Appliance Process Improvement Meeting

January 17 and 18, 1996

PNL Conference Room - The Aerospace Center

901 D Street, S.W., 9th Floor

Washington, D.C.

Sponsored by the Department of Energy , Office of Energy Efficiency and

Renewable Energy, Washington, D.C.

Wednesday, January 17th

12:00 PM to 12:45 PM Lunch

12:45 PM to 1:00 PM

1:00 PM to 1:45 PM

1:45 PM to 3:00 PM

3:00 PM to 3:20 PM

3:20 PM to 4:40 PM

4:40 PM to 5:00 PM

9:00 AM to 9:15 AM

9:15 AM to 10:30 AM

10:30 AM to 10:45 AM

10:45 AM to 12:15 PM

12:15 PM to 1:00 PM

1:00 PM to 2:30 PM

Introductions, Overview

- Doug Brookman

Impact/Analysis Overview: Is there a better way to measure

the impacts on stakeholder groups than what we do presently?

Engineering Analysis/The Impact of Standards on Consumers

- Statutory Issues

- Process Improvement

Break

The Impact of Standards on Consumers

- Analysis Improvement

Preview Day 2, Next Steps

- All

Thursday, January 18th

Introductions, Overview

- Doug Brookman

- Agenda Review

The Impact of Standards on Manufacturers

- Statutory Issues

- Process Improvement

Break

The Impact of Standards on Manufacturers

- Analysis Improvement

Lunch

The Impact of Standards on National Energy

- Statutory Issues

- Process Improvement

- Analysis Improvement

2:30 PM to 2:45 PM Break

2:45 PM to 3:45 PM The Impact of Standards on Utilities and National Emissions

- Statutory Issues

- Process Improvement

- Analysis Improvement

3:45 PM to 4 :00 PM Next Steps

- All

 EE-PI-96-001 COMMENT 05

/, 

Appliance Process Improvement Meeting 

January 17 and 18, 1996 

PNL Conference Room - The Aerospace Center 

901- D Street, S.W., 9th Floor 

Washington, D.C. 

Sponsored by the Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Washington, D.C. 

12:00 PM to 12:45 PM 

12:45 PM to 1:00 PM 

1:00 PM to 1:45 'PM 

I :45 PM to 3:00 PM 

3:00 PM to 3:20 PM 

3:20 PM to 4:40 PM 

4:40 PM to 5:00 PM 

9:00 AM to 9:15 AM 

9: 15 AM to 10:30 AM 

10:30 AM to 10:45 AM 

10:45 AM to 12:15 PM 

12:15 PM to 1:00 PM 

1:00 PM to 2:30 PM 

2:30 PM to 2:45 PM 

2:45 PM to 3:45 PM 

3:45 PM to 4:00 PM 

Wednesday, January 17th 

Lunch 

Introductions, Overview 

- Doug Brookman 

Impact! Analysis Overview: Is there a better way to measure 

the impacts on stakeholder groups than what we do presently? 

Engineering AnalysislThe Impact of Standards on Consumers 

- Statutory Issues 

- Process Improvement 

Break 

The Impact of Standards on Consumers 

- Analysis Improvement 

Preview Day 2, Next Steps 

-All 

Thursday, January 18th 

Introductions, Overview 

- Doug Brookman 

- Agenda Review 

The Impact of Standards on Manufacturers 

- Statutory Issues 

- Process' Improvement 

Break 

The Impact of Standards on Manufacturers 

- Analysis Improvement 

Lunch 

The Impact of Standards on National Energy 

- Statutory Issues 

- Process Improvement 

- Analysis Improvement 

Break 

The Impact of Standards on Utilities and National Emissions 

- Statutory Issues 

- Process Improvement 

- Analysis Improvement 

Next Steps 

- All 
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Input/Analysis Stakeholder Meeting, January 17-18, 1996

Issue Matrix for Agenda Development -

IMPACT

AREA

Product

Consumers

Manufacturers

Statutory Issues Process Improvement Analysis Improvement

Stakeholder Data Contractor Mdl o e s/ Ass tion ump I Ke Issues Involvement Issues Issues Methods /Issues

y

Technologically * Pre-ANPR * Appropriate * Industry Engineering * Baseline unit * Diminishing

feasible meeting sources experience Analysis * Typical returns

- Need for rule * Role of * Selection * Cost usage * Manufacturing

* Economically (progress private sector DOE support efficiency profiles practidality

justified review) standards options * Product * Product utility

- Product associations * Peer review models * Uncertainty

* Max tech classes (ASHRAE, * Parcel work

- Technical etc.)

