council 

JULIA FARBER, UL LLC 

STEPHEN B. LEYBOURN, Association of Home 

 Appliance Manufacturers 

JESSICA LYMAN, ICF International 
202-234-4433

Neal R. Gross & Co., Inc.

Page 2

JOANNA MAUER, Appliance Standards Awareness 

 Project 

JUDITH REICH, Navigant Consulting 

MICHAEL RIVEST, Navigant Consulting 

CHARLES STEPHENS, Northwest Energy Efficiency 

 Alliance 

MEG WALTNER, Natural Resources Defense 

 Council 

CHRISTOPHER WOLD, CLASP 

DIMPLES YOUNG, Hydromatic Technologies 
202-234-4433

Neal R. Gross & Co., Inc.

Page 3

 CONTENTS 

Call to Order 5 

 Doug Brookman 

 Facilitator 

Welcome 5 

 Stephen Witkowski 

 DOE 

Introductions 6 

Agenda Review 9 

 Doug Brookman 

 Facilitator 

Comments by Charles Stephens 13 

 Northwest Energy Efficiency Alliance 

Comments by Michael Brown 24 

 Hydromatic Technologies 

Comments by Joanna Mauer 28 

 Appliance Standards Awareness Project 

Introduction and Regulatory History 

 Stephen Witkowski 

 DOE 

Covered Products: Automatic Cycle 31, 38 

Termination 56, 63 

 James Battaglia 67, 69 

 Navigant 73, 77 

 84, 102 

 105, 120 

 133, 135 

 Questions and Comments 35, 40 

 59, 64 

 68, 69 

 75, 79 

 85, 104 

 110, 122 

 134, 136 
202-234-4433

Neal R. Gross & Co., Inc.

Page 4

 CONTENTS (CONTINUED) 

Standby/Off Mode: Incorporating 141, 150 

IEC Standard 62301 (Second Edition) 155, 164 

 James Battaglia 172, 174 

 Navigant 

 Questions and Comments 145, 153 

 163, 166 

 172, 182 

Closing Remarks and Adjourn 202 

 Stephen Witkowski 

 DOE 
202-234-4433

Neal R. Gross & Co., Inc.

Page 5

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

2 9:01 a.m. 

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

4 Good morning, everyone, and 

5 welcome. 

6 This is the U.S. Department of 

7 Energy's public meeting on test procedures for 

8 residential clothes dryers. Today is February 

9 6th, 2013, here in the Forrestal Building in 

10 Washington, D.C. 

11 My name is Doug Brookman from 

12 Public Solutions in Baltimore. I will be 

13 facilitating today's meeting. 

14 We are going to start off this 

15 morning with welcoming remarks from Stephen 

16 Witkowski. 

17 MR. WITKOWSKI: Well, good 

18 morning, everyone. I want to welcome you to 

19 this rulemaking. 

20 Just a few things to try to keep 

21 in mind. 

22 DOE is here to collect 
202-234-4433

Neal R. Gross & Co., Inc.

Page 6

1 information, to share information, and to 

2 eventually evaluate it. We hope that, besides 

3 your remarks in this meeting, you will -- 

4 MR. BROOKMAN: Hey, Stephen, is 

5 your microphone on? 

6 MR. WITKOWSKI: I think so. 

7 MR. BROOKMAN: Thank you. 

8 MR. WITKOWSKI: Is that better? 

9 MR. BROOKMAN: Yes. 

10 MR. WITKOWSKI: And we strongly 

11 urge you to supply written comments or any 

12 additional comments that you have after the 

13 meeting within the comment period. 

14 So, that's it. 

15 MR. BROOKMAN: Okay. So, it is 

16 our tradition to start with introductions 

17 around the room. I will start here, 

18 immediately to my left. 

19 You can get used to turning the 

20 microphone on and off. That little green 

21 button needs to be illuminated. 

22 Please say your name and 
202-234-4433

Neal R. Gross & Co., Inc.

Page 7

1 organizational affiliation. 

2 MR. BROWN: Good morning. 

3 MR. BROOKMAN: Down below there is 

4 that broader band. That thing, yes (referring 

5 to turning on the microphone). 

6 MR. BROWN: Okay. Good morning. 

7 My name is Michael Brown. We 

8 represent Hydromatic Technologies Corporation. 

9 We are the newest appliance manufacturing 

10 organization with a highly-energy-efficient 

11 clothes dryer. We are happy to be here this 

12 morning. 

13 MR. BROOKMAN: Thank you. 

14 MS. YOUNG: Okay. My name is 

15 Dimples Young. I am here representing 

16 Hydromatic Technologies with Michael Brown, 

17 just supporting. 

18 And thank you all for having us 

19 here. 

20 MR. BROOKMAN: Thank you. 

21 MS. CLEARY: Jennifer Cleary with 

22 the Association of Home Appliance 
202-234-4433

Neal R. Gross & Co., Inc.

Page 8

1 Manufacturers. 

2 MR. LEYBOURN: Steve Leybourn, 

3 also with the Association of Home Appliance 

4 Manufacturers. 

5 MS. DAKEN: Abigail Daken, U.S. 

6 EPA. 

7 MS. FARBER: Julia Farber with UL. 

8 MR. CALWELL: I'm Chris Calwell 

9 from Ecova, and we are representing the 

10 California Investor-Owned Utilities. 

11 MR. STEPHENS: Charlie Stephens 

12 from the Northwest Energy Efficiency Alliance. 

13 MR. ECKMAN: Tom Eckman, Northwest 

14 Power and Conservation Council. 

15 MS. WALTNER: Meg Waltner, Natural 

16 Resources Defense Council. 

17 MS. MAUER: Joanna Mauer, 

18 Appliance Standards Awareness Project. 

19 MR. WOLD: Christopher Wold from 

20 CLASP. I am also representing SEDI, the Super 

21 Efficient Dryer Initiative. 

22 MS. KOHL: Betsy Kohl, DOE General 
202-234-4433

Neal R. Gross & Co., Inc.

Page 9

1 Counsel. 

2 MR. WITKOWSKI: Stephen Witkowski 

3 with the Department of Energy. 

4 MR. BATTAGLIA: James Battaglia, 

5 Navigant Consulting. 

6 MS. ARMSTRONG: Ashley Armstrong, 

7 DOE. 

8 MS. LYMAN: Jessica Lyman, ICF 

9 Consulting. 

10 MR. BROOKMAN: Thank you. 

11 Would you like to introduce 

12 yourself? Thank you. Okay. 

13 All of you I see received a packet 

14 of information as you came into the room, both 

15 an agenda and a series of PowerPoint slides, 

16 as well as The Federal Register notice. So, I 

17 am going to do a brief review of the agenda 

18 first. 

19 Immediately following this agenda 

20 review, we are going to have opening remarks 

21 and, then, an introduction and regulatory 

22 history. There is an opportunity here at the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 10

1 outset for anybody who wishes to do so to make 

2 brief summary comments about issues that are 

3 important to you. 

4 Following that, we are going to 

5 have a description of the covered products. 

6 You can see it there listed: the automatic 

7 cycle termination feature. 

8 We will take a break mid-morning, 

9 round about 11 o'clock or so. 

10 Following the mid-morning break, 

11 standby and off mode, incorporating IEC 

12 Standard 62301, the Second Edition. 

13 Moving on from there, technical 

14 corrections and clarifications to test 

15 conditions. 

16 Following that, effects of test 

17 procedures revisions on standards, and EPCA 

18 requirements. 

19 At 12:45 or so, whenever we get 

20 there today, yet another opportunity for 

21 anybody who wishes to do so to make closing 

22 remarks, cover issues that haven't been 
202-234-4433

Neal R. Gross & Co., Inc.

Page 11

1 covered to your satisfaction today. 

2 And as the agenda reflects, we 

3 intend to adjourn today early, perhaps 12:45 

4 or so. But we will take a mid-morning break 

5 and, then, we are going to keep pressing on. 

6 We are not going to pause for lunch. We are 

7 just going to get this done as soon as we can 

8 expeditiously. Okay? 

9 I ask for your consideration, 

10 please. I have charted up here on the flip 

11 chart what have emerged as common courtesies 

12 in these meetings. 

13 Please speak one at a time. 

14 Please say your name for the record each time 

15 you speak. You don't need to say your 

16 organizational affiliation. We know who is 

17 here, but we do want your name because there 

18 will be a complete transcript of this meeting. 

19 If you could keep the focus here, 

20 please turn your cell phones on silent mode 

21 and limit sidebar conversations. 

22 All of you have already gotten the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 12

1 habit of turning the microphones on and off. 

2 They work pretty well. But let's do turn them 

3 on and off. 

4 If you could be concise, share the 

5 airtime. Even though this is a fairly brief 

6 meeting, there is still a lot to be said. And 

7 the Department really values all of your good 

8 comments. So, let's make sure we get them all 

9 appropriately captured in the record. 

10 And for webinar participants, 

11 welcome. We are glad to have you joining us. 

12 How many do we have on the web? 

13 MR. GRAUL: Twelve. 

14 MR. BROOKMAN: Twelve via the web. 

15 If you could please mute your 

16 telephones, so that you don't cause feedback 

17 here in the room at Forrestal. And when you 

18 wish to speak, if you wish to speak, please 

19 raise your hand on the software, and we will 

20 find a way to get you into this conversation. 

21 Questions and comments here at the 

22 outset before we proceed? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 13

1 (No response.) 

2 Then, to Stephen Witkowski. Do 

3 you want to do that first? Okay. Do you want 

4 to cue this slide? 

5 So, then, we are going to hear 

6 from NEEA first. Charlie Stephens is going to 

7 provide an overview. 

8 There is a slide -- yes. 

9 MR. STEPHENS: Good morning. 

10 There is not a long explanation 

11 here. I will take just a minute to explain 

12 what you are about to see. It is going to be 

13 pretty much visual. 

14 It comes from a combination of my 

15 organization's field data in 50 households in 

16 four states in the Pacific Northwest. We have 

17 been into 1400 households there, and this is a 

18 subset of that. We have the data. We will 

19 share the data with anyone who wants it. 

20 Where we had our people in these 

21 households basically tell us what they were 

22 washing. We have their laundry equipment by 
202-234-4433

Neal R. Gross & Co., Inc.

Page 14

1 make and model number and year of manufacture. 

2 We know the demographics for the household, 

3 and we monitored the energy use of the clothes 

4 washer and the clothes dryer, the clothes 

5 dryer at one-minute intervals -- or excuse me 

6 -- at 15-second intervals. 

7 And so, we have a lot of data here 

8 that showed us what people are washing. These 

9 people weighed their clothes for us three 

10 times with each load for a month, before it 

11 went in the washer, between the washer and 

12 dryer, and after it came out of the dryer. 

13 And they kept a log of what they were doing 

14 and whether they took stuff out, whether they 

15 used dryer sheets, all that kind of stuff. 

16 So, we have a lot of data. 

17 We also worked with Ecova -- Chris 

18 Calwell is back here in the back of the room 

19 -- to do some lab testing, some of which was 

20 on machines that were virtually identical to 

21 some of the machines that were in our study, 

22 so we could compare the lab data and the field 
202-234-4433

Neal R. Gross & Co., Inc.

Page 15

1 data. 

2 And we have been testing those 

3 with more than one kind of load, with a DOE 

4 load, but we have also been testing with the 

5 AHAM 1992 load. So, what you are going to see 

6 here is the data from those two things. 

7 First of all, just to give you an 

8 idea of the character of what you are going to 

9 see, this is the distribution of drying times 

10 from our field data. And you can see what the 

11 typical DOE load takes in terms of drying time 

12 there in the red line on the left. 

13 So, when you see that, it tells us 

14 right away that what is going on in the field 

15 is not exactly what goes on in the test 

16 procedures. So, there are lots of graphs like 

17 this, but they will be in different forms. 

18 This is another form of the graph. 

19 On the left is energy consumed per cycle in 

20 kilowatt hours, and on the bottom is drying 

21 time in minutes. Now the square with the 

22 green rim around it down there in the lower 
202-234-4433

Neal R. Gross & Co., Inc.

Page 16

1 left is the DOE test load, and the rest is our 

2 data. And our average is the green triangle. 

3 So, you can sort of see where the DOE test 

4 load comes out in relation to the field data 

5 when we actually look at what people wash and 

6 how they wash it. 

7 In this one, energy consumed is on 

8 the left and load size is on the bottom. And 

9 you can sort of see here that DOE does a 

10 little bit better on the load size. Our 

11 average load size was actually slightly 

12 smaller than the DOE load size to start with. 

13 So, what is going on? 

14 Well, here is a summary of what is 

15 going on and why these things look the way 

16 they do. First of all, you can see that the 

17 remaining moisture in our customer loads 

18 averaged 80 percent, not the 70 percent that 

19 we used to use and not the 60 percent plus or 

20 minus, 57 percent -- excuse me -- that we are 

21 using now. 

22 We think we have some explanations 
202-234-4433

Neal R. Gross & Co., Inc.

Page 17

1 for why that is. We would be happy to talk 

2 about it later. 

3 You can see, because of that RMC, 

4 water removed is much larger. The dry weight, 

5 as I said, is actually less than the 8.45 DOE 

6 load. 

7 You can see down in the big box 

8 that the clothes that are being washed are 

9 mostly three-dimensional and heavy, heavier 

10 fabric and varying thickness. The average 

11 drying time is more than double what you get 

12 with a typical DOE load. So, obviously, the 

13 energy used per load is greater. 

14 And you can see the washer cycles 

15 that go into the dryer is greater than 100 

16 percent, and that is because some of these 

17 loads are being split in two. So, people are 

18 washing one load, but they are splitting it up 

19 to dry it because they know that the dryer 

20 won't dry it in any reasonable amount of time 

21 if they don't probably. That is what some 

22 interviews with some of our folks will tell 
202-234-4433

Neal R. Gross & Co., Inc.

Page 18

1 us. 

2 Loads per year, a little bit 

3 higher than the old DOE number of 416. So, 

4 the average number of loads has gone up a 

5 little bit, but not enough so we would 

6 complain about it. 

7 The other thing you will notice is 

8 that I think a lot of people assumed that the 

9 bigger clothes washers would result in more 

10 consolidated loads and bigger loads. Well, 

11 that is not happening. As you can see, our 

12 average load size was actually a little under 

13 DOE's load size. So, people are not, 

14 obviously, using their larger clothes washers 

15 to wash larger loads. 

16 And you can see what the average 

17 energy use per dryer in kilowatt hours per 

18 year was. If you use the DOE test procedure 

19 and scale it up, it is 641 kilowatt hours. 

20 Our average annual energy use is 1134 kilowatt 

21 hours, nearly double what the DOE test 

22 procedure produces. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 19

1 These are the loads that we are 

2 looking at. On the left is the DOE load. The 

3 big rectangle is just one of those things that 

4 is folded, stretched out. That is the case in 

5 all of these loads. There is one sample of 

6 these, what is in the piles, spread out, so 

7 you can see what they actually are. 

8 So, there is the IEC easy care 

9 load -- that is a mixed load -- and the AHAM 

10 1992 test load. 

11 Okay. Now here is the difference 

12 in the loads, and I want to show you this 

13 because it is kind of interesting to see when 

14 you stretch it all out. 

15 What you are going to see is the 

16 cotton content of the load on the left and the 

17 ply thickness, the fabric thickness, 

18 essentially, along the bottom. We are going 

19 to plot some dots here. 

20 The first one you are going to 

21 see, there is the DOE test load. It is a 

22 mixed load, cotton and polyester, but it is 
202-234-4433

Neal R. Gross & Co., Inc.

Page 20

1 utterly consistent, and the ply is fairly 

2 thin. 

3 This is the IEC mixed load, a 

4 little bit thinner fabric yet, but a little 

5 more cotton in the fabric. 

6 This is the IEC cotton load, 

7 obviously, 100 percent cotton, but the plies 

8 that are being loaded or washed and dried here 

9 are obviously fairly thin. They are not 

10 really different at all than the DOE ply. 

11 This is the Australia/New Zealand 

12 load, which, as you can see, is mostly cotton, 

13 but you can see that there is an enormous 

14 range of ply thickness here. So, some things 

15 are easier to dry than others. This a lot 

16 more resembles the loads that we actually see 

17 when we see stuff in the field. You can see 

18 there is a little bit of mix down there in the 

19 60 percent cotton on the far right, but it is 

20 a heavy ply. 

21 And this is the AHAM 1992 test 

22 load, which is what we have been testing in 
202-234-4433

Neal R. Gross & Co., Inc.

Page 21

1 the lab. And you can see that it is cotton, 

2 but it has a very good range of ply thickness. 

3 And so, it gives you a better idea of what it 

4 takes to actually dry a typical field load, we 

5 think, than all of these others. 

6 We haven't tested the Australian 

7 load because we haven't been able to get a 

8 hold of one. 

9 Just a few other things from our 

10 study. You can see that for dryer temperature 

11 selected, more than half, just more than half, 

12 selected medium as the temperature setting for 

13 the load. Dryness level, you can see that 57 

14 percent selected normal, and 42 selected very 

15 dry. 

16 Airflow rates, we measured the 

17 airflow of the dryers at the terminus of the 

18 dryer vent for each of these houses. The 

19 lowest airflow we measured was 6 CFM, and you 

20 can see the highest was up there a little over 

21 160 CFM. We did have to repair the one that 

22 had 6 CFM. We didn't dare let those people 
202-234-4433

Neal R. Gross & Co., Inc.

Page 22

1 use the dryer during the study. So, we had to 

2 actually clean out their exhaust. 

3 But you can see there that the 

4 typical DOE airflow rate is quite a bit higher 

5 than the preponderance of our data. So, the 

6 airflow that we are seeing in the field 

7 averaged 79 CFM. 

8 This is a result from our lab 

9 work. You can sort of see the variation of 

10 the IEC cotton auto termination load and the 

11 DOE auto termination load. When you plot the 

12 variation that you see in the tests, it is a 

13 little bit higher with the cotton load, but it 

14 is not that much higher. And given that the 

15 amount of energy that it takes to dry these 

16 loads is quite a bit higher, the results as a 

17 percentage of what you are measuring are not 

18 all that different. So, we are not very 

19 concerned about that. 

20 So, we will cover all of this 

21 stuff, I am sure, in part of the discussion 

22 today. But all I wanted to do was give you a 
202-234-4433

Neal R. Gross & Co., Inc.

Page 23

1 sense of the data and what it looks like as we 

2 make our comments as we go through the morning 

3 here. 

4 MR. BROOKMAN: Okay. 

5 MR. STEPHENS: Thanks very much. 

6 MR. BROOKMAN: Thank you, Charlie. 

7 As I understand it, the audio, for 

8 those of you that are joining us via the web, 

9 the audio for everyone that is not at the 

10 podium, presenting at the podium, is garbled, 

11 but we are working on it. So, hopefully, that 

12 will be fixed, and you will be able to hear 

13 all the comments coming from every participant 

14 here in the room. 

15 Since we started with these 

16 comments here at the outset, maybe we will 

17 just continue with that before we have Stephen 

18 Witkowski's opening remarks. 

19 Other comments here at the outset 

20 from anybody? 

21 Michael, do you wish to make a 

22 comment? Please say your name for the record. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 24

1 MR. BROWN: Yes, Michael Brown. 

2 I would like to represent 

3 something to this audience and to the 

4 Department of Energy here. 

5 Our company, Hydromatic 

6 Technologies, has been in business since 2005. 

7 We developed a clothes dryer technology that 

8 has tested against all of the big boys in this 

9 room, for the most part, the biggest one, I 

10 should say. I am going to call them out 

11 because I have no other choice. 

12 Whirlpool Corporation and 

13 Electrolux, we tested our dryers' technology 

14 against their heating system. Bear in mind, 

15 although these are giant companies, I am here 

16 today in the company of giants, but I am not 

17 here to represent that role of a mouse. So, I 

18 have to speak to let everyone know that our 

19 technology, the hybrid electric technology, is 

20 better than any technology for dryers that we 

21 are talking about today. 

22 I am saying that because I have 
202-234-4433

Neal R. Gross & Co., Inc.

Page 25

1 already gone up against the heating systems of 

2 electric resistance heat elements. And my 

3 hydronic technology, which we formerly called 

4 hydronic, is now known as a hybrid electric 

5 technology. 

6 I have gone up against gas dryers 

7 and tested against gas dryers, and our 

8 technology has outperformed, in energy 

9 efficiency and safety, gas dryers. 

10 I have gone -- 

11 MR. BROOKMAN: I want to make sure 

12 your comments relate to the test procedure. 

13 MR. BROWN: Yes, I am. Yes, they 

14 are. Thank you. 

15 And as a result of the fact, we 

16 now understand the heat pump dryer. And Mr. 

17 Stephens has mentioned previously about the 

18 testing of dryers. He didn't call out the 

19 heat pump dryer, but I understand that you are 

20 speaking of the heat pump dryer. 

21 And when it comes to testing, Mr. 

22 Brookman, we seem to have a big problem with 
202-234-4433

Neal R. Gross & Co., Inc.

Page 26

1 getting our dryers tested, a major problem. 

2 And I understand that there is a process, but 

3 I just am here today to state for the record 

4 that the best technology that is not here 

5 today has not yet been tested. 

6 And I want it tested by any 

7 organization that is a valid, fair, unbiased 

8 organization for testing a clothes dryer 

9 technology that will deliver less energy 

10 consumption for every load that may be 

11 utilized. Whether it is DOE's load or AHAM's 

12 load or even the real-world load, it will 

13 deliver better once it is tested. 

14 So, this NOPR is here to discuss 

15 testing protocols for dryers. And I am still 

16 here to say -- I came personally with my 

17 executive representative -- to share with the 

18 DOE that this room is not representing the 

19 best technologies for testing dryers that are 

20 going to be at some point offered to the U.S. 

21 public. 

22 And I am challenging everyone to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 27

1 please look at what I am saying, listen to 

2 what I am saying, and engage the technology 

3 for testing before you set standards in place 

4 for how you will test a clothes dryer, and you 

5 leave out and omit the best technology that is 

6 available today. 

7 UL approved our technology also in 

8 2009, I might say, and I am also familiar with 

9 James Battaglia. When I tried to get my dryer 

10 tested, and I submitted it to the Department 

11 of Energy and the NETL Laboratory, then it got 

12 sent back without being tested because it 

13 wasn't commercialized. So, I just want to 

14 make a statement to that effect. 

15 Testing is important for us. We 

16 want our dryers tested, so that it can become 

17 a part of the forum here at some future point 

18 in time. 

19 Thank you. 

20 MR. BROOKMAN: Okay. Now we will 

21 take other comments here at the outset. Other 

22 comments here at the outset? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 28

1 Joanna? 

2 MS. MAUER: Joanna Mauer. 

3 We are pleased to see that DOE has 

4 worked to address the issue of effectiveness 

5 of automatic-termination controls, which was 

6 raised by efficiency advocates and AHAM in a 

7 joint petition. We thank DOE for advancing 

8 this rulemaking. 

9 We generally support DOE's 

10 proposal in the NOPR for capturing the 

11 effectiveness of automatic-termination 

12 controls in the test procedure. However, we 

13 are unclear as to the purpose of the field 

14 adjustment factor of 0.8 which DOE has 

15 proposed in the NOPR. It seems as though, 

16 instead of reflecting field performance, the 

17 application of the field adjustment factor 

18 would actually result in energy consumption, 

19 as measured by the test procedure further 

20 diverging from field consumption. 

21 And in addition, NEEA has raised 

22 several additional test procedure issues, and 
202-234-4433

Neal R. Gross & Co., Inc.

Page 29

1 we generally join in the comments that NEEA 

2 and the California IOUs will be making. Some 

3 of these issues include test load, initial 

4 RMC, and cycles per year. 

5 Thank you. 

6 MR. BROOKMAN: Thank you. 

7 Other comments here at the outset? 

8 (No response.) 

9 Then, we will go to Stephen 

10 Witkowski. 

11 MR. WITKOWSKI: Good morning, and 

12 thank you. I will quickly go through the test 

13 procedure rulemaking timetable here and the 

14 legislative history. 

15 Could I see the first slide? 

16 Okay. Well, anyway, most of this 

17 you already know. But the NOPR was published 

18 in The Federal Register on January 2nd, 2013. 

19 Today is the public meeting for that NOPR. 

20 And what is particularly important for today 

21 are your comments on the NOPR from the 

22 interested parties. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 30

1 Remember that the transcripts of 

2 the recorded oral comments will be published 

3 and, also, we strongly recommend that you 

4 submit written comments. This is your 

5 opportunity to express your interest, your 

6 concerns about the test procedure. Then, DOE 

7 will review all of the comments and then final 

8 rule publication. 

9 Next slide. 

10 MR. BROOKMAN: Do you have a 

11 clicker up there? 

12 MR. WITKOWSKI: It didn't work 

13 right for me. 

14 MR. BROOKMAN: Okay. 

15 MR. WITKOWSKI: Anyway, just a 

16 quick overview of the test procedure and the 

17 issues that we expect to cover today. 

18 There will be a discussion of the 

19 covered products and proposed amendments to 

20 the test procedure; the automatic-termination 

21 cycle, which I know all of you or most of you 

22 are interested in; incorporation by reference 
202-234-4433

Neal R. Gross & Co., Inc.

Page 31

1 of IEC 62301, which is what we use now for 

2 measuring standby and off mode power; 

3 technical corrections to the per-cycle 

4 combined total energy consumption calculation; 

5 clarifications to the test procedure in 

6 general; the effects of the proposed test 

7 procedure revisions on compliance with the 

8 standards, and compliance with other EPCA 

9 requirements. 

10 The regulatory history is pretty 

11 straightforward. I am not going to go through 

12 this line-by-line. The history is there. So, 

13 in the interest of moving forward, let's -- 

14 and again, the regulatory history is there. 

15 And now, it is time to get into 

16 the meat of the meeting, and we will start 

17 with products covered by the proposed 

18 amendments. 

19 James Battaglia of Navigant. 

20 MR. BATTAGLIA: Hi, everybody. I 

21 am James Battaglia. 

22 So, just to first cover the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 32

1 covered products for this rulemaking, the 

2 proposed amendments that we will be discussing 

3 today will cover both gas and electric clothes 

4 dryers, which are defined in DOE's regulations 

5 as cabinet-like appliances that are designed 

6 to dry fabrics in a tumble-type drum with 

7 forced-air circulation, with blowers, and the 

8 drum and blowers are driven by one or more 

9 electric motors. And the heat source is 

10 either gas or electricity. Now DOE is not 

11 proposing any amendments to these definitions 

12 at this time. 

13 Now, to get into the issues of 

14 automatic cycle termination, the current DOE 

15 test procedure in both Appendix D and D1 

16 currently requires that manufacturers apply a 

17 field-use factor to the per-cycle energy 

18 consumption measurement to determine the 

19 performance of automatic cycle termination. 

20 DOE recognizes that the current 

21 test procedure for automatic cycle termination 

22 does not distinguish between the type of 
202-234-4433

Neal R. Gross & Co., Inc.

Page 33

1 sensor being used -- that is, whether it is a 

2 temperature sensor, a moisture sensor, or some 

3 other form of sensing -- and the accuracy and 

4 sophistication of the control system. Now, 

5 for automatic-termination dryers, they are 

6 currently assigned a field-use factor of 1.04, 

7 and timer dryers are assigned a field-use 

8 factor of 1.18. 

9 Now, in the last final rule for 

10 the test procedure that published in January 

11 of 2011, DOE did not adopt amendments for more 

12 accurately measuring the effects of automatic13 termination that were originally proposed in 

14 the SNOPR for that rulemaking. DOE had 

15 conducted testing for that rulemaking that 

16 showed that using the proposed automatic17 termination test method, all of the dryers 

18 tested significantly overdried the DOE test 

19 load to a near bone-dry state. As a result, 

20 the measured CEF was significantly lower than 

21 using the current test procedure. 

22 So, in that final rule, DOE 
202-234-4433

Neal R. Gross & Co., Inc.

Page 34

1 determined that the amendments that were 

2 proposed in the SNOPR for automatic3 termination did not adequately measure the 

4 energy consumption of automatic-termination 

5 dryers. 

6 Now DOE noted in that final rule 

7 that the clothes dryers with automatic8 termination sensing controls, which actually 

9 infer the RMC of the load, using either 

10 moisture or temperature sensing, may be 

11 designed to stop the cycle when loads that are 

12 composed of varying shapes and sizes and 

13 composition, when those loads have a higher 

14 RMC than the RMC using the DOE test load. 

15 Now in -- oh, sorry. 

16 MR. BROOKMAN: Let's pause there. 

17 Charlie Stephens, we have received 

18 a consultation from our tech folks. Let's try 

19 this because this might work. Everybody turn 

20 on your microphone, and then we will see if 

21 that helps to ungarble the sound that is being 

22 sent to the webinar participants. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 35

1 Charlie, you are next in the 

2 queue. You go first. 

3 MR. STEPHENS: Yes, I am Charlie 

4 Stephens. 

5 I take it DOE did not do any 

6 testing of other loads other than the DOE test 

7 load when they were drawing the conclusions 

8 about the dryers might behave with a different 

9 load? 

10 MR. BATTAGLIA: For that testing, 

11 we did use the IEC/AHAM test load for that 

12 previous rulemaking. 

13 MR. STEPHENS: Okay. 

14 MR. BATTAGLIA: So, this was 

15 comparing the results for those. 

16 MR. STEPHENS: But I haven't seen 

17 anywhere any published results of what the 

18 RMCs actually were when you tested that load, 

19 and were they 5 percent or over/under 5 

20 percent? 

21 MR. BATTAGLIA: Yes, there is 

22 actually, in the NOPR there is a good amount 
202-234-4433

Neal R. Gross & Co., Inc.

Page 36

1 of data for the RMC using the IEC/AHAM test 

2 load. I believe it ranged from about 1.3 to 

3 4.7 percent. 

4 MR. STEPHENS: Okay. And so, we 

5 understand the bone-dry relationship, but the 

6 range of the data that I saw was substantially 

7 less than 5 percent. I mean, there was a lot 

8 of data there that was well under 5 percent, 

9 which seemed to be the behavior of the dryer. 

10 Is that true? Could that be said to be true? 

11 MR. BATTAGLIA: Sorry. Is that 

12 for the IEC test load? 

13 MR. STEPHENS: Right. 

14 MR. BATTAGLIA: That there was a 

15 wide range or -- 

16 MR. STEPHENS: Yes, there was a 

17 wide range, but, I mean, I think a lot of it 

18 was well under 5 percent. At termination of 

19 the auto-termination cycle, substantial 

20 amounts of the loads were well under 5 percent 

21 RMC. 

22 MR. BATTAGLIA: Yes, I believe the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 37

1 majority were. I would have to go back and 

2 look at the data, but it is probably between 1 

3 and 3 were the majority. 

4 MR. STEPHENS: Yes, that is kind 

5 of my impression, too. Thank you. 

6 MR. BATTAGLIA: Okay. 

7 MR. BROOKMAN: Okay. Michael? 

8 MR. BROWN: Michael Brown. 

9 I understand that the DOE doesn't 

10 distinguish between the type of sensors used 

11 for auto termination. Does the DOE specify 

12 the location of those particular sensors? 

13 MS. YOUNG: No, it does not. 

14 MR. BROWN: Okay. 

15 MR. BATTAGLIA: That is just for 

16 the field-use factor that is applied to the 

17 test cycle energy consumption calculation, and 

18 it just applies to all dryers with automatic19 termination. So, currently, any dryer that 

20 has automatic-termination would receive that 

21 1.04 field-use factor. 

22 MR. BROWN: So, in effect, I 
202-234-4433

Neal R. Gross & Co., Inc.

Page 38

1 understand the field-use factor. So, in 

2 effect, the location of the sensors, then, 

3 themselves could be per se located in the 

4 exhaust of a dryer? 

5 MR. BATTAGLIA: Yes, that is 

6 correct. 

7 MR. BROWN: Okay. Thank you. 

8 MR. BROOKMAN: Okay. 

9 MR. BATTAGLIA: So, in August of 

10 2011, DOE published a Request for Information 

11 notice to further investigate the effects of 

12 automatic cycle termination and to request 

13 information and additional comments on this 

14 issue. In particular, DOE sought comment on 

15 the issues we have listed here. That is the 

16 characteristics of the loads of varying 

17 weights, composition, and size; the accuracy 

18 of different automatic-termination sensors and 

19 controls; the target final RMC used by 

20 manufacturers to maintain consumer 

21 satisfaction; the effects of the 

22 characteristics of the water for wetting the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 39

1 load, and, in particular, the hardness and 

2 conductivity of the water; and, finally, the 

3 automatic-termination settings that were 

4 selected by consumers. 

5 Now, in response to the RFI, DOE 

6 received a joint stakeholder petition stating 

7 that DOE should amend the clothes dryer test 

8 procedure to include provisions to account for 

9 the effectiveness of automatic-termination. 

10 The petition specifically stated that DOE 

11 should amend the test procedure to include the 

12 full automatic-termination cycle, including 

13 the cool-down period and that the final RMC of 

14 using DOE test load should be no more than 2 

15 percent. And that 2 percent was based on data 

16 submitted by manufacturers representing, I 

17 believe it was 60 percent of shipments, 

18 showing that all of the tested dryers using 

19 the DOE load and the automatic-termination 

20 method dried the test load to below 2 percent 

21 RMC. 

22 The joint petition also stated 
202-234-4433

Neal R. Gross & Co., Inc.

Page 40

1 that, if DOE adopts these amendments, DOE 

2 should also revise the relevant energy 

3 conservation standards. And, in particular, 

4 they said that DOE should select dryers that 

5 dried the test load to only 1.5 to 2 percent 

6 RMC, so that the updated standard represents 

7 test units with minimal overdrying. They also 

8 stated that, if DOE cannot select specific 

9 units, that DOE should continue to adopt the 

10 amendments, but not limit the sample of 

11 representative dryers. 

12 I believe we will have data later, 

13 but there are some issues with the final RMC 

14 that you will be able to see in the data that 

15 sometimes a higher RMC doesn't always 

16 correspond to a lower energy consumption or 

17 higher efficiency. 

18 So, in order to investigate -- oh, 

19 I'm sorry. 

20 MR. BROOKMAN: Maybe pause. 

21 Michael, please. 

22 MR. BROWN: Right, Michael Brown. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 41

1 In relationship to the RMC, has 

2 the DOE determined that there is an overdrying 

3 of articles of prewashed clothing that are 

4 being dried that are actually considered to be 

5 overdry? I understand DOE's current rule is 

6 that the RMC should be between 2.5 and 5.0. 

7 However, with this proposal here that I am 

8 seeing as far as the 2 percent, has not the 

9 DOE decided that there is, with the minimum 

10 being 2.5 current, that below 2.5 RMC would be 

11 actually overdrying loads? And if that is the 

12 case, that DOE has established for years, that 

13 2.5 is the actual lowest, what has DOE done to 

14 establish that 2.5 and less than that 

15 parameter is actually overdrying the clothes 

16 and, therefore, wasting energy? 

17 MR. BATTAGLIA: Well, I think the 

18 idea with lowering the target RMC of 2 percent 

19 is to sort of capture the differences between 

20 loads of varying weights and sizes that might 

21 be dried in the real world and the DOE test 

22 load, and how that reacts to the termination 
202-234-4433

Neal R. Gross & Co., Inc.

Page 42

1 sensing controls and how those are set up. 

2 So, I believe the idea is that 

3 drying with the DOE test load on an automatic4 termination program, below 2 percent would be 

5 what would be representative of drying in the 

6 field. 

7 MR. BROWN: And you mentioned the 

8 real world load, which is not the same as the 

9 DOE load. 

10 MR. BATTAGLIA: That's correct. 

11 MR. BROWN: Okay. So, the 2 

12 percent, representative here in this RMC for 

13 testing purposes, is relative to a real-world 

14 load? 

15 MR. BATTAGLIA: Well, that RMC was 

16 based on the previous test procedure. And I 

17 believe there are certainly differences 

18 between what you would -- I believe the field19 use factors would attempt to somewhat correct 

20 for that. 

21 MR. BROWN: My purpose for asking 

22 about it is I have no information that the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 43

1 Department of Energy had issued for what 

2 actually is a real-world load. Therefore, 

3 when we were trying to test a real-world load, 

4 there is no actual definition of what a real5 world load consists of from the Department of 

6 Energy's perspective. So, can you give me 

7 some clarification on where I might find the 

8 actual specific real-world load, so that we 

9 can actually begin testing of a real-world 

10 load, so we can see if our dryer will reach 

11 those levels of 2 percent? 

12 MR. BATTAGLIA: Well, I don't know 

13 that DOE has a definition of a real-world 

14 load. I think DOE recognizes that there is 

15 lots of different -- that the term "real-world 

16 load" is to recognize that there are varying 

17 composition weights and sizes that consumers 

18 are drying. So, I don't know that the term 

19 "real-world load" would be defined by a single 

20 load. 

21 MR. BROWN: Well, to make sure I 

22 understand, we are talking about testing a 
202-234-4433

Neal R. Gross & Co., Inc.

Page 44

1 real-world load that there is no clear 

2 definition of what that real-world load is? 

3 MR. BATTAGLIA: Well, I mean, I 

4 believe the idea is to capture differences 

5 between what happens in the field and 

6 developing a test procedure. 

7 MR. BROWN: Yes, I understand. I 

8 am lost on something here. I need your help 

9 here. 

10 I understand what the Department 

11 of Energy has prescribed for what is a DOE 

12 load or an AHAM load. I do not see 

13 information relative to a real-world load that 

14 the Department of Energy has adopted. 

15 So, when it comes to testing of a 

16 real-world load and the variable differences 

17 that one may receive from testing a real-world 

18 load, without knowing what a real-world load 

19 is, how does a company actually utilize that 

20 particular load for testing, so that we can 

21 understand what the proposal that the 

22 Department of Energy may be getting, or is 
202-234-4433

Neal R. Gross & Co., Inc.

Page 45

1 going to be actually enacted upon, so that 

2 companies, other companies, whether it is my 

3 company or whomever, may be able to 

4 effectively test those loads that are 

5 currently unclear? Can you help us understand 

6 that, please? 

7 MR. WITKOWSKI: I think we have a 

8 difference of opinion here about testing. 

9 MS. KOHL: It is okay. Go ahead. 

10 It is okay. 

11 MR. WITKOWSKI: I think we have a 

12 difference of opinion here -- 

13 MR. BROOKMAN: Stephen Witkowski. 

14 MR. WITKOWSKI: -- of how DOE 

15 undertakes and adopts its test procedures and 

16 what we test. 

17 And you are certainly welcome to 

18 submit in written comments any disagreement 

19 you have, but I think trying to take something 

20 such as a definition of a real-world load, 

21 which we all know is a nebulous concept -- we 

22 do the best that we can to look at the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 46

1 information and the data that we have and that 

2 is supplied to us and make determinations on 

3 that. 

4 We can't say that this little 

5 thing is a real-world load. But if you have a 

6 comment or a suggestion or a definition that 

7 you would like to submit to us in writing, we 

8 would appreciate that. 

