UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

**PRELIMINARY ANALYSIS PUBLIC**  **MEETING ON** 

**RESIDENTIAL FURNACE FANS ENERGY CONSERVATION STANDARDS** 

U.S. Department of Energy 1000 Independence Ave., SW Washington, D.C. 20585 Room 8 E

- 089 Review Center

Fri day Ju ly 27 , 2012

**Facilitator:**

Doug Brookman Public Solutions Baltimore, MDExecutive Court Reporters (301) 565

- 0064 2 **Participants Identified:**

Karim Amrane AHRI

Timothy Ballo Earth Justice

Alex Boesenberg NEMA

Rob Boteler Midec Motor Corporatio n

Adam Christiansen Appliance Standards Awareness Project

Michelle Cox ... Blake Corporation

Abigail Dakem EPA

Tom Eckman Northwest Power and Conservation Council

Michel Evanovich Air Movement and Control Assoc. International, Inc.

Diane Jakobs Rheem Manufacturing Company

Brian James Southern California Edison

Paul Lin Regal Beloit

Joanna Mauer Appliance Standards Awareness Project

Sarah Medepalli ICF InternationalExecutive Court Reporters (301) 565

- 0064 3 Craig Messmer Unico, Incorporated

David Ransom, Esquire McDermott Will & Emery

St eve Rosenstock Edison Electric Institute

Aniruddh Roy Air Conditioning, Heating, and Refrigeration Institute

Charlie Stephens Northwest Energy Efficiency Alliance

Greg Wagner Morrison Products

Meg Waltner Natural Resources Defense Council

Ted Williams American Gas Association

Dave Wi nn ingham Allied Air Enterprises , Lennox

**Participants from DOE:**

Michael Kido DOE General Counsel’s Office

Mohammed Khan DOE

Ashley Armstrong Department of Energy

Brenda Edwards Department of EnergyExecutive Court Reporters (301) 565

- 0064 4 **P articipants f**  **rom Consultants:**

Sam Jasinski Navigant Consulting Incorporated

Christopher L au Navigant Consulting

Detle f Westphalen Navigant Consulting

Alex L e k ov Lawrence Berkeley National Laboratory

Victor Fran c o Lawrence Berkeley National Laboratory

Gregory Ros enquist Lawrence Berkeley National Laboratory

Bingyi Yu Lawrence Berkeley National Laboratory

**Participants via the web:**

Rachelle C ocks Regal Beloit

Terr ell Small Mortex

Anush Mystery (ph)

Dan Williams

Jim Vershaw

John Hunley

Linda Wilson

Tom Cha seExecutive Court Reporters (301) 565

- 0064 5 **AGENDA**

**ITEM PAGE** 

Welcome, Doug Brookman 6

Welcome for DOE, Mr. Khan 6

Introductions 7

Agenda Review , Doug Brookman 10

Introductory Remarks and Overview Mr. Khan 13

Opening Statements 1 4

Meeting Overview, Mr. Khan 26

Market and Technology Assessment , and Screening Analysis Mr. Jasinski 32

Engineering Analysis Mr. Jasinski 85

Markups, Energy Use Characterization LCC and Payback Period analysis Mr. Lekov 1 4 4

National Impact Analysis, Shipments Analysis Mr. Lekov 225

National Energy Savings, Net Present Value, Mr. Lekov 239

Manufacturer’s Impact Analysis Mr. Jasinski 249

Final Comments of interested parties 2 59

Closing Remarks, Mr. Khan 2 64Executive Court Reporters (301) 565

- 0064 6

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

MR. BROOKMAN: Let’s get started. Good 2

morning every one and w elcome . This is the U.S. 3

Department of Energy’s P reliminary Analysis Public 4

Meeting on Residential Furnace Fans Energy 5

Conservation S tandards. 6

To day is Fri day, July 27, 2012 at the U.S. 7

Department of Energy here in the Forrestal Building. 8

My name is Doug Brookman from Public Solutions in 9

Baltimore. 10

We’re going to start off this morning with 11

welcoming remarks from Mohammed Khan. 12

(Discussion about problems with microphone.) 13

Okay. I’ll speak loudly. We are going to 14

start with welcoming remarks from Mohammed Khan , 15

Department of Energy. 16

**Welcoming Remarks** 17

MR. KHAN: Good morning

. Mohammed Khan , 18

Department of Energy

. F irst , I w ant to thank you for 19

participating today

. As you’ll find out, we have a 20

lot of material to cover and we’re going to be 21

appealing to you for your comments and input on this 22Executive Court Reporters (301) 565

- 0064 7 material. We were here just over a month ago, having 1

a meeting on the related rule making that we’re doing, 2

which is the test procedure for furnace fans, and I 3

think I see a lot of you here again today, and that’s 4

great. And what I said at that meeting was of your 5

comments are very important, but also explained that 6

this rulemaking is u nique really for two reasons. 7

One, it’s a first time that we’re developing a 8

standard and test procedure for furnace fans. The 9

other reason is that it’s a product that is already a 10

part of

– or is a component of a product that we 11

already cover. So that’ s basically unchartered 12

grounds, in a sense, but we look forward to your input 13

today and I look forward to a g reat discussion. 14

MR. BROOKMAN: Thank you. Let’s start with 15

introductions. I’ll start over here to my left , 16

please

. S ay your name and orga nizational affiliation, 17

and you can get used to turning the microphone s both 18

on and off . If we leave them on, then we get feedback 19

in the system, please

. 20

**Introduction s**  21

MR. BOTELER: Rob Boteler. I work for Nidec 22

Motor Corporation in St. Louis and I cha ir the energy 23

committee for NEMA, the National Elect rical 24

Manufacturers Association. 25Executive Court Reporters (301) 565

- 0064 8 MR. BROOKMAN: Thank you. 1

MR. LIN: Paul Lin, with Regal Beloit 2

manufacturer of electric motors

. 3

MR. BOESENBERG: Alex Boesenberg, National 4

Electrical Manufacturer s Association, regulations

. 5

MR. MESSMER: Craig Messmer, with Unico, 6

Incorporated in St. Louis

. 7

MR. WAGNER: Greg Wagner, with Morrison 8

Products. 9

MS. JAKOBS: Diane Jakobs, with Rheem 10

Manufacturing

. 11

MR. ROY: My name is Aniruddh Roy, Air 12

Condition ing, Heating, and Refrigeration Institute. 13

MR. CHRISTIANSEN: Adam Christiansen with 14

the Appliance Standards Awareness Project. 15

MR. WILLIAMS: Ted Williams, American Gas 16

Association. 17

MR. JAMES: Brian James, Southern California 18

Edison. 19

MR. WINNING HAM: Dave Winningham, Allied 20

Air, and Lennox. 21

MR. ROSENSTOCK: Steve Rosenstock, Edison 22

Electric Institute. 23

MR. ECKMAN: Tom Eckman, Northwest Power and 24

Conservation Council. 25Executive Court Reporters (301) 565

- 0064 9 MR. KIDO: Michael Kido, Department of 1

Energy, Office of General Council. 2

MR. KHAN: Mohammed Khan, DOE. 3

MR. BROOKMAN: Please. Stand up. 4

MR. WESTPHALEN: Detlef Westphalen, Navigant 5

Consulting. 6

MR. JASINSKI: Sam Jasinski, Navigant 7

Consulting. 8

MR. FRANCO: Victor Franco , Lawrence 9

Berkeley National Laboratory. 10

MR. L EKOV: Alex Lekov, Lawrence Berkeley 11

National Lab. 12

(Several inaudible introductions.) 13

MS. MAUER: Joanna Mauer, Appliance 14

Standards Awareness Project. 15

MR. RANSOM: McDermott Will and Emery. 16

MR. BROOKMAN: And let me just note for the 17

record that t hose of you that didn’t speak into a 18

microphone, we didn’t get all your names on the 19

record, but most of you have

-- hopefully all of you 20

registered so we know who’s here. 21

One thing we have been doing recently is 22

we’ve been asking those who have been joi ning us via 23

the web to read their names so we know who is joining 24

us via the web. Can you do that, and their 25Executive Court Reporters (301) 565

- 0064 10 organizational affiliations are also there, that would 1

be a good thing. They’re not, just names. Okay. 2

WEBMASTER: So we’ve got Anush Mystery (ph), 3

Dan Williams, Jim Vershaw, John Hunley, Linda Wilson, 4

Rachelle Cox, Terry Small, Tom Chase, and that’s it. 5

MR. BROOKMAN: Thanks to those of you that 6

are joining us via the web. 7

**Agenda Review** 8

MR. BROOKMAN: All of you received a packet 9

of informa tion as you came and registered this 10

morning. Please take a peek at that, particularly the 11

agenda, that’s where I’m starting with a brief review. 12

F ollowing this agenda review we’re going to 13

have an overview presentation, the purpose of the 14

public meet ing, regulatory authority and rulemaking 15

from Mohammed. Following that, those introductory 16

remarks, there’s an opportunity for anybody who wishes 17

to do so to make opening statements, summary 18

statements surrounding the issues that are of concern 19

to you tod ay. 20

And then from there we’ll launch straight 21

into the more detailed comment that’s in this Power 22

Point packet that all of you received. Market and 23

technology assessment and screening analysis. 24

We’ll take a break mid

- morning, round about 1 0: 4 5 25Executive Court Reporters (301) 565

- 0064 11

or so. Following that, engineering analysis, 1

following that, markups, energy use characterization 2

and LCC and payback period analysis. 3

W e’ll take lunch round Around about 12:30 or 4

so. Immediately following lunch, or whenever we get 5

there, LCC and payback period analysis continued, then 6

national impact analysis. We’ll take a break mid

7

afternoon, preliminary manufacturer impact analysis, 8

next steps in the late afternoon, 3:30 or so, and then 9

finally, closing remarks, another opportunity for 10

any body who w ant s to, to make additional comments or 11

statements. So two opportunit ies for open ended 12

comment. We do hope, however, that the bulk of the 13

commentary will be focused in on the content that’s 14

being presented because that will keep it organized 15

for us. 16

I’d ask for your consideration , if you 17

would, please

. Many of you have attended these 18

meetings previously. Please speak one at a time. 19

Please s ay your name for the record each time you 20

speak. I’m going to be cuing individuals by name as 21

best I can

. I a lso w ish to encourage follow on 22

comments , sometimes the back and forth is very useful 23

for the Department as they ’re try ing to consider this 24

information. 25Executive Court Reporters (301) 565

- 0064 12 If you keep the focus here, turn your cell 1

phones on silent mode, limit the sidebar 2

conversations . You will need to turn these 3

microphones on and off please. We do have many web 4

participants joining us. If those of you joining us 5

via the web, if you would keep your telephones on 6

mute, it will limit the amount of feedback we receive 7

here in the room, and if you raise your hand, then we 8

will find a way to fit you into the conversation as 9

best we can that’s going on here. So please feel free 10

to join us and be proactive. 11

And then finally, as there are 100

- and 12

however many slides here, a lot of slides, I would ask 13

for your consideration, please try to be concise 14

today , share the air time. There’s a lot to cover. 15

We’re going to do it very efficiently, I know we will, 16

and so that’s the task for the day. Questions and 17

comments on any of this ? 18

Okay, so then, we’re going to start off 19

then, Mohammed Khan. And Mohammed, I’ve been asked, 20

please use the Lavaliere microphone, as the other one 21

provides feedback

. You want to hit the microphone and 22

introduce yourself, name and organizational 23

affiliation. 24

MS. DAKEN: Abigail Daken, US EPA, Energy 25Executive Court Reporters (301) 565

- 0064 13 Star Program. 1

MR. BROOKMAN: Thank you. 2

**Purpose of Public Meeting, Overview** 3

MR. KHAN: Good morning everyone. T hank you 4

for participating in today’s meeting on the U.S. 5

Department of Energy’s preliminary analys is on energy 6

conservation standards for residential furnace fans. 7

My name’s Mohammed Khan and I’m the project manager 8

for this rulemaking activity. 9

Today’s meeting serves multiple purposes. 10

Mainly, our goal is to have a two

- way discussion. We 11

want to convey the key points and concepts associated 12

with this rulemaking, as well as to hear and listen to 13

your thoughts and potential concerns. 14

**•** So first the Department wants to present its 15

methodologies and characterize its analysis to 16

date. 17

**•** Second, DOE wants to discuss specific issues 18

and invites comment from all participants at 19

today’s meeting , on the methodologies, 20

assumptions and data sources used in the 21

preliminary analyses

. 22

**•** Th e la s t thing we want to describe the 23

downstream analyses and next steps in th e 24Executive Court Reporters (301) 565

- 0064 14 rulemaking process. 1

But as Doug mentioned, if anyone has an 2

opening statement they want to make, we can allow 3

that. 4

MR. BROOKMAN: So let’s have opening 5

statements. We’ll hear from Diane first. Please get 6

that microphone close to you. 7

**Introductor y Statements**  8

MS. JAKOBS: I don’t know, I’m just assuming 9

that Sam did a lot of this work, and I just want to 10

compliment him on the breadth of it. It’s really 11

intimidating, all the detail. And just

– I tried to 12

go through it. I’ve got all my post it n otes and 13

things, and just in general, I think some of the 14

costing

– I checked with our procurement people and we 15

might be using some of your numbers in our 16

negotiations with Nidec and Regal Beloit, I think. It 17

looks like you got a better deal than we do

. And you 18

used, it seems, like from ASHRAE 103 E

- sub

- AE, so I 19

was kind of on familiar ground with that in some of 20

your analysis, so that was good. 21

We did

– you were asking us for data, and 22

I’m on

-- AHRI, we have been trying to collect data 23

and just in ou r lab only, it was like Friday and 24

Monday we got FER data for three samples and it looks 25Executive Court Reporters (301) 565

- 0064 15 like your numbers are a little low compared to mine. 1

So just in general, I think there’s a lot of good 2

engineering work and certainly some economic analysis 3

that I th ink I can learn a lot from, but I was very 4

impressed. Thank you. 5

MR. BROOKMAN: Thank you, Diane. Thank you. 6

Other comments here at the outset. Your name, please. 7

MR. ROY: Aniruddh Roy, Air Conditioning, 8

Heating, and Refrigeration Institute. We’d like to 9

make one comment with respect to the timing of today’s 10

meeting. The test procedure has not been finalized 11

yet and comments or the deadline for providing 12

comm ents on the test procedure is July 30 th . And so we 13

just wanted to comment on the ti ming of the energy 14

conservation standards meeting. Because I think a 15

bunch of the stakeholders are going to be submitting 16

comments, or expected to provide something to DOE by 17

July 30 th , and so we feel that the timing of this 18

meeting is inappropriate, espe cially given the fact 19

that that analysis takes into account the FER metric 20

which hasn’t been

– at least the test procedure hasn’t 21

been finalized yet. 22

MR. BROOKMAN: Okay. Thank you. Yes, Adam. 23

MR. CHRISTIANSEN: This is Adam from ASAP. 24

I’ve got som e prepared comments that I’d like to 25Executive Court Reporters (301) 565

- 0064 16 submit for the record. So the Appliance Standards 1

Awareness Project leads a broad

- based coalition effort 2

that works to advance standards which deliver large 3

energy savings, monetary savings, as well as 4

environmental be nefits. Thank you for the opportunity 5

to participate in today’s workshop. We very much 6

appreciate the significant work of DOE and its 7

contractors to advance this important docket

. 8

Standards for residential furnace fans have 9

potential to deliver large benefits. Per DOE’s 10

analysis in the PTSD we’re going to discuss today, the 11

energy savings from these products could be as high as 12

1.67 quads of primary energy. The national economic 13

benefits of a strong, but reasonable standard could 14

total between $3.8 a nd $10.7 billion dollars over the 15

life of the standard. 16

In general, we think the approach DOE has 17

taken in this docket is reasonable. We are pleased to 18

see that DOE has taken steps to address the 19

complicated aerodynamics in cabinets. As DOE has 20

noted these effects influence ultimate energy 21

consumption of furnace fans. We’re also very 22

supportive of an energy standard being developed on a 23

rating method that includes measurements from multiple 24

operating points. Single point rating methods are 25Executive Court Reporters (301) 565

- 0064 17 simply no t adequate to capture the complicated 1

operation of a furnace fan in a meaningful way. 2

One area of concern for us that I’d like to 3

highlight is the issue of the scope of coverage. DOE 4

has excluded split system central air conditioning and 5

heat pump b lowe r coil units and single package central 6

air conditioning heat pump units in the preliminary 7

analysis. These products represent about 37 percent 8

of products that contain furnace fans. It is unclear 9

to us that the SEER and HSPF ratings fully capture the 10

fu rnace fans. We think DOE should consider including 11

in this rulemaking, air handlers that are part of a 12

blower coil and single package central AC and heat 13

pump systems. And we hope today’s hearing will offer 14

an opportunity to discuss the issue. 15

Again, w e look forward to participating in 16

the hearing and engaging with DOE and other 17

stakeholders in this rulemaking process and we’re 18

looking forward to the discussion today. 19

MR. BROOKMAN: Thank you. I’m going to ask 20

each of you to speak up. Hey, Greg, are you hearing 21

okay back there now? Is it getting any better? 22

Crackling. Yeah, we’ve got a guy working on it. 23

We’ll see if we can improve that. There’s also a fair 24

amount of feedback up here in the front, I don’t know 25Executive Court Reporters (301) 565

- 0064 18 whether everybody can hear that or not, but we’ll be 1

working on it. 2

Karim, did you have a comment here at the 3

outset? Get to the microphone, please. 4

MR. AMRANE: Karim Amrane, AHRI. I just 5

wanted to restate a little bit this issue of the 6

timing here. I think DOE has a process rule that 7

basically lay out how things have to be done. They 8

have to be done, and test procedures must come before 9

energy efficiency standard. And here we are doing two 10

things at the same time. DOE has spent a lot of time 11

doing this analysis based on this m etric that may or 12

may not be what was going to end up being as test 13

procedures. So again, either we are wasting our time 14

today or DOE has already decided that that’s going to 15

be the metric. So I would like to understand why DOE 16

is doing two things at the same time. I would like an 17

answer from DOE, maybe legal counsel as well. 18

MR. BROOKMAN: Do you want to do that now? 19

I’m looking at Michael Kido. 20

MR. KIDO: The timing for this particular 21

activity, just to emphasize, we’re at a preliminary 22

stage righ t now. There’s no proposal right now with 23

respect to the standards. My understanding is that 24

with respect to the analysis that we’ve got right now, 25Executive Court Reporters (301) 565

- 0064 19 because it’s preliminary, it is based on the procedure 1

that has been proposed earlier. So this is an atte mpt 2

to try to get some feedback with respect to the 3

overall approach that the Agency is considering. 4

If there’s a need for additional time to 5

analyze what it is that the Agency is considering as 6

part of today’s meeting, we can consider possibly 7

looking at providing a longer comment period. That’s 8

something that we could look at. But I think the way 9

that you should view this particular meeting, it’s one 10

that’s purely preliminary in nature. 11

MR. BROOKMAN: Okay. Thank you. Other 12

comments here at the outset? Alex, please. 13

MR. BOESENBERG: Alex Boesenberg, National 14

Electrical Manufacturers Association. I want to thank 15

the Department for welcoming us here today and ... a 16

month without a public meeting is ... (Problem with 17

microphone.) So we weren’t sure if we needed to come. 18

In fact, it was sort of a hunch to attend. We knew 19

there were motors that drove fans, so we thought we’d 20

show up, and the number of people who have said, oh, 21

boy, we’re glad you’re here, makes us glad we came. 22

My members will b e listening from a motor 23

standpoint. I’m going to be listening from a slightly 24

larger systems standpoint as Mr. Khan already alluded 25Executive Court Reporters (301) 565

- 0064 20 to, the fan itself is not only a component of a 1

previously regulated product, but also there’s a fan 2

in the housing of the motor that drives it and other 3

effects. And I’m going to be watching for how the 4

system is discussed because of the precedent that that 5

sets for some of the rulemakings we have where it’s 6

pretty hard to divorce the individual components. So 7

I’m very int erested in seeing how the Department 8

approaches that and what that bodes for some of our 9

other rulemakings that involve composite systems. 10

Thank you. 11

MR. BROOKMAN: Thank you. Yes, it is Craig, 12

right? 13

MR. MESSMER: Craig Messmer. I want to let 14

eve rybody rest assured that I will not be talking 15

about small duct high velocity at this meeting, since 16

it is excluded, thank you very much. But I will keep 17

my comments to the topics, and the technical support 18

document weighs about six and a half pounds, so you 19

get an A

- plus on the report. Thank you. 20

MR. BROOKMAN: Okay. Steve Rosenstock. 21

MR. ROSENSTOCK: Steve Rosenstock, EEI. 22

Again, thank you. I thought the Department did a good 23

job with the technical support document. We will have 24

comments, but I think there’s some really bigger 25Executive Court Reporters (301) 565

- 0064 21 issues for the Department in terms of not just 1

furnaces and air conditioners, but also other products 2

where t hey’re looking at components. For example, the 3

DOE has rules on battery chargers now. Well, battery 4

chargers a re components of dozens and dozens of 5

products, and so it’s always interesting, you look at 6

the component, you make it more efficient, but what 7

are you doing to the whole product? Is it making the 8

whole product more efficient or are there laws of 9

unintend ed consequences where the product can be

– 10

you’re not changing the efficiency of the whole 11

product, or even worse, you’re actually increasing the 12

energy usage of the whole product. 13

And I think going forward, there is possibly 14

going to be a resource iss ue. You have a furnace fan 15

rulemaking, you have an air conditioner heat pump 16

rulemaking, you have a furnace rulemaking, and do you 17

do them all together? Do you do them separately? You 18

know, three separate tracks? You’re kind of talking 19

about energy use for heating and cooling. 20

So I think going forward, this component 21

versus system is going to be a bigger issue, not just 22

in terms of energy, but in terms of resources of DOE 23

and stakeholders. Thank you. 24

MR. BROOKMAN: Thank you. Steve was 25Executive Court Reporters (301) 565

- 0064 22 speakin g clearly. Greg, was that better or the same? 1

MR. WAGNER: The same. 2

MR. BROOKMAN: Okay. 3

MR. WAGNER: Actually, that microphone is 4

very clear. 5

MR. BROOKMAN: Okay. We’re still working on 6

it. Yes, please, Dave. 7

MR. WINNINGHAM: Dave Winningh am, Allied 8

Air. First of all, I’d like to thank the Department 9

for the detail of the work that went into this. A 10

couple of key issues, I think, that the Department 11

needs to consider. 12

The increasing burden that this and other 13

metrics are placing on the HVAC manufacturers is 14

increasing. As this proliferation of metrics 15

increase, these costs are going to be passed along to 16

the consumer. The net result of this could 17

potentially be a reduction in the affordability of the 18

products within this industry. I t hink we’ve seen 19

some of that as we went from 10 SEER to 13 SEER. 20

While the energy conservation side of this 21

is very important, we need to look at ways that we can 22

reduce the burden of this and other metrics. The test 23

procedure that has been proposed is a completely 24

separate set up, completely separate test procedure 25Executive Court Reporters (301) 565

- 0064 23 than the AFUE test procedure that is applied to the 1

majority of the products that this is referenced to. 2

I would ask

– and we will make comments in 3

regard to the test procedure

– that the D epartment 4

look at ways that the data needed for these metrics be 5

aligned with other test procedures and test setups. 6

I would also like to comment and second 7

Diane’s findings that some of the assumptions going 8

into

– in regard to the cost differential of the 9

components, as well as the performance of the 10

products, needs to be reviewed thoroughly. I would 11

agree that we could use some help negotiating our 12

motor prices, because they don’t align with the 13

Department’s assumptions. 14

MR. BROOKMAN: Okay. Thank you. Greg. 15

Thank you for getting that close. 16

MR. WAGNER: Greg Wagner, Morrison Products. 17

I want to echo the gentleman’s sentiments from the 18

Edison Electric Institute. The combined rulemaking 19

process of all the various standards that go into the 20

vari ous appliances creates a huge burden to comply 21

with each one of these regulations. In addition to 22

that, appliances being regulated as components versus 23

being regulated as systems can lead to sub

- optimal 24

systems, rather than optimal overall energy use. 25Executive Court Reporters (301) 565

- 0064 24 I n this case we’re looking at electrical 1

energy versus performance of the appliance in the 2

furnace case. Consumers are going to be looking at 3

two different numbers, and they’re going to have to 4

make a decision on which number is more important, the 5

electri cal or the furnace performance. So the 6

question is going to be, how do they evaluate and how 7

do they make choices based upon these two different 8

numbers. So combining standards to where it reduces 9

the regulatory burden is good. It also helps the 10

consume r in making the appropriate choice for energy 11

efficient designs. 12

MR. BROOKMAN: Okay. Other comments here at 13

the outset? We have one individual, Terrell Small has 14

raised his hand. Terrell, unmute your phone and 15

hopefully as you speak, you should come here into this 16

room. 17

MR. SMALL: Doug, can you hear me? 18

MR. BROOKMAN: Yes, we can hear you but 19

speak up. 20

MR. SMALL: Yes, Doug. First, I’m sorry 21

that I’m not up there. This is Terry Small with 22

Mortex, and I ’m sorry I’m not up there with you guys. 23

I want to thank Mohammed and his team at DOE for all 24

the hard work that went into this, including Sam and 25Executive Court Reporters (301) 565

- 0064 25 his team, and of course you, Doug, for moderating it. 1

We’re a small manufacturer that builds 2

products in some of the niche markets that would be 3

impacted by this. Some of the slices of the pie chart 4

in the summary, the very thin ones, are where we are. 5

And this is going to be a big burden on us , and of 6

course our customers who will ultimately have to pass 7

the cost of doing all this through to , pa rticularly in 8

this weak economy

. We build to order, very low 9

quantities. Some models that we offer are never built 10

during the year, so the burden of having to test 11

something that you’re not selling is going to be 12

particularly bad. I would highly recomme nd that AEDM 13

be allowed that perhaps would lessen some of the 14

testing burden. 15

We also disagree with some of the production 16

cost. We pay a lot more for our motors than is 17

basically described in some of the economic analysis, 18

so that in my mind, calls into question some of the 19

initial economic analysis that was done. 20

And finally, I agree with Diane and the 21

group that the values, what are called baseline 22

values, look like to me that they may have been 23

generated from published data, you know, which is 24

m aybe not the best way to generate that stuff. The 25Executive Court Reporters (301) 565

- 0064 26 published data is based on ASHRAE 103, and whereas the 1

test NOPR that DOE is proposing is amped (ph) at 210. 2

I think that table is just completely premature. 3

We’re thinking that some of our values will b e above 4

those values that are in that table. 5

But anyway, thank you for allowing us to 6

participate in this. 7

MR. BROOKMAN: Yes, thank you. Terry, and 8

to all of you via the webinar, the Department does 9

wish to make this accessible to you, so if you wish to 10

speak, raise your hand and we’ll fit you in. Final 11

comments here at the outset before we move on. Okay, 12

then to Mohammed. 13

**Overview** 14

MR. KHAN: First, let me thank everyone for 15

those really good comments. I think it is on, let me 16

just speak up. Aga in, let me just first thank 17

everybody for those very good comments. Those were 18

comments that

– those are the kinds of comments that 19

we’re looking for. Let me also add that with those 20

comments, I’d like to get written comments and 21

certainly any kind of da ta or information that you 22

might have to support some of the assertions that I 23

just heard. And, for example, the gentleman here to 24

my left mentioned that in trying to bolster the 25Executive Court Reporters (301) 565

- 0064 27 performance of the fan and motor assembly, it could 1

have some unintended con sequences, such as reducing 2

the overall furnace performance, and there’s a risk of 3

a consumer having to trade off one for the other. I 4

think what I’d be interested in knowing is how far can 5

we actually push that motor performance

– fan assembly 6

performanc e before there actually is a decline in the 7

entire system? So if there’s any kind of data , 8

modeling, or information that you have on that, that 9

would be great. So with that, I’m going to resume my 10

presentation. 11

Comments. Comments are central to the 12

su ccess of this rulemaking. All participants are 13

encouraged to submit summary comments and raise any 14

additional issue relevant to the rule. As indicated 15

in the Federal Register notice which was published on 16

July 10 th , the close of the comment period is Sep tember 17

10 th

. 18

Let me also point out here on this slide, 19

the sample call

- out box. We will use these throughout 20

our presentation to identify certain issues the 21

Department seeks detailed information on. For 22

reference, please note that the numbering of th e issue 23

boxes correspond to the issues listed in the executive 24

summary of the technical support document. 25Executive Court Reporters (301) 565

- 0064 28 Again, because your feedback is very 1

important, I want to make sure everyone is clear on 2

how to submit comments. This slide provides the 3

postal, co urier, and e

- mail addresses which are 4

appropriate for submitting your comments. Please 5

include the information here at the top so that your 6

comment is properly identified and catalogued. While 7

not provided on this slide, you may also submit 8

comments via www.regulations.gov . Regulations.gov is 9

a new, on

- line tool for submitting comments on all 10

federal government proposed rules. Let me also point 11

out again that the comment period closes on September 12

10 th

. 13

**Meetin g Overview**  14

This slide outlines the agenda for today’s 15

meeting. Following my introduction and overview, we 16

will discuss all of the preliminary analyses including 17

the market and technology and screening analysis, 18

engineering analysis, and all other analys es presented 19

here before we describe the next steps. 20

So what’s driving this effort? The Energy 21

Policy and Conservation Act, as amended by the Energy 22

Policy Act of 2005, charges DOE to establish 23

applicable energy conservation standards or energy use 24

stan dards for electricity use for the purposes of 25Executive Court Reporters (301) 565

- 0064 29 circulating air through ductwork. After being amended 1

in 2007 by the Energy Independence and Security Act, 2

EPCA requires DOE to address standby mode and off mode 3

energy use in its standards that are adopted af ter 4

July 20 10. EISA 2007 also says that the energy use 5

associated with standby mode and off mode must be 6

integrated into the energy conservation standard 7

unless existing standards already account for standby 8

mode and off mode, or integration is not techni cally 9

feasible. If integration is not technically feasible, 10

EPCA requires separate standards for standby mode and 11

off mode energy use. 12

This slide summarizes the Department ’s 13

activities for furnace fans to date. As I said at the 14

outset of our meeting, D OE currently does not have a 15

test procedure or standard for furnace fans, but has 16

made significant progress. For the test procedure 17

which DOE is developing in parallel to the standards 18

rulemaking, DOE published a Notice of Proposed 19

Rulemaking on May 15, 2 012, and on June 15 it held a 20

public meeting. The comment period for the test 21

procedure NOPR remains open until July 30 th . I 22

encourage all of you to submit comments on the test 23

procedure NOPR, so please appreciate that there are 24

only three days left to d o so. 25Executive Court Reporters (301) 565

- 0064 30 The energy conservation standard effort was 1

initiated on June 3, 2010 when the Department 2

published its framework document for its standards 3

rulemaking. DOE then solicited and heard comments 4

regarding the framework document at its June 18, 2010 5

pu blic meeting. 6

And today we’re holding our public meeting 7

for the preliminary technical support document which 8

DOE published a notice for just over two weeks ago on 9

July 10 th . I’d like to remind you that the comment 10

period for this phase of the rulemak ing closes on 11

September 10 th

. 12

One last point on this slide, DOE ’s 13

preliminary analyses also was conducted using the test 14

procedure proposed in the NOPR. And again, comment 15

period for that ends July 30 th

. 16

DOE proposed a performance metric for 17

furnace f ans that provides a measure for annual 18

electricity consumption, normalized by annual 19

operating hours and air flow. The FER equation 20

reflects cooling, heating, and constant circulation 21

operating times. Integrated fan efficiency rating or 22

IFER modifies FER to account for standby mode and off 23

mode operation, and is applicable to hydronic air 24

handlers. 25Executive Court Reporters (301) 565

- 0064 31 In deciding whether a new or amended 1

standard is economically justified, DOE must determine 2

whether the benefits of the standard exceed its 3

burdens. DOE is directed by EPCA to consider seven 4

factors in making this determination. This slide 5

lists the seven factors as well as the corresponding 6

analyses that DOE performs. Throughout the day we 7

will be describing the analyses in detail to make the 8

relevance and relationships between each analysis and 9

the seven EPCA factors. 10

This slide depicts the rulemaking stages and 11

shows the sequence and relationships between the 12

various analyses the Department conducts. DOE is 13

currently in the preliminary activities phase wherein 14

it conducts the sets of analyses shown here. What’s 15

important to recognize here is that the results or 16

outputs of the proceeding analyses are inputs to the 17

downstream analyses. Because of this relationship, 18

it’s important for the Department to r eceive your 19

input on its methodologies and any relevant data to 20

help insure accuracy and completeness. 21

Now just in case you haven’t already fully 22

read each page of the Federal Register notice, and the 23

17 chapters and the 17 appendices of the technical 24

su pport document, we prepared this slide to point out 25Executive Court Reporters (301) 565

- 0064 32 the key documents that describe the preliminary 1

analysis activities. 2

**•** First is the executive summary that provides an 3

overview of the preliminary activities in the 4

TSD, summarizes key analysis results and lists 5

the issues that the Department seeks your comment 6

on. 7

**•** Chapter two of the preliminary TSD provides a 8

review of analyses and a discussion of the 9

comments DOE received from interested parties on 10

the framework document, including DOE’s 11

interpretations an d responses. 12

**•** And finally, the Federal Register notice itself, 13

which discusses in a broader sense, the 14

rulemaking process, the preliminary activities 15

analyses, and where to find the relevant 16

documents on the DOE web page. 17

This concludes my portion of the 18

presentation and we’ll proceed with the market and 19

technology assessment and screening analysis portion. 20

MR. BROOKMAN: Next we’re going to hear from 21

Sam Jasinski. 22

**Market and Technology Assessment and** 23

**Screening Analysis** 24Executive Court Reporters (301) 565

- 0064 33 MR. JASINSKI: Thank you, Mohamm ed. My name 1

is Sam Jasinski from Navigant Consulting. I’m going 2

to start by providing or giving a discussion about the 3

market and technology assessment with a lead into the 4

screening analysis. As Mohammed showed you, we 5

provided these roadmaps to just t o kind of show you 6

how each analysis fits into the broader scope of the 7

rulemaking process. 8

The market and technology assessment has two 9

essential parts, the market assessment and the 10

technology assessment. The purpose of the market 11

assessment is to p rovide a quantified and qualified 12

characterization of the furnace fan, and in this case, 13

residential HVAC market. As Mohammed described, the 14

earlier

– Mohammed described the statutory language 15

that’s driving this rulemaking. DOE has interpreted 16

that lang uage to provide a tentative definition for 17

furnace fan. Furnace fan means any electrically 18

powered device used in a residential heating, 19

ventilation, air conditioning product for the purpose 20

of circulating air through the ductwork. 21

DOE realizes that a significant number of 22

products may fit this broad interpretation of the 23

statutory language and the resulting definition. So 24

this graphic here tries to provide a summary of HVAC 25Executive Court Reporters (301) 565

- 0064 34 products or key HVAC products that contain a furnace 1

fan, include a furnace fa n, according to this 2

definition. I don’t know how easy that is for 3

everyone to see, but essentially the HVAC system here 4

is simply applied to indoor and outdoor units. And 5

the boxes in red indicate the components of HVAC 6

systems that contain a furnace fa n according to that 7

definition. 8

On the left you can see a lone outdoor unit, 9

it says weatherized and packaged unit. That’s 10

essentially an entire HVAC system in itself. And to 11

the right, leading out from the condensing unit

– can 12

you read this graphic? Each path represents a unique 13

system. So for instance, a condensing unit can be 14

paired with a coil only unit, and then a coil only 15

unit can be paired with an electric furnace and 16

modular blower. So that particular path would 17

represent one variation of an HVAC system, and so 18

forth. 19

As I mentioned, DOE realizes that a 20

significant number of HVAC products contain a furnace 21

fan according to that definition. The provisional 22

scope of coverage includes furnace fans that are 23

integrated in 63 percent of furnac es, air 24

conditioners, and air handling units that include 25Executive Court Reporters (301) 565

- 0064 35 furnace fans. 1

In this pie chart here, provides a market 2

share according to the same products that were shown 3

in the previous graphic by shipments. The products to 4

the left that are in black are those that are 5

excluded, are not considered in this rulemaking, and 6

those include single package central air conditioners 7

and heat pumps, as well as split central air 8

conditioners and heat pump or coil units. The 9

remainder of the

– yes. 10

MR. BROOKMAN: Let’s

– Diane first. Go 11

ahead. 12

MS. JAKOBS: Okay. Would you mind just 13

going back a slide? So when you talk about coil only 14

unit, I was trying

– are you referring to like coil 15

only ratings that we do? 16

MR. JASINSKI: Here this is just a 17

representation of the product. So that would be the 18

coil only component of a larger HVAC system. 19

MS. JAKOBS: Well, what’s a coil only unit? 20

MR. JASINSKI: That’s the

– what you’re 21

referring to, that would be something

– it’s not the 22

coil only rating, it’s a coil that would be paired 23

with a furnace, or with a modular blower. It’s 24

essentially just the

– it’s a coil that would be 25Executive Court Reporters (301) 565

- 0064 36 paired with a condensing unit. 1

MS. JAKOBS: Oh, okay. So you’re talking 2

about the coil only, so the homeowner buys it as a 3

component a nd then it’s matched with

– 4

MR. JASINSKI: Yes. 5

MS. JAKOBS: Okay. Thank you. 6

MR. JASINSKI: Anybody else? 7

MR. BROOKMAN: Dave and then Abigail. 8

MR. WINNINGHAM: Yes, it appears as if you 9

have a conflict in between your information. You show 10

the indoor unit as a blower coil unit being covered in 11

this slide. In the next slide, you show it not. And 12

then in the introduction, 1.2 Excluded products, it 13

specifically calls that, you know, “Excluded products, 14

other products that incorporate furnace fans such as 15

central air conditioning, CAC floor coil units. 16

MR. JASINSKI: So it might be a little bit 17

easier if these graphics were on the same slide, but 18

the intent here is to show that DOE’s broad 19

interpretation of the language would mean that

– for 20

this slide, the red only means that it would meet that 21

definition. So according to the definition the blower 22

coil only unit

– I’m sorry, the blower coil unit 23

contains a furnace fan according to that definition. 24

However, for the preliminary scope of cover age of this 25Executive Court Reporters (301) 565