options

* Life-cycle costs - Test * Life-cycle * Product diversity

procedures costs * Regional

* Safe harbor - Preferred * Payback impacts

approach * Cost of * Equity for

(formal, conserved consumer types

negotiated)

d

energy * Discount

- Data require rates/paybacks

* Uncertainty

* Lessening of * Workshops * Public data * Average * Foregone

competition * Consultations * Confidentiality manufacturer investment

* Review drafts * Anti-trust * Cost pass- * Stranded assets MAM/GRIM through * Competition

impacts * Validity Jobs impacts * Clarity * Cumulative * Stakeholder burden acceptance * Short-run

impact

S H G M I A 1/ 1 5/96 Reference No. 47603-00

 EE-PI-96-001 COMMENT 05

Input/Analysis Stakeholder Meeting, Jan~ary 17-18, 1996 

- Issue Matrix for Agenda Development -

Statutory Iss Process Improvement Analysis Improvement 

IMPACT Stakeholder Data Contractor Models! Assu~Jtion AREA Involvement Issues Issues Methods !Issues 

Product * Technologically * Pre-ANPR . * Appropriate * Industry Engineering * Baseline unit * Diminishing 

feasible meeting sources experience Anal~sis * Typical returns 

- Need for rule * Role of * Selection * Cost usage * Manufacturing 

* Economically (progress private sector * DOE support efficiency profiles practicality 

justified review) standards options * Product * Product utility 

- Product associations * Peer review models *. Uncertainty 

* Max tech classes (ASHRAE, * Parcel work 

- Technical etc.) 

options 

Consumers * Life-cycle costs - Test * Life-cycle * Product diversity 

* Safe ha~bor 

procedures costs * Regional 

- Preferred * Payback impacts 

approach * Cost of * Equity for 

(formal, conserved consumer types 

negotiated) energy * Discount 

- Data require rates/paybacks 

* Uncertainty 

* Lessening of * Workshops * Public data * Average * Foregone 

competition * Consultations * Confidentiali.ty manufacturer investment 

* Review drafts * Anti-trust * Cost pass- * Stranded assets 

Manu- MAM/GRIM through * Competition facturers impacts * Validity .. Jobs impacts * Clarity * Cumulative * Stakeho burden acceptance * Short-run 

impact 

SHGMIA 1/15/96 Reference No. 47603·00 1 
Input/Analysis Stakeholder Meeting, January 17 -18, 1996

- Issue Matrix for Agenda Development -

Statutory Issues Process Improvement Analysis Improvement

IMPACT Data Key

Assumptions Keylssues AREA Issues Issues /issues

National * Need for REM * Price * Regional equity

Energy conservation elasticity impacts

* Significant Energy * Consumer * Market solutions

savings discount rate

* Average

energy rates

* Baseline

energy

consumption

* Energy price

forecasts

Utilities ASEUM * Avoided * Impact on

costs electric and

* Capacity gas utilities

savings

Lost revenues

National ASEUM * Average * Regional impacts

Emissions generation * Monetizing

Emissions * Effects of externalities

existing laws/

regulations

S H G M I A 1/15/96 Reference No. 47603-00

 EE-PI-96-001 COMMENT 05

Input/Analysis Stakeholder Meeting, January 17-18, 1996 

- Issue Matrix for Agenda Development -

Statutory Issues Process Improvement . Analysis Improvement 

IMPACT Stakeholder Data Contractor I Models! 

AREA Involvement Issues Issues Methods 

National * Need for REM * Price * Regional equity 

Energy conservation elasticity impacts 

* Significant Energy * Consumer * Market solutions 

savings discount rate 

* Average 

energy rates 

* Baseline 

energy 

consumption 

* Energy price 

forecasts 

Utilities ASEUM * Avoided * Impact on 

cqsts electric and 

* Capacity gas utilities 

savings 

* Lost revenues 

National ASEUM * Average * Regional impacts 

Emissions generation * Monetizing 

Emissions * Effects of externalities 

existing laws/ 

regulations 

SHGMIA 1/15/96 Reference No. 47603-00 2 
APPLIANCE PROCESS IMPROVEMENTS MEETING

January 17-18

PNL, Washington

PURPOSE: Explore a range of diverse views on DOE's rulemaking process.

1/17-1/18 GOAL: Uncover/extract potential process improvements with a-focus on

input/analysis issues.

Not get lost in detail.

GROUND RULES: Not focus on past.

Inform future action.

Not trip FACA.

Have an open process review.

OUTPUT THIS MEETING

-- Greater understanding, but not resolve the issues.