9 MS. ARMSTRONG: Okay. This is 

10 Ashley Armstrong from DOE. 

11 I am going to attempt to address 

12 your question. There is no such thing as a 

13 DOE real load. What DOE has defined as a DOE 

14 test load, that assumes the DOE test load 

15 under certain drying conditions. What we 

16 noticed when we did testing was that, when 

17 using the DOE test cloth load, it seems that 

18 the RMC values were significantly lower than 

19 the 5 percent range. In other words, we saw 

20 ranging between 1 and 3 percent, roughly, RMC 

21 with the DOE test load. So, that is the 

22 cloth, not the real world. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 47

1 The assumption there is that 

2 manufacturers are designing their dryers to 

3 what consumers would accept as a certain level 

4 of moisture in variance of loads in the real 

5 world. So, there is no such thing as a DOE 

6 real-world load, but what we saw is that level 

7 of overdrying in the DOE test cloth probably 

8 translates to varying levels of acceptance of 

9 moisture in a real-world load. Does that make 

10 sense? 

11 MR. BROWN: Yes. I guess what I 

12 would like to know -- thank you for that. 

13 Mike Brown. I would like to ask, to clarify, 

14 are you saying, then, in the course of this 

15 discussion that the real-world load, as 

16 described by Mr. Battaglia, that that load has 

17 not yet been defined? And I understand that 

18 the load has been tested by manufacturers who 

19 are submitting proposals for the changing of 

20 the RMCs relative to the real-world loads. 

21 I understand what you are saying 

22 in the sense that there is no clear definition 
202-234-4433

Neal R. Gross & Co., Inc.

Page 48

1 of a DOE real-world load. My question is, are 

2 those undefined definitions of a real-world 

3 load going to be utilized as a part of a 

4 rulemaking for establishing an RMC for a test 

5 load that is yet to be defined? 

6 MR. RIVEST: I will try. 

7 MS. ARMSTRONG: Yes. Are you 

8 going to try a different way? Round three. 

9 MR. BROOKMAN: Mike Rivest. 

10 MR. RIVEST: You know, to try and 

11 answer your question here, the test procedure 

12 currently assumes that a 5 percent RMC with 

13 the DOE test cloth is what is most 

14 representative of what is happening out there. 

15 And that is why the test procedure was set up 

16 that way. We don't have the full history of 

17 that 5 percent. 

18 But what we know is that, when we 

19 test existing dryers that have been designed 

20 to give consumers what they are looking for in 

21 terms of dryness, the results are not 5 

22 percent. They are more like 2 percent. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 49

1 And what I understood the 

2 recommendation from the joint petitioners 

3 being is that they are correlating what is 

4 acceptable in the real world with a variety of 

5 different loads with 2 percent of DOE test 

6 load. So, there is not going to be in this 

7 proposal the definition of what a real-world 

8 load is. The test procedure will continue to 

9 be defined by the DOE test, but the standard, 

10 if you will, or the equation for determining 

11 the energy factor will be reset to 2 percent 

12 RMC. 

13 MR. BROWN: So, they are going to 

14 reset the -- Mike Brown here -- they are going 

15 to reset the RMC. This is the DOE that is 

16 going to reset the RMC? 

17 MS. ARMSTRONG: No. 

18 MR. BROOKMAN: Ashley Armstrong. 

19 MS. ARMSTRONG: This is Ashley 

20 Armstrong, DOE. 

21 Why don't we let James present our 

22 proposal? And it is going to walk through 
202-234-4433

Neal R. Gross & Co., Inc.

Page 50

1 exactly what we are proposing and how the 

2 translation from 5 percent to 2 percent will 

3 work. And then, at the time, if we still have 

4 questions at the end of the day, we can go 

5 through it. 

6 MR. BROOKMAN: Well, let's hear 

7 from Charlie, and then maybe we will return to 

8 James and let him go through his material. 

9 Charlie? 

10 MR. STEPHENS: Yes. Charlie 

11 Stephens. 

12 I think one of the things that may 

13 be confusing is that there is such a thing as 

14 a real-world load. I have data from 1800-plus 

15 of those, from real-world households washing 

16 real-world laundry. I have the remaining 

17 moistures from those. And so, that is real18 world loads and real-world data from real 

19 households. 

20 So, I think what DOE is trying to 

21 do is translate the energy use ultimately in 

22 that mode in real-world households, which I 
202-234-4433

Neal R. Gross & Co., Inc.

Page 51

1 have, like I said, more than 1800 loads' 

2 worth, to what you get from the same dryers in 

3 a test procedure. 

4 The whole idea here is to try to 

5 translate the test procedure to the real 

6 world. I have the real-world data. So, that 

7 is what you look at when you try to 

8 understand, okay, this dryer did this in the 

9 field with real clothes in real households 

10 with real people. This dryer did this with 

11 the DOE test load in the lab. How do you 

12 translate those two and make them 

13 representative, because DOE is required by law 

14 to produce a test procedure that reflects 

15 average use in the field? 

16 So, I think that is what we are 

17 going to hear, is an attempt to translate 

18 those things. 

19 MR. BROOKMAN: Let's let James lay 

20 out the proposal, but Ashley first. 

21 MS. ARMSTRONG: Just one second. 

22 MR. BROOKMAN: Ashley, get close 
202-234-4433

Neal R. Gross & Co., Inc.

Page 52

1 to the microphone, please. 

2 MS. ARMSTRONG: To follow on on 

3 Charlie's point, I just want to make clear 

4 that, when he is referencing -- and please 

5 correct me if I am wrong -- but when he is 

6 referencing his real-world data, I mean, that 

7 is the variance of household loads you would 

8 see from, you know, Household A down the block 

9 in a community. 

10 There is no such thing; he is not 

11 defining a real-world load. It may be towels, 

12 it may be jeans, it may be a mixture. It may 

13 be whites. So, when he is talking about his 

14 data, it is this variety that is seen. There 

15 is no such thing as a definition of a uniform 

16 real-world load from a DOE perspective. 

17 What we are trying to do is 

18 capture that variance that you might see and 

19 translate it into the DOE test cloth load. 

20 MR. BROWN: Mike Brown here. 

21 You are trying to capture that 

22 variance from a gas or an electric dryer? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 53

1 Because I believe Mr. Stephens is referring to 

2 a heat pump dryer in his 1900, 1800 test? 

3 MR. STEPHENS: No, no, no. 

4 MR. BROWN: You are talking about 

5 an electric or gas dryer? 

6 MR. STEPHENS: No, no. All of our 

7 heat pump testing is in the lab. We don't 

8 have anything in the field. 

9 MR. BROWN: No, I mean the 1800 

10 tests you have already conducted. That is not 

11 a heat pump dryer test? 

12 MR. STEPHENS: Oh, no, no, no. 

13 MR. BROWN: Okay. 

14 MR. STEPHENS: Like I said, we 

15 don't have any heat pump dryers in the field. 

16 MR. BROWN: Okay. So, I guess so 

17 I can clarify, the testing that we are talking 

18 about proposing to be changed in terms of the 

19 remaining moisture content is for electric and 

20 gas clothes dryers, and this is the testing 

21 protocols and the results that have come from 

22 all these loads, load testing? Is that RMC 
202-234-4433

Neal R. Gross & Co., Inc.

Page 54

1 being looked at as being changed from 5 

2 percent down to previously, which I understand 

3 now the DOE has at 2.5 percent. 

4 Currently, if I am not mistaken, 

5 the rule from DOE is 2.5 percent is the 

6 minimum remaining moisture content. So, I am 

7 asking, is this a proposal to change that? 

8 MR. BROOKMAN: Let's let James lay 

9 this out. Let's see what he has got to say 

10 here, and then, we can evaluate from there. 

11 Okay? 

12 MR. BROWN: Okay. 

13 MR. BROOKMAN: Jennifer, you want 

14 in before I move us on? 

15 MS. CLEARY: Yes, I just have one 

16 point of clarification. I think, Mike, that 

17 maybe earlier you were asking a question about 

18 the testing that we did in support of this 

19 petition with the 2 percent. And it sounded 

20 to me like maybe you were thinking that our 

21 testing was with a real-world load, and maybe 

22 that is where this was coming from. I might 
202-234-4433

Neal R. Gross & Co., Inc.

Page 55

1 be misinterpreting. Is that what you were -- 

2 MR. BROWN: Mike Brown here. 

3 MS. CLEARY: Is that your 

4 question? 

5 MR. BROOKMAN: I don't want to 

6 open this up again. Let's let James -- 

7 MS. CLEARY: Well, I have a 

8 clarification on that that is very succinct. 

9 MR. BROOKMAN: Okay. 

10 MS. CLEARY: So, was that your 

11 understanding? 

12 MR. BROWN: When I hear the 

13 terminology used "real world," then I am 

14 thinking real world, and it is being 

15 differentiated between DOE and AHAM. 

16 MS. CLEARY: Okay. Well, our 

17 testing for this joint petition was done with 

18 the DOE test cloth. 

19 MR. BROWN: Thank you. 

20 MS. CLEARY: So, if that clarifies 

21 your question -- 

22 MR. BROWN: That does clarify. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 56

1 MR. BROOKMAN: Okay. Now back to 

2 James. Go ahead, James. 

3 MR. BATTAGLIA: All right. Now, 

4 in order to evaluate potential amendments to 

5 the test procedure for automatic-termination, 

6 DOE tested a representative sample of 20 

7 clothes dryers. Now DOE conducted testing 

8 using the DOE test load, which is composed of 

9 24-by-36-inch momie test cloths that are a 

10 blend of 50/50 cotton and polyester. 

11 And DOE also conducted testing 

12 with the test load specified in the IEC and 

13 AHAM clothes dryer test procedures, and that 

14 is a load consisting of cotton bed sheets, 

15 towels, and pillowcases. 

16 Now, for the testing, DOE 

17 essentially used the current test procedure, 

18 but included modifications for automatic19 termination. And those for the cycle setting, 

20 DOE used the normal automatic-termination 

21 program. And also, where the temperature and 

22 dryness level settings can be chosen 
202-234-4433

Neal R. Gross & Co., Inc.

Page 57

1 independently of that cycle selection or the 

2 cycle program selection, the temperature 

3 setting was set to the highest level and the 

4 dryness level was set to the normal or medium 

5 level. 

6 And then, the clothes dryer was 

7 then allowed to run until the completion of 

8 the automatic cycle, including the cool-down 

9 period, at which point the load was weighed to 

10 determine the final RMC. Now, if that final 

11 RMC was below 2 percent using the DOE test 

12 load, the test was considered valid. Now, if 

13 it was higher than 2 percent, the test was 

14 considered invalid and had to be rerun using 

15 the highest dryness level setting. And that 2 

16 percent RMC threshold was based on the data 

17 from the joint petition to show levels of RMC 

18 that are acceptable to consumers. 

19 Now, for the testing with the 

20 IEC/AHAM test load, DOE essentially used the 

21 same automatic-termination method, except that 

22 the threshold RMC was changed to 5 percent 
202-234-4433

Neal R. Gross & Co., Inc.

Page 58

1 because of the more varied composition of that 

2 load. 

3 Now here we have presented the 

4 results from this testing. In the table here, 

5 we are showing the averages for each product 

6 class. 

7 Now the test results showed that 

8 the automatic-termination tests using the DOE 

9 test load, for those tests, all of the tests 

10 resulted in a lower measured CEF. That is a 

11 higher per-cycle energy use compared to the 

12 current DOE test procedure. And that ranged 

13 from a decrease of 3.5 percent to about 42 

14 percent. So, there was a wide range in that 

15 decrease of CEF. 

16 And similarly for the IEC/AHAM 

17 test load, there was, again, in every case the 

18 RMC was lower using the IEC/AHAM test load as 

19 compared to the DOE test load, and in that 

20 case ranging from about a 6 percent decrease 

21 to a 40 percent decrease. 

22 MR. BROOKMAN: And I am not sure 
202-234-4433

Neal R. Gross & Co., Inc.

Page 59

1 where to -- is this a good stopping point? 

2 MR. BATTAGLIA: Yes, sure. 

3 MR. BROOKMAN: Okay. Then, let's 

4 hear from Abigail first, and then to Chris. 

5 MS. DAKEN: This is a very quick, 

6 clarifying question. Was there any case where 

7 a product did not meet the 2 percent RMC with 

8 the automatic-termination cycle at all? 

9 MR. BATTAGLIA: I believe -- I 

10 would have to go back and check the data 

11 -- but I believe there was one that had to be 

12 rerun using the highest dryness setting. So, 

13 it was tested first with the normal setting, 

14 and then it was, I believe, slightly -- I am 

15 not sure exactly what the RMC was, but it was 

16 slightly above that 2 percent. So, it had to 

17 be rerun. 

18 MS. DAKEN: Okay. So, you don't 

19 anticipate a case where a product doesn't meet 

20 the final RMC of 2 percent, even on the most 

21 dry setting? 

22 MR. BATTAGLIA: We haven't 
202-234-4433

Neal R. Gross & Co., Inc.

Page 60

1 observed that. 

2 MS. DAKEN: Okay. Thank you. 

3 MR. BATTAGLIA: Okay. 

4 MR. BROOKMAN: Chris? And then, 

5 we will go back to you, Mike. 

6 MR. CALWELL: Yes, Chris Calwell. 

7 I was curious about the columns on 

8 the right for the IEC/AHAM load. You were 

9 showing on average about 20 percent lower 

10 efficiency compared to testing the DOE load, 

11 and that is to 5 percent RMC instead of 2. 

12 What if you dried it to 2? 

13 MR. BATTAGLIA: Well, I believe 

14 there are a number of cases -- in the NOPR we 

15 present the actual RMC that each of the tests 

16 tested to. And in some cases, it was below 2 

17 percent. 

18 So, I don't know that there would 

19 be an enormous difference between the drying 

20 to 5 percent and 2 percent. So, basically, we 

21 are letting the dryer run until the completion 

22 of the cycle and taking the energy consumption 
202-234-4433

Neal R. Gross & Co., Inc.

Page 61

1 from that. 

2 MR. CALWELL: Yes, or maybe let me 

3 restate it. In general, what we found in the 

4 lab is that the ending part of the cycle is 

5 fairly inefficient. You know, it is somewhat 

6 difficult to remove the very last bit of water 

7 from the load. 

8 And so, if you saw a 20 percent 

9 efficiency difference under this more generous 

10 condition, if both tests had to do the same 

11 amount of work, I think that difference might 

12 widen further. And so, it points to whether 

13 the difference between the DOE results and 

14 what you would actually see in the field might 

15 be wider still as you attempt to get the 

16 conditions as similar to the field as 

17 possible. 

18 MR. BATTAGLIA: So, you are saying 

19 that you might see a higher energy consumption 

20 if you are drying to even lower RMCs with 

21 the -- 

22 MR. CALWELL: A higher energy 
202-234-4433

Neal R. Gross & Co., Inc.

Page 62

1 consumption and a lower efficiency. 

2 MR. BATTAGLIA: Okay. 

3 MR. BROOKMAN: Michael? 

4 MR. BROWN: Michael Brown. 

5 The tests that were conducted by 

6 DOE, or at least the test results that were 

7 submitted to DOE, and that the DOE may be 

8 relying upon to provide this NOPR here today, 

9 what particular dryer are we talking about 

10 that was used to provide these test results? 

11 MR. BATTAGLIA: DOE selected a 

12 wide variety of dryers from different 

13 manufacturers. 

14 MR. BROWN: Is there anywhere in 

15 the NOPR here that actually says this is the 

16 type of dryer that was used to provide these 

17 test results, like electric dryer or gas 

18 dryer, and that particular model of either one 

19 of those? 

20 MR. BATTAGLIA: No, we do not 

21 provide that information. 

22 MR. BROWN: So, the information 
202-234-4433

Neal R. Gross & Co., Inc.

Page 63

1 relative to these test results is coming from 

2 dryers that are not defined, is that correct, 

3 here in this NOPR? 

4 MR. BROOKMAN: Ashley Armstrong. 

5 MS. ARMSTRONG: We are going to 

6 try this again. This is Ashley. 

7 If you have The Federal Register 

8 notice in your packet, turn to page 157, Table 

9 3-1. It doesn't provide manufacturer model 

10 numbers; it does provide features of the 

11 dryers that were tested, all 19, as part of 

12 this rulemaking. So, I think that is what you 

13 are looking for. 

14 MR. BROWN: Thank you. 

15 MR. BROOKMAN: Okay. James. 

16 MR. BATTAGLIA: Okay. Yes, I also 

17 just would like to point out, to what Chris 

18 said, in nearly every case for the IEC/AHAM 

19 test load, the measured CEF was actually lower 

20 than the CEF using the automatic-termination 

21 test method with the DOE test clause. So, 

22 there was that trend where the CEF with the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 64

1 IEC/AHAM test load was, in fact, lower than 

2 the DOE test load. 

3 MR. CALWELL: And I think I just 

4 wanted to emphasize that that is consistent 

5 with our lab work as well. Anything you do to 

6 make the load in the lab more similar to what 

7 Charlie's data showed in the field increases 

8 energy use and reduces efficiency. And so, it 

9 makes the mathematical process of adjusting 

10 what you measure to reflect the real world 

11 become harder and more heroic. You know, the 

12 farther apart they get, the more it points to 

13 the question of whether you might want to just 

14 test a different load. 

15 MR. BROOKMAN: Thank you, Chris. 

16 Abigail? 

17 MS. DAKEN: Abigail Daken. Thank 

18 you. 

19 I guess I just want to ask a 

20 question, put it out there for consideration. 

21 Is the intention of the test method to give 

22 data which reflects the amount of energy 
202-234-4433

Neal R. Gross & Co., Inc.

Page 65

1 people will use in the field? Or is the 

2 purpose of the test method to give data which 

3 accurately represents the relative ranking of 

4 more- versus less-efficient products? 

5 And I would submit that the 

6 second, where we get the correct relative 

7 ranking but it is not a one-to-one reflection 

8 of what people can expect in the field, is a 

9 good test method. 

10 MS. KOHL: So, just to clarify 

11 real quick -- this is Betsy Kohl from DOE 

12 GC -- the statutory requirement for us is in 

13 42 USC 6293, and it talks about measuring the 

14 energy use, I believe it is of a 

15 representative average annual use cycle. I 

16 might not be getting the words quite right, 

17 but that is the standard that we are operating 

18 under. 

19 MR. BROOKMAN: Okay. Michael? 

20 MR. BROWN: I would just like to 

21 clarify. There is an understanding from our 

22 testing that to create or to deliver lower 
202-234-4433

Neal R. Gross & Co., Inc.

Page 66

1 RMCs, typically, will inherently bring in more 

2 or create more energy consumption when you 

3 lower the RMC target. And also, you do lose 

4 or you deliver less in your energy factor. 

5 I am asking for clarification, if 

6 the Department of Energy is quite aware that, 

7 when you seek lower RMCs of today's dryers 

8 that are currently on the market, that that 

9 inherently will bring about lower energy 

10 efficiencies? 

11 MR. BATTAGLIA: Yes, I believe the 

12 idea is to try to capture the difference. We 

13 recognize that the DOE test load has to 

14 capture differences between loads of varying 

15 composition. So, there are going to be 

16 differences between what you are measuring. I 

17 don't know that we want to say that drying to 

18 below 2 percent RMC with the DOE test load is 

19 going to represent overdrying in the field as 

20 well. I believe there is a difference between 

21 the DOE test procedure and what you would 

22 expect. Dryers might be designed of varying 
202-234-4433

Neal R. Gross & Co., Inc.

Page 67

1 loads and composition and size. 

2 MR. BROWN: Thank you. 

3 MR. BROOKMAN: Okay. James, keep 

4 going. 

5 MR. BATTAGLIA: Okay. Now DOE 

6 also, as part of the testing, we also looked 

7 at the final measured RMC from each test. For 

8 the DOE test load, the final RMC ranged from 

9 0.4 to 2 percent, and for the IEC/AHAM test 

10 load with the automatic-termination program, 

11 the final RMC ranged from 1.3 to 4.7 percent. 

12 And I should also note in the 

13 tables in the NOPR it shows that, for nearly 

14 all the units tested, the average final RMC 

15 was actually higher than the tests using the 

16 IEC/AHAM test load. 

17 And also, just to point to the 

18 correlation between the final RMC and the 

19 measured CEF, it didn't always correlate that 

20 a higher final RMC corresponded to a higher 

21 efficiency. 

22 Now DOE had received information 
202-234-4433

Neal R. Gross & Co., Inc.

Page 68

1 from manufacturers that the test loads and 

2 types different from the test load specified 

3 in the DOE test procedure do not produce as 

4 repeatable and reproducible results. So, DOE 

5 also conducted testing to evaluate the test6 to-test variation. 

7 So, DOE conducted three repeat 

8 tests for each dryer tested, and that testing 

9 DOE used both the current DOE test procedure 

10 with both the DOE and substituting in the 

11 IEC/AHAM test load, and using that same basic 

12 time-dry method and, also, using the 

13 automatic-termination test method with both 

14 dryers. In both cases, the test-to-test 

15 variation was slightly higher than compared to 

16 the DOE test load. 

17 Charlie? 

18 MR. BROOKMAN: Charlie Stephens? 

19 MR. STEPHENS: Charlie Stephens. 

20 I just wanted to add, for 

21 everybody's clarification, the last slide that 

22 I showed in my deck was a graphic of what 
202-234-4433

Neal R. Gross & Co., Inc.

Page 69

1 James just described. It was the DOE data 

2 with the DOE test load and the IEC load. It 

3 was just a graphic of DOE's data. 

4 MR. BROOKMAN: Okay. Thank you. 

5 MR. BATTAGLIA: Okay. And DOE 

6 also conducted testing at a lab to evaluate 

7 the reproducibility of results from lab-to8 lab, taking into consideration different 

9 batches of test cloth. And the results from 

10 that showed that the percentage difference in 

11 the results between the labs was on average 3 

12 percent for the DOE test load and 4.7 percent 

13 for the IEC/AHAM test load. So, once you get 

14 from lab-to-lab, it does start to show a more 

15 significant increase in the reproducibility of 

16 results because you do have more variation 

17 from lot-to-lot of test cloth. 

18 MR. BROOKMAN: Chris? 

19 MR. CALWELL: Chris Calwell. 

20 This is just a clarification 

21 question for me because I don't recall, and I 

22 was trying to skim through The Federal 
202-234-4433

Neal R. Gross & Co., Inc.

Page 70

1 Register to see if I could spot it. What is 

2 the allowable range of ambient humidities? 

3 MR. BATTAGLIA: In the test 

4 procedure, it is 40 to 60 percent. 

5 MR. CALWELL: Yes. So, I am just 

6 wondering, if the room can be anywhere between 

7 40 and 60 percent humidity when you are making 

8 the test, is it possible that that amount of 

9 variation would introduce more randomness or 

10 uncertainty in your test result than a lot of 

11 these other more precisely-specified 

12 conditions? 

13 MR. BATTAGLIA: That is certainly 

14 possible. I mean, there are obviously going 

15 to be various components of the test procedure 

16 that could introduce variability. 

17 MR. CALWELL: Or maybe even say it 

18 another way. Obviously, I know it is 

19 important to you to try to get that 

20 variability down as low as reasonable without 

21 spending too much money. So, if you had to 

22 accept a change in the test composition or the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 71

1 test load that increased your uncertainty or 

2 your difficulty with repeatability, you might 

3 be able to change something else about the 

4 test procedure to reduce that uncertainty to 

5 compensate for it, such as specified a tighter 

6 range of allowable humidities? 

7 MR. BROOKMAN: Ashley Armstrong? 

8 MS. ARMSTRONG: This is Ashley. 

9 I think it is fair to say we could 

10 change, we could consider changing anything in 

11 the test procedure that we have results that 

12 show it impacted or it decreased the 

13 tolerances. 

14 So, to the extent you have results 

15 showing significant variance in humidity 

16 levels would decrease the -- or tightening the 

17 range would decrease the tolerance, perhaps I 

18 am not sure that DOE has data at this point 

19 showing such things. And tightening those 

20 levels is definitely a restriction on where 

21 you can test, and et cetera, et cetera. 

22 MR. CALWELL: Yes, I think that is 
202-234-4433

Neal R. Gross & Co., Inc.

Page 72

1 completely fair. We were just noticing that, 

2 since the job of the air coming into the dryer 

3 is to evaporate water, if the air starts with 

4 more water in it, it is relatively harder to 

5 evaporate more than if the air starts with 

6 less. 

7 So, we will take that as a 

8 recommendation to try to actually assess the 

9 impact of that variable and submit data. 

10 MR. BROOKMAN: AS Stephen has 

11 said, written comments, right, to the 

12 Department. 

13 Now back to James. 

14 MR. CALWELL: And data. 

15 MR. BROOKMAN: And data, yes. 

16 MS. WALTNER: One other quick 

17 clarification, if I could? 

18 MR. BROOKMAN: Hey, I'm sorry. 

19 Yes, please, Meg. 

20 MS. WALTNER: Meg Waltner with 

21 NRDC. 

22 I was just curious whether DOE 
202-234-4433

Neal R. Gross & Co., Inc.

Page 73

1 has -- 

2 MR. BROOKMAN: Might I ask, please 

3 -- you're doing well, Meg -- try to get these 

4 microphones close to your mouth, so that our 

5 webinar participants can hear everyone. 

6 Meg? 

7 MS. WALTNER: I was just wondering 

8 whether DOE has data on the lab-to-lab 

9 reproducibility with the current DOE test, for 

10 both the two columns on the left there, either 

11 with the current test cloths or with the 

12 IEC/AHAM test load? 

13 MR. BATTAGLIA: I would have to go 

14 back and check to see if we have that data. 

15 MS. WALTNER: Thank you. 

16 MR. BATTAGLIA: Okay. So, as part 

17 of the automatic-termination testing, for the 

18 testing that we conducted at the independent 

19 test lab, we also collected data for the 

20 measured energy consumption and also the 

21 estimated instantaneous RMC throughout the 

22 test cycle. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 74

1 And the data that we have shown 

2 here in the table, we looked at the energy 

3 consumption at different points of the cycle. 

4 So, taking a look at the energy consumption 

5 when the test load initially reached 5 percent 

6 RMC, when it initially reached 2 percent RMC, 

7 and also at the end of the test cycle, 

8 including after the cool-down period. 

9 Now the data in the table showed 

10 that the energy consumption measured over the 

11 full automatic-termination program was about, 

12 I believe, 11 to 72 percent greater than the 

13 energy consumption during the dry cycle, when 

14 the test load initially reached 5 percent RMC, 

15 and it was 4 to 62 percent greater than the 

16 energy consumption when the test load 

17 initially reached 2 percent RMC. 

18 We should also note that the final 

19 RMC at the end of the test cycle, which we 

20 have shown here in the parentheses on the 

21 right column, was achieved after an extended 

22 cool-down period during which the dryer 
202-234-4433

Neal R. Gross & Co., Inc.

Page 75

1 tumbles with no added heat after the end of 

2 the heated drying or after an extended period 

3 of operation at nearly zero percent RMC, so at 

4 a bone-dry state, when the heater is cycling 

5 on and off. 

6 So, the data showed that during 

7 these non-heated cycling times, the test load 

8 was actually picking up moisture. So, the 

9 moisture at the end of the cycle was actually 

10 higher than the RMC of the test load when the 

11 heater shut off for the final time. 

12 MR. CALWELL: James, this is 

13 Chris. I wonder, could you just repeat the 

14 two ranges of percentages you gave? I wanted 

15 to make sure I followed exactly what you said. 

16 MR. BATTAGLIA: Oh, yes, sure. It 

17 is listed in the NOPR. It is 11 to 72 percent 

18 as compared to the 5 percent point and 4 to 62 

19 percent for the 2 percent point. 

20 And again, you can see here in the 

21 data for some cases, such as dryer 6 and I 

22 believe 15, the higher RMC, the final RMC 
202-234-4433

Neal R. Gross & Co., Inc.

Page 76

1 actually resulted in a higher measured energy 

2 consumption. 

3 MR. CALWELL: So, does that mean, 

4 then, that, in effect, the dryers that were 

5 the smartest or the most able to determine 

6 when they had gotten to 2 percent and to stop 

7 promptly were using, say -- I took your range 

8 of 11 -- I'm sorry -- let's take 4 to 62 

9 percent, because that was the one that was 

10 relative to 2 percent RMC, if I followed you. 

11 So, the dryers that were the 

12 smartest would only use 4 percent more energy 

13 in the cool-down phase, and the dryers that 

14 were the least able to determine when to stop 

15 were using 62 percent more? 

16 MR. BATTAGLIA: Yes, that is what 

17 the data showed. And we will get to that on 

18 the next slide. 

19 MR. CALWELL: Okay. I mean, that 

20 is a fairly-remarkable finding, right? It 

21 says that auto-termination can work to a very 

22 wide -- it can vary quite widely in its 
202-234-4433

Neal R. Gross & Co., Inc.

Page 77

1 effectiveness, as currently implemented. 

2 MR. BROOKMAN: Abigail? 

3 MS. DAKEN: Abigail Daken. 

4 A quick question. I see that 

5 these sensor technologies are listed as 

6 moisture or temperature. Were there no units 

7 that had both? 

8 MR. BATTAGLIA: Sorry? 

9 MS. DAKEN: Were there no units 

10 that had a moisture sensor and a temperature 

11 sensor? 

12 MR. BATTAGLIA: Oh, yes, they are 

13 actually, the moisture, the ones listed as 

14 moisture are actually moisture plus 

15 temperature sensing. Sorry. 

16 MS. DAKEN: Thanks. Forgive my 

17 ignorance. 

18 MR. BROOKMAN: Okay, James. 

19 MR. BATTAGLIA: Okay. And here we 

20 have the graph for the electric standard 

21 dryers. And this will show more clearly what 

22 is happening at the end of the cycle. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 78

1 So, here in the graph we have 

2 shown the latter portion of the cycle, 

3 starting from when the RMC initially reached 5 

4 percent. And we have also marked off where 

5 the load initially reached 2 percent RMC. 

6 So, as you can see in the graphs, 

7 for all the tested dryers, the test load 

8 actually reached 2 percent RMC before the 

9 heater started cycling on and off in that 

10 cool-down period. 

11 And you can also see between 

12 dryers 4 and 6, which both used the same 

13 moisture technology, they resulted in a very 

14 different energy consumption because the dryer 

15 No. 6 had an extended period of non-heated 

16 tumbling and cool-down period, whereas dryer 4 

17 only achieved, it actually achieved a lower 

18 RMC, but only with a short cool-down period. 

19 And here we have similar results 

20 for gas clothes dryers. And again, you can 

21 see in all the cases the test load was 

22 reaching 2 percent RMC before the heater was 
202-234-4433

Neal R. Gross & Co., Inc.

Page 79

1 cycling on and off. And for these cases, 

2 there was an extended period of non-heated 

3 tumbling. 

4 MR. BROOKMAN: Chris? 

5 MR. CALWELL: This is Chris. 

6 Did I follow, then, it looks like 

7 the dryers spent more of their total cycle 

8 time after they had reached 2 percent than 

9 they did getting to 2 percent? 

10 MR. BATTAGLIA: In some cases, 

11 yes. Or, yes, in some -- 

12 MS. DAKEN: This plot doesn't show 

13 the part before they get to 5. 

14 MR. BATTAGLIA: Right. This is 

15 only showing -- 

16 MR. CALWELL: It doesn't, but the 

17 graph does say 20 minutes -- 

18 MR. BATTAGLIA: Right. 

19 MR. CALWELL: -- presuming that 20 

20 minutes is the amount of elapsed time before 

21 the graph started, right? 

22 MR. BATTAGLIA: Right. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 80

1 MR. CALWELL: So, they got to 5 

2 percent RMC typically around 20 to 23 -- I'm 

3 sorry -- no, they got to 2 percent RMC around 

4 20 to 23 minutes. And they got to 5 percent 

5 around -- I can't quite tell -- 20ish minutes, 

6 21, 22. 

7 MR. BATTAGLIA: Yes. 

8 MR. CALWELL: Twenty-one, 22, and 

9 it looks like they ran to a period of, yes, 35 

10 to 45 minutes? 

11 MR. BATTAGLIA: Yes, that is 

12 correct. 

13 MR. CALWELL: Okay. Thanks. 

14 MR. BROOKMAN: Michael? 

15 MR. BROWN: Michael Brown. 

16 The data that I see here, that you 

17 have here, that data was conducted by the data 

18 testing that provided these results? This is 

19 data that was actually achieved by the 

20 Department of Energy's tests or data that was 

21 submitted by another company to the -- 

22 MR. BATTAGLIA: This was DOE 
202-234-4433

Neal R. Gross & Co., Inc.

Page 81

1 testing. 

2 MR. BROWN: DOE testing? In the 

3 NETL facility? 

4 MR. BATTAGLIA: No, I mean, we 

5 tested at various labs, as we said, to 

6 evaluate reproducibility. So, this is at 

7 different labs. 

8 MR. BROWN: Okay. But what I am 

9 trying to clarify is the test data that I see 

10 here, which I will say all of it is inferior 

11 to what our test data shows for our hybrid 

12 electric dryer, which blows me away, this data 

13 comes from the Department of Energy testing a 

14 dryer in the Department of Energy's National 

15 Energy Testing Laboratory? Or where 

16 specifically was this data collected? 

17 MS. ARMSTRONG: No, this comes 

18 from -- 

19 MR. BROOKMAN: Ashley Armstrong. 

20 MS. ARMSTRONG: Thank you. 

21 This comes from DOE testing 

22 products it bought off retail at third-party 
202-234-4433

Neal R. Gross & Co., Inc.

Page 82

1 laboratories. 

2 MR. BROWN: Third-party 

3 laboratories? 

4 MS. ARMSTRONG: Third-party 

5 laboratories. 

6 MR. BROWN: So, these third-party 

7 laboratories are not representative of the 

8 Department of Energy's actual testing at a DOE 

9 laboratory? This is -- 

10 MS. ARMSTRONG: There is no such 

11 thing as a DOE laboratory. We test at third12 party laboratories. 

13 MR. BROWN: All right. I need 

14 some clarification on that. 

15 MR. BROOKMAN: And they are all 

16 accredited and all that. 

17 MR. BROWN: Okay. I need 

18 clarification on it. 

19 MS. ARMSTRONG: Well, you are more 

20 than welcome, if your test data is different 

21 than this, whether it is at your own facility 

22 or at a third-party facility, if you want to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 83

1 submit it as part of your comments to this 

2 test procedure, you know, DOE is open to 

3 considering that. 

4 MR. BROWN: And I would like to 

5 ask a question relative to your statement that 

6 there is no such thing as a DOE laboratory for 

7 testing. And the reason why I am asking that 

8 is because I was requested to submit my dryer 

9 technology to the DOE National Energy Testing 

10 Laboratory in Morgantown, New York, in 2010, 

11 with James Battaglia and Judith Reich. And it 

12 was to be tested by the Department of Energy. 

13 MS. ARMSTRONG: Sure. 

14 MR. BROWN: So, I am trying to 

15 clarify, when you say there is no such thing 

16 as a DOE testing laboratory, I submitted my 

17 technology to a DOE testing laboratory. 

18 MS. ARMSTRONG: Right. So, the 

19 Department currently conducts all its testing 

20 at third-party laboratories. There is a 

21 variety of them out there, a variety of 

22 different companies, some of which are in the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 84

1 audience today. 

2 MR. BROWN: So, that has changed, 

3 is what you are saying? There is no longer a 

4 NETL Laboratory that is testing dryers, for 

5 instance, in this particular subject matter 

6 for testing dryers? It is all third-party? 

7 MS. ARMSTRONG: Correct. There is 

8 no testing done -- 

9 MR. BROWN: In relationship to 

10 third-party testing, do all of the test 

11 laboratories that are testing data and are 

12 submitting data to the Department of Energy, 

13 are all of those laboratories accredited? 

14 MS. ARMSTRONG: Yes. 

15 MR. BROWN: Thank you. 

16 MR. BROOKMAN: Okay. James, back 

17 to you. 

18 MR. BATTAGLIA: Okay. So, based 

19 on all this testing, DOE considered whether a 

20 field-use factor could be applied in the per21 cycle energy consumption calculation to 

22 account for the measured energy consumption at 
202-234-4433

Neal R. Gross & Co., Inc.

Page 85

1 the end of the automatic-termination cycle for 

2 drying the DOE test load, recognizing the 

3 differences between loads of varying weights 

4 and sizes, and to represent the energy 

5 consumed drying the test load below 2 percent 

6 RMC, including any cool-down and non-heated 

7 tumbling. 

8 Now, using the data in the lab, 

9 DOE calculated a field-use factor of 0.80 by 

10 taking the difference between the measured 

11 energy consumption when the test load 

12 initially reached 2 percent RMC and the 

13 measured energy consumption at the end of the 

14 test cycle. And the final column here just 

15 shows the field-adjusted energy consumption at 

16 the end of the test. 

17 MR. BROOKMAN: Joanna? 

18 MS. MAUER: Joanna Mauer. 

19 I am not sure I understand what 

20 you are trying to account for with the 

21 application of the field-use factor. 

22 MR. BATTAGLIA: Yes, I believe the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 86

1 idea is to like capture the differences, how a 

2 dryer is designed to dry loads of varying 

3 composition versus how it reacts to drying a 

4 DOE test load. So, the way it senses a DOE 

5 test load will be different than how it reacts 

6 to a load of varying weights and sizes. 

7 MS. MAUER: So, I guess the 

8 roughly 20 percent or 25 percent difference 

9 you found in testing with the DOE test load, 

10 essentially, represents overdrying. So, using 

11 the DOE test load, or in other words the 

12 additional energy use, to dry clothes below 2 

13 percent? So, are you saying that you had 

14 suspected in the field those same dryers would 

15 not, in fact, consume any overdrying energy 

16 relative to a perhaps 5 percent or higher RMC? 

17 MR. BROOKMAN: Ashley Armstrong. 

18 MS. ARMSTRONG: I don't think the 

19 Department can definitively say that. I think 

20 what we are showing here is that we 

21 acknowledge that there will be some variance. 

22 We are not going to say there is never any 
202-234-4433

Neal R. Gross & Co., Inc.

Page 87

1 overdrying in the field with a real-world test 

2 load, but with the uniform DOE test load, what 

3 we are seeing is pretty consistent overdrying, 

4 where we wouldn't expect manufacturers to be 

5 designing their products for consistently 

6 overdrying in the field. 

7 So, what we are trying to say is 

8 that there is probably some variance in the 

9 field. This is trying to account for that 

10 variance. 

11 MS. CLEARY: Charlie Stephens. 

12 MR. STEPHENS: Charlie Stephens. 

13 I am a little confused. I keep 

14 hearing the term "overdrying," but that is not 

15 what I am seeing in the graphs that you just 

16 presented. What I am seeing is overuse of 

17 energy. The clothes reached 2 percent 

18 remaining moisture, but then they just, in the 

19 auto-termination cycle anyway, they just kept 

20 running, to the point where you had 

21 approximately a third of the energy used with 

22 quite a lot of variation, though, between 
202-234-4433

Neal R. Gross & Co., Inc.