- 0064 37 rulemaking, that’s being excluded. So it is a furnace 1

fan, but it’s not being considered in this rulemaking. 2

MR. WINNINGHAM: Okay. Thank you. 3

MR. BROOKMAN: Okay. Abigail. 4

MS. DAKEN: That was in fact my question. 5

So I’m going to f ollow up with another one instead, 6

which is, I assume you’re going to get into why you 7

are not considering these later on in the 8

presentation? 9

MR. JASINSKI: Yes

– well, I’m not sure that 10

it’s explicitly stated in the presentation. We 11

provide details ab out the scope of coverage in chapter 12

two as well as chapter three of the TSD. 13

MR. BROOKMAN: Joanna. 14

MS. MAUER: Joanna Mauer. So we recognize 15

that fan energy is captured to some extent in the test 16

procedures for central air conditioners and heat 17

pump s. Our concern is that the external static 18

pressures that are assumed in the test procedures for 19

central AC and heat pumps are unrealistically low, 20

point one to point two. DOE’s analysis of field data 21

for the furnace fan test procedure rulemaking has 22

sho wn that external static pressures in the field are 23

more like point seven

– sorry, point five to point 24

seven, in that range. So clearly there’s a 25Executive Court Reporters (301) 565

- 0064 38 significant difference. And we’re concerned that the 1

central AC and heat pump test procedures don’t 2

accuratel y reflect fan energy consumption in the 3

field, and this can also result in air handlers not 4

being able to provide sufficient air flow in the 5

field, which can affect both comfort and heating and 6

cooling efficiency. 7

Now, we’ve heard from manufacturers that 8

changing the external static pressure values in the 9

central AC and heat pump test procedures would 10

represent a significant burden because they’d have to 11

re

- rate all of their products. And we understand that 12

concern, and we think a way around this is to i nclude 13

furnace fans that are part of blower coil and single 14

package central AC and heat pump products in the 15

furnace fan rulemaking. And the SEER and HSPF ratings 16

could be left alone. 17

MR. BROOKMAN: Thank you. Charlie 18

Stephens. 19

MR. STEPHENS: Charli e Stephens. We have 20

some additional concern that these products that are 21

indoor units for AC and heat pump systems are also 22

sold separately. I know, I’ve installed or overseen 23

the installation of a number of them myself, so I know 24

it happens. And I also am someone who specifies these 25Executive Court Reporters (301) 565

- 0064 39 things and I have to specify them typically by model 1

number, or several model numbers because there’s no 2

other metric to use for these things when they are 3

sold separately as part of

– when they’re not part of 4

a split system . I can’t specify them by HSPF or SEER, 5

you know, I’m only specifying an air handler. So it 6

gets a little difficult at times to tell a contractor 7

who doesn’t sell this brand but sells somebody else’s 8

brand, exactly what it is you’re specifying because 9

th ere is no metric for these things. There is no 10

rating for these things, and some contractors, quite 11

frankly, don’t understand the importance of what the 12

specification is. 13

So these things are sold fairly commonly as 14

air handlers for houses out where I li ve, and I think 15

they need

– we’re very concerned that they need some 16

sort of a separate rating, regardless of the fact that 17

they are often found as an indoor unit in a split 18

system. So we would like to see the Department 19

include those in some way. We wou ld also like to have 20

them included in a way that isn’t overly burdensome to 21

test in addition to the other testing, so some 22

consistencies would be nice. But in the meantime, we 23

feel strongly that they should be included in this 24

rulemaking. 25Executive Court Reporters (301) 565

- 0064 40 MR. BROOKMAN: Other comments here before

– 1

Diane. 2

MS. JAKOBS: I’m not sure I followed which 3

thing Charlie was talking about. 4

MR. BROOKMAN: Diane, you’ve got to get 5

close to that microphone, please. 6

MS. JAKOBS: I’m sorry. I didn’t know which 7

thing

– 8

MR. STEP HENS: (off mic) The box that has 9

black

– not considered in this rulemaking. 10

MS. JAKOBS: So an air handler that would be 11

matched with that heat pump. Okay. 12

MR. BROOKMAN: Okay. Terry Small has his 13

hand up. Terry, speak, please. 14

MR. SMALL: Yes , Terry Small with Mortex. 15

Sam, I’m wondering, are you excluding , for instance, 16

these type products that would be used in multifamily, 17

perhaps considered commercial fan coils? They may 18

have, particularly in the hydronic, you know, they may 19

have a hot wat er source that’s a boiler or a big hot 20

water heater, may have a chiller attached. Is all of 21

that type product excluded from this? 22

MR. JASINSKI: The scope of coverage of this 23

rulemaking is limited to residential products, so this 24

was an issue that was b rought up during the test 25Executive Court Reporters (301) 565

- 0064 41 procedure public meeting also. We’re asking for 1

manufacturers, especially of hydronic air handlers 2

because they’re somewhat of an emerging product, to 3

provide information about how they are used, so that 4

we can consider factors l ike when they’re used in 5

multifamily homes, to be sure that we keep the scope 6

of coverage limited to residential products. 7

MR. SMALL: Well, you know that it’s been 8

traditional that fan coils or ceiling mount units or 9

wall mount units have been used in t he larger 10

multifamily apartment buildings, et cetera. So I think 11

you need to be pretty specific. Of course, I guess 12

you’re asking for comments, but I mean there’s a gray 13

area here that is not well laid out in the way you 14

described it here. 15

MR. BROOKMAN: Okay. Thank you. Final 16

comments before we move on? Okay. 17

MR. JASINSKI: So, with that identified in 18

the scope of coverage, DOE has identified nine key 19

product classes that represent most of the energy use 20

associated with furnace fans considered in this 21

analysis, because they are associated with the 22

products that have the highest number of shipments. 23

And because these are pretty important, I will go 24

through the labor of reading through each one of 25Executive Court Reporters (301) 565

- 0064 42 those. 1

MR. BROOKMAN: Sam? 2

MR. JASINSKI: Yes. 3

MR. BROOKMAN: Hold on a second, if you 4

would please. Jim Vershaw has his hand up. Jim, does 5

your comment relate to the previous slides? 6

MR. VERSHAW: Yes. 7

MR. BROOKMAN: Speak up. 8

MR. VERSHAW: This discussion about whether 9

or not fan coil units and other things should be 10

included in the standard points out the issue when you 11

try to put standards around components of systems. 12

The gentleman who was concerned about an air handler 13

for special installations not having ratings, which 14

really should be a system rating. This is going to 15

create over and over and over, issues on how to 16

regulate components of systems when we ought to look 17

at the system level performance of these things. In 18

particular with heat pumps and air conditioners in 19

which blower co ils are always part of the performance 20

and the standard set at the certain external static 21

pressure, we do that. If you start putting another 22

standard on top of that

– a consumer who only buys an 23

air conditioning system or heater once or twice in his 24

life time, will be totally confused as to what’s going 25Executive Court Reporters (301) 565

- 0064 43 on and it will all be lost

– all this effort will be 1

lost on the consumer. It’s important that we start 2

thinking about this in terms of systems. Thank you. 3

MR. BROOKMAN: Thanks, Jim. Okay. 4

MR. VER SHAW: Oh, and one more thing. The 5

gentleman who’s speaking right now

– his voice is 6

fading in and out and I’m having a hard time picking 7

up everything he’s saying. 8

MR. BROOKMAN: Thanks

– we’re working on it. 9

We’re having trouble with the audio today. We’re 10

going to ask him to speak loudly. So thanks for 11

flagging that. Back to Sam. 12

MR. JASINSKI: Thank you. I’ll pick up 13

where I left off. I want to read through the nine key 14

product classes. 15

1. Non

- weatherized, non

- condensing gas furnace fans 16

2. Non

- weat herized, condensing gas furnace fans 17

3. Weatherized gas furnace fans 18

4. Non

- weatherized oil, non

- condensing furnace fans 19

5. Non

- weatherized electric furnace and modular 20

boiler fans 21

6. Heating and cooling hydronic air handler fans 22

7. Manufactured home non

- weatherized gas non

23

condensing furnace fans 24

8. Manufactured home non

- weatherized gas condensing 25Executive Court Reporters (301) 565

- 0064 44 furnace fans 1

9. And lastly, manufactured home electric furnaces 2

and modular boiler fans. 3

Important to note here is that DOE 4

differentiated these product classes by application 5

and internal structure that impacted air flow and 6

furnace fan performance. 7

DOE also identified 12 additional product 8

classes that represent significantly fewer shipments 9

and significantly less energy use for the preliminary 10

analysis. DOE grouped each non

- key product class 11

with a key product class to which it is closely 12

related in internal structure and fan performance 13

related

– I’m sorry, application and fan performance 14

related internal structure, which as I mentioned, are 15

the primary criteria for differen tiating between the 16

key product classes. 17

I’m going to toggle between the next slide 18

and back to this one because I think it will provide a 19

snapshot of what I mean here. 20

As I mentioned, here are the groupings. You 21

can see on the left, the column on the left is the key 22

product classes for this rulemaking, and then to the 23

right you can see the proposed additional product 24

classes that I’m speaking about that have the fewer 25Executive Court Reporters (301) 565

- 0064 45 shipments and significantly less

– contribute

– I’m 1

sorry, significantly less energy use than the primary 2

product classes, and this shows the groupings. I won’t 3

read through the 12 additional product classes, but 4

that just provides a graphic for what I mean as to the 5

method that is being used. 6

DOE assigned the baseline FER or IFER and 7

a nalysis results of each key product class to the non

8

key product classes with which it is grouped. And if 9

DOE continues with this approach in the NOPR, it would 10

result i n proposed efficiency levels for each 11

additional product class that is equivalent to t he 12

proposed efficiency level with the key product class 13

with which it is paired. 14

So as an example, I’ll use the top one, if 15

DOE continues with this approach, the baseline and 16

analysis results for weatherized gas furnace fans 17

would be assigned to weatheri zed non

- condensing oil 18

furnace fans, and the result would be that in the 19

Notice of Proposed Rulemaking whatever efficiency 20

level trials standard level was proposed for the 21

weatherized gas furnace fan would also be proposed for 22

weatherized, non

- condensing o il furnace fans. 23

Anybody has any questions? 24

MR. BROOKMAN: Steve Rosenstock. 25Executive Court Reporters (301) 565

- 0064 46 MR. ROSENSTOCK: Steve Rosenstock, Edison 1

Electric Institute. So is this another situation 2

where the products on the left are being used as a 3

proxy

– the results are going to be proxy for the 4

products on the right side of the table? 5

MR. JASINSKI: Yes. 6

MR. ROSENSTOCK: So, eventually, from the 7

previous slide there’s nine product classes, and then 8

with this there might be 21 product classes with the 9

final rule. Is that

– 10

MR. JASINSKI: Yes. 11

MR. ROSENSTOCK: Okay. Just to give

– 12

MR. JASINSKI: Yes, and a clarification

– 13

there’s only three key product classes shown here 14

because all the 12 additional product classes are 15

grouped with them. The six remaining key produc t 16

classes don’t have any additional product classes. 17

MR. BROOKMAN: So if would be nine plus 18

three? 19

MR. JASINSKI: No, it would be the nine plus 20

the 12 that are shown here, so 21. 21

MR. BROOKMAN: Okay. Joanna. 22

MS. MAUER: Joanna Mauer. I just want to 23

make sure I understand. Are you saying that the same 24

FER values would be used for the other product 25Executive Court Reporters (301) 565

- 0064 47 classes? The same values? 1

MR. JASINSKI: Yes. 2

MS. MAUER: So I guess what’s the benefit of 3

having the separate product classes as opposed to 4

combi ning them into one? 5

MR. JASINSKI: Well, as I’ll get to in the 6

next slide, this is an issue that DOE is requesting 7

comment on. Essentially because the products that 8

make up the additional product classes have so few 9

shipments, there’s not a lot of data readily available 10

to perform a detailed analysis to the level that is 11

possible for the key product classes. So a little 12

early, I’ll ask that manufacturers and other 13

interested parties provide comment on, and data, about 14

shipments, the prevalence and also performance

- related 15

data for the 12 additional product classes. 16

MR. BROOKMAN: Diane. Close. Get that 17

microphone close. 18

MS. JAKOBS: Close, okay. Just from your 19

own FER values, it seems like the manufactured homes 20

units, they were much lower, and we don’t build those, 21

but I don’t know if there’s something special about 22

those where they should be a key product class. 23

MR. JASINSKI: A major factor for the 24

difference is that in the proposed test procedure, DOE 25Executive Court Reporters (301) 565

- 0064 48 is proposing to use a reference system ext ernal static 1

pressure of three

- tenths inches water column for 2

manufactured home products, whereas for the non

3

manufactured home products, the proposed reference 4

system external static pressure is

– are on the order 5

of half an inch water column, and point s ix five 6

inches water column. 7

MS. JAKOBS: So it was point six five, so if 8

you have a manufactured home furnace that doesn’t come 9

with a coil, wouldn’t that have the point six five 10

then too? 11

MR. JASINSKI: No, that would

– that would 12

have a point three inches water column. Any 13

manufactured home product class would use that 14

reference system external static pressure. 15

MS. JAKOBS: Okay. I’ll have to look at 16

that. We talked about that in our meeting, and nobody 17

was real forthcoming from the manufactured home group. 18

MR. JASINSKI: Comments are always welcome. 19

MS. JAKOBS: Okay. And I’ll just have to 20

look into that, I don’t

– 21

MR. BROOKMAN: Tom Eckman. 22

MR. ECKMAN: I think one of the

– as I 23

understand it, one of the reasons is because the 24

manufact ured homes don’t have return ductwork at all, 25Executive Court Reporters (301) 565

- 0064 49 basically, a single return pickup in the

– near the 1

furnace, so there’s no

– there’s a supply side, but 2

there’s no return side ductwork. 3

MR. BROOKMAN: Thanks, Tom. Steve 4

Rosenstock. 5

MR. ROSENSTOCK: Agai n, Steve Rosenstock, 6

EEI. This is kind of a

– for that first category, is 7

a weatherized gas furnace fan for single family home, 8

non

- manufactured home, is going to be used

– is a 9

proxy for the manufactured home even though they have 10

significantly different external static pressures? 11

MR. JASINSKI: Yes. Well , yeah. In this 12

case one approach that DOE could take is that it would 13

use the same raw data from the weatherized gas furnace 14

fan and potentially use a different reference system 15

external static pres sure, so in that case one 16

potential approach could be to assign a different 17

baseline and different analyses result based on the 18

lower external static pressure. But this is

– these 19

are the type of comment that DOE is asking for, really 20

comments on what is the appropriate approach for 21

handling the additional product classes in the absence 22

of the amount of detailed data that’s available for 23

the key product classes? 24

MR. BROOKMAN: Terry Smith, you’re next. 25Executive Court Reporters (301) 565

- 0064 50 Pardon me, Terry Small. I apologize. Terry. 1

MR. SMALL: This is Terry Small with Mortex. 2

I guess I’m a little confused. So on your baseline 3

FER values, they were in the executive summary, there 4

are nine product class es. Really that should have 5

been 21 values including the additional product 6

classes? If they all have different baselines? I’m 7

confused. 8

MR. JASINSKI: So the approach that’s being 9

presented here is that the baselines that are assigned 10

to the key product classes, you would assign those to 11

the additional product classes with which it’s 12

grouped. So essentially, anywhere you see a value for 13

weatherized gas furnace fan, you would just duplicate 14

that value for the additional product classes that are 15

grouped with weatherized furnace fans. So if you 16

expanded that table, there would be 21 va lues, but for 17

each additional product class it would just be a 18

duplication of whatever the value of the key product 19

class for which it’s group ed . Does that answer

– 20

MR. SMALL: Well just to comment. I think 21

that the

– certainly on some of these product classes, 22

particularly the hydronic and all that, you’re going 23

to have some huge variations once you get into the 24

additional product classes. So I don’t think you’re 25Executive Court Reporters (301) 565

- 0064 51 going to find that one size is going to fit all, but 1

that’s just my opinion, thank you. 2

MR. BROOKMAN: Terry, those kinds of 3

comments in detail will benefit the Department when 4

you sent them in. 5

MR. JASINSKI: Yeah, to add to what Doug is 6

saying

– sorry. 7

MR. SMALL: And Doug, what’s interesting 8

about is unfortunately

– you know, we’re a s mall 9

manufacturer. We just don’t have the resources. I 10

mean I wish I had all of our product

– I wish that 11

there was a final test procedure then we could test 12

our products in about a year’s time we could tell you 13

where we thought we were. I mean, we’re c ompletely 14

flying in the dark on this. We’re not certain about 15

the test procedure, and just to figure out where we 16

are on all these different products is going to 17

require quite a bit of testing. 18

MR. BROOKMAN: Thanks, Terry. 19

MR. SMALL: It’s almost as if we’re getting 20

the carts in front of the horse pretty substantially 21

on this, and I would really

– I would really caution 22

that we show down on this before we start setting 23

values, but that’s my opinion, thank you. 24

MR. BROOKMAN: Thank you. Detlef

. 25Executive Court Reporters (301) 565

- 0064 52 MR . WESTPHALEN: Detlef Westphalen, 1

Navigant. I think one of the things with these 12 2

additional product classes is that we’re not sure all 3

of them exist. For instance, the manufactured home 4

weatherized gas furnaces, and, you know, this is a 5

framework, a s tructure with which to say okay, suppose 6

significant quantities of these are sold. This is a 7

proposed place to put them within the analysis 8

structure. And so, you know, we’re presenting this 9

and requesting comment and also information on, you 10

know, are t hese important product classes and what 11

kind of sales levels are associated with them and what 12

kind of characteristics do they have that would allow 13

us to determine, are these the appropriate alignments. 14

MR. BROOKMAN: Okay. Thank you. 15

MR. JASINSKI: Yes, to add to what Detlef 16

said, in addition to comments on whether these 17

products exist, and if they do what the level of 18

shipments are, Terry Small mentioned that there are 19

factors that would create discrepancies with the key 20

product classes with which they’re paired. If in your 21

comments you could detail what those are, that could 22

provide information for DOE to modify the framework 23

and could address those discrepancies. 24

MR. BROOKMAN: Final comments on these

– 25Executive Court Reporters (301) 565

- 0064 53 actually I guess there are a couple of s lides as they 1

talk about these groupings. Okay. 2

MR. JASINSKI: So as I said, this is just a 3

callout box with the questions that we’ve been 4

discussing. DOE is interested in comments here and 5

written comments on the methodology for 6

differentiating the product classes that I mentioned, 7

by application, and internal structure. And DOE also 8

seeks comment and data regarding the market for the 12 9

additional product classes and their expected energy 10

performance, specifically historical and future 11

shipment dat a and energy performance data that would 12

be useful to estimate FER or IFER for those product 13

classes. 14

MR. BROOKMAN: We have another comment from 15

Terry Small. Go ahead, Terry. 16

MR. SMALL: Yes, I’d just like to add one 17

other thing. What is really inte resting about this 18

fantastic HVAC industry and market we have is that the 19

industry has evolved such that it meets the needs of 20

the consumer, particularly in indoor situations. No 21

two houses are the same, and the application of HVAC 22

to houses and apartment s varies a lot so you have a 23

lot of different products, a lot of different heat 24

loads or cooling loads to meet. And I would be very 25Executive Court Reporters (301) 565

- 0064 54 worried that if you set too low of a bar for the 1

product class

-- the overall nine product classes, you 2

may wide that inadv ertently some of these additional 3

product classes that wouldn’t meet the value, to serve 4

a particular application in people’s homes or 5

apartments here in the US. It’s much easier to 6

prescribe what is happening with an outdoor unit which 7

sits outside the h ouse or apartment, than it is what 8

has to be fit into

– and a lot of this could be 9

replacement also remember, so there’s not very much 10

new construction going on. Most of this is really, 11

for the foreseeable future, going back in and 12

replacing existing equ ipment. It could be a real 13

problem. So I would recommend that you carefully look 14

at these additional product classes and take into 15

account, maybe the uniqueness of their design, and, 16

you know, just the application. Thank you. 17

MR. BROOKMAN: Thank yo u. We’re moving on, 18

Sam. 19

MR. JASINSKI: Another important aspect of 20

the market assessment, as I said, is to identify 21

manufacturers and their market share. Here DOE found 22

that the top seven gas furnace manufacturers represent 23

99 percent of the gas furna ce market. And the pie 24

chart on the left shows that market distribution by 25Executive Court Reporters (301) 565

- 0064 55 shipments

– market share distribution by shipments. 1

In addition , ten oil furnace manufacturers represent

– 2

the top ten oil furnace manufacturers represent over 3

90 percent of the m arket and here’s a table here that 4

shows on the left, the manufacturers that have an 5

estimated

– at least an estimated market share of ten 6

percent, and on the right, the remaining oil furnace 7

manufacturers that are estimated to have a less than 8

ten percent market share. 9

And just to note for related products and 10

also products like modular blowers that are often part 11

of the discussion for CAC and heat pump issues, the 12

market share distribution is very similar to the gas 13

furnace market share distribution. T he manufacturers 14

are the same and the percentages vary by only a few 15

points. 16

MR. BROOKMAN: Craig. 17

MR. MESSMER: Yeah, looking at that pie 18

chart, I didn’t see any

-- this is Craig Messmer

– I 19

didn’t see any analysis in the technical support 20

document fo r small companies. Is that in there? 21

MR. JASINSKI: There’s no analysis yet. The 22

analysis that would relate to small businesses would 23

be something that would occur in the NOPR stage of the 24

manufacturing impact analysis. So at this stage, in 25Executive Court Reporters (301) 565

- 0064 56 the prel iminary analysis, DOE is just striving to 1

identify small business manufacturers, so that during 2

the NOPR phase those small business manufacturers can 3

be included in that manufacturing impact analysis. 4

MR. MESSMER: So that will be included in 5

the cost be nefit analysis, then? 6

MR. JASINSKI: Yes, so I guess it’s 7

important to raise another request that if you are a 8

small business manufacturer and you’re not included in 9

that list that’s included in the preliminary technical 10

support document, please let DOE know so that you can 11

be included in those downstream analyses. 12

MR. MESSMER: Thank you. 13

MR. JASINSKI: The second part of the market 14

and technology assessment is the technology 15

assessment, and the important outcome of the 16

technology assessment is ide ntification of 17

technologies that manufacturers can use to improve the 18

efficiency of furnace fans in their products. Here is 19

a table that shows the technology options that DOE 20

identified. 21

**•** The first is invert er technology for PSC motors. 22

These are motor controls that can be used to 23

extend the air flow and flexibility of PSC 24Executive Court Reporters (301) 565

- 0064 57 motors. Flexibility here just means the ability 1

to match the demand. 2

**•** Second, X13 fan motors. I will say here that DOE 3

is using X13 to

– as a generic term for constant 4

torque permanen t magnet motors, and these motors 5

are

– well, we realize that X13 may be the name 6

of a specific model by a specific manufacturer, 7

but they’re often discussed in the industry and 8

referred to as X13, so that’s the same

– we’re 9

continuing that convention here . And these are 10

more efficient than PSC motors because they have 11

typically

– they’re more

– they operate more 12

efficiently and they also have an extended air 13

flow range. 14

**•** ECM fan motors, again here, ECM is also 15

trademarked, I believe. Here DOE is using thi s 16

as a generic term for constant air flow permanent 17

magnet motors. And these adds the energy 18

benefits of X13 motors because they operate more 19

efficiently and again, extend the air flow range 20

available. 21

**•** Next, backward inclined impellors. These are 22

impello rs with backward facing inclined blades 23

that can be more efficient than the standard or 24Executive Court Reporters (301) 565

- 0064 58 forward curved impellers. 1

**•** Next, toroidal (ph) transformer. And here I 2

noted that these are only for the standby and off 3

mode product classes, or the product classes fo r 4

which standby and off mode are being considered 5

in this rulemaking. Toroidal (ph) transformer 6

has an annular

– well, I won’t read these in 7

detail, but essentially their construction makes 8

them more efficient than the conventional 9

laminated core power tr ansformers that are 10

standard in products. 11

**•** Next, switching mode power supplies, similar to 12

toroidal (ph) transformers for the standby and 13

off mode product classes, and these are more 14

efficient than the solid state power supplies

– 15

I’m sorry, these are solid state power supplies 16

tha t are more efficient than the conventional 17

transformer

- based power supplies. 18

**•** Next, fan housing design modifications. 19

Optimizing the shape of the fan housing has the 20

potential to increase furnace fan efficiency. 21

**•** Next, air flow path design. Modifying the HVAC 22

product envelope and elements in the air flow 23

path, such as the heat exchanger, to reduce 24Executive Court Reporters (301) 565

- 0064 59 external static pressure also has the potential 1

to improve efficiency of furnace fans. 2

**•** And lastly, ECM control relay. Again, also 3

partic ular to standby and off mode product 4

classes. This is the use of a control relay on 5

an ECM to disconnect it when it’s not needed to 6

eliminate the standby power that’s associated 7

with the controls of the ECM motor. 8

Any questions before I move on? 9

MR. B ROOKMAN: Brian, please. 10

MR. JAMES: Brian James, Southern California 11

Edison, on behalf of the California IRUs. Backward 12

inclined impellers isn’t necessarily a straightforward 13

energy efficiency improvement. It is more efficient 14

over a narrow range, but outside of that range it can 15

actually be less efficient, as well as noisier in 16

residential applications. So, that should be taken 17

into consideration that it’s efficient only over a 18

narrow range. 19

MR. BROOKMAN: Thank you. And this is the 20

kind of commen t the Department would wish to elicit in 21

this spot, I believe, that is, comments on these and 22

others that may be missed. Charlie Stephens. 23

MR. STEPHENS: Charlie Stephens. I’ve been 24Executive Court Reporters (301) 565

- 0064 60 wondering since we started here where to address this, 1

and I guess thi s is as good a place as any, so pardon 2

me if I go backwards, but this touches on everything. 3

I’ve been confused ever since I started reading the 4

technical support document here, about whether we’re 5

regulating fans or air handlers. And what I see here 6

in the beginning, in the introduction is that, you 7

know, a fan is a component of an HVAC product, and I 8

presume that most of those HVAC products that we’re 9

talking about are air handlers. Now that definition 10

is entirely consistent with the list that I’m look ing 11

at here on the slide in terms of what design options 12

you’re looking at. They pertain to the definition 13

that DOE put forward of that being an electric motor 14

and an impeller and a housing and a control, period. 15

Not the cabinet, not the air flow path, n othing else. 16

I mean there’s no other option I see here that relates 17

to an air handler. These all relate, literally, to 18

the fan. 19

And I can’t help but go back and think of an 20

analogy here where DOE right now, for instance, is 21

considering regulating pumps , which are in an 22

electrically powered device for moving water through 23

pipes. Not all altogether different from this, 24

different fluid. And DOE

– I mean the proposal I see 25Executive Court Reporters (301) 565

- 0064 61 if you insist on the definition of fan that you have 1

today, regulating

– would you regulate pumps as a 2

component of a residential or commercial appliance 3

product, clothes washers? Are you going to regulate 4

pumps by regulating the manufacturers of clothes 5

washers? So if you insist on this thing being only 6

about fans, I’m not sure I unde rstand even the 7

regulation proposals for hydronic air handlers. I 8

mean if you get into that, there’s lots of things you 9

could do to those to make them more efficient in terms 10

of moving the air through them, but they have a fan. 11

Hydronic air handlers have a fan in them like the 12

others, but you seem to ambivalent about what you’re 13

regulating here. And I think if you really are 14

regulating air handlers, then this list is woefully 15

short. 16

And, if on the other hand, you’re actually 17

regulating fans, well, this is the right list. But I 18

think the Department first and foremost needs to 19

decide whether it’s regulating fans or air handlers. 20

And if it’s air handlers in the end because you’re 21

regulating the manufacturers of air handlers, then 22

this list is not adequat e, and we’ll add to it as we 23

go through in our comments. But I think

– I’ve been 24

confused all the way through this document because 25Executive Court Reporters (301) 565

- 0064 62 people seem to be using this term fan and air handler 1

interchangeably. And based on your own definitions 2

here, they’re not interchangeable. 3

MR. BROOKMAN: Thanks, Charlie. Yes, 4

Abigail. 5

MS. DAKEN: To follow on a little bit on 6

Charlie’s comment. I’m wondering about the air flow 7

path design, if you’re regulating the fan itself and 8

not the air handler, whether that’s appr opriate to 9

regulating the fan. 10

The other comment I would make is that I’m 11

sort of listening to people talking about improving 12

the efficiency of the fan, and whether that is done at 13

the cost of the efficiency of the entire system. I’d 14

like to understan d that better, but I wonder whether 15

the difference that Charlie is referring to, between 16

regulating air handlers and regulating fans, might 17

help explain it. 18

MR. BROOKMAN: Greg. Thanks for getting 19

that close. 20

MR. WAGNER: I’ll try. Greg Wagner. To 21

g ive a little example on the efficiency of components 22

versus systems, with the advent of 13 SEER, 14 SEER 23

regulations, coils have grown in size to take up more 24

space in the heating volume, if you will, inside any 25Executive Court Reporters (301) 565

- 0064 63 residence, and so it’s reduced the size that ’s 1

available to furnaces, and as such, furnaces have 2

shrunk in size since the advent of the 13 SEER 3

regulation. That leaves less room for blowers and 4

they’re less efficient when they’re smaller in size. 5

So there are systems that have to be designed to mee t 6

the performance for the other regulations, and those 7

drive what happens in terms of design options 8

available to people that are putting together the 9

furnace, the air handler systems. 10

MR. BROOKMAN: Okay. Yes, Diane. 11

MS. JAKOBS: There’s also

– it’s just 12

physics, but if you have higher velocity air you 13

improve the heat transfer between the gas heat 14

exchanger or the

– any heat exchanger. So we can get 15

a higher A FUE by increasing the air flow, which will 16

burn more watts. So that’s kind of a

– one goes up 17

and one goes down. 18

MR. BROOKMAN: Thank you. Yes, Dave. 19

MR. WINNINGHAM: Yes, this is Dave from 20

Allied. Just to kind of add to Diane’s, for our gas 21

furnace, 80 percent versus a 90 percent furnace. The 22

majority of the power consumption is on the gas side, 23

but the heat exchanger for an 80 percent, for 24

instance, typically less restrictive than a 90 25Executive Court Reporters (301) 565

- 0064 64 percent, to extract more efficiency, you put a 1

secondary coil which is going to typically either 2

require more power in the blower system, so this 3

additio nal metric could drive some unintended 4

consequences as part of that. 5

MR. BROOKMAN: Okay. Thank you. Yes, 6

please, Greg. 7

MR. WAGNER: I was just going to echo that 8

that secondary heat exchanger is another one where it 9

is energy consumed to pull out, e xtract, more energy 10

and the cost difference between those, since you’re 11

doing 98 percent in the gas part of it versus two 12

percent in the electrical consumption, you want to get 13

the most benefit from the gas part of it from an 14

energy efficiency standpoint. So those are some 15

things to answer your questions of the beginning, 16

Mohammed, so that’s why system effects are the 17

important part that we need to look at, not just 18

components. 19

MR. BROOKMAN: Diane

– follow on? 20

MS. JAKOBS: Okay. There is just one thi ng 21

from your TSD that I learned, and I was aware of it in 22

Rheem’s furnaces, but I thought I was a special case, 23

but it looks like the

– actually the condensing 24

furnaces had lower FER values, or lower E

- sub

- AE 25Executive Court Reporters (301) 565

- 0064 65 values than the non

- condensing, which was the i nverse 1

of what I thought. But maybe because we all use, or 2

almost all of us use these two ... coils, and to go back 3

to Harvey’s air straighterners, maybe we’re helping 4

them and so we have this space in there for the 5

secondary coil. I don’t know it was just an unusual 6

thing that I notice from your data. It is motor 7

differences? I don’t know. It was weird. 8

MR. JASINSKI: (comment off mic) 9

MS. JAKOBS: I think

-- I know I’ve stated 10

that but your data doesn’t reflect that. The 80

- plus 11

has lower electr ical consumption. 12

MR. BROOKMAN: Do you have any follow on or 13

should we move on? 14

MR. JASINSKI: We can move on. When we 15

present the table based on value, we can explore that. 16

MR. BROOKMAN: Okay. 17

MR. JASINSKI: Because that’ll

– it’ll make 18

it ea sier for everyone to see what she’s referring to. 19

MR. BROOKMAN: Yes, please. 20

MR. LIN: Paul Lin from Regal Beloit. This 21

table, and I thought in the analysis you had a higher 22

efficiency PSC in the analysis, but I don’t see that 23

on your table h ere. 24

MR. JASINSKI: In the engineering analysis 25Executive Court Reporters (301) 565

- 0064 66 when we get to it, there is an efficiency level that’s 1

associated with an improved PSC, and an improved PSC 2

in this sense just means a PSC motor that has

– the 3

baseline is described as a furnace fan that re lies on 4

a PSC motor that has three or fewer air flow control 5

settings, improved

– there are

– an improved PSC in 6

this analysis just refers to those that have more

– a 7

larger number of air control settings which 8

contributes to a wider range of air flow and also 9

flexibility. 10

MR. BROOKMAN: We have another individual 11

who wants to

– who’s raised his hand. Jim Vershaw, 12

you’re next. 13

MR. VERSHAW: Hi, this is Jim Vershaw. I’m 14

with Ingersoll Rand Trane. A few comments. At first 15

I agree on the backward incli ned impeller comment. If 16

those were usable in the conventional furnaces, 17

obviously they would have been used a long time ago. 18

They are very loud and very tight tolerance, and 19

they’re difficult to manufacture and they have a very 20

limited area where you ca n actually use them with good 21

efficiency. 22

Second comment has to do with improving the 23

efficiency of fan systems on furnaces, remember that 24

in the heating mode all of the heat goes into the 25Executive Court Reporters (301) 565

- 0064 67 motor, either goes into moving the air or goes into 1

the air strea m, so as you take that efficiency of that 2

motor up, you’re going to have to put more gas into 3

the furnace to maintain the house load. So there is 4

an effect on how much gas will be used versus how much 5

electricity is going to be used. 6

The other issue is as you look at higher 7

statics, remember the PSC motor will unload and 8

actually use less energy at high statics, whereas the 9

E CM, the ... DC motor will use more energy at the high 10

statics. So as we start looking at different static 11

points for measurement for fan versus for systems, 12

that’s going to be very confusing as to what the 13

system is really doing, and then the consumer will be 14

unable to determine how to choose

– how to utilize 15

that information. Thanks. 16

MR. BROOKMAN: Okay. Thank you. We’re 17

going to keep pressing on here. 18

MR. JASINSKI: After technology options are 19

identified, DOE conducts a screening analysis, and the 20

screening analysis is to evaluate the technology 21

options according to the following criteria: 22

**•** technological feasibility, 23

**•** practicab ility to manufacture, install, service 24Executive Court Reporters (301) 565

- 0064 68

**•** impacts on utility or product availability 1

**•** and lastly, impacts on health or safety. 2

The technology options that don’t meet these 3

criteria are screened out or not considered in the 4

downstream analyses. 5

DOE screened out three technology options. 6

This table summarizes those technology options and 7

the reasons they were screened out. First, housing 8

design modifications. In this case DOE is requesting 9

more data. DOE did not find any quantified data that 10

quantified en ergy savings associated with specific 11

design modifications to the housing. So if 12

interested parties have that available, if they could 13

provide that, DOE would really appreciate it. 14

Secondly, the air flow path design 15

technology option, and this speaks to a lot of the 16

discussion that was happening earlier. DOE is 17

constantly considering the trade off between system 18

efficiency and component efficiency because of the 19

unique nature of this rulemaking. So in terms of how 20

definitions are set, how product class es are 21

differentiated, DOE is attempting to not neglect the 22

fact that there are system impacts to the decisions 23

that are made with regard to the framework and 24Executive Court Reporters (301) 565

- 0064 69 methodologies that we are using. So this particular 1

case, air flow path design was identified as a 2

technology option because DOE recognizes that there 3

is an impact on the fan efficiency related to the air 4

flow path design. Similar to the test procedure, the 5

fan being tested as it is factory installed in the 6

HVAC product for similar reasons. But in this case, 7

the air flow path design technology option was 8

screened out because DOE understands that there are 9

impacts on thermal performance. However, on 10

quantifying them and understanding the tradeoffs is 11

something that DOE requires more information for, and 12

because of the impacts and a lot of the examples that 13

were provided by manufacturers here, there is a 14

chance that if overall system efficiency is impacted, 15

that product utility could be impacted. And as I 16

stated earlier, one of the screening analysis 17

criteria is product utility. So for those reasons, 18

the air flow path design was preliminary screened out 19

for this analysis. 20

Lastly, ECM control relay. This is the 21

standby and off mode technology option where relay 22

would be used to eliminate the standb y power 23

consumption of ECM motors when they’re not being 24

used. Again, this impacts product utilities, 25Executive Court Reporters (301) 565