-- Process improvement is the focus, not resolving each substantive issue.

 EE-PI-96-001 COMMENT 05

· APPLIANCE PROCESS IMPROVEMENTS MEETING 

January 17-18 

PNL, Washington 

PURPOSE: Explore a range of diverse views on DOE's rulemaking process. 

1/17-1118 GOAL: Uncover/extract potential process improvements with a'focus on 

input/analysis issues. . 

Not get lost in detail. 

- GROUND RULES: Not focus on past. 

Inform future action. 

Not trip F ACA. 

Have an open process review. 

OUTPUT THIS MEETING 

-- Greater understanding, but not resolve the issues. 

-- Process improvement is the focus, not resolving each substantive issue. 
SIMPLE PROBLEM DEFINITION

1. DOE IS REQUIRED TO MAKE JUDGMENTS

2. ASK FOR PROPRIETARY DATA 3. POOR DATA/NO DATA

4. DOE USES MODELS/ASSUMPTIONS, 5. STAKEHOLDERS DISAGREE

ETC. AND ARRIVE AT DATA WITH JUDGMENTS

6. EXCHANGE OF VIEWS ENSUES

IS THERE A BETTER WAY TO ANSWER THESE QUESTIONS?

How to get the input and do the analysis to obtain good results

There is a significant variation among products especially regarding Data Spread,

depending on the number of manufacturers, product market penetration, etc.

There may be a way to get enough data that would not be public that would serve the data

needs, especially in areas such as Technology Forcing Standards

There are 2 types of data - Don't mix them

-- Energy consumption data

-- Manufacturer cost data

Data disclosure is not the problem

PROBLEM: Frequently there are only one or two companies that can submit

data

DOE has tried to quantify all the data, then these estimates standing alone are given

credence. The estimates end up not portraying the uncertainty that exists

 EE-PI-96-001 COMMENT 05

SIMPLE PROBLEM DEFINITION 

1. DOE IS REQUIRED TO MAKE ruDGMENTS 

2. ASK FOR PROPRIETARY DATA 

4. DOE USES MODELS/ASSUMPTIONS, 

ETC. AND ARRIVE AT DATA 

6. EXCHANGE OF VIEWS ENSUES 

3. POORDATAINODATA 

5. STAKEHOLDERS DISAGREE 

WITH ruDGMENTS 

IS THERE A BETTER WAY TO ANSWER THESE QUESTIONS? 

How to get the input and do the analysis to obtain good results 

There is a significant variation among products especially regarding Data Spread, 

depending on the number of manufacturers, product market penetration, etc. 

There may be a way to get enough data that would not be public that would serve the data 

needs, especially in areas such as Technology Forcing Standards 

There are 2 types of data - Don't mix them 

-- Energy consumption data 

-- Manufacturer cost data 

Data disclosure is not the problem 

PROBLEM: Frequently there are only.one or two companies that can submit 

data 

DOE has tried to quantify all the data, then these estimates standing alone are given 

credence. The estimates end up not portraying the uncertainty that exists 
HOW TO IMPROVE

One key issue is how to approach/deal with commercial technology and determine

minimum vs. pushing, forcing at the leading edge

Decision criteria next meeting

Cost & Efficiency are the key drivers (Consumer Economy)

-- Manufacturer impacts Harder to get data

-- Lifecycle costs Getting initial data is not that difficult

-- ROE Gettinginitial data is not that difficult

Manufacturers need a higher technology standard product available that can be purchased

at premium

Impact of design options do not land equally (i.e. Numbers are averaged and effect on

manufacturers is unequal)

Maybe use some subjective analysis (RE: Manufacturer impact that could achieve

manufacturer buy-off impacts)

Industry would have lots more interest in developing a new standard if it were the last

standard

A consensus process would be preferable to results based. on Garbage In-Garbage Out

 EE-PI-96-001 COMMENT 05

HOW TO IMPROVE 

One key issue is how to approach/deal with commercial technology and determine 

minimum vs. pushing, forcing at the leading edge 

Decision criteria next meeting 

Cost & Efficiency are the key drivers (Consumer Economy) 

-- Manufacturer impacts Harder to get data 

-- Lifecycle costs Getting initial data is not that difficult 

-- ROE Getting initial data is not that difficult 

Manufacturers need a higher technology standard product available that can be purchased 

at premium 

Impact of design options do not land equally (i.e. Numbers are averaged and effect on . 

manufactur.ers is unequal) 

Maybe use some subjective analysis (RE: Manufacturer impact that could achieve 

manufacturer buy-off impacts) 