Page 88

1 clothes dryer, depending on how they 

2 implemented their technology. 

3 But we saw a third of the energy 

4 use after the clothes reached the overdried 

5 state of 2 percent. So, I am not sure why you 

6 are not making a correction in the other 

7 direction, if what we are actually after here 

8 is an appropriate level of energy use that is 

9 representative of energy use, not dryness, but 

10 energy use in the field. 

11 MR. BATTAGLIA: I think the idea 

12 is to capture -- the idea is that sensors in 

13 dryers on the market are designed to dry loads 

14 of varying weights and sizes. So, when it 

15 sees the DOE test load, it is going to react 

16 differently. 

17 So, when it is drying -- the test 

18 results showed, that we had showed, that 

19 drying after it reached 2 percent RMC, it kept 

20 going to close to zero, or in some cases close 

21 to zero or close enough to zero percent RMC 

22 before the end of the cycling and came back 
202-234-4433

Neal R. Gross & Co., Inc.

Page 89

1 up. So, the idea is to capture the difference 

2 between how the sensors are going to react to 

3 different loads. 

4 MR. STEPHENS: Well, our data 

5 suggests, both in the lab and in the field, 

6 that they are going to continue to run the 

7 clothes for a much longer period of time. So, 

8 if you are field-adjusting the RMC, that is 

9 one thing. You are field-adjusting the energy 

10 use, correct? You are multiplying the energy 

11 use by .8? 

12 MR. BATTAGLIA: Right. 

13 MR. STEPHENS: I still am at a 

14 loss as to understand why you aren't 

15 multiplying it by 1.4. 

16 MR. BROOKMAN: Ashley? 

17 MS. ARMSTRONG: I think you can 

18 submit that as your comment and as to the 

19 reasons why we should. Do you see what I am 

20 saying? I think it is a difference of -- I 

21 mean, I don't think you can assume from this 

22 graph that you are looking at that it is just 
202-234-4433

Neal R. Gross & Co., Inc.

Page 90

1 drying to 2 percent RMC. 

2 So, in other words, I mean, you 

3 are seeing the heater come on. You will see 

4 the tumble cycling. And it is not clear -- we 

5 have pointed out 5 percent RMC and 2 percent 

6 RMC. What we haven't shown is the final RMC 

7 value at the end of the auto-termination 

8 cycle. If those were well below 2 percent 

9 RMC, it is not just tumbling, is the added 

10 issue. 

11 MR. STEPHENS: Well, I think you 

12 have our data and you have the RMC data from 

13 our tests. And I think you have the ability 

14 to look and see that the average drying cycle 

15 time to whatever RMC in the auto-termination 

16 mode most of the time, two-thirds of the time, 

17 was more than double the amount of time that 

18 the RMC numbers you are talking about here 

19 took to reach, which is to say under 25 

20 minutes. 

21 So, you saw that our average cycle 

22 time was 53 minutes. You saw that the energy 
202-234-4433

Neal R. Gross & Co., Inc.

Page 91

1 use was more than double what you would get 

2 with the test procedure. So, I am trying to 

3 understand why you are correcting, why you 

4 propose to correct the energy use in the wrong 

5 direction. 

6 I mean, you have the data as to 

7 what real dryers do. I mean, if what you are 

8 correcting for here is what the dryer would do 

9 with a real load or with a more typical load 

10 than the DOE test load, then I would suggest 

11 you really should be looking at the data that 

12 you have got that suggests what it does do, 

13 which is use twice as much energy and take 

14 twice as long in the dryer before the cycle 

15 terminates. 

16 MR. BROOKMAN: Charlie, since you 

17 have all that data -- 

18 MR. STEPHENS: They have all that 

19 data. 

20 MR. BROOKMAN: Yes, but can you 

21 submit that in your comments? 

22 MR. STEPHENS: Well, I will, but I 
202-234-4433

Neal R. Gross & Co., Inc.

Page 92

1 did submit the data to DOE in May -- 

2 MR. BROOKMAN: Yes. 

3 MR. STEPHENS: -- of last year. 

4 So, I am presuming that they have the data to 

5 work with. 

6 I guess I am not questioning the 

7 data. I am questioning what they are 

8 proposing to do with it or what they haven't 

9 done with it. Maybe they didn't look at that 

10 part of the data, but -- 

11 MS. ARMSTRONG: We can re-look at 

12 the data. We have looked at your data. 

13 This is Ashley from DOE. 

14 This is our proposal. To the 

15 extent you disagree with it or have a 

16 different proposal in mind, feel free to 

17 submit it. 

18 MR. STEPHENS: Okay. You can be 

19 sure we will do that. I am just trying to 

20 understand your proposal because, for the life 

21 of me, I just can't grasp this at all. 

22 MR. BROOKMAN: Gotcha. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 93

1 I see Abigail. 

2 MS. DAKEN: Abigail Daken. 

3 Again, this is -- please forgive 

4 me because I am kind of new to dryers, and I 

5 am not sure that I am understanding it -- it 

6 sounds like there are two reasons that the 

7 field loads would have different results than 

8 the DOE load. 

9 One is that the DOE load would 

10 interact with the automatic-termination 

11 sensors differently. And it sounded to me, 

12 Ashley, like the explanation that you gave of 

13 the .8 was referring to that. 

14 The other reason that the field 

15 result would be different is because the loads 

16 are different. They are more mixed. They 

17 have higher dimensionality, so on and so 

18 forth. 

19 And I guess I didn't hear you say 

20 that the field adjustment, field-use factor 

21 was supposed to account for that. Is it 

22 supposed to account for that? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 94

1 MR. BROOKMAN: Ashley? 

2 MS. ARMSTRONG: This is Ashley 

3 from DOE. 

4 I think it is fair to say that the 

5 field-use factor is supposed to account for 

6 the differences between the DOE's test cloth 

7 and the variety of factors you would see in 

8 the field. So, it is both, yes. 

9 MR. BROOKMAN: Chris? 

10 MR. CALWELL: This is Chris 

11 Calwell. 

12 And so, given the field data you 

13 have seen, do you think 0.8 does that? 

14 MS. ARMSTRONG: That is our 

15 proposal. 

16 MR. CALWELL: Let me try it again. 

17 So, have you seen any measurements in the 

18 field that on average are lower than what you 

19 measure in the lab? Because .8 makes your 

20 number lower. I mean, it sounds elementary, 

21 but I am just trying to be as clear as I can. 

22 MR. BROOKMAN: Ashley? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 95

1 MS. ARMSTRONG: I get what you are 

2 saying. It is not that I don't get it. I 

3 don't have the field data in front of me. 

4 What I am saying is, based on the 

5 field data, based on the test data we did, 

6 based on our knowledge of dryers, this is our 

7 proposal. 

8 MR. CALWELL: Okay. 

9 MS. ARMSTRONG: To the extent you 

10 disagree with the proposal, you are more than 

11 welcome to make comments -- 

12 MR. CALWELL: Sure. 

13 MS. ARMSTRONG: -- about what an 

14 alternative proposal may be. 

15 MR. CALWELL: Okay. And one other 

16 question, if I could. Did I remember right 

17 that the 0.8 on average takes the results -- 

18 let's see, how would I say this? 

19 You had an original standards 

20 proposal, I think, in 2011, right? There was 

21 an issued final standard. And that was when 

22 the dryers were measured a different way. Now 
202-234-4433

Neal R. Gross & Co., Inc.

Page 96

1 we are proposing to measure them a new way. 

2 And if you multiply the results of the new 

3 measurements by .8, I think later in The 

4 Federal Register notice you said that it gives 

5 you a similar outcome to the old standard. 

6 And so, the standard doesn't need to be 

7 modified. Is that a fair summary of The 

8 Federal Register comment? 

9 MR. BATTAGLIA: Yes. Yes, we will 

10 get into that. 

11 MS. ARMSTRONG: We did make that 

12 determination on average. 

13 This is Ashley. 

14 MR. CALWELL: Okay. So, I know we 

15 will get to that later, but I would just 

16 submit now from the California utilities' 

17 perspective, another alternative would be go 

18 ahead and measure the dryers in a new way, 

19 but, then, set the standard at the appropriate 

20 level from the real results you get. When? 

21 Thereafter, right? 

22 So, you have a 2015 effectiveness 
202-234-4433

Neal R. Gross & Co., Inc.

Page 97

1 date, and I think that could hold. If you 

2 modify and set your final test procedure, you 

3 could modify your standard thereafter and be 

4 done a year and a half before your 

5 effectiveness date. 

6 MS. ARMSTRONG: Do you want to try 

7 that? 

8 MR. BROOKMAN: Okay. Back to 

9 James. Keep going. 

10 Oh, wait, quickly. 

11 MS. MAUER: Sorry. Joanna Mauer. 

12 I am still just trying to 

13 understand the rationale. And so, if I 

14 understand correctly, a dryer that is tested 

15 with the DOE test cloths, DOE procedure, and 

16 shuts off exactly when it reaches 2 percent 

17 RMC for the first time, so that there is no 

18 cycling on and off for the heat or any 

19 additional energy consumption, by multiplying 

20 by .8, you are suggesting that in the field 

21 that dryer would actually consume 20 percent 

22 less energy than it is consuming during the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 98

1 DOE test? 

2 MR. BATTAGLIA: Can you say that 

3 one more time? Sorry. 

4 MS. MAUER: So, a dryer that is 

5 tested under this proposal, and if it shuts 

6 off right when it reaches 2 percent RMC using 

7 the DOE test cloths, and when it reaches 2 

8 percent RMC for the first time -- so, not a 

9 case where it is going below 2 percent RMC and 

10 regaining moisture, but shuts off right at 2 

11 percent RMC, but, then, we are multiplying by 

12 .8. So, it seems to suggest that, it is kind 

13 of making the assumption that in the field 

14 that dryer would actually use 20 percent less 

15 energy than was measured during the test. 

16 MR. BATTAGLIA: Well, I mean, the 

17 idea is that, if it is stopping at 2 percent 

18 RMC, then that would be reflected in the test 

19 procedure. 

20 MR. BROOKMAN: I see Judith Reich 

21 is here. 

22 Judith? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 99

1 MS. REICH: Yes, Judith Reich from 

2 Navigant. 

3 I just want to comment that we did 

4 not see any machines that stopped right at 2 

5 percent RMC. They each had this additional 

6 period after initially reaching 2 percent RMC 

7 with various amounts of energy use and 

8 combinations of overdrying and moisture 

9 regain. And the .8 percent or the .8 factor 

10 is intended to capture the average behavior of 

11 all of these that, presumably, in the real 

12 world have been designed by manufacturers to 

13 get to a reasonable RMC with real-world 

14 clothing that consumers will accept. So, the 

15 .8 is that average percent of all of the 

16 machines that do this extra period of tumbling 

17 and potentially heating. 

18 MR. BROOKMAN: Okay. Charlie? 

19 And then, Chris. 

20 MR. STEPHENS: Yes, I guess I 

21 wanted to ask Ashley in a different way. 

22 Currently, there is no energy guide label for 
202-234-4433

Neal R. Gross & Co., Inc.

Page 100

1 clothes dryers, correct? 

2 MR. BATTAGLIA: That is correct. 

3 MS. ARMSTRONG: That is correct. 

4 MR. STEPHENS: Okay. Presumably, 

5 if there were an energy guide label, the 

6 number that would go on that label would be 

7 derived by this field-use factor as applied to 

8 the test results that you are proposing? Is 

9 that correct? 

10 MS. ARMSTRONG: Yes. I mean, 

11 presumably, DOE would -- the basis would be 

12 the DOE test procedure, and then, DOE would 

13 work with FTC to come up with some methodology 

14 for that number. 

15 MR. STEPHENS: Okay. And you 

16 believe on that basis that this would meet the 

17 legal test of 6293? 

18 MS. ARMSTRONG: Yes. I mean, we 

19 have proposed it. 

20 MR. STEPHENS: Okay. 

21 MR. BROOKMAN: Chris? And then, 

22 Michael. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 101

1 MR. CALWELL: I was listening to 

2 Judith's comment and wanted to make sure I 

3 understood. Yes, it is true that none of them 

4 stopped immediately at 2 percent, but it 

5 sounds like the best of the ones that James 

6 described only used 4 percent more energy. 

7 So, they were quite close, and the energy 

8 penalty of determining when to shut off was 

9 extraordinarily low for the best dryers and 

10 quite poor for the worst ones. 

11 So, there is a meaningful 

12 efficiency difference that DOE has found in 

13 its laboratory, and it is a source of savings 

14 when manufacturers who take the poorly15 designed automatic-termination systems and 

16 replace them with well-designed automatic 

17 termination systems. They could save that 

18 difference that you measured. And yet, none 

19 of that savings potential was considered in 

20 your original standards analysis because you 

21 weren't measuring dryers this way at the time. 

22 That is the part I guess I am stumped by 
202-234-4433

Neal R. Gross & Co., Inc.

Page 102

1 here. 

2 MR. BATTAGLIA: I think the test 

3 procedure as we have proposed it would still 

4 capture those differences between a dryer that 

5 is effectively drying like that, the one we 

6 showed, and one that is overdrying. So, that 

7 field-use factor is applied to all dryers. 

8 MR. BROOKMAN: Okay. We are all 

9 set? Okay. We are going to press on here, as 

10 a matter of time. 

11 And as reflecting Stephen's 

12 comment earlier, both your data and your 

13 comments about the way this was derived, those 

14 are all welcomed by the Department. So, let's 

15 make sure you get them in and do a good job of 

16 developing them. 

17 James, let's continue. 

18 MR. BATTAGLIA: Okay. So, DOE 

19 also during its testing investigated the 

20 conditions of the water supply used for 

21 wetting the test load, and its review of test 

22 procedures, looking at the IEC procedure for 
202-234-4433

Neal R. Gross & Co., Inc.

Page 103

1 clothes dryers, IEC 61121, the Fourth Edition, 

2 which recently published, and notes in that 

3 procedure that the characteristics of the 

4 water being used for wetting the test load may 

5 influence the results for an automatic6 termination test, particularly for a dryer 

7 that uses moisture sensors. 

8 Now the IEC procedure provides the 

9 conditions we have listed here for the total 

10 hardness and conductivity of the water supply 

11 for both standard soft and hard water. And 

12 DOE conducted testing using the standard soft 

13 water to closely match the current test 

14 procedure, which requires soft water. 

15 Now the results that we have here 

16 in the table, again, this shows the averages 

17 for each product class for testing on 16 

18 clothes dryers. And those test results showed 

19 DOE was not able to observe any consistent 

20 trends between for the relationships between 

21 the two different water supply characteristics 

22 and the measured CEF. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 104

1 And similarly, for the IEC/AHAM 

2 test load, DOE, again, was unable to determine 

3 any definitive correlation between CEF and the 

4 different test waters for both the DOE test 

5 water and the IEC test water. 

6 There is a good amount of data 

7 here. So, if anybody has questions? 

8 MR. BROOKMAN: Tom Eckman. 

9 MR. ECKMAN: I hate to go back, 

10 but I just want to remind DOE that the joint 

11 proposal that AHAM and the energy advocates 

12 made to DOE in terms of the petition was to 

13 remove the field-use adjustment factor and 

14 actually measure. So that what Chris pointed 

15 out would actually occur, that manufacturers 

16 would be encouraged to produce equipment that 

17 would terminate with only 4 percent instead of 

18 60 percent overdry. So, that was our original 

19 proposal to DOE. This goes back against that 

20 proposal. 

21 MR. BROOKMAN: Okay. Judith, go 

22 ahead. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 105

1 MS. REICH: Yes. I would just 

2 like to comment that, you know, we understand 

3 what the intent of the proposal was. However, 

4 I think our understanding of the complexity of 

5 dryer behavior, it is a much more complex 

6 situation. They don't simply dry in one 

7 continuous reduction on RMC and stop when the 

8 sensor tells it that it has reached that 

9 level. It turned out to have much more 

10 unexpected behavior, I think, than anybody 

11 realized. 

12 And so, we are trying to do the 

13 best job to balance what the intent of the 

14 proposal is with what the reality of dryer 

15 behavior is, you know, recognizing we need to 

16 have reproducible and repeatable test methods 

17 that won't result in any backsliding. So, it 

18 is just trying to balance all these competing 

19 things while still recognizing we are trying 

20 to capture the performance of something that 

21 dries to a reasonable level. 

22 MR. BROOKMAN: Okay. James. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 106

1 MR. BATTAGLIA: Okay. So, DOE 

2 again also evaluated the final RMC, test-to3 test variation and lab-to-lab reproducibility. 

4 And again, for the final RMC, again, DOE 

5 wasn't able to determine any definitive 

6 correlations between that final RMC and the 

7 DOE test water or the IEC test water. And 

8 again, for the test-to-test variation, DOE did 

9 not observe any significant difference in the 

10 repeatability between Appendix D1 and the IEC 

11 water. 

12 And also, DOE looked at a very 

13 small sample of dryers from lab-to-lab. While 

14 it did show a slight improvement in the lab15 to-lab reproducibility, that variation was on 

16 the same order of the lab-to-lab variation for 

17 the IEC/AHAM test load. 

18 So, based on this testing, DOE is 

19 not proposing to amend the test procedure to 

20 include the requirements for the modifications 

21 to the water supply based on the IEC 61121 

22 test procedure. However, if DOE receives 
202-234-4433

Neal R. Gross & Co., Inc.

Page 107

1 additional data that shows that the IEC water 

2 produces more repeatable and reproducible 

3 results, DOE may consider amendments in a 

4 future test procedure rulemaking. 

5 Now, getting into the proposed 

6 amendments, based on all the testing we have 

7 conducted, we are proposing to amend the test 

8 procedure to account for the effectiveness of 

9 automatic-termination. Now, starting with the 

10 definitions, DOE is proposing to include 

11 definitions for automatic-termination dryers 

12 and timer dryers. And automatic-termination 

13 dryers would be defined as dryers which can be 

14 preset to carry out at least one operation 

15 that would be terminated by means of a system 

16 that assesses, either directly or indirectly, 

17 the RMC of the load. 

18 And additionally, DOE is proposing 

19 to specify that any automatic-termination 

20 dryer that also has a timer or manual controls 

21 would be tested as an automatic-termination 

22 dryer. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 108

1 Now, for timer dryers, DOE is 

2 proposing to define those as dryers that can 

3 be preset to carry out at least one operation 

4 to be terminated by a timer or that may be 

5 manually controlled, and does not include any 

6 form of automatic-termination. 

7 Now, for the test load, based on 

8 DOE's results, we are not proposing to change 

9 the test load at this time. However, we are 

10 proposing to change the starting RMC, which in 

11 the current test procedure is 57.5 plus or 

12 minus 3.5. We are proposing to change that to 

13 57.5 plus or minus 0.33, to produce more 

14 repeatable results, particularly for the 

15 automatic-termination dryers. 

16 Now, if we were to allow a wider 

17 range in RMC, such as the plus or minus 3.5 

18 percent, it would result in very different 

19 results using the proposed automatic20 termination test method because a load with a 

21 starting RMC of, say, 61 percent, I believe it 

22 would have about a little over half a pound 
202-234-4433

Neal R. Gross & Co., Inc.

Page 109

1 more water than the test load that has a 

2 starting RMC of 54 percent. 

3 So, here we have our first 

4 official Request for Comment on the proposal 

5 to continue using the DOE test load. And, 

6 also, we are welcoming additional data on the 

7 test repeatability and lab-to-lab 

8 reproducibility for both the DOE and IEC 

9 loads. 

10 MR. BROOKMAN: Michael? 

11 MR. BROWN: Michael Brown, 

12 Hydromatic Technologies. 

13 Is it the DOE's position that the 

14 data acquisition equipment that utilized -- or 

15 I should say the equipment that is utilized 

16 for automatic-termination control for dryers 

17 is highly accurate components for assessing 

18 the remaining moisture content of a dryer? 

19 MR. BROOKMAN: Go ahead. Go 

20 ahead, James. 

21 MR. BATTAGLIA: Yes, I don't 

22 believe that is DOE's determination to make. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 110

1 The dryers have different sensing systems, and 

2 whether those are accurate or not, it varies 

3 among different dryers. 

4 MR. BROWN: Correct. Because what 

5 we are seeing in our testing laboratories in 

6 the field and in the lab are very wide 

7 variances of performance values for the 

8 automatic controls that are on today's 

9 existing clothes dryers. We are getting 

10 results where the dryer will achieve a level 

11 of 2 percent RMC and continue to run until the 

12 RMC reached negative zero percent. And we are 

13 seeing the dryers that are purchased directly 

14 from retailers that are put in laboratory 

15 testing and are tested with DOE loads, momie 

16 cloth loads, and are providing under automatic 

17 control instances and results where they are 

18 far from meeting what the Department of Energy 

19 is trying to create in terms of uniformity. 

20 And I am wondering how is the DOE 

21 going to provide uniformity for establishing a 

22 particular type of RMC for automatic-
202-234-4433

Neal R. Gross & Co., Inc.

Page 111

1 termination when the uniformity doesn't exist 

2 in the field or in the laboratory. I am 

3 trying to understand how the DOE is achieving 

4 the level of uniformity for setting its rules 

5 for the RMCs for automatic-termination when 

6 the actual components used to terminate a 

7 dryer are grossly inconsistent in their means 

8 of being able to auto terminate. 

9 MR. BROOKMAN: Judith Reich. 

10 MS. REICH: Yes, so DOE requires 

11 that the performance of a clothes dryer be 

12 measured and provides a sampling plan, so that 

13 the manufacturer must demonstrate that a 

14 sample of clothes dryers tested must meet the 

15 tolerances that are specified in the sampling 

16 plan among the results for the different 

17 units. 

18 That is in 10 CFR 429. I am not 

19 sure of the section. 

20 MR. BROOKMAN: And right now, we 

21 are seeking comment on DOE's proposed change, 

22 starting the RMC 57.5 plus or minus 3.5 to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 112

1 57.5 plus or minus .33 percentage. 

2 Chris? 

3 MR. CALWELL: This is Chris 

4 Calwell. 

5 Regarding the specific request 

6 asked for here, the California utilities would 

7 recommend a change in the DOE test load. And 

8 the summary would be that the DOE test cloths 

9 are intentionally uniform in their thickness 

10 and in their horizontal and vertical 

11 dimensions. They are, by definition, two12 dimensional. They are thin, and they are 50 

13 percent synthetic. 

14 In the real world, most of the 

15 items we have seen in dryers are three16 dimensional. So, they have two interior sides 

17 that remain in contact with each other that 

18 are wet. And therefore, they don't see 

19 directly the warm air that is circulating in 

20 the dryer, and they are, by definition, harder 

21 to dry and harder to sense. 

22 Real-world clothing has diversity 
202-234-4433

Neal R. Gross & Co., Inc.

Page 113

1 in thickness. It generally has a higher 

2 cotton content. And these qualities could be 

3 represented with either of two already4 available official loads, the AHAM 1992 load 

5 developed in the U.S. by the relevant trade 

6 association or the Australian load. 

7 Charlie showed graphics of both of 

8 them, and we will submit data speaking to the 

9 questions you asked for here, which is what is 

10 the test-to-test repeatability when those 

11 loads are used. And we would urge DOE to 

12 consider that. 

13 I think the closer you can get to 

14 represent what people actually dry, the less 

15 you will need mathematical adjustment factors 

16 to try to turn what you are measuring into 

17 something people would actually see in their 

18 homes. 

19 MR. BROOKMAN: Okay. Additional 

20 comments based on this question box, this 

21 query? 

22 Tom Eckman. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 114

1 MR. ECKMAN: Tom Eckman. 

2 Yes, given what Charlie showed 

3 earlier with respect to the field use of 

4 dryers in the Northwest, I don't think -- it 

5 is possible, but I think it is remote that 

6 using this RMC is the base condition for 

7 material entering the dryer. And the current 

8 DOE test procedure would get us energy 

9 consumption values that represent what the 

10 consumer is seeing. 

11 So, I am concerned that, while I 

12 agree that the tolerance by diminishing the 

13 range, that would improve the repeatability, I 

14 am concerned that without doing what Chris is 

15 suggesting, where we change the test load, we 

16 are able to get an energy consumption value 

17 out of the test procedure that represents 

18 field use. 

19 MR. BROOKMAN: Okay. Additional 

20 comments? 

21 James? Oh, yes, Jen, please. 

22 MS. AMANN: Jennifer Amann, ACEEE. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 115

1 We are also very supportive of 

2 further exploration of the clothes dryer, the 

3 test load, for the very issues that have been 

4 raised. I know I missed Charlie's 

5 presentation earlier, but I understand the 

6 issues that were raised. 

7 We are very interested that we get 

8 a test procedure that can reflect as 

9 adequately as possible with the issues about 

10 repeatability the in-field performance, 

11 recognizing that the test procedure is going 

12 to be used to determine standards going 

13 forward. And whatever we are missing in this 

14 round of the test procedure or revision has 

15 the potential to really affect our ability to 

16 get a standard that meets the requirements for 

17 DOE for a standard, and that meets the goals 

18 that we have for maximizing energy efficiency 

19 and reducing consumption from these products. 

20 MR. BROOKMAN: Okay. Thank you. 

21 Yes, Jennifer? 

22 MS. CLEARY: Jennifer Cleary. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 116

1 I just was wondering if I could 

2 ask those of you who are suggesting to change 

3 the test load, are you intending with your 

4 suggestion that that would be changed for the 

5 2015 standard or sometime in the future? 

6 MR. BROOKMAN: Chris? 

7 MR. CALWELL: For the California 

8 utilities, that is correct, yes. In essence, 

9 until you have final agreement on the dataset 

10 and the test procedure, it is difficult to set 

11 a standard. And so, the sequence I think 

12 would be revise and finalize the test 

13 procedure, revisit the standard, publish both 

14 in time to be effective for 2015. 

15 MR. BROOKMAN: Seeing no 

16 additional comments, James? 

17 Oh, Michael, a comment? Michael? 

18 MR. BROWN: Thank you. 

19 Michael Brown, Hydromatic 

20 Technologies. 

21 I would like to simply say I 

22 really didn't see these comments that are 
202-234-4433

Neal R. Gross & Co., Inc.

Page 117

1 being made today in the proposals that the DOE 

2 is making known here today during this NOPR as 

3 being very valuable to myself, the corporation 

4 Hydromatic, and those who we try to serve, our 

5 constituencies. 

6 The proposals that we are to 

7 submit relative to dryer testing, it is a 

8 little bit difficult for me to make a proposal 

9 for submitting proposed changes to the dryer 

10 testing when the dryers that the DOE is 

11 currently evaluating are, in my honest 

12 opinion, inferior to what already exists that 

13 has not yet been tested from a third-party 

14 agency, which we are going to work harder to 

15 try to accomplish. 

16 I would just like to say, when I 

17 submit my comments and my data, that we are 

18 going to submit that data relative to a hybrid 

19 electric clothes dryer that is significantly 

20 more energy efficient and safer, and will 

21 achieve all the levels that the Department of 

22 Energy is looking for uniformity for RMCs and 
202-234-4433

Neal R. Gross & Co., Inc.

Page 118

1 energy efficiency. And so, in the course of 

2 that, I would like to propose that the 

3 Department of Energy investigate the newer 

4 dryer technologies outside of electric and gas 

5 that they are currently relying upon for the 

6 subsequent energy ratings that are going to 

7 come out for dryers. 

8 And I would like the hybrid 

9 electric dryer to be considered as a product 

10 covered by the DOE that would provide what the 

11 Department of Energy is designed to do, 

12 provide consumers at some point with an 

13 energy-efficient product. So, I would just 

14 like to make that comment here at the table. 

15 And I thank everyone for all their 

16 comments that they have made in trying to help 

17 me understand what is going on here in this 

18 meeting. 

19 MR. BROOKMAN: Thank you. And the 

20 Department will welcome your comments. 

21 MR. BROWN: Thank you. 

22 MR. BROOKMAN: Yes. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 119

1 Yes, Joanna? 

2 MS. MAUER: Joanna Mauer. 

3 Just to add on the test load, I 

4 mean, we certainly recognize the challenges 

5 associated with changing the test load, and I 

6 think realize that it may have to be a longer7 term action. I think we would encourage DOE 

8 perhaps as a longer-term action to consider 

9 changes in the test load. 

10 And just from an energy-savings 

11 perspective, I think the importance may really 

12 be that having a test load that better 

13 represents field loads may allow the test 

14 procedure to better capture certain technology 

15 options that may achieve significant energy 

16 savings in the field. And they may be 

17 technology options that can't be really 

18 captured with the DOE test load that could be 

19 reflected using a more representative load. 

20 MR. BROOKMAN: Okay. 

21 Jennifer? 

22 MS. CLEARY: Jennifer Cleary. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 120

1 Joanna, just to clarify on what 

2 you said, so are you suggesting that changing 

3 the test load could be something that could be 

4 done beyond 2015, so that for these 

5 amendments, we would continue with the 

6 existing test load and, then, look at changing 

7 the test load for whatever the future standard 

8 would be? 

9 MS. MAUER: I was involved with -- 

10 I guess the most recent change tested was the 

11 clothes washer test load. But, from what I 

12 understand, it was a long and difficult 

13 process. So, assuming that it would also be a 

14 difficult process, it seems unlikely from my 

15 perspective that it is something that could be 

16 done and go into effect in 2015. 

17 MR. BROOKMAN: Okay. We are going 

18 to keep pressing on here. Shortly, I hope, in 

19 10-15 minutes or so, we are going to take a 

20 break. So, hang in there. 

21 James? 

22 MR. BATTAGLIA: Okay. Yes, we are 
202-234-4433

Neal R. Gross & Co., Inc.

Page 121

1 almost there. 

2 So, for the actual test cycle, DOE 

3 is proposing to require separate test methods 

4 for automatic-termination dryers and timer 

5 dryers. And for automatic-termination dryers, 

6 DOE is proposing to use the settings that we 

7 presented earlier that we used in our testing. 

8 Just to go quickly through them, 

9 we have proposed to use the normal cycle 

10 program, and for any dryers that do not have a 

11 normal program, the cycle recommended by the 

12 manufacturer for drying cotton and linen loads 

13 would be used. Where the drying temperature 

14 can be set independently of the cycle program, 

15 it would be set to the maximum. And where the 

16 dryness level setting can be chosen 

17 independently of the program, it would be set 

18 to the normal or medium level. And if such a 

19 designation isn't provided for the dryness 

20 level setting, it would be at the midpoint 

21 between the minimum and maximum values, 

22 settings. Sorry. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 122

1 And DOE is also requesting or 

2 proposing that the cycle settings be recorded 

3 for the tests. 

4 And then, again, for the test 

5 cycle, as we mentioned before, the dryer would 

6 be allowed to run until the completion of the 

7 cycle. And that 2 percent RMC would be used 

8 as the threshold. So, if anything was above 2 

9 percent RMC, it would be considered invalid 

10 and would have to be rerun on the highest 

11 dryness level setting. 

12 And again, that 2 percent RMC was 

13 based on the data in the joint petition, to be 

14 representative of dryers currently on the 

15 market and the maximum consumer-accepted RMC. 

16 Do you want to make a comment, 

17 Abby? 

18 MS. DAKEN: Yes, this is Abigail. 

19 I have a question. The completion 

20 of the cycle, including the cool-down, some 

21 dryers have, I guess, a wrinkle-prevention 

22 feature where at the end of the cycle they 
202-234-4433

Neal R. Gross & Co., Inc.

Page 123

1 will keep tumbling or tumble occasionally in 

2 order to keep clothes, presumably, from 

3 wrinkling. Would that be included? So, the 

4 end-of-cycle signal, if it is on, would occur 

5 before that? How would you determine the end 

6 of cycle in that case? 

7 MR. BATTAGLIA: Well, so later we 

8 will get into a few clarifications on the test 

9 procedure. What we state later is that DOE 

10 specifies the cycle settings for the 

11 temperature, the program temperature, and 

12 dryness, and does not specify any 

13 modifications to any other settings from the 

14 condition that it is shipped in. 

15 MS. DAKEN: But is the end of 

16 cycle defined as when the dryer stops doing 

17 anything? Or is it defined as when the dryer 

18 signals that the cycle is over? 

19 MR. BATTAGLIA: If there are 

20 different cases, we would certainly welcome 

21 examples of that. So, we would have to 

22 consider what the differences would be. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 124

1 MR. BROOKMAN: Michael? 

2 MR. BROWN: I am trying to 

3 understand clarification of this subject 

4 matter. The proposed test currently is the 

5 dryer is allowed to run until the completion 

6 of the cycle, including the cool-down period 

7 under the auto termination? 

8 MR. BATTAGLIA: That is correct. 

9 MR. BROWN: Okay. I am a little 

10 bit lost on something here. If the dryer is 

11 being operated on the auto-terminate cycle and 

12 it shuts off in, say, 20 minutes, then, does 

13 that constitute the end of the cycle? 

14 MR. BATTAGLIA: Yes, if it is 

15 using the settings that we have listed here 

16 and it stops the cycle at that point, if it 

17 meets the requirements for the 2 percent RMC, 

18 then that would be considered a valid test. 

19 MR. BROWN: Okay. Then, whereas, 

20 if the dryer is allowed to continue to run 

21 during the cool-down period, the cool-down 

22 period typically is at the end of the cycle, 
202-234-4433

Neal R. Gross & Co., Inc.

Page 125

1 of a time-dry cycle. 

2 MR. BATTAGLIA: Right, and we will 

3 get to the time-dry proposal in a minute. 

4 MR. BROWN: What I am trying to 

5 understand and clarify, and gain some 

6 understanding of, is, if you are operating a 

7 dryer in an automatic-termination mode, there 

8 is no cool-down cycle where it would actually 

9 reach a cool-down period. It just shuts off 

10 when the clothes are dry. 

11 MR. BATTAGLIA: No, from what we 

12 have seen, dryers do have a cool-down period 

13 after an automatic cycle. 

14 MR. BROWN: Okay. Then, let me 

15 understand then. 

16 MS. ARMSTRONG: Can I chime in 

17 here maybe? 

18 MR. BROOKMAN: Ashley. 

19 MS. ARMSTRONG: So, this is Ashley 

20 from DOE. 

21 So, what we have seen -- and you 

22 can see that from some of our graphs earlier -
202-234-4433

Neal R. Gross & Co., Inc.

Page 126

1 - is that those that employ automatic2 termination, you know, what we specified here 

3 is that the cycle is finished when the auto4 termination cycle is finished. That auto5 termination cycle includes both the drying and 

6 this what you are calling tumbling time. So, 

7 it doesn't differentiate. It is all 

8 considered the cycle. And that would all be 

9 captured. 

10 MR. BROWN: So, the cycle you are 

11 speaking of, you are referencing, is not a 

12 time-dry cycle that has an automatic13 termination mode in it, or is it? It is a 

14 time-dry cycle with an automatic-termination 

15 feature in it? 

16 MR. BATTAGLIA: Well, time-drying 

17 and auto-drying are two separate methods -- 

18 MR. BROWN: Right. 

19 MR. BATTAGLIA: -- to dry in a 

20 dryer. 

21 MR. BROWN: That is my 

22 understanding. Because if I set the dryer for 
202-234-4433

Neal R. Gross & Co., Inc.

Page 127

1 60 minutes, it is going to run for 60 minutes. 

2 MS. ARMSTRONG: Right. 

3 MR. BROWN: And it is not going to 

4 shut off automatically. 

5 MS. ARMSTRONG: This is Ashley. 

6 There are two different methods. 

7 There is the time-dry method and there is an 

8 auto-termination method. 

9 MR. BROWN: Okay. 

10 MS. ARMSTRONG: In the test 

11 procedure, it specifies both. 

12 MR. BROWN: Okay. So, for the 

13 purposes of this and my particular question 

14 here, a dryer is allowed to run. This is 

15 under the automatic-termination control? 

16 MR. BATTAGLIA: That is correct. 

17 MR. BROWN: The dryer is allowed 

18 to run until the completion of the cycle. My 

19 question is, what constitutes the completion 

20 of the cycle? Is it when the dryer actually 

21 shuts off, no matter what time that is, or is 

22 there some other definition of allowing the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 128

1 dryer to run until it reaches a cool-down 

2 period? 

3 MR. BATTAGLIA: Well, once the 

4 dryer shuts off, and that may include a cool5 down period. 

6 MR. BROWN: Okay. 

7 MR. BATTAGLIA: If the cool-down 

8 period is part of the automatic cycle, then it 

9 would end when the dryer completely shuts off. 

10 MR. BROWN: Okay. So, then, just 

11 so I can clarify, if the dryer shut off in 20 

12 minutes without achieving the cool-down cycle, 

13 that would be a valid test? 

14 MR. BATTAGLIA: Yes, if that is 

15 how it is employed. 

16 MR. BROWN: Yes. That is what I 

17 wanted to understand. Thank you. 

18 MS. REICH: This is Judith Reich. 

19 I just want to clarify. If the 

20 main drying cycle stops but there continues to 

21 be a cool-down period before all tumbling and 

22 all heating stops, then that cool-down is 
202-234-4433

Neal R. Gross & Co., Inc.

Page 129

1 still part of the cycle because, presumably, 

2 it is not indicated to the consumer that the 

3 cycle is completed. So, it includes, if there 

4 is cool-down, it is all part of the cycle. It 

5 is considered part of it. 

6 MR. BROOKMAN: Meg? 

7 MR. BROWN: Thank you. 

8 MS. WALTNER: Judith, you started 

9 to answer my question, but DOE's intention is 

10 to end the test when the dryer indicates to 

11 the consumer that the cycle is over? Is that 

12 correct? So, it wouldn't capture, you know, 

13 the tumbling to prevent wrinkling, et cetera? 

14 You said before when the dryer is completely 

15 off. That is not quite correct. What you are 

16 intending is when it indicates to the consumer 

17 that the cycle is done? Sorry if I -- 

18 MS. REICH: Yes, I mean, it is not 

19 specified in the proposal, but I believe that 

20 is correct. That intermittent tumbling for 

21 wrinkle prevention, on the units where we have 

22 seen it, that has been an option that is 
202-234-4433

Neal R. Gross & Co., Inc.

Page 130

1 selected and would not be selected for the DOE 

2 test. 

3 MS. WALTNER: Okay. 

4 MS. REICH: So, as far as we know, 

5 the information we have is that the indicator 

6 to the consumer that the cycle is done occurs 

7 at the conclusion of any of that cool-down 

8 tumbling and would not include that 

9 intermittent wrinkle prevention. 

10 MR. BROOKMAN: Ashley? 

11 MS. ARMSTRONG: Yes, I think the 

12 only clarification I would have to that is, if 

13 the wrinkle prevention is always incorporated, 

14 it would show up, in other words. Does that 

15 make sense. If it is part of the normal 

16 cycle, if it is always there, it would be 

17 included here. 

18 MS. WALTNER: Okay. Well, I don't 

19 know, just from my personal experience with my 

20 own dryer, it stops the cycle. But, then, if 

21 you don't get your clothes out, it will keep 

22 doing that wrinkle prevention indefinitely 
202-234-4433

Neal R. Gross & Co., Inc.