- 0064 70 specifically reliability, because the control

– if 1

ECM motor controls are turned off and on repeatedly, 2

DOE has received comments that that could shorten the 3

life of the motor which has an impact on product 4

utility. 5

So after the screening analysis, DOE 6

retained six technology options for the following 7

engineering analysis. For more information about the 8

screening analysis, you can refer to Chapter 4 of the 9

TSD. 10

MR. BROOKMAN: Let’s just pause there. 11

Comments on these technology options which the 12

Department is suggesting in a preliminary way might 13

be screened out. Adam. 14

MR. CHRISTIANSEN: So just with regard to 15

the fan housing design modification, I believe

– I’d 16

have to go back to my computer, but I believe there 17

was a study done in early 2007

– 18

MR. BROOKMAN: Louder, Adam. 19

MR. CHRISTIANSEN: Sorry. I believe there 20

was a study done early 2000’s by GE that they looked 21

at things like inlet cone o f the fan housing, some 22

curved sections, you know, improving the outlet 23

dimensions of the fan, and they actually quantified 24

some of those energy savings in that report. Those 25Executive Court Reporters (301) 565

- 0064 71 are things that don’t necessarily take up a whole lot 1

of space within an air han dler, and I think DOE 2

should

– I’ll forward along the document to the 3

appropriate person if you don’t know what I’m talking 4

about, but I think it’s something that should be 5

looked at. 6

MR. BROOKMAN: Craig Messmer and then to 7

Diane. 8

MR. MESSMER: Craig Messmer. Can you 9

explain what you meant by air flow path design? Is 10

it just the fan scroll housing? Is it the inlet 11

conditions or the discharge? 12

MR. JASINSKI: (off mic) 13

MR. BROOKMAN: Sam, sorry, your microphone 14

is not working. 15

MR. JASINSKI: Sou nds like it’s on now, 16

sorry. Yes, the air flow path technology options 17

here refers to the envelope

– 18

PARTICIPANT: It’s off again, sorry. 19

MR. BROOKMAN: Use this one. 20

MR. JASINSKI: Thanks. Does that answer 21

your question? 22

MR. MESSMER: Yes, and t o follow up on that. 23

What is the baseline air flow path design? I think 24

you’re going to find that products from different 25Executive Court Reporters (301) 565

- 0064 72 manufacturers have different air flow path designs, 1

and you’re going to have a widely different FER for 2

different manufacturers. And if we don’t establish 3

what the baseline is, so how do we know what the 4

improvements are going to be in the future, or even 5

if the FER baseline is valid. 6

MR. JASINSKI: Yeah, in this particular 7

case, DOE did not assign a baseline value because it 8

was scr eened out, meaning because the air flow path 9

design technology option was not considered in the 10

engineering analysis. 11

MR. MESSMER: I guess what I’m saying is 12

that it should be. 13

MR. JASINSKI: Okay. 14

MR. BROOKMAN: It should be screened out. 15

MR. M ESSMER: No. It should be considered. 16

MR. BROOKMAN: It should be considered. 17

Thank you. That’s clarification. Diane. Please. 18

MS. JAKOBS: I wanted to go back to your 19

comment about

– 20

MR. BROOKMAN: To Adam’s comment. Yes. 21

MS. JAKOBS:

-- the paper about

– we’ve 22

looked at that paper too and at ASHRAE just last 23

month, I was talking to some of Greg’s engineers 24

about whether what’s important is that we’re getting 25Executive Court Reporters (301) 565

- 0064 73 close to the wheel in that study, or they’re giving 1

more space between the sides of t he housing and the 2

wall of the jacket. Because one of the things, 3

because we have all these components, they all have 4

to fit together and mix and match. We have fixed 5

widths, so we’re trying to get a lot of air flow. 6

We’re trying to use the space we hav e, and I know our 7

old Rheem air handler design had really tight

– the 8

sides of the housing were tight to the wheel, and we 9

felt like that improved our air flow. It was very 10

difficult manufacturing and we’re always fighting 11

about

– because in manufacturing they had trouble 12

getting the wheel into the housing and people on the 13

line would pry it apart and then it would be out of 14

alignment. 15

But Craig’s engineers there told me that it 16

was really that we had more room between the side of 17

the jacket and the ho using, it wasn’t

– so all these 18

things all work together, the air is everywhere and 19

it’s hard to distinguish exactly what

– you know, you 20

change one thing and you might be changing something 21

else without realizing it. 22

MR. JASINSKI: So are you suggesting that 23

air flow path design should be screened out or should 24

be retained or what? 25Executive Court Reporters (301) 565

- 0064 74 MS. JAKOBS: Well, as a manufacturer if I 1

was starting from scratch and I could redesign my air 2

handler furnace, I would work on air flow path 3

design, because that doesn’t c ost me anything. 4

MR. BROOKMAN: Charlie, I see Dave’s not in 5

his ..., Dave do you want to jump in here? 6

MR. WINNINGHAM: Yes, I would encourage that 7

the path design needs to be included. There are 8

various configurations and designs of blowers, the 9

devel opment angle, the tolerances, the type of wheel, 10

the angle of the blades into the wheel, the internal 11

restrictions

– all of these things are

– can be 12

critical and can have a significant difference on the 13

performance. You know, we’re all trying to squeeze 14

it into the smallest possible envelope, but there 15

needs to be a consideration for the design path, or 16

the air path because that can be a much more cost

17

effective option to improve efficiency, rather than 18

adding, you know, premium components. 19

MR. BROOKMAN : Okay. Thank you. Charlie 20

Stephens. 21

MR. STEPHENS: Charlie Stephens. I would 22

concur with all of the comments that have gone before 23

me here, and the Department seems to, in screening 24

this out

– I mean assuming we’re

– the subject of 25Executive Court Reporters (301) 565

- 0064 75 this rulemaking i s actually air handlers. Air flow 1

path design, based on my own experience in the field, 2

can often improve thermal performance when the air 3

flow path is improved, and can improve the product 4

utility, but the Department seems to have assumed 5

that it’s negat ive, or that because it’s potentially 6

negative that it should be screened out. I strongly 7

disagree with that, based

– I’m not going to name the 8

products that I have worked with, but believe me some 9

of them could have improved everything with a better 10

air flow path. And I think it is a way to achieve 11

efficiency relatively cost

- effectively. 12

MR. BROOKMAN: Several people are in the 13

queue. We’re going to go in this order as 14

efficiently and concisely as possible. Greg. And 15

then Abigail, and then Steve, an d then Adam, briefly. 16

MR. WAGNER: Okay. Greg Wagner. All these 17

– certainly the first two options, the fan housing 18

design and the air path design are significant 19

players in the performance and efficiency of these 20

products that we’re looking to cover he re , and you 21

can see in the E

- sub

- AE and the other numbers you’ve 22

been using that there’s a broad distribution of 23

electrical consumption, and it’s a function of those 24

different designs. And the question of how do you 25Executive Court Reporters (301) 565

- 0064 76 get a baseline, which I think this is t argeting to 1

where you start a baseline and then what is the max 2

technology piece, may be difficult to find because of 3

those parameters that are outside the scope of what 4

this is, which is a function of heat exchangers and 5

other things inside this unit. So I understand why 6

it’s screened out , but to the point of everybody 7

making these comments, those things do affect the air 8

flow efficiency. 9

MR. BROOKMAN: Abigail. 10

MS. DAKEN: So I heard somebody say that the 11

fan is testing in situ in the HVAC product in which 12

its intended, and what I’m hearing the manufacturers 13

say is that as long as that is the case, they will in 14

fact be modifying the air flow design to try to 15

achieve higher efficiency. And so it seems strange 16

not to take it into account in the analysi s, though 17

obviously, it’s going to be complicated. 18

MR. BROOKMAN: Thank you. Steve Rosenstock. 19

MR. ROSENSTOCK: Steve Rosenstock, EEI. 20

Again, I guess I was a little

– when I saw that in 21

the document, I was a little confused about it in 22

terms of are y ou talking about the air flow path 23

that’s really controlled by the manufacturer, the air 24

flow path that’s really a function of the house, the 25Executive Court Reporters (301) 565

- 0064 77 duct work that’s in the house, the existing house, or 1

the new house in terms of how you can modify that 2

path to ma ke the fan system more efficient, I guess. 3

Or are you just talking about the air flow path just 4

within the fan housing unit, and that’s it? Because 5

it seemed like you’re saying product envelope. I 6

thought you were talking a little bit almost about 7

the d uct work where the fan is being placed, or am I 8

misinterpreting? Again,

-- 9

MR. JASINSKI: The scope does not include 10

the duct work of the house. 11

MR. ROSENSTOCK: Specifically just talking 12

about within the fan unit, regardless of where

– 13

MR. JASINSKI : Right. Yes, the HVAC product 14

itself. 15

MR. ROSENSTOCK: Okay. That threw me off a 16

little bit, thank you very much. 17

MR. BROOKMAN: Adam, thank you for being 18

patient. 19

MR. CHRISTIANSEN: This is Adam from ASAP. 20

I know I commented on the fan housing before, but I’m 21

encouraged by the conversation here about maybe 22

considering the air flow path design as well, so I 23

would support that as well. 24

MR. BROOKMAN: Okay. Thank you. We’re 25Executive Court Reporters (301) 565

- 0064 78 moving on to the next slide. 1

MR. JASINSKI: I would also

– I’ll just say 2

that to include the air flow path design, DOE would

– 3

the type of information that would be very helpful 4

from industry participants and interested parties 5

would be specific, quantified savings related to 6

specific design changes, but also to echo what 7

M ohammed said to open the meeting, is that DOE is 8

also very interested in understanding where the 9

limits of those design modifications are as it 10

relates to impacting the overall system efficiency 11

negatively. So to include a design option for the 12

fan housin g design and air flow path design, that’s 13

the type of information that DOE’s continually 14

looking for and would appreciate from interested 15

parties. 16

MR. BROOKMAN: Diane. Oh, let’s hear from 17

Mohammed. Go ahead, Mohammed. 18

MR. KHAN: Sorry, Diane, I’ll m ake this very 19

brief. I just want to add on to what Sam just 20

mentioned, looking

– we’re asking for the data about 21

the improvements that can be made with changing the 22

air flow path design. I would like to see that data 23

also include not only what levels of improvements 24

that you can make with whatever kind of changes, but 25Executive Court Reporters (301) 565

- 0064 79 also include the cost element of it, so, you know, 1

how much

– and I heard you earlier, Diane, saying 2

that, I think your words were, it doesn’t cost 3

anything. But there’s always some cost as sociated 4

with anything. So that was it, thanks. 5

MR. BROOKMAN: Diane, follow on. 6

MS. JAKOBS: One of the problems with what 7

you’re asking

– you know I certainly want to help you, 8

but like Rheem has one design, Len n ox has one design. 9

You know we all h ave our individual designs, and we 10

certainly have opinions about each others designs, but 11

we don’t spend a lot of time testing each others 12

furnaces. So I don’t know if

– I know I was

– if we 13

can use the data from the AHRI directory, I don’t know 14

if you ca n use the E

- sub

- AE and characterize heat 15

exchangers and try to sort out the data that way, but 16

certainly at the very maximum each individual 17

manufacturer could do is give information about their 18

own equipment, and you would have to analyze it, and 19

you shou ldn’t play favorites. 20

MR. JASINSKI: We would love to do that. 21

MR. BROOKMAN: Yes, please, Craig. 22

MR. MESSMER: Craig Messmer, just to follow 23

up with what Diane said and what I was trying to drive 24

at before, there is such a wide variety of air flow 25Executive Court Reporters (301) 565

- 0064 80 p ath designs in the industry, when you do the 1

baseline, you have to establish what that’s going to 2

be and what the air flow path is. You can have the 3

same motor, the same fans, the same everything and the 4

air flow path can make or break you on the FER. So 5

there ha s to be some discussion on this, at least with 6

the baseline. Otherwise you could pick an FER that 7

only one manufacturer could, in fact, achieve, and 8

that would not be good. 9

MR. BROOKMAN: This was very useful, this 10

last discussion. Now we’re g oing to the last slide. 11

MR. JASINSKI: And this is just sort of a 12

summary of the results after the screening analysis. 13

These are the remaining six technology options that 14

were considered in the engineering analysis. 15

MR. BROOKMAN: So comments on the remaining 16

six? Joanna. 17

MS. MAUER: Joanna Mauer. Just a question. 18

Can you explain what you mean, the third option, ECM 19

fan motors where it says multi

- staging? Can you 20

explain what you mean by the multi

- staging? 21

MR. JASINSKI: Yes . They are used t ypically 22

with a furnace that also

– a furnace or HVAC that has 23

multi

- stage heating, and DOE found that in using the 24

FER metric or IFER metric, multi

- staging contributes 25Executive Court Reporters (301) 565

- 0064 81 to the efficiency improvements of that ECM fan motor, 1

so it’s sort of a joint technolog y option that’s used 2

together. So there’s efficiency benefits of the motor 3

technology as I stated earlier, that it operates more 4

efficiently and has a wider air flow range, but also 5

that it’s usually used in multi

- stage products, multi

6

stage heating produ cts. 7

MR. BROOKMAN: Diane. 8

MS. JAKOBS: Well, we were just

– Greg was 9

asking if we used PSCs and X13s in the multi

- stage, 10

and we do. But we did a

– we set up data collection 11

equipment with our modulating furnace and to just kind 12

of explain how it wor ks, our modulating furnace goes 13

from 40 percent capacity to 100 percent, and what 14

happened was the furnace would run almost continuously 15

at 40 percent, and the blower is backed off and 16

running at a lower speed, but over a longer period of 17

time. So that’s kind of the trade off that you would 18

address in the test procedure. But if you’re going to 19

imagine it’s running at 40 percent of the speed at a 20

longer time, so it’s not on and off like most people 21

are familiar with. 22

MR. BROOKMAN: Steve Rosenstock. 23

MR. ROSENSTOCK: Steve Rosenstock, EEI. 24

Again, I’ll just say for with the multi

- stage 25Executive Court Reporters (301) 565

- 0064 82 effecter , you’re also lowering the fan speed. However, 1

the efficiency metric as proposed is only based on the 2

maximum fan speed, correct? 3

MR. JASINSKI: No. the effic iency metric 4

has the consumption from each of three rated air flow 5

control settings. So if you look at the top of the 6

equation, you’ll see that it’s

– actually, I’ll just 7

go back to the slide so that everybody can see what 8

I’m referring to. So if you loo k at the equation, the 9

top is a summation of the operating hours times the 10

power consumption in each rated mode. So for FER it 11

would be cooling times the maximum

– the power 12

consumption in the maximum air flow control setting. 13

The heating hours would be multiplied by the power 14

consumption in the heating mode, or the heating air 15

flow control setting, and then finally constant 16

circulation. 17

MR. BROOKMAN: Diane, go ahead. 18

MS. JAKOBS: And it’s actually, for multi

19

stage, you had us collect the watts at th e lowest 20

heating speed, but then there’s a ratio and we 21

increase the hours. 22

MR. JASINSKI: Right. These details are 23

provided in the test procedure NOPR. I don’t have a 24

slide that can show that, but what she’s referring to 25Executive Court Reporters (301) 565

- 0064 83 is that the trade off that she mentioned earlier is 1

that you may be running the fan at a lower air flow 2

control setting, but the hours are increased to 3

account for that. So each of these variables CH , HH , 4

CCH, those are the hours that DOE is assigning to 5

those modes of operation, thos e are set values based 6

on analysis that DOE conducted. 7

So, for instance, CH is set at 640 hours, 8

heating hours is 830 hours, and then constant 9

circulation is 400. But for multi

- staging to account 10

for that trade

- off, the heating hours of 830 heating 11

ho urs, for a multi

- stage unit, would be divided by 12

what’s called the heat capacity ratio, and that’s the 13

output

– ratio of the output capacity in the lowest 14

heat setting divided by the output capacity in the 15

highest heat setting, usually results in something 16

around point seven, just for reference. And so that 17

would expand the 830 heating hours to, I think it’s 18

1185 , I’m not sure. 19

MR. ROSENSTOCK: Can you adjust the air flow 20

in the denominator as well? 21

MR. JASINSKI: The air flow in the 22

denominator is the max

– only in the maximum, yes. 23

MR. ROSENSTOCK: But you adjust the hours. 24

MR. JASINSKI: Yes. 25Executive Court Reporters (301) 565

- 0064 84 MR. ROSENSTOCK: Thank you. 1

MR. BROOKMAN: Final comments on this slide? 2

These issues, product classes, technology options are 3

very, very important. We spent a fair amount of time 4

on them. If we need to spend more time on them when 5

we return, we can and might, but now it’s time to take 6

a break. 7

It’s now 1 0 : 4 5 . Surprisingly, we are 8

tracking the agenda, which is a surprise to me, but 9

let me know

– w e did have almost an extra half hour in 10

there because we were efficient on the front end, so 11

when we return we’ ll have to remain efficient to get 12

through the remainder of the day. 13

Here in the Forrestal Building you must wear 14

this badge visible above your waist. There are 15

restrooms on both ends of the hall. If you’re going 16

to go for coffee, on the ground floor, which is 17

directly below us, go quickly if you’re going to go 18

get coffee because we will resume at 11 o’clock. 19

And thanks for a good start. W e really 20

gained ground on the content here. This was good. 21

(Whereupon, at 1 1 : 15 a.m., the meeting was 22

recessed for a 22 minute period.) 23

MR. BROOKMAN: So our apologies to those 24

that were joining us via the web. We somehow got 25Executive Court Reporters (301) 565

- 0064 85 adisconnect going there, and we, for those that are 1

joining us by the web again, we’ve delayed the meeting 2

so that you could be included, and I’m pleased you’re 3

back with us. W e a re going to re s u me with Sam and 4

launch into engineering analysis. 5

**Engineering Analysis** 6

MR. JASINSK I: Thanks, Doug. Yes, so I’ll 7

move on to the engineering analysis. Here’s the “you 8

are here” slide. The purpose of the engineering 9

analysis is to evaluate technologies that reduce 10

furnace fan electrical consumption and characterize 11

the relationship bet ween the cost to the manufacturer 12

of implementing those technologies and the expected 13

energy consumption reduction. 14

To the left you can see a very stylized 15

representation of the expected relationship between 16

the cost and efficiency. And essentially, the primary 17

outcome of the engineering analysis are a set of cost 18

efficiency curves, one for each key product class in 19

this particular rulemaking that looks somewhat similar 20

to that. And those results feed into our downstream 21

analyse s such as the life

- cycle cost and payback 22

period analysis , national impacts, and so on which 23

will be discussed in further detail later on in the 24

presentation. 25Executive Court Reporters (301) 565

- 0064 86 For the engineering analysis, here’s a list 1

of some of the central sources of information that 2

were used, publications l ike Appliance Magazine , the 3

performance directories from AHRI, and if we look as 4

far back as GAMA , manufacturer interviews, product 5

tear

- downs, and manufacturing cost modeling, and also 6

product energy testing was also conducted for this 7

rulemaking. 8

As I mentioned, DOE tests and tears down 9

products. DOE acquired units for testing and tear 10

down to assist in development of the FER and IFER 11

values. This table here just provides a general 12

overview of the types of products that DOE selected 13

for testing and te ar down. Twenty

- six units were 14

selected, six manufacturers were represented. DOE 15

typically tries to select test and tear down units to 16

span a number of manufacturers and even within

– 17

usually tries to select products within the same 18

product line of a sin gle manufacturer. And in this 19

particular case, the selections fell in that air flow 20

capacity range, 800 to 2200 CFM, and that’s typically 21

the maximum air flow capacity. 22

DOE also tries to select products that span 23

the available range of efficiencies, a nd in this 24

particular case, DOE targeted these technology 25Executive Court Reporters (301) 565

- 0064 87 variations which we’ve kind of touched on in previous 1

discussions: the motor type, PSC, constant torque, 2

brushless permanent magnet

– referred to as X13, 3

constant volume brushless permanent magnet

– referred 4

to as ECM. Again, the air flow capacity range. Heat 5

exchanger type

– there are a number of different types 6

of heat exchangers, depending on the application. 7

Some examples are clam shell, tubular, drum, hydronic 8

– and those refer a lot to the a pplication, as I 9

mentioned, but also the geometry of the heat 10

exchanger. 11

DOE also tried to isolate the variation 12

between non

- condensing and condensing units. As was 13

discussed earlier and mentioned, there are impacts on 14

fan performance when there is th e presence of that 15

secondary condensing heat exchanger. And finally, DOE 16

also tried to investigate different fan housing 17

designs. DOE is aware that there is at least one 18

proprietary design available. 19

MR. BROOKMAN: Aniruddh. 20

MR. ROY: Aniruddh. Aniru ddh, with an H. 21

MR. BROOKMAN: Aniruddh. 22

MR. ROY: Or Roy is fine as well. 23

MR. BROOKMAN: No, no. I want to get it 24

right. 25Executive Court Reporters (301) 565

- 0064 88 MR. ROY: Sam, one question I have for you 1

on on this slide is, you know, with respect to the 2

table ES.3.3 and 3.4, you have the backward incline 3

impellor technology in there. Was that also 4

considered under these technology variations? 5

MR. JASINSKI: So these represents the units 6

that were selected for test and tear down. To DOE’s 7

knowledge there is not a commercially availab le 8

product that includes a backward incline impeller, so 9

information

– I’ll get into this

– but information for 10

design options that are not commercially available in 11

an HVAC product, DOE relied on publications that had 12

detailed data about expected impacts on energy 13

performance and cost, if available. 14

MR. ROY: Okay. So the 63 percent reduction 15

that is shown in that table is based on that data? 16

MR. JASINSKI: The ECM

– 17

MR. ROY: For that max tech

– 18

MR. JASINSKI: Yes. 19

MR. ROY: Okay. 20

MR. JASINSK I: It’s based on test and tear 21

down data as well as data from those reports. 22

MR. ROY: Okay. Thank you. 23

MR. JASINSKI: Anyone else? To develop the 24

cost efficiency curves, DOE goes through the following 25Executive Court Reporters (301) 565

- 0064 89 four steps: 1

**•** First, DOE defines baseline specifi cations for 2

each product class; 3

**•** Next, DOE identifies design options from the 4

baseline to max tech as a pathway for improving 5

the efficiency of the furnace fan; 6

**•** Next, DOE conducts tear down analysis for the 7

selected products spanning the available range of 8

efficiencies; 9

**•** And then finally, DOE uses a cost model to 10

generate cost efficiency curves which account for 11

the full production costs. 12

As I mentioned, the first step is specifying 13

the baseline. DOE selected baseline models typical of 14

the least efficient furnace fans used in commercially 15

available HVAC models. For products that have 16

previous standards, usually the baseline is set at 17

whatever the current standard during that rulemaking, 18

or previous standard. However, because furnace fans 19

are not previousl y regulated, there is no previous 20

standard, and so DOE selected the baseline to be 21

typical of the least efficient furnace fan that’s 22

commercially available. 23

Across all product classes, a baseline 24Executive Court Reporters (301) 565

- 0064 90 furnace fan includes a PSC motor with three or fewer 1

air f low control settings, a forward curved impeller, 2

a standard sheet metal fan housing, a linear power 3

supply

– and again, this is referring specifically to 4

those product classes where standby and off mode is 5

considered

– and a laminated core power transforme r. 6

Any comments on the baseline specifications? 7

DOE, as I mentioned, DOE reviewed

– 8

MR. BROOKMAN: No comments on baseline 9

specification? I just thought I would give you a 10

chance. Okay. Go ahead. 11

MR. JASINSKI: DOE’s publicly available 12

informat ion, as well as the FER values and IFER values 13

that were calculated using the test data to determine 14

the baseline FER ratings that correspond with those 15

baseline specifications

– we have a question? 16

MR. BROOKMAN: Steve Rosenstock. 17

MR. JASINSKI: On th is slide or the

– 18

MR. ROSENSTOCK: Thirty

- four, the previous

– 19

yes, that slide, thank you. So you test data from the 20

manufacturer or you did your own testing? 21

MR. JASINSKI: It’s a combination of both. 22

MR. ROSENSTOCK: Combination. 23

MR. JASINSKI: DOE was able to find 24

performance data in specification sheets from 25Executive Court Reporters (301) 565

- 0064 91 manufacturers, but then as I mentioned, DOE also used 1

some

– used its own test data for

– 2

MR. ROSENSTOCK: Were they the same tests? 3

MR. JASINSKI: Meaning? 4

MR. ROSENSTOCK: Same exte rnal static 5

pressure, same

– 6

MR. JASINSKI: Yes. 7

MR. ROSENSTOCK: Okay. Next thing is, 8

basically on this table, for baseline sample, I want 9

zero for those cases, right, by way of a dash? 10

MR. JASINSKI: No, it’s not zero. This is

– 11

the dash here jus t represents not applicable in this 12

particular standard. I’ll explain. So, standby and 13

off mode for a lot of these products is already being 14

considered in other rulemaking activities. So, for 15

instance, furnaces and also some products that might 16

fall into the CAC scope of coverage, there are test 17

procedures and standards, either already specified or 18

being proposed for those particular products. So 19

their standby is not going to be included in this 20

rulemaking. 21

However, for hydronic air handlers, there’s 22

no previous standard and there are no standards or 23

proposed test procedures for standby and off mode for 24

those products, therefore that’s being covered in this 25Executive Court Reporters (301) 565

- 0064 92 rulemaking. 1

MR. BROOKMAN: Greg and then to Charlie. 2

Steve, you weren’t done. I’m sorry. 3

MR. ROSENSTOCK: No. So

– so basically 4

because the furnace system has a standby test 5

procedure or off mode, you’re not going to worry about 6

it for this, but doesn’t federal law says for any 7

product with

– that you’re doing an efficiency 8

standard that you have to look at standby? 9

MR. JASINSKI: Yes, I’ll let Michael Kido 10

speak to the statute. 11

MR. ROSENSTOCK: Okay. 12

MR. KIDO: Yes, that’s correct, but given 13

that there’s already some coverage of that particular 14

level of energy consumption in another p ortion, we’re 15

already considering that element as part of another 16

test procedure. That’s the way we’re viewing it. 17

MR. ROSENSTOCK: Thank you. Okay, again, it 18

was just

– so you’re saying there are some standby 19

watts but you’re not going to worry about it for this. 20

MR. JASINSKI: I think the confusion here

– 21

and I think there’s some detail provided, I believe, 22

especially in the test procedure NOPR, but the 23

justification behind this proposed approach is that 24

the fan is integrated

– so well integrated in to the 25Executive Court Reporters (301) 565

- 0064 93 controls of the HVAC product, that there’s no 1

distinguishable

– that it’s difficult to differentiate 2

the standby specific to the fan, as opposed to the 3

standby of the entire product. So the standby of the 4

entire product for those other products whi ch I’ve 5

already covered, is already being considered in those 6

other rulemaking activities. There’s no additional 7

standby watts that aren’t being considered. What 8

we’re saying is the same standby consumption of these 9

produc t s is covered

– is considered en tirely by those 10

other rulemakings. And so the similar case would be 11

for hydronic air handlers, for this particular 12

rulemaking, we are proposing to account for all 13

standby and off mode consumption of hydronic air 14

handlers. 15

MR. BROOKMAN: Greg, I think Ch arlie has a 16

comment that relates to this. Charlie, go ahead. 17

MR. STEPHENS: Yeah, I would suggest that 18

that’s not true. As I suggested earlier, some of the 19

air handlers that we’re concerned with are air 20

handlers that are also used as an indoor unit wit h a 21

heat pump system, for instance, in our part of the 22

world. I believe the Department hasn’t finalized that 23

test procedure yet, to my knowledge, but I believe the 24

proposals show standby consumption for those systems 25Executive Court Reporters (301) 565

- 0064 94 with an outdoor unit to be on the orde r of 33 watts. 1

Now the vast majority of that standby power is not in 2

the air handler, it’s in the outdoor unit. Now while 3

you may be accounting for the standby consumption in 4

the air handler portion, it is not 33 watts, I can 5

assure you. And so you real ly do

– if you’re going to 6

regulate an air handler, again, this is still a 7

question I realize, but if you’re going to regulate 8

the air handler it’s not the same number that you’re 9

going to have associated with these other rulemakings. 10

It’s going to be a d ifferent number. It may be a 11

component in that other number, but when you sell this 12

thing as an air handler and not a heat pump system, 13

split system, those numbers are not the same and you 14

need to get the right numbers on this product when 15

it’s sold as an air handler. 16

Secondly, by incorporating standby for 17

hydronic for air handler here, you have grossly 18

distorted the ratings for these things and how much 19

energy they use. In the examples that are published 20

in the PTSD, you’ve got a PSC equipped air handl er, 21

and you’ve got an ECM equipped hydroni c air handler. 22

The hydronic ECM air handler uses approximately one

23

half of the electricity annually, based on your 24

calculations, as the PSC air handler, and yet its 25Executive Court Reporters (301) 565

- 0064 95 efficiency rating is approximately eight times a s 1

good. So you’ve got a rating here that says it uses 2

one

- eighth of the energy, but it actually uses half 3

the energy when you look at the numbers in kilowatt 4

hours. That is a highly misleading arrangement. And 5

so I would suggest to you that you need to fix that. 6

MR. BROOKMAN: Thank you. Greg, and then to 7

Diane. 8

MR. WAGNER: Okay. Two

– this is Greg 9

Wagner. Two comments. One to dovetail with what you 10

were just talking about, with regard to the 11

differences in product classes. This gets back to 12

wh at we originally talked about in terms of scope, 13

scope of what the law and regulations covers and the 14

fact that these products haven’t been covered 15

previously for the standby watts, indicates they are a 16

separate class, and are not covered by this standard. 17

So that’s just further indication regarding scope. 18

To on to a question I have for Sam, you 19

mentioned that when you did this baseline 20

analysis,that you did some testing and you took 21

literature from the manufacturers. Your testing was 22

to the standard as it’s outlined currently, is that 23

correct? 24

MR. JASINSKI: Yes. 25Executive Court Reporters (301) 565

- 0064 96 MR. WAGNER: And you used the AMCA 210 type 1

of test process. The manufacturers don’t use the AMCA 2

210, so your numbers and their numbers are going to be 3

different. They use either ASHRAE 37 which is 4

different from the ASHRAE 51 equivalent to the AMCA 5

210, or they use another test which is that 103 test. 6

So you can’t add apples and oranges together. 7

MR. BROOKMAN: You think it would be 8

substantially different? 9

MR. WAGNER: Yes, there’s different 10

corrections for density, and different method of 11

testing, and this is what we covered in the last 12

session and we did that in our written comments. And 13

we’ll certainly reflect all those differences. 14

MR. BROOKMAN: Thank you. Diane, and then 15

b ack to Steve. 16

MS. JAKOBS: I did (off mic) ... 17

MR. JASINSKI: Diane, I think the microphone 18

is

– there’s trouble with the microphone. 19

MR. BROOKMAN: Is the mic on? 20

MS. JAKOBS: Oh, I pressed the button twice, 21

I guess. I had three samples of one furn ace model, 22

and I got 405, 415, 416. So I mean it sounds like a 23

little bit, but compared to 380, that’s more than ten 24

percent, I think. 25Executive Court Reporters (301) 565

- 0064 97 MR. JASINSKI: So your samples were non

1

weatherized, non

- condensing? 2

MS. JAKOBS: Non

- weatherized, non

3

condensing. And before

– I want to take back my

– 4

well, I’m not sure about my comment before. Part of 5

it, I might have mixed myself up, whether a good 6

number was higher or lower, but I do think that this 7

differentiation between condensing and non

- condensing, 8

you kn ow, is only 13 points on your chart, and that 9

might reflect

– it’s really what we were talking about 10

the air flow path and how you design it and what motor 11

speeds you select, that a non

- condensing gas furnace 12

might use more watts to provide the same compar able 13

performance. So it’s one of the things, it depends on 14

your design because turbulent air is good for heat 15

transfer and we can get our AFUE up, but it’s not as 16

good for the fan watts, so those are all interact. 17

MR. BROOKMAN: Craig. 18

MR. MESSMER: C raig Messmer. Looking at the 19

FER, I’m not at all thrilled by dividing it by the 20

maximum CFM. It’s going to skew a lot of numbers. 21

Some of that’s going to depend on the design of the 22

product itself. Not everybody’s

– if it’s a heating 23

product, the inten t is BTUs and here you’re kind of 24

dividing it by CFM. Nobody cares about the CFM, they 25Executive Court Reporters (301) 565

- 0064 98 only care about the BTUs. If you’re just going to do 1

the fan itself, then I don’t see why you’d want to 2

divide by the maximum CFM to get an FER. It should be 3

an avera ged number based on the CFM that’s operating 4

at the different multi speeds, for example. So I 5

think that we’re getting numbers that are so massaged 6

that you’re not going to have any reality to them. 7

MR. BROOKMAN: Steve. 8

MR. ROSENSTOCK: Steve Rosensto ck, EEI. I 9

was just also kind of curious if there was information 10

out

– you know, the new boiler standards kick in in 11

September for higher AFUE, and then the automatic 12

temperature resets control mandates, and then the 13

furnaces kick in in May, next year, fo r all of them 14

that are not in the condensing furnaces. And then you 15

have the small motor efficiency standards kick in in 16

2015, which I think there’s some correlation between 17

those small motors that are covered by DOE and then 18

the motors going into the fur naces. I believe a lot 19

of the same models are covered by

– again, the 20

manufacturers will let me know which ones are

– 21

there’s no correlation? They’re different fans? 22

Okay. Scratch that one, then. 23

I’m just kind of curious then if

– I mean 24

it’s reall y just for the boilers, if that makes a 25Executive Court Reporters (301) 565

- 0064 99 difference in terms of some of these ratings. 1

MR. JASINSKI: I don’t believe so. 2

MR. ROSENSTOCK: Okay. Thank you. 3

MR. JASINSKI: Rob. 4

MR. BOTELER: Yeah, the small motor 5

regulation that goes into effect i n 2015, it only 6

handles general purpose open motors. It does not 7

handle the type of motors that OEM specific. 8

MR. JASINSKI: Thanks. 9

MR. BROOKMAN: Let’s move on. 10

MR. JASINSKI: Okay. Just a couple of 11

bullets, and I hope I remember all of these. A s Greg 12

Wagner mentioned, there was some discussion during the 13

test procedure public meeting about the data that was 14

used to generate these values, and how manufacturers 15

using different setups might impact that. After the 16

framework document, or during the framework document 17

public meeting, DOE identified AMCA 210 as a standard, 18

and there were a lot of interested parties that 19

commented that that was a widely used and widely known 20

standard, and also was used to generate the air flow 21

performance tables that ca n be found in a lot of 22

specification sheets. I think there are even some 23

specification sheets that reference the standard in a 24

footnote. So it is important to get comments that 25Executive Court Reporters (301) 565

- 0064 100 might indicate whether or not those values would be 1

different. And if manufa cturer

– comments related to 2

how familiar manufacturers are with AMCA 210 and 3

whether or not they use that or test setups according 4

to AMCA 210 is important. 5

To Craig’s comments, the

– normalizing by 6

maximum air flow capacity

– we’ll get to this reques t 7

for comment. The intent here is two things. There’s 8

a relationship between

– the higher efficiency motors 9

react differently to increased external static 10

pressures. For an ECM motor, it will consume more 11

power to maintain a constant air flow at higher 12

external static pressures, whereas a PSC will provide 13

less air flow and therefore the consumption will go 14

down. So normalizing by the maximum is a means to try 15

to limit how sensitive the rating metric is to that, 16

so that higher efficiency motors are not be ing 17

penalized because they’re still providing more air 18

flow. 19

And on the other side, is it’s also a 20

mechanism to try to reduce the sensitivity of the 21

metric to changes in capacity because DOE expects that 22

air flow

– maximum air flow capacity is specifie d with 23

some relationship to BTUs, as you mentioned. I know 24

there are a lot of numbers out there, you know, 25Executive Court Reporters (301) 565

- 0064 101 anywhere between 350 to 450 CFM per ton. Ton here is 1

a reflection of the capacity. So that’s just an 2

overview. Comments regarding those assumption s and 3

whether or not normalizing achieves those goals is 4

something that DOE is very interested in. 5

MR. BROOKMAN: Diane. 6

MS. JAKOBS: So one thing that I was a 7

little bit concerned about, these numbers, they look 8

kind of similar to what

– if you were j ust going to 9

measure the CFM and measure the watts in an 10

installation, you would get kind of same order of 11

magnitude numbers. And we’re already having trouble 12

now where there are some hand held tests, combustion 13

analyzers, and people are trying to, in the field, 14

commission their equipment. And they’re saying that 15

we’re not meeting our AFUE rating because they have 16

this hand held analyzer that they’re testing their 17

installed unit on, and I wish that we could do AFUE 18

testing with a hand held analyzer, but i t’s much more 19

complicated than that. And those numbers, they look 20

kind of the same, so I was thinking that the IFER, 21

actually looked better because it was significantly 22

different but my friends pointed out that we were 23

already on the path to submitting st andby watts. But 24

these are similar order of magnitude numbers to what 25Executive Court Reporters (301) 565