Industry would have lots more interest in developing anew standard if it were the last 

standard 

A consensus process would be preferable to results based on Garbage In-Garbage Out 
WAYS TO IMPROVE ENGINEERING ANALYSIS

Additions to matrix: Consumers Test Payback Analysis

Product installation and infrastructure should also be added to the list

Setting efficiency standards on components, not systems, causes redundancy

Create a standards end point-a level that once reached, there would be no new

standards would be required

-- Significant energy savings should be defined

-- End point Priorities discussion needed

New standards on horizon cause manufacturers to hold back. on taking new technology to

market because they know a new rulemaking is ahead

Maybe have a much longer period between reconsidering new standards

Concurrent rulemakings can be problematic in terms of inputs being used. Maybe try to

negotiate some of these issues collectively (e.g. discount rates) which then would

provide a common basis

Because these issues are quantitative driven, certain elements like discount rates are too

important (i.e. Use qualitative analysis more)

Product groupings in classes needs more discussion (e.g. Different fuel, different class)

01

 EE-PI-96-001 COMMENT 05

WAYS TO IMPROVE ENGINEERING ANALYSIS 

Additions to matrix: Consumers Test = Payback Analysis 

Product installation and infrastructure should also be added to the list 

Setting efficiency standards on components, not systems, causes redundancy 

Create a standards end point-a level that once reached, there would be no new 

standards would be required 

-- Significant energy savings should be defined 

-- End point Priorities discussion needed 

New standards on horizon cause manufacturers to hold back on taking new technology to 

market because they know a new rulemaking is ahead 

Maybe have a much longer period between reconsidering new standards 

Concurrent rulemakings can be problematic in terms of inputs being used. Maybe try to 

negotiate some of these issues collectively (e.g. discount rates) which then would 

provide a common basis 

Because these issues are quantitative driven, certain elements like discount rates are too 

important (i.e. Use qualitative analysis more) 

Product groupings in classes needs more discussion (e. g. Different fuel, different class) 

, 
WAYS TO IMPROVE PRODUCT ANALYSIS

Contractors:

DOE contractors are not familiar enough with industry for them to make good

judgments

-- Solutions - early and often stakeholder involvement

- share and VETT documents

If no good data - suspend/stop the process until you get the data you need, otherwise,

models simply create lousy guesses

An RFP should go out that describes/addresses analysis needed.

-- Not always the same contractor should be used

-- "Manufacturer Practicality" needs better definition

RE: Product utility - formerly focused on product class

-- Goal = No standard adversely affect any significant product utility

-- Issues of safety and reliability should be included

-- "Changes to the consumer should be invisible"

RE: Uncertainty - it gets lost in quantitative analysis

-- The uncertainty is not described or quantified throughout nor is confidence level

considered

-- Two dimensions need to be considered: 1. Can manufacturers do it?

2. Can manufacturers sell it?

PRODUCT - CONTRACTORS ISSUES

-- How do we get the right individuals involved in evaluating/informing a potential

contractor selected by a RFP?

PROBLEMS:

Rigid conflicts of interest standards are a problem

Nature of contract (Fixed price, Deliverable) can be a problem

First document we see is Technical Support Document - From the manufacturer's

perspective, the first page is all that matters

 EE-PI-96-001 COMMENT 05

WAYS TO IMPROVE PRODUCT ANALYSIS 

Contractors: 

DOE contractors are not familiar enough with industry for them to make good 

judgments 

Solutions - early and often stakeholder involvement 

- share and VETT documents 

If no good data - suspend/stop the process until you get the data you need, otherwise, 

models simply create lousy guesses 

An RFP should go out that describes/addresses analysis needed. 

- Not always the same contractor should be used 

-- "Manufacturer Practicality" needs better definition· 

RE: Product utility. - formerly focused on product class 

-- Goal = No standard adversely affect any significant product utility 

- Issues of safety and reliability should be included 

-- "Changes to the consumer should be invisible" 

RE: Uncertainty - it gets lost in quantitative analysis 

-- The uncertainty is not described or quantified throughout nor is confidence level 

considered 

- Two dimensions need to be considered: 1. Can manufacturers do it? 

2. Can manufacturers sell it? 

PRODUCT - CONTRACTORS ISSUES 

How do we get the right individuals involved in evaluating/informing a potential 

contractor selected by a RFP? 