Page 131

1 every 30 minutes or so, until you open the 

2 dryer again. So, I just am trying to get -- 

3 MS. REICH: I am not sure we can 

4 answer that because it depends on what it says 

5 to the consumer. 

6 MR. BROOKMAN: Judith, we can't 

7 hear you. 

8 MS. ARMSTRONG: Yes, I think it is 

9 going to be a case-by-case basis. But, 

10 obviously, based on the discussion, maybe we 

11 should think about clarifying. 

12 (Laughter.) 

13 MR. BATTAGLIA: Yes, and 

14 certainly, if you have examples of cases where 

15 that is happening, where it is built into the 

16 cycle, you can certainly let us know that in 

17 your comments. 

18 MR. BROOKMAN: Okay. Michael, 

19 final comment. 

20 MR. BROWN: Okay. So, I 

21 understand; that is a part of it also. The 

22 end-of-cycle or wrinkle-prevention mode for 
202-234-4433

Neal R. Gross & Co., Inc.

Page 132

1 the dryers that we have, even though the dryer 

2 will terminate under auto termination, if it 

3 is in the wrinkle-prevention mode, it will 

4 continue to cycle off and on indefinitely 

5 until the dryer door is opened. So, it is the 

6 DOE's position that they will, I would say, 

7 clarify more what the end of the cycle 

8 actually means when a wrinkle cycle or wrinkle 

9 provision is provided in the test? 

10 MS. ARMSTRONG: I think what the 

11 DOE's position -- this is Ashley from DOE -- I 

12 think the DOE's position is that, based on the 

13 discussion today, based on the comments that 

14 we get in response to both the NOPR and the 

15 SNOPR, where we provided clarifications over 

16 these types of things, we will consider 

17 whether clarifications are needed as part of 

18 the final rule. 

19 To the extent you have specific 

20 examples where this wrinkle prevention is not 

21 a user-selectable option, but it is 

22 incorporated into the specific actual dryer as 
202-234-4433

Neal R. Gross & Co., Inc.

Page 133

1 part of the normal cycle, you know, obviously, 

2 we would welcome that. And that would lead 

3 towards part of our consideration for 

4 clarification. 

5 MR. BROOKMAN: Let's press on. 

6 MR. BATTAGLIA: Okay. Let's see. 

7 Okay, yes. So, the DOE is also proposing to 

8 change the field-use factor, as we discussed, 

9 from 1.04 to 0.80 for automatic-termination 

10 dryers. And that was based on the data we 

11 presented earlier on the energy consumption 

12 versus the RMC, to account for the measured 

13 energy consumption at the end of the test 

14 cycle to dry the DOE load below 2 percent RMC. 

15 Now here we are seeking comment on 

16 the proposed automatic-termination test 

17 method, and that includes the final RMC of 2 

18 percent, the cycle, temperature, and dryness 

19 level settings for the tests, and that field20 use factor of 0.80. So, I know we have 

21 come -- 

22 MR. BROOKMAN: Maybe we have 
202-234-4433

Neal R. Gross & Co., Inc.

Page 134

1 covered this. But any final comments? 

2 Jennifer? 

3 MS. CLEARY: I just have a 

4 question. It is a little unclear in the 

5 tables presented in the NOPR which data is 

6 presented including the field-use factor of .8 

7 and which is presented without. So, just the 

8 titles don't make it totally clear. I mean, I 

9 think you can infer, but we were just 

10 wondering if it would be possible to clarify 

11 for each table whether the field-use factor is 

12 applied or not. 

13 MR. BATTAGLIA: Sure. We can do 

14 that, and as a rule of thumb, anything before, 

15 if you look in the NOPR, anything before the 

16 section that discusses -- or, actually, I will 

17 go through and clarify because it might be 

18 different in different places. 

19 MS. CLEARY: Thank you. And where 

20 can we look to find that clarification? Like 

21 how will we find out about it? 

22 MS. ARMSTRONG: At break. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 135

1 MS. CLEARY: Okay. 

2 MR. BATTAGLIA: We can do that. 

3 Okay. Moving on, so for the timer 

4 dryers, DOE is proposing to essentially use 

5 the same basic test method that is currently 

6 specified in Appendix D1, but with the 

7 following modification that we listed. And 

8 that is to change the final RMC from 1 to 2.5 

9 percent for the test. 

10 And DOE is also proposing to add a 

11 clarification that the dryer should not be 

12 stopped intermittently throughout the test for 

13 any reason. And this would be to prevent 

14 testers from stopping the dryer multiple times 

15 to remove and weigh the test load because that 

16 would produce significantly-different results, 

17 because of heat loss when you open the door. 

18 And for that time-dry cycle, DOE 

19 is also proposing to change the normalization 

20 and per-cycle energy consumption calculation 

21 to reflect that new target final RMC of 2 

22 percent. We are not proposing at this time to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 136

1 change the field-use factor for timer dryers 

2 of 1.18. And we are also not proposing to 

3 include the cool-down period because it would 

4 add a significant burden on testers to figure 

5 out and preset the appropriate time setting, 

6 and it could also introduce issues with 

7 repeatability because different combinations 

8 of the time-dry heating and cool-down could 

9 potentially result in the same final RMC. 

10 So, here we are seeking comment on 

11 the proposed time-dry test method. And that 

12 is the change in the RMC, the proposal to 

13 maintain the field-use factor, and the 

14 proposal to clarify that the dryer should not 

15 be stopped intermittently throughout the test 

16 cycle. 

17 MR. BROOKMAN: And these slides 

18 that you have in your hands show both Item 3 

19 and Item 4. So, maybe we can address both of 

20 these at the same time. 

21 Chris? 

22 MR. CALWELL: This is Chris 
202-234-4433

Neal R. Gross & Co., Inc.

Page 137

1 Calwell. 

2 I was just curious if you have a 

3 rough market estimate of what fraction of the 

4 dryers sold today are timer dryers. 

5 MR. BATTAGLIA: I don't have the 

6 exact number, but there are very few, if any, 

7 like probably -- I can't comment on the exact 

8 number, but it is very few. 

9 MR. CALWELL: Yes, that was my 

10 sense as well. Essentially, you almost have 

11 to have some form of automatic termination to 

12 meet the standard. 

13 MR. BATTAGLIA: Right. And this, 

14 the proposal for timer dryers is just to 

15 provide, we have to provide methods for both 

16 types of dryers. So, it is to cover all 

17 cases. 

18 MR. CALWELL: Okay. Yes, I think 

19 the only other comment I would make is, 

20 because automatic-termination dryers are 

21 overwhelmingly dominant in the market, it puts 

22 added emphasis and importance and sort of 
202-234-4433

Neal R. Gross & Co., Inc.

Page 138

1 scrutiny on doing that procedure as carefully 

2 as possible because it is sort of the central 

3 technology being employed to meet your 

4 standard. 

5 MR. BROOKMAN: Jennifer? 

6 MS. CLEARY: I just received some 

7 input from someone on the webinar, that they 

8 haven't been able to receive the audio since 

9 10:30. I don't know if they have provided 

10 similar feedback on the webinar. 

11 MR. BROOKMAN: So, I guess we 

12 could try it again. Apparently, it worked 

13 when we turned on all the microphones. And 

14 then, we had that feedback blast. 

15 MS. ARMSTRONG: Why don't we take 

16 a break? 

17 MR. BROOKMAN: We are about five 

18 minutes away from taking our break. 

19 MS. ARMSTRONG: No, we are there. 

20 MR. BATTAGLIA: I think we are at 

21 the break. 

22 MS. ARMSTRONG: We are there. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 139

1 MR. BROOKMAN: I know. I know, 

2 but I just wanted to make sure we receive 

3 comments on Item No. 4, because I wasn't sure 

4 we had done that yet. 

5 You see Item No. 4. It is slide 

6 32 in your packet. And we will take a break 

7 after we have received these comments. 

8 (No response.) 

9 Okay. No additional comments? 

10 Let's take a break. It is now 11:10. We will 

11 break for 15 minutes. 

12 Those of you who are not familiar 

13 with the Forrestal Building, you must wear 

14 this badge in the building. 

15 There are restrooms on both ends 

16 of the hall. 

17 We will resume at 11:25. 

18 There is a coffee shop on the 

19 ground floor, if you go down the elevator, and 

20 there is a big cafeteria -- you have got to go 

21 quickly -- in any case, about 100 yards that 

22 way on the ground floor. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 140

1 So, we will see you back here at 

2 11:25. 

3 And for those of you on the 

4 webinar, we will try to resolve the audio 

5 issue. 

6 (Whereupon, the foregoing matter 

7 went off the record at 11:09 a.m. and went 

8 back on the record at 11:25 a.m.) 

9 MR. BROOKMAN: So, let's resume. 

10 Please take your seats. 

11 For those of you that are joining 

12 us via the web, as I understand it or as we 

13 understand it, our webmaster over here is 

14 saying that one person has had difficulty 

15 hearing and participating, but many other 

16 individuals, 10-12 or so, are making sense of 

17 what is being said here; that they are able to 

18 participate. 

19 Let me also say, as I said at the 

20 outset, joining by the web, if you wish to 

21 comment, please raise your hand. We will fit 

22 you into this conversation. We don't want to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 141

1 deny anybody access here. So, that is the 

2 general plan. 

3 Now we are going to return to 

4 where we were. 

5 Oh, and I think that Brenda 

6 distributed a list of all the individuals that 

7 registered with their business cards, this 

8 Xerox copy. So, I hope that is useful to you. 

9 Now we are going to return to 

10 James and pick up where we left off, which I 

11 believe is slide 33. 

12 MR. BATTAGLIA: Okay. So, now 

13 getting into standby and off mode, the test 

14 methods for those modes. 

15 Now the last final rule that DOE 

16 published in January 2011 incorporated 

17 provisions from IEC 62301, First Edition, for 

18 measuring standby and off mode power. And it 

19 also included some additional clarifications 

20 and adopted definitions of active, standby and 

21 off mode based on a draft version of the 

22 Second Edition, the Committee Draft for Vote. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 142

1 Now, for this SNOPR, because the 

2 IEC 62301 Second Edition published after the 

3 January 2011 final rule, DOE decided to 

4 consider the Second Edition for this 

5 rulemaking, and DOE determined that the Second 

6 Edition was an internationally-accepted test 

7 procedure and it does provide clarifications 

8 to certain conditions as compared to the First 

9 Edition. 

10 Now, for the power supply, the 

11 Second Edition, DOE is proposing to 

12 incorporate Section 4.4 of the Second Edition 

13 for the power-measuring instruments. Now DOE 

14 notes that it provides a more comprehensive 

15 specification for the required measurement 

16 accuracy. It requires the measurement of a 

17 crest factor, a power factor, and calculation 

18 of the maximum current ratio. And it also 

19 provides calculations for determining the 

20 allowable uncertainty in the maximum current 

21 ratio. 

22 And DOE determined that that 
202-234-4433

Neal R. Gross & Co., Inc.

Page 143

1 uncertainty is the same or less stringent than 

2 the allowable uncertainty in the First 

3 Edition, and that the changes in the allowable 

4 uncertainty maintain sufficient accuracy of 

5 the measurements without placing undue burden 

6 on test instruments. 

7 So, the Second Edition requires 

8 that the value of the harmonic content of the 

9 voltage also be recorded during the test, 

10 along with the crest factor and maximum 

11 current ratio. And it also requires measuring 

12 the average power or the total integrated 

13 energy consumption. 

14 Now DOE is aware that certain 

15 power-measuring instruments can measure each 

16 of these values individually. However, DOE is 

17 aware that certain industry standard test 

18 instruments are unable to measure the harmonic 

19 content and crest factor while also measuring 

20 the average power or total integrated energy 

21 consumption. 

22 So, DOE is proposing that it would 
202-234-4433

Neal R. Gross & Co., Inc.

Page 144

1 be acceptable to measure, if a power 

2 measurement instrument can't make all those 

3 measurements during the test, it would be 

4 acceptable to measure the total harmonic 

5 content, crest factor, and maximum current 

6 ratio both before and after the test. 

7 The other major changes in the 

8 Second Edition involve the actual power 

9 measurement techniques. And the Second 

10 Edition contains a more detailed technique to 

11 evaluate the stability of the power 

12 consumption and to measure power consumption 

13 of loads with different stability 

14 characteristics. And it provides three 

15 different test techniques. Those are the 

16 sampling, average reading, and direct meter 

17 reading methods. 

18 Now, based on DOE's evaluation of 

19 each of these test methods, DOE is proposing 

20 to require the use of the sampling method from 

21 Section 5.3.2 of the Second Edition, which the 

22 IEC procedure specifies as the preferred 
202-234-4433

Neal R. Gross & Co., Inc.

Page 145

1 method for all power measurements. 

2 And DOE notes that the sampling 

3 method provides for a test duration that is 

4 approximately the same or similar to the 

5 allowable alternatives. 

6 And it does not require the 

7 classification of the nature of the power 

8 consumption, that is, whether it is stable or 

9 unstable or cyclic or non-cyclic, prior to 

10 running the test. So, a tester would be able 

11 to monitor the power during the test to 

12 determine the appropriate test duration. 

13 Now here -- oh, sorry, a question? 

14 MR. BROOKMAN: Charlie Stephens. 

15 MR. STEPHENS: Standard 62301 

16 includes a definition of a network mode. Does 

17 DOE also include that in its use of 62301 or 

18 require any of these products to be measured 

19 in network mode, as defined by 62301? 

20 MR. BATTAGLIA: That is not in 

21 this proposal, no. 

22 MR. STEPHENS: How does DOE 
202-234-4433

Neal R. Gross & Co., Inc.

Page 146

1 propose to deal with that, given that most of 

2 these appliances are being shipped, or will be 

3 shipped very shortly, with the capability for 

4 demand-control response, smart-grid response, 

5 and given that these things, power consumption 

6 typically spikes up over 5500 watts when they 

7 are actually running. I think it is probably 

8 going to be one of the loads that is targeted 

9 as one that would be managed, and it does use 

10 power in the network mode in order to do that. 

11 So, I am kind of wondering how DOE intends to 

12 incorporate that. 

13 MR. BATTAGLIA: And we haven't 

14 considered that at this time. We are not 

15 aware of clothes dryers with network mode that 

16 are currently on the market. So, it becomes 

17 too difficult to develop a test procedure 

18 without actual products. 

19 MR. BROOKMAN: Chris? 

20 MR. CALWELL: Yes, this is Chris 

21 Calwell. 

22 We looked through the DOE database 
202-234-4433

Neal R. Gross & Co., Inc.

Page 147

1 that was recently published online of all the 

2 dryers, and the two most efficient electric 

3 models, the first one was from Miele and the 

4 second one was from Samsung. We have 

5 purchased both, and they are being tested in 

6 our lab right now. 

7 The Samsung does have the feature 

8 that Charlie described. It is the second-most 

9 efficient dryer on your dataset. And it logs 

10 into the wireless network of your house and 

11 will, among other things, send you an email 

12 when your laundry is done, which is an 

13 interesting feature. 

14 Right now, we don't know what the 

15 associated energy use is of that. We can 

16 measure it and submit data, but I think you 

17 might find -- as Charlie said, it is a new 

18 feature. It is not that common today. But, 

19 to the extent that Energy Star or others might 

20 be awarding a credit for dryers with smart21 grid capability, you probably would want to 

22 know what the energy use is in standby mode 
202-234-4433

Neal R. Gross & Co., Inc.

Page 148

1 for them to talk to the network. 

2 MR. BROOKMAN: Ashley? 

3 MS. ARMSTRONG: Yes, this is 

4 Ashley. 

5 DOE is working with EPA on smart 

6 dryers. We will be coming up with a test 

7 procedure for smart dryers as part of the 

8 Energy Star Program. Once we address it 

9 there, we will then also address it in 

10 baseline consumption as necessary. 

11 We are going through the same 

12 exercise right now with refrigerators. 

13 MR. BROOKMAN: Charlie? 

14 MS. ARMSTRONG: It just won't be 

15 here. 

16 MR. STEPHENS: Okay, but, then, my 

17 next question comes back to 62301. Is their 

18 definition of network mode, which is already 

19 defined in 62301, what you are using in your 

20 work with EPA? And if not, why not? 

21 MS. ARMSTRONG: I think that is 

22 beyond the scope of this setting, right? But 
202-234-4433

Neal R. Gross & Co., Inc.

Page 149

1 we could talk about that in terms of what we 

2 are doing. We just started doing the dryer 

3 effort for smart dryers. You can look at what 

4 we have done for connected refrigerators to 

5 see there. But I think it is beyond the scope 

6 of today's public meeting. 

7 MR. BROOKMAN: Michael? 

8 MR. BROWN: Michael Brown, 

9 Hydromatic. 

10 So, if I understand correctly, to 

11 connect the functionality is not a part of 

12 this discussion at this point in time? Is 

13 that correct? Thank you. 

14 MR. BROOKMAN: Okay. Let's see, 

15 Julia? 

16 MS. FARBER: Yes, Julia Farber 

17 from UL. 

18 Ashley, just while we brought up 

19 this topic of Energy Star, I was just curious 

20 if you might clarify how this rulemaking 

21 incorporate into the new version of the Energy 

22 Star Program that is due out this spring. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 150

1 MS. DAKEN: That is actually a 

2 question for me to answer. Abigail Daken. 

3 Basically, stay tuned. We are 

4 making that decision right now. We expect in 

5 the next week or two to get back to Energy 

6 Star dryer stakeholders on that very topic. 

7 MR. BROOKMAN: Okay. 

8 MS. FARBER: Thank you. 

9 MR. BROOKMAN: Thanks to both of 

10 you. 

11 Okay, James. 

12 MR. BATTAGLIA: Okay. And here we 

13 have a comment request on the adequacy of the 

14 Second Edition and the provisions we are 

15 proposing to incorporate for that. 

16 MR. BROOKMAN: Additional 

17 comments? 

18 (No response.) 

19 MR. BATTAGLIA: Okay. 

20 MR. BROOKMAN: Okay. Move it on. 

21 MR. BATTAGLIA: Just to discuss a 

22 minor technical correction in the per-cycle 
202-234-4433

Neal R. Gross & Co., Inc.

Page 151

1 energy consumption, combined total energy 

2 consumption calculation, the current 

3 calculation just contains an incorrect section 

4 number. The per-cycle standby mode and off 

5 mode energy consumption, which is actually in 

6 Section 4.7, is incorrectly referenced as 

7 Section -- or sorry -- it is contained in 4.5, 

8 and it is incorrectly referenced as 4.7. And 

9 DOE is just proposing to correct this 

10 reference and welcoming comments on that. 

11 MR. BROOKMAN: Moving on. 

12 MR. BATTAGLIA: Okay. So, DOE 

13 also received a number of inquiries regarding 

14 or requesting clarification on some of the 

15 test conditions for testing according to the 

16 current test procedures. And this section 

17 will address a few of those. 

18 Now, first, for the cycle 

19 settings, the first thing is about how to test 

20 a clothes dryer that has a time-dry cycle 

21 length, but no temperature sensing on the 

22 control panel. So, Section 3.3 of Appendix D 
202-234-4433

Neal R. Gross & Co., Inc.

Page 152

1 currently specifies that the maximum 

2 temperature setting and if it is equipped with 

3 a timer, the maximum time dryer setting should 

4 be used for the test. 

5 Now DOE is just proposing to 

6 clarify that, if the dryer does not have a 

7 separate temperature setting on the control 

8 panel, that the maximum time setting would be 

9 used for the test. And DOE is also proposing 

10 to include this change in Appendix D1 for the 

11 time-dry test method because that uses the 

12 same basic test method. 

13 Now, also, for the cycle settings, 

14 DOE received an inquiry about how to test a 

15 clothes dryer that has optional cycle setting, 

16 other than the temperature and time setting, 

17 that is activated by default in the condition 

18 that it is shipped in by the manufacturer. 

19 So, DOE is proposing to clarify in both 

20 Appendix D and D1 for that time-dry test 

21 method, that the test procedures only specify 

22 temperature and time settings and do not 
202-234-4433

Neal R. Gross & Co., Inc.

Page 153

1 specify modifications to any other optional 

2 cycle settings that do not affect those 

3 temperature and time settings. 

4 MR. BROOKMAN: Chris? 

5 MR. CALWELL: Chris Calwell. 

6 So, I think this does bear on the 

7 conversation we had a little earlier about the 

8 extended wrinkle prevention. And just for 

9 absolute clarity, it sounds like what you are 

10 saying here is, if it does the after-cycle 

11 -- let's just call it "after-cycle" -- 

12 tumbling by default, but you are able to 

13 optionally shut that off, would DOE optionally 

14 shut that off before it measures? 

15 MR. BATTAGLIA: I think what it is 

16 saying here is that, however it is shipped, 

17 the default mode would be the mode that is 

18 tested. If a product is shipped in that 

19 manner, then that is how we would test it. 

20 MR. CALWELL: Okay. And run 

21 indefinitely, as needed, to capture that 

22 energy? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 154

1 MR. BATTAGLIA: Correct. 

2 MS. DAKEN: One could argue, I 

3 suppose, that that -- this is Abigail Daken 

4 -- one could argue, I suppose, that that would 

5 affect the time. You know, depending on how 

6 DOE defines the end of the cycle, if the end 

7 of the cycle is when the buzzer goes off, then 

8 it wouldn't affect the time. If the end of 

9 the cycle is when the dryer ceases all 

10 activity, then it would affect the time. So, 

11 it should be turned off. 

12 MR. BATTAGLIA: Yes, and we can 

13 certainly take into consideration the wrinkle14 free, when exactly the end of cycle should be 

15 defined. 

16 MR. CALWELL: Yes, it sounds like 

17 there is just a little ambiguity there. And 

18 our sense is that it is a fairly new feature, 

19 but it is becoming more prevalent. 

20 MR. BROOKMAN: Charlie Stephens. 

21 MR. STEPHENS: Yes, I would also 

22 add there is some interaction here with 62301, 
202-234-4433

Neal R. Gross & Co., Inc.

Page 155

1 when you go to measure standby and off mode 

2 energy consumption because, you know, you are 

3 having cyclical energy used here that kind of 

4 goes on indefinitely. And you may run into 

5 some problems trying to decide how and when to 

6 apply 62301 if you don't get that fairly clear 

7 about when the cycle actually ends in these 

8 cases. 

9 MR. BROOKMAN: Okay. Thank you. 

10 MR. BATTAGLIA: Okay. And DOE is 

11 also proposing to make a similar clarification 

12 in Appendix D1 for the automatic-termination 

13 test methods, that any other optional settings 

14 other than the cycle program, temperature 

15 settings and dryness settings, the test 

16 procedures do not specify any modification to 

17 those optional settings that do not affect the 

18 settings that we have listed. 

19 Now, for the gas supply 

20 requirements in Section 2.3.2 and in both 

21 Appendix D and D1, it specifies that the 

22 normal inlet test pressure of 7 to 10 inches 
202-234-4433

Neal R. Gross & Co., Inc.

Page 156

1 of water column must be maintained for the gas 

2 supply to the clothes dryer, and that the 

3 hourly Btu rating of the burner must be 

4 maintained within plus or minus 5 percent of 

5 the rating specified by the manufacturer. 

6 Now DOE received an inquiry noting 

7 that during testing a gas dryer under test, it 

8 was not able to meet the requirement to 

9 maintain the specified Btu rating under the 

10 allowable inlet test pressure. So, DOE is 

11 proposing to clarify in both Appendix D and D1 

12 that, if the dryer is unable to achieve the 

13 Btu rating within the allowable pressure, the 

14 orifice of the burner should be modified as 

15 necessary to meet that requirement. 

16 Now, again, in Section 2.3.2, for 

17 the gas supply requirements, it specifies that 

18 if a dryer is equipped with a gas appliance 

19 pressure regulator, the regulator outlet 

20 pressure at the normal test pressure must be 

21 approximately that recommended by the 

22 manufacturer, but it does not specify exactly 
202-234-4433

Neal R. Gross & Co., Inc.

Page 157

1 what approximately equates to. 

2 So, DOE noted that similar gas3 heating products, such as gas water heaters 

4 specify that the regulator outlet pressure 

5 must be maintained within plus or minus 10 

6 percent. So, DOE is proposing to include that 

7 same requirement here to replace the term 

8 "approximately". 

9 Now there are also a few 

10 additional inquiries that DOE received. I 

11 don't know if everybody has seen it yet, but 

12 DOE has issued a separate SNOPR, and we just 

13 want to address those in the public meeting 

14 today to get people's feedback. 

15 So, the first of those was 

16 regarding the console lighting. That is 

17 contained in the installation conditions in 

18 Section 2.1 of both Appendix D and D1. And it 

19 specifies that all console lights or other 

20 lighting systems that do not consume more than 

21 10 watts shall be disconnected from the dryer 

22 during the active mode test cycle. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 158

1 Now DOE noted that this provision, 

2 which was originally adopted in the September 

3 1977 final rule, was intended to apply to an 

4 older generation of clothes dryers existing at 

5 that time that were equipped with task lights 

6 that illuminate the area of the dryer for the 

7 consumers, and that did not provide any 

8 function or information related to the drying 

9 process. 

10 Now DOE notes that the newer 

11 generation of dryers that are equipped with 

12 electronic controls may have fully integrated 

13 control setting indicators, such as indicator 

14 lights that show the cycle progression, 

15 temperature, or dryness settings, or other 

16 cycle functions. And those are built directly 

17 into the control boards for the dryers. 

18 So, DOE is proposing to clarify 

19 this section to state that console lights or 

20 other lighting system refers to all lights 

21 such as task lights that do not provide any 

22 function or information during the drying 
202-234-4433

Neal R. Gross & Co., Inc.

Page 159

1 cycle related to the drying process. 

2 And DOE is also proposing to 

3 clarify that the control setting indicators, 

4 such as those that we listed on the last 

5 slide, such as for the dryness and temperature 

6 settings, that cannot be turned off during the 

7 cycle should not be disconnected for the 

8 active-mode test cycle. 

9 Now Section 3.1 in both Appendix D 

10 and D1 for the drum capacity measurement 

11 specifies that the drum shall be filled with 

12 water to a level determined by the 

13 intersection of the door plan and the loading 

14 port. In addition, it also specifies that 

15 volume should also be added or subtracted, 

16 depending on whether the plastic bag that is 

17 used for the capacity measurement protrudes 

18 into the drum interior. 

19 Now DOE received an inquiry 

20 regarding this provision. So, we are 

21 proposing to clarify that the intersection of 

22 the door plan refers to the uppermost edge of 
202-234-4433

Neal R. Gross & Co., Inc.

Page 160

1 the drum that is in contact with the door 

2 seal, and that volume should be added or 

3 subtracted to account for any space that is 

4 not measured by the water fill. That is, for 

5 example, space occupied by the door protruding 

6 into the drum interior or space above the 

7 uppermost edge of the drum within a curved 

8 door. 

9 Now, for the weighing scale 

10 requirements, first, Section 2.4.1 for the 

11 test cloth weighing scale, specifies that the 

12 range of the scale must have a range of zero 

13 to a maximum of 30 pounds with a resolution of 

14 at least 0.2 ounces and a max error no greater 

15 than 0.3 percent for any values within the 

16 range of 3 to 15 pounds. 

17 And for the drum capacity 

18 measurement scale, it similarly requires a 

19 range of zero to 500 pounds with a resolution 

20 of half a pound and a max error of no greater 

21 than 5 percent of any measured value. 

22 So, DOE received an inquiry 
202-234-4433

Neal R. Gross & Co., Inc.

Page 161

1 regarding this, in particular, for the maximum 

2 range for each of the scale values. Now DOE 

3 recognizes that scales for weighing the test 

4 cloth may actually have a higher capacity than 

5 30 pounds, but it would still be able to meet 

6 the requirements for the resolution and the 

7 maximum error within the range of 3 to 15 

8 pounds that is specified in the test 

9 procedure. 

10 For the drum capacity 

11 measurements, a clothes dryer that is filled 

12 with water could potentially have a higher 

13 weight than 500 pounds. So, based on these, 

14 DOE is proposing to increase the range and 

15 allowable scale ranges for the test cloth up 

16 to 60 pounds and for the drum capacity scale 

17 for up to 600 pounds, but maintaining the 

18 resolution and maximum error requirements that 

19 are currently specified. 

20 And then, the final clarification 

21 is regarding the relative humidity 

22 measurement. Currently, on the test 
202-234-4433

Neal R. Gross & Co., Inc.

Page 162

1 procedure, it specifies that the dry and wet 

2 bulb psychrometer used for measuring the 

3 ambient humidity shall have an error of no 

4 greater than plus or minus 1-degree 

5 Fahrenheit. 

6 Now DOE recognizes that relative 

7 humidity sensors may be used in place of a dry 

8 and wet bulb psychrometer to measure the 

9 ambient humidity. And DOE also noted that 

10 certain humidity meters may express their 

11 error tolerances in degrees Fahrenheit for the 

12 dry and wet bulb temperatures, while others 

13 may express error in terms of the percent 

14 relative humidity. 

15 So, for that last one, in order to 

16 equate that to the current test procedure, DOE 

17 determined that, based on the allowable ranges 

18 of the temperature, which I believe are 72 to 

19 78 degrees Fahrenheit, and the humidity, which 

20 is 40 to 60 percent, the plus or minus 1-

21 degree Fahrenheit tolerance would translate to 

22 a tolerance between plus or minus 2 percent 
202-234-4433

Neal R. Gross & Co., Inc.

Page 163

1 and plus or minus 4 percent within the 

2 allowable ranges for the relative humidity. 

3 So, based on this, DOE is 

4 proposing to allow the use of a relative 

5 humidity meter that has error tolerances 

6 expressed in degrees Fahrenheit that are 

7 equivalent to the current requirements for the 

8 dry and wet bulb psychrometer and, also, for 

9 humidity meters that have error tolerances of 

10 plus or minus 2 percent that are displayed in 

11 percent relative humidity. 

12 And here, we are seeking comment 

13 on all of these clarifications from the cycle 

14 settings to the last relative humidity meter. 

15 MR. BROOKMAN: So, look at the 

16 comment request Box No. 7. You can see six 

17 different items that the Department is seeking 

18 comments on, should you have any. 

19 Chris? 

20 MR. CALWELL: Chris Calwell. 

21 The only one I would comment on 

22 here is the relative humidity that I mentioned 
202-234-4433

Neal R. Gross & Co., Inc.

Page 164

1 briefly before. There is a fairly short time 

2 between now and when the written comments are 

3 due. So, we will attempt to make some 

4 measurements of this for a few different 

5 models. But I guess my comment here now would 

6 be to encourage DOE to do the same. 

7 And the question might be for a 

8 handful of models, as you migrate from 40 to 

9 50 to 60 percent, what happens to measured 

10 energy use, drying time and measured 

11 efficiency? 

12 MR. BROOKMAN: Okay. Additional 

13 comments? 

14 (No response.) 

15 Okay. I see none. 

16 MR. BATTAGLIA: Okay. Now to 

17 address the effects of the proposed test 

18 procedure on compliance with the standards. 

19 In any test procedure rulemaking, DOE is 

20 required to determine how a proposed test 

21 procedure would alter the measured efficiency 

22 of covered products as compared to the current 
202-234-4433

Neal R. Gross & Co., Inc.

Page 165

1 test procedure. And if DOE determines that 

2 the amended test procedure would alter the 

3 measured efficiency, DOE must amend the 

4 applicable energy conservation accordingly. 

5 For Appendix D, DOE is only 

6 proposing to clarify the test conditions for 

7 the cycle settings, and so on, that we 

8 discussed in the last section. DOE notes that 

9 these proposed amendments would not affect the 

10 measured efficiency according to Appendix D, 

11 and therefore, would not affect a 

12 manufacturer's ability to comply with the 

13 current standards. 

14 Now, because the January 2015 

15 standards are based on the CEF, as measured 

16 according to Appendix D1, DOE investigated how 

17 the proposed amendments would affect the 

18 measured CEF, starting with the proposed 

19 active-mode amendments. Now DOE conducted 

20 testing on 20 dryers, and the results showed 

21 that the measured CEF was either higher or 

22 lower than the CEF as compared to the current 
202-234-4433

Neal R. Gross & Co., Inc.

Page 166

1 test procedure. And that ranged from about a 

2 27 percent decrease to about a 20 percent 

3 increase in CEF, with an average of about 4 

4 percent. 

5 Based on this, DOE tentatively 

6 concludes that the proposed active-mode 

7 amendments will, on average, for dryers 

8 currently on the market, would not impact the 

9 measured efficiency as compared to the current 

10 test procedure. 

11 MR. BROOKMAN: Tom Eckman. 

12 MR. ECKMAN: So, this is assuming 

13 that the 80 percent field-adjustment factor is 

14 employed? 

15 MR. BATTAGLIA: That is correct. 

16 MR. ECKMAN: And what would happen 

17 if that was not? 

18 MR. BATTAGLIA: I think on a few 

19 of the earlier slides it showed that like a 

20 20-percent decrease. I don't have the exact 

21 average, but it was that range of maybe 10 to 

22 40 percent decrease in CEF. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 167

1 MR. ECKMAN: So, just looking at 

2 the map there of the 20 tested, given the 

3 percent increase was smaller than the percent 

4 decrease, yet the average was an increase, it 

5 means that more of the units failed than 

6 passed without the field-adjustment factor. 

7 MR. BATTAGLIA: I don't have the 

8 -- I can look at the exact numbers of how many 

9 were below. 

10 MR. ECKMAN: I mean, if you have a 

11 27 percent decrease and only a 20 percent 

12 increase, then the average is a 4 percent 

13 increase. The majority of that would have had 

14 to fail without the field-use-adjustment 

15 factor. 

16 MR. BATTAGLIA: Okay. We can look 

17 at the data, but -- 

18 MR. ECKMAN: I am going to make 

19 you say it. 

20 (Laughter.) 

21 MR. BROOKMAN: Ashley? 

22 MS. ARMSTRONG: This is Ashley. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 168

1 I think it is fairly clear, 

2 without the field-use factor, they pretty much 

3 all fail. 

4 MS. MAUER: Joanna Mauer. 

5 Just a clarification. So, if DOE 

6 were to decide not to apply the field-use 

7 factor, then the standards would be adjusted 

8 accordingly, such that on average a dryer that 

9 just complies with the 2015 standards under 

10 the current test procedure would still comply 

11 with the 2015 standards? 

12 MR. BROOKMAN: Is that -- 

13 MS. MAUER: I guess a 

14 clarification. That is my understanding of 

15 the statute. 

16 MR. BATTAGLIA: That is my 

17 understanding of the procedure. 

18 MS. MAUER: But it is a question, 

19 I guess, in case I misinterpreted it. 

20 MS. ARMSTRONG: I think our 

21 proposal is a reflection of what we did. Feel 

22 free to comment. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 169

1 MS. MAUER: Okay. Sorry. Joanna 

2 Mauer again. 

3 Just one observation. A 4 percent 

4 increase, it doesn't seem to me to be 

5 insignificant considering that the 2015 

6 standards will reduce energies by about 5 

7 percent compared to the current standards. 

8 MR. BROOKMAN: Okay. Chris? 

9 MR. CALWELL: Yes, Chris Calwell. 

10 I think it is interesting here 

11 that the swing was so wide. You know, at one 

12 end you had a 27 percent decrease and on the 

13 other end a 20 percent increase. On average, 

14 it might be a fairly small change, but dryers 

15 aren't qualifying on average. They are 

16 qualifying individually. And so, depending on 

17 the choice of technologies they used, this 

18 difference is profound. 

19 I guess if we had a range of 

20 heights of people in this room and the water 

21 level came up, we could say, on average, none 

22 of us are drowning, but some of us are and 
202-234-4433

Neal R. Gross & Co., Inc.

Page 170

1 some of us aren't. 

2 (Laughter.) 

3 And so, it might be interesting to 

4 know what actually happens to the dryers, you 

5 know, rather than on average. 

6 We were testing dryers with the 

7 DOE test and otherwise, and one of my 

8 colleagues said that it looks like they are 

9 measuring precisely the wrong thing. And as I 

10 looked at the data and talked to folks and 

11 considered things, I think, no, that is not 

12 quite right. I think they are measuring the 

13 wrong thing precisely. 

14 There is a lot of precision around 

15 the test procedure. That part is good. It is 

16 admirable. It is repeatable, and so forth. 

17 But it is not necessarily measuring the right 

18 thing. 

19 And so, it seems like it is a 

20 convenient coincidence that the 20 percent 

21 adjustment factor that you have chosen is just 

22 what is needed to say the standard came out 
202-234-4433

Neal R. Gross & Co., Inc.

Page 171

1 about the same. But maybe, as Tom was saying, 

2 I think a more honest procedural approach 

3 would be change the test procedure to measure 

4 real-world -- I'm sorry -- to measure the real 

5 effects of automatic termination, and then see 

6 what standard needs to be selected to capture 

7 the cost effect of savings you observed. That 

8 seems like the most honest, literal reading of 

9 what the law asks you to do. 

10 MR. BROOKMAN: Okay. Ashley? 

11 MS. ARMSTRONG: Yes. 

12 MR. BROOKMAN: Okay. Good. Okay. 

13 Additional, and perhaps final, 

14 comments on this section here? 

15 Yes, Jennifer? 

16 MS. CLEARY: I do have more 

17 comments, but I see there is a comment box 

18 coming up. Are we going to skip that one 

19 or -- 

20 MR. BATTAGLIA: Sure. I think 

21 there is just one more slide. It should be 

22 pretty quick. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 172

1 MS. CLEARY: Okay. 

2 MR. BATTAGLIA: Okay. So, for the 

3 standby and off mode, DOE conducted testing 

4 both according to the current Appendix D that 

5 uses the First Edition and the proposed 

6 Appendix D1 that uses the Second Edition. And 

7 basically, just the testing showed that there 

8 was no difference in the measured values. So, 

9 as a result, DOE does not believe that the 

10 proposed standby and off mode amendments would 

11 affect the measured efficiency. So, DOE is 

12 not considering amendments to the current 

13 standards or the January 2015 standards. 

14 Sorry. 

15 And here we have the comment 

16 request. 

17 MR. BROOKMAN: Jennifer? 

18 MS. CLEARY: Okay. Jennifer 

19 Cleary. 

20 I guess we have sort of similar 

21 comments that we have been hearing expressed 

22 already. AHAM, first of all, questions DOE's 
202-234-4433

Neal R. Gross & Co., Inc.

Page 173

1 authority under EPCA to make de minimis 

2 determinations regarding the impact of test 

3 procedure changes on measured energy. 

4 We are also concerned that DOE's 

5 approach is ignoring the range that was just 

6 mentioned across basic models, you know, in 

7 situations like this where the average is zero 

8 or close to it, but the range is quite 

9 significant. 

10 We think that DOE's policies, when 

11 applied prior to an already promulgated, but 

12 not yet mandatory amended standard, undercuts 

13 the three-year lead-in period that is required 

14 by law, especially because of the 

15 grandfathering protections in 6293(e)(2) may 

16 not apply in many of these situations. So, we 

17 are quite concerned about this, and we will 

18 certainly provide more comments, more detail 

19 rather in our written comments, as well as 

20 data, if possible. 