- 0064 102 they’re talking about in California, but a different 1

test procedure, but so

– just for what that’s worth. 2

Thank you. 3

MR. BROOKMAN: Thank you. Okay. Jim 4

Vershaw, you’re next. 5

M R. VERSHAW: Jim Vershaw, Ingersoll Rand. 6

I think I made this comment during the test procedure 7

thing. But we do not use AMCA 210 for either our 8

furnaces or our air handlers. If we were making a fan 9

only, we would, but this is an appliance that 10

generate s heating and cooling, and that falls under 11

ASHRAE 37, and of course, furnaces are tested under 12

ASHRAE 103. So the numbers that you’re going to get 13

using 210 are going to be different than what you 14

find, at least in our literature. 15

MR. BROOKMAN: Yes, D ave. 16

MR. WINNINGHAM: This is Dave from Allied. 17

I would echo what Jim has said. We do not use AMCA 18

210 either at Allied or at Len n ox to generate air flow 19

tables. And would also recommend that these baseline 20

numbers be thoroughly reviewed before any mi nimum 21

threshold level is established. 22

MR. JASINSKI: So once the baseline has been 23

established, DOE identifies intermediate efficiency 24

levels as a path to more efficient products. Each 25Executive Court Reporters (301) 565

- 0064 103 efficiency level above the baseline is defined by a 1

specific design option used to achieve that level. 2

DOE determined average percentage reductions in FER or 3

IFER for each efficiency level and applied these 4

reductions across all product classes. The reasoning 5

behind that is DOE found that manufacturers use 6

similar compon ents and design paths to improve 7

efficiency across all product classes that DOE is 8

examining. DOE does not expect that the percent 9

reduction FER associated with each design option, 10

whether commercially available or prototype, will 11

differ across product cl asses. 12

DOE based the reductions in FER associated 13

with commercialized technologies on measurements or 14

publicly available performance information, and DOE 15

based the FER reductions associated with prototype 16

technologies or those that aren’t in commercial 17

a pplications on research reports that included 18

detailed performance data. 19

This table provides a snapshot of those 20

percent reductions in FER. As I mentioned, DOE 21

assigned the percentage reductions in FER to each 22

efficiency level to obtain FER values for i ntermediate 23

efficiency levels. DOE also assigned a reduction in 24

standby watts for the standby design options. 25Executive Court Reporters (301) 565

- 0064 104 MR. BROOKMAN: Steve Rosenstock. 1

MR. ROSENSTOCK: Steve Rosenstock, EEI. And 2

again, I know we had the discussion about standby 3

before, but ag ain, since you’re analyzing this 4

component as a stand alone appliance, was there any 5

information about the standby power usage of these 6

components, and in some cases did they ever increase, 7

let’s say, with level four, or the multi staging 8

control added a c ouple watts just because it’s 9

tracking everything. 10

MR. JASINSKI: Yeah, those

– that standby 11

consumption, in consideration of that, is considered 12

in the other rulemaking, so for instance, in this 13

particular case, in the components of the fan that are 14

bei ng analyzed, I think the analysis shows that an ECM 15

motor contributes anywhere between three to five watts 16

of standby and that is for the products where you see 17

a non

- applicable

– those watts are included in the 18

analysis and standards that are being consid ered or 19

specified in those other rulemakings. 20

MR. ROSENSTOCK: Okay, and

-- Steve 21

Rosenstock, EEI

– thank you for that. Suppose the 22

baseline is, I’ll just say one watt. I don’t know 23

what it is for the baseline unit. But then you get to 24

level four and it’s five watts, you’re saying, oh, 25Executive Court Reporters (301) 565

- 0064 105 I’ll do that in another analysis. Well, hold on a 1

second. You were analyzing this component. If you’re 2

ignoring those watts, that’s reducing the energy 3

savings, that’s going to have an impact on your energy 4

analysis a nd your life

- cycle cost analysis and all the 5

other analyses. Isn’t it? I understand what you’re 6

saying. It’s really covered in another

– in the 7

overall system standby, but since you’re analyzing 8

this component as a stand alone appliance, by not 9

looking at it

– if it were zero, great, it’s no 10

problem. It makes no difference whatsoever. But 11

there is a difference upwards or downwards, it could 12

have an impact on the rest of the

– it won’t have an 13

impact on the metric, but it will have an impact on 14

the ener gy savings and life

- cycle cost analysis. 15

MR. JASINSKI: Those costs and benefits are 16

included in the other rulemaking, so those

– 17

MR. ROSENSTOCK: But there’s a separate cost 18

and benefit analysis for this rulemaking. 19

MR. JASINSKI: Yes. 20

MR. ROSENS TOCK: Okay. So, and again, it’s 21

a component system issue is you’re saying we’re going 22

to do the standby for the system, but not going to 23

worry about the standby for the component. It’s kind 24

of a dichotomy there. 25Executive Court Reporters (301) 565

- 0064 106 MR. BROOKMAN: I see Alex wishes to co mment. 1

Find a microphone, Alex. Maybe that one right over 2

there. Yes, coming back to you, Diane. 3

MR. LEKOV: Alex Lekov, Lawrence Berkeley 4

National Laboratory. So to answer these impacts are 5

included in the life

- cycle cost analysis, and it will 6

be ex plained in the follow up slides, when we get to 7

this point. 8

MR. BROOKMAN: Okay. Thank you. Diane. 9

MS. JAKOBS: Just kind of to emphasize how 10

intertwined all these parts are, on a furnace, our 11

biggest source of standby watts is actually a 12

transformer that you need when you run the air 13

conditioning. So, at Rheem we talked about moving 14

that transformer outside, so the guys downstairs would 15

have to worry about it, but that didn’t fly. So they 16

work as a system, and we assume they’re all going to 17

work to gether and it’s hard to attribute specific 18

components to different modes of operation. It’s 19

difficult. 20

MR. BROOKMAN: Okay. Thank you. Keep going 21

– oh, Greg, go ahead. 22

MR. WAGNER: Greg Wagner. Question about 23

the efficiency number that you have the re under number 24

five, the center column, what’s the basis for that? 25Executive Court Reporters (301) 565

- 0064 107 MR. JASINSKI: The basis for that is 1

research reports and data that was acquired using a 2

prototype furnace that had a backward incline impeller 3

installed. 4

MR. WAGNER: The one that was referenced in 5

the TSD? 6

MR. JASINSKI: Yes. 7

MR. WAGNER: Okay. I reviewed that report, 8

and that’s testing a blower only. Isn’t that tested 9

in a unit? And it was one data point, and gentleman 10

from Southern California Edison pointed out that as 11

you va ry performance, those numbers change. 12

Additionally, that blower component was tested by 13

Lawrence Berkeley, and they put a report out in 14

September 2005 and in it, on Page 41, they basically 15

say they see no efficiency gain from using that in it, 16

in a furnac e system . So I guess, do you look at all 17

the literature, or just part of the literature? 18

MR. JASINSKI: No, we look at all the 19

literature. A lot of the issues that you are raising, 20

there’s a request for comment to get more information 21

about the perform ance across the entire range of 22

operation. The 2005 report that you mention, we do 23

have access to some of the raw data for that, and that 24

testing was done with the prototype. And here, the 25Executive Court Reporters (301) 565

- 0064 108 prototype I’m referring to is the premium ECM motor 1

with the back ward inclined impeller. A premium ECM 2

motor here is a motor that is narrower, that is the 3

diameter is smaller so there’s less interference with 4

the blower inlet, but it also operates at higher RPM 5

which is characteristic of a motor that’s paired with 6

a ba ckward incline prototype, and that prototype was 7

installed in the

– in a furnace, so that raw data was 8

taken while it was installed in situ, to my knowledge. 9

So some of the analysis is also done on that raw data 10

that was used for that 2005 study that you mentioned. 11

And, as a preface to the comments that we’re 12

requesting, DOE is very aware that there are varying 13

degrees of performance and DOE is asking for data and 14

comments to understand what the expected relative 15

efficiency of operation would be for impl ementing a 16

backward incline impeller, among many other issues. 17

MR. WAGNER: Well, this ten percent used 18

later to drive your energy savings, I notice. 19

MR. JASINSKI: Yes, I can say that with the 20

raw data we saw anywhere from

– a lot of the reports 21

don’t

– obviously don’t use the rating metric that 22

we’re pro posing, that DOE is proposing. But the 23

benefits

– there’s a wide range between, like you 24

said, in some cases, very small to much larger than 25Executive Court Reporters (301) 565

- 0064 109 ten percent, and that’s impact on FER. So DOE is 1

proposing to use ten percent in the preliminary 2

analysis and also asking for comment about the 3

appropriateness of that number. 4

MR. WAGNER: Well, I just want to go back to 5

the report that you referenced. We gman (ph) in blower 6

only, did have one point that was te n percent, but the 7

rest of it was two to four percent in the other 8

systems they analyzed. But the specific one that got 9

to ten percent when Ian Walker and company out of 10

Lawrence Berkeley tested it, they report that they 11

didn’t see any improvement or enha ncement. 12

MR. JASINSKI: Sure. The ten percent 13

reported in that is not using

– this is ten percent in 14

FER, so the FER is actually a little bit more 15

sensitive. So a ten percent reduction there would 16

actually be something along the lines of 20

– a lot 17

lar ger percent reduction in FER. So this is not 18

simply taking the ten percent from that report and 19

plugging it into our analysis. 20

MR. WAGNER: I would say it’s less sensitive 21

because you have multiple operating points and the 22

efficiency is going to change over those operating 23

ranges, as pointed out earlier, and shown in the 24

report, and it would actually reduce those numbers, 25Executive Court Reporters (301) 565

- 0064 110 not increase them. 1

MR. BROOKMAN: Okay. Thank you. Detlef

. 2

MR. WESTPHALEN: Detlef Westphalen, Navigant 3

Consulting. I guess we wrestled with some of this 4

data as well, and, you know, some of this work was 5

going on over a number of years, not all of it was 6

made public. Some of the reports that were made 7

public showed less benefit than some of the other data 8

that was

– that we were eventually able to obtain. 9

So, the story is not all in the reference. 10

That just happens to be the public reference that 11

could be cited. And so one of the questions is, 12

whether more of this data could be made public, but 13

that’s not for me to answer. 14

MR. BROOKMAN: Let me just note that this is 15

important stuff and we’re diving rather deep it seems 16

to me. We need to make sure we come up high enough so 17

we cover all this material. Diane, go ahead. 18

MS. JAKOBS: I just want to say that I think 19

it was se veral years ago, maybe about the time you 20

came to ... to visit Sam, but I did try to get

– I was 21

on the C S A 8 23 committee, and I did try to get a hold 22

of this prototype to test it in one of our furnaces, 23

and I talked to Lau and Regal Beloit, and there seemed 24

to be some intellectual property, they didn’t know if 25Executive Court Reporters (301) 565

- 0064 111 they could share with me, and because you have to run 1

the wheel, you know, it’s not just a matter of getting 2

that particular wheel, you have to run it at much 3

higher RPM, so I was trying to get the moto r and the 4

control that I never did get it. I tried for six 5

months or something, so I did try to test this in our 6

furnace, and was unsuccessful. 7

MR. BROOKMAN: We’ve had a lot of comments 8

on slide 36 and there are many other equivalent slides 9

which follo w, so let’s press on. 10

MR. JASINSKI: Okay. 11

MR. BROOKMAN: Final comment from Craig, and 12

then we’re moving on. 13

MR. MESSMER: Craig Messmer. I see these 14

percentages on this chart and I looked in the TSD, I 15

don’t know where they come from. Are you g oing to 16

explain where these come from? Because 45 percent, 59 17

percent, are pretty big numbers. 18

MR. BROOKMAN: You’re referring again to 19

slide 36? 20

MR. MESSMER: Yes. 21

MR. BROOKMAN: Keep going, Sam. Sam, are 22

you saying where these

-- 23

MR. JASINSKI: As I mentioned, we used the 24

publicly available performance data that was in 25Executive Court Reporters (301) 565

- 0064 112 specification sheets to derive FER values and IFER 1

values, in addition to the testing that was done by 2

DOE. 3

MR. MESSMER: And you did it at the static 4

pressures required by the new FER

-- 5

MR. JASINSKI: Yes. 6

MR. MESSMER:

-- test procedures? Because 7

the motors aren’t really that much more efficient. 8

But, that’s okay. 9

MR. BROOKMAN: So in your comments, right. 10

Okay, then on to the next. 11

MR. JASINSKI: For all product c lasses 12

except hydronic air handlers, DOE analyzed four 13

efficiency levels in addition to the baseline and the 14

max tech for a total of the baseline plus five 15

additional efficiency levels. Here are the results 16

for the primary

– or excuse me, the non

- hydronic key 17

product classes. We won’t spend too much time reading 18

each of the numbers unless someone has prepared a 19

specific comment about the values. If not, written 20

comments on these levels would be appreciated. 21

MR. BROOKMAN: If there are overarching 22

comme nts on these numbers as we had in the previous 23

slide, then I think that would be helpful. Then we 24

will move on. 25Executive Court Reporters (301) 565

- 0064 113 MR. JASINSKI: For furnace fans using 1

hydronic air handlers , DOE considered two additional 2

efficiency levels, efficiency levels six and seven , 3

and those are using the design options that reduce 4

standby and off mode energy consumption. Here’s the 5

analogous table for hydronic air handler furnace fans. 6

So as you see, the baseline through

– well, one 7

through five have the same design options, and then 8

there are the t wo additional, the switching mode power 9

supply and toroidal (ph) transformer for six and 10

seven. 11

MR. BROOKMAN: Brian first. 12

MR. JAMES: Brian James, Southern California 13

Edison. Just a point of clarification. Are six and 14

seven an add

- on to five? 15

MR. JASINSKI: Yes. 16

MR. BROOKMAN: Diane. 17

MS. JAKOBS: Well, we have a hydronic air 18

handler and we

– the way we advertise it, we match it 19

with a condensing tankless water heater which would

– 20

if you looked at the efficiency of the con densing 21

water heater, and you looked at this, you would assume 22

that your operating costs would be much lower than a 23

condensing furnace. And I don’t think that’s true at 24

all. So I think that this is misleading because I 25Executive Court Reporters (301) 565

- 0064 114 think you can, in the same installa tion, have a choice 1

between a direct

– you need to make a direct 2

comparison between a gas furnace and a hydronic air 3

handler. 4

MR. JASINSKI: Yeah, I don’t mean to speak 5

for Diane, but I think this comment is related to the 6

discussion earlier about how th e metrics for hydronic 7

air handlers uses the integrated fan efficiency rating 8

which includes standby and off mode and therefore is 9

normalized by total annual hours because it includes 10

those, which makes these numbers a lot less in 11

comparison. So correct m e if I’m wrong, but

– 12

MS. JAKOBS: Yeah, I mean

– I like these 13

numbers better. But, you know, just because of the 14

waiting for the standby mode at the much lower watts 15

level, they just look like you’re saving money, and 16

you would not be. 17

MR. BROOKMAN: Okay. Thank you. 18

MR. JASINSKI: So now, just a request for 19

comment about the rating metrics, that they will not 20

be dependent on capacity because they are normalized 21

by the maximum air flow capacity. This is something 22

that I asked earlier. If anybod y has comments related 23

to how the proposed metric is impacted by capacity. 24

MR. BROOKMAN: Move on. 25Executive Court Reporters (301) 565

- 0064 115 MR. JASINSKI: After establishing FER 1

values, the next part of the engineering analysis is 2

to develop costs for these values. The manufacturing 3

cost mod els were developed by DOE as part of the 4

efficiency level approach. First, bills of material 5

are generated during product tear down analysis and 6

entered into a cost model. The cost model generates 7

manufacturing material, labor, and overhead costs. 8

The p hysical tear down, as I mentioned earlier, is 9

conducted on representative products that were 10

selected based on the criteria that I spoke about, and 11

as part of this preliminary manufacturer interviews 12

are conducted to further refine some of the inputs for 13

t his cost model. And that flow chart there provides a 14

graphic for what I just described. 15

This is a lot of detail about what is 16

included in the cost of production numbers in terms of 17

the structure and classification of the manufacturing 18

cost. I won’t go into a lot of detail about these, 19

but you have this slide for reference, and it’s also 20

included in Chapter 5 of the TSD. 21

MR. BROOKMAN: Rob. 22

MR. BOTELER: We had a couple of comments 23

earlier about the cost of the ECMs and one of the 24

things that we as m otor manufacturers noted is we’re 25Executive Court Reporters (301) 565

- 0064 116 not aware of any conversations with Navigant to 1

actually get motor costs from us. Maybe they got 2

motor costs from the air handler manufacturers, but 3

they didn’t get them from us so we’re not sure if they 4

are correct in yo ur calculations. 5

MR. JASINSKI: Typically, manufacturer 6

interviews are conducted mostly during the NOPR phase, 7

and my understanding is that typically manufacturer 8

interviews are targeted towards the HVAC product 9

manufacturers, so those prices, if we do g et any, 10

would come from them. 11

MR. BROOKMAN: Diane. 12

MS. JAKOBS: I mean certainly we did talk to 13

you, I don’t know. Two weeks ago, I took the same 14

heat exchanger and the same jacket and we offer it 15

with a PSC motor X13 and ECM. I did one, one sample, 16

and it was

– our cost for the X13 was almost double 17

what is in this table. And then we had AHRI group 18

that we’ve been discussing all this, and I asked if 19

other manufacturers saw the similar patter n . So I had 20

agreement from other manufacturers. If you g ave us 21

that small a data set, we would criticize you, but 22

that’s what we have. That’s just what I did for a 23

check. 24

MR. JASINSKI: There will be an opportunity 25Executive Court Reporters (301) 565

- 0064 117 during the NOPR where extensive manufacturing 1

interviews are conducted to have these types of 2

conversations and refine the analysis. 3

MR. BROOKMAN: Alex. 4

MR. BOESENBERG: Alex Boesenberg, NEMA. I 5

would encourage the Department and Navigant on those 6

interviews to bear in mind, when you make the cost 7

scaling factors, that certainly I heard more than one 8

fan manufacturer here mention that they do, some of 9

them do pretty small runs, which means that you don’t 10

get the economies of scale that may be reflected in 11

those original estimates. If it’s a million motors a 12

year, not buying a million at once, maybe only a few 13

hundred, and that of course results in a lot less 14

savings, so please bear that in mind. Thank you. 15

MR. BROOKMAN: Yes, Dave. 16

MR. WINNINGHAM: I would concur with Diane’s 17

comments. We actually analyzed about six furnaces 18

with simila r configuration with the exception of the 19

motor and the controls, and found a distinctly 20

different

– difference in price delta. I would also 21

recommend that as you look at this price delta, to 22

include all aspects of the installed cost. Because, 23

in many ca ses, the higher efficiency motors require 24

additional controls and wiring that goes along with 25Executive Court Reporters (301) 565

- 0064 118 them, and make sure that you’re including those costs 1

as part of that. 2

MR. JASINSKI: Sure. Thank you. And I 3

guess it would be good to mention that

-- a lot o f 4

manufacturers are mentioning that they’re doing 5

analyses

– if you can share that data in your written 6

comments, t hat would be really appreciated, but also, 7

as a note, if there is information that you are 8

wanting to protect, the manufacturer interviews ar e 9

conducted under NDA agreements so that might be 10

another opportunity to provide data that you might not 11

want to submit publicly. 12

MR. BROOKMAN: Diane. 13

MS. JAKOBS: We kind of brought it up, that 14

everything’s going so fast, but, you know, if you’re 15

int erested in one little data point, it seems trivial, 16

but if that’s still interesting, I guess

– 17

MR. JASINSKI: Every little bit helps. 18

MS. JAKOBS: Thank you. 19

MR. BROOKMAN: Charlie Stephens. 20

MR. STEPHENS: Just a quick point of 21

clarification. Ch arlie Stephens. Are these fan costs 22

and fan pricing, or air handlers? 23

MR. JASINSKI: Yeah, I’ll get into that, 24

I’ll show you specifically what’s included in the

– 25Executive Court Reporters (301) 565

- 0064 1 19 MR. STEPHENS: Okay. Thank you. Because 1

the design options only so far, are fan relate d. 2

MR. BROOKMAN: Let’s proceed then. 3

MR. JASINSKI: So to answer Charlie’s 4

question, the costs used in the engineering analysis 5

represent the cost of the furnace fan, and not the 6

cost of the entire HVAC product. The following 7

components are included in the manufacturer production 8

cost, MPC, estimates: 9

**•** the fan motor and integrated controls, 10

**•** the primary control board, 11

**•** the impeller, 12

**•** the fan housing, 13

**•** and components used to direct or guide air flow. 14

And the last one is somewhat ambiguous, but 15

I will ex plain that. When reverse engineering these 16

products, there are elements that are easily 17

distinguishable as intended specifically to direct air 18

flow, maybe over the heat exchanger, or

– and these 19

would be typically, you know, sheet metal or something 20

like that. Those elements were included in the costs 21

because they’re expected to have an impact on the 22

efficiency, therefore we want to include them in the 23

cost. 24Executive Court Reporters (301) 565

- 0064 120 MR. BROOKMAN: Greg. 1

MR. WAGNER: Were motor mounting 2

arrangements also considered? I don’t s ee that up on 3

there. In other words, there’s something that holds 4

the motor in place. 5

MR. JASINSKI: Yes. 6

MR. WAGNER: Okay. Just not listed. 7

MR. JASINSKI: So the fan motor and 8

integrated controls

– yeah, it’s not explicit, and so 9

as a point of cl arification, the fan motors are 10

typically considered a purchase part and in a lot of 11

cases, that

– the mount may come as part of that 12

purchased part as an assembly from a component 13

supplier. But, DOE does reverse engineer them also to 14

get costs, whether i t’s a purchased part or

– but it 15

is included. 16

MR. BROOKMAN: Terry Small, you’re next. 17

MR. SMALL: Terry Small at Mortex. I just 18

wanted to ask, it looks to me that you’re basing your 19

manufacturing cost on a manufacturer that would be 20

making one and a quarter million fan furnaces a year. 21

And that may be indicative of a residential furnace 22

manufacturer, sort of what I would call a high volume, 23

low mix manufacturer. But a lot of these product 24

classes, including the additional product classes, the 25Executive Court Reporters (301) 565

- 0064 121 volume s are such that they’re really low volume, high 1

mix, and that would be completely inappropriate, those 2

manufacturing costs, for some of the smaller 3

manufacturers. So could you address that? 4

MR. JASINSKI: Sure. I think the next slide 5

will

– it’s a good segue into the next slide. 6

So as many interested parties have 7

commented, DOE separated furnace and product classes 8

into high volume and low volume product classes to 9

account for factors that impact manufacturers’ 10

production cost and purchasing power. F or instance, 11

some products

– DOE is aware that some products are 12

produced at significantly higher volumes than others. 13

Some manufacturers offer most types of HVAC products, 14

while others only focus on small niches. 15

So high volume manufacturers operatin g in 16

lower volume adjacent markets are expected to have the 17

same purchase part price efficiencies consistent with 18

their overall purchasing volume. This just means that 19

even if a particular HVAC manufacturer is offering a

– 20

one product that has a very low volume of shipments, 21

if that manufacturer also produces another product 22

that has a high volume of shipments, they will get the 23

same

– similar pricing because they can purchase 24

motors that might be used in both. 25Executive Court Reporters (301) 565

- 0064 122 And then lastly, low volume operations, wer e 1

model ed to have lower production volumes and fewer 2

shifts per day, to account for the fact that not all 3

manufacturers have production volumes on the order of 4

1.25 million units per year. And at the bottom here, 5

you can see

– these are the products

– thi s is the 6

separation of product classes into high volume and low 7

volume. So all product classes

– oil furnaces and 8

hydronic air handlers were classified as low volume 9

product classes. The rest were high volume. 10

And the math here is right. Like, non

11

weatherized gas furnaces, that accounts for condensing 12

and non

- condensing. So not all nine product classes 13

are listed here, but all the products are. 14

MR. BROOKMAN: Greg. 15

MR. WAGNER: Greg Wagner. In the third 16

bullet item, you mention that the high v olume 17

manufacturers are going to get

– expected to get the 18

same purchasing power for all products. That may or 19

may not be true, because small volume products are run 20

through different processes than high volume products , 21

and so there are different costs b ased upon volumes of 22

production

. You can’t make that, I guess, universal 23

blanket statement there. 24

MR. BROOKMAN: Diane. 25Executive Court Reporters (301) 565

- 0064 123 MS. JAKOBS: To make things harder for you, 1

our hydronic air handler uses the same blower system 2

as a gas furnace. So even though we’re not selling a 3

lot of them, you know, they’re coming from the same 4

pool that we have for gas furnaces. 5

MR. JASINSKI: That’s exactly the third 6

point, that for someone in that situation, you’re 7

using

– you’re ordering one component for both the 8

small production volume and large production volume 9

together. 10

Do DOE uses a design option approach to 11

estimate the cost of technologies not commercially 12

available in furnace fan applications. These are 13

essentially the design options that aren’t offered in 14

pr oducts that can be torn down. So here you have the 15

table that shows the efficiency level and design 16

option, and then the high volume and low volume 17

estimated manufacturer production cost. 18

And just as an explanation, so the inverted 19

controls for the PSC motor, this cost is based on a 20

reverse engineering inverter that can and was used in 21

a furnace fan application. There’s the specific model 22

that was used, and that comes out to, as you can see, 23

$12.00 for the high volume, and $16.00 for the low 24

volume, and that’s only the cost for the inverter. 25Executive Court Reporters (301) 565

- 0064 124 Next, the premium ECM, multi

- staging and the 1

backward curved impeller, DOE used a ten percent 2

markup on the estimated cost for an ECM as the added 3

cost for the premium ECM motor. As a reminder, the 4

premium ECM mot or is that ECM motor that’s a little 5

bit narrower and operates at higher RPM, which is

– 6

DOE expects is required for backward curved impellers. 7

DOE used photographs and specifications found in 8

research reports to determine cost model inputs to 9

estimate th e MPC of the backward curved impeller. It 10

turned out to be $12.00 for low volume and $12.32 for 11

the high volume. 12

MR. BROOKMAN: Greg. 13

MR. WAGNER: On that BC wheel technology

– 14

backward inclined wheel technology requires much 15

tighter tolerances in or der to be effective. How is 16

that accounted for, because the tolerances are on an 17

order of magnitude tighter in order to get the same 18

effect. In addition to that, the motor mounts and the 19

support structure, et cetera, were going to have to be 20

significantl y beefed up in order to be able to be 21

shipped in process. So I would question those dollar 22

numbers on those bases alone. 23

MR. JASINSKI: In this particular case, the 24

cost model for a standard forward curved was

– the 25Executive Court Reporters (301) 565

- 0064 125 products were compared and as I said, the inputs for a 1

backward curved were determined, based on the 2

differences identified between the two. So if there 3

are other factors that would need to be included in 4

that cost, written comments or comments during 5

interviews that would tell us what else needs to be 6

included, and how much that costs so we can use those 7

as inputs, would be greatly appreciated. 8

And then finally, the efficiency

– excuse me 9

– the estimates for efficiency levels six and seven 10

are identical to those used in the HVAC products, the 11

other standby and off mode rulemakings. 12

MR. BROOKMAN: Craig. 13

MR. MESSMER: Just going back to that slide, 14

you really think that you could make those products 15

for $12.00? And the backward curved impeller and 16

motor for $107? 17

MR. JASINSKI: Based on our analysis. 18

MR. MESSMER: Okay. You have that somewhere 19

that we can take a look at that and comment on it? 20

MR. JASINSKI: Yes, it’s in the TSD, and if 21

you provide written comments explaining why that 22

should go up, then that would be appreciated. 23

MR. MESSMER: There’s so much detail in the 24

TSD that would tell you not how those are derived. 25Executive Court Reporters (301) 565

- 0064 126 MR. JASINSKI: Well, there’s detail about 1

the methodology used and the cost model. So if you 2

can talk about maybe a particular component that’s not 3

being in cluded that’s necessary, I think you mentioned 4

that the mounts need to be different or if you can 5

explain the different processes, the cost model used 6

can account for most of those variations, we just need 7

– DOE just needs to know what those variations are

. 8

MR. MESSMER: Well, given they’re not used 9

currently, there’s not a good model to give you that 10

guidance. But what I’m suggesting is there wasn’t any 11

details in the TSD to be able to make that kind of 12

evaluation of how you generated your costs. 13

MR. JASINSKI: Well, as I’m saying, nothing 14

– I’m not leaving any details out. Essentially, you 15

look at the standard forward curved impeller that’s 16

included in current models and by observation you 17

compare the design, based on what type of processes 18

DOE expec ts are used, what types of materials, that’s 19

put in the cost model, and the cost model uses 20

assumptions about material prices and all those other 21

costs that this slide shows, to generate the estimated 22

manufacturer production cost. If there’s something 23

mis sing or something that shouldn’t be included, or 24

something that needs to be tweaked, those are things 25Executive Court Reporters (301) 565

- 0064 127 that we can use to change our inputs to the cost 1

model, to generate different values. But for this 2

particular case, that was the methodology used. So if 3

that methodology needs to be changed, DOE would 4

appreciate comments on what we left out, or how it 5

should be done different, and that way we can refine 6

the analysis. 7

MR. BROOKMAN: Mohammed. 8

MR. KHAN: Mohammed Khan, DOE. First, I 9

appreciate the fact that, you know, in some instances 10

there might not be a full enough description on the 11

methodology for you to comfortably be able to comment 12

on. However, if you’re able to look at these numbers 13

as you are right now, and it seems to be that you 14

believe tha t they’re off, they’re probably too low, 15

and you know that they should be much higher, based on 16

your expertise and your manufacturing knowledge, your 17

manufacturing processes, it would be very helpful for 18

us for you to comment on what your process is and ho w 19

you know these prices should be higher based on your 20

knowledge alone, rather than not being able to comment 21

on our methodology. But just give us what you know 22

and then we can certainly take that information into 23

account. Thanks. 24

MR. MESSMER: Well, t o that point, we 25Executive Court Reporters (301) 565

- 0064 128 manufacture a product that’s not like these currently, 1

but the product that we manufacture would be in a 2

different process than what would be used for the 3

manufacture of these types of products in the 4

tolerance level that’s described in th e literature and 5

other places that we know is necessary to apply that 6

technology, would have a different manufacturing 7

process all together. So using the same metric for 8

evaluating one technology versus the other wouldn’t 9

necessarily be appropriate. 10

MR. JASINSKI: So if you, in your written 11

comment for example, if you could explain the process 12

that would be used, that’s an input we can use in the 13

cost model that would change the result. And in 14

addition to what Mohammed said, another very important 15

facto r in refining these costs are the inputs that we 16

get from manufacturers who have the expertise and who 17

are actually producing them. So those are also 18

considered. It’s not just what the model generates. 19

So the next few slides are comments specific 20

to ea ch of the design options. This one in particular 21

is comment on inverter driven PSC fan motors. DOE 22

requests data and energy

- related

– data regarding the 23

energy performance and costs. As I said, DOE based 24

its cost on a reverse tear down of an inverter th at 25Executive Court Reporters (301) 565

- 0064 129 can be used in these applications, and the energy 1

performance information was taken from a product that 2

was formerly commercially available that used this 3

technology. 4

Here’s a snapshot of the engineering 5

analysis results. Essentially the data used th at make 6

up the cost efficiency curve. At the top you can see 7

– this is for the high volume, key product classes. 8

At the top you can see the manufacturer production 9

cost. And as I mentioned, because DOE doesn’t expect 10

that manufacturers are using differe nt components or 11

pathways to improve efficiency across different 12

products, then the same manufacture production cost is 13

applied across all product classes here. 14

Here’s that same data, just in graphical 15

representation. And as you can see, it reflects the 16

stylized version that I showed earlier where, as FER 17

decreases, meaning the energy consumption decreases, 18

the estimated manufacture production cost increases. 19

MR. BROOKMAN: Yes, Dave. 20

MR. WINNINGHAM: This is Dave from Allied 21

Air. A question on EL

- 4 where you’ve got an ECM plus 22

multi

- staging. Is the additional cost

– the furnace 23

fan is one component of that multi

- staging, but there 24

are other components that go into that multi

- staging, 25Executive Court Reporters (301) 565

- 0064 130 is that at all accounted for in your

– 1

MR. JASINSKI: Yes. The increased cost of 2

the primary control board is included, in addition to 3

wiring, and also the gas valve. 4

MR. BROOKMAN: Diane, you wish to comment on 5

these numbers? 6

MS. JAKOBS: It would be the control, the 7

gas valve, the wire harnesses, and the motor. 8

MR. JASINSKI: Uh

- huh. Here are the results 9

for the low volume key product classes, again, non

10

weatherized oil, non

- condensing and hydronic air 11

handlers. As you can see those manufacture production 12

costs are higher to reflect the fact of the low volum e 13

– the factors that I spoke about earlier in terms of 14

the differences in volume. 15

And here are those in graphic form. As 16

you’ll notice, the hydronic air handler curve has two 17

additional points, and those are related to the 18

standby and off mode design op tions. 19

One particular issue that DOE requests 20

comment on is the turn down ratio of the different 21

motor technologies. Here the turn down ratio is the 22

ratio of the minimum motor speed to the maximum motor 23

speed. DOE has preliminarily found that high 24

effi ciency motors, on average, have lower turn down 25Executive Court Reporters (301) 565

- 0064 131 ratios, which indicates that it has a wider range of 1

achievable speeds. So DOE seeks comment on the 2

typical turn down ratios that can be achieved 3

technically and in practice by each motor technology. 4

And I provided

– there’s a list here of the motor 5

technologies of interest. 6

MR. BROOKMAN: Yes, Paul. 7

MR. LIN: Paul Lin from Regal Beloit. In 8

the TSD, I’m not sure if I

– maybe I missed it

– where 9

you talked about what speeds you assumed on the turn 10

down? You did in the detailed report on the speeds. 11

MR. JASINSKI: Yes, it’s the maximum and the 12

minimum. 13

MR. LIN: No, in evaluating the turn down 14

ratio for a PSC, the high efficiency, did you specify 15

what RPM you were turning down to in the FER, in 16

detail ? 17

MR. JASINSKI: No, I think

– in the TSD we 18

just provided the actual turn down ratios, but I can 19

explain that what was done, is for all the units that 20

we had information for, the performance information is 21

usually in the form of a table of air flow and CFM 22

across a range of external static pressures for each 23

available air flow control setting. So to generate 24

those ratios, the air flow at something close to the 25Executive Court Reporters (301) 565

- 0064 132 proposed reference standard, external static pressure, 1

the air flow in the minimum was divided by the air 2

flow in the maximum at that external static pressure 3

for each model that we had that information for. And 4

then, you know, generated average values based on 5

that. But I believe the table with the percentages is 6

in there, that’s how that inform ation was generated. 7

MR. BROOKMAN: No additional comments on 8

turn down ratio? 9

MR. JASINSKI: DOE requests comment on 10

proprietary permanent brushless magnet motor 11

technology. DOE is aware that there might be 12

intellectual property around some of the hi gher 13

efficiency motor technologies, so DOE seeks comment on 14

the validity of its premise that alternative motor 15

technologies can achieve comparable performance, i.e., 16

the turn down ratios and efficiency, at comparable 17

cost to the brushless permanent magnet motor 18

technology offered by Regal Beloit. Many interested 19

parties have commented that there are issues related 20

to this, so DOE seeks comment on the validity of that 21

assumption. And essentially the availability , cost 22

and relative performance of alternativ es. 23

MR. BROOKMAN: Yes, please, Steve. 24

MR. ROSENSTOCK: Steve Rosenstock, Edison 25Executive Court Reporters (301) 565

- 0064 133 Electric Institute. In terms of this, do we have any 1

information about the patents length of these 2

manufacturers? I mean of these patents for whichever 3

aspects of the te chnology. You know, a typical patent 4

can last as long as 17 years. So depending on

– and 5

they can be extended as well. So again, I don’t know 6

what the time frame for the expiration of the patent 7

is after, let’s say, 2020. I don’t know exactly how 8

these other manufacturers are going to use similar 9

technologies without

– they’d have to pay a licensing 10

fee or something. 11

MR. BROOKMAN: Diane. 12

MS. JAKOBS: Part of it, it isn’t just the 13

motor technology, it’s the good job that GE and Regal 14

Beloit have don e in providing us engineering tools, so 15

that we can easily apply their products. And I know 16

Rheem has been approached by manufacturers from other 17

countries and they, on the surface, seem to have this 18

similar motor technology, but they want us to provide 19

t hem the program. Well, we use a Regal Beloit program 20

to program the motors, so it’s all kind of tied in 21

that we don’t

– we program the motors, but we use 22

engineering tools from Regal Beloit in order to do 23

that. So I guess we’re not as smart as maybe we c ould 24

be, but that’s kind of where we are. We depend on the 25Executive Court Reporters (301) 565

- 0064 134 vendor to provide the technology for us to use this 1

ECM technology. 2

MR. BROOKMAN: Okay. 3

MR. JASINSKI: Yeah, just as a follow on. 4

The crux of this is that the MPC estimates reflect 5

what DO E expects are current manufacture production 6

costs, but DOE is trying to understand the market 7

factors that need to be considered to understand what, 8

in the presence of standards and in the absence of 9

standards, I think we’ll talk about these different 10

sce narios, what will happen to our assumptions and 11

costs. 12

MR. BROOKMAN: Rob. 13

MR. BOTELER: Rob Boteler with NEMA. Yeah, 14

just to pick up on that comment, that’s exactly right. 15

What the motor manufacturers in the US do, is we have 16

labs where we actually bring in the fan equipment from 17

our customer, and we go through a characterization 18

process for our ECM that’s in a lot of cases, unique 19

to each manufacturer’s application. So it’s not just 20

an off the shelf product that’s available. 21

MR. BROOKMAN: Okay. Move on to six. 22

MR. JASINSKI: DOE is requesting comments on 23

high efficiency fan motor control cost. DOE would 24

like information regarding whether or not more costly 25Executive Court Reporters (301) 565