21 MR. BROOKMAN: Okay. Thank you. 

22 You can see the comment box there. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 174

1 Additional comments here? 

2 (No response.) 

3 MR. BATTAGLIA: All right. Now 

4 just to cover a few other EPCA requirements, 

5 first, for the test burden, EPCA requires that 

6 test procedures not be unduly burdensome to 

7 conduct. 

8 Now, for the proposed amendments 

9 for automatic-cycle termination, since we are 

10 proposing to use the full program cycle, 

11 including the cool-down period, and just 

12 allowing the dryer to run until the completion 

13 of the cycle, DOE believes that this will be 

14 less burdensome than the current test 

15 procedure because it wouldn't require testers 

16 to monitor or make any estimates about the RMC 

17 throughout the test to stop the dryer at the 

18 appropriate time. 

19 For the time-dry test method, DOE 

20 is proposing to use the same basic test 

21 method, except the test would be stopped at 1 

22 to 2.5 percent RMC. And while that would 
202-234-4433

Neal R. Gross & Co., Inc.

Page 175

1 result in a slightly-longer cycle time, DOE 

2 believes that the additional time would be 

3 minimal compared to the overall time required 

4 to set up and run a test. 

5 So, for these reasons, DOE does 

6 not believe that the proposed amendments for 

7 active mode would be a test burden. 

8 Now, for standby and off mode, the 

9 proposed amendments are based on the updated 

10 version of 62301, which has been the subject 

11 of significant review and input from 

12 interested parties. Now the provisions in the 

13 Second Edition provide a means to measure the 

14 power consumption with greater accuracy and 

15 repeatability than the provisions in the First 

16 Edition of IEC 62301. 

17 And DOE also notes that interested 

18 parties have commented in general that the 

19 test methods would not be unduly burdensome to 

20 conduct. 

21 Now the potential for increased 

22 test burden for certain power consumption 
202-234-4433

Neal R. Gross & Co., Inc.

Page 176

1 measurement requirements DOE notes would be 

2 offset by the more reasonable requirements for 

3 the testing equipment while maintaining 

4 sufficient accuracy. 

5 So, for these, DOE tentatively 

6 concludes that the proposed standby and off 

7 mode amendments would not be unduly burdensome 

8 to conduct. And here, we are just seeking 

9 comment on that issue. 

10 MR. BROOKMAN: Chris? 

11 MR. CALWELL: Yes, this is Chris 

12 Calwell. 

13 Can you remind me -- and this is 

14 just because we haven't done the test -- how 

15 long does it take to complete the DOE testing 

16 for a clothes washer relative to a clothes 

17 dryer? I mean just roughly. 

18 MR. BATTAGLIA: Judy, do you want 

19 to -- 

20 MR. BROOKMAN: Judith? 

21 MS. REICH: Judith Reich from 

22 Navigant. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 177

1 A clothes washer, on average, 

2 takes about three days to test. 

3 MR. CALWELL: And a clothes dryer, 

4 gosh, let's see, three runs, maybe a day, a 

5 day and a half? I mean, you have to calculate 

6 the burden. So, you might have an actual 

7 official estimate, but would that be about 

8 right? 

9 MR. BATTAGLIA: I mean, it depends 

10 on whether it is for compliance testing or 

11 not. But the DOE test procedure only requires 

12 one run. So, it is probably in the 

13 neighborhood of a couple of hours, I would 

14 say. 

15 MR. CALWELL: Yes. 

16 MR. BATTAGLIA: Sorry. A couple 

17 of hours for the active mode and, then, the 

18 additional hours for the standby and off mode. 

19 MR. CALWELL: Yes, so relatively 

20 more burden for the washer than for the dryer 

21 might be a fair statement. 

22 Part of why that interested us was 
202-234-4433

Neal R. Gross & Co., Inc.

Page 178

1 I think, when all this effort began, you know, 

2 decades ago, washers were using significantly 

3 more energy than dryers. And so, it would 

4 make sense that you might have to undergo more 

5 testing and do more work, in effect, to see 

6 how much energy they are using. 

7 Because washers have improved so 

8 much, at least the rough numbers that we have 

9 calculated said that a dryer now uses about 

10 three times as much energy as a washer on 

11 average. And this is not per cycle or 

12 anything else. It is just annual average, 

13 total consumption in the field. 

14 And so, I guess I would submit 

15 that it might be worth a little more test 

16 burden to determine how much energy they are 

17 actually using and to try to reduce it, 

18 because the relative size of the target is now 

19 larger. And the washer test burden has been 

20 justified in the past and accepted by industry 

21 for what is now a much smaller potential 

22 energy savings to be gotten. So, that would 
202-234-4433

Neal R. Gross & Co., Inc.

Page 179

1 be one comment. 

2 The second one is actually a 

3 question for AHAM. I know that, quite apart 

4 from all this energy testing, of course, 

5 manufacturers do a lot of other testing of 

6 other products for other reasons. And AHAM 

7 had certified this more diverse load that 

8 Charlie showed you earlier back in 1992. 

9 What do your members use that load 

10 for? 

11 MS. CLEARY: I think they use it 

12 for testing under our test procedure and 

13 probably a variety of other things. I would 

14 be glad to get back to you on that. 

15 MR. CALWELL: Yes. My sense was 

16 that it was probably developed at the 

17 manufacturers' request because they all wanted 

18 some standard way to know how their dryers 

19 would perform, not necessarily for energy 

20 reasons, but for whatever. You know, did the 

21 clothes get dry enough? How long did it take, 

22 whatever it might be? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 180

1 In other words, manufacturers have 

2 to test things to make sure that consumers 

3 will be happy with them. So, the DOE testing 

4 for energy is, in effect, an additional test 

5 beyond what you might run originally. 

6 If you already had a 

7 representative load that the industry was 

8 using to determine consumer satisfaction with 

9 the dryers, I would submit that simply 

10 measuring energy at the same time would be a 

11 lower test burden than coming up with an 

12 additional, less-representative DOE test and 

13 doing it in addition to the testing the 

14 manufacturers are already doing. 

15 MR. BROOKMAN: Okay. Thank you. 

16 Additional comments related to 

17 active mode, standby and off modes? 

18 (No response.) 

19 MR. BATTAGLIA: Okay. Now EPCA 

20 authorizes DOE to enforce compliance with the 

21 standards established for certain consumer 

22 products. Now, for dryers, the certification 
202-234-4433

Neal R. Gross & Co., Inc.

Page 181

1 requirements consist of a sampling plan for 

2 the selection of units for testing and 

3 requirements for certification reports. 

4 Now, because DOE introduced the 

5 new CEF metric in the January 2011 final rule, 

6 DOE is proposing to include that in the CFR 

7 for the compliance requirements. 

8 And DOE is also proposing to amend 

9 the reporting requirements in the CFR for 

10 manufacturers when using Appendix D or D1 to 

11 provide an indication of whether the dryer has 

12 automatic-termination controls and, also, to 

13 report the hourly Btu rating of the burner for 

14 gas dryers. 

15 And when using Appendix D, DOE is 

16 also requiring manufacturers to report, to 

17 list the cycle settings and also the CEF, 

18 which I don't think I listed here, but we are 

19 also proposing to include that. 

20 Now, for the compliance date, DOE 

21 has issued guidance previously that 

22 manufacturers may voluntarily use a newly-
202-234-4433

Neal R. Gross & Co., Inc.

Page 182

1 amended test procedure to rate and certify 

2 their products prior to the compliance date 

3 required for using the new test procedure or 

4 an amended test procedure. 

5 Now EPCA requires that, effective 

6 180 days after the promulgation of any final 

7 test procedure amendments, based on this 

8 proposal, manufacturers must make 

9 representation of energy efficiency, including 

10 for certification of compliance, using either 

11 Appendix D or D1. 

12 And DOE is also proposing to 

13 require that manufacturers must use a single 

14 appendix for all representations and may not 

15 use Appendix D for some and D1 for others. 

16 And finally, we would just like to 

17 note that the compliance with DOE's amended 

18 standards for clothes dryers and corresponding 

19 use of the test procedure would be required as 

20 of the January 1, 2015 date. 

21 MR. BROOKMAN: Jennifer? 

22 MS. CLEARY: I just want to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 183

1 clarify that, if manufacturers choose to use 

2 Appendix D1 before the mandatory date, then 

3 they would also, as I understand the guidance 

4 related to this, be required to meet the 2015 

5 standard? 

6 MS. KOHL: This is Betsy Kohl from 

7 DOE. 

8 It is not a requirement. It is 

9 not a legal requirement. We encourage it. 

10 MR. BROOKMAN: Michael? 

11 MR. BROWN: Michael Brown. 

12 Relative to the compliance, the 

13 Department of Energy has a waiver program, I 

14 understand, that is in place that, if your 

15 dryer will deliver a level of energy 

16 efficiency that is not capturable currently by 

17 DOE's current Subpart 430(b), Appendix D or 

18 D1, classification, that a waiver may be 

19 sought for that particular dryer. 

20 The question I have relative to 

21 that is, how does that affect the 

22 certification of a dryer when there is no 
202-234-4433

Neal R. Gross & Co., Inc.

Page 184

1 procedure in place for the DOE to effectively 

2 capture energy that a particular dryer may 

3 deliver, but not capturable by the DOE's 

4 current D or D1 classification? 

5 MR. BROOKMAN: Ashley? 

6 MS. ARMSTRONG: This is Ashley 

7 from DOE. 

8 Currently, certification for 

9 dryers is already required for any dryers that 

10 are distributed in commerce in the U.S. These 

11 are just revised changes. 

12 But, to your question, a 

13 manufacturer may apply for a test procedure 

14 waiver if they determine that the measures of 

15 energy consumption, as measured by the 

16 existing test procedure, would be 

17 unrepresentative of their product's energy 

18 use. Or if they have some technology that is 

19 not accurately captured, you may apply for 

20 one. You know, there is a variety of things 

21 that need to go with your application, but one 

22 of those is an alternative method of test, an 
202-234-4433

Neal R. Gross & Co., Inc.

Page 185

1 alternative method of determining CEF for 

2 those particular models for which you are 

3 seeking a waiver. 

4 You need to go through the 

5 process. The Department would need to 

6 evaluate that waiver and either deny or accept 

7 such waiver. And once you do that, the 

8 certification is still required, and we would 

9 have the method of test that you would need to 

10 use to determine the CEF of your dryer. And 

11 then, subsequently, you would, then, certify. 

12 And there is a place on the certification 

13 form that, if you have a test procedure 

14 waiver, you must declare that. 

15 MR. BROWN: Okay. So that I 

16 understand properly, during the DOE's 

17 evaluation of the certification or waiver 

18 request, commercialization is not allowed? 

19 And how long does it take for the DOE to 

20 actually review a waiver of a particular 

21 clothes dryer test, D or D1? 

22 MS. ARMSTRONG: It varies, but I 
202-234-4433

Neal R. Gross & Co., Inc.

Page 186

1 would say the first step would be getting the 

2 process started. You must certify before 

3 distribution in commerce. 

4 MR. BROWN: So, when you say it 

5 varies, I mean, that is kind of ambiguous. 

6 You mean like varies like it might take three 

7 months or a year? If a waiver is submitted, 

8 which, of course, if a waiver is submitted and 

9 the commercialization is, therefore, prevented 

10 of that particular technology, then that would 

11 have a profound effect on a company trying to 

12 provide commercialization product that can't 

13 be adequately evaluated until a waiver is 

14 actually evaluated. So, we can't 

15 commercialize until a waiver has been reviewed 

16 and accepted? 

17 MS. ARMSTRONG: Correct. So, this 

18 is actually from DOE: we strongly encourage 

19 manufacturers to approach the Department if 

20 they feel a waiver is needed during the 

21 designing process, way before you get to the 

22 point of commercialization. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 187

1 That being said, you know, 

2 typically, if we get a waiver, you know, it 

3 may be missing parts or pieces. We work with 

4 the manufacturer to get through that process 

5 as quickly as we can. So, it is hard to say. 

6 You know, we get waivers that are 

7 simply stated, "I need a waiver." And 

8 obviously, that does not meet our requirements 

9 and our regulations. And we get complete 

10 waivers, in which case we can process those 

11 very quickly, depending on -- 

12 MR. BROWN: Okay. So, 

13 historically, it could range -- 

14 MS. ARMSTRONG: I'm not going to 

15 say a date. I'm not going to give you a date 

16 or a range. 

17 So, the first step would be, if 

18 you are that close, you need to apply for a 

19 waiver, if you feel that you need one. 

20 MR. BROWN: Okay. So, I had 

21 actually asked Mr. Witkowski about a waiver a 

22 year ago, and I am curious now. We are in the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 188

1 process where we would like to commercialize 

2 our technology. 

3 MS. ARMSTRONG: Yes. 

4 MR. BROWN: And let me just 

5 clarify this. I was informed by the DOE, and 

6 Judy Reich may be able to remember me in 2010 

7 when I submitted my dryer technology -- 

8 MS. ARMSTRONG: So, can we take 

9 this conversation offline? I am just going to 

10 ask, is there a reason that it needs to go on 

11 the record? 

12 MR. BROWN: Yes. 

13 MS. ARMSTRONG: Okay. 

14 MR. BROWN: There is a very 

15 important reason why my questions and my 

16 statements need to go on the record. Because 

17 when it comes to commercializing a technology, 

18 the Department of Energy will prevent a 

19 company from commercializing the technology if 

20 that technology requires a waiver because the 

21 current test protocol for clothes dryer, 

22 according to D or D1, may not effectively 
202-234-4433

Neal R. Gross & Co., Inc.

Page 189

1 represent the true energy consumption of that 

2 particular dryer. Therefore, if it does not 

3 capture that dryer's energy efficiency per se, 

4 then it is not representative of that; the 

5 current test may not be representative. 

6 So, in that regard, when we tried 

7 to get our dryer commercialized, we were 

8 informed by DOE officials that it had to be 

9 tested first. Of course, when we followed 

10 suit with that, and for three months we waited 

11 for DOE, who had our technology, and it 

12 ultimately was sent back to us because it 

13 wasn't commercialized. 

14 So, we were getting two different 

15 things. We were getting it must be 

16 commercialized, and then we were getting it 

17 must be tested before it is commercialized. 

18 So, my particular question here, 

19 because it is a different technology, is, if 

20 we submit a waiver to the DOE relative to the 

21 fact that its current D or D1 tests may not be 

22 representative of the energy efficiency of our 
202-234-4433

Neal R. Gross & Co., Inc.

Page 190

1 current dryer, I am just trying to try to get 

2 an understanding of what the length of time in 

3 that process may be. And if you don't have a 

4 clear answer on that, which you may not have, 

5 is there a way where a company can expedite a 

6 waiver request to be looked at? 

7 MS. ARMSTRONG: So, this is Ashley 

8 from DOE. 

9 I think it is fair to say that the 

10 first step in the process is submitting a 

11 completed waiver application. DOE does not 

12 test your products. The requirement is on the 

13 manufacturer to come up with their certified 

14 ratings through testing, using the DOE test 

15 procedure and applicable sampling plans. 

16 That being said, you may do it in 

17 your facilities or you may do it at a third18 party lab. It is at your discretion for 

19 dryers. We do not have laboratory testing 

20 requirements for dryers. It just must be done 

21 in accordance with our test procedure. 

22 In order to test, if you feel you 
202-234-4433

Neal R. Gross & Co., Inc.

Page 191

1 need a waiver, you need to go through the 

2 waiver process. So, the first step would be 

3 to apply for a waiver and complete the full 

4 application process, which includes an 

5 alternative method of tests for your dryer 

6 that you feel more accurately represents these 

7 consumption of your dryer. 

8 There are a variety of steps. I 

9 am more than happy to lay out the process. 

10 But, as I said earlier, we are committed to 

11 working with you; you need to begin the 

12 process, though. It is not, "I am going to 

13 turn my product over to DOE for testing." 

14 That is not part of the process. The testing 

15 requirements are on you as the manufacturer. 

16 MR. BROWN: Okay. And then, to 

17 clarify, I am not asking the DOE to test it. 

18 I understand I need third-party validation, 

19 not by the DOE. 

20 MS. ARMSTRONG: You do not. The 

21 requirements, manufacturers can self-certify 

22 using their own test data. They can elect to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 192

1 use a third party if they wish. They do not 

2 have to for dryers. 

3 MR. BROWN: Okay. Okay. So, for 

4 certification purposes for a dryer, you are 

5 saying that it does not have to be, the dryer 

6 does not have to be certified by a third-party 

7 agency? It can be submitted by our company? 

8 MS. ARMSTRONG: The requirement is 

9 on the manufacturer and/or the importer. They 

10 may elect to use their own testing facilities 

11 or a third-party testing facility, at their 

12 discretion. 

13 MR. BROWN: Okay. Thank you. 

14 MS. ARMSTRONG: The test just 

15 needs to be done in accordance with D or D1. 

16 When you certify, you will certify a legally17 binding statement saying that you have tested 

18 in accordance with the test procedure and 

19 these are the results you have gotten. And 

20 that all must be completed before distribution 

21 in commerce. 

22 MR. BROWN: Thank you. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 193

1 MS. ARMSTRONG: Yes. 

2 MR. BROOKMAN: Okay. So, final 

3 comments on slide 63, compliance data? I want 

4 to make sure. 

5 Yes, Charlie? 

6 MR. STEPHENS: Charlie Stephens. 

7 On the second sub-bullet there, 

8 "Manufacturers must use a single appendix for 

9 all representations," would an example of that 

10 representation be Energy Star certification? 

11 So, one appendix for everything they certify 

12 to? 

13 MS. ARMSTRONG: Correct. 

14 MR. STEPHENS: Okay. 

15 MS. ARMSTRONG: So, if Energy Star 

16 opted to use the amended test procedure early, 

17 then for compliance purposes, the 

18 certification to DOE would have to be using 

19 that. 

20 MR. STEPHENS: Okay. Thank you. 

21 MS. ARMSTRONG: Yes. 

22 MR. BROOKMAN: Thank you, Ashley. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 194

1 Final comments on this set of 

2 slides? 

3 (No response.) 

4 Then, go to the final slide, 64. 

5 As you are looking at this one, there is an 

6 opportunity now, as we promised first thing 

7 this morning, for anybody that wishes to do so 

8 to make final comments, raise other issues 

9 that haven't been adequately addressed during 

10 the course of this proceeding. 

11 Charlie? 

12 MR. STEPHENS: Yes, just some 

13 quick ones that were highlighted in the slides 

14 that I first showed with some differences that 

15 we haven't really discussed today. 

16 But DOE made some changes to the 

17 test procedure in the last round from the 2005 

18 procedure that lowered the number of annual 

19 cycles from 416 to 283, that changed the 

20 remaining moisture from 70 percent to 57 

21 percent. Those turned out not to be actually 

22 very relevant to the field, as it turns out. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 195

1 I went through all of that, and I 

2 remember the RECS survey and RECS data that 

3 was used and the rationalization of larger 

4 clothes washers, meaning larger loads, and 

5 therefore, fewer loads annually, and all of 

6 those justifications that were used, for 

7 instance. But those turn out not to be true, 

8 based on the data from the field. 

9 Does DOE have any plans to 

10 reevaluate those numbers and perhaps put them 

11 back closer to where they were, which, albeit 

12 not entirely where our data shows, would be a 

13 lot closer? 

14 MR. BATTAGLIA: We will take into 

15 consideration any data and comments submitted. 

16 MR. BROOKMAN: Chris? 

17 MR. CALWELL: Yes, I think the 

18 California utilities would just like to make a 

19 similar point there, that the data were 

20 submitted to DOE -- what was the date, 

21 Charlie? 

22 MR. STEPHENS: May 24th of 2012. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 196

1 MR. CALWELL: Okay, yes. So, 

2 eight-nine months ago. And I think it is true 

3 that they are somewhat daunting. I mean, we 

4 have been struggling with the data for a while 

5 ourselves. And so, it is one thing to have 

6 the data and another thing to try to sort 

7 through them and draw conclusions from them. 

8 But what we saw in The Federal 

9 Register was DOE did reference a few aspects 

10 of the field data that were similar to DOE's 

11 existing assumptions, like the dry weight of 

12 the load, and I think the settings that people 

13 typically chose. 

14 What we didn't see cited by DOE 

15 were other aspects of NEEA data that clearly 

16 differed from DOE's assumptions. And the two 

17 most important ones I think would be the ones 

18 that Charlie just mentioned. 

19 So, just to reiterate, that the 

20 field data show that the clothes are wetter 

21 when they come out of the washer than DOE 

22 assumes. And it is a vexing problem. It 
202-234-4433

Neal R. Gross & Co., Inc.

Page 197

1 creates challenges for your washer standard as 

2 well, and I don't want to get into that. But 

3 one can imagine that new washers are 

4 absolutely capable of removing more water from 

5 clothing; they are just not consistently doing 

6 so. And that leaves the dryer with more work 

7 to do than you think it has to do. That is 

8 especially true when you are drying real 

9 clothing instead of the test cloths. 

10 The second issue, which I think 

11 doesn't delay you, doesn't reopen your test 

12 procedure, doesn't radically increase your 

13 work burden, is simply to acknowledge field 

14 results, that there are more loads being dried 

15 per year than you think, a lot more. 

16 And when you do that, what happens 

17 is the denominator, you know, the absolute 

18 amount of energy consumption that is occurring 

19 gets higher. And so, even if you can only 

20 save a modest percentage of that, you are 

21 saving more absolute energy that is worth more 

22 dollars and is, therefore, more cost-effective 
202-234-4433

Neal R. Gross & Co., Inc.

Page 198

1 to save. 

2 MR. BROOKMAN: Okay. So, another 

3 invitation, anybody that wishes to make a 

4 final comment at this point? 

5 Michael, briefly. 

6 MR. BROWN: Thank you. 

7 This is Michael Brown with 

8 Hydromatic Technologies. 

9 This question is relative to the 

10 Department of Energy's concern about the 

11 safety of clothes dryers and how they operate 

12 as opposed to just their energy efficiency and 

13 their RMCs. How does the Department go about 

14 bringing in or investigating new technologies 

15 that offer all of the energy efficiency the 

16 Department is seeking and the benefits that 

17 the Department is seeking that it can make 

18 sure it offers to consumers with the issue of 

19 safety for dryer fires, in particular which, 

20 according to CPSC, those numbers are pretty 

21 high on an annual basis. Dollar value, $100 

22 million a year in property damage. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 199

1 If there is a dryer technology, 

2 which we profess that there is one that will 

3 completely eliminate lint fires, as our hybrid 

4 electric dryer will do, how does the DOE 

5 address the safety concerns for a dryer that 

6 proposes to -- 

7 MR. BROOKMAN: Michael, I have to 

8 wonder whether this is germane to the topic 

9 today of the test procedure. 

10 MR. BROWN: It regards testing 

11 because, if a clothes dryer is being tested 

12 for energy efficiency, for RMCs, is that dryer 

13 not being tested for safety for dryer fires by 

14 the Department of Energy? 

15 MS. ARMSTRONG: No. 

16 MR. BROOKMAN: Ashley? 

17 MS. ARMSTRONG: The Department is 

18 testing for energy efficiency, not for safety. 

19 MR. BROWN: Not for safety? Okay. 

20 Thank you very much. 

21 MS. ARMSTRONG: We have other 

22 agencies that deal with safety and the testing 
202-234-4433

Neal R. Gross & Co., Inc.

Page 200

1 of such. 

2 MR. BROWN: Okay. Thank you. 

3 MR. BROOKMAN: Okay. Final 

4 comments before we close this session and I 

5 turn it back to Stephen Witkowski? 

6 Jen? 

7 MS. WALTNER: Hi. Jennifer Amann, 

8 ACEEE. 

9 As always, we appreciate the 

10 opportunity to sit on a public meeting and 

11 talk through the issues around test procedures 

12 and standards, and we look forward to 

13 submitting our written comments, which, just 

14 to reiterate, will deal primarily with 

15 concerns that we have regarding I think two 

16 main issues. 

17 So, in the joint petition that was 

18 submitted by the manufacturers and the 

19 efficiency advocates, we had based that on a 

20 set standard level that was to be adjusted to 

21 deal with changes to the test procedure as we 

22 had outlined. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 201

1 So, now I think we have some 

2 concerns about the Department's determination 

3 that the standard does not need to be 

4 adjusted, based on the results of the test 

5 procedure, and, also, with concerns about the 

6 adjustment to the test procedure not truly 

7 reflecting the automatic-termination controls 

8 and allowing the clothing to dry and the cycle 

9 to run and use those results, which was the 

10 basis of our petition. 

11 So, I just wanted to reiterate 

12 those comments, and we look forward to 

13 submitting our written comments and the next 

14 stage of the process. 

15 MR. BROOKMAN: Thank you. 

16 Anybody else? 

17 (No response.) 

18 Then, for my part, I thank you. 

19 We had a very productive meeting today, and I 

20 think it was efficient coverage of these 

21 topics. 

22 I would encourage you, as a part 
202-234-4433

Neal R. Gross & Co., Inc.

Page 202

1 of your packet, there is an evaluation form. 

2 Please take a few seconds to fill that out. 

3 And I will turn it back to Stephen 

4 Witkowski for closing remarks. 

5 MR. WITKOWSKI: Well, again, I 

6 just thank you for coming, and I want to 

7 reiterate the importance of submitting your 

8 written comments. The comment period closes 

9 by March 18th. So, please get them in, and we 

10 look forward to reviewing and evaluating what 

11 you have to say. And thank you again for 

12 attending. 

13 MR. BROOKMAN: Safe travels to 

14 everyone. 

15 (Whereupon, the above-entitled 

16 matter went off the record at 12:24 p.m.) 

17

18

19

20

21

22
202-234-4433

Neal R. Gross & Co., Inc.

Page 203

A

Abby 122:17

Abigail 1:20 8:5

59:4 64:16,17

77:2,3 93:1,2

122:18 150:2

154:3

ability 90:13

115:15 165:12

able 21:7 23:12

40:14 45:3 71:3

76:5,14 103:19

106:5 111:8

114:16 138:8

140:17 145:10

153:12 156:8

161:5 188:6

above-entitled

202:15

absolute 153:9

197:17,21

absolutely 197:4

accept 47:3 70:22

99:14 185:6

acceptable 49:4

57:18 144:1,4

acceptance 47:8

accepted 178:20

186:16

access 141:1

accomplish 117:15

account 39:8 84:22

85:20 87:9 93:21

93:22 94:5 107:8

133:12 160:3

accredited 82:16

84:13

accuracy 33:3

38:17 142:16

143:4 175:14

176:4

accurate 109:17

110:2

accurately 33:12

65:3 184:19 191:6

ACEEE 114:22

200:8

achieve 110:10

117:21 119:15

156:12

achieved 74:21

78:17,17 80:19

achieving 111:3

128:12

acknowledge 86:21

197:13

acquisition 109:14

action 119:7,8

activated 152:17

active 141:20

157:22 175:7

177:17 180:17

active-mode 159:8

165:19 166:6

activity 154:10

actual 41:13 43:4,8

60:15 82:8 111:6

121:2 132:22

144:8 146:18

177:6

add 68:20 119:3

135:10 136:4

154:22

added 75:1 90:9

137:22 159:15

160:2

addition 28:21

159:14 180:13

additional 6:12

28:22 38:13 86:12

97:19 99:5 107:1

109:6 113:19

114:19 116:16

139:9 141:19

150:16 157:10

164:12 171:13

174:1 175:2

177:18 180:4,12

180:16

additionally 107:18

address 28:4 46:11

136:19 148:8,9

151:17 157:13

164:17 199:5

addressed 194:9

adequacy 150:13

adequately 34:3

115:9 186:13

194:9

adjourn 4:7 11:3

adjusted 168:7

200:20 201:4

adjusting 64:9

adjustment 28:14

28:17 93:20

104:13 113:15

170:21 201:6

admirable 170:16

adopt 33:11 40:9

adopted 44:14

141:20 158:2

adopts 40:1 45:15

advancing 28:7

advocates 28:6

104:11 200:19

affect 115:15 153:2

154:5,8,10 155:17

165:9,11,17

172:11 183:21

affiliation 7:1

11:16

after-cycle 153:10

153:11

agencies 199:22

agency 117:14

192:7

agenda 3:7 9:15,17

9:19 11:2

ago 178:2 187:22

196:2

agree 114:12

agreement 116:9

AHAM 15:5 19:9

20:21 28:6 44:12

55:15 56:13

104:11 113:4

172:22 179:3,6

AHAM's 26:11

ahead 45:9 56:2

96:18 104:22

109:19,20

air 72:2,3,5 112:19

airflow 21:16,17,19

22:4,6

airtime 12:5

albeit 195:11

Alliance 2:3 3:9

8:12

allow 108:16

119:13 163:4

allowable 70:2 71:6

142:20 143:2,3

145:5 156:10,13

161:15 162:17

163:2

allowed 57:7 122:6

124:5,20 127:14

127:17 185:18

allowing 127:22

174:12 201:8

alter 164:21 165:2

alternative 95:14

96:17 184:22

185:1 191:5

alternatives 145:5

Amann 1:16

114:22,22 200:7

ambient 70:2 162:3

162:9

ambiguity 154:17

ambiguous 186:5

amend 39:7,11

106:19 107:7

165:3 181:8

amended 165:2

173:12 182:1,4,17

193:16

amendments 30:19

31:18 32:2,11

33:11 34:1 40:1

40:10 56:4 107:3

107:6 120:5 165:9

165:17,19 166:7

172:10,12 174:8

175:6,9 176:7

182:7

AMERICA 1:1

American 1:16

amount 17:20

22:15 35:22 61:11

64:22 70:8 79:20

90:17 104:6

197:18

amounts 36:20

99:7

analysis 101:20

and/or 192:9

annual 18:20 65:15

178:12 194:18

198:21

annually 195:5

answer 48:11 129:9

131:4 150:2 190:4

anticipate 59:19

anybody 10:1,21

23:20 104:7

105:10 141:1

194:7 198:3

201:16

anyway 29:16

30:15 87:19

apart 64:12 179:3

Apparently 138:12

appendix 32:15

106:10 135:6

151:22 152:10,20

155:12,21 156:11

157:18 159:9

165:5,10,16 172:4

172:6 181:10,15

182:11,14,15

183:2,17 193:8,11

appliance 1:19,22

2:1 3:12 7:9,22

8:3,18 156:18

appliances 32:5

146:2

applicable 165:4

190:15

application 28:17

85:21 184:21

190:11 191:4

applied 37:16

84:20 100:7 102:7

134:12 173:11
202-234-4433

Neal R. Gross & Co., Inc.

Page 204

applies 37:18

apply 32:16 155:6

158:3 168:6

173:16 184:13,19

187:18 191:3

appreciate 46:8

200:9

approach 171:2

173:5 186:19

appropriate 88:8

96:19 136:5

145:12 174:18

appropriately 12:9

approved 27:7

approximately

87:21 145:4

156:21 157:1,8

area 158:6

argue 154:2,4

Armstrong 1:14

9:6,6 46:9,10 48:7

49:17,18,19,20

51:21 52:2 63:4,5

71:7,8 81:17,19

81:20 82:4,10,19

83:13,18 84:7,14

86:17,18 89:17

92:11 94:2,14

95:1,9,13 96:11

97:6 100:3,10,18

125:16,19 127:2,5

127:10 130:11

131:8 132:10

134:22 138:15,19

138:22 148:3,14

148:21 167:22

168:20 171:11

184:6 185:22

186:17 187:14

188:3,8,13 190:7

191:20 192:8,14

193:1,13,15,21

199:15,17,21

articles 41:3

Ashley 1:14 9:6

46:10 49:18,19

51:20,22 63:4,6

71:7,8 81:19

86:17 89:16 92:13

93:12 94:1,2,22

96:13 99:21

125:18,19 127:5

130:10 132:11

148:2,4 149:18

167:21,22 171:10

184:5,6 190:7

193:22 199:16

asked 112:6 113:9

187:21

asking 42:21 54:7

54:17 66:5 83:7

191:17

asks 171:9

aspects 196:9,15

assess 72:8

assesses 107:16

assessing 109:17

assigned 33:6,7

associated 119:5

147:15

association 1:19,22

7:22 8:3 113:6

assume 89:21

assumed 18:8

assumes 46:14

48:12 196:22

assuming 120:13

166:12

assumption 47:1

98:13

assumptions

196:11,16

attempt 42:19

46:11 51:17 61:15

164:3

attending 202:12

audience 24:3 84:1

audio 23:7,9 138:8

140:4

August 38:9

Australian 21:6

113:6

Australia/New

20:11

authority 173:1

authorizes 180:20

auto 22:10,11

37:11 111:8 124:7

126:3,4 132:2

automatic 3:15

10:6 32:14,19,21

33:12,16 34:2,7

37:18 38:12 42:3

56:18 57:8 101:16

103:5 108:19

110:8,16,22

125:13 126:1,12

128:8 137:11

171:5

automatically

127:4

automatic-cycle

174:9

automatic-termi...

28:5,11 30:20

33:5 34:4 37:20

38:18 39:3,9,12

39:19 56:5,20

57:21 58:8 59:8

63:20 67:10 68:13

73:17 74:11 85:1

93:10 101:15

107:9,11,12,19,21

108:6,15 109:16

111:5 121:4,5

125:7 126:14

127:15 133:9,16

137:20 155:12

181:12 201:7

auto-drying 126:17

auto-terminate

124:11

auto-termination

36:19 76:21 87:19

90:7,15 127:8

available 27:6

113:4

Avenue 1:11

average 16:2,11

17:10 18:4,12,16

18:20 51:15 60:9

65:15 67:14 69:11

90:14,21 94:18

95:17 96:12 99:10

99:15 143:12,20

144:16 166:3,7,21

167:4,12 168:8

169:13,15,21

170:5 173:7 177:1

178:11,12

averaged 16:18

22:7

averages 58:5

103:16

awarding 147:20

aware 66:6 143:14

143:17 146:15

Awareness 2:1 3:12

8:18

a.m 1:11 5:2 140:7

140:8

B

B 1:22

back 14:18,18

27:12 37:1 56:1

59:10 60:5 72:13

73:14 84:16 88:22

97:8 104:9,19

140:1,8 148:17

150:5 179:8,14

189:12 195:11

200:5 202:3

backsliding 105:17

badge 139:14

bag 159:16

balance 105:13,18

Baltimore 5:12

band 7:4

base 114:6

based 39:15 42:16

57:16 84:18 95:4

95:5,6 106:18,21

107:6 108:7

113:20 122:13

131:10 132:12,13

133:10 141:21

144:18 161:13

162:17 163:3

165:15 166:5

175:9 182:7 195:8

200:19 201:4

baseline 148:10

basic 68:11 135:5

152:12 173:6

174:20

basically 13:21

60:20 150:3 172:7

basis 100:11,16

131:9 198:21

201:10

batches 69:9

Battaglia 1:17 3:16

4:3 9:4,4 27:9

31:19,20,21 35:10

35:14,21 36:11,14

36:22 37:6,15

38:5,9 41:17

42:10,15 43:12

44:3 47:16 56:3

59:2,9,22 60:3,13

61:18 62:2,11,20

63:16 66:11 67:5

69:5 70:3,13

73:13,16 75:16

76:16 77:8,12,19

79:10,14,18,22

80:7,11,22 81:4

83:11 84:18 85:22

88:11 89:12 96:9

98:2,16 100:2

102:2,18 106:1

109:21 120:22

123:7,19 124:8,14

125:2,11 126:16

126:19 127:16

128:3,7,14 131:13

133:6 134:13

135:2 137:5,13

138:20 141:12

145:20 146:13

150:12,19,21

151:12 153:15

154:1,12 155:10

164:16 166:15,18
202-234-4433

Neal R. Gross & Co., Inc.

Page 205

167:7,16 168:16

171:20 172:2

174:3 176:18

177:9,16 180:19

195:14

bear 24:14 153:6

becoming 154:19

bed 56:14

began 178:1

behave 35:8

behavior 36:9

99:10 105:5,10,15

believe 36:2,22

39:17 40:12 42:2

42:17,18 44:4

53:1 59:9,11,14

60:13 65:14 66:11

66:20 74:12 75:22

85:22 100:16

108:21 109:22

129:19 141:11

162:18 172:9

175:6

believes 174:13

175:2

benefits 198:16

best 26:4,19 27:5

45:22 101:5,9

105:13

Betsy 1:15 8:22

65:11 183:6

better 6:8 16:10

21:3 24:20 26:13

119:12,14

beyond 120:4

148:22 149:5

180:5

big 17:7 19:3 24:8

25:22 139:20

bigger 18:9,10

biggest 24:9

binding 192:17

bit 16:10 18:2,5

20:4,18 22:4,13

22:16 61:6 117:8

124:10

blast 138:14

blend 56:10

block 52:8

blowers 32:7,8

blows 81:12

boards 158:17

bone-dry 33:19

36:5 75:4

bottom 15:20 16:8

19:18

bought 81:22

box 17:7 113:20

163:16 171:17

173:22

boys 24:8

break 10:8,10 11:4

120:20 134:22

138:16,18,21

139:6,10,11

Brenda 141:5

brief 9:17 10:2 12:5

briefly 164:1 198:5

bring 66:1,9

bringing 198:14

broader 7:4

Brookman 1:11,13

3:2,7 5:3,11 6:4,7

6:9,15 7:3,13,20

9:10 12:14 23:4,6

25:11,22 27:20

29:6 30:10,14

34:16 37:7 38:8

40:20 45:13 48:9

49:18 50:6 51:19

51:22 54:8,13

55:5,9 56:1 58:22

59:3 60:4 62:3

63:4,15 64:15

65:19 67:3 68:18

69:4,18 71:7

72:10,15,18 73:2

77:2,18 79:4

80:14 81:19 82:15

84:16 85:17 86:17

89:16 91:16,20

92:2,22 94:1,9,22

97:8 98:20 99:18

100:21 102:8

104:8,21 105:22

109:10,19 111:9

111:20 113:19

114:19 115:20

116:6,15 118:19

118:22 119:20

120:17 124:1

125:18 129:6

130:10 131:6,18

133:5,22 136:17

138:5,11,17 139:1

140:9 145:14

146:19 148:2,13

149:7,14 150:7,9

150:16,20 151:11

153:4 154:20

155:9 163:15

164:12 166:11

167:21 168:12

169:8 171:10,12

172:17 173:21

176:10,20 180:15

182:21 183:10

184:5 193:2,22

195:16 198:2

199:7,16 200:3

201:15 202:13

brought 149:18

Brown 1:17 3:10

7:2,6,7,16 24:1,1

25:13 37:8,8,14

37:22 38:7 40:22

40:22 42:7,11,21

43:21 44:7 47:11

47:13 49:13,14

52:20,20 53:4,9

53:13,16 54:12

55:2,2,12,19,22

62:4,4,14,22

63:14 65:20 67:2

80:15,15 81:2,8

82:2,6,13,17 83:4

83:14 84:2,9,15

109:11,11 110:4

116:18,19 118:21

124:2,9,19 125:4

125:14 126:10,18

126:21 127:3,9,12

127:17 128:6,10

128:16 129:7

131:20 149:8,8

183:11,11 185:15

186:4 187:12,20

188:4,12,14

191:16 192:3,13

192:22 198:6,7

199:10,19 200:2

Btu 156:3,9,13

181:13

building 5:9 139:13

139:14

built 131:15 158:16

bulb 162:2,8,12

163:8

burden 136:4

143:5 174:5 175:7

175:22 177:6,20

178:16,19 180:11

197:13

burdensome 174:6

174:14 175:19

176:7

burner 156:3,14

181:13

business 24:6 141:7

button 6:21

buzzer 154:7

C

cabinet-like 32:5

cafeteria 139:20

calculate 177:5

calculated 85:9

178:9

calculation 31:4

37:17 84:21

135:20 142:17

151:2,3

calculations 142:19

California 8:10

29:2 96:16 112:6

116:7 195:18

call 3:2 24:10 25:18

153:11

called 25:3

calling 126:6

Calwell 1:18 8:8,8

14:18 60:6,6 61:2

61:22 64:3 69:19

69:19 70:5,17

71:22 72:14 75:12

76:3,19 79:5,16

79:19 80:1,8,13

94:10,11,16 95:8

95:12,15 96:14

101:1 112:3,4

116:7 136:22

137:1,9,18 146:20

146:21 153:5,5,20

154:16 163:20,20

169:9,9 176:11,12

177:3,15,19

179:15 195:17

196:1

capability 146:3

147:21

capable 197:4

capacity 159:10,17

160:17 161:4,10

161:16

capturable 183:16

184:3

capture 41:19 44:4

52:18,21 66:12,14

86:1 88:12 89:1

99:10 102:4

105:20 119:14

129:12 153:21

171:6 184:2 189:3

captured 12:9

119:18 126:9

184:19

capturing 28:10

cards 141:7

care 19:8

carefully 138:1

carry 107:14 108:3

case 19:4 41:12

58:17,20 59:6,19

63:18 98:9 123:6

139:21 168:19
202-234-4433

Neal R. Gross & Co., Inc.

Page 206

187:10

cases 60:14,16

68:14 75:21 78:21

79:1,10 88:20

123:20 131:14

137:17 155:8

case-by-case 131:9

cause 12:16

ceases 154:9

CEF 33:20 58:10

58:15 63:19,20,22

67:19 103:22

104:3 165:15,18

165:21,22 166:3

166:22 181:5,17

185:1,10

cell 11:20

central 138:2

certain 46:15 47:3

119:14 142:8

143:14,17 162:10

175:22 180:21

certainly 42:17

45:17 70:13 119:4

123:20 131:14,16

154:13 173:18

certification

180:22 181:3

182:10 183:22

184:8 185:8,12,17

192:4 193:10,18

certified 179:7

190:13 192:6

certify 182:1

185:11 186:2

192:16,16 193:11

cetera 71:21,21

129:13

CFM 21:19,21,22

22:7

CFR 111:18 181:6

181:9

challenges 119:4

197:1

challenging 26:22

change 54:7 70:22

71:3,10 108:8,10

108:12 111:21

112:7 114:15

116:2 120:10

133:8 135:8,19

136:1,12 152:10

169:14 171:3

changed 53:18 54:1

57:22 84:2 116:4

194:19

changes 117:9

119:9 143:3 144:7

173:3 184:11

194:16 200:21

changing 47:19

71:10 119:5 120:2

120:6

character 15:8

characteristics

38:16,22 103:3,21

144:14

Charles 2:3 3:9

Charlie 8:11 13:6

23:6 34:17 35:1,3

50:7,9,10 68:17

68:18,19 87:11,12

91:16 99:18 113:7

114:2 145:14

147:8,17 148:13

154:20 179:8

193:5,6 194:11

195:21 196:18

Charlie's 52:3 64:7

115:4

chart 11:11

charted 11:10

check 59:10 73:14

chime 125:16

choice 24:11

169:17

choose 183:1

chose 196:13

chosen 56:22

121:16 170:21

Chris 1:18 8:8

14:17 59:4 60:4,6

63:17 64:15 69:18

69:19 75:13 79:4

79:5 94:9,10

99:19 100:21

104:14 112:2,3

114:14 116:6

136:21,22 146:19

146:20 153:4,5

163:19,20 169:8,9

176:10,11 195:16

Christopher 2:5

8:19

circulating 112:19

circulation 32:7

cited 196:14

clarification 43:7

54:16 55:8 66:5

68:21 69:20 72:17

82:14,18 124:3

130:12 133:4

134:20 135:11

151:14 155:11

161:20 168:5,14

clarifications 10:14

31:5 123:8 132:15

132:17 141:19

142:7 163:13

clarifies 55:20

clarify 47:13 53:17

55:22 65:10,21

81:9 83:15 120:1

125:5 128:11,19

132:7 134:10,17

136:14 149:20

152:6,19 156:11

158:18 159:3,21

165:6 183:1 188:5

191:17

clarifying 59:6

131:11

clarity 153:9

CLASP 2:5 8:20

class 58:6 103:17

classification 145:7

183:18 184:4

clause 63:21

clean 22:2

clear 44:1 47:22

52:3 90:4 94:21

134:8 155:6 168:1

190:4

clearly 77:21

196:15

Cleary 1:19 7:21

7:21 54:15 55:3,7

55:10,16,20 87:11

115:22,22 119:22

119:22 134:3,19

135:1 138:6

171:16 172:1,18

172:19 179:11

182:22

clicker 30:11

close 51:22 73:4

88:20,20,21 101:7

173:8 187:18

200:4

closely 103:13

closer 113:13

195:11,13

closes 202:8

closing 4:7 10:21

202:4

cloth 46:17,22 47:7

48:13 52:19 55:18

69:9,17 94:6

110:16 160:11

161:4,15

clothes 1:5 5:8 7:11

14:3,4,4,9 17:8

18:9,14 24:7 26:8

27:4 32:3 34:7

39:7 41:15 51:9

53:20 56:7,13

57:6 78:20 86:12

87:17 88:1,4 89:7

100:1 103:1,18

110:9 111:11,14

115:2 117:19

120:11 123:2

125:10 130:21

146:15 151:20

152:15 156:2

158:4 161:11

176:16,16 177:1,3

179:21 182:18

185:21 188:21

195:4 196:20

198:11 199:11

clothing 41:3 99:14

112:22 197:5,9

201:8

cloths 56:9 73:11

97:15 98:7 112:8

197:9

coffee 139:18

coincidence 170:20

colleagues 170:8

collect 5:22

collected 73:19

81:16

column 74:21

85:14 156:1

columns 60:7 73:10

combination 13:14

combinations 99:8

136:7

combined 31:4

151:1

come 53:21 90:3

100:13 118:7

133:21 190:13

196:21

comes 13:14 16:4

25:21 44:15 81:13

81:17,21 148:17

188:17

coming 23:13

54:22 63:1 72:2

148:6 171:18

180:11 202:6

comment 6:13

23:22 38:14 46:6

89:18 96:8 99:3

101:2 102:12

105:2 109:4

111:21 116:17

118:14 122:16

131:19 133:15

136:10 137:7,19

140:21 150:13

163:12,16,21

164:5 168:22
202-234-4433

Neal R. Gross & Co., Inc.

Page 207

171:17 172:15

173:22 176:9

179:1 198:4 202:8

commented 175:18

comments 3:9,10

3:12,19 4:5 6:11

6:12 10:2 12:8,21

23:2,13,16,19

25:12 27:21,22

29:1,7,21 30:2,4,7

38:13 45:18 72:11

83:1 91:21 95:11

102:13 113:20

114:20 116:16,22

117:17 118:16,20

131:17 132:13

134:1 139:3,7,9

150:17 151:10

163:18 164:2,13

171:14,17 172:21

173:18,19 174:1

180:16 193:3

194:1,8 195:15

200:4,13 201:12

201:13 202:8

commerce 184:10

186:3 192:21

commercialization

185:18 186:9,12

186:22

commercialize

186:15 188:1

commercialized

27:13 189:7,13,16

189:17

commercializing

188:17,19

committed 191:10

Committee 141:22

common 11:11

147:18

community 52:9

companies 24:15

45:2,2 83:22

company 24:5,16

44:19 45:3 80:21

186:11 188:19

190:5 192:7

compare 14:22

compared 58:11,19

60:10 68:15 75:18

142:8 164:22

165:22 166:9

169:7 175:3

comparing 35:15

compensate 71:5

competing 105:18

complain 18:6

complete 11:18

176:15 187:9

191:3

completed 129:3

190:11 192:20

completely 72:1

128:9 129:14

199:3

completion 57:7

60:21 122:6,19

124:5 127:18,19

174:12

complex 105:5

complexity 105:4

compliance 31:7,8

164:18 177:10

180:20 181:7,20

182:2,10,17

183:12 193:3,17

complies 168:9

comply 165:12

168:10

components 70:15

109:17 111:6

composed 34:12

56:8

composition 34:13

38:17 43:17 58:1

66:15 67:1 70:22

86:3

comprehensive

142:14

concept 45:21

concern 198:10

concerned 22:19

114:11,14 173:4

173:17

concerns 30:6

199:5 200:15

201:2,5

concise 12:4

concludes 166:6

176:6

conclusion 130:7

conclusions 35:7

196:7

condition 61:10

114:6 123:14

152:17

conditions 10:15

46:15 61:16 70:12

102:20 103:9

142:8 151:15

157:17 165:6

conduct 174:7

175:20 176:8

conducted 33:15

53:10 56:7,11

62:5 68:5,7 69:6

73:18 80:17

103:12 107:7

165:19 172:3

conductivity 39:2

103:10

conducts 83:19

confused 87:13

confusing 50:13

connect 149:11

connected 149:4

conservation 1:20

8:14 40:3 165:4

consider 71:10

107:3 113:12

119:8 123:22

132:16 142:4

consideration 11:9

64:20 69:8 133:3

154:13 195:15

considered 41:4

57:12,14 84:19

101:19 118:9

122:9 124:18

126:8 129:5

146:14 170:11

considering 83:3

169:5 172:12

consist 181:1

consistent 20:1

64:4 87:3 103:19

consistently 87:5

197:5

consisting 56:14

consists 43:5

console 157:16,19

158:19

consolidated 18:10

constituencies

117:5

constitute 124:13

constitutes 127:19

consultation 34:18

Consulting 1:17

2:2,2 9:5,9

consume 86:15

97:21 157:20

consumed 15:19

16:7 85:5

consumer 38:20

114:10 129:2,11

129:16 130:6

131:5 180:8,21

consumers 39:4

43:17 47:3 48:20

57:18 99:14

118:12 158:7

180:2 198:18

consumer-accept...

122:15

consuming 97:22

consumption 26:10

28:18,20 31:4

32:18 34:4 37:17

40:16 60:22 61:19

62:1 66:2 73:20

74:3,4,10,13,16

76:2 78:14 84:21

84:22 85:11,13,15

97:19 114:9,16

115:19 133:11,13

135:20 143:13,21

144:12,12 145:8

146:5 148:10

151:1,2,5 155:2

175:14,22 178:13

184:15 189:1

191:7 197:18

contact 112:17

160:1

contained 151:7

157:17

contains 144:10

151:3

content 19:16

53:19 54:6 109:18

113:2 143:8,19

144:5

CONTENTS 3:1

4:1

continue 23:17

40:9 49:8 89:6

102:17 109:5

110:11 120:5

124:20 132:4

CONTINUED 4:1

continues 128:20

continuous 105:7

control 33:4 109:16

110:17 127:15

151:22 152:7

158:13,17 159:3

controlled 108:5

controls 28:5,12

34:8 38:19 42:1

107:20 110:8

158:12 181:12

201:7

convened 1:10

convenient 170:20

conversation 12:20

140:22 153:7

188:9

conversations

11:21

cool 128:4

cool-down 39:13

57:8 74:8,22

76:13 78:10,16,18
202-234-4433

Neal R. Gross & Co., Inc.

Page 208

85:6 122:20 124:6

124:21,21 125:8,9

125:12 128:1,7,12

128:21,22 129:4

130:7 136:3,8

174:11

copy 141:8

corporation 1:18

7:8 24:12 117:3

correct 38:6 42:10

42:19 52:5 63:2

65:6 80:12 84:7

89:10 91:4 100:1

100:2,3,9 110:4

116:8 124:8

127:16 129:12,15

129:20 149:13

151:9 154:1

166:15 186:17

193:13

correcting 91:3,8

correction 88:6

150:22

corrections 10:14

31:3

correctly 97:14

149:10

correlate 67:19

correlating 49:3

correlation 67:18

104:3

correlations 106:6

correspond 40:16

corresponded

67:20

corresponding

182:18

cost 171:7

cost-effective

197:22

cotton 19:16,22

20:5,6,7,12,19

21:1 22:10,13

56:10,14 113:2

121:12

Council 1:16,21 2:4

8:14,16

Counsel 9:1

couple 177:13,16

course 47:14 118:1

179:4 186:8 189:9

194:10

courtesies 11:11

cover 10:22 22:20

30:17 31:22 32:3

137:16 174:4

coverage 201:20

covered 3:15 10:5

11:1 30:19 31:17

32:1 118:10 134:1

164:22

CPSC 198:20

create 65:22 66:2

110:19

creates 197:1

credit 147:20

crest 142:17 143:10

143:19 144:5

cue 13:4

curious 60:7 72:22

137:2 149:19

187:22

current 32:14,20

33:21 41:5,10

56:17 58:12 68:9

73:9,11 103:13

108:11 114:7

142:18,20 143:11

144:5 151:2,16

162:16 163:7

164:22 165:13,22

166:9 168:10

169:7 172:4,12

174:14 183:17

184:4 188:21

189:5,21 190:1

currently 32:16

33:6 37:19 45:5

48:12 54:4 66:8

77:1 83:19 99:22

117:11 118:5

122:14 124:4

135:5 146:16

152:1 161:19,22

166:8 183:16

184:8

curved 160:7

customer 16:17

cycle 3:15 10:7

15:19 30:21 32:14

32:19,21 34:11

36:19 37:17 38:12

39:12 56:19 57:1

57:2,8 59:8 60:22

61:4 65:15 73:22

74:3,7,13,19 75:9

77:22 78:2 79:7

84:21 85:1,14

87:19 90:8,14,21

91:14 121:2,9,11

121:14 122:2,5,7

122:20,22 123:6

123:10,16,18

124:6,11,13,16,22

125:1,8,13 126:3

126:4,5,8,10,12

126:14 127:18,20

128:8,12,20 129:1

129:3,4,11,17

130:6,16,20

131:16 132:4,7,8

133:1,14,18

135:18 136:16

151:18,20 152:13

152:15 153:2

154:6,7,9,14

155:7,14 157:22

158:14,16 159:1,7

159:8 163:13

165:7 174:10,13

175:1 178:11

181:17 201:8

cycles 17:14 29:4

194:19

cyclic 145:9

cyclical 155:3

cycling 75:4,7 78:9

79:1 88:22 90:4

97:18

D

D 32:15 151:22

152:20 155:21

156:11 157:18

159:9 165:5,10

172:4 181:10,15

182:11,15 183:17

184:4 185:21

188:22 189:21

192:15

Daken 1:20 8:5,5

59:5,18 60:2

64:17,17 77:3,3,9

77:16 79:12 93:2

93:2 122:18

123:15 150:1,2

154:2,3

damage 198:22

dare 21:22

data 13:15,18,19

14:7,16,22 15:1,6

15:10 16:2,4 22:5

23:1 36:1,6,8 37:2

39:15 40:12,14

46:1 50:14,18

51:6 52:6,14

57:16 59:10 64:7

64:22 65:2 69:1,3

71:18 72:9,14,15

73:8,14,19 74:1,9

75:6,21 76:17

80:16,17,17,19,20

81:9,11,12,16

82:20 84:11,12

85:8 89:4 90:12

90:12 91:6,11,17

91:19 92:1,4,7,10

92:12,12 94:12

95:3,5,5 102:12

104:6 107:1 109:6

109:14 113:8

117:17,18 122:13

133:10 134:5

147:16 167:17

170:10 173:20

191:22 193:3

195:2,8,12,15,19

196:4,6,10,15,20

database 146:22

dataset 116:9 147:9

date 97:1,5 181:20

182:2,20 183:2

187:15,15 195:20

daunting 196:3

day 50:4 177:4,5

days 177:2 182:6

de 173:1

deal 146:1 199:22

200:14,21

decades 178:2

decide 155:5 168:6

decided 41:9 142:3

decision 150:4

deck 68:22

declare 185:14

decrease 58:13,15

58:20,21 71:16,17

166:2,20,22 167:4

167:11 169:12

decreased 71:12

default 152:17

153:12,17

Defense 2:4 8:16

define 108:2

defined 32:4 43:19

46:13 47:17 48:5

49:9 63:2 107:13

123:16,17 145:19

148:19 154:15

defines 154:6

defining 52:11

definitely 71:20

definition 43:4,13

44:2 45:20 46:6

47:22 49:7 52:15

112:11,20 127:22

145:16 148:18

definitions 32:11

48:2 107:10,11

141:20

definitive 104:3

106:5

definitively 86:19

degree 162:21

degrees 162:11,19
202-234-4433

Neal R. Gross & Co., Inc.

Page 209

163:6

delay 197:11

deliver 26:9,13

65:22 66:4 183:15

184:3

demand-control

146:4

demographics 14:2

demonstrate

111:13

denominator

197:17

deny 141:1 185:6

Department 1:3

5:6 9:3 12:7 24:4

27:10 43:1,5

44:10,14,22 66:6

72:12 80:20 81:13

81:14 82:8 83:12

83:19 84:12 86:19

102:14 110:18

117:21 118:3,11

118:20 163:17

183:13 185:5

186:19 188:18

198:10,13,16,17

199:14,17

Department's

201:2

depending 88:1

154:5 159:16

169:16 187:11

depends 131:4

177:9

derived 100:7

102:13

described 47:16

69:1 101:6 147:8

description 10:5

designation 121:19

designed 32:5

34:11 48:19 66:22

86:2 88:13 99:12

101:15 118:11

designing 47:2 87:5

186:21

detail 173:18

detailed 144:10

determination

96:12 109:22

201:2

determinations

46:2 173:2

determine 32:18

57:10 76:5,14

104:2 106:5

115:12 123:5

145:12 164:20

178:16 180:8

184:14 185:10

determined 34:1

41:2 142:5,22

159:12 162:17

determines 165:1

determining 49:10

101:8 142:19

185:1

develop 146:17

developed 24:7

113:5 179:16

developing 44:6

102:16

differed 196:16

difference 19:11

45:8,12 60:19

61:9,11,13 66:12

66:20 69:10 85:10

86:8 89:1,20

101:12,18 106:9

169:18 172:8

differences 41:19

42:17 44:4,16

66:14,16 85:3

86:1 94:6 102:4

123:22 194:14

different 15:17

20:10 22:18 35:8

38:18 43:15 48:8

49:5 62:12 64:14

68:2 69:8 74:3

78:14 81:7 82:20

83:22 86:5 89:3

92:16 93:7,15,16

95:22 99:21

103:21 104:4

108:18 110:1,3

111:16 123:20

127:6 134:18,18

136:7 144:13,15

163:17 164:4

189:14,19

differentiate 126:7

differentiated

55:15

differently 88:16

93:11

difficult 61:6

116:10 117:8

120:12,14 146:17

difficulty 71:2

140:14

dimensional

112:12,16

dimensionality

93:17

dimensions 112:11

diminishing 114:12

Dimples 2:5 7:15

direct 144:16

direction 88:7 91:5

directly 107:16

110:13 112:19

158:16

disagree 92:15

95:10

disagreement

45:18

disconnected

157:21 159:7

discretion 190:18

192:12

discuss 26:14

150:21

discussed 133:8

165:8 194:15

discusses 134:16

discussing 32:2

discussion 22:21

30:18 47:15

131:10 132:13

149:12

displayed 163:10

distinguish 32:22

37:10

distributed 141:6

184:10

distribution 15:9

186:3 192:20

diverging 28:20

diverse 179:7

diversity 112:22

DOE 1:14,15,15

3:5,14 4:8 5:22

8:22 9:7 15:3,11

16:1,3,9,12 17:5

17:12 18:3,18,21

19:2,21 20:10

22:4,11 26:18

28:3,7,14 30:6

32:10,14,20 33:11

33:14,18,22 34:6

34:14 35:5,6 37:9

37:11 38:10,14

39:5,7,10,14,19

40:1,1,4,8,9 41:2

41:9,12,13,21

42:3,9 43:13,14

44:11 45:14 46:10

46:13,13,13,14,17

46:21 47:5,7 48:1

48:13 49:5,9,15

49:20 50:20 51:11

51:13 52:16,19

54:3,5 55:15,18

56:6,7,8,11,16,20

57:11,20 58:8,12

58:19 60:10 61:13

62:6,7,7,11 63:21

64:2 65:11 66:13

66:18,21 67:5,8

67:22 68:3,4,7,9,9

68:10,16 69:1,2,5

69:12 71:18 72:22

73:8,9 80:22 81:2

81:21 82:8,11

83:2,6,9,16,17

84:19 85:2,9 86:4

86:4,9,11 87:2

88:15 91:10 92:1

92:13 93:8,9 94:3

97:15,15 98:1,7

100:11,12,12

101:12 102:18

103:12,19 104:2,4

104:10,12,19

106:1,4,7,8,12,18

106:22 107:3,10

107:18 108:1

109:5,8 110:15,20

111:3,10 112:7,8

113:11 114:8

115:17 117:1,10

118:10 119:7,18

121:2,6 122:1

123:9 125:20

130:1 132:11

133:7,14 135:4,10

135:18 141:15

142:3,5,11,13,22

143:14,16,22

144:19 145:2,17

145:22 146:11,22

148:5 151:9,12

152:5,9,14,19

153:13 154:6

155:10 156:6,10

157:2,6,10,12

158:1,10,18 159:2

159:19 160:22

161:2,14 162:6,9

162:16 163:3

164:6,19 165:1,3

165:5,8,16,19

166:5 168:5 170:7

172:3,9,11 174:13

174:19 175:1,5,17

176:1,5,15 177:11

180:3,12,20 181:4

181:6,8,15,20

182:12 183:7

184:1,7 185:19

186:18 188:5

189:8,11,20 190:8

190:11,14 191:13

191:17,19 193:18
202-234-4433

Neal R. Gross & Co., Inc.

Page 210

194:16 195:9,20

196:9,14,21 199:4

DOE's 18:13 26:11

28:9 32:4 41:5

69:3 94:6 108:8

109:13,22 111:21

129:9 132:6,11,12

144:18 172:22

173:4,10 182:17

183:17 184:3

185:16 196:10,16

doing 14:13 73:3

114:14 123:16

130:22 138:1

149:2,2 180:13,14

197:5

Dollar 198:21

dollars 197:22

dominant 137:21

door 132:5 135:17

159:13,22 160:1,5

160:8

dots 19:19

double 17:11 18:21

90:17 91:1

Doug 1:11,13 3:2,7

5:11

draft 141:21,22

draw 196:7

drawing 35:7

dried 20:8 39:20

40:5 41:4,21

60:12 197:14

dries 105:21

driven 32:8

drowning 169:22

drum 32:6,8

159:10,11,18

160:1,6,7,17

161:10,16

dry 17:4,19,20

20:15 21:4,15

22:15 32:6 59:21

74:13 86:2,12

88:13 105:6

112:21 113:14

125:10 126:19

133:14 162:1,7,12

163:8 179:21

196:11 201:8

dryer 7:11 8:21

14:4,5,12,12,15

17:15,19 18:17

21:10,18 22:1

24:7 25:16,19,20

26:8 27:4,9 36:9

37:19 38:4 39:7

43:10 51:8,10

52:22 53:2,5,11

56:13 57:6 60:21

62:9,16,17,18

68:8 72:2 74:22

75:21 78:14,16

81:12,14 83:8

86:2 88:1 91:8,14

97:14,21 98:4,14

102:4 103:6 105:5

105:14 107:20,22

109:18 110:10

111:7,11 112:20

114:7 115:2 117:7

117:9,19 118:4,9

122:5 123:16,17

124:5,10,20 125:7

126:20,22 127:14

127:17,20 128:1,4

128:9,11 129:10

129:14 130:20

131:2 132:1,5,22

135:11,14 136:14

147:9 149:2 150:6

151:20 152:3,6,15

154:9 156:2,7,12

156:18 157:21

158:6 161:11

168:8 174:12,17

176:17 177:3,20

178:9 181:11

183:15,19,22

184:2 185:10,21

188:7,21 189:2,7

190:1 191:5,7

192:4,5 197:6

198:19 199:1,4,5

199:11,12,13

dryers 1:5 5:8

21:17 24:13,20

25:6,7,9,18 26:1

26:15,19 27:16

32:4 33:5,7,17

34:5,7 35:8 37:18

39:18 40:4,11

47:2 48:19 51:2

53:15,20 56:7

62:12 63:2,11

66:7,22 68:14

76:4,11,13 77:21

78:7,12,20 79:7

84:4,6 86:14

88:13 91:7 93:4

95:6,22 96:18

100:1 101:9,21

102:7 103:1,18

106:13 107:11,12

107:13,13 108:1,2

108:15 109:16

110:1,3,9,13

111:14 112:15

114:4 117:10

118:7 121:4,5,5

121:10 122:14,21

125:12 132:1

133:10 135:4

136:1 137:4,4,14

137:16,20 146:15

147:2,20 148:6,7

149:3 158:4,11,17

165:20 166:7

169:14 170:4,6

178:3 179:18

180:9,22 181:14

182:18 184:9,9

190:19,20 192:2

198:11

dryer's 189:3

drying 15:9,11,20

17:11 42:3,5

43:18 46:15 60:19

61:20 66:17 75:2

85:2,5 86:3 88:17

88:19 90:1,14

102:5 121:12,13

126:5 128:20

158:8,22 159:1

164:10 197:8

dryness 21:13

48:21 56:22 57:4

57:15 59:12 88:9

121:16,19 122:11

123:12 133:18

155:15 158:15

159:5

due 149:22 164:3

duration 145:3,12

D.C 1:11 5:10

D1 32:15 106:10

135:6 152:10,20

155:12,21 156:11

157:18 159:10

165:16 172:6

181:10 182:11,15

183:2,18 184:4

185:21 188:22

189:21 192:15

E

earlier 54:17

102:12 114:3

115:5 121:7

125:22 133:11

153:7 166:19

179:8 191:10

early 11:3 193:16

easier 20:15

easy 19:8

Eckman 1:20 8:13

8:13 104:8,9

113:22 114:1,1

166:11,12,16

167:1,10,18

Economy 1:16

Ecova 1:18 8:9

14:17

edge 159:22 160:7

Edition 4:3 10:12

103:1 141:17,22

142:2,4,6,9,11,12

143:3,7 144:8,10

144:21 150:14

172:5,6 175:13,16

effect 27:14 37:22

38:2 76:4 120:16

171:7 178:5 180:4

186:11

effective 116:14

182:5

effectively 45:4

102:5 184:1

188:22

effectiveness 28:4

28:11 39:9 77:1

96:22 97:5 107:8

effects 10:16 31:6

33:12 38:11,21

164:17 171:5

efficiencies 66:10

efficiency 2:3 3:9

8:12 25:9 28:6

40:17 60:10 61:9

62:1 64:8 67:21

101:12 115:18

118:1 164:11,21

165:3,10 166:9

172:11 182:9

183:16 189:3,22

198:12,15 199:12

199:18 200:19

efficient 8:21

117:20 147:2,9

201:20

effort 149:3 178:1

eight-nine 196:2

either 32:10 34:9

62:18 73:10

107:16 113:3

165:21 182:10

185:6

elapsed 79:20

elect 191:22 192:10

electric 24:19 25:2

25:4 32:3,9 52:22

53:5,19 62:17

77:20 81:12

117:19 118:4,9

147:2 199:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 211

electricity 32:10

Electrolux 24:13

electronic 158:12

elementary 94:20

elements 25:2

elevator 139:19

eliminate 199:3

email 147:11

emerged 11:11

emphasis 137:22

emphasize 64:4

employ 126:1

employed 128:15

138:3 166:14

enacted 45:1

encourage 119:7

164:6 183:9

186:18 201:22

encouraged 104:16

ends 139:15 155:7

end-of-cycle 123:4

131:22

energies 169:6

energy 1:3 2:3 3:9

8:12 9:3 14:3

15:19 16:7 17:13

18:17,20 22:15

24:4 25:8 26:9

27:11 28:18 31:4

32:17 34:4 37:17

40:2,16 41:16

43:1 44:11,14,22

49:11 50:21 58:11

60:22 61:19,22

64:8,22 65:14

66:2,4,6,9 73:20

74:2,4,10,13,16

76:1,12 78:14

81:13,15 83:9,12

84:12,21,22 85:4

85:11,13,15 86:12

86:15 87:17,21

88:3,8,9,10 89:9

89:10 90:22 91:4

91:13 97:19,22

98:15 99:7,22

100:5 101:6,7

104:11 110:18

114:8,16 115:18

117:20,22 118:1,3

118:6,11 119:15

133:11,13 135:20

143:13,20 147:15

147:19,22 148:8

149:19,21 150:5

151:1,1,5 153:22

155:2,3 164:10

165:4 173:3 178:3

178:6,10,16,22

179:4,19 180:4,10

182:9 183:13,15

184:2,15,17

188:18 189:1,3,22

193:10,15 197:18

197:21 198:12,15

199:12,14,18

Energy's 5:7 43:6

80:20 81:14 82:8

198:10

energy-efficient

1:16 118:13

energy-savings

119:10

enforce 180:20

engage 27:2

enormous 20:13

60:19

entering 114:7

entirely 195:12

EPA 1:20 8:6 148:5

148:20

EPCA 10:17 31:8

173:1 174:4,5

180:19 182:5

equate 162:16

equates 157:1

equation 49:10

equipment 13:22

104:16 109:14,15

176:3

equipped 152:2

156:18 158:5,11

equivalent 163:7

error 160:14,20

161:7,18 162:3,11

162:13 163:5,9

especially 173:14

197:8

essence 116:8

essentially 19:18

56:17 57:20 86:10

135:4 137:10

establish 41:14

established 41:12

180:21

establishing 48:4

110:21

estimate 137:3

177:7

estimated 73:21

estimates 174:16

et 71:21,21 129:13

evaluate 6:2 54:10

56:4 68:5 69:6

81:6 144:11 185:6

evaluated 106:2

186:13,14

evaluating 117:11

202:10

evaluation 144:18

185:17 202:1

evaporate 72:3,5

eventually 6:2

everybody 31:20

34:19 157:11

everybody's 68:21

exact 137:6,7

166:20 167:8

exactly 15:15 50:1

59:15 75:15 97:16

154:14 156:22

example 160:5

193:9

examples 123:21

131:14 132:20

excuse 14:5 16:20

executive 26:17

exercise 148:12

exhaust 22:2 38:4

exist 111:1

existing 48:19

110:9 120:6 158:4

184:16 196:11

exists 117:12

expect 30:17 65:8

66:22 87:4 150:4

expedite 190:5

expeditiously 11:8

experience 130:19

explain 13:11

explanation 13:10

93:12

explanations 16:22

exploration 115:2

express 30:5

162:10,13

expressed 163:6

172:21

extended 74:21

75:2 78:15 79:2

153:8

extent 71:14 92:15

95:9 132:19

147:19

extra 99:16

extraordinarily

101:9

F

fabric 17:10 19:17

20:4,5

fabrics 32:6

facilitating 5:13

Facilitator 1:12,13

3:3,8

facilities 190:17

192:10

facility 81:3 82:21

82:22 192:11

fact 25:15 64:1

86:15 189:21

factor 28:14,17

32:17 33:6,8

37:16,21 38:1

49:11 66:4 84:20

85:9,21 93:20

94:5 99:9 100:7

102:7 104:13

133:8,20 134:6,11

136:1,13 142:17

142:17 143:10,19

144:5 166:13

167:6,15 168:2,7

170:21

factors 42:19 94:7

113:15

Fahrenheit 162:5

162:11,19,21

163:6

fail 167:14 168:3

failed 167:5

fair 26:7 71:9 72:1

94:4 96:7 177:21

190:9

fairly 12:5 20:1,9

61:5 154:18 155:6

164:1 168:1

169:14

fairly-remarkable

76:20

familiar 27:8

139:12

far 20:19 41:8

110:18 130:4

Farber 1:21 8:7,7

149:16,16 150:8

farther 64:12

feature 10:7 122:22

126:15 147:7,13

147:18 154:18

features 63:10

February 1:8 5:8

Federal 9:16 29:18

63:7 69:22 96:4,8

196:8

feedback 12:16

138:10,14 157:14

feel 92:16 168:21

186:20 187:19

190:22 191:6

fewer 195:5

field 13:15 14:22

15:10,14 16:4

20:17 21:4 22:6

28:13,16,17,20
202-234-4433

Neal R. Gross & Co., Inc.

Page 212

42:6,18 44:5 51:9

51:15 53:8,15

61:14,16 64:7

65:1,8 66:19

86:14 87:1,6,9

88:10 89:5 93:7

93:14,20 94:8,12

94:18 95:3,5

97:20 98:13 110:6

111:2 114:3,18

119:13,16 133:19

178:13 194:22

195:8 196:10,20

197:13

field-adjusted

85:15

field-adjusting

89:8,9

field-adjustment

166:13 167:6

field-use 32:17

33:6,7 37:16,21

38:1 84:20 85:9

85:21 93:20 94:5

100:7 102:7

104:13 133:8

134:6,11 136:1,13

168:2,6

field-use-adjust...

167:14

figure 136:4

fill 160:4 202:2

filled 159:11

161:11

final 30:7 33:9,22

34:6 38:19 39:13

40:13 57:10,10

59:20 67:7,8,11

67:14,18,20 74:18

75:11,22 85:14

90:6 95:21 97:2

106:2,4,6 116:9

131:19 132:18

133:17 134:1

135:8,21 136:9

141:15 142:3

158:3 161:20

171:13 181:5

182:6 193:2 194:1

194:4,8 198:4

200:3

finalize 116:12

finally 39:2 182:16

find 12:20 43:7

134:20,21 147:17

finding 76:20

finished 126:3,4

fires 198:19 199:3

199:13

first 9:18 13:3,6

15:7 16:16 19:20

29:15 31:22 35:2

51:20 59:4,13

97:17 98:8 109:3

141:17 142:8

143:2 147:3

151:18,19 157:15

160:10 172:5,22

174:5 175:15

186:1 187:17

189:9 190:10

191:2 194:6,14

fit 140:21

five 138:17

fixed 23:12

flip 11:10

floor 139:19,22

focus 11:19

folded 19:4

folks 17:22 34:18

170:10

follow 52:2 79:6

followed 75:15

76:10 189:9

following 9:19 10:4

10:10,16 135:7

forced-air 32:7

foregoing 140:6

forgive 77:16 93:3

form 15:18 33:3

108:6 137:11

185:13 202:1

formerly 25:3

forms 15:17

Forrestal 5:9 12:17

139:13

forth 93:18 170:16

forum 27:17

forward 31:13

115:13 200:12

201:12 202:10

found 61:3 86:9

101:12

four 13:16

Fourth 103:1

fraction 137:3

free 92:16 154:14

168:22

front 95:3

FTC 100:13

full 39:12 48:16

74:11 174:10

191:3

fully 158:12

function 158:8,22

functionality

149:11

functions 158:16

further 28:19

38:11 61:12 115:2

future 27:17 107:4

116:5 120:7

G

gain 125:5

garbled 23:10

gas 25:6,7,9 32:3

32:10 52:22 53:5

53:20 62:17 78:20

118:4 155:19

156:1,7,17,18

157:2,3 181:14

GC 65:12

general 8:22 31:6

61:3 141:2 175:18

generally 28:9 29:1

113:1

generation 158:4

158:11

generous 61:9

germane 199:8

getting 26:1 44:22

65:16 79:9 107:5

110:9 141:13

186:1 189:14,15

189:16

giant 24:15

giants 24:16

give 15:7 22:22

43:6 48:20 64:21

65:2 187:15

given 22:14 94:12

114:2 146:1,5

167:2

gives 21:3 96:4

glad 12:11 179:14

go 17:15 23:2 29:9

29:12 31:11 35:2

37:1 45:9 50:4,8

56:2 59:10 60:5

73:13 96:17 100:6

104:9,21 109:19

109:19 120:16

121:8 134:17

139:19,20 155:1

184:21 185:4

188:10,16 191:1

194:4 198:13

goals 115:17

goes 15:15 104:19

154:7 155:4

going 5:14 9:17,20

10:4 11:5,6,7 13:5

13:6,12 15:5,8,14

16:13,15 19:15,18

19:20 24:10 26:20

31:11 45:1 46:11

48:3,8 49:6,13,14

49:16,22 51:17

63:5 66:15,19

67:4 70:14 86:22

88:15,20 89:2,6

97:9 98:9 102:9

110:21 115:11,12

117:14,18 118:6

118:17 120:17,19

127:1,3 131:9

141:3,9 146:8

148:11 167:18

171:18 187:14,15

188:9 191:12

good 5:4,17 7:2,6

12:7 13:9 21:2

29:11 35:22 59:1

65:9 102:15 104:6

170:15 171:12

gosh 177:4

Gotcha 92:22

gotten 11:22 76:6

178:22 192:19

grandfathering

173:15

graph 15:18 77:20

78:1 79:17,21

89:22

graphic 68:22 69:3

graphics 113:7

graphs 15:16 78:6

87:15 125:22

grasp 92:21

GRAUL 12:13

greater 17:13,15

74:12,15 160:14

160:20 162:4

175:14

green 6:20 15:22

16:2

grid 147:21

grossly 111:7

ground 139:19,22

guess 47:11 53:16

64:19 86:7 92:6

93:19 99:20

101:22 120:10

122:21 138:11

164:5 168:13,19

169:19 172:20

178:14

guidance 181:21

183:3

guide 99:22 100:5

H

habit 12:1

half 21:11,11 97:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 213

108:22 160:20

177:5

hall 139:16

hand 12:19 140:21

handful 164:8

hands 136:18

hang 120:20

happen 166:16

happening 18:11

48:14 77:22

131:15

happens 44:5 164:9

170:4 197:16

happy 7:11 17:1

180:3 191:9

hard 103:11 187:5

harder 64:11 72:4

112:20,21 117:14

hardness 39:1

103:10

harmonic 143:8,18

144:4

hate 104:9

hear 13:5 23:12

50:6 51:17 55:12

59:4 73:5 93:19

131:7

hearing 87:14

140:15 172:21

heat 25:2,16,19,20

32:9 53:2,7,11,15

75:1 97:18 135:17

heated 75:2

heater 75:4,11 78:9

78:22 90:3

heaters 157:3

heating 24:14 25:1

99:17 128:22

136:8 157:3

heavier 17:9

heavy 17:9 20:20

heights 169:20

help 44:8 45:5

118:16

helps 34:21

heroic 64:11

Hey 6:4 72:18

Hi 31:20 200:7

high 198:21

higher 18:3 22:4,13

22:14,16 34:13

40:15,17 57:13

58:11 61:19,22

67:15,20,20 68:15

75:10,22 76:1

86:16 93:17 113:1

161:4,12 165:21

197:19

highest 21:20 57:3

57:15 59:12

122:10

highlighted 194:13

highly 109:17

highly-energy-eff...