- 0064 135 primary control boards that are required to be paired 1

with higher efficiency motors, an d this, just as a 2

clarification or a preface, DOE is aware that ECM or 3

higher motor efficiency technologies come with their 4

own integrated controls, but this request for comment 5

is aimed at trying to understand the impacts on the 6

primary control board of t he HVAC product, whether or 7

not those become more complicated, and in turn, more 8

costly when being paired with those higher efficiency 9

motor technologies. 10

MR. BROOKMAN: Terry Small, you’re next. 11

MR. SMALL: Terry Small, Mortex. I’d like 12

to point out that right now the watts spread, the 13

number of manufacturers, and usage in PSC motors gives 14

a lot of flexibility for both big and small 15

manufacturers to use the technology. If we end up 16

outlawing PSC motors, which I don’t know whether 17

that’s the hidden ag enda here, I think you will

– then 18

we’re relying on one or two manufacturers of the more 19

efficiency technologies for motors. That would be a 20

real disservice to the consumer. Thank you. . 21

MR. BROOKMAN: Thank you. Other comments on 22

high efficiency fan motor control costs? Yes, Diane. 23

MS. JAKOBS: We talked about it in 2010, but 24

one of the issues with the programmable motors is 25Executive Court Reporters (301) 565

- 0064 136 replacement in the field. And I think you added 1

something in there for that, but when we started out 2

we ended up with kind of a special motor for every 3

furnace model, and then to replace it, a lot of our 4

customers, our distributors didn’t want to stock all 5

of these flavors of ECM motors, and because they’re 6

expensive. So it turns out that maybe to replace your 7

ECM motor you h ave to air freight it in, because no 8

one keeps it in stock. You have to get it directly 9

from the manufacturer. And we’ve tried to do some 10

things to get around that, but I don’t know how 11

widespread it is in the industry. So that issue of 12

where does the p rogram reside for this programmable 13

motor? Does it sit in the motor or in the furnace? 14

And then there are safety implications if

– it’s like 15

all our components don’t really talk to each other, 16

they kind of assume each individual component knows 17

what it’s supposed to be doing and if there’s a 18

mismatch it might be a safety hazard. 19

MR. BROOKMAN: Okay. Paul, did you have a 20

comment? 21

MR. LIN: I was just going to comment that 22

there exists more than one or two motor manufacturers 23

that provide ECM technolog y, so that there’s a breadth 24

of manufacturers that provides motor technology 25Executive Court Reporters (301) 565

- 0064 137 relative to the access as well as a fully ... ECM. 1

MR. BROOKMAN: Okay. I have a comment from 2

Jim Vershaw. Jim, you’re next. 3

MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 4

On iss ue four, the turn down, you’ve got to remember 5

that there is an upper end to how fast typical blower 6

wheels can be turned and a lower end to what bearings 7

can handle the motors. That kind of limits your turn 8

down. So please be aware that if you’re going to try 9

to go above 11, 1200 RPM, you’re going to have to 10

change the blower wheel and make it more expensive. 11

So maybe if your analyses are going above that RPM, 12

you’ve got to be aware of that. 13

On issue six, on the fan control, yes. The 14

furnace controls change with fan type, or motor type I 15

mean. You will get substantially different needs for 16

different types of motors, and usually they’re more 17

complex as you go up in motor complexity as well. 18

Thanks. 19

MR. BROOKMAN: Okay. Thank you. On to 20

issue seve n. 21

MR. JASINSKI: Issue seven is regarding 22

backward inclined impellers, and we’ve touched on some 23

of these a little bit already, so DOE seeks comment on 24

the expected efficiency improvements across the range 25Executive Court Reporters (301) 565

- 0064 138 of operating conditions in residential applicat ions. 1

This request speaks to the issue that’s been raised 2

about how the relative performance is different under 3

different operating conditions. So DOE is requesting 4

information to understand that so that it can be 5

reflected in the analysis. 6

MR. BROOKMA N: I think we already received 7

one comment on this, did we not? Additional comments 8

on backward inclined impellers? Diane. 9

MS. JAKOBS: I was working on this a couple 10

of years ago, but there’s an ISO standard

– I think it 11

was someone from Lau who was telling me about it, but 12

there are different levels and he had a graph where he 13

showed where for different diameters and for larger 14

diameters, it is significantly more efficient, but he 15

had them where they were crossing, just in the ten 16

inch area where we are. And since that was my project 17

in advanced R&D that was a kind of disappointing 18

revelation, but we’re kind of

– for residential 19

furnace fans and diameter of wheels that we’re using, 20

there seems to be certain tradeoffs in that area, and 21

where if you we re going to a commercialized unit where 22

they are more and more common, that there’s clearly an 23

advantage. But in our specific size, there is some 24

issues where the trend is not what it is at larger 25Executive Court Reporters (301) 565

- 0064 139 diameters. 1

MR. BROOKMAN: Okay. Greg. 2

MR. WAGNER: Gr eg Wagner. I commented a 3

bunch on this earlier, but I’ll just reiterate that 4

the literature that you reference in some of the 5

testing shows that there are varying degrees of 6

performance improvements and reduction, depending on 7

where you’re operating it in the system. So it’s not 8

a universal

– that it translates into appliances. 9

MR. BROOKMAN: Okay. Additional comments? 10

MR. JASINSKI: One that we didn’t touch on 11

and I’ll mention it is the DOE is seeking comment on 12

whether the backward inclined impelle r could impact 13

product offerings that might

– if it’s incompatible 14

with certain designs or components currently used in 15

furnaces. That’s important information to understand 16

how implementing them might impact the mix of product 17

offerings. 18

MR. BROOKMAN: Greg. 19

MR. WAGNER: I’ll comment on that one. 20

Specifically to that with the implementation of 13 21

SEER furnaces in particular, and other products like 22

that, have shrunk in size because of available space 23

to fit them in most homes. They have eight foot 24

ce ilings as a max, and so when you’re putting in a 25Executive Court Reporters (301) 565

- 0064 140 bigger coil to do the air conditioning part, the other 1

remaining parts of the system are shrunk down. Back 2

when Wegman (ph) and those guys did the research in 3

2003, that wasn’t part of the equation. Since then, 4

furnaces have gone from 46 to 52 inches down to about 5

33, 34 inches, principally. So there’s even less 6

space today for the air moving section, if you will. 7

So to your comment about designs and impact, that’s a 8

significant impact on being able to im plement some of 9

these technologies perhaps, in many applications. 10

MR. BROOKMAN: Thank you. Other comments? 11

MR. JASINSKI: Regarding the air flow path 12

design, DOE seeks comment on air flow path design 13

changes that could result in improved air flow 14

eff iciency, and in addition to that, cost and 15

efficiency data related to those air flow path design 16

improvements, and also the expected tradeoffs between 17

air flow efficiency and thermal efficiency or system 18

efficiency for those designs. But I think these are 19

issues that we have already touched on in depth, but 20

written comments would be really appreciated. 21

MR. BROOKMAN: Yes, and if you want to call 22

out any specifically that you don’t think we’ve 23

covered sufficiently, that would be okay, but

– Jim 24

Vershaw, y ou’re next. 25Executive Court Reporters (301) 565

- 0064 141 MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 1

Back to the previous issue, if you look at the Wegman 2

(ph) report , once you get above 1200 CFM

– 3

MR. BROOKMAN: Jim, see if you can speak up, 4

please. 5

MR. VERSHAW: Okay. I am. If you look at 6

the Wegman (ph) report, the results above 1200 CFM 7

showed that FC wheels are actually more efficient than 8

BI wheels. So I think you’ve got to be careful on the 9

backward inclined as far as capacities. You get 10

above three tons of air flow, the performance is going 11

to fall off unless you essentially different wheel 12

diameters and speeds. Thanks. 13

MR. BROOKMAN: Thank you. Okay. And 14

comments on air flow path design. We’ve covered this 15

somewhat, maybe fully. Additional comments? Terry 16

Small, you’re next

. 17

MR. SMALL: Hi. This is Terry Small with 18

Mortex. On issue eight, and this we’ve had a lot of 19

discussion on it. But I think what was interesting, 20

I’m a bit dismayed that the word safety has never 21

crept into the discussion so far. And so much of air 22

path design is around the safety aspects of whether it 23

would be a heat exchanger, or a natural gas furnace, 24

or resistance heat, where you’re worried about where 25Executive Court Reporters (301) 565

- 0064 142 the limits operate, even on a hydronic unit. So I 1

think that the air path design is very much to be 2

determined more by safety, which of course is a 3

liability to manufacture. We’re less concerned about 4

efficiency when it comes to safety. Any comments on 5

that? 6

MR. JASINSKI: Yeah, I would just say that 7

one of the major screening criteria is we ev aluate 8

technology options for their health and safety 9

impacts, so if there are specific health and safety 10

impacts that would be related to any type of air flow 11

path design, DOE would really appreciate comments 12

regarding that, so that it can be considered i n the 13

screening analysis. 14

MR. BROOKMAN: Additional comments on air 15

flow path design? And then we have kind of a summary 16

box, correct? 17

MR. JASINSKI: Right, just other comments or 18

recommendations related to the analyses I’ve 19

presented: the market and technology assessment, the 20

screening analysis, and the engineering analysis in 21

general. 22

MR. BROOKMAN: Any overarching comments at 23

this point? Okay, so it’s now 12:30. I’m going to 24

sugg est we pause for lunch , and I think we need it. 25Executive Court Reporters (301) 565

- 0064 143 We’ve covered a l ot of ground. It’s been very, very 1

productive conversation. I appreciate especially all 2

of you coming forward with such good comments. 3

You’re probably familiar

– many of you 4

worked in this building before. Once again, you must 5

wear this badge. Thi s room will be locked during 6

lunch, or it will be supervised, so you can leave your 7

stuff here. T here’s a big cafeteria, down to the 8

ground floor about 100 yards in that direction after 9

you get to the elevator. It’s 12:30. W e will take a 10

full hour for l unch, because that’s about how long it 11

takes, which means we’ll resume at 1: 30. We’re a 12

little behind on everything, but we’ll catch it up. 13

You may need an ID to get back in. Sometimes 14

they require it, sometimes they don’t, but you’ll have 15

to go back through security portal

– what do they call 16

those things. So anyways, thanks for a good morning, 17

we’ve got more to cover, but we’ll get there, and 18

we’ll see you back here to start at 1:30. 19

(Whereupon, at 12: 30 p.m., the meet ing in 20

the above captioned ma tter was adjourned for lunch 21

recess , to reconvene at 1: 30 p .m.) 22

23Executive Court Reporters (301) 565

- 0064 144 AFTERNOON SESSION 1

1:31 p.m. 2

MR. BROOKMAN: We’re still a few folks 3

short, but l et’s start back up. Thanks for coming 4

back. Thanks for being on time. We’re now going to 5

proceed with Marku ps, Energy Use Characterization, and 6

LCC, and payback period analysis and hear from Alex 7

Lekov. 8

**Markups, Energy Use Characterization** 9

MR. LEKOV: Alex Lekov, Lawrence Berkeley 10

National Laboratory. So we co mplet ed engineering 11

analysis, and now we’re conti nuing on the economic 12

analysis with the focus on the impacts on the 13

consumers and follow up by national impact analysis. 14

So here is the diagram showing where this 15

belongs in the flow of the overall analysis, and 16

directly switching to my first topic, whic h are the 17

markups. But here is essentially, it is a component 18

of the overall economic analysis. 19

So markups or product price determination, is 20

used to characterize the channels, how a product are 21

distributed as well, to determine the price paid by 22

the consumers for baseline and higher efficiency 23

products. 24

So in this part of the presentation, I also 25Executive Court Reporters (301) 565

- 0064 145 will be talking about the energy use characterization, 1

which essentially develops the energy consumer savings 2

for the considered efficiency levels. And t hose will 3

be tied in the overall life

- cycle cost and payback 4

analysis, which also are developed for all analyzed 5

efficiency levels. 6

Here is the overall flow. What you see here 7

is the typical life

- cycle cost analysis. Essentially, 8

it’s based on total in stalled cost for the products, 9

and lifespan operating expenses. This is the total 10

installed cost represented by the upper part of the 11

chart, lifetime operating expenses represented by the 12

lower part of the chart. All the components, as you 13

see them on th is chart, will be discussed in some 14

detail in the next slides. 15

So, starting with the markups. Markups 16

relate consumer price to cost of goods sold. The 17

markups are not the same for baseline and for the 18

higher efficiency standard. This is a methodology 19

that DOE developed over the years and it’s been the 20

same for many rulemakings, some of you participated 21

over the last period. So we have baseline and 22

incremental markups. The incremental markups do not 23

include the component of the cost that are not 24

impac ted by the higher efficiency product, and that 25Executive Court Reporters (301) 565

- 0064 146 would be primarily the direct labor cost, which 1

includes salaries, renting occupants. 2

DOE’s approach also developed the markup 3

originally for all geographical areas considered in 4

the analysis. The lower of the slide shows the 5

sources for development of the markup for all market 6

participants. I suggest not to read it in details, 7

manufacturer markup comes from engineering, wholesale, 8

and mechanical contractors come from Hardy (ph) and 9

AMCA reports. General c ontractors markups, as well as 10

manufactured home. Manufacturer and contractors come 11

from different table of 2007 economic census. And the 12

sales taxes are coming from what’s called Sales Tax 13

Cleaning House Data, which essentially includes this 14

data

– repo rts this data by state. 15

As mentioned in the beginning, one of the 16

purposes of the markup analysis is to identify the 17

channels, the distribution channel for the product. 18

The important thing here is to highlight that furnace 19

fans are essentially component s of a furnace fan 20

equipment. Therefore, they’re distributed as part of 21

the equipment. Therefore, the channel shown here, the 22

two market segment, replacement and new construction, 23

are for the furnace fan equipment, and you’re familiar 24

with similar charts which were shown during the 25Executive Court Reporters (301) 565

- 0064 147 residential furnace rulemaking, residential ... 1

rulemaking. There is a separate channel for 2

manufactured homes. 3

So, with that, here is our first question. 4

DOE in this analysis did not consider a distribution 5

channel for repla cing furnace fans which are already 6

included in installed equipment. So the question here 7

is if such things exist, what’s the market share if it 8

exists? So any information on this topic will help 9

DOE to determine whether such distribution channels 10

should be included in the analysis. 11

MR. BROOKMAN: Diane. 12

MS. JAKOBS: Okay. This one thing I went in 13

– we have a man who’s in charge of quality, and I went 14

and talked to him about replacement rates for higher 15

efficiency motors versus PSC motors, and we wen t back 16

and forth, and we came up with that we’re seeing a 17

failure rate of double in higher efficiency motors 18

than we do with the PSC. And you have to keep in mind 19

that our focus is on the warranty part because that’s 20

what we’re paying. But he said they s tart out pretty 21

even the first year, and it can get much, much worse 22

if there’s a specific problem. But he was saying 23

overall he would say it was double the failure rate. 24

So something is going on there, and just the 25Executive Court Reporters (301) 565

- 0064 148 idea that you have a copper control b oard in a air 1

stream that might have moist air, that that’s not a 2

failure that can happen on a PSC motor. It’s only 3

because you’ve added this electronic control that 4

you’ve added another failure mode. 5

So you’re saying for replacing furnace fans, 6

usual ly because the set screw is jammed onto the 7

shaft, you know, they probably end up replacing 8

several components even though maybe the motor control 9

board is the only component that you end up doing a 10

whole assembly. So I’m not exactly

– I know in the 11

analy sis you excluded the warranty period, but 12

actually if we have a lot of warranty cost, we’re 13

going to put that in our original sale price. So, you 14

know, I don’t know how to handle it , but that bit of 15

information that the higher efficiency motors pretty 16

muc h have double the failure rate. 17

MR. BROOKMAN: Do they have different 18

maintenance requirements or anything like that? No, 19

they’re not. 20

MR. LEKOV: So let me connect to your 21

statement. I believe you are referring to replacement 22

in case of failures. T hose, you will see a little bit 23

further, those are accounted in the analysis. Here is 24

the primary issue is a replacement

– whether such 25Executive Court Reporters (301) 565

- 0064 149 things exist

– a replacement for efficiency reasons. 1

MS. JAKOBS: Ah, like

– 2

MR. LEKOV: That they’re already

– in the 3

frequency, you’ll see the detailed analysis, there is 4

a whole slide on this topic. It has been accounted 5

for. 6

MS. JAKOBS: We are not excited about that 7

at all because of the safety implications. So we 8

discourage it. I know it exists. 9

MR. BROOKM AN: Steve Rosenstock. 10

MR. ROSENSTOCK: Steve Rosenstock, EEI, but 11

it’s also replacement in case of current motor 12

failure, right? That would also fall under that? 13

That they’ve decided not to replace the whole unit, 14

but just the fan because that’s all t hat needed to be 15

replaced and the old fan is shot, so replace it with a 16

new fan? 17

MR. LEKOV: I would say the repair and 18

maintenance slide will probably talk more about this 19

aspect of it. Okay. Thank you. 20

So with that, here are the results. 21

Essenti ally, the average markups for the market 22

participants as explained in the introductory slide 23

showing them for mobile home and non

- mobile home 24

classes, but the baseline and incremental markup and 25Executive Court Reporters (301) 565

- 0064 150 also the market participant. Note that those are 1

average val ues. 2

The LCC analysis and the salary (ph)

– we do 3

this several times

– represent actually distribution 4

of values. So the households are getting different 5

within the range of this average. 6

Maybe more informative is this one, that’s 7

the final, actuall y, average markup by product class. 8

MR. BROOKMAN: Yes, Craig. 9

MR. MESSMER: I have a question on t he 10

incremental markups you have. This is Craig Messmer, 11

I’m sorry. You’ve got a lower value. Is that 12

incremental going to apply to once it is the ne w 13

baseline? I mean if you go to a higher standard which 14

becomes the baseline, you don’t really have an 15

incremental markup any more, correct? Isn’t that now 16

what the same markup would be for the baseline? I 17

mean, I don’t understand why they’re different. 18

You’ve got a much lower markup for the incremental 19

cost than you do for the baseline cost. And I read 20

the document, and I know there’s a graph and curve 21

that you used to come up with that, but if you have

– 22

if you have an option to a piece of equipment, yes, it 23

might have a smaller markup for that option, but if 24

it’s the baseline unit, it’s going to have the same 25Executive Court Reporters (301) 565

- 0064 151 markup for the whole unit. 1

MR. LEKOV: Yes, the baseline markup is the 2

baseline. If the unit is a baseline unit, then the 3

baseline markup is applied to the baseline unit. 4

MR. MESSMER: Okay. But why is the 5

incremental lower then? 6

MR. LEKOV: The incremental markup indicates 7

that not all cost are additionally marked up when the 8

equipment becomes more efficient. And as I already 9

stated, th is is the only difference is the direct 10

labor cost, essentially. The salaries don’t change 11

it, the people. If they can

– for example, a 12

distributor, salaries are the same; renting in the 13

warehouse is the same; utilities that he pays inside 14

are the same. This is our interpretation, and that’s 15

the basis of this. 16

MR. MESSMER: Right. Go back to

– I mean 17

one of the things in the document you show that the 18

X13 to the consumer is going to be an extra $50 or 19

$60, compared to the baseline. So that’s telling me 20

that the margin for that $60 is going to be

– it’s 21

going to be much smaller than what the margin was for 22

the base cost. 23

MR. LEKOV: So just go

– to highlight this, 24

this incremental markup applied to the incremental 25Executive Court Reporters (301) 565

- 0064 152 cost only. 1

MR. MESSMER: That’s wh at I’m saying. No, I 2

get that. I just don’t think it’s valid is all. 3

Enough said. 4

MR. BROOKMAN: Okay. Thank you. Other 5

comments on these two markup slides? 6

MR. LEKOV: So this was the questions about 7

any recommendation aspect of the markup analys is. And 8

with that

– 9

MR. STEPHENS: Yes, I do have one. 10

MR. BROOKMAN: Yes, Charlie. 11

MR. STEPHENS: Only on manufactured homes, 12

your numbers on the manufactured homes, new 13

construction, look a little high to me. And I don’t 14

know if it stems from you r terms of reference

– you 15

called it, I think, in the chain, a contractor, a 16

manufactured home contractor. Where we live, they’re 17

called a dealer. 18

MR. LEKOV: Correct. 19

MR. STEPHENS: And they sell the home and 20

they do arrange for the setup, which does n’t really 21

have to do with the mechanical system, typically. But 22

I’m trying to understand, when you say contractor , 23

where do you get your markup for a manufactured home, 24

as I say in our region, dealer, for the thing? Is he 25Executive Court Reporters (301) 565

- 0064 153 a contractor, or is he a dealer ? 1

MR. LEKOV: So the one for new construction, 2

you are correct, dealer or builder or general 3

contractor, this is the term of the participant. And 4

here are the sources that are used for the derivation 5

of this particular markup. As you see, the general 6

c ontractor markups comes from financial data from 2007 7

economic census, specifically from the residential 8

building construction sector tables. 9

MR. STEPHENS: Well, yeah, and I guess what 10

I’m getting at here is in the bullet on manufactured 11

home, manufactu rer and contractor markups. 12

Manufactured home, manufacturing sector, I understand 13

that, and that’s for the making and assembling of the 14

home and the installation of the

– the buying and the 15

installation of the HVAC system and components. But 16

then you hav e all other specialty trade contractors. 17

The people who sell the new home are not a contractor. 18

They’re more akin to a car dealer. They sell a home 19

like a car dealer sells a home, and there is a markup, 20

but I don’t think the markup is a contractor’s mar kup. 21

A typical contractor’s markup where we are is like 22

1.3. I think that you’ll find if you actually look

– 23

I don’t think that source is where you’re going to 24

find the right numbers is what I’m getting at here. I 25Executive Court Reporters (301) 565

- 0064 154 think you need to look more closely int o how 1

manufactured homes are sold, because I’ve never heard 2

the term contractor applied to that level in the 3

chain. 4

MR. LEKOV: Okay. 5

MR. BROOKMAN: Thanks, Charlie. Yes, Tom. 6

MR. ECKMAN: And I would recommend that DOE 7

consult the group that’s wo rking on the new 8

manufactured housing standards for the markups in that 9

sector, since you have another rulemaking that’s 10

proceeding down those lines. Access to that 11

information should be readily available. 12

MR. BROOKMAN: Thank you. 13

MR. LEKOV: Thank you. So with that, 14

switching to the next precursor to the life

- cycle cost 15

analysis, which is the energy use characterization. 16

And the purpose of it is to determine the annual 17

energy cost. In order to do this , energy consumption 18

of the furnace and produ ct in the individual 19

households need s to be determined with associated 20

energy prices. 21

So it came through this morning, the way the 22

energy use is determined in its essence, is sum of the 23

energy use at each operating mode: heating, cooling, 24

and constant ventilation for each household. The 25Executive Court Reporters (301) 565

- 0064 155 primary components are the operating hours and power. 1

In addition to this, the analysis account for the 2

effect of more efficient fans on the overall energy 3

use of the household space conditioning equipment. 4

The next s lides will go in details of all those. 5

MR. ROSENSTOCK: Quick question. 6

MR. BROOKMAN: Steve, please. 7

MR. ROSENSTOCK: Are there plans to use some 8

of the RECS 2009 data for this analysis as you go on 9

through the NOPR stage? 10

MR. LEKOV: Absolutely. The NOPR phase will 11

be based on RECS 2009, and we already started to 12

download the tables. 13

So in order to do the energy use analysis, 14

you need to have a sample of households. So if we 15

start with RECS 2005, and apply a set of criteria

– 16

see the small fou r criteria at the bottom, and they 17

determine whether the household actually includes the 18

furnace end product. Once this is determined, we

– 19

you can tend to physically think of it as RECS 5000 20

households. We apply the selection criteria down to 21

3000. Now we are here at the house

– we’re splitting 22

this mob ile home versus non

- mobile home part of the 23

sample. 24

I’ll focus more on the non

- mobile home part. 25Executive Court Reporters (301) 565

- 0064 156 We look at the households, separate them by fuel type. 1

And as you see here, on the right side are the nine 2

key product classes as discussed this morning. So the 3

primary and most interesting point is how we develop 4

the sample for the gas households. 5

So first, the entire sample is applied for 6

non

- motorized gas for the condensing, non

- motorized 7

gas for th e ... After that, we select just the 8

households that are in the center region to use for 9

the sampling for non

- condensing, non

- motorized furnace 10

fans. We add another criteria, household

– to the 11

center sample

– households that include central air 12

conditioni ng equipment to identify the weatherized gas 13

furnace fans. To this sample, to the sample that is 14

for the center region, has central AC, we apply the 15

criteria which is listed right there, that has gas 16

water heater with some limitation on the square 17

footage , to isolate the sample for hydronic air 18

handler heating and cooling. 19

So that’s how primary the entire sample is 20

developed and used in the Monte Carlo simulations for 21

the determining the energy consumption for each 22

household. 23

MR. BROOKMAN: Joanna Ma uer. 24

MS. MAUER: Alex, can you just explain again 25Executive Court Reporters (301) 565

- 0064 157 why the identification of a house that has central AC 1

indicates that it would be a weatherized gas furnace 2

fan? 3

MR. LEKOV: So everything is based on the 4

available data. Weatherized gas furnace is 5

esse ntially a package that includes heating and 6

cooling, so from the sample we are removing the ones 7

that don’t have cooling. They are not weatherized 8

furnace fan ... 9

MR. BROOKMAN: Abigail. 10

MS. DAKEN: So, Alex, this is essentially a 11

follow on question bec ause I didn’t quite understand 12

the response. When you say has central AC, does that 13

mean that the household has central AC, or that 14

central AC is included in the same product? 15

MR. LEKOV: So, step back. For the non

16

condensing, non

- weatherized furnace fan s we’re using 17

the entire sample that is incident US. Now, the same 18

example, we look at households that must have central 19

air conditioning. So I hope this answered the 20

question. So

– 21

MS. DAKEN: I’m sorry, would that include 22

households that had

– 23

MR. LEKOV:

-- in order to qualify for as a 24

weatherized gas furnace fan product, the household 25Executive Court Reporters (301) 565

- 0064 158 needs to have a central air conditioning. 1

MS. DAKEN: So a household that has a split 2

system, central air conditioner, with an indoor coil 3

and an outdoor coil, an d then a non

- weatherized gas 4

furnace, would end up in your weatherized gas sample ? 5

MR. LEKOV: Yes, it’s going to be in this 6

sample. 7

MS. DAKEN: Okay. Thank you. 8

MR. BROOKMAN: Ted Eckman. 9

MR. ECKMAN: So how does this account for

– 10

how does thi s market share allocation using RECS 11

either 2005 or 2009, account for the federal standards 12

change in 2013 for condensing versus non

- condensing 13

requirements? 14

MR. LEKOV: So I think we’ll answer this 15

when we talk about the baseline efficiency 16

distribution

. 17

So we have the sample now and we’re starting 18

to calculate the energy use. Here is the chart. 19

Essentially, the household reflects the formula which 20

you saw in the beginning. Furnace fan energy use you 21

need to determine power, you need to determine t he 22

operating powers for each household. In addition, for 23

each household we calculate the impact on the energy 24

use. So the power requires the determination of fan 25Executive Court Reporters (301) 565

- 0064 159 performance curves and system curves. The operating 1

powers, there are two separate methodol ogies for 2

heating and cooling operating, and for continuous fan 3

operating powers. The details are on the next slide. 4

So, starting with fan power determination. 5

This chart is just an illustration. Here is

– I’ll go 6

in additional details of describing h ow each of these 7

are derived. So, in essence, from the manufacturer 8

data we are deriving the fan performance curves in 9

terms of air flow, the upper three, for each of the 10

operating modes. Simultaneously with this, develop 11

the power curves as the bottom t hree lines. And this 12

we impose the system curves that’s for this particular 13

household, which allows to determine the operating 14

mode at each of these three modes, and to arrive at 15

the furnace fan power as shown on the right side. So 16

that’s the schematic. This is just one general 17

presentation for a specific furnace fan design. 18

MR. BROOKMAN: Diane, please. 19

MS. JAKOBS: I just want to point out that 20

if you look at this graph, I mean there’s not any 21

strange peaks, it’s all kind of even flat if you look 22

a t the bottom three curves, and it’s kind of

– it’s 23

like the fan laws govern that at higher static, the 24

energy consumption goes down. So there’s not a lot of 25Executive Court Reporters (301) 565

- 0064 160 weird things going on. There’s all this thing about 1

manufacturers will game the system by only ha ving one 2

point. I mean this is kind of how they work, so

– 3

MR. LEKOV: So that’s an illustration, I 4

hope the more specific slides will get us deeper in 5

this discussion. Okay. So

-- 6

MR. BROOKMAN: Before we move on, Paul. 7

MR. LIN: Just one commen t. I see that 8

you’ve used three different fan speeds for the three 9

different settings. Sometimes manufacturers utilize 10

only two speeds of the three or four speeds that are 11

available in the motor. So on a heat and a cool, it 12

could be one of two speeds, a nd the constant fan could 13

be one of the heating or cooling speeds, and not the 14

low speed. 15

MR. LEKOV: So this topic has been discussed 16

in detail in the furnace fan test procedure 17

discussion, and this morning also quite a bit was 18

touched upon. There is a

– exactly

– there may be 19

some simplified cases that will not have settings for 20

all three. 21

So let’s start with a system curve 22

variation. It’s needed because it is how the 23

operation of the furnace fan in the individual 24

household is determined. And it is characterized by 25Executive Court Reporters (301) 565

- 0064 161 assigning an external static pressure value at the 1

maximum cooling air flow operating mode. How is 2

actually this incorporated in the analysis. As 3

mentioned multiple times, DOE compiled a number of ESP 4

measurement from 27 studies that in cludes furnace fan, 5

single family and manufactured homes. Now, once we 6

have this sample, here the table shows

– illustrates 7

this kind of

– hopefully in a more clear way. We 8

split the sample to two parts for non

- mobile home 9

products and mobile home produc ts. After that we 10

tender those two larger samples, looking at the sample 11

whether it has air conditioning coil or not. As a 12

result of this we are coming with two sets of data 13

which essentially represents a distribution of values 14

which are after that, rand omly sampled for the 15

households that meet these conditions. 16

MR. BROOKMAN: Diane, go ahead. 17

MS. JAKOBS: I just want to point out one 18

thing. So, on the previous graph, manufacturers have 19

to have three coefficients to describe one fan motor 20

curve. Whe re we can describe every duct system with 21

just one coefficient. So, I mean, it just seems 22

disproportionate. I know this is an engineering 23

assumption that people do to do load calculations and 24

design ductwork, and it’s simplified. But, you know, 25Executive Court Reporters (301) 565

- 0064 162 the degre e of accuracy is suspect. I mean it 1

represents something, but I don’t know that

– I 2

seriously doubt that you have it

– while you have it 3

under system curve derivation, I don’t think you 4

looked at whether the system curve represented the 5

1300 field conditi ons. You were just looking for the 6

average static. If someone asked me to estimate a 7

system curve, I’m sure I would come up with the same 8

thing, I don’t know how accurate it is. I mean I kind 9

of doubt it’s very accurate. 10

MR. BROOKMAN: Steve. 11

MR. RO SENSTOCK: Just as a quick question, 12

in terms of

– again, there’s all this data, you show 13

the averages. Do you have any sort of standard 14

deviations, or do you have the median value that

– 15

again, just for all the numbers that you were 16

collecting, that type of data might be useful for us 17

to see any sort of correlation, or just in terms of 18

the range of values that you got in the field. 19

MR. LEKOV: So we can affirm the furnace fan 20

test procedure proceedings, DOE published a list of 21

all 27 studies, and the da ta is available. 22

MR. BROOKMAN: Greg. 23

MR. WAGNER: Greg Wagner. I looked through, 24

not all 27 of them, but ten

- plus of them, I’ve 25Executive Court Reporters (301) 565

- 0064 163 forgotten now how many, and I couldn’t find a 1

standardized methodology, or a method that , again, 2

would allow you to averag e those. They’re not taken 3

in the same fashion in each of those test setups. So 4

I would just say that averaging this is putting 5

together a pile of stuff that’s not necessarily 6

equivalent. So if you look at study to study, they’re 7

not the same test setup

. 8

MR. LEKOV: Maybe part to answer, DOE’s 9

analysis does not use average rates. Those are 10

distributions, very wide distributions per sample, but 11

this is just to show where the average of this 12

distribution is. 13

MR. BROOKMAN: Additional comments on this ? 14

MR. LEKOV: So we got the system curve, now 15

let’s focus on the fan performance curves. So first 16

step DOE did is to derive the average fan performance 17

curve, a set of average fan performance curves. So 18

those were done for the six efficiency levels , 19

ess entially represent ing design options. In addition 20

to this, at each of these efficiency levels, DOE 21

developed a separate fan curve for the seven fan sizes 22

listed here, from one through five turns. So if you 23

think of a metric six by seven, starting with th e 42 24

reference performance curves. 25Executive Court Reporters (301) 565

- 0064 164 Here’s the small picture in the bottom shows how this 1

was developed. 2

In essence, DOE took the manufacturers ’ 3

public literature for every single model, something 4

between 700 and 800 models. We extracted all the 5

perf ormance data, flow and function of ... and we 6

develop

– see how for each pressure there is a range 7

of values. So for each of these cases we fit the 8

curve to represent the range of this reported 9

operating conditions. 10

Now once this is available, it’s a nee d to 11

fit it to match the FER values derived in the 12

engineering analysis. This morning has been 13

explained , I believe, in good details, that a single 14

FER value was derived for each of these

– for each 15

product class and for each efficiency level. However, 16

t here are some differences between the set we 17

developed, which is based on 800 models and accounts 18

for the sizes compared to engineering. There are not 19

very large differences. So, adjustment factors were 20

derived t o DOE’s performance curve to match the FER 21

values as described in the engineering analysis. 22

So as a result of this, since we need to do 23

it for each product class for each efficiency level, 24

and in addition to this, need to be done for all nine 25Executive Court Reporters (301) 565

- 0064 165 product classes, the sample answer with 376 furnace 1

f an performance curves and those are the curves that 2

are used in the Monte Carlo simulation when we do the 3

sample

– we do the sampling. So again, there is a DOE 4

developed 100 representative performance curves to fit 5

as close as possible to the operating co nditions in 6

the individual households. 7

MR. BROOKMAN: Diane. 8

MS. JAKOBS: All right, you said you used 9

fan performance curves from literature. It’s unusual 10

to show the watts, so really you’re talking about the 11

air flow, right? 12

MR. LEKOV: You are ri ght that some 13

manufacturer s

– not all manufacturer s, report the 14

watts curve, but there are some that report the watt. 15

MS. JAKOBS: I’m aware of two. 16

MR. LEKOV: Yeah. It’s a pretty significant 17

sample. 18

MS. JAKOBS: It’s a small group. 19

MR. LEKOV: Y eah. 20

MS. JAKOBS: So you only used their furnaces 21

in your analysis, the ones that had

– 22

MR. LEKOV: No, we used all that have air 23

flow, and for the watts curve we used the ones that 24

are from available manufacturers, which is a little 25Executive Court Reporters (301) 565

- 0064 166 bit smaller sampl e. 1

MS. JAKOBS: The TSD in the references, it 2

shows like specific furnace specification sheets

– are 3

those the only furnaces that you used in your analysis 4

then? So did you list which manufacturers furnaces 5

data sheets you used ? 6

MR. LEKOV: It’s the s preadsheet actually 7

includes the entire sample

– is correct? Yeah. 8

MS. JAKOBS: But I mean, I don’t

– you can’t 9

have any Rheem data, right, because we don’t publish 10

it. 11

MR. LEKOV: Yes, there are other companies 12

have also the watts data, but Rheem has the air flow 13

data. 14

MS. JAKOBS: So that’s what I was

– so did 15

you use our air flow data? 16

MR. LEKOV: Yes. 17

MS. JAKOBS: Okay. But somehow it’s 18

divorced from the watts part of it because we didn’t 19

give you that information. I’m just kind of a little 20

confused about

– there’s kind of a part about what is 21

a static and what is a CFM, and then there’s a part 22

about

– to calculate FER you have to have the

– 23

MR. LEKOV: Both of them. Okay. I could

– 24

maybe we could elaborate on the derivation of how this 25Executive Court Reporters (301) 565

- 0064 167 is used in actual sample for the manufacturer that 1

reports just the air flow data. 2

MR. BROOKMAN: Yes, Victor. 3

MR. FRANCO: Hi, Victor Franco from Lawrence 4

Berkeley National Lab. So actually we have air flow 5

data for a lot of the manufacturers, especi ally non

6

weatherized gas furnaces. We only have for, as you 7

mentioned, for only a few manufacturers the watts per 8

CFM. To generate the air flow curves, we used

– we 9

try to use all the data. For the watts per CFM, we 10

used to derive the power curves, we u sed the 11

literature from just the available data. We have some 12

test data that we were able to map also to some of the 13

manufacturers, that was the 26 models that were 14

tested, so that helps increase the number of 15

manufacturers. 16

MR. BROOKMAN: Greg. 17

MR. W AGNER: When you did the testing, you 18

did it to the AMCA 210 that’s described in the

– 19

MR. LEKOV: That’s probably

– Sam? 20

MR. JASINSKI: Yes. 21

MR. BROOKMAN: Sam says yes. 22

MR. WAGNER: I mentioned it this morning, 23

but again, there’s a difference in the way the 24

correction factors are used between AMCA 210, ASHRAE 25Executive Court Reporters (301) 565