7:10

historically 187:13

history 3:13 9:22

29:14 31:10,12,14

48:16

hold 21:8 97:1

Home 1:19,22 7:22

8:3

homes 113:18

honest 117:11

171:2,8

hope 6:2 120:18

141:8

hopefully 23:11

horizontal 112:10

hourly 156:3

181:13

hours 15:20 18:17

18:19,21 177:13

177:17,18

house 147:10

household 14:2

52:7,8

households 13:15

13:17,21 50:15,19

50:22 51:9

houses 21:18

humidities 70:2

71:6

humidity 70:7

71:15 161:21

162:3,7,9,10,14

162:19 163:2,5,9

163:11,14,22

hybrid 24:19 25:4

81:11 117:18

118:8 199:3

Hydromatic 1:17

2:5 3:11 7:8,16

24:5 109:12

116:19 117:4

149:9 198:8

hydronic 25:3,4

I

ICF 1:23 9:8

idea 15:8 21:3

41:18 42:2 44:4

51:4 66:12 86:1

88:11,12 89:1

98:17

identical 14:20

IEC 4:3 10:11 19:8

20:3,6 22:10 31:1

36:12 56:12 69:2

102:22 103:1,8

104:5 106:7,10,21

107:1 109:8

141:17 142:2

144:22 175:16

IEC/AHAM 35:11

36:1 57:20 58:16

58:18 60:8 63:18

64:1 67:9,16

68:11 69:13 73:12

104:1 106:17

ignorance 77:17

ignoring 173:5

illuminate 158:6

illuminated 6:21

imagine 197:3

immediately 6:18

9:19 101:4

impact 72:9 166:8

173:2

impacted 71:12

implemented 77:1

88:2

importance 119:11

137:22 202:7

important 10:3

27:15 29:20 70:19

188:15 196:17

importer 192:9

impression 37:5

improve 114:13

improved 178:7

improvement

106:14

inches 155:22

include 29:3 39:8

39:11 106:20

107:10 108:5

128:4 130:8 136:3

145:17 152:10

157:6 181:6,19

included 56:18

123:3 130:17

141:19

includes 126:5

129:3 133:17

145:16 191:4

including 39:12

57:8 74:8 85:6

122:20 124:6

134:6 174:11

182:9

inconsistent 111:7

incorporate 142:12

146:12 149:21

150:15

incorporated

130:13 132:22

141:16

incorporating 4:2

10:11

incorporation

30:22

incorrect 151:3

incorrectly 151:6,8

increase 69:15

161:14 166:3

167:3,4,12,13

169:4,13 197:12

increased 71:1

175:21

increases 64:7

indefinitely 130:22

132:4 153:21

155:4

Independence 1:11

independent 73:18

independently 57:1

121:14,17

indicated 129:2

indicates 129:10,16

indication 181:11

indicator 130:5

158:13

indicators 158:13

159:3

indirectly 107:16

individually 143:16

169:16

individuals 140:16

141:6

industry 143:17

178:20 180:7

inefficient 61:5

infer 34:9 134:9

inferior 81:10

117:12

influence 103:5

information 6:1,1

9:14 38:10,13

42:22 44:13 46:1

62:21,22 67:22

130:5 158:8,22

informed 188:5

189:8

inherently 66:1,9

initial 29:3

initially 74:5,6,14

74:17 78:3,5

85:12 99:6

Initiative 8:21

inlet 155:22 156:10

input 138:7 175:11

inquiries 151:13

157:10

inquiry 152:14
202-234-4433

Neal R. Gross & Co., Inc.

Page 214

156:6 159:19

160:22

insignificant 169:5

installation 157:17

instance 84:5 195:7

instances 110:17

instantaneous

73:21

instrument 144:2

instruments 142:13

143:6,15,18

integrated 143:12

143:20 158:12

intend 11:3

intended 99:10

158:3

intending 116:3

129:16

intends 146:11

intent 105:3,13

intention 64:21

129:9

intentionally 112:9

interact 93:10

interaction 154:22

interest 30:5 31:13

interested 29:22

30:22 115:7

175:12,17 177:22

interesting 19:13

147:13 169:10

170:3

interior 112:16

159:18 160:6

intermittent

129:20 130:9

intermittently

135:12 136:15

International 1:23

internationally-a...

142:6

intersection 159:13

159:21

intervals 14:5,6

interviews 17:22

introduce 9:11

70:9,16 136:6

introduced 181:4

introduction 3:13

9:21

introductions 3:6

6:16

invalid 57:14 122:9

investigate 38:11

40:18 118:3

investigated 102:19

165:16

investigating

198:14

Investor-Owned

8:10

invitation 198:3

involve 144:8

involved 120:9

in-field 115:10

IOUs 29:2

issue 28:4 38:14

90:10 140:5 176:9

197:10 198:18

issued 43:1 95:21

157:12 181:21

issues 10:2,22

28:22 29:3 30:17

32:13 38:15 40:13

115:3,6,9 136:6

194:8 200:11,16

Item 136:18,19

139:3,5

items 112:15

163:17

J

James 1:17 3:16

4:3 9:4 27:9

31:19,21 49:21

50:8 51:19 54:8

55:6 56:2,2 63:15

67:3 69:1 72:13

75:12 77:18 83:11

84:16 97:9 101:5

102:17 105:22

109:20 114:21

116:16 120:21

141:10 150:11

January 29:18

33:10 141:16

142:3 165:14

172:13 181:5

182:20

jeans 52:12

Jen 114:21 200:6

Jennifer 1:16,19

7:21 54:13 114:22

115:21,22 119:21

119:22 134:2

138:5 171:15

172:17,18 182:21

200:7

Jessica 1:23 9:8

Joanna 2:1 3:12

8:17 28:1,2 85:17

85:18 97:11 119:1

119:2 120:1 168:4

169:1

job 72:2 102:15

105:13

join 29:1

joining 12:11 23:8

140:11,20

joint 28:7 39:6,22

49:2 55:17 57:17

104:10 122:13

200:17

Judith 2:2 83:11

98:20,22 99:1

104:21 111:9

128:18 129:8

131:6 176:20,21

Judith's 101:2

Judy 176:18 188:6

Julia 1:21 8:7

149:15,16

justifications 195:6

justified 178:20

K

keep 5:20 11:5,19

67:3 87:13 97:9

120:18 123:1,2

130:21

kept 14:13 87:19

88:19

kilowatt 15:20

18:17,19,20

kind 14:15 15:3

19:13 37:4 93:4

98:12 146:11

155:3 186:5

know 11:16 14:2

17:19 24:18 29:17

30:21 43:12,18

45:21 47:12 48:10

48:18 52:8 60:18

61:5 64:11 66:17

70:18 83:2 96:14

105:2,15 115:4

126:2 129:12

130:4,19 131:16

133:1,20 138:9

139:1,1 147:14,22

154:5 155:2

157:11 169:11

170:4,5 173:6

178:1 179:3,18,20

184:20 187:1,2,6

197:17

knowing 44:18

knowledge 95:6

known 25:4 117:2

Kohl 1:15 8:22,22

45:9 65:10,11

183:6,6

L

lab 14:19,22 21:1

22:8 51:11 53:7

61:4 64:5,6 69:6,8

73:19 85:8 89:5

94:19 106:14

110:6 147:6

190:18

label 99:22 100:5,6

laboratories 82:1,3

82:5,7,12 83:20

84:11,13 110:5

laboratory 27:11

81:15 82:9,11

83:6,10,16,17

84:4 101:13

110:14 111:2

190:19

labs 69:11 81:5,7

lab-to 69:7

lab-to-lab 69:14

73:8 106:3,13,16

109:7

larger 17:4 18:14

18:15 178:19

195:3,4

Laughter 131:12

167:20 170:2

laundry 13:22

50:16 147:12

law 51:13 171:9

173:14

lay 51:19 54:8

191:9

lead 133:2

lead-in 173:13

leave 27:5

leaves 197:6

left 6:18 15:12,19

16:1,8 19:2,16

73:10 141:10

legal 100:17 183:9

legally 192:16

legislative 29:14

length 151:21

190:2

less-efficient 65:4

less-representative

180:12

letting 60:21

let's 5:3 12:2,8

31:13 34:16,18

50:6 51:19 54:8,9

55:6 59:3 76:8

95:18 102:14,17

133:5,6 139:10

140:9 149:14

153:11 177:4

level 21:13 47:3,6

56:22 57:3,4,5,15

88:8 96:20 105:9

105:21 110:10
202-234-4433

Neal R. Gross & Co., Inc.

Page 215

111:4 121:16,18

121:20 122:11

133:19 159:12

169:21 183:15

200:20

levels 43:11 47:8

57:17 71:16,20

117:21

Leybourn 1:22 8:2

8:2

life 92:20

lighting 157:16,20

158:20

lights 157:19 158:5

158:14,19,20,21

limit 11:21 40:10

line 15:12

linen 121:12

line-by-line 31:12

lint 199:3

list 141:6 181:17

listed 10:6 38:15

75:17 77:5,13

103:9 124:15

135:7 155:18

159:4 181:18

listen 27:1

listening 101:1

literal 171:8

little 6:20 16:10

18:2,5,12 20:4,4

20:18 21:20 22:13

46:4 87:13 108:22

117:8 124:9 134:4

153:7 154:17

178:15

LLC 1:21

load 14:10 15:3,4,5

15:11 16:1,4,8,10

16:11,12 17:6,12

17:13,18 18:12,13

19:2,9,9,10,16,21

19:22 20:3,6,12

20:22 21:4,7,13

22:10,11,13 26:10

26:11,12,12 29:3

33:19 34:9,14

35:7,9,11,18 36:2

36:12 39:1,14,19

39:20 40:5 41:22

42:3,8,9,14 43:2,3

43:5,8,10,14,16

43:19,20 44:1,2

44:12,12,13,16,18

44:18,20 45:20

46:5,13,14,14,17

46:21 47:6,9,15

47:16,18 48:1,3,5

49:6,8 50:14

51:11 52:11,16,19

53:22 54:21 56:8

56:12,14 57:9,12

57:20 58:2,9,17

58:18,19 60:8,10

61:7 63:19 64:1,2

64:6,14 66:13,18

67:8,10,16 68:2

68:11,16 69:2,2

69:12,13 71:1

73:12 74:5,14,16

75:7,10 78:5,7,21

85:2,5,11 86:4,5,6

86:9,11 87:2,2

88:15 91:9,9,10

93:8,9 102:21

103:4 104:2

106:17 107:17

108:7,9,20 109:1

109:5 112:7 113:4

113:6 114:15

115:3 116:3 119:3

119:5,9,12,18,19

120:3,6,7,11

133:14 135:15

179:7,9 180:7

196:12

loaded 20:8

loading 159:13

loads 16:17 17:17

18:2,4,10,10,15

19:1,5,12 20:16

22:16 34:11,13

35:6 36:20 38:16

41:11,20 45:4

47:4,20 49:5

50:18 51:1 52:7

53:22 66:14 67:1

68:1 85:3 86:2

88:13 89:3 93:7

93:15 109:9

110:15,16 113:4

113:11 119:13

121:12 144:13

146:8 195:4,5

197:14

located 38:3

location 37:12 38:2

log 14:13

logs 147:9

long 13:10 91:14

120:12 176:15

179:21 185:19

longer 84:3 89:7

119:6

longer-term 119:8

look 16:5,15 27:1

37:2 45:22 51:7

74:4 90:14 92:9

120:6 134:15,20

149:3 163:15

167:8,16 200:12

201:12 202:10

looked 54:1 67:6

74:2 92:12 106:12

146:22 170:10

190:6

looking 19:2 48:20

63:13 89:22 91:11

102:22 117:22

167:1 194:5

looks 23:1 79:6

80:9 170:8

lose 66:3

loss 89:14 135:17

lost 44:8 124:10

lot 12:6 14:7,16

18:8 20:15 36:7

36:17 70:10 87:22

170:14 179:5

195:13 197:15

lots 15:16 43:15

lot-to-lot 69:17

low 70:20 101:9

lower 15:22 33:20

40:16 46:18 58:10

58:18 60:9 61:20

62:1 63:19 64:1

65:22 66:3,7,9

78:17 94:18,20

165:22 180:11

lowered 194:18

lowering 41:18

lowest 21:19 41:13

lunch 11:6

Lyman 1:23 9:8,8

M

machines 14:20,21

99:4,16

main 128:20

200:16

maintain 38:20

136:13 143:4

156:9

maintained 156:1,4

157:5

maintaining

161:17 176:3

major 26:1 144:7

majority 37:1,3

167:13

making 29:2 70:7

88:6 98:13 117:2

140:16 150:4

managed 146:9

mandatory 173:12

183:2

manner 153:19

manual 107:20

manually 108:5

manufacture 14:1

manufacturer 63:9

111:13 121:12

152:18 156:5,22

184:13 187:4

190:13 191:15

192:9

manufacturers

1:19,22 8:1,4

32:16 38:20 39:16

47:2,18 62:13

68:1 87:4 99:12

101:14 104:15

179:5,17 180:1,14

181:10,16,22

182:8,13 183:1

186:19 191:21

193:8 200:18

manufacturer's

165:12

manufacturing 7:9

map 167:2

March 202:9

marked 78:4

market 66:8 88:13

122:15 137:3,21

146:16 166:8

match 103:13

material 50:8

114:7

mathematical 64:9

113:15

matter 84:5 102:10

124:4 127:21

140:6 202:16

Mauer 2:1 3:12

8:17,17 28:2,2

85:18,18 86:7

97:11,11 98:4

119:2,2 120:9

168:4,4,13,18

169:1,2

max 160:14,20

maximizing 115:18

maximum 121:15

121:21 122:15

142:18,20 143:10

144:5 152:1,3,8

160:13 161:1,7,18

mean 36:7,17 44:3

52:6 53:9 70:14

76:3,19 81:4

89:21 90:2 91:6,7

94:20 98:16

100:10,18 119:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 216

129:18 134:8

167:10 176:17

177:5,9 186:5,6

196:3

meaning 195:4

meaningful 101:11

means 107:15

111:7 132:8 167:5

175:13

measure 34:3

64:10 94:19 96:1

96:18 104:14

143:15,18 144:1,4

144:12 147:16

155:1 162:8 171:3

171:4 175:13

measured 21:16,19

28:19 33:20 58:10

63:19 67:7,19

73:20 74:10 76:1

84:22 85:10,13

95:22 98:15

101:18 103:22

111:12 133:12

145:18 160:4,21

164:9,10,21 165:3

165:10,15,18,21

166:9 172:8,11

173:3 184:15

measurement

32:18 142:15,16

144:2,9 159:10,17

160:18 161:22

176:1

measurements

94:17 96:3 143:5

144:3 145:1

161:11 164:4

measures 153:14

184:14

measuring 22:17

31:2 33:12 65:13

66:16 101:21

113:16 141:18

143:11,19 162:2

170:9,12,17

180:10

meat 31:16

medium 21:12 57:4

121:18

meet 59:7,19

100:16 111:14

137:12 138:3

156:8,15 161:5

183:4 187:8

meeting 1:5,10,11

1:13 5:7,13 6:3,13

11:18 12:6 29:19

31:16 110:18

118:18 149:6

157:13 200:10

201:19

meetings 11:12

meets 115:16,17

124:17

Meg 2:4 8:15 72:19

72:20 73:3,6

129:6

members 179:9

mentioned 25:17

42:7 122:5 163:22

173:6 196:18

meter 144:16 163:5

163:14

meters 162:10

163:9

method 33:17

39:20 57:21 63:21

64:21 65:2,9

68:12,13 108:20

127:7,8 133:17

135:5 136:11

144:20 145:1,3

152:11,12,21

174:19,21 184:22

185:1,9 191:5

methodology

100:13

methods 105:16

121:3 126:17

127:6 137:15

141:14 144:17,19

155:13 175:19

metric 181:5

Michael 1:17 2:2

3:10 7:7,16 23:21

24:1 37:7,8 40:21

40:22 62:3,4

65:19 80:14,15

100:22 109:10,11

116:17,17,19

124:1 131:18

149:7,8 183:10,11

198:5,7 199:7

microphone 6:5,20

7:5 34:20 52:1

microphones 12:1

73:4 138:13

midpoint 121:20

mid-morning 10:8

10:10 11:4

Miele 147:3

migrate 164:8

Mike 47:13 48:9

49:14 52:20 54:16

55:2 60:5

million 198:22

mind 5:21 24:14

92:16

minimal 40:7 175:3

minimis 173:1

minimum 41:9

54:6 121:21

minor 150:22

minus 16:20

108:12,13,17

111:22 112:1

156:4 157:5 162:4

162:20,22 163:1

163:10

minute 13:11 125:3

minutes 15:21

79:17,20 80:4,5

80:10 90:20,22

120:19 124:12

127:1,1 128:12

131:1 138:18

139:11

misinterpreted

168:19

misinterpreting

55:1

missed 115:4

missing 115:13

187:3

mistaken 54:4

mix 20:18

mixed 19:9,22 20:3

93:16

mixture 52:12

mode 4:2 10:11

11:20 31:2 50:22

90:16 125:7

126:13 131:22

132:3 141:13,18

141:21 145:16,19

146:10,15 147:22

148:18 151:4,5

153:17,17 155:1

157:22 172:3,10

175:7,8 176:7

177:17,18 180:17

model 14:1 62:18

63:9

models 147:3 164:5

164:8 173:6 185:2

modes 141:14

180:17

modest 197:20

modification 135:7

155:16

modifications

56:18 106:20

123:13 153:1

modified 96:7

156:14

modify 97:2,3

moisture 16:17

33:2 34:10 47:4,9

53:19 54:6 75:8,9

77:6,10,13,14,14

78:13 87:18 98:10

99:8 103:7 109:18

194:20

moistures 50:17

momie 56:9 110:15

money 70:21

monitor 145:11

174:16

monitored 14:3

month 14:10

months 186:7

189:10 196:2

Morgantown 83:10

morning 5:4,15,18

7:2,6,12 13:9 23:2

29:11 194:7

motors 32:9

mouse 24:17

mouth 73:4

move 54:14 150:20

moving 10:13

31:13 135:3

151:11

multiple 135:14

multiply 96:2

multiplying 89:10

89:15 97:19 98:11

mute 12:15

N

name 5:11 6:22 7:7

7:14 11:14,17

23:22

National 81:14

83:9

Natural 2:4 8:15

nature 145:7

Navigant 1:17 2:2

2:2 3:17 4:4 9:5

31:19 99:2 176:22

near 33:19

nearly 18:21 63:18

67:13 75:3

nebulous 45:21

necessarily 170:17

179:19

necessary 148:10

156:15

NEEA 13:6 28:21

29:1 196:15

need 11:15 44:8

82:13,17 96:6

105:15 113:15

184:21 185:4,5,9
202-234-4433

Neal R. Gross & Co., Inc.

Page 217

187:7,18,19

188:16 191:1,1,11

191:18 201:3

needed 132:17

153:21 170:22

186:20

needs 6:21 171:6

188:10 192:15

negative 110:12

neighborhood

177:13

NETL 27:11 81:3

84:4

network 145:16,19

146:10,15 147:10

148:1,18

never 86:22

new 83:10 93:4

96:1,2,18 135:21

147:17 149:21

154:18 181:5

182:3 197:3

198:14

newer 118:3 158:10

newest 7:9

newly 181:22

non-cyclic 145:9

non-heated 75:7

78:15 79:2 85:6

NOPR 26:14 28:10

28:15 29:17,19,21

35:22 60:14 62:8

62:15 63:3 67:13

75:17 117:2

132:14 134:5,15

normal 21:14

56:20 57:4 59:13

121:9,11,18

130:15 133:1

155:22 156:20

normalization

135:19

Northwest 1:20 2:3

3:9 8:12,13 13:16

114:4

note 67:12 74:18

182:17

noted 34:6 157:2

158:1 162:9

notes 103:2 142:14

145:2 158:10

165:8 175:17

176:1

notice 9:16 18:7

38:11 63:8 96:4

noticed 46:16

noticing 72:1

noting 156:6

NRDC 72:21

number 14:1 18:3

18:4 60:14 94:20

100:6,14 137:6,8

151:4,13 194:18

numbers 63:10

90:18 167:8 178:8

195:10 198:20

O

observation 169:3

observe 103:19

106:9

observed 60:1

171:7

obviously 17:12

18:14 20:7,9

70:14,18 131:10

133:1 187:8

occasionally 123:1

occupied 160:5

occur 104:15 123:4

occurring 197:18

occurs 130:6

offer 198:15

offered 26:20

offers 198:18

official 109:4 113:4

177:7

officials 189:8

offline 188:9

offset 176:2

oh 34:15 40:18

53:12 75:16 77:12

97:10 114:21

116:17 141:5

145:13

okay 5:3 6:15 7:6

7:14 9:12 11:8

13:3 19:11 23:4

27:20 29:16 30:14

35:13 36:4 37:6,7

37:14 38:7,8

42:11 45:9,10

46:9 51:8 53:13

53:16 54:11,12

55:9,16 56:1 59:3

59:18 60:2,3 62:2

63:15,16 65:19

67:3,5 69:4,5

73:16 76:19 77:18

77:19 80:13 81:8

82:17 84:16,18

92:18 95:8,15

96:14 97:8 99:18

100:4,15,20 102:8

102:9,18 104:21

105:22 106:1

113:19 114:19

115:20 119:20

120:17,22 124:9

124:19 125:14

127:9,12 128:6,10

130:3,18 131:18

131:20 133:6,7

135:1,3 137:18

139:9 141:12

148:16 149:14

150:7,11,12,19,20

151:12 153:20

155:9,10 164:12

164:15,16 167:16

169:1,8 171:10,12

171:12 172:1,2,18

173:21 180:15,19

185:15 187:12,20

188:13 191:16

192:3,3,13 193:2

193:14,20 196:1

198:2 199:19

200:2,3

old 18:3 96:5

older 158:4

omit 27:5

once 26:13 69:13

128:3 148:8 185:7

ones 77:13 101:5

101:10 194:13

196:17,17

one-minute 14:5

one-to-one 65:7

online 147:1

open 55:6 83:2

131:1 135:17

opened 132:5

opening 9:20 23:18

operate 198:11

operated 124:11

operating 65:17

125:6

operation 75:3

107:14 108:3

opinion 45:8,12

117:12

opportunity 9:22

10:20 30:5 194:6

200:10

opposed 198:12

opted 193:16

option 129:22

132:21

optional 152:15

153:1 155:13,17

optionally 153:13

153:13

options 119:15,17

oral 30:2

order 3:2 40:18

56:4 106:16 123:2

146:10 162:15

190:22

organization 7:10

26:7,8

organizational 7:1

11:16

organization's

13:15

orifice 156:14

original 95:19

101:20 104:18

originally 33:13

158:2 180:5

ounces 160:14

outcome 96:5

outlet 156:19 157:4

outlined 200:22

outperformed 25:8

outset 10:1 12:22

23:16,19 27:21,22

29:7 140:20

outside 118:4

overall 175:3

overdried 33:18

88:4

overdry 41:5

104:18

overdrying 40:7

41:2,11,15 47:7

66:19 86:10,15

87:1,3,6,14 99:8

102:6

overuse 87:16

overview 13:7

30:16

overwhelmingly

137:21

over/under 35:19

o'clock 10:9

P

Pacific 13:16

packet 9:13 63:8

139:6 202:1

page 63:8

panel 151:22 152:8

parameter 41:15

parentheses 74:20

part 22:21 24:9

27:17 48:3 61:4

63:11 67:6 73:16

79:13 83:1 92:10

101:22 128:8

129:1,4,5 130:15

131:21 132:17

133:1,3 148:7

149:11 170:15

177:22 191:14
202-234-4433

Neal R. Gross & Co., Inc.

Page 218

201:18,22

participant 23:13

participants 12:10

34:22 73:5

participate 140:18

participating

140:15

particular 37:12

38:14 39:1 40:3

44:20 62:9,18

84:5 110:22

127:13 161:1

183:19 184:2

185:2,20 186:10

189:2,18 198:19

particularly 29:20

103:6 108:14

parties 29:22

175:12,18

parts 187:3

party 82:12 190:18

192:1

passed 167:6

pause 11:6 34:16

40:20

penalty 101:8

people 13:20 14:8,9

16:5 17:17 18:8

18:13 21:22 51:10

65:1,8 113:14,17

169:20 196:12

people's 157:14

percent 16:18,18

16:19,20 17:16

20:7,19 21:14

35:19,20 36:3,7,8

36:18,20 39:15,15

39:17,20 40:5

41:8,18 42:4,12

43:11 46:19,20

48:12,17,22,22

49:5,11 50:2,2

54:2,3,5,19 57:11

57:13,16,22 58:13

58:14,20,21 59:7

59:16,20 60:9,11

60:17,20,20 61:8

66:18 67:9,11

69:12,12 70:4,7

74:5,6,12,14,15

74:17 75:3,17,18

75:19,19 76:6,9

76:10,12,15 78:4

78:5,8,22 79:8,9

80:2,3,4 85:5,12

86:8,8,13,16

87:17 88:5,19,21

90:1,5,5,8 97:16

97:21 98:6,8,9,11

98:14,17 99:5,6,9

99:15 101:4,6

104:17,18 108:18

108:21 109:2

110:11,12 112:13

122:7,9,12 124:17

133:14,18 135:9

135:22 156:4

157:6 160:15,21

162:13,20,22

163:1,10,11 164:9

166:2,2,4,13,22

167:3,3,11,11,12

169:3,7,12,13

170:20 174:22

194:20,21

percentage 22:17

69:10 112:1

197:20

percentages 75:14

perform 179:19

performance 28:16

32:19 105:20

110:7 111:11

115:10

period 6:13 39:13

57:9 74:8,22 75:2

78:10,15,16,18

79:2 80:9 89:7

99:6,16 124:6,21

124:22 125:9,12

128:2,5,8,21

136:3 173:13

174:11 202:8

person 140:14

personal 130:19

personally 26:16

perspective 43:6

52:16 96:17

119:11 120:15

per-cycle 31:3

32:17 58:11

135:20 150:22

151:4

petition 28:7 39:6

39:10,22 54:19

55:17 57:17

104:12 122:13

200:17 201:10

petitioners 49:2

phase 76:13

phones 11:20

pick 141:10

picking 75:8

pieces 187:3

piles 19:6

pillowcases 56:15

place 27:3 162:7

183:14 184:1

185:12

places 134:18

placing 143:5

plan 111:12,16

141:2 159:13,22

181:1

plans 190:15 195:9

plastic 159:16

please 6:22 11:10

11:13,14,20 12:15

12:18 23:22 27:1

40:21 45:6 52:1,4

72:19 73:2 93:3

114:21 140:10,21

202:2,9

pleased 28:3

plies 20:7

plot 19:19 22:11

79:12

plus 16:19 77:14

108:11,13,17

111:22 112:1

156:4 157:5 162:4

162:20,22 163:1

163:10

ply 19:17 20:1,10

20:14,20 21:2

podium 23:10,10

point 26:20 27:17

52:3 54:16 57:9

59:1 63:17 67:17

71:18 75:18,19

87:20 118:12

124:16 149:12

186:22 195:19

198:4

pointed 90:5

104:14

points 61:12 64:12

74:3

policies 173:10

polyester 19:22

56:10

poor 101:10

poorly 101:14

port 159:14

portion 78:2

position 109:13

132:6,11,12

possible 61:17 70:8

70:14 114:5 115:9

134:10 138:2

173:20

potential 56:4

101:19 115:15

175:21 178:21

potentially 99:17

136:9 161:12

pound 108:22

160:20

pounds 160:13,16

160:19 161:5,8,13

161:16,17

power 1:20 8:14

31:2 141:18

142:10,17 143:12

143:20 144:1,8,11

144:12 145:1,7,11

146:5,10 175:14

175:22

PowerPoint 9:15

power-measuring

142:13 143:15

precisely 170:9,13

precisely-specified

70:11

precision 170:14

preferred 144:22

preponderance

22:5

prescribed 44:11

present 1:13 49:21

60:15

presentation 115:5

presented 58:3

87:16 121:7

133:11 134:5,6,7

presenting 23:10

preset 107:14

108:3 136:5

presiding 1:12

press 102:9 133:5

pressing 11:5

120:18

pressure 155:22

156:10,13,19,20

156:20 157:4

presumably 99:11

100:4,11 123:2

129:1

presuming 79:19

92:4

pretty 12:2 13:13

31:10 87:3 168:2

171:22 198:20

prevalent 154:19

prevent 129:13

135:13 188:18

prevented 186:9

prevention 129:21

130:9,13,22

132:20 153:8

previous 35:12

42:16

previously 25:17

54:2 181:21

prewashed 41:3
202-234-4433

Neal R. Gross & Co., Inc.

Page 219

primarily 200:14

prior 145:9 173:11

182:2

probably 17:21

37:2 47:7 87:8

137:7 146:7

147:21 177:12

179:13,16

problem 25:22

26:1 196:22

problems 155:5

procedural 171:2

procedure 18:18

18:22 25:12 28:12

28:19,22 29:13

30:6,16,20 31:5,7

32:15,21 33:10,21

39:8,11 42:16

44:6 48:11,15

49:8 51:3,5,14

56:5,17 58:12

66:21 68:3,9 70:4

70:15 71:4,11

83:2 91:2 97:2,15

98:19 100:12

102:3,22 103:3,8

103:14 106:19,22

107:4,8 108:11

114:8,17 115:8,11

115:14 116:10,13

119:14 123:9

127:11 138:1

142:7 144:22

146:17 148:7

161:9 162:1,16

164:18,19,21

165:1,2 166:1,10

168:10,17 170:15

171:3 173:3

174:15 177:11

179:12 182:1,3,4

182:7,19 184:1,13

184:16 185:13

190:15,21 192:18

193:16 194:17,18

197:12 199:9

200:21 201:5,6

procedures 1:5 5:7

10:17 15:16 45:15

56:13 102:22

151:16 152:21

155:16 174:6

200:11

proceed 12:22

proceeding 194:10

process 26:2 64:9

120:13,14 158:9

159:1 185:5 186:2

186:21 187:4,10

188:1 190:3,10

191:2,4,9,12,14

201:14

produce 51:14 68:3

104:16 108:13

135:16

produces 18:22

107:2

product 58:5 59:7

59:19 103:17

118:9,13 153:18

186:12 191:13

productive 201:19

products 3:15 10:5

30:19 31:17 32:1

65:4 81:22 87:5

115:19 145:18

146:18 157:3

164:22 179:6

180:22 182:2

190:12

product's 184:17

profess 199:2

profound 169:18

186:11

program 42:4

56:21 57:2 67:10

74:11 121:10,11

121:14,17 123:11

148:8 149:22

155:14 174:10

183:13

progression 158:14

Project 2:1 3:12

8:18

promised 194:6

promptly 76:7

promulgated

173:11

promulgation

182:6

properly 185:16

property 198:22

proposal 28:10

41:7 44:21 49:7

49:22 51:20 54:7

92:14,16,20 94:15

95:7,10,14,20

98:5 104:11,19,20

105:3,14 109:4

117:8 125:3

129:19 136:12,14

137:14 145:21

168:21 182:8

proposals 47:19

117:1,6

propose 91:4 118:2

146:1

proposed 28:15

30:19 31:6,17

32:2 33:13,16

34:2 100:19 102:3

107:5 108:19

111:21 117:9

121:9 124:4

133:16 136:11

164:17,20 165:9

165:17,18 166:6

172:5,10 174:8

175:6,9 176:6

proposes 199:6

proposing 32:11

50:1 53:18 92:8

96:1 100:8 106:19

107:7,10,18 108:2

108:8,10,12 121:3

121:6 122:2 133:7

135:4,10,19,22

136:2 142:11

143:22 144:19

150:15 151:9

152:5,9,19 155:11

156:11 157:6

158:18 159:2,21

161:14 163:4

165:6 174:10,20

181:6,8,19 182:12

protections 173:15

protocol 188:21

protocols 26:15

53:21

protrudes 159:17

protruding 160:5

provide 13:7 62:8

62:10,16,21 63:9

63:10 110:21

118:10,12 137:15

137:15 142:7

158:7,21 173:18

175:13 181:11

186:12

provided 80:18

121:19 132:9,15

138:9

provides 103:8

111:12 142:14,19

144:14 145:3

providing 110:16

provision 132:9

158:1 159:20

provisions 39:8

141:17 150:14

175:12,15

psychrometer

162:2,8 163:8

public 1:5,13 5:7

5:12 26:21 29:19

149:6 157:13

200:10

publication 30:8

publish 116:13

published 29:17

30:2 33:10 35:17

38:10 103:2

141:16 142:2

147:1

pump 25:16,19,20

53:2,7,11,15

purchased 110:13

147:5

purpose 28:13

42:21 65:2

purposes 42:13

127:13 192:4

193:17

put 64:20 110:14

195:10

puts 137:21

P-R-O-C-E-E-D-...

5:1

p.m 202:16

Q

qualifying 169:15

169:16

qualities 113:2

query 113:21

question 46:12

48:1,11 54:17

55:4,21 59:6

64:13,20 69:21

77:4 83:5 95:16

113:20 122:19

127:13,19 129:9

134:4 145:13

148:17 150:2

164:7 168:18

179:3 183:20

184:12 189:18

198:9

questioning 92:6,7

questions 3:19 4:5

12:21 50:4 104:7

113:9 172:22

188:15

queue 35:2

quick 30:16 59:5

65:11 72:16 77:4

171:22 194:13

quickly 29:12

97:10 121:8

139:21 187:5,11

quite 22:4,16 65:16

66:6 76:22 80:5

87:22 101:7,10

129:15 170:12
202-234-4433

Neal R. Gross & Co., Inc.

Page 220

173:8,17 179:3

R

radically 197:12

raise 12:19 140:21

194:8

raised 28:6,21

115:4,6

ran 80:9

randomness 70:9

range 20:14 21:2

36:6,15,17 46:19

58:14 70:2 71:6

71:17 76:7 108:17

114:13 160:12,12

160:16,19 161:2,7

161:14 166:21

169:19 173:5,8

187:13,16

ranged 36:2 58:12

67:8,11 166:1

ranges 75:14

161:15 162:17

163:2

ranging 46:20

58:20

ranking 65:3,7

rate 22:4 182:1

rates 21:16

rating 156:3,5,9,13

181:13

ratings 118:6

190:14

ratio 142:18,21

143:11 144:6

rationale 97:13

rationalization

195:3

reach 43:10 90:19

125:9

reached 74:5,6,14

74:17 78:3,5,8

79:8 85:12 87:17

88:4,19 105:8

110:12

reaches 97:16 98:6

98:7 128:1

reaching 78:22

99:6

react 88:15 89:2

reacts 41:22 86:3,5

reading 144:16,17

171:8

real 41:21 42:8

43:4 46:13,22

47:4 49:4 50:17

50:18 51:5,9,9,10

55:13,14 64:10

65:11 91:7,9

96:20 99:11

112:14 171:4

197:8

reality 105:14

realize 119:6

realized 105:11

really 12:7 20:10

91:11 115:15

116:22 119:11,17

194:15

real-world 26:12

42:13 43:2,3,8,9

43:13,15,19 44:1

44:2,13,16,17,18

45:20 46:5 47:6,9

47:15,20 48:1,2

49:7 50:14,15,16

50:18,22 51:6

52:6,11,16 54:21

87:1 99:13 112:22

171:4

reason 83:7 93:14

135:13 188:10,15

reasonable 17:20

70:20 99:13

105:21 176:2

reasons 89:19 93:6

175:5 179:6,20

recall 69:21

receive 37:20 44:17

138:8 139:2

received 9:13 34:17

39:6 67:22 138:6

139:7 151:13

152:14 156:6

157:10 159:19

160:22

receives 106:22

recognize 43:16

66:13 119:4

recognizes 32:20

43:14 161:3 162:6

recognizing 85:2

105:15,19 115:11

recommend 30:3

112:7

recommendation

49:2 72:8

recommended

121:11 156:21

record 11:14 12:9

23:22 26:3 140:7

140:8 188:11,16

202:16

recorded 30:2

122:2 143:9

RECS 195:2,2

rectangle 19:3

red 15:12

reduce 71:4 169:6

178:17

reduces 64:8

reducing 115:19

reduction 105:7

reevaluate 195:10

reference 30:22

151:10 196:9

referenced 151:6,8

referencing 52:4,6

126:11

referring 7:4 53:1

93:13

refers 158:20

159:22

reflect 64:10 115:8

135:21

reflected 98:18

119:19

reflecting 28:16

102:11 201:7

reflection 65:7

168:21

reflects 11:2 51:14

64:22

refrigerators

148:12 149:4

regain 99:9

regaining 98:10

regard 189:6

regarding 112:5

151:13 157:16

159:20 161:1,21

173:2 200:15

regards 199:10

Register 9:16 29:18

63:7 70:1 96:4,8

196:9

registered 141:7

regulations 32:4

187:9

regulator 156:19

156:19 157:4

regulatory 3:13

9:21 31:10,14

Reich 2:2 83:11

98:20 99:1,1

105:1 111:9,10

128:18,18 129:18

130:4 131:3

176:21,21 188:6

reiterate 196:19

200:14 201:11

202:7

relate 25:12

related 158:8 159:1

180:16 183:4

relation 16:4

relationship 36:5

41:1 84:9

relationships

103:20

relative 42:13

44:13 47:20 63:1

65:3,6 76:10 83:5

86:16 117:7,18

161:21 162:6,14

163:2,4,11,14,22

176:16 178:18

183:12,20 189:20

198:9

relatively 72:4

177:19

relevant 40:2 113:5

194:22

relying 62:8 118:5

remain 112:17

remaining 16:17

50:16 53:19 54:6

87:18 109:18

194:20

remarks 4:7 5:15

6:3 9:20 10:22

23:18 202:4

remember 30:1

95:16 188:6 195:2

remind 104:10

176:13

remote 114:5

remove 61:6

104:13 135:15

removed 17:4

removing 197:4

reopen 197:11

repair 21:21

repeat 68:7 75:13

repeatability 71:2

106:10 109:7

113:10 114:13

115:10 136:7

175:15

repeatable 68:4

105:16 107:2

108:14 170:16

replace 101:16

157:7

report 181:13,16

reporting 181:9

reports 181:3

represent 7:8 24:2

24:17 66:19 85:4

113:14 114:9

189:1

representation

182:9 193:10

representations

182:14 193:9
202-234-4433

Neal R. Gross & Co., Inc.

Page 221

representative

26:17 40:11 42:5

42:12 48:14 51:13

56:6 65:15 82:7

88:9 119:19

122:14 180:7

189:4,5,22

represented 113:3

representing 7:15

8:9,20 26:18

39:16

represents 40:6

65:3 86:10 114:17

119:13 191:6

reproducibility

69:7,15 73:9 81:6

106:3,15 109:8

reproducible 68:4

105:16 107:2

request 38:10,12

109:4 112:5

150:13 163:16

172:16 179:17

185:18 190:6

requested 83:8

requesting 122:1

151:14

require 121:3

144:20 145:6,18

174:15 182:13

required 51:13

142:15 164:20

173:13 175:3

182:3,19 183:4

184:9 185:8

requirement 65:12

156:8,15 157:7

183:8,9 190:12

192:8

requirements

10:18 31:9 106:20

115:16 124:17

155:20 156:17

160:10 161:6,18

163:7 174:4 176:1

176:2 181:1,3,7,9

187:8 190:20

191:15,21

requires 32:16

103:14 111:10

142:16 143:7,11

160:18 174:5

177:11 182:5

188:20

requiring 181:16

rerun 57:14 59:12

59:17 122:10

resembles 20:16

reset 49:11,14,15

49:16

residential 1:5 5:8

resistance 25:2

resolution 160:13

160:19 161:6,18

resolve 140:4

Resources 2:4 8:16

respect 114:3

response 13:1 29:8

39:5 132:14 139:8

146:4,4 150:18

164:14 174:2

180:18 194:3

201:17

rest 16:1

restate 61:3

restriction 71:20

restrooms 139:15

result 18:9 22:8

25:15 28:18 33:19

70:10 93:15

105:17 108:18

136:9 172:9 175:1

resulted 58:10 76:1

78:13

results 22:16 35:15

35:17 48:21 53:21

58:4,7 61:13 62:6

62:10,17 63:1

68:4 69:7,9,11,16

71:11,14 78:19

80:18 88:18 93:7

95:17 96:2,20

100:8 103:5,15,18

107:3 108:8,14,19

110:10,17 111:16

135:16 165:20

192:19 197:14

201:4,9

resume 139:17

140:9

retail 81:22

retailers 110:14

return 50:7 141:3,9

review 3:7 9:17,20

30:7 102:21

175:11 185:20

reviewed 186:15

reviewing 202:10

revise 40:2 116:12

revised 184:11

revision 115:14

revisions 10:17

31:7

revisit 116:13

re-look 92:11

RFI 39:5

right 15:14 20:19

30:13 36:13 40:22

56:3 60:8 65:16

72:11 74:21 76:20

79:14,18,21,22

82:13 83:18 89:12

95:16,20 96:21

98:6,10 99:4

111:20 125:2

126:18 127:2

137:13 147:6,14

148:12,22 150:4

170:12,17 174:3

177:8

rim 15:22

Rivest 2:2 48:6,9

48:10

RMC 17:3 29:4

34:9,14,14 36:1

36:21 38:19 39:13

39:21 40:6,13,15

41:1,6,10,18

42:12,15 46:18,20

48:4,12 49:12,15

49:16 53:22 57:10

57:11,16,17,22

58:18 59:7,15,20

60:11,15 66:3,18

67:7,8,11,14,18

67:20 73:21 74:6

74:6,14,17,19

75:3,10,22,22

76:10 78:3,5,8,18

78:22 80:2,3 85:6

85:12 86:16 88:19

88:21 89:8 90:1,5

90:6,6,9,12,15,18

97:17 98:6,8,9,11

98:18 99:5,6,13

105:7 106:2,4,6

107:17 108:10,17

108:21 109:2

110:11,12,22

111:22 114:6

122:7,9,12,15

124:17 133:12,14

133:17 135:8,21

136:9,12 174:16

174:22

RMCs 35:18 47:20

61:20 66:1,7

111:5 117:22

198:13 199:12

role 24:17

room 1:10 6:17

9:14 12:17 14:18

23:14 24:9 26:18

70:6 169:20

rough 137:3 178:8

roughly 46:20 86:8

176:17

round 10:9 48:8

115:14 194:17

rule 30:8 33:9,22

34:6 41:5 54:5

132:18 134:14

141:15 142:3

158:3 181:5

rulemaking 5:19

28:8 29:13 32:1

33:14,15 35:12

48:4 63:12 107:4

142:5 149:20

164:19

rules 111:4

run 57:7 60:21 89:6

110:11 122:6

124:5,20 127:1,14

127:18 128:1

153:20 155:4

174:12 175:4

177:12 180:5

201:9

running 87:20

145:10 146:7

runs 177:4

S

Safe 202:13

safer 117:20

safety 25:9 198:11

198:19 199:5,13

199:18,19,22

sample 19:5 40:10

56:6 106:13

111:14

sampling 111:12

111:15 144:16,20

145:2 181:1

190:15

Samsung 147:4,7

satisfaction 11:1

38:21 180:8

save 101:17 197:20

198:1

saving 197:21

savings 101:13,19

119:16 171:7

178:22

saw 36:6 46:19

47:6 61:8 88:3

90:21,22 196:8

saying 24:22 27:1,2

47:14,21 61:18

84:3 86:13 89:20

95:2,4 140:14

153:10,16 171:1

192:5,17

says 62:15 76:21
202-234-4433

Neal R. Gross & Co., Inc.

Page 222

131:4

scale 18:19 160:9

160:11,12,18

161:2,15,16

scales 161:3

scope 148:22 149:5

scrutiny 138:1

se 38:3 189:3

seal 160:2

seats 140:10

second 4:3 10:12

51:21 65:6 141:22

142:2,4,5,11,12

143:7 144:8,9,21

147:4 150:14

172:6 175:13

179:2 193:7

197:10

seconds 202:2

second-most 147:8

section 111:19

134:16 142:12

144:21 151:3,6,7

151:16,22 155:20

156:16 157:18

158:19 159:9

160:10 165:8

171:14

SEDI 8:20

see 9:13 10:6 13:12

15:5,9,10,13 16:3

16:9,16 17:3,7,14

18:11,16 19:7,13

19:15,21 20:12,13

20:16,17,17 21:1

21:10,13,20 22:3

22:9,12 28:3

29:15 34:20 40:14

43:10 44:12 52:8

52:18 54:9 61:14

61:19 70:1 73:14

75:20 77:4 78:6

78:11,21 80:16

81:9 89:19 90:3

90:14 93:1 94:7

95:18 98:20 99:4

112:18 113:17

116:22 125:22

133:6 139:5 140:1

149:5,14 163:16

164:15 171:5,17

173:22 177:4

178:5 196:14

seeing 22:6 41:8

87:3,15,16 90:3

110:5,13 114:10

116:15

seek 66:7

seeking 111:21

133:15 136:10

163:12,17 176:8

185:3 198:16,17

seen 35:16 52:14

94:13,17 112:15

125:12,21 129:22

157:11

sees 88:15

select 40:4,8

selected 21:11,12

21:14,14 39:4

62:11 130:1,1

171:6

selection 57:1,2

181:2

self-certify 191:21

send 147:11

sense 23:1 47:10,22

112:21 130:15

137:10 140:16

154:18 178:4

179:15

senses 86:4

sensing 33:3 34:8

34:10 42:1 77:15

110:1 151:21

sensor 33:1,2,2

77:5,10,11 105:8

sensors 37:10,12

38:2,18 88:12

89:2 93:11 103:7

162:7

sent 27:12 34:22

189:12

separate 121:3

126:17 152:7

157:12

September 158:2

sequence 116:11

series 9:15

serve 117:4

session 200:4

set 27:3 42:1 48:15

57:3,4 96:19 97:2

102:9 116:10

121:14,15,17

126:22 175:4

194:1 200:20

setting 21:12 56:19

57:3,15 59:12,13

59:21 111:4

121:16,20 122:11

136:5 148:22

152:2,3,7,8,15,16

158:13 159:3

settings 39:3 56:22

121:6,22 122:2

123:10,13 124:15

133:19 151:19

152:13,22 153:2,3

155:13,15,15,17

155:18 158:15

159:6 163:14

165:7 181:17

196:12

shapes 34:12

share 6:1 12:4

13:19 26:17

sheets 14:15 56:14

shipments 39:17

shipped 123:14

146:2,3 152:18

153:16,18

shop 139:18

short 78:18 164:1

shortly 120:18

146:3

show 19:12 57:17

69:14 71:12 77:21

79:12 106:14

130:14 136:18

158:14 196:20

showed 14:8 33:16

58:7 64:7 68:22

69:10 74:9 75:6

76:17 88:18,18

102:6 103:18

113:7 114:2

165:20 166:19

172:7 179:8

194:14

showing 39:18 58:5

60:9 71:15,19

79:15 86:20

shown 74:1,20 78:2

90:6

shows 67:13 81:11

85:15 103:16

107:1 195:12

shut 75:11 101:8

127:4 128:11

153:13,14

shuts 97:16 98:5,10

124:12 125:9

127:21 128:4,9

sidebar 11:21

sides 112:16

signal 123:4

signals 123:18

significant 69:15

71:15 106:9

119:15 136:4

173:9 175:11

significantly 33:18

33:20 46:18

117:19 178:2

significantly-diff...

135:16

silent 11:20

similar 61:16 64:6

78:19 96:5 138:10

145:4 155:11

157:2 172:20

195:19 196:10

similarly 58:16

104:1 160:18

simply 105:6

116:21 180:9

187:7 197:13

single 43:19 182:13

193:8

sit 200:10

situation 105:6

situations 173:7,16

six 163:16

size 16:8,10,11,12

18:12,13 38:17

67:1 178:18

sizes 34:12 41:20

43:17 85:4 86:6

88:14

skim 69:22

skip 171:18

slide 13:4,8 29:15

30:9 68:21 76:18

139:5 141:11

159:5 171:21

193:3 194:4

slides 9:15 136:17

166:19 194:2,13

slight 106:14

slightly 16:11

59:14,16 68:15

slightly-longer

175:1

small 106:13

169:14

smaller 16:12

167:3 178:21

smart 147:20 148:5

148:7 149:3

smartest 76:5,12

smart-grid 146:4

SNOPR 33:14 34:2

132:15 142:1

157:12

soft 103:11,12,14

software 12:19

sold 137:4

Solutions 1:14 5:12

somewhat 42:19

61:5 196:3

soon 11:7

sophistication 33:4

sorry 34:15 36:11

40:19 72:18 76:8
202-234-4433

Neal R. Gross & Co., Inc.

Page 223

77:8,15 80:3

97:11 98:3 121:22

129:17 145:13

151:7 169:1 171:4

172:14 177:16

sort 16:3,9 22:9

41:19 137:22

138:2 172:20

196:6

sought 38:14

183:19

sound 34:21

sounded 54:19

93:11

sounds 93:6 94:20

101:5 153:9

154:16

source 32:9 101:13

space 160:3,5,6

speak 11:13,15

12:18,18 24:18

speaking 25:20

113:8 126:11

specific 40:8 43:8

112:5 132:19,22

specifically 39:10

81:16

specification

142:15

specified 56:12

68:2 71:5 111:15

126:2 129:19

135:6 156:5,9

161:8,19

specifies 123:10

127:11 144:22

152:1 155:21

156:17 157:19

159:11,14 160:11

162:1

specify 37:11

107:19 123:12

152:21 153:1

155:16 156:22

157:4

spending 70:21

spent 79:7

spikes 146:6

split 17:17

splitting 17:18

spot 70:1

spread 19:6

spring 149:22

square 15:21

stability 144:11,13

stable 145:8

stage 201:14

stakeholder 39:6

stakeholders 150:6

standard 4:3 10:12

40:6 49:9 65:17

77:20 95:21 96:5

96:6,19 97:3

103:11,12 115:16

115:17 116:5,11

116:13 120:7

137:12 138:4

143:17 145:15

170:22 171:6

173:12 179:18

183:5 197:1

200:20 201:3

standards 2:1 3:12

8:18 10:17 27:3

31:8 40:3 95:19

101:20 115:12

164:18 165:13,15

168:7,9,11 169:6

169:7 172:13,13

180:21 182:18

200:12

standby 10:11 31:2

141:13,18,20

147:22 151:4

155:1 172:3,10

175:8 176:6

177:18 180:17

Standby/Off 4:2

Star 147:19 148:8

149:19,22 150:6

193:10,15

start 5:3,14 6:16,17

16:12 31:16 69:14

started 23:15 78:9

79:21 129:8 149:2

186:2

starting 78:3 107:9

108:10,21 109:2

111:22 165:18

starts 72:3,5

state 26:3 33:19

75:4 88:5 123:9

158:19

stated 39:10,22

40:8 187:7

statement 27:14

83:5 177:21

192:17

statements 188:16

states 1:1 13:16

stating 39:6

statute 168:15

statutory 65:12

stay 150:3

step 186:1 187:17

190:10 191:2

Stephen 1:15,22

3:4,14 4:8 5:15

6:4 9:2 13:2

23:17 29:9 45:13

72:10 200:5 202:3

Stephens 2:3 3:9

8:11,11 13:6,9

23:5 25:17 34:17

35:3,4,13,16 36:4

36:13,16 37:4

50:10,11 53:1,3,6

53:12,14 68:18,19

68:19 87:11,12,12

89:4,13 90:11

91:18,22 92:3,18

99:20 100:4,15,20

145:14,15,22

148:16 154:20,21

193:6,6,14,20

194:12 195:22

Stephen's 102:11

steps 191:8

Steve 8:2

stop 34:11 76:6,14

105:7 174:17

stopped 99:4 101:4

135:12 136:15

174:21

stopping 59:1

98:17 135:14

stops 123:16

124:16 128:20,22

130:20

straightforward

31:11

stretch 19:14

stretched 19:4

stringent 143:1

strongly 6:10 30:3

186:18

struggling 196:4

study 14:21 21:10

22:1

stuff 14:14,15

20:17 22:21

stumped 101:22

subject 84:5 124:3

175:10

submit 30:4 45:18

46:7 65:5 72:9

83:1,8 89:18

91:21 92:1,17

96:16 113:8 117:7

117:17,18 147:16

178:14 180:9

189:20

submitted 27:10

39:16 62:7 80:21

83:16 186:7,8

188:7 192:7

195:15,20 200:18

submitting 47:19

84:12 117:9

190:10 200:13

201:13 202:7

Subpart 183:17

subsequent 118:6

subsequently

185:11

subset 13:18

substantial 36:19

substantially 36:6

substituting 68:10

subtracted 159:15

160:3

sub-bullet 193:7

succinct 55:8

sufficient 143:4

176:4

suggest 91:10

98:12

suggesting 97:20

114:15 116:2

120:2

suggestion 46:6

116:4

suggests 89:5 91:12

suit 189:10

summary 10:2

16:14 96:7 112:8

Super 8:20

supplied 46:2

supply 6:11 102:20

103:10,21 106:21

142:10 155:19

156:2,17

support 28:9 54:18

supporting 7:17

supportive 115:1

suppose 154:3,4

supposed 93:21,22

94:5

sure 12:8 22:21

25:11 43:21 58:22

59:2,15 71:18

75:15,16 83:13

85:19 88:5 92:19

93:5 95:12 101:2

102:15 111:19

131:3 134:13

139:2,3 171:20

180:2 193:4

198:18

survey 195:2

suspected 86:14

swing 169:11

synthetic 112:13

system 24:14 33:4

107:15 158:20
202-234-4433

Neal R. Gross & Co., Inc.

Page 224

systems 25:1

101:15,17 110:1

157:20

T

table 58:4 63:8

74:2,9 103:16

118:14 134:11

tables 67:13 134:5

take 10:8 11:4

13:11 27:21 35:5

45:19 72:7 76:8

91:13 101:14

120:19 138:15

139:6,10 140:10

154:13 176:15

179:21 185:19

186:6 188:8

195:14 202:2

takes 15:11 21:4

22:15 95:17 177:2

talk 17:1 148:1

149:1 200:11

talked 170:10

talking 24:21 43:22

52:13 53:4,17

62:9 90:18

talks 65:13

target 38:19 41:18

66:3 135:21

178:18

targeted 146:8

task 158:5,21

tech 34:18

technical 10:13

31:3 150:22

technique 144:10

techniques 144:9

144:15

technologies 1:17

2:5 3:11 7:8,16

24:6 26:19 77:5

109:12 116:20

118:4 169:17

198:8,14

technology 24:7,13

24:19,19,20 25:3

25:5,8 26:4,9 27:2

27:5,7 78:13 83:9

83:17 88:2 119:14

119:17 138:3

184:18 186:10

188:2,7,17,19,20

189:11,19 199:1

telephones 12:16

tell 13:21 17:22

80:5

tells 15:13 105:8

temperature 21:10

21:12 33:2 34:10

56:21 57:2 77:6

77:10,15 121:13

123:11,11 133:18

151:21 152:2,7,16

152:22 153:3

155:14 158:15

159:5 162:18

temperatures

162:12

tentatively 166:5

176:5

term 43:15,18

87:14 119:7 157:7

terminate 104:17

111:6,8 132:2

terminated 107:15

108:4

terminates 91:15

termination 3:16

10:7 22:10,11

32:14,19,21 33:13

33:17 34:3,8

36:18 37:11,19

38:12 41:22 42:4

56:19 101:17

103:6 108:20

111:1 124:7 126:2

126:4,5,13 132:2

137:11 171:5

174:9

terminology 55:13

terminus 21:17

terms 15:11 48:21

53:18 104:12

110:19 149:1

162:13

test 1:5 5:7 10:14

10:16 15:15 16:1

16:3 18:18,21

19:10,21 20:21

25:12 27:4 28:12

28:19,22 29:3,12

30:6,16,20 31:5,6

32:15,21 33:10,17

33:18,21 34:14

35:6,11 36:1,12

37:17 39:7,11,14

39:20 40:5,7

41:21 42:3,16

43:3 44:6 45:4,15

45:16 46:14,14,17

46:21 47:7 48:4

48:11,13,15,19

49:5,8,9 51:3,5,11

51:14 52:19 53:2

53:11 55:18 56:5

56:8,9,12,13,17

57:11,12,13,20

58:7,9,12,17,18

58:19 62:6,10,17

63:1,19,21,21

64:1,2,14,21 65:2

65:9 66:13,18,21

67:7,8,9,16 68:1,2

68:3,5,9,11,13,16

69:2,9,12,13,17

70:3,8,10,15,22

71:1,4,11,21 73:9

73:11,12,19,22

74:5,7,14,16,19

75:7,10 78:7,21

81:9,11 82:11,20

83:2 84:10 85:2,5

85:11,14,16 86:4

86:5,9,11 87:1,2

88:15,17 91:2,10

94:6 95:5 97:2,15

98:1,7,15,18

100:8,12,17 102:2

102:21,21 103:4,6

103:13,18 104:2,4

104:4,5 105:16

106:3,7,7,17,19

106:22 107:4,7

108:7,9,11,20

109:1,5,7 112:7,8

114:8,15,17 115:3

115:8,11,14 116:3

116:10,12 119:3,5

119:9,12,13,18

120:3,6,7,11

121:2,3 122:4

123:8 124:4,18

127:10 128:13

129:10 130:2

132:9 133:13,16

135:5,9,12,15

136:11,15 141:13

142:6 143:6,9,17

144:3,6,15,19

145:3,10,11,12

146:17 148:6

151:15,16,19

152:4,9,11,12,14

152:20,21 153:19

155:13,15,22

156:7,10,20

157:22 159:8

160:11 161:3,8,15

161:22 162:16

164:17,19,20

165:1,2,6 166:1

166:10 168:10

170:7,15 171:3

173:2 174:5,6,14

174:17,19,20,21

175:4,7,19,22

176:14 177:2,11

178:15,19 179:12

180:2,4,11,12

182:1,3,4,7,19

184:13,16,22

185:9,13,21

188:21 189:5

190:12,14,21,22

191:17,22 192:14

192:18 193:16

194:17 197:9,11

199:9 200:11,21

201:4,6

tested 21:6 24:8,13

25:7 26:1,5,6,13

27:10,12,16 33:18

35:18 39:18 47:18

56:6 59:13 60:16

63:11 67:14 68:8

78:7 81:5 83:12

97:14 98:5 107:21

110:15 111:14

117:13 120:10

147:5 153:18

167:2 189:9,17

192:17 199:11,13

tester 145:10

testers 135:14

136:4 174:15

testing 14:19 15:2,4

20:22 25:18,21

26:8,15,19 27:3

27:15 33:15 35:6

35:10 42:13 43:9

43:22 44:15,17,20

45:8 46:16 53:7

53:17,20,22 54:18

54:21 55:17 56:7

56:11,16 57:19

58:4 60:10 65:22

67:6 68:5,8 69:6

73:17,18 80:18

81:1,2,13,15,21

82:8 83:7,9,16,17

83:19 84:4,6,8,10

84:11,19 86:9

102:19 103:12,17

106:18 107:6

110:5,15 117:7,10

121:7 151:15

156:7 165:20

170:6 172:3,7

176:3,15 177:10

178:5 179:4,5,12

180:3,13 181:2

190:14,19 191:13

191:14 192:10,11

199:10,18,22
202-234-4433

Neal R. Gross & Co., Inc.

Page 225

tests 22:12 53:10

58:8,9,9 60:15

61:10 62:5 67:15

68:8 80:20 90:13

122:3 133:19

189:21 191:5

test-to 106:2

test-to-test 68:14

106:8 113:10

thank 6:7 7:13,18

7:20 9:10,12 23:6

25:14 27:19 28:7

29:5,6,12 37:5

38:7 47:12 55:19

60:2 63:14 64:15

64:17 67:2 69:4

73:15 81:20 84:15

115:20 116:18

118:15,19,21

128:17 129:7

134:19 149:13

150:8 155:9

173:21 180:15

192:13,22 193:20

193:22 198:6

199:20 200:2

201:15,18 202:6

202:11

Thanks 23:5 77:16

80:13 150:9

thickness 17:10

19:17,17 20:14

21:2 112:9 113:1

thin 20:2,9 112:12

thing 7:4 18:7 46:5

46:12 47:5 50:13

52:10,15 82:11

83:6,15 89:9

151:19 170:9,13

170:18 194:6

196:5,6

things 5:20 15:6

16:15 19:3 20:14

21:9 50:12 51:18

71:19 105:19

132:16 146:5

147:11 170:11

179:13 180:2

184:20 189:15

think 6:6 16:22

18:8 21:5 36:17

41:17 43:14 45:7

45:11,19 50:12,20

51:16 54:16 61:11

63:12 64:3 71:9

71:22 86:18,19

88:11 89:17,20,21

90:11,13 94:4,13

95:20 96:3 97:1

102:2 105:4,10

113:13 114:4,5

116:11 119:6,7,11

130:11 131:8,11

132:10,12 134:9

137:18 138:20

141:5 146:7

147:16 148:21

149:5 153:6,15

166:18 168:1,20

169:10 170:11,12

171:2,20 173:10

178:1 179:11

181:18 190:9

195:17 196:2,12

196:17 197:7,10

197:15 200:15

201:1,20

thinking 54:20

55:14

thinner 20:4

third 82:11 87:21

88:3 190:17 192:1

third-party 81:22

82:2,4,6,22 83:20

84:6,10 117:13

191:18 192:6,11

THORNE 1:16

three 14:9 48:8

68:7 112:15

144:14 177:2,4

178:10 186:6

189:10

three-dimensional

17:9

three-year 173:13

threshold 57:16,22

122:8

thumb 134:14

tightening 71:16,19

tighter 71:5

time 11:13,14

15:11,21 17:11,20

27:18 31:15 32:12

50:3 75:11 79:8

79:20 89:7 90:15

90:16,16,17,22

97:17 98:3,8

101:21 102:10

108:9 116:14

126:6 127:21

135:22 136:5,20

146:14 149:12

152:3,8,16,22

153:3 154:5,8,10

158:5 164:1,10

174:18 175:1,2,3

180:10 190:2

timer 33:7 107:12

107:20 108:1,4

121:4 135:3 136:1

137:4,14 152:3

times 14:10 15:9

75:7 135:14

178:10

timetable 29:13

time-dry 68:12

125:1,3 126:12,14

127:7 135:18

136:8,11 151:20

152:11,20 174:19

time-drying 126:16

titles 134:8

today 5:8 10:20

11:1,3 22:22

24:16,21 26:3,5

27:6 29:19,20

30:17 32:3 62:8

84:1 117:1,2

132:13 137:4

147:18 157:14

194:15 199:9

201:19

today's 5:13 66:7

110:8 149:6

tolerance 71:17

114:12 162:21,22

tolerances 71:13

111:15 162:11

163:5,9

Tom 1:20 8:13

104:8 113:22

114:1 166:11

171:1

topic 149:19 150:6

199:8

topics 201:21

total 31:4 79:7

103:9 143:12,20

144:4 151:1

178:13

totally 134:8

towels 52:11 56:15

to-lab 106:15

to-test 68:6

trade 113:5

tradition 6:16

transcript 11:18

transcripts 30:1

translate 50:21

51:5,12,17 52:19

162:21

translates 47:8

translation 50:2

travels 202:13

trend 63:22

trends 103:20

triangle 16:2

tried 27:9 189:6

true 36:10,10 101:3

189:1 195:7 196:2

197:8

truly 201:6

try 5:20 34:18 48:6

48:8,10 51:4,7

63:6 66:12 70:19

72:8 73:3 94:16

97:6 113:16 117:4

117:15 138:12

140:4 178:17

190:1 196:6

trying 43:3 45:19

50:20 52:17,21

69:22 81:9 83:14

85:20 87:7,9 91:2

92:19 94:21 97:12

105:12,18,19

110:19 111:3

118:16 124:2

125:4 131:2 155:5

186:11 190:1

tumble 90:4 123:1

tumbles 75:1

tumble-type 32:6

tumbling 78:16

79:3 85:7 90:9

99:16 123:1 126:6

128:21 129:13,20

130:8 153:12

tuned 150:3

turn 11:20 12:2

34:19 63:8 113:16

191:13 195:7

200:5 202:3

turned 105:9

138:13 154:11

159:6 194:21

turning 6:19 7:5

12:1

turns 194:22

Twelve 12:13,14

Twenty-one 80:8

twice 91:13,14

two 15:6 17:17

51:12 73:10 75:14

93:6 103:21

112:11,16 113:3

126:17 127:6

147:2 150:5

189:14 196:16

200:15

two-thirds 90:16

type 32:22 37:10

62:16 110:22

types 68:2 132:16

137:16
202-234-4433

Neal R. Gross & Co., Inc.

Page 226

typical 15:11 17:12

21:4 22:4 91:9

typically 66:1 80:2

124:22 146:6

187:2 196:13

U

UL 1:21 8:7 27:7

149:17

ultimately 50:21

189:12

unable 104:2

143:18 156:12

unbiased 26:7

uncertainty 70:10

71:1,4 142:20

143:1,2,4

unclear 28:13 45:5

134:4

undefined 48:2

undercuts 173:12

undergo 178:4

understand 23:7

25:16,19 26:2

36:5 37:9 38:1

41:5 43:22 44:7

44:10,21 45:5

47:17,21 51:8

54:2 85:19 89:14

91:3 92:20 97:13

97:14 105:2 111:3

115:5 118:17

120:12 124:3

125:5,15 128:17

131:21 140:12,13

149:10 183:3,14

185:16 191:18

understanding

55:11 65:21 93:5

105:4 125:6

126:22 168:14,17

190:2

understood 49:1

101:3

undertakes 45:15

undue 143:5

unduly 174:6

175:19 176:7

unexpected 105:10

ungarble 34:21

uniform 52:15 87:2

112:9

uniformity 110:19

110:21 111:1,4

117:22

UNITED 1:1

units 40:7,9 67:14

77:6,9 111:17

129:21 167:5

181:2

unrepresentative

184:17

unstable 145:9

updated 40:6 175:9

uppermost 159:22

160:7

urge 6:11 113:11

USC 65:13

use 14:3 16:19

18:17,18,20 22:1

31:1 35:11 42:19

50:21 51:15 58:11

64:8 65:1,14,15

76:12 86:12 88:4

88:8,9,10 89:10

89:11 91:1,4,13

98:14 99:7 114:3

114:18 121:6,9

133:20 135:4

144:20 145:17

146:9 147:15,22

163:4 164:10

174:10,20 179:9

179:11 181:22

182:13,15,19

183:1 184:18

185:10 192:1,10

193:8,16 201:9

useful 141:8

user-selectable

132:21

uses 103:7 152:11

172:5,6 178:9

utilities 8:10 96:16

112:6 116:8

195:18

utilize 44:19

utilized 26:11 48:3

109:14,15

utterly 20:1

U.S 5:6 8:5 26:20

113:5 184:10

V

valid 26:7 57:12

124:18 128:13

validation 191:18

valuable 117:3

value 90:7 114:16

143:8 160:21

198:21

values 12:7 46:18

110:7 114:9

121:21 143:16

160:15 161:2

172:8

variability 70:16

70:20

variable 44:16 72:9

variance 47:4 52:7

52:18,22 71:15

86:21 87:8,10

variances 110:7

variation 22:9,12

68:6,15 69:16

70:9 87:22 106:3

106:8,15,16

varied 58:1

varies 110:2 185:22

186:5,6

variety 49:4 52:14

62:12 83:21,21

94:7 179:13

184:20 191:8

various 70:15 81:5

99:7

vary 76:22

varying 17:10

34:12 38:16 41:20

43:16 47:8 66:14

66:22 85:3 86:2,6

88:14

vent 21:18

version 141:21

149:21 175:10

versus 65:4 86:3

133:12

vertical 112:10

vexing 196:22

virtually 14:20

visual 13:13

voltage 143:9

volume 159:15

160:2

voluntarily 181:22

Vote 141:22

W

wait 97:10

waited 189:10

waiver 183:13,18

184:14 185:3,6,7

185:14,17,20

186:7,8,13,15,20

187:2,7,19,21

188:20 189:20

190:6,11 191:1,2

191:3

waivers 187:6,10

walk 49:22

Waltner 2:4 8:15

8:15 72:16,20,20

73:7,15 129:8

130:3,18 200:7

want 5:18 11:17

13:3,3 19:12

25:11 26:6 27:13

27:16 52:3 54:13

55:5 64:13,19

66:17 82:22 97:6

99:3 104:10

122:16 128:19

140:22 147:21

157:13 176:18

182:22 193:3

197:2 202:6

wanted 22:22 64:4

68:20 75:14 99:21

101:2 128:17

139:2 179:17

201:11

wants 13:19

warm 112:19

wash 16:5,6 18:15

washed 17:8 20:8

washer 14:4,11,11

17:14 120:11

176:16 177:1,20

178:10,19 196:21

197:1

washers 18:9,14

178:2,7 195:4

197:3

washing 13:22 14:8

17:18 50:15

Washington 1:11

5:10

wasn't 27:13 106:5

139:3 189:13

wasting 41:16

water 17:4 38:22

39:2 61:6 72:3,4

102:20 103:4,10

103:11,13,14,21

104:5,5 106:7,7

106:11,21 107:1

109:1 156:1 157:3

159:12 160:4

161:12 169:20

197:4

waters 104:4

watts 146:6 157:21

way 12:20 16:15

48:8,16 70:18

86:4 95:22 96:1

96:18 99:21

101:21 102:13

139:22 179:18

186:21 190:5

wear 139:13

web 12:12,14 23:8

140:12,20

webinar 12:10

34:22 73:5 138:7

138:10 140:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 227

webmaster 140:13

WEDNESDAY 1:7

week 150:5

weigh 135:15

weighed 14:9 57:9

weighing 160:9,11

161:3

weight 17:4 161:13

196:11

weights 38:17

41:20 43:17 85:3

86:6 88:14

welcome 3:4 5:5,18

12:11 45:17 82:20

95:11 118:20

123:20 133:2

welcomed 102:14

welcoming 5:15

109:6 151:10

well-designed

101:16

went 14:11 140:7,7

195:1 202:16

weren't 101:21

wet 112:18 162:1,8

162:12 163:8

wetter 196:20

wetting 38:22

102:21 103:4

Whirlpool 24:12

whites 52:13

wide 36:15,17

58:14 62:12 76:22

110:6 169:11

widely 76:22

widen 61:12

wider 61:15 108:16

wireless 147:10

wish 12:18,18

23:21 140:20

192:1

wishes 10:1,21

194:7 198:3

Witkowski 1:15

3:4,14 4:8 5:16,17

6:6,8,10 9:2,2

13:2 29:10,11

30:12,15 45:7,11

45:13,14 187:21

200:5 202:4,5

Witkowski's 23:18

Wold 2:5 8:19,19

wonder 75:13

199:8

wondering 70:6

73:7 110:20 116:1

134:10 146:11

words 46:19 65:16

86:11 90:2 130:14

180:1

work 12:2 22:9

30:12 34:19 50:3

61:11 64:5 76:21

92:5 100:13

117:14 148:20

178:5 187:3 197:6

197:13

worked 14:17 28:4

138:12

working 23:11

148:5 191:11

world 41:21 42:8

43:5 46:22 47:5

49:4 50:18 51:6

55:13,14 64:10

99:12 112:14

worst 101:10

worth 51:2 178:15

197:21

wouldn't 87:4

129:12 154:8

174:15

wrinkle 129:21

130:9,13,22 132:8

132:8,20 153:8

154:13

wrinkle-preventi...

122:21 131:22

132:3

wrinkling 123:3

129:13

writing 46:7

written 6:11 30:4

45:18 72:11 164:2

173:19 200:13

201:13 202:8

wrong 52:5 91:4

170:9,13

X

Xerox 141:8

Y

yards 139:21

year 14:1 18:2,18

29:4 92:3 97:4

186:7 187:22

197:15 198:22

years 41:12

York 83:10

Young 2:5 7:14,15

37:13

Z

Zealand 20:11

zero 75:3 88:20,21

88:21 110:12

160:12,19 173:7

$

$100 198:21

0

0.2 160:14

0.3 160:15

0.33 108:13

0.4 67:9

0.8 28:14 94:13

95:17

0.80 85:9 133:9,20

1

1 37:2 46:20 135:8

162:20 174:21

182:20

1E 1:10

1-degree 162:4

1.04 33:6 37:21

133:9

1.18 33:8 136:2

1.3 36:2 67:11

1.4 89:15

1.5 40:5

10 111:18 155:22

157:5,21 166:21

10-12 140:16

10-15 120:19

10:30 138:9

100 17:15 20:7

139:21

1000 1:11

102 3:17

104 3:21

105 3:18

11 10:9 74:12 75:17

76:8

11:09 140:7

11:10 139:10

11:25 139:17 140:2

140:8

110 3:22

1134 18:20

12:24 202:16

12:45 10:19 11:3

120 3:18

122 3:22

13 3:9

133 3:18

134 3:22

135 3:18

136 3:22

1400 13:17

141 4:2

145 4:5

15 75:22 139:11

160:16 161:7

15-second 14:6

150 4:2

153 4:5

155 4:3

157 63:8

16 103:17

160 21:21

163 4:5

164 4:3

166 4:5

172 4:3,6

174 4:3

18th 202:9

180 182:6

1800 51:1 53:2,9

1800-plus 50:14

182 4:6

19 63:11

1900 53:2

1977 158:3

1992 15:5 19:10

20:21 113:4 179:8

2

2 39:14,15,20 40:5

41:8,18 42:4,11

43:11 48:22 49:5

49:11 50:2 54:19

57:11,13,15 59:7

59:16,20 60:11,12

60:16,20 66:18

67:9 74:6,17

75:19 76:6,10

78:5,8,22 79:8,9

80:3 85:5,12

86:12 87:17 88:5

88:19 90:1,5,8

97:16 98:6,7,9,10

98:17 99:4,6

101:4 110:11

122:7,8,12 124:17

133:14,17 135:21

162:22 163:10

2nd 29:18

2.1 157:18

2.3.2 155:20 156:16

2.4.1 160:10

2.5 41:6,10,10,13

41:14 54:3,5

135:8 174:22

20 56:6 60:9 61:8

79:17,19 80:2,4

86:8 97:21 98:14

124:12 128:11

165:20 166:2

167:2,11 169:13

170:20

20ish 80:5

20-percent 166:20

2005 24:6 194:17
202-234-4433

Neal R. Gross & Co., Inc.

Page 228

2009 27:8

2010 83:10 188:6

2011 33:11 38:10

95:20 141:16

142:3 181:5

2012 195:22

2013 1:8 5:9 29:18

2015 96:22 116:5

116:14 120:4,16

165:14 168:9,11

169:5 172:13

182:20 183:4

202 4:7

21 80:6

22 80:6,8

23 80:2,4

24 3:10

24th 195:22

24-by-36-inch 56:9

245 1:11

25 86:8 90:19

27 166:2 167:11

169:12

28 3:12

283 194:19

3

3 37:3 46:20 69:11

136:18 160:16

161:7

3-1 63:9

3.1 159:9

3.3 151:22

3.5 58:13 108:12,17

111:22

30 131:1 160:13

161:5

31 3:15

32 139:6

33 112:1 141:11

35 3:19 80:9

38 3:15

4

4 74:15 75:18 76:8

76:12 78:12,16

101:6 104:17

136:19 139:3,5

163:1 166:3

167:12 169:3

4.4 142:12

4.5 151:7

4.7 36:3 67:11

69:12 151:6,8

40 3:19 58:21 70:4

70:7 162:20 164:8

166:22

416 18:3 194:19

42 21:14 58:13

65:13

429 111:18

430(b) 183:17

45 80:10

5

5 3:2,4 35:19,19

36:7,8,18,20

46:19 48:12,17,21

50:2 54:1 57:22

60:11,20 74:5,14

75:18 78:3 79:13

80:1,4 86:16 90:5

156:4 160:21

169:6

5.0 41:6

5.3.2 144:21

50 13:15 112:12

164:9

50/50 56:10

500 160:19 161:13

53 90:22

54 109:2

5500 146:6

56 3:16

57 16:20 21:13

194:20

57.5 108:11,13

111:22 112:1

59 3:20

6

6 1:8 3:6 21:19,22

58:20 75:21 78:12

78:15

6th 5:9

60 16:19 20:19

39:17 70:4,7

104:18 127:1,1

161:16 162:20

164:9

600 161:17

61 108:21

61121 103:1 106:21

62 74:15 75:18 76:8

76:15

62301 4:3 10:12

31:1 141:17 142:2

145:15,17,19

148:17,19 154:22

155:6 175:10,16

6293 65:13 100:17

6293(e)(2) 173:15

63 3:16 193:3

64 3:20 194:4

641 18:19

67 3:16

68 3:20

69 3:16,20

7

7 155:22 163:16

70 16:18 194:20

72 74:12 75:17

162:18

73 3:17

75 3:21

77 3:17

78 162:19

79 3:21 22:7

8

8 89:11 93:13 94:19

96:3 97:20 98:12

99:9,9,15 134:6

8.45 17:5

80 16:18 166:13

84 3:17

85 3:21

9

9 3:7

9:00 1:11

9:01 5:2
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

229

Test Procedures for

Residential Clothes Dryers

US DOE

02-06-12

Washington, DC