- 0064 168 51 and the ASHRAE 37 that all these charts and data 1

will be, and that is in ASHRAE 37 they correct as if 2

it’s a constant mass flow, so therefore you’re 3

correcting to standard CFM. In AMCA 21 0 you’re 4

correcting as if it’s a constant volume pump and 5

you’re adjusting your pressure and power. So they are 6

two different methodologies for co rrecting to standard 7

air density. So the data is not

– you’ve got apples 8

and oranges again. 9

MR. BROOKMAN: Sam Jasinski. 10

MR. JASINSKI: Yes, Sam Jasinski, Navigant 11

Consulting. Like I said, we’re interested to look at 12

the comments and make sure we understand what the 13

differences might be between the test method that we 14

used, which is proposed in the NOPR and based largely 15

on AMCA 210 versus ASHRAE 37. But some of those test 16

models, some of the models that were tested were 17

compared to the performance data that were published 18

in the specification sheets, and the raw data did not 19

differ too dramatically between what we took for 20

measurements using AMCA 210 and the measurements that 21

were in the specifications sheets, which according to 22

manufacturers, was taken with ASHRAE 37. So this is a 23

very important issue and one that we want to make sure 24

that we understand c ompletely, so that the values that 25Executive Court Reporters (301) 565

- 0064 169 we’re

– the test procedure that we’re using is 1

appropriate, but also that the values we’re basing our 2

analyses on to conservation standard, are also 3

appropriate. 4

MR. WAGNER: Greg Wagner again. I would 5

suggest you take a look at that test data and process 6

then because there should be a difference that is 7

noticeable. Having done enough of these tests where 8

we typically are running AMCA 210 because we make belt 9

fans, but we also work with our customers and do 10

testing wi th the ASHRAE 37 mode. And there’s a 11

distinct different between those curves, and it’s a 12

clear DC offset that you’re going to see between those 13

two. So if you’re matching up, that means one of the 14

two sets of data is probably all wrong. So I would 15

just caution that there’s some systematic error 16

probably involved there. 17

MR. BROOKMAN: Okay. Thank you. Are we 18

ready. 19

MR. LEKOV: So now we have the methodology. 20

Here are illustrations of the results. This is the 21

performance curve for a very specific ca se, non

22

weatherized gas furnace fan, non

- condensing, three ton 23

size, heating mode. And here are how the fan 24

performance c urves will look in this particular case. 25Executive Court Reporters (301) 565

- 0064 170 MR. BROOKMAN: Steve. 1

MR. ROSENSTOCK: Steve Rosenstock, EEI. You 2

said that the average ... static pressure was about 3

either point

– 0.73 or 0.52 , depending on central air 4

conditioning in the previous slide. It ranges from 5

0.52 to 0.73 , whether you have central air 6

conditioning or not, correct? 7

MR. LEKOV: The average value is 0.65 8

because y ou need to weight it for

– 9

MR. ROSENSTOCK: Okay. So again, looking at 10

this graph, going from 0.52 to 0.75 , the air flow 11

ranges, I’ll say from around 790 CFM to as much as 12

1100 CFM. For that furnace, what is the required CFM 13

to meet the needs of that house? 14

MR. LEKOV: So, first, again this is a non

15

condensing, non

- weatherized furnace fan, so the value 16

in terms of power that you need to utilize reflects 17

the three operating modes. The required CFM will be 18

the CFM depending

– for this particular produ ct class, 19

the average values it will be different depending in 20

the distribution of the average value which is 0.65

. 21

MR. ROSENSTOCK: I guess

– Steve Rosenstock, 22

EEI. My point being is if there’s a need inside that 23

house for at least, say 1000 CFM, some of the products 24

will not meet the required CFM. Or am I missing 25Executive Court Reporters (301) 565

- 0064 171 something? 1

MR. BROOKMAN: Charlie. 2

MR. LEKOV: Yeah, the

– 3

MR. BROOKMAN: We also have

– why don’t you 4

go first. Please say your name again. 5

MR. FRANCO: Victor Franco, LBNL. So we 6

consider the requirements that the household needs in 7

terms of an air flow. If

– what’s usually done in the 8

field is if the air flow requirements need to be at a 9

certain level, you change the air flow setting. So 10

what’s on the LCC spreadsheet then, the a ir flow 11

setting for like say the PSC needs to be higher, it’ll 12

go to the higher air flow setting. So it will consume 13

more energy to meet the requirements. 14

MR. BROOKMAN: Charlie. 15

MR. STEPHENS: Charlie Stephens. I’ll just 16

add that in the field what a house needs is a very 17

fungible term. The average oversizing factor in the 18

field is what results in some fairly short cycle 19

times, so houses almost always get more than they 20

need, based on the habits of most contractors out 21

there, more air flow than they really require. So, 22

you know, I’m looking at the error bands, if you will, 23

in the field in these actual houses that we’re trying 24

to use as representative of the whole population of 25Executive Court Reporters (301) 565

- 0064 172 house, and quite frankly, there’s a lot of mushiness 1

out there in those ho uses and I think what we’re 2

trying to do here is land on an average set of values 3

to sample from on either side of average values and 4

try to come up with something that is a reasonable 5

approximation. And again, when we get down to this, 6

we’re looking at t his from candidate standard level to 7

candidate standard level. We’re looking at 8

differences in the end. 9

And I don’t see any real problems here with 10

the methodology that’s going on. I just talked to my 11

field tech during lunch who also added that he find s 12

remarkable agreement between field conditions and how 13

an air handler behaves under certain external static 14

conditions, and the manufacturers literature in most 15

cases. So it’s actually more predictable than you 16

think, and the least predictable part of th is is the 17

house itself, and how this thing is matched to a duct 18

system in a house. So I think the methodology we see 19

here is actually a pretty good, reasonable 20

approximation given how messy it is in the real world. 21

MR. BROOKMAN: Go ahead, Victor, go ah ead. 22

MR. FRANCO: Just a clarification. The 23

adjustment is made more in terms of the safety 24

requirements. So for example, th ere are some 25Executive Court Reporters (301) 565

- 0064 173 households that when sampled, they might go into one 1

point something static pressure, and at that level 2

you’re going over the bounds of what you need in terms 3

of air flow. So

-- for those households. So there is 4

obviously a band that is acceptable. Over that band 5

is where

– and that’s a smaller effect in terms of how 6

many households actually change air flow settings. 7

MR. BROOKMAN: Diane. 8

MS. JAKOBS: Well, that was one of my

– that 9

was related to my question. I’m kind of surprised by 10

this linear line for the X13. Are you saying that 11

that one maybe you change the motor speed as you went 12

up in static or

– 13

MR. LEKOV: No. That’s

-- 14

MS. JAKOBS: I think after your last reply, 15

that’s not what you were saying. 16

MR. BROOKMAN: Victor, go ahead, and then 17

back to Paul. 18

MR. FRANCO: So on the X13 is actually 19

mostly based on Lennox data for a couple series of 20

mode ls, and test data. And for this specific three 21

ton unit, that’s a flat for actually for other curves 22

that we have. It’s actually more like the PSC, it’s a 23

little bit more of a curve, but it is decreasing, it’s 24

decreasing faster than the PSC curve usually . But it 25Executive Court Reporters (301) 565

- 0064 174 depends on the fan size and the product class. 1

MR. LEKOV: And also here, to bring up here 2

note

– see the distributions, so it is essentially 3

representing performance conditions

– a set of 4

performance conditions at static pressure, so this 5

allo ws to account for a number of models from 6

different manufacturers if we have

– if the data is 7

available. 8

MR. BROOKMAN: Paul. Wait, Diane’s not 9

finished. Keep going. 10

MS. JAKOBS: Well, I mean, that’s one way to 11

look at it that you’re accounting for t his broad band 12

by drawing a single line, or you could think that 13

you’re only accounting for a thin line and you’re not 14

accounting for the broad band. So it’s a matter of 15

opinion, you know, whether selecting one thing is 16

really, you know, do you

– as an en gineer, you always 17

have a broad band, nothing’s ever exactly correct. So 18

there’s always the choice. You can pick the top, you 19

can take

– so

– 20

MR. LEKOV: As you said, it’s a methodology. 21

MS. JAKOBS: The watts will change 22

dramatically. 23

MR. BROOKMAN : Okay. Paul. 24

MR. LIN: I guess the comment, and I’ll 25Executive Court Reporters (301) 565

- 0064 175 defer to a lot of our OEMs, but when I look at this 1

curve, usually your PSC motor is designed at one 2

specific point in terms of the fan load. As you 3

increase the load on a PSC motor, it’s not going to 4

deliver more air flow versus a discrete torque or 5

constant torque ECM motor. So to see a static 6

pressure rise with more air flow on the PSC motor 7

versus an X13, to us, it doesn’t look right. The data 8

that we’ve taken relative to an X13 motor versus a PSC 9

motor on a higher static environment, we see more air 10

flow delivery from an X13 versus a PSC high static. 11

So, from this graph, I’m not seeing how it relates the 12

data we’ve taken in our air flow chamber. 13

MR. BROOKMAN: Thank you. 14

MR. LEKOV: So

– 15

MR. BROOKMAN: Wait just a second. Go ahead 16

Victor. 17

MR. FRANCO: Just to point, this is for 18

heating mode, this is for air flow

– the curves for 19

cooling would be different. I don’t know if that’s 20

the maximum air flow, but that’s the design that you 21

were looking. 22

MR. BROOKMAN: Paul. 23

MR. LIN: Well, whether it’s heating or 24

cooling, it’s a load on the motor, and regardless, the 25Executive Court Reporters (301) 565

- 0064 176 motor doesn’t know whether it’s in heating or cooling. 1

It’s only going to deliver its design load point, and 2

it’s only g ot so much torque available. As you 3

increase the load on the motor, on the PSC motor, it’s 4

going to fall off that curve, and deliver less. 5

Whereas an X13 will deliver up to a certain point and 6

then it’ll start falling off like a PSC motor. And 7

then if y ou look at a fully variable PSM motor, you’ll 8

ramp the load up until the current limit, and then 9

it’ll start falling off. So that’s why I’m saying the 10

curves don’t look like the data that we have in our 11

lab. 12

MR. FRANCO: So one possibility

– again, 13

Vict or Franco

– is this is an average. Since this was 14

based on one manufacturer, the other data is based on 15

more manufacturers. This depend on the air flow 16

setting for the heating speed, so potentially that’s

– 17

that could be the

– 18

MR. BROOKMAN: Sam Jasins ki. 19

MR. JASINSKI: Yeah, just as a point of 20

clarification that might help with the conversation, 21

is the green curve, the PSC with controls

– that 22

refers to a model that uses a PSC that’s driven by an 23

inverter. So just in the conversation, comparing the 24

X13 to the

– there’s two PSC curves there

– you may be 25Executive Court Reporters (301) 565

- 0064 177 referring to the comparison with the red one, but the 1

green one, as a clarification for everyone else, the 2

with controls is referring with that inverter 3

technology that we spoke about during the engine ering 4

analysis, if that changes anything. 5

MR. BROOKMAN: Mohammed. 6

MR. KHAN: Yes, this is Mohammed. Thank 7

you, Sam, that’s a very good clarification. And I 8

don’t know if the gentleman was going to respond to 9

that, but since I have the mic, I was jus t going to 10

ask you if you could please share that particular data 11

specifying exactly what kind of PSC, with or without 12

controls, the exact test condition specifications, and 13

then we might be able to look at that and see how that 14

might compare or marry up o r doesn’t marry up to the 15

distribution that Alex was talking about. 16

MR. LIN: Yes, this is Paul Lin again. I 17

think what we’re going to do is submit some of that 18

data that we’ve taken in the lab. We’ve taken 19

manufacturer A, B, and C furnaces and applied a PSC 20

motor to it and then in the same box, applied the X13 21

and then applied a fully variable system in the same 22

box and compared static pressure versus CFM and we 23

were doing that not for this particular rulemaking, we 24

were actually responding to utility questions relative 25Executive Court Reporters (301) 565

- 0064 178 to static pressure and watts with various ECM motors. 1

And so it just happens that this particular data is 2

useful for this rulemaking. 3

But one comment about the averaging is , 4

although the average data shows that, I think it’s

– 5

if you look at each individual case, it’s the same 6

thing, which is the X13 is going to deliver more air 7

flow than the PSC motor, the red line. And even 8

though you have an average, that kind of skews that 9

rule that we’ve seen in the lab, which is

– you almost 10

def ine physics here. 11

MR. BROOKMAN: Both Greg and Diane I’ve seen 12

simultaneously. 13

MS. JAKOBS: Okay. Ladies first. Just from 14

our understanding, you know, these guys they come and 15

they explain this new whiz

- bang thing and we try to 16

make sense out of it i n our applications, but the PSC, 17

it drops down and

– the red line

-- it drops down 18

pretty severely. And then when we got the blue, the 19

two blues, you know, it’s almost a straight line 20

across. So static pressure is like out of the 21

equation. And then the way I understood X13, it’s 22

kind of a compromise between the two. It’s better 23

than a PSC and not as constant as the ECM. 24

MR. BROOKMAN: Craig. 25Executive Court Reporters (301) 565

- 0064 179 MR. MESSMER: Having stared at millions of 1

these curves, but looked at them in an opposite 2

direction than wha t you guys publish them for whatever 3

reason, normally flow is on the bottom and the static 4

pressure going up the vertical axis, it takes me a 5

little while to get used to looking at this way. But 6

I can tell you that, to echo what these folks are 7

saying, th ose curves don’t look quite right, and the 8

PSC would be a more vertical curve in this type of 9

arrangement. But that’s also dependent upon where 10

you’re operating that PSC motor relative to its peak 11

efficiency point. 12

So averaging a bunch of curves using a 13

variety of different designs is going to give you 14

really odd looking results that don’t necessarily 15

reflect the typical or a median type of an 16

arrangement. So to summarize, I guess, what you’re 17

getting is a blending here that’s giving an odd 18

looking cu rve to this process, and that’s what these 19

folks are looking at and trying to figure out why this 20

doesn’t look right. 21

MR. LEKOV: So Craig, it would be great if 22

we hear about an alternative methodology, instead of 23

averaging for a range of existing model data, what are 24

other options, and DOE will look at those. 25Executive Court Reporters (301) 565

- 0064 180 MR. MESSMER: I’m not sure where you’re 1

going with this, so I don’t know how to pose

– 2

MR. LEKOV: What would be an alternative 3

approach to the averaging that is done this way here, 4

basically de riving the performance curve

– 5

MR. BROOKMAN: Diane, you want to start

– 6

MR. LEKOV:

-- for a range of available 7

data. 8

MR. MESSMER: No, my question is I don’t 9

know where you’re going, what’s the end goal of this 10

use of these performance curves. 11

MR . LEKOV: So these performance curves are 12

after that used to determine the energy use of 13

specific households that under these conditions, 14

normalized

– for example, this specific case. 15

MR. MESSMER: (off mic) 16

MR. BROOKMAN: Diane. 17

MS. JAKOBS: Well, I think if I was doing 18

it, because you have such a large range of data, 19

instead of just averaging it, I think I would want to 20

look at like on either range, because it seems to me 21

you’re distorting the shapes of the motor curves. So 22

it seems like it might b e better to select one from 23

the high range and one from the low and look at it, 24

you know, at least as a sanity check. 25Executive Court Reporters (301) 565

- 0064 181 MR. LEKOV: Yeah, that’s an alternative. 1

MS. JAKOBS: Yeah, that’s what you just 2

asked. 3

MR. LEKOV: Yes. 4

MR. BROOKMAN: We’re go ing to keep moving 5

ahead. 6

MR. LEKOV: So the same sample, here are the 7

power curves. So on the left side, in terms of watts 8

per CFM, on the right side, the watts which ... more 9

clearly show for the same four designs. 10

MR. ROSENSTOCK: Doug? 11

MR. BROOKMA N: Yes, please, Steve. 12

MR. ROSENSTOCK: Steve Rosenstock, EEI, and 13

I’m looking at the

– and again, I appreciate the 14

graphs

– I’m looking at the graph on the right and so 15

what I’m seeing here is

– and again, remembering the 16

static

– average external stat ic pressure that you had 17

was from 0.52 to 0.73 in a previous slide

– in terms 18

of a non

- weatherized, non

- condensing gas furnace, what 19

this graph tells me is that for those operating 20

conditions, 0.52 to 0.73 , and again I don’t know what 21

the standard deviatio n is, that the PSC fan with the 22

controls is going to use more energy than the baseline 23

PSC fan. Is that correct? That’s what this graph 24

says. And the reason I ask that is because in the 25Executive Court Reporters (301) 565

- 0064 182 technical support document later on, it’s saying that 1

the annualize d energy savings with the PSC with 2

controls and I’m not sure how you get there from this 3

graph. 4

MR. LEKOV: So remember that the household 5

is not getting the average value

– it’s a range of 6

static pressures, so could be from much lower from 7

what you are stating

– 8

MR. ROSENSTOCK: Or it could be higher. 9

MR. LEKOV:

-- or it could be higher. 10

MR. ROSENSTOCK: So again, I don’t know if 11

it’s an average or a median, but again, looking at 12

this graph and then looking at the

– I’m just 13

wondering if again, I don’t know what percentages 14

within that range of operating performance or external 15

static pressures, but let’s say 80 percent of the 16

homes are within that 0.5 to 0.8 external static 17

pressure range

– again, I don’t have the exact number 18

– I’m still not seei ng

– and later on in this 19

analysis, in this preliminary analysis, how you’re 20

getting any annual energy savings from going to PSC 21

with controls. 22

MR. LEKOV: So with the PSC with controls is 23

a very specific design. It’s essentially based on

– 24

it’s include d as an efficiency level in this analysis 25Executive Court Reporters (301) 565

- 0064 1 83 and is based on actually single prototype developed 1

five years ago and not in manufacturing. And the 2

purpose of this specific design is to allow for a wide 3

range of rotational speed and appropriate CFMs while 4

usin g a PSC motor. So as Sam pointed, this is a 5

design with inverter. As a result of this, it has 6

certain advantages if you’re going to, let’s say, use 7

it at constant ventilation. But on the other hand, if 8

you use it at some higher static pressure in heatin g 9

and cooling for longer hours, it may end up with 10

results that you notice. 11

MR. ROSENSTOCK: But again

– Steve 12

Rosenstock, EEI

– but based on your field results, 13

again, you show that the average was 0.73 for the 14

households with central air conditioning, so again, I 15

don’t know what the variation throughout the day or 16

throughout the season is, but if it’s not more than 17

0.2 , it would be 0.53 to 0.93

– aren’t you going to 18

have a higher energy usage with that product? 19

MR. LEKOV: It’s much wider than what yo u’re 20

just saying. But yes, that’s correct in some fraction 21

of households. 22

MR. ROSENSTOCK: Because I didn’t see it 23

anywhere, I’m not sure what that range is, so

– 24

MR. LEKOV: In some fraction of households 25Executive Court Reporters (301) 565

- 0064 184 you end up with higher energy ... 1

MR. ROSENS TOCK: Thank you. 2

MR. BROOKMAN: Victor, and then coming to 3

Greg and then to Charlie. Yes. 4

MR. FRANCO: Victor Franco. Just to add 5

then, the results you’ll find a little bit of this 6

discrepancy. On the heating and cooling in general, 7

it’s similar or lower performance or more energy use 8

and the main advantage is on the constant fan. So on 9

average you could get some energy savings in terms of 10

electricity, and that’s what you’ll see in the end 11

results. 12

MR. BROOKMAN: I’m not sure, but I have this 13

g eneral impression we’re gaining on it here, I think, 14

and I think the Department is earnestly seeking your 15

comment on these methodologies and how to make sense 16

of them from experts such as sit in this room, so Greg 17

is first, and then Charlie. 18

MR. WAGNER: Real quick, I had a similar 19

sentiment than when you look at these it’s going to 20

look like it’s going to use more energy and since 21

you’re saying that on average it’s always above that 22

0.5 , it will use more energy. But this is the problem 23

with also tying i t to static pressures versus putting 24

it against flow. If you had flipped these curves 25Executive Court Reporters (301) 565

- 0064 185 around and put them in a normal way, you would see it 1

against flow and you’d have different numbers and 2

different results, and it might be more indicative 3

because the gr een line delivers more air and it 4

wouldn’t have to run as long, so it might make more 5

sense. But this whole business of shoving stuff 6

together like this when they have different shapes of 7

curves, you’re going to get skewed results that look 8

like this. 9

M R. BROOKMAN: Okay. Charlie. 10

MR. STEPHENS: Yeah, this is Charlie. I 11

think

– I don’t think I’d necessarily characterize it 12

as skewed results. What you’re doing here is 13

statistical analysis. You’re trying to represent

– 14

you’re trying to come out with a single number at any 15

given box in a matrix, based on thousands of samples. 16

And when you sample all around, you’re going to have 17

houses that have no air conditioning; houses that have 18

200 hours a year of air conditioning like we do and 19

where you’ve got 1 8

- 2200 hours of heating; you’re 20

going to have houses that have low static pressure in 21

the duct system. There’s going to be all different 22

kinds of things, and you’re sampling from all of those 23

houses, and then looking at the net result in the end 24

and tryin g to put a single number in a box. The 25Executive Court Reporters (301) 565

- 0064 186 single number could have to do with the fact that you 1

selected a different manufacturer’s system whose 2

motors and fans run at a different point on that 3

curve, above or below it. Or it could be just that 4

it’s a diffe rent static pressure, or it could be that 5

– there’s enough variables here that you just have to 6

statistically have to try to come out with some sort 7

of central variable that gives you an answer in the 8

end, because the Department’s required to come to an 9

an swer. 10

We do this with our field data all the time, 11

and we actually go out and measure things. But we 12

still, in the end, if we want to come up with some one 13

number we have to somehow average and smush all that 14

together with some reasonable answer, knowin g that 15

there is a distribution around the answer, you know, a 16

standard deviation, if you will, around that answer. 17

All we do is acknowledge that and say, yep, it’s this 18

plus or minus whatever, and is it reasonable within 19

that range. And I think in the en d, we’re all going 20

to have to look at the results and ask if it’s 21

reasonable within that range. 22

But again, I don’t find anything that 23

bothers me based on my own statistical work with real 24

data from the field, doing exactly the same thing as 25Executive Court Reporters (301) 565

- 0064 187 we’re doing here, only from

– with field data. 1

MR. BROOKMAN: Okay. Thank you. Diane

– we 2

need to move on here shortly. 3

MS. JAKOBS: Okay. I just wanted to make 4

one point. So we talked about the field static is so 5

much higher than what’s assumed for the coil only 6

rating. And if you think back to when we developed, 7

our industry with DOE, that at the time it was 8

developed for the SEER rating, 0.2 inch static, if 9

you’re looking at the red line, that was a 10

conservative number. I mean the watts went down, and 11

it was only when we added the ECM and X13 where the 12

slope is the opposite and it’s rising. So it’s not 13

like someone specifically tried to game the rating and 14

make things look in a way that was misleading, it’s 15

more like new technology has changed the origina l 16

assumptions. 17

And I’m on a lot of standards committees and 18

one of the things we’ve struggled with was this thing 19

about not backsliding. And if you want to update 20

things for new technology, but it’s going to cost the 21

efficiency to go in the wrong direct ion, you’re not 22

allowed to do it. So it’s really hard to know what, 23

what do you do? Because sometimes we make a whole 24

bunch of assumptions when we put together these energy 25Executive Court Reporters (301) 565

- 0064 188 descriptors and as the industry learns, as installers 1

learn, some of those assump tions aren’t so good any 2

more. But if you implement it into the rating, it may 3

cause your energy descriptor to actually show an 4

improvement for the same unit, and you’re not allowed 5

to do that. 6

MR. BROOKMAN: Okay. Thank you. Dave. 7

MR. WINNINGHAM: Just a general comment here 8

that the control points of the static pressure ranges 9

– we’re selecting here from the field data

– and 10

really in a lot of cases, outside of what a 11

manufacturer would recommend. And we’re in the 12

process of setting a metric in wh ich we measure them 13

that is outside of those boundaries. And if you look 14

at these curves, what they would suggest is a large 15

energy saving would be to shift that point to the left 16

to reduced static pressures where you see the biggest 17

improvement between t he technologies. Because as you 18

go out to the right, they’re converging and you really 19

aren’t seeing the benefit of the other technologies to 20

the same magnitude. And while the manufacturers have 21

a concern around safety and reliability of the 22

equipment an d the installation, there’s an obvious 23

performance difference here that I think DOE needs to 24

take into consideration. 25Executive Court Reporters (301) 565

- 0064 189 I understand, you know, the people who are 1

specifying want to have something that’s real world, 2

but what we have here is a comparison to ol. So to 3

compare one product to another, and I think as we’re 4

looking at that we should align it around where it’s 5

designed to operate. 6

MR. BROOKMAN: Okay. Thank you. 7

MR. LEKOV: Okay. So now we have the fan 8

performance and the power. The next point is we need 9

the operating hours. So the operating hours for each 10

product, they’re essentially heating or cooling

... and 11

capacity. For this analysis those values were 12

adjusted for

– 13

MR. BROOKMAN: Alex, pardon me for 14

interrupting. I forgot and I dr opped Jim Vershaw out 15

of the queue. Jim, I presume your comments relate to 16

the previous discussion, so Jim, why don’t you do that 17

now. I apologize, Alex. 18

MR. VERSHAW: Can you hear me? 19

MR. BROOKMAN: Yes. 20

MR. VERSHAW: Jim Vershaw, Ingersoll Rand. 21

One of the things that really pointed up

-- that last 22

chart pointed out to me was how much the continuous 23

fan hours and watts can skew what’s going to happen in 24

the real world. If you could end up with a system 25Executive Court Reporters (301) 565

- 0064 190 that could come up with a lower FER and yet if you 1

don’t use continuous fan, you’ll use more energy, 2

looking at the red and the green lines. And I’ve just 3

got to wonder the value of putting in the continuous 4

fan in this thing versus the number of people who do 5

use continuous fan

– and I think thos e are based maybe 6

on a couple of states in the far north. I’m really 7

concerned that we can end up with some unintended 8

consequences by having that included in this whole 9

calculation. 10

MR. BROOKMAN: Okay. Thank you. Alex, back 11

to you. I apologize. 12

M R. LEKOV: All right. Continuing with the 13

derivation of the operating curves in heating and 14

cooling mode. As I said, basically, function of ... and 15

capacity of the equipment, corrected for fan ... ratio 16

and as well an adjustment factor applied. The 17

adjustme nt factor is important basically it includes 18

statistical data, predictions regarding the future 19

building shell efficiency in terms of physical size of 20

the household and shell attributes. And this is from 21

EIA’s 2012 data. Also the result is adjusted for t he 22

average climate conditions. The data we have is for 23

2005. We used the AA methodology to average it over 24

the ten years period and there are two other 25Executive Court Reporters (301) 565

- 0064 191 conditions which are included in this adjustment 1

factor. 2

MR. BROOKMAN: Steve. 3

MR. ROSENSTOCK: Qu estion on the last slide. 4

Steve Rosenstock, Edison Electric Institute. In terms 5

of building shell efficiency, I don’t know if I found 6

that section in the technical support document. For 7

the new homes is this assuming that all new homes will 8

meet IECC 20 09 or IECC 2012? 9

MR. LEKOV: This is based on the EIA’s 10

forecast for the integrity of the envelope in 2018. 11

MR. ROSENSTOCK: Okay. Steve Rosenstock, 12

EEI. In terms of forecast for new homes, I would 13

suggest using the values shown in IECC 2012 because 14

DOE came out with their final determination and states 15

are supposed to update their codes by the spring of 16

2014. So you might want to use that for you new homes 17

portion of your analysis. Thank you. 18

MR. LEKOV: Thank you. Now, for constant 19

fan mode, it’s based on fan constant circulation study 20

conducted in Wisconsin and Minnesota. DOE based the 21

adjustment for the national sample using this dataset. 22

However, it’s very different for the other regions in 23

the United States. For the south hot, humid reg ion, 24

it’s ten percent of the value used from these studies, 25Executive Court Reporters (301) 565

- 0064 192 and for the north and south hot and dry, it’s half of 1

it. The table shows actually the results from the 2

study on the left side, and if you go right on the 3

side, you see it drops half and drops by 90 percent in 4

the last column. So those are the values used in the 5

analysis. 6

MR. BROOKMAN: Diane. 7

MS. JAKOBS: I looked at this and I thought 8

it made a really strong case that we shouldn’t 9

consider circulating fan mode. I mean, 97 percent in 10

the so uth don’t use it, and 84 percent in the north 11

don’t use it, so I don’t see how this supports the 12

idea that actually

– because of

– for a gas furnace, 13

because of the hours, we’re actually attributing 20 14

percent of our FER value to the constant fan motor. 15

B ut hardly anyone uses it, and then, you know, so it’s 16

like

– I forget

– I think it was like 34 percent for 17

heating and something

– whatever it adds up to, to air 18

conditioning, is less. So I would look at this data 19

and I would interpret it completely diffe rently, and I 20

would say constant fan circulation is not a 21

consideration. 22

We were on the

– Greg and I were on a CSCA23 23

committee

– in Canada, that’s different. They have a 24

ventilation requirement in their building code, and 25Executive Court Reporters (301) 565

- 0064 193 there are a lot of people usin g the constant fan with 1

a duct to the outside air, and they are using it. But 2

here in the States I don’t see that we are using it. 3

MR. BROOKMAN: Charlie. 4

MR. STEPHENS: Charlie Stephens. I hope to 5

be able to provide some data on this. I would 6

disag ree. Five years ago, I would have agreed with 7

Diane, but based on recent trends, both in ventilation 8

and in the sales of rather expensive filtrations 9

systems that contractors really love to sell, there is 10

a substantial increase in the use of circulation m ode 11

where I live in the four states of the Pacific 12

Northwest, and I hope to be able to document that. 13

MR. BROOKMAN: New home construction? 14

MR. STEPHENS: Mostly in new home 15

construction, but also in older homes as well because 16

again, this is an adjunc t of a filtration system. 17

What’s being sold is a $400 to $500 dollar electronic 18

filtration system, generally, and to use it and to 19

make it effective, you have to circulate the air in 20

the house. And we’ve got a number of houses that 21

circulate 24/7, 8760 a year, at some speed that we’ve 22

encountered out there. They’re always running at some 23

speed. And that’s not the norm, but there are some 24

out there that actually do this. 25Executive Court Reporters (301) 565

- 0064 194 And it’s only

– from what we can tell, it’s 1

only in the last five years or so wh ere this is 2

becoming ubiquitous enough that we’re actually quite 3

concerned about it. As I say, the driver is only half 4

filtration, the other half is this ventilation 5

requirement where one way to meet that is to let fresh 6

air in. April Air is an outfit th at makes the 7

connection to the outdoors. It’s done on a timer. It 8

is a

– if you have a ducted system in the Pacific 9

Northwest, it’s common to just put a hole to the 10

outside with a damper on it, and you run your air 11

handler in circulation mode on a timer, so many hours 12

a day, typically about eight hours a day. 13

And this is new because the ventilation 14

requirements are just now starting to come into the 15

code everywhere. And I would suggest that DOE not 16

only here, but in other places in the analysis, pay 17

more attention to the last five years. In some cases 18

your data only seems to go through about 2006 or 19

2007o, and I’m talking about financial data here too, 20

we somehow stop short of 2008. There’s a lot of 21

trends going on out there right now that I would 22

s uggest are not temporary, and I think we really need 23

to bring some of this up to date. And circulating 24

mode is one of those places that needs to be brought 25Executive Court Reporters (301) 565

- 0064 195 up to date, and I hope, as I say, to provide some 1

data. 2

MR. BROOKMAN: Thank you. Greg. Oh, 3

act ually, Greg

– Dave, do you want to follow on? 4

MR. WINNINGHAM: Actually, this is a 5

question for Charlie. Charlie in the instances where 6

you’re using constant circulation, are you looking for 7

a lower constant circulation value? Because there’s 8

equipment that’s designed different ways. You can 9

have a cooling speed, a heating speed, and a lot of 10

equipment uses one of those two steps for constant 11

circulation. Other manufacturers will choose to have 12

a constant circulation value that’s much lower. One 13

of t he outcomes of this could be that more 14

manufacturers, an effort to drive an FER number up, 15

drop that circulation speed and value. 16

MR. STEPHENS: Yeah, I

– that’s true. 17

Everything you just said is true and I had an alarming 18

report just last week of one m anufacturer who may have 19

a single speed for circulation, and it’s the highest 20

speed, which concerns us somewhat. 21

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

MR. WAGNER: This is Greg Wagner. I was 23

just going to say that since we’re talking about 24

anecdotal

– as Diane said, we’ve served on committee 25Executive Court Reporters (301) 565

- 0064 196 up there in Canada, and they did expressly talk about 1

this in the circulating mode because of that 2

requirement of internal

– of bringing in external

– 3

outside air and circulating for ventilation purposes 4

on a cont inuous basis. What they’re finding though, 5

is that most people wind up turning them off once they 6

get their first electric bill, so it’s not being used 7

nearly as much as what is reported. So that runs 8

counter a little bit to what Charlie’s saying, but I 9

suppose if you’re putting

– 10

MR. BROOKMAN: This is Canadians, right? 11

MR. WAGNER: Well, no, I’m saying I suppose 12

if you put in a really expensive house and have a lot 13

of money, you will keep running things continuously 14

and have that nice ventilation sy stem going, because 15

you can afford to do that. 16

MR. BROOKMAN: Okay. Keep going. 17

MR. LEKOV: This is the slide that request 18

comment on this topic. I know we got some and 19

probably more are coming in the written comments. 20

Here I will just acknowledge t hat the impact of more 21

efficient furnace fan is accounted for the heating

– 22

as an impact on the heating and cooling compilation, 23

and it’s a connection to Steve Rosenstock’s this 24

morning. Question here, it shows that for all 25Executive Court Reporters (301) 565

- 0064 197 products other than air handler s, essentially the 1

analysis are accounting for the difference in power 2

between the PEC and ECM and X13 motors from the 3

furnaces and the air conditioning rule

– the numbers 4

are coming from the rule and explain there. So that’s 5

how it’s accounted for. 6

For the hydronic air handlers, it’s simply 7

included in the metric , as explained this morning. 8

MR. BROOKMAN: Steve. 9

MR. ROSENSTOCK: Steve Rosenstock. I really 10

appreciate that, and just as a quick follow up, when 11

it says the difference is three watts, is that a three 12

watt increase or decrease? 13

MR. LEKOV: The furnace fan products with 14

ECM motors use three watts more, from eight to 11. 15

MR. BROOKMAN: Thank you. 16

MR. LEKOV: So the next slide are an example 17

showing the results for non

- weatherized gas furnace 18

both non

- condensing and condensing. This is the 19

energy use. 20

MR. BROOKMAN: Joanna. 21

MS. MAUER: Joanna Mauer. Has DOE provided 22

either average annual electricity use or electricity 23

use savings for the three different modes of operation 24

separat ely? I was trying to find it and I wasn’t able 25Executive Court Reporters (301) 565

- 0064 198 to find it in the TSD or the spreadsheet. 1

MR. LEKOV: They’re probably not in the TSD. 2

MS. MAUER: Okay. 3

MR. LEKOV: The spreadsheet may allow for 4

this derivation, but it would be a separate run. 5

MS . MAUER: I see, so it’s not something you 6

have. The comment is that I think it would be helpful 7

if DOE is able to provide that kind of information. 8

MR. BROOKMAN: Okay. Paul. 9

MR. LIN: Paul Lin. So I just want to make 10

sure I understood. Additional fuel use is because of 11

the higher efficiency of the motors? 12

MR. LEKOV: Yes. 13

MR. LIN: And was the high efficiency on the 14

cooling side taken into account, because you didn’t 15

have to reheat, or recool? 16

MR. LEKOV: Yes. 17

MR. BROOKMAN: Diane. 18

MS. J AKOBS: I just want to point out the 19

units are different, and if you get it all in kilowatt 20

hours, that the last column is more significant. So 21

there’s a conversion there. But just comparing the 22

first two columns, so for X13, you’re going to use 23

half of the electrical

– so if the annual electric use 24

is 508, then the savings would be 290. So are you 25Executive Court Reporters (301) 565

- 0064 199 going to cut your electric bill in half, is that what 1

you’re saying? For the furnace? 2

MR. LEKOV: That’s the average value 3

compared to the baseline. From 798 will drop to 508. 4

MR. BROOKMAN: From the baseline. 5

MS. JAKOBS: Okay. But if you’re looking at 6

different columns

– 7

MR. ROSENSTOCK: Thirty

- six percent. 8

MS. MAUER:

-- so it’s 798 minus 290 is 508. 9

Oh, okay. 10

MR. ROSENSTOCK: Thirty

- six pe rcent. Steve 11

Rosenstock EEI. That’s an estimated 36 percent 12

reduction. 13

MS. MAUER: Oh. 14

MR. ROSENSTOCK: Steve Rosenstock, EEI. 15

Just a quick one, non

- weatherized furnace fan, non

16

condensing and condensing, for the annual electric use 17

that’s both in the heating and cooling mode? 18

MR. LEKOV: Total. Total. 19

MR. ROSENSTOCK: Total, so

– 20

MR. LEKOV: And continuous. 21

MR. ROSENSTOCK: So

– and that’s kind of 22

average for those with and without the central air 23

conditioning, right? 24

MR. LEKOV: The e ntire sample, yes. 25Executive Court Reporters (301) 565

- 0064 200 MR. ROSENSTOCK: For the entire sample. 1

Okay. Very good. Thank you. 2

MR. BROOKMAN: Tom Eckman. 3

MR. ECKMAN: This is based on the RECS 4

distribution? Or is this per standard household? 5

MR. LEKOV: That’s a result of everythin g I 6

explained, all ten slides, the entire methodology when 7

you derive the system curves, the performance curves, 8

get to a specific household, do the calculation, do 9

the sampling in a Monte Carlo, and you arrive at this 10

average value. 11

MR. ECKMAN: And the AEO estimates of annual 12

energy use for heating and cooling, or the RECS 13

estimates? 14

MR. LEKOV: The starting points are the RECS 15

estimates. 16

MR. ECKMAN: And you convert to AEO going 17

forward, for projections? I just don’t know how these 18

weights

– the u nderlying question that is whether or 19

not the new furnace standards which

– and the new air 20

conditioner standards which go into effect during the 21

period of time before this standard would go into 22

effect, will change the annual loads you’re using here 23

to de rive these savings, because the minimum values 24

for both AC SEERS

– 25Executive Court Reporters (301) 565

- 0064 201 MR. LEKOV: Those are accounted for. 1

MR. ECKMAN:

-- ... going forward basis, using 2

the AEO data. 3

MR. LEKOV: That is correct. 4

MR. ECKMAN: Okay. 5

MR. BROOKMAN: Greg. Alex, one m ore

-- 6

MR. WAGNER: I’m confused. When we look at 7

that chart you just had, you look at the condensing 8

versus the non

- condensing, we see the condensing uses 9

less watts of electricity in the baseline. All the 10

way down, I guess. But on your FER data in t he key 11

product classes, it’s the other way around. Why would 12

there be a difference between the two? 13

MR. LEKOV: So this is energy use, kilowatt 14

hours. The FER is normalized watts per CFM. 15

MR. ROSENSTOCK: The run times are less on 16

the condensing side because they’re higher efficiency. 17

MR. LEKOV: Yeah. 18

MR. WAGNER: No? I don’t know how

– it’s 19

kilowatt hours, so you’re accounting for an annual run 20

time in that, but we are accounting for run time in 21

the FER as well. I guess they’re just flipped fr om 22

each other and so it makes

– begs the question of, you 23

know, what’s the FER measuring, or is it an accurate 24

reflection of what the energy use between the two 25Executive Court Reporters (301) 565

- 0064 202 different blowers would be ? 1

MR. BROOKMAN: So, we’re due for a break. 2

It’s now three o’clock . Let’s see if we can do this 3

in ten minutes. And resume at 3:10, and then maybe 4

Alex and others can put their heads together and see 5

if they can unscramble this

– what seems to be 6

divergent results. Okay. 7

So we’re taking a break now. Everybody get 8

up, move. We’re going to resume in ten. 9

(Whereupon, at 3:00 p .m., the meeting was 10

recessed for a 10 minute period.) 11

MR. BROOKMAN: I’ve asked Alex to pick up 12

where we left off, which he says he’s in a position to 13

explain the divergence that Greg was referring to. 14

Alex. 15

MR. LEKOV: So here is the explanation. 16

We’re talking about non

- condensing furnace fan product 17

and condensing furnace fan product. The sample for 18

non

- condensing is primary from the south where the 19

condensing includes the north. Th e south is dominated 20

by the cooling coil which is at high speed. So, while 21

you have a large heating coil, but lower operating 22

point. So that’s kind of mathematically how you are 23

getting to this. 24

So with that now we’ll go through the life

- 25Executive Court Reporters (301) 565

- 0064 203 cycle cost and payback period analysis. Basically we 1

have the total installed cost, have the lifetime 2

operating expenses, and applying a number of economic 3

parameters to arrive at the life

- cycle cost as well as 4

the payback period. Most of you are familiar with 5

DOE’s a pproach to the life

- cycle cost analysis. The 6

primary thing here is that it’s performed from the 7

consumer perspective. The analysis models, the 8

uncertainty and variability of input, using Monte 9

Carlo approach, and is implemented in the Excel 10

spreadsheet w ith CrystalBall software. 11

Starting with the components of the life

12

cycle cost analysis. Consumer price, not much to say 13

here. We have manufacturer cost. For above baseline 14

standard to the markups were explained. Applying 15

sales tax, arrive at consumer price. 16

Installation cost. Installation cost for 17

furnace fans, there is not much because the furnace 18

fan product is installed in the factory as a part

– it 19

becomes part of the furnace fan equipment. There is 20

one exception in this analysis for the ext ernal ECM 21

furnace fan installation, we add some for installation 22

cost primarily for check up and adjust the air flow. 23

Now the next component is you need energy 24

prices, because energy prices multiply energy use 25Executive Court Reporters (301) 565

- 0064 204 you’re getting the cost of energy is part of the 1

operating expenses. So in this shipments analysis we 2

are using the average marginal monthly prices, and 3

those are essentially a product of three components 4

which are the average annual energy prices, using 5

monthly price factors, and marginal price fa ctors. 6

So, here are the sources listed for all these three 7

components using this methodology. And I could go in 8

some details. In essence, the average annual prices 9

are for 2010 from these sources. The monthly energy 10

prices are essentially the same sour ces, but over a 20 11

year period. And the marginal energy prices are from 12

the RECS 2005 data, it actually provides the billing 13

data for these regions. 14

MR. ROSENSTOCK: Question? 15

MR. LEKOV: Yes. 16

MR. ROSENSTOCK: Steve Rosenstock, EEI. I 17

understand th is and I guess my question is again, for 18

the updated analysis, well especially for natural gas 19

since the bottom’s kind of fallen in terms of natural 20

gas prices compared to four or five years ago, will 21

those projections be updated based on, I’ll say either 22

AEO 2012 or other more recent forecasts? 23

MR. LEKOV: Yes. 24

MR. ROSENSTOCK: Thank you. 25Executive Court Reporters (301) 565

- 0064 205 MR. LEKOV: And in line with what Steve just 1

said, here is the methodology how we calculate the 2

energy prices over the entire analysis period, and its 3

primary sourc e is the most current version of AEO 4

2012. So for the next round of this rulemaking, it 5

will be updated with the most current AEO data. 6

Repair and maintenance. 7

MR. BROOKMAN: These are annualized, right? 8

I’m sorry, go ahead. 9

MR. LEKOV: Yeah, the y are annualized. 10

MR. BROOKMAN: Yes, Paul. 11

MR. LIN: Paul Lin. Just maybe just a 12

question , because a lot of times I look at EIA data, 13

because we try to factor in some savings calculations 14

for some of our products. But if you look at 15

California rel ative to the EIA data, it looks fairly 16

low. I don’t know if you take it into account the 17

tier levels. As you consume more and more energy in 18

California, you get more and more charges. 19

MR. LEKOV: So the answer is it is by 20

geographical area, so we appli ed it by geographical 21

area, and for the next round of analysis it will be 22

even much more detailed than the 14 areas. It will be 23

27 areas because 2009 will have the RECS data and 24

we’ll be able to apply that. 25Executive Court Reporters (301) 565

- 0064 206 MR. LIN: But my point though is that in the 1

E IA data, I think California was like 15 or 17 cents 2

average, and I know that that’s not an average 3

consumer price based on bills, because the 15 may be 4

on the early stages of the tiers, but not at the end. 5

That’s where the consumer actually ends up paying

. 6

You probably

– 7

MR. ROSENSTOCK: Steve Rosenstock, EEI. 8

Well, if you look at the

– there’s only a few 9

utilities that have that sort of increasing price 10

tiers. Most utilities don’t have anything like that. 11

They have seasonal pricing that will vary, but

– what? 12

Congratulations. So and

– even in California, it’s 13

revenue divided by sales is how they come up with the 14

annualized value. California is

– and Hawaii are kind 15

of at the high end. There are many other parts of the 16

country where the annualize d price is like seven cents 17

for residential. And especially some of those going 18

to time

- of

- day pricing, some of them are getting 19

prices as low as off

- peak, three cents, four cents 20

kilowatt hour. So prices are all over the map, but 21

this again is a nation alized average, which I think is 22

what this graph is showing, it’s not

– it’s not bad at 23

all. 24

MR. BROOKMAN: Okay. So let’s

– 25Executive Court Reporters (301) 565

- 0064 207 MR. ROSENSTOCK: But there are going to be 1

some very regional specific, just like with natural 2

gas, there are certain parts of the country that are 3

going to be much more expensive than others. 4

MR. LEKOV: So getting into the repair and 5

maintenance part, essentially, repairs occur if the 6

fan motor lifetime is less than the furnace equipment 7

lifetime. We determined the failure y ear, expressed 8

essentially the motor lifetime expressing operating 9

cost, divided by the furnace fan annual operating 10

cost, the labor cost is coming from the RSMeans data 11

and we

– this is essentially through the center of the 12

sample, we determine which hous eholds will encounter 13

this expense. The maintenance cost is essentially 14

just in this analysis, assumes that will be a blower 15

checking as part of regular equipment maintenance, and 16

it happened that we had a survey regarding the 17

maintenance frequency of the se type of equipment and 18

we used from RSMeans the labor hour cost. 19

MR. BROOKMAN: Charlie Stephens. 20

MR. STEPHENS: I have one question here to 21

make sure I understand the effect of your analysis 22

methodology here, which is annualized repair costs. 23

If th e

– I’m just going to throw out some example 24

numbers. If the furnace lifetime is say 18 years and 25Executive Court Reporters (301) 565

- 0064 208 the motor failure for those that fail is 12 years, how 1

many motor replacements will I pay for? 2

MR. LEKOV: Essentially one. You have, 3

after the 12 th year, another one comes. 4

MR. STEPHENS: But you’re annualizing these 5

costs. Are you annualizing the next motor replacement 6

in year 13? 7

MR. LEKOV: Yes. 8

MR. STEPHENS: Then you really should not 9

annualize these costs. You need to put these costs 10

into the analysis. Because what you just told me is 11

that by the time I hit the end of the furnace 12

lifetime, I’ve paid for one and a half motor 13

replacements, and that’s not what actually happens. 14

MR. LEKOV: No, you’re paying for a whole 15

motor. This is how it’s included in the analysis. 16

MR. STEPHENS: Well, are you annualizing the 17

cost, or are you imposing them in year 12? 18

MR. LEKOV: It’s annualized over the period 19

with the total cost, I believe. 20

MR. STEPHENS: Well, you really need

– 21

there’s a difference , when you’re using discount 22

rates, and depending on the discount rate the effect 23

changes, but you really need to impose those costs. 24

You don’t pay those on an annual basis, you pay them 25Executive Court Reporters (301) 565

- 0064 209 when they happen in the year they occur. And I’ve 1

made this comment before. You shouldn’t be 2

annualizing repair costs that occur every 12 or 15 3

years. If it’s every one or two years, that’s fine, 4

but when you start doing that and annualizing it, you 5

actually distort the analysis financially. So you 6

really need to chang e that part of the analysis and 7

not annualize the repair costs. 8

MR. BROOKMAN: Tom, you want to follow on? 9

MR. ECKMAN: Yes, treating it as a periodic 10

capital replacement X years out, and then it’s a 11

discounted value back to the

– 12

MR. LEKOV: So in the year of the 13

replacement? 14

MR. ECKMAN: Yeah. 15

MR. BROOKMAN: Good. Okay. Thank you. 16

Yes, Craig. 17

MR. MESSMER: Craig Messmer. Okay. The 18

lifetime of the motor you said is in terms of 19

operating hours, and it was based on the small motor 20

ruling. Does that differentiate the life of the motor 21

if it’s an EC motor or if it’s a PSC motor, because 22

they will be different? EC motors have a 23

significantly shorter life span that PFC motors. 24

MR. LEKOV: We use a distribution of more 25Executive Court Reporters (301) 565

- 0064 210 the left. I don’t belie ve that we used

– that we 1

differentiated. 2

MR. BROOKMAN: So in your supportive data, 3

Craig, that would be helpful. 4

MR. MESSMER: I’m going to have to defer to 5

my compatriots here that are motor manufacturers to 6

tell us what the expected life is of thes e motors. 7

MR. LIN: Well, in the small motor rule, 8

that talks to cap start, cap run, cap start induction 9

run, and polyphase motors, and they’re all fixed speed 10

motors. So there’s no consideration in there for ECMs 11

whatsoever. So they’re not in the sm all motor rule. 12

MR. MESSMER: Okay. So that’s inappropriate 13

to use that data then. We need something else, right. 14

MR. BROOKMAN: Paul, first. 15

MR. LIN: From a specification standpoint, I 16

could be wrong, but I remember ECM motor life 17

specification s from manufacturers to be the same as a 18

PSC motor, on your specs. 19

MR. BROOKMAN: Diane. 20

MS. JAKOBS: I think that’s true, but I 21

don’t think that’s

– well, when I talk about what our 22

actual returns are and our warranty costs, that’s what 23

we ask for. Tha t’s not how it’s playing out. 24

MR. BROOKMAN: Dave, you’re next. 25Executive Court Reporters (301) 565

- 0064 211 MR. WINNINGHAM: Yeah, I would agree with 1

that, and I think the expectation is for them to be 2

the same, but I think in the real world, they’re not. 3

More complex systems in our products te nd to have 4

different failure rates, higher failure rates. And I 5

think for each of these technology levels you need to 6

take that into account, into your life

- cycle cost, 7

because, you know, a lot of times you will have a 8

motor and a control, and they’re goi ng to replace the 9

whole thing. And we need to account for those costs 10

accurately to come to the right conclusion here. 11

MR. BROOKMAN: Diane. 12

MS. JAKOBS: I think with the PSC motor that 13

the bearings are probably the weak point, and then as 14

we add the control board to the assembly, the control 15

board with all the components and the potting (ph) and 16

all that, that that’s a weak link in the device. So 17

we have a different failure mode with the high 18

efficiency motors. 19

MR. BROOKMAN: Okay. Thank you. 20

MR. LEKOV: Another important component is 21

to determine the lifetime. So, in general, it’s 22

assumed that a furnace fan lifetime equals the furnace 23

equipment lifetime. For the individual product cost 24

there is a different methodology for determining the 25Executive Court Reporters (301) 565

- 0064 212 equ ipment lifetimes, and it’s based on an analysis for 1

not only the ... furnaces, it’s based on the analysis 2

which were performed also for the furnace rule, and it 3

uses a combination of shipment data, REX data on the 4

age of the furnaces, and the historical HS d ata on the 5

stock. 6

For the mobile home and electric furnaces, 7

we use the decision ... survey, and those are the 8

sources and the methodologies used for the 9

determination of the furnace fan lifetime. 10

The average values are summarized in this 11

table for the individual product cost. 12

MR. BROOKMAN: Steve Rosenstock. 13

MR. ROSENSTOCK: Steve Rosenstock, EEI. I 14

can’t remember

– I’m trying to think in the

– I’m just 15

kind of

– and again, maybe other people

– in the small 16

motor rule , I can’t remember

– what was the lifetime

– 17

I thought it was like a 15

- year lifetime for those 18

motors that were under the small motor rule. 19

MR. LEKOV: So I would just like to

– 20

essentially we are talking about the entire furnace 21

fan component here, in terms of assumptions for the 22

l ifetime. The failure of the motor is accounted in 23

the repair and maintenance, the right rate. 24

MR. LIN: Paul Lin. I think you just be 25Executive Court Reporters (301) 565

- 0064 213 careful with taking the small motor and then cross

1

referencing that over to an HVAC motor. The design of 2

a general pu rpose duty small electric motor as defined 3

by the DOE standard is much different than an HVAC 4

motor. There’s different requirements and loads on 5

those motors. Diane mentioned the bearing being the 6

weakest link on most HVAC motors. It’s sleeve bearing 7

on the PSC and ball bearing on the ECM. And on the 8

general purpose, small electric motor, they’re all 9

larger ball bearings with, I would say, higher loads 10

and a lot of times there are different application 11

environments that may reduce the life or may increa se 12

the life relative to the HVAC environment. So I think 13

drawing a comparison between the two may not be 14

accurate. The HVAC motor is an air

- cooled rated 15

motor, whereas the small electric motor is not. So 16

there’s a big difference between the two. 17

MR. B ROOKMAN: Okay. Steve. 18

MR. ROSENSTOCK: Steve Rosenstock. Yeah, 19

again, thank you for that. Just kind of following on, 20

so you would say that the HVAC motors would tend to 21

have a longer life based on the operating conditions? 22

MR. LIN: I think the HVA C motors have a 23

more benign environment versus the small electric 24

motors. 25Executive Court Reporters (301) 565

- 0064 214 MR. ROSENSTOCK: Okay. Thank you. 1

MR. BROOKMAN: And would you say, looking at 2

this table that this is an accurate reflection? 3

MR. LIN: Paul Lin. This table here is 4

referr ing to the appliance equipment. 5

MR. BROOKMAN: Yeah. 6

MR. LIN: Is not referring to the life of 7

the motor, so I can’t fault the distinction between 8

the two. 9

MR. BROOKMAN: So we can

– go ahead. Diane. 10

MS. JAKOBS: Diane again. Yes, I think this 11

re flects the life of our furnaces, and especially, you 12

know, after 15 years, you have to change the motor 13

out, you’re good to go for another ten years or more. 14

MR. BROOKMAN: Okay. So this winter I could 15

be in trouble, right? Go ahead, Craig. 16

MR. MESSM ER: Is this slide saying that the 17

furnace fan is the life of the unit? 18

MR. LEKOV: The furnace as a whole analysis 19

in terms as it’s a unit in the analysis, the furnace 20

fan product equals the life of the equipment. 21

MR. MESSMER: Okay. They typically g et 22

replaced when the motor gets replaced? 23

MR. LEKOV: Correct. 24

MR. MESSMER: So

– 25Executive Court Reporters (301) 565

- 0064 215 MR. LEKOV: Oh, that’s a comment. 1

MR. MESSMER: They change out both parts at 2

the same time. 3

MR. BROOKMAN: Okay. Diane. 4

MS. JAKOBS: So you’re saying when you g et a 5

new furnace, you don’t keep your furnace fan because 6

it has some life left in it, you’re done with it when 7

you replace your whole furnace system. 8

MR. LEKOV: That’s correct. 9

MR. BROOKMAN: Okay. Dave. 10

MR. WINNINGHAM: And just back to the life 11

issue. The motor side of it can be one thing, but how 12

a manufacturer applies it

– and some manufacturers may 13

choose to be more aggressive than others and to the 14

operating window that they’re placing that motor in. 15

So I don’t think that just a generic sta tement around, 16

you know, the expected life of an HVAC motor is, you 17

know, from the suppliers is X because in most cases 18

we’re specifying to them what we need from them for 19

performance and we kind of choose where we’re going to 20

operate it in regard to tempe rature rise and bearing 21

temperatures. 22

MR. BROOKMAN: Okay. 23

MR. LEKOV: So, DOE uses discount rates to 24

determine the lifetime of the operating expenses for 25Executive Court Reporters (301) 565

- 0064 216 the product, and the methodology is to derive those 1

discount rates from estimates of the financ e cost to 2

purchase a residential product from the large federal 3

reserve board survey of consumer finances. The 4

sources at the last bullet. There are actually a 5

number of surveys , each of them contain 200,000 data 6

points, and the finance cost is essential ly 7

represented as the financial cost of any debt incurred 8

to purchase the product or as an opportunity cost. 9

Now, here essentially, the interest rates 10

that are encountered in both new construction and 11

replacement, I will repeat

– this is a question

– 12

th ose are real interest rates. They account for the 13

inflation. In essence it’s when people ask how we 14

compare with the current one, you add three, 15

approximate. 16

MR. BROOKMAN: Steve. 17

MR. ROSENSTOCK: Steve Rosenstock, EEI. So, 18

the

– for the mortgage, i t’s basically assuming that 19

it’s a real rate of three percent, but the nominal 20

rate of six percent. Is that a good way of kind of 21

looking backwards over the last, I’d say, 20

- plus 22

years. 23

MR. LEKOV: ’89 through 2007, about 200,000 24

data points. And I gu ess the issue with replacements, 25Executive Court Reporters (301) 565

- 0064 217 again, there’s no data from 2010. I know it would be 1

a real interest rate of

– a nominal interest rate of 2

about eight percent. Looking back over 20 years, that 3

might be a little on the low side, just because 4

interest rate s were a lot higher in the late 80s, 5

early 90s. So, again, it’s kind of in the weeds, but 6

again

– and especially in terms of replacement, 7

especially after the recession, I have no idea how 8

more people are financing the replacements but it’s 9

much harder

– I think it’s probably much harder for a 10

lot of people to get loans or home equity loans than 11

it was just seven years ago, so that might also push 12

up the real rates as well. 13

MR. BROOKMAN: Other comments on discount 14

rates? 15

MR. LEKOV: Product assignment in the base 16

case. Base case product efficiency assignment 17

reflects the projected market share of products at 18

different efficiency levels, and it reflects the fact 19

that not all consumers purchase products at the 20

current minimum standard, as well as the LC C 21

recognizes that the consumers already purchase 22

products at efficiency greater than or equal to 23

projected standard level. So they are not impacted by 24

the standard. 25Executive Court Reporters (301) 565

- 0064 218 The approach taken is

– the sources for the 1

methodology are explained here in the bullet s. 2

Basically, we’re using historical data that comes from 3

sales of furnace by efficiency and by product class 4

which is not available, so we use stakeholder comment s 5

from the furnace rule which stated that the ECM share 6

rose from ten to 30 percent within t he last five 7

years. Just for the PSC product classes, there was no 8

data, so it was assumed that 50 percent are at the 9

baseline level and 50 percent are at improved PSC 10

motors, and there are no designs representing PSC with 11

controls. 12

Regarding the market share projections for 13

the ECM motors. So if it’s done based on the fraction 14

of motors

– fraction of equipment with ECM motors in 15

the current directories, which is 45 percent in 2010, 16

we assume that this fraction of 45 percent will 17

actually meet the marke t share in 2080. And the 18

market share in replacement versus new construction 19

was determined from Canadian survey. 20

MR. BROOKMAN: Diane. 21

MS. JAKOBS: I know in 2010 public meeting I 22

said that 30 percent of our sales were going to ECMs, 23

and back then when we had, I don’t know, tax rebate it 24

was called, and we’re all geared up, you know, 25Executive Court Reporters (301) 565

- 0064 219 everybody’s going high efficiency, and last year it 1

all turned back around and everybody wants to buy the 2

bottom. So you don’t have that graph, but it’s in 3

here, you k now, where it shows this big bleep, and 4

then you go up from there. We’ve actually come way 5

back down. And I don’t know where it’s going to be. 6

We’re kind of focused on the lower end of our offering 7

because that seems to be where we need to be 8

competitiv e. 9

MR. BROOKMAN: It’s come all the way back 10

down to where it was? Wow. Dave. 11

MR. WINNINGHAM: Yeah, I don’t have the 12

data specific, but it has

– it is turned more complete 13

down. 14

MR. BROOKMAN: Okay. 15

MR. LEKOV: So I assume it’s also at the 16

comm ents right now. And here are the life

- cycle cost 17

and payback analysis report from DOE’s preliminary 18

analysis for the furnace fan products. 19

MR. BROOKMAN: Craig. 20

MR. MESSMER: It’s Craig Messmer. I didn’t 21

read all the way through the technical docum ent, but 22

the lifetime operating cost includes the cost of the 23

repair, the replacement of the motor as well? The 24

average lifetime operating cost? 25Executive Court Reporters (301) 565

- 0064 220 MR. LEKOV: As part of the operating 1

expense. 2

MR. MESSMER: Well, somebody’s getting a 3

good deal. Thank y ou. 4

MR. BROOKMAN: Well, I mean

– Craig, you 5

should feel free to offer you additional thoughts on 6

this, how this could be improved. 7

MR. MESSMER: I mean, replace an EC motor, I 8

mean I’ve seen prices in contractors that charge 9

customers over $5

- 600 do llars sometimes, and this is 10

already $800 for the average lifetime, operating cost 11

for the whole unit. So if you replace that motor one 12

time, you have nothing left for the electricity for 13

the whole use. So I’m not

– you don’t really say what 14

the repair c osts are, do you? 15

MR. LEKOV: I don’t think it’s listed here, 16

but it’s in the TSD. 17

MR. MESSMER: Okay. I’ll have to take a 18

look at that more carefully, because I think it may be 19

under

- reported. 20

MR. BROOKMAN: Charlie Stephens. 21

MR. STEPHENS: Charl ie Stephens. Yeah, I 22

think you’ve got to remember this is all rolled up 23

into one number. Not everyone out there got repaired. 24

So the overall number of homes that had a motor 25Executive Court Reporters (301) 565

- 0064 221 replaced might be three percent or four percent or 1

something of the total. So, when I weight that in the 2

costs, it’s not $500 bucks, it’s not even $100 3

dollars, it’s probably more like $45 dollars or 4

something because it’s only a fraction of the homes 5

that actually had to replace a motor. So this is a 6

very rolled

- up set of numbers. And it’s more like an 7

expected value in a distribution, really. 8

MR. BROOKMAN: I saw Dave first. 9

MR. WINNINGHAM: Well, just to echo what 10

Craig had mentioned. I think the markup in the after 11

market for replacement parts, you know, after the 12

warranty period is much, much higher than what you 13

would find for an OEM. That combined with the 14

difference in failure rates, I think we need to be 15

careful that we include a realistic view of that in 16

these life

- cycle cost. 17

MR. BROOKMAN: Okay. Thank you. Stev e. 18

MR. ROSENSTOCK: Steve Rosenstock, EEI. It 19

might be

— and again, I think I’m going to agree, 20

because if you take a look between three and four, in 21

a previous slide, the savings were about the same, 290 22

versus 265 kilowatt hours, but life

- cycle cost c hanges 23

between three and four are quite dramatic, both 24

because of initial cost and lowered reduced lifetime 25Executive Court Reporters (301) 565

- 0064 222 energy savings, plus, probably, some of the repair 1

costs. So go from a five year payback to a 22 year 2

payback, something’s going on there. 3

MR. BR OOKMAN: Paul. 4

MR. LIN: Paul Lin. Just wanted to comment 5

because I’ve heard some of our OEMs talk about 6

replacement of the whole ECM. We spend a tremendous 7

amount of energy and time educating the contractor 8

base that

– of how to diagnose between a con trol 9

failure versus a motor failure. So we offer control 10

only replacement, as well as a motor only replacement, 11

to try to tackle the total cost of install. So it’s 12

not

– so after the markup, it’s not the whole motor. 13

It’s hopefully a smaller portion of t he cost than what 14

it used to be. 15

MR. BROOKMAN: Okay. Tom Eckman. 16

MR. ECKMAN: I have a question, this is to 17

the manufacturers and motor manufacturers, both, 18

whether the X13 type technology suffers the same fate 19

because it has a control board too. Is it a higher 20

frequency replacement item than the ECM? And is it 21

like the ECM in terms of magnitude, that it’s double 22

your PSCs? 23

MR. BROOKMAN: Diane. 24

MS. JAKOBS: Just this specific point in 25Executive Court Reporters (301) 565

- 0064 223 time, X13s are more of a problem for us this month 1

than ECMs . But they’re newer, so I don’t know that 2

that reflects on the technology. It’s both. When I 3

was talking about double, we were talking about

– 4

MR. LIN: Both X13s and ECMs. 5

MS. JAKOBS: Yes. 6

MR. BROOKMAN: Dave, you want to weigh in 7

here? 8

MR. WI NNINGHAM: Yeah, I think, you know, 9

looking at the various technologies and looking at 10

what the real world failure rates from various 11

manufacturers would be a good exercise. We’re not 12

here to say it’s poor motor designs, but we do see 13

higher ORT (ph) rate s and failure rates in the field 14

of more technical products. 15

MR. BROOKMAN: Okay. Terry Small , I see 16

you’ve raised your hand. You’re next. 17

MR. SMALL: Terry Small with Mortex. I 18

think this just proves that the consumer might know 19

something that we d on’t know. I really think that 20

choice three, the X13, the payback period from our 21

experience of what we’re paying for the motors is 22

going to be much lower, you know, it might be eight or 23

ten years. And I’m not sure that’s an acceptable 24

payback period whe n you consider you’re making some 25Executive Court Reporters (301) 565

- 0064 224 generous assumptions about discount rates, et cetera. 1

So, maybe the consumer actually is voting on an 2

economic basis when they’re tending to stick with PSC 3

motors. It’s my opinion. 4

MR. BROOKMAN: Okay. Thank you. Fin al 5

comments on this chart. Noting that you have plenty 6

of time to write copious comments and send them in. 7

MR. LEKOV: So DOE invites comments and 8

recommendations regarding overall life

- cycle cost 9

analysis. 10

MR. BROOKMAN: Joanna, you have a question? 11

MS. MAUER: Why was 2018 chosen as the first 12

year of the analysis period? 13

MR. LEKOV: That’s the five year period 14

after the final rule. 15

MS. MAUER: And why is the assumption that 16

the standard would have gone into effect five years 17

after the final rul e? 18

MR. ROSENSTOCK: That’s typical. Steve 19

Rosenstock, EEI. That’s typical for motors, five year 20

lead time. 21

MS. MAUER: This is on furnace fans, so I’m 22

asking about furnace fans. 23

PARTICIPANT: (comment off mic) 24

MS. MAUER: So again, this is not furnace, 25Executive Court Reporters (301) 565

- 0064 225 the furnace rulemaking, but a furnace fan rulemaking. 1

MR. BROOKMAN: And we can accept an 2

affidavit on that point. 3

**National Impact Analysis, Shipments Analysis** 4

MR. LEKOV: We discussed the consumer, let’s 5

now focus on the nation. The national impact analysis 6

has shipments and

– shipments component and national 7

impact analysis component. So, the national impact 8

analysis, we need an estimate for the national energy 9

savings as well as the national economic impacts, 10

which are presented in terms o f NPVs

. 11

Now, here is the process. Essentially, 12

starting with some inputs which come from the life

13

cycle cost

-- primar il y from the life

- cycle cost 14

analysis and the results from the shipments model, 15

we’re going into the calculation process to determine 16

the national energy savings and national consumer 17

economic impacts. And after that, those are reported 18

in terms of quads and net present value by estimating 19

the savings over the period, 2018 and 2047, and same 20

for the NPV calculations for the products. 21

Starting with the shipments analysis. The 22

shipments projection s are done by markets. Three 23

markets are identified for the furnace fan products: 24

New construction, replacement, new owners. The new 25Executive Court Reporters (301) 565

- 0064 226 constructions are coming from new housing construction 1

p rojections and historical market share. The 2

replacement s are using the product lifetime applied to 3

the product stock. There is a market segment called 4

new owners, this is for the existing buildings that 5

acquire furnaces or furnace fans for the first time , 6

and it’s in this particular market to include also 7

consumers that switch between the furnace fan product 8

classes. 9

In addition, the projected shipment inputs 10

are done separately by region, north and south, and in 11

accounting for impacts of standard level s, the 12

shipments are adjusted using the price LCC. And I’ll 13

be talking in more details during the next several 14

slides. 15

Now, same thing here what I just said 16

verbally, it’s presented on this graphic. 17

Now, shipments model input. Very busy 18

slide , but es sentially includes all the information if 19

you want to read it. What are the sources for the 20

historical shipments? What’s happened in the 21

replacement shipments? Shipment sources for the 22

shipments to new housing. We’re talking also about 23

how we develop t he so

- called new owners, and I was 24

pointing to the source of calculation of condensing 25Executive Court Reporters (301) 565

- 0064 227 and non

- condensing market shares. 1

MS. JAKOBS: Can I ask a question? 2

MR. BROOKMAN: Yes, Diane. 3

MS. JAKOBS: So I’m looking ahead at the 4

graphs, but

– 5

MR. LEKOV : Which one? The shipments model 6

results? 7

MS. JAKOBS: Yeah, the historical one, that 8

looks familiar. And the next one, though

– so the 9

next one, you’re kind of assuming we’re going to go 10

back to 1992 and just go back on our old trajectory, 11

which I re ally wish would happen. So part of your 12

analysis

– you’re so detailed

– but are there housing 13

projections? I mean there are a lot of houses that 14

have been foreclosed on, and they’re not

– no one’s 15

living there any more. All that

-- is a housing stock 16

ex pected to go back to where it used to be. 17

MR. LEKOV: So the slides here, the model 18

explains how we arrived. Those are all those details 19

of the shipments model that utilize the sources listed 20

here to arrive at this conclusion. 21

MS. JAKOBS: But you don ’t really talk about 22

how many houses there are that are going to need this 23

equipment, and that might

– 24

MR. LEKOV: No, in fact, that’s an 25Executive Court Reporters (301) 565

- 0064 228 accounting which is done exactly this way within the 1

spreadsheet. That’s published on the DOE website. 2

MR. BROOKM AN: Charlie. 3

MR. STEPHENS: Alex, I can tell by looking 4

at your graph there and knowing what your furnace 5

lifetimes are, that there’s something wrong with your 6

model already because when you see a 50 percent or 7

nearly 50 percent drop in 2008 shipments, which I 8

think most of us know was due to housing start 9

failure, there should be an echo of that about one 10

furnace lifetime later, and there’s not even a tiny 11

ripple in your projections out there. All those 12

houses that didn’t get built, that didn’t get new 13

furnaces, aren’t going to get replacement furnaces 14

either. So I don’t know where that echo is, but there 15

should be one there. 16

MR. LEKOV: So this reflects essentially the 17

AEO’s projection of the new housing start projection. 18

So this is what it is. 19

M R. STEPHENS: This is all shipments, right? 20

MR. LEKOV: Correct. 21

MR. STEPHENS: Including replacements? 22

MR. LEKOV: Including replacements. 23

MR. STEPHENS: There should be an echo of 24

what you’re seeing on the left there. If I play out 25Executive Court Reporters (301) 565

- 0064 229 your furnace lifetimes, you know, there should be an 1

echo of that somewhere, and it’s not there. So I 2

don’t know where your model went wrong. 3

The other thing is that I’ve got a bunch of 4

houses that are being built for me right now in a 5

pilot program that aren’t goin g to use any air 6

handlers or ducted systems because they’re design 7

space heating loads are between 12 and 15,000 BTU per 8

hour. So this is a trend

– the codes are going there, 9

and there aren’t any furnaces, ducted systems that are 10

small enough for these ho uses, and so the people who 11

are building these houses are using other means. And 12

I think it’s a trend that you need to pay attention 13

to, because by the time you get out 20 years from 14

where we are now, which is way less than 20 years from 15

the time this tak es effect, 2018, things will have 16

moved to the point where, unless we reinvent the air 17

handler and the furnace, I don’t know that you’re 18

going to maintain anything that looks like an increase 19

here. 20

And I don’t

– I’m not going to say anything 21

about AEO, b ut the fact is that the trends in the 22

marketplace that we’re seeing, and that in part, my 23

organization is actually driving, suggests that any 24

increase out there is probably ill

- advised in your 25Executive Court Reporters (301) 565

- 0064 230 projections. 1

MR. BROOKMAN: Steve. 2

MR. ROSENSTOCK: Steve R osenstock, EEI. You 3

always have to make a projection and I think that I 4

would say that this numbers look a little ambitious 5

for a couple of reasons. Number one, the era 6

especially from 2000 to 2007, was the housing bubble 7

and new homes were being built at a rate like

– single 8

family homes, about 1.2, 1.4 million per year. And 9

the latest numbers that I saw in terms of houses built 10

are about 600,000, and I think that might even include 11

multi

- family as well as single family. And new home 12

sales, single fa mily home sales were

– well, they 13

jumped up to all of 350,000 on a seasonally adjusted 14

average. So I don’t know how long it will take. It 15

might be much more of gradual slope than what’s being 16

shown here, that there’s going to be some sort of 17

explosion st arting in like 2013 or so. And the 2009, 18

2010 and even maybe some of the other numbers were 19

helped by federal tax incentives that disappeared. I 20

believe they expired at the end of 2011 or 2010, I 21

can’t remember

– no, 2010, that was when the rush was. 22

Th ey were in effect from 2009 to 2010. So again, 23

there’s

– again, I’m trying to

– I know it’s AEO, but 24

I don’t know what economic factors are going to lead 25Executive Court Reporters (301) 565

- 0064 231 to this explosion of shipments back to where it was in 1

– during the housing bubble. Again, this is j ust 2

personal opinion that that I think that rise is going 3

to be much more gradual than what’s being shown here. 4

Again, thank you. 5

MR. BROOKMAN: Yes. 6

PARTICIPANT: I think another thing you’re 7

seeing evidence of here, and that bled over from the 8

2006 minimum efficiency increases, particularly on the 9

air conditioning and heat pump side, is that people 10

chose to repair instead of replace. And I think that 11

is still an ongoing trend, and as we look at rules 12

that potentially put into place more expensive 13

eq uipment, that trend could possibly continue and 14

actually be a detriment to seeing increased energy 15

savings by people being able to afford newer higher 16

efficiency equipment. 17

MR. BROOKMAN: Okay. Thank you. Greg. 18

MR. WAGNER: I would echo that, that yo u do 19

see more replacement parts being sold. Also if you 20

would look at the use of room air conditioners, those 21

sales have continued to increase. So people are 22

finding other alternatives to the expensive options of 23

new equipment. 24

MR. LEKOV: Are there an y observations 25Executive Court Reporters (301) 565

- 0064 232 regarding heating equipment? 1

MR. WAGNER: The repair, again, they’re 2

doing what they can to repair. 3

MR. LEKOV: Repair is in essence, a delay. 4

MR. WAGNER: A delay, correct. Replace 5

components. Parts. 6

MR. BROOKMAN: Okay. Thank you . Yes, Alex. 7

MR. BOESENBERG: Alex Boesenberg, NEMA. For 8

what it’s worth, there are some comments in the 9

distribution transformers rulemaking that are very 10

similar in that the

– some of the proposed increased 11

efficiencies, utilities directly stated the y would 12

repair existing units to old efficiency levels rather 13

than buy new. So there’s other industries with the 14

exact same trend, largely owing to the economy and 15

first price cost

– first purchase cost, whatever you 16

call that. 17

MR. BROOKMAN: We kind of moved very quickly 18

over the first slide, the precursor slide, the inputs. 19

If that’s okay, that’s great, and we move to the 20

graphics. Additional comments on all of those, and 21

maybe you can keep going, Alex, talk about the line 22

graph. 23

MR. LEKOV: So bas ically this is the outcome 24

of the shipments model. Here shows the baseline

– 25Executive Court Reporters (301) 565

- 0064 233 this is essentially a line from the previous chart, 1

and shows the standard cases, and as here, ... there is 2

a, in case of higher cost, we’re seeing a drop in the 3

purchases, and del ay, essentially, which is a little 4

bit further. 5

MR. BROOKMAN: Yes, Diane. 6

MS. JAKOBS: If you just look at like the 7

foreseeable

– I mean, it starts at 2015, so like 2016, 8

2017, they’re going to go up at an amazing rate, which 9

will be good, and then

– I wish this was true. I 10

would echo Steve’s comments. It’s so hard because 11

it’s been so erratic, and we have

– even if you look 12

at the slide before, we had all this

– a whole bunch 13

of sales, and those furnaces are going to wear out. 14

So maybe it’s going t o be compounded, but just like 15

this dip is going to be echoed in 15 years, I can see 16

it’s really hard to make this assumption, and this 17

seems to be very aggressive. 18

MR. BROOKMAN: Thank you. 19

MR. LEKOV: So, from here we have the 20

shipments results. W e’re going to calculate the 21

national impacts, and here are the inputs that go into 22

the national impact analysis. Annual energy 23

consumption per unit, this is from the life

- cycle cost 24

analysis. Shipments, from the model just described. 25Executive Court Reporters (301) 565

- 0064 234 The equipment stock from uses annual shipments and the 1

lifetime of the product. And the national annual 2

energy consumption is essentially a product of the 3

annual energy consumption and the equipment stock. 4

Here it’s important to say that DOE actually 5

applied a rebound imp act for this product, thus 6

reducing the economic national economic benefits, and 7

those came from the

– they are based on the 2009 8

Wisconsin study. They were applied

– somewhat 9

differently to the north and south. And in addition 10

to this, the national impac t analysis using .. source 11

conversion factors for converting the ... energy 12

consumption into primary or source energy consumption, 13

and those are from NEMS (ph) 14

In this case, DOE particularly requests 15

comments on the values used to characterize the 16

rebound effect. 17

MR. BROOKMAN: Steve Rosenstock. 18

MR. ROSENSTOCK: Steve Rosenstock, EEI. 19

Again, I don’t know if I’m sure that study is 20

available, but in terms of that field study, there was 21

a state standard requiring ECM furnace fans, is that 22

what I’m reading ? 23

MR. LEKOV: No, it’s based

– actually the 24

study did a targeted replacement of furnace fans with 25Executive Court Reporters (301) 565

- 0064 235

– furnaces with PEC to ECM models, and they over a 1

period of time, they calculated how people are using a 2

constant ventilation, constant circulation. And t hey 3

found that it’s quite significantly more people are 4

using constant ventilation. 5

MR. ROSENSTOCK: So, but those are replacing 6

the furnace, not just the furnace fan in those cases, 7

is that correct? Again, it’s a component system thing 8

again, because I think that’s going to play a big role 9

in terms of

– my opinion

– it’ll play a big role in 10

the rebound effect. 11

MR. LEKOV: My understanding is they’re 12

replacing the entire equipment. 13

MR. ROSENSTOCK: The entire furnace, okay. 14

Two comments. Again, we’ re just looking at this 15

component. I’d be very surprised to see rebound 16

effects that high because you have the same furnace. 17

If and some

– you’re just looking at the component, 18

you’re just replacing the fan, you’re not replacing 19

the rest of the furnace f or some reason, again, just 20

looking at the fan as a component, because that’s what 21

this analysis is about, the furnace efficiency is the 22

same. The thermostat settings are the same. I don’t 23

see how much of a rebound effect you’re going to get 24

because in m any people’s eyes, you may or may not get 25Executive Court Reporters (301) 565

- 0064 236 that much energy savings. You replace a furnace, I 1

think some of these rebound effects might be available 2

because, again, people might think oh, I’ve got a much 3

more efficient furnace, I can raise the thermostat a 4

little bit. So I think if we’re just looking at the 5

fan, especially I think a 20 percent number might be a 6

little on the high side. I don’t know about the 10 7

percent, but , and again, but if you’re assuming

– 8

again, just for the fan, those numbers might be high, 9

but if it’s the whole furnace, 20 percent might still 10

be a little on the high side, but again, that’s just 11

my thoughts on that. Again, it’s all a matter of how 12

we’re looking at this analysis. 13

MR. BROOKMAN: Mohammed. 14

MR. KHAN: Mohammed Khan, DOE. I just want 15

to point out that if you’re in the constant 16

circulation mode, only, so you’re just running the fan 17

that’s in the furnace or AC unit or air handler, 18

whatever you want to call it, you’re not heating or 19

cooling. You’re just moving air. So I would think it 20

wouldn’t matter. 21

MR. BROOKMAN: Charlie Stephens. 22

MR. STEPHENS: Charlie Stephens. I 23

mentioned this earlier and I don’t want to go into it 24

in great depth, we’re running late, but you’re not 25Executive Court Reporters (301) 565

- 0064 237 just moving air. You’re filtering air. An d you’re 1

going to say in a lot of cases I don’t know whether 2

there’s a correlation or a causation here. I don’t 3

know. I’m not convinced that people are doing this 4

because they bought an ECM equipped furnace, or 5

because the contractor sold them a great el ectronic 6

filter system and promised them really good indoor air 7

quality if only they added another $500 bucks to the 8

job, and I don’t know whether it mattered what kind of 9

furnace they put in or not. But I know that every 10

time I’ve had interaction with th ese contractors and 11

people who have, there has been an attempt to upsell a 12

filtration system, and it almost always comes with 13

circulation attached. And the other piece is 14

ventilation. There is ventilation going on here, and 15

they are sometimes using this in a ducted system. 16

They’re using the air handler to distribute the fresh 17

air that they bring in on the return side. 18

So that’s a trend and you can’t ignore these 19

things because they’re going on. But I don’t think 20

you can attribute it as rebound effect to the choice 21

of an ECM motor. If you require ventilation because 22

the code says you have to have ventilation and you 23

choose this inlet fresh air to do it, it doesn’t 24

matter what furnace you picked, or what the motor is, 25Executive Court Reporters (301) 565

- 0064 238 you’re going to have to run it so m any hours a day, 1

regardless of what’s in there. So then you save a 2

little energy if you pick the more efficient fan. 3

But, you know, the fact is, to really apply 4

rebound effect, there has to be a cause and effect, 5

and I’m not convinced that these thing s are related. 6

The choice of an ECM motor results in more circulation 7

time. 8

MR. BROOKMAN: Diane. 9

MS. JAKOBS: I read this paper a long time 10

ago, and I’m from Chicago, and I’m close to Wisconsin. 11

But my impression from reading it was more that during 12

the shoulder months, that people open the window and 13

run their circulation fan to distribute the air. So 14

it’s not necessarily a filtering, that it was just to 15

distribute the air within the house. And it seemed 16

like it was a pretty good study, that there was a 17

significant reason for where they went from PSC to 18

ECM, and it seemed like a good study. 19

MR. BROOKMAN: Okay. Thank you. 20

MR. LEKOV: So, here is an illustration of 21

how the ECM market share, in the absence of standards, 22

was calculated. It ref lects the two, the ten percent 23

and the 30 percent point, and 45 percent in 2018. 24

MR. BROOKMAN: Go ahead, Diane. 25Executive Court Reporters (301) 565

- 0064 239 MS. JAKOBS: So in your curve there, I would 1

go back down to 15 percent in 2011, and see what that 2

does to your curve. It would probably m ake it go way 3

up, right. But

– there was a significant event when 4

the tax rebates ended. 5

MR. LEKOV: So more data points would be 6

appreciated. 7

MR. BROOKMAN: Okay. Thank you. 8

**Na tional**  **E nergy**  **S avings and**  **N et**  **P resent**  **V alue**  9

MR. LEKOV: So, I’ll go d irectly to the

– 10

those are the national energy savings for the product 11

classes based on the preliminary analysis. 12

MR. BROOKMAN: Joanna. 13

MS. MAUER: Joanna Mauer. In the TSD there 14

is some discussion of double counting of cooling 15

savings. Is that re levant to the scope that’s 16

included in the preliminary analysis, the issue of 17

potential double counting of energy savings? 18

MR. LEKOV: The scope was discussed this 19

morning, and the equipment that includes

-- some 20

furnace fan equipment is not considered i n this 21

rulemaking, and it was listed on one of the first 22

slides this morning. 23

MS. MAUER: And is that equipment that’s 24

excluded where potential issue of double counting 25Executive Court Reporters (301) 565

- 0064 240 would come in, not for the equipment that has been 1

included in the scope. 2

MR. BROOK MAN: Let’s hear from Sam Jasinski. 3

MR. JASINSKI: So one of the key product 4

classes, weatherized gas furnaces, actually includes 5

the central air conditioner component, so it does have 6

a SEER rating, so that one would be subject to the CAC 7

rulemaking, an d that is where

– an example of where 8

this double counting may occur, and has to be 9

considered in the energy savings. 10

MR. BROOKMAN: So for those of us that don’t 11

know, what is double jumping? 12

MR. JASINSKI: Double counting is

– 13

MR. BROOKMAN: Oh, d ouble counting. 14

MR. JASINSKI: Yes. Essentially the SEER 15

rating used for CAC and heat pump products does 16

consider the fan electricity consumption to a certain 17

degree, so Alex can explain in more detail, but 18

measures were taken to be sure that any savi ngs 19

attributable to the SEER standard would not double 20

counted in these numbers. 21

MR. BROOKMAN: Got you. Okay. I obviously 22

mis

- heard the term. Okay. Other

– so there’s a lot 23

of content h ere in these two slides. Comme n t s on what 24

you see here. 25Executive Court Reporters (301) 565

- 0064 241 MR. LEKOV: So those are the results on the 1

national energy savings and the net present value. 2

They are listed in the technical support document 3

also. 4

MR. ROSENSTOCK: And Doug, just real quick. 5

This is Steve Rosenstock, EEI. This is 2018 to 2048? 6

MR. LEKOV: Correct. 7

MR. ROSENSTOCK: Thank you. 8

MR. BROOKMAN: Thank you, Steve. Greg. 9

MR. WAGNER: So if I’m reading this right, I 10

look at column three and four, going from an X13 to an 11

ECM, we save less energy? 12

MR. LEKOV: Over the analysis perio d, 13

depending on the product class. So looking at the 14

three and four, X13 versus ECM, product classes are 15

listed on the left side, you compare the values next 16

to each other. 17

MR. WAGNER: This is energy savings in 18

quads? 19

MR. LEKOV: Correct. 20

MR. WAGNE R: I guess I’m

– 21

MR. BROOKMAN: Dave. 22

MR. WINNINGHAM: I think this points to a 23

disconnect back to our summary results page, where 24

earlier we had shown the EL levels and the approximate 25Executive Court Reporters (301) 565

- 0064 242 savings for X13 of 45 percent, and 59 percent for the 1

ECM, where your results page showed for non

2

weatherized, non

- condensing showed a 35 percent 3

savings for X13, and only a 33 percent savings for ECM 4

plus multi

- stage. So, I guess I am very concerned 5

that the EL levels shown as a percentage don’t align 6

with the data t hat has been presented. They have 7

taken them to the extreme edge of a single category. 8

MR. WAGNER: And this is Greg. And the same 9

thing holds for the next column, column four to column 10

five. That’s nowhere near that ten percent level that 11

was talked about earlier for that technology. So how 12

did that go from ten to 30? Or 50 on say, NWGC? 13

MR. LEKOV: For which product class? 14

MR. WAGNER: Non

- weatherized gas condensing, 15

column four to column five. It’s about 50 percent 16

jump. 17

MR. LEKOV: Between the ECM and the ECM with 18

backward impeller? 19

MR. WAGNER: Yeah. I’m guessing, and I 20

don’t know how these were derived, but there’s some 21

kind of glitch in this modeling? These numbers don’t 22

match up with those EL levels that Dave was just 23

talking about. 24

MR. BROOKMAN: Okay. While he’s searching 25Executive Court Reporters (301) 565

- 0064 243 there, Jim Vershaw, you’re next. 1

MR. VERSHAW: Okay. Jim Vershaw, Ingersoll 2

Rand. Based on the conversation on the projected 3

shipments, doesn’t discussion about these numbers 4

become mute ? If those numbers were wrong, doesn’t it 5

change all these numbers? 6

MR. BROOKMAN: Jim, several individuals in 7

the room are nodding their heads in sympathy. So 8

thank you for the comment. 9

MR. VERSHAW: And

-- okay. 10

MR. BROOKMAN: Additional thoughts or 11

comments on the se two very busy tables? Nothing 12

additional? Okay. Yes. Diane. 13

MS. JAKOBS: So this table

– is it saying 14

that

– 15

MR. BROOKMAN: Which one, Diane? 16

MS. JAKOBS: I’m sorry, net present value 17

results. If the interest rates go up to seven percent 18

from current three percent that the savings will be 19

negative? 20

MR. LEKOV: So remember that one

- year change 21

in the interest rate is not going to impact the 22

distributions for the interest rate is over a 20 year 23

period. 24

MR. ECKMAN: This is just the discounti ng of 25Executive Court Reporters (301) 565

- 0064 244 the values, right, according to federal requirements, 1

either three or seven, so you’re just following OEM

– 2

OMB. Get the right. 3

MR. BROOKMAN: Tom, state it again. 4

MR. LEKOV: Talking here about the discount 5

rates? 6

MR. ECKMAN: Yeah. 7

MR. LE KOV: Okay. Yeah, those usually DOE 8

presents two cases at three and seven percent. That’s 9

just the options here. And both of them are used when 10

a selection is made, when the potential standard 11

levels are considered, both of those values are used. 12

MS. JAKOBS: So does negative mean you’re 13

not saving money? 14

MR. LEKOV: Correct. 15

MR. BROOKMAN: And Greg, go ahead. 16

MR. WAGNER: And these are based upon the 17

previous slide, the quads saved and the projected 18

increase in sales combined? 19

MR. LEKOV: It’s not the savings, it’s the 20

economic impact nationally, on all consumers. 21

MR. WAGNER: Okay. We’re going to be going 22

back and revisiting these things, looking at those 23

growth rates, as well as the projected numbers? 24

MR. LEKOV: No, those three and seve n 25Executive Court Reporters (301) 565

- 0064 245 percent

– 1

MR. WAGNER: No, not the discount rates, 2

those are the numbers you use. But the other 3

projection numbers, is this going to be rerun? Taking 4

a look at these anomalies that are going on here? 5

MR. LEKOV: So DOE will utilize all and any 6

inpu ts that

-- we’ll consider all and any inputs that 7

are coming from the interested parties. 8

MR. BROOKMAN: Yes, Paul. 9

MR. LIN: Paul Lin. I just want to clarify 10

slide 105, page 105, you r subsection of ECM market 11

share. That is assuming that there is no , just 12

natural progressing in the market, that there is no 13

mandate to move towards an ECM, correct? 14

MR. LEKOV: That’s the base case, correct. 15

MR. BROOKMAN: Yes, Tom. 16

MR. ECKMAN: Not to add a lot of work, but I 17

think part of the confusion in folks’ mind as we go 18

through this is that we have a rolling up of multiple 19

cases here that is strongly influenced by the location 20

of the equipment, and by the association of that 21

equipment with these product classes. So some are 22

cooling, some are heating and co oling, and some are 23

just primarily heating. And so the benefits are 24

different by candidate standard level based on whether 25Executive Court Reporters (301) 565

- 0064 246 it’s a cooling piece of equipment or a non

- cooling 1

piece of equipment. And so these can look really 2

weird when you see a summary be cause the population 3

behind each one of those is really different. 4

So it may be useful if we see some of the 5

geographic distributions. So we know that this is 6

representing the south and the southwest. This is 7

representing the north and the north

– beca use when 8

you look at these, they don’t make a lot of sense 9

intuitively because you’re getting these weights 10

together, and the population is migrating to the south 11

and the southwest where there’s more cooling, so the 12

benefits for cooling get larger for some technologies 13

than for others. So I’m just

– it’s kind of a mind 14

warp to look at this and make intuitive sense out of 15

it when you know that the impacts are different by 16

candidate standard level because they have either 17

larger cooling benefits than their a djoining 18

companion. 19

MR. LEKOV: In the past, DOE responded to 20

interested parties request for such scenario. 21

MR. ECKMAN: Yeah, I’m not so much 22

interested in scenarios, but seeing some of the 23

derivation of the

– the precursor tables before these 24

that sh ow

– that can tell us that this is a product 25Executive Court Reporters (301) 565

- 0064 2 47 that has really

– its location is in the cooling 1

climates. We had that one table where we had 2

condensing, non

- condensing, but this is just a 3

manifestation of that , where you could look at it side 4

by side, and s ome of these are bigger than the 5

adjoining number

– gets larger because it’s in a 6

cooling climate than the preceding candidate standard 7

level which should be more efficient, but they’re

– 8

I’m not being real clear here but

– 9

MR. LEKOV: No, I understand. 10

MR. ECKMAN: It’s just hard to

– the 11

generalization that the national level makes less 12

sense than it does at the regional level. 13

MR. BROOKMAN: Right. Okay. 14

MR. LEKOV: But on the other hand also, just 15

remember that there is no original standard fo r 16

furnace fan products. So the results need to be 17

presented also as a whole. What you’re asking is for 18

more information

– 19

MR. ECKMAN: Just in order to interpret 20

them, seeing the sub

- national level gives

– it’s 21

easier to grasp what I’m looking at beca use I know 22

there’s a difference in technology here. 23

MR. BROOKMAN: Let’s move on. 24

MR. LEKOV: So, this is an additional point, 25Executive Court Reporters (301) 565

- 0064 248 relating to some analysis that DOE performed. In 1

2011, DOE published a notice of policy stating 2

intention to incorporate ful l fuel cycle metric into 3

the cost benefits analysis. In essence , an additional 4

multiplier or conversion factor is applied to the 5

energy savings associated with either primary fuels 6

used by the product and for these particular products, 7

this methodology wa s applied, and results similar to 8

these previous two tables that you saw, but including 9

the full fuel cycle of impacts are presented in the 10

technical support document. 11

MR. ROSENSTOCK: Comment? 12

MR. BROOKMAN: Please, Steve. 13

MR. ROSENSTOCK: Steve Ros enstock, Edison 14

Electric Institute. We will make written comments, 15

but we’re very

– we think that there are significant 16

problems with doing the full fuel cycle analysis. The 17

numbers shown in the technical support document refer 18

to a paper that was publis hed elsewhere, so there was 19

the methodology and the results, but there is no 20

information about the actual derivation of the values 21

shown in the table. And I think there are special 22

issues when you’re looking at the full fuel cycle, you 23

really have to go i nternational for any, especially 24

for fuel oil, and I believe that there is just quite a 25Executive Court Reporters (301) 565

- 0064 249 huge variation in terms if you’re looking upstream in 1

terms of the energy use with energy production, 2

especially for fuel oil, that could be understated. 3

And on the el ectric side, it’s overstated. So I think 4

there are issues with using it. We objected before. 5

We maintain our objections and we will write and file 6

written comments. Thank you. 7

MR. BROOKMAN: Okay. Thank you. We’re 8

going to move on. 9

MR. LEKOV: So comments on the full fuel 10

cycle and DOE invites comments and recommendations on 11

any aspect of national impact analysis. Go ahead, 12

Sam. 13

MR. BROOKMAN: So now back to Sam Jasinski. 14

**Manufacturer Impact Analysis** 15

MR. JASINSKI: Thank you Alex, thank you 16

Doug. I will give a brief overview of the preliminary 17

manufacturer impact analysis. As I mentioned earlier, 18

the bulk of the manufacturer impact analysis is 19

actually conducted during the Notice of Proposed 20

Rulemaking. But during the preliminary analysis 21

activities, DOE makes an effort to set the stage for 22

the analysis in the NOPR by basically starting to put 23

together an industry overview and also identify key 24

issues. Here’s the “ you are here ” slide, to show you 25Executive Court Reporters (301) 565

- 0064 250 where it fall s within the grand scope of th e 1

rulemaking. 2

During the preliminary manufacturer impact 3

analysis, DOE identified 11 small business 4

manufacturers associated with these products. As I 5

mentioned earlier, if there are others that aren’t 6

identified in the

– in Chapter 3 of the TSD, plea se 7

let DOE know. Also as part of the preliminary 8

manufacturer impact analysis, DOE conducted onsite and 9

telephone interviews, not on the scale that it will 10

during the Notice of Proposed Rulemaking, but again, 11

as part of the preliminary activities. We did have 12

the pleasure of receiving some feedback from 13

manufacturers during preliminary interviews. 14

The interview topics included the 15

engineering analysis, overview, methodology, and 16

results. Key issues as identified and defined by the 17

manufacturer, curre nt market conditions, such as 18

shipment, market share, product mix, et cetera. 19

Potential impacts of new energy conservation 20

standards, especially with a focus on potential 21

conversion costs, and then finally, a discussion about 22

cumulative regulatory burdens . As we’ve heard, there 23

are a lot of state, federal, and international 24

standards, as well as some voluntary programs that

– 25Executive Court Reporters (301) 565

- 0064 251 regarding the efficiency of furnace fan products. 1

Some of the key issues that were identified 2

during these interactions with manu facturers

- 3

preliminary interactions with manufacturers: 4

**•** higher up

- front costs for consumers. 5

Manufacturers are concerned that higher initial 6

cost can lead to consumer switching to less 7

efficient products, essentially by making a 8

component more expensiv e, in higher efficiency 9

products, the overall

– consumers will switch to 10

systems that are overall less efficient, to reach 11

lower price points, or the same price point that 12

they would have prior to standards. 13

**•** Secondly, higher initial cost may also push 14

cons umers to repair, as we’ve heard, rather than 15

replace units. 16

**•** Another key issue are conversion costs. 17

Stringent standards may require significant 18

capital conversion costs to implement the 19

technologies that we’ve identified, to reach the 20

higher efficiency le vels. 21

**•** And finally, reduction in innovation. 22

Manufacturers are concerned that a new furnace 23

fan standard would take resources away from 24Executive Court Reporters (301) 565

- 0064 252 development of new products and in addition, 1

higher standards for furnace fans place new 2

constraints on manufacturers an d may limit their 3

options for maximizing maximum system efficiency, 4

essentially resources are finite for 5

manufactures, and the more targets you give them, 6

the more it takes away

– it adds constraints they 7

have to focus those resources on meeting those 8

spec ific standards as opposed to focusing on 9

innovation on overall systems. 10

MR. BROOKMAN: Many of you are familiar with 11

manufacturer impact analysis or preliminary 12

manufacturer impact analysis. Comments on those 13

before we move on. Yes, Paul. 14

MR. LIN: Pa ul Lin with Regal Beloit. Just 15

to maybe touch on some earlier comments from Diane 16

relative to cost of AC of the X 13 motor being two 17

times of what you guys are showing here in the 18

preliminary analysis. I wish we were

– maybe we need 19

to adjust our pricing to Rheem when we go back, but I 20

think maybe the bigger issue is maybe some comments 21

could be given from Navigant and DOE on this report in 22

terms of the product mix. Because I think the product 23

mix has a large deal in coming up with an average X13 24

cost. A higher horsepower will have a lot higher cost 25Executive Court Reporters (301) 565

- 0064 253

versus

– so we have a third, a half, three

- quarter, 1

and one horsepower. So if you look at a model by 2

model basis from a third horsepower to a one 3

horsepower, there is significant cost delta between 4

that. So, depending on your mix analysis on getting 5

together an average product cost, that’s the 6

assumption. What is the assumption on your horsepower 7

range to come up with your average cost ? I think 8

that’s maybe some of the discrepancy that the OEMs may 9

see rela tive to the costs that you have in your 10

analysis. 11

MR. BROOKMAN: Mohammed. 12

MR. KHAN: This is Mohammed Khan, DOE. We 13

try to make our samples as statistically 14

representative as possible. And I’m not really sure 15

how many samples were really used, but m aybe Sam could 16

comment on that. 17

MR. JASINSKI: Yes, so for this particular 18

rulemaking activity, as I said earlier, we had 26 19

units selected for test and tear down. But because 20

there are a lot of similarities with previously 21

regulated and products that a re being currently 22

regulated where similar analyses have been done, we do 23

have data beyond those 26 units, and I’ll call them 24

cost factors that you mention, are something that we 25Executive Court Reporters (301) 565

- 0064 254 tried to account for in the analysis. So when we do 1

the tear downs and selec t products across what’s 2

commercially available, capacity and horsepower, 3

things of that nature are taken into consideration so 4

that we can try to understand how the cost of, for 5

instance, a motor, would scale with horsepower. 6

MR. BROOKMAN: Is that mix listed in the 7

TSD? 8

MR. JASINSKI: No, we try to prevent

– keep 9

details about the selections protected so that it’s 10

hard to disaggregate the results. 11

MR. BROOKMAN: Diane. 12

MS. JAKOBS: This kind of goes back to the 13

test procedure, but in the NOPR for the test 14

procedure, you came up with four hours for an average 15

testing time to calculate FER. And in my personal 16

experience now running it, that’s correct. Only you 17

went on to say that wasn’t a burden, and that would be 18

horrible for us. So, I don’t know , we might

– it’s a 19

huge impact to double the amount of testing we have to 20

do. And you’ve seen our air flow test stands, and

– 21

but just in the analysis you went through something 22

and said it was two and a half percent of the sales 23

price or something, but for a manufacturer impact, 24

just the amount of test time that’s required, is a big 25Executive Court Reporters (301) 565

- 0064 255 deal for us, and that’s kind of reflected in our 1

participation. 2

MR. BROOKMAN: So send those details in. 3

Yes? 4

MR. JASINSKI: Yes, absolutely. Information 5

that would hel p DOE quantify the burden in terms of 6

hours to test or the equipment necessary

– 7

MS. JAKOBS: So that would be like an 8

increase in R&D test time. I have trouble quantifying 9

that. 10

MR. JASINSKI: Well, just number of hours, 11

things like that, help. 12

MS . JAKOBS: Well, I can say I agree with 13

you on the hours, just does it give me heart 14

palpitations or not. But it’s also

– we have to

– we 15

verify our ratings every year, so it’s not just when 16

you design the equipment and release it, it’s ongoing 17

cost that will go on forever, so it’s a big deal for 18

us at four hours. 19

MR. BROOKMAN: Okay. We’ve also heard from 20

Terry Small. Terry, you’re next, and then Steve 21

Rosenstock. 22

MR. SMALL: Terry Small, Mortex. I know on 23

one of the pages there’s a discussion on t he PSC 24

market and eliminating it. I think that the forecast 25Executive Court Reporters (301) 565

- 0064 256 is pretty optimistic, the paybacks are optimistic, and 1

the payback on going to the PSC motor, the improved 2

motor with an additional speed or two for continuous 3

air flow to really get what Charlie wants, means to me 4

that I think we ought to be careful not to eliminate 5

PSC motors in general. I think that would be a great 6

mistake for the country. It’s my opinion. Thank you. 7

MR. BROOKMAN: Thank you. Okay. Steve. 8

MR. ROSENSTOCK: Steve Rose nstock, EEI. 9

Again, in terms of the up front cost for consumers, 10

just to kind of follow up with what Alex said, if 11

there’s a space, it might not be a bad idea to kind of 12

describe what happens, especially in the northern 13

region of the US, combination of th e higher furnace 14

system standard A FUE in the north, plus the highest 15

furnace fan standard. Because for new furnaces, the 16

consumer’s going to face the cost increase due to 17

both. And the higher the percentage, the higher the 18

likelihood of possible people t rying to repair rather 19

than replace. Thank you. 20

MR. BROOKMAN: Thank you. Okay. Additional 21

comments on this? 22

MR. JASINSKI: So the presentation as it’s 23

posted in the packet includes some slides that 24

describe the next steps. Each is generally just an 25Executive Court Reporters (301) 565

- 0064 257 overview. 1

MR. BROOKMAN: Paul. 2

MR. LIN: Paul Lin. Is there a target date 3

that you’re targeting to release the NOPR? 4

MR. JASINSKI: The NOPR? It’s hard to say. 5

The statutory deadline is 2013, so it’s going to be 6

between now and then, I think. 7

MR. LIN: That’s a forecast we can believe. 8

MR. JASINSKI: Yeah. 9

MR. BROOKMAN: Yes, Aniru dd h. 10

MR. ROY: I have a comment with regards to 11

what was said earlier on the components and system 12

level efficiencies. Is DOE planning to do any kind of 13

st udy on furnaces, for example, let’s say there’s a 14

high efficiency AFUE furnace that may not be as 15

efficient on the furnace fan side versus something 16

that’s very efficient on the furnace fan side but 17

maybe not as high in AFUE, and combining that with the 18

fu ll fuel cycle analysis that you are referring to, is 19

there any plans to do that kind of study in the 20

future? 21

MR. JASINSKI: Well, a specific study, I 22

don’t know about a targeted study, but hopefully as 23

we’ve shown throughout the analysis, it is something 24

that DOE is concerned with. So any information that 25Executive Court Reporters (301) 565

- 0064 258 we can get through comments, and obviously through our 1

own efforts, we will constantly keep that in 2

consideration to make sure that if at all possible, 3

what we are doing does not negatively impact overa ll 4

system efficiency. 5

MR. ROY: Okay. But currently there’s no 6

data available to show that, right, that comparison? 7

MR. JASINSKI: I’m not going to say that 8

there’s no data, but we need more

– 9

MR. ROY: I mean in the TSD. 10

MR. JASINSKI: Oh, in th e TSD, there is no 11

data presented in the TSD along those lines. 12

MR. ROY: Thank you. 13

MR. BROOKMAN: So we’ve covered all the 14

material that we came here to cover, and I want to 15

thank everyone and also at this point, provide an 16

opportunity for any final comments from anybody in the 17

room, things that didn’t get covered adequately , final 18

remarks. Yes, Craig. 19

**Closing Remarks** 20

MR. MESSMER: Craig Messmer, I don’t really 21

have any remarks other than thank you. And, you know, 22

if we ever have a question on cla rification on what 23

we’ve read here, is it possible for us to contact 24

someone and have some sort of discussion, sidebar or 25Executive Court Reporters (301) 565

- 0064 259 something, because, you know, we covered a lot of 1

topics here and I don’t think we covered them 2

adequately and had enough of an exchan ge between the 3

manufacturers and the DOE in this case. So is there 4

another method of talking to you about it ? 5

MR. BROOKMAN: Michael Kido. 6

MR. KIDO: There’s a

– you can have an ex 7

parte communication with the Agency. There’s actually 8

a process that you can follow in doing that, and if 9

you give me your e

- mail, I can just e

- mail to you, 10

there’s a Federal Register notice that outlines the 11

process, and it’s a very short notice. So basically 12

what that would entail is, you know, there’s a meeting 13

between , say , company X and DOE, and then there’s a 14

certain amount of time that has to

– well, within a 15

certain amount of time you have to submit a memo to 16

very specific e

- mail address that handles all the ex 17

parte communications between the Agency and outside 18

par ties. And that memo essentially just briefly 19

summarizes the nature of the discussion. And that’s 20

just to insure that there’s transparency in the whole 21

process. Everyone knows who DOE has met with and what 22

was discussed. So if you want, I can send you t hat, 23

and if anyone else wants that, just give me your e

24

mail address and I’ll e

- mail it out to you. 25Executive Court Reporters (301) 565

- 0064 260 MR. KHAN: Mohammed Khan, DOE. I think your 1

question was whether or not you could hear directly 2

from DOE as follow on about maybe any further 3

interpretat ion about any of the technical information 4

that was provided, you can certainly do

– go thro ugh 5

the process that Michael Kid o has talked about 6

already. You can certainly contact me directly, and 7

depending on the questions, it may be something I may 8

not be able to respond to from the DOE perspective, 9

process wise, but it might also be something that we 10

can have a discussion on. So it really depends on 11

what the nature is. 12

MR. MESSMER: Okay. Good. That’s what I 13

wanted to hear. Thank you. 14

MR. BROOKM AN: Yes, Paul and then Aniruddh, 15

and then I will also hand out these evaluation forms. 16

You can pass them down. Paul. 17

MR. LIN: Could we ask an advocate directly, 18

questions, or is it

– or do we have to follow the 19

process for whether it would be Navigan t versus DOE? 20

MR. BROOKMAN: Michael. 21

MR. KIDO: If it’s purely a technical 22

question, you just say, for example, you’ve got a 23

question about the formula or the basis for the 24

analysis that we’ve got in the TSD, something like 25Executive Court Reporters (301) 565

- 0064 261 that, you can contact Navi gant directly. If it’s an 1

issue regarding policy like for example, you know, 2

you guys really should do this versus that, then 3

you’re probably going to want to have a discussion 4

with us, and then that will have to be a discussion 5

that’ll be subject to the ex parte requirements. 6

MR. BROOKMAN: Other remarks here as we 7

close? Diane. 8

MS. JAKOBS: I’ve got a lot to say and I 9

really enjoyed this discussion today. It’s fun to talk 10

to a lot of smart people about an important subject 11

and I’m really encour aged. But I’m also chairman of 12

the AHRI ad hoc furnace fan committee, and there’s so 13

many things that we’re supposed to submit comments on, 14

is there any

– I don’t know if someone could give me a 15

hint maybe about a priority things where

– you know, 16

it seem ed like you said that the X13 curve on the 17

graph was based on one furnace, maybe you need more 18

furnaces. And then we were talking about the drop in 19

sales in ECM motors. Aniruddh said that we could look 20

at sales, that that’s information that maybe AHRI 21

co llects. So if there’s some particular question you 22

want to make sure that we don’t miss as our time runs 23

out, you know, please let me know somehow. Thank you. 24

MR. BROOKMAN: Thank you. Aniruddh. 25Executive Court Reporters (301) 565

- 0064 262 MR. ROY: As Diane mentioned, again Aniruddh 1

Roy. U nder AHRI, as Diane mentioned we have an ad hoc 2

committee that has developed some modifications to the 3

existing or the proposed FER metric, and we will be 4

submitting that in our comments on July 30 th . However, 5

it’s just a series of steps that’s proposing the 6

modifications, it’s not the actual test procedure with 7

edits in it. We are going to be starting to work on 8

that as well as we will be providing data sometime in 9

August to DOE to support our arguments. And we feel 10

that the modified FER metric is

– it’s significantly 11

less burdensome in form of testing, as well as 12

reporting to the manufacturers. But not only that, it 13

also meets DOE’s goals from the preliminary analysis 14

that’s occurred, it looks like the FER and the 15

modified FER values are almost the same . And so I 16

think that’s something that DOE and other stakeholders 17

will be happy with. So please look out for those 18

comments, and we can discuss it after DOE has reviewed 19

it. 20

MR. BROOKMAN: Additional remarks? Tom

. 21

MR. ECKMAN: Again, I want to thank DOE and 22

the contractors for spelling things out. I have one 23

comment on the utility impact analysis which we went 24

by briefly. I understand its purpose. I would ask 25Executive Court Reporters (301) 565

- 0064 263 that DOE in the outputs also specify what the present 1

value cost reductions might be from the reduction in 2

capacity required to meet the standards. Right now as 3

change in energy sales and prices, the mix of 4

generation, and the difference in capacity, there’s a 5

dollar value associated with the difference in 6

capacity, and I think that should be incorporated in 7

the analysis. 8

MR. BROOKMAN: Thank you

. Steve Rosenstock

. 9

MR. ROSENSTOCK: Steve Rosenstock, EEI. 10

Following up on that, since certain standards will 11

increase the amount of furnace energy use, the fossil 12

fuel use, then in terms of ene rgy production, then if 13

there’s any increases on the production needed for 14

fossil fuels, that that should be accounted for as 15

well. Thank you.

. 16

MR. BROOKMAN: Thank you. Other remarks 17

here as we move towards closure? So then, for my 18

part, I thank you. W e had a very produ ctive meeting. 19

We covered a tremendous amount of material. You all 20

were very forthcoming with a lot of very, very good 21

information. I appreciate your good humor and your 22

tenacity. I really do. I turn it back to Mohammed 23

Khan f or closing remarks. 24

**Closing Remarks from DOE** 25Executive Court Reporters (301) 565

- 0064 264 MR. KHAN: Mohammed Khan, DOE. Very briefly 1

because we went over our scheduled time, and I 2

apologize for that. But this morning I said I looked 3

forward to a very good discussion exchange, and I 4

think my expe ctations were exceeded. So I appreciate 5

everyone’s participation and we look forward to 6

getting your written comments as well. Thank you. 7

MR. BROOKMAN: Safe travels home

. 8

(Whereupon, at 4:30 p.m., the meet ing in the 9

above captioned matter was adjo urned .) 10

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25Executive Court Reporters (301) 565

- 0064 265 **REPORTER'S CERTIFICATE**

This is to certify that the attached proceedings

before:

**U.S. DEPARTMENT OF ENERGY**

In the Matter of:

**PRELIMINARY ANALYSIS PUBLIC**  **MEETING ON** 

**RESIDENTIAL FURNACE FANS ENERGY CONSERVATION STAN DARDS** 

Were held as herein appears and that this is the

original transcript thereof for the file of the

Department, Commission, Board, Administrative Law Judge

or the Agency.

Further, I am neither counsel for or related to any

party to the above proceedi ngs.



### Wendy Greene Official Reporter

Dated: August 1, 2012