PROBLEMS: 

Rigid conflicts of interest standards are a problem 

Nature of contract (Fixed price, Deliverable) can be a problem 

First document we see is Technical Support Document - From the manufacturer's 

perspective, the first page is all that matters 
SOLUTIONS:

Early peer review

Early review by experts to analyze/evaluate inputs before modeling

"Excluding contractors'based on conflicts of interest can cause all involved to not know

anything about the issues"

Three meetings - The assumptions - What - Brainstorm

WAYS TO IMPROVE CONSUMERS ANALYSIS

Regional impacts should be considered - these are minimum standards

-- Consumer can buy higher efficiency products

-- States can set Building Code Standards

Alternative is to provide enough information for consumers to make informed

choices

-- This issue is minimized if not setting maximum standards - DOE should

consistently set more modest standards

Equity - standards setting activities should not eliminate product classes

Discount rates - not quantitative only

-- Can be addressed as a group

 EE-PI-96-001 COMMENT 05

SOLUTIONS: 

Early peer review 

Early review by experts to analyze/evaluate inputs before modeling 

«Excluding contractors based on conflicts of interest can cause all involved to not know 

anything about the issues" 

Three meetings - The assumptions - What - Brainstorm . 

WAYS TO IMPROVE CONSUMERS ANALYSIS 

Regional impacts should be considered - these are minimum standards 

Consumer can buy higher efficiency products 

States can set Building Code Standards 

Alternative is to provide enough information for consumers to make informed 

choices 

This issue is minimized if not setting maximum standards - DOE should 

consistently set more modest standards 

Equity - standards setting activities should not eliminate product classes 

Discount rates - not quantitative only 

-- Can be addressed as a group 
DEALING WITH CUMULATIVE REGULATORY BURDEN

More accurate analysis of data follows from more stringent standards. The more stringent

the standard, the more accurate/rigorous the analysis should be.

How much cost can be pass-through to consumers?

Develop a research agenda which specifies which products will be considered and when.

(Staggering products is one way to address Cumulative Burden)

-- COMMEND has been misapplied. It is an energy forecast model.

It is designed for systems, but has been used for components.

The key issue is DOE balancing both the stringency of standards levels and the list of

products so that cumulative burden is minimized.

MODELS

What makes them acceptable/useful?

They must not be misapplied - ex. Components vs. Systems

They must be understandable to outsiders

Real data must be used, not assumptions

They must use a methodology that is understandable

-- 2 problems regarding the effects of standards on costs and products in the

marketplace

1. Transparency Black Box problem - requests economic data not

manufacturer/product data (There is no such thing as economic data,

i.e. prospective data).

2. Units of measure problem Ex: Not cost accounting based makes it

difficult for manufacturers to accept

If it is a problem, what to do about it?

-- Get research on a few products to analyze the cost pass through. This is

complicated, but very stringent standards necessitate this level of analysis.

 EE-PI-96-001 COMMENT 05

DEALING WITH CUMULATIVE REGULATORY BURDEN 

More accurate analysis of data follows from more stringent standards. The more stringent 

the standard, the more accurate/rigorous the analysis should be. 

How much cost can be pass-through to consumers? 

Develop a research agenda which specifies which products will be considered and when. 

(Staggering products is one way to address Cumulative Burden) 

-- COMMEND has been misapplied. It is an energy forecast model. 

It is designed for systems, but has been used for components. 

The key issue is DOE balahcing both the stringency of standards levels and the list of 

products so that cumulative burden is minimized. 

MODELS. 

What makes them acceptable/useful? 

They must not be misapplied - ex. Components vs. Systems 

They must be understandable to outsiders 

Real data must be used, not assumptions 

They must use a methodology that is understandable 

-- 2 problems regarding the effects of standards on costs and products in the 

marketplace 

1. Transparency Black Box problem - requests economic data not 

manufacturer/product data (There is no such thing as economic data, 

i.e. prospective data). 

2. Units of measure problem Ex: Not cost accounting based makes it 

difficult for manufacturers to accept 

If it is a problem, what to do about it? 

Get research on a few products to analyze the cost pass through. This is 

complicated, but very stringent standards necessitate this level of analysis. 
WAYS TO IMPROVE MANUFACTURERS ANALYSIS

Much of this comes down to consultation. There is no process to resolve these model

differences and results. Create a new step in the process. Previously, discussion has not

led to path toward resolution.

Foregone investment: Mandated investments cause industry to forego other investments.

Meeting Standards can create a large resource requirement. There may be ways to solve

this - demand side, other capital sources, etc.

Stranded assets - Rulemakings can cause existing plant, equipment and personnel to be

changed.

Competition impacts vs. elimination of manufacturers

-- Company to company advantage

-- Competitiveness vis a vis world competition

Jobs impact

-- Energy efficiency creates lots of jobs

-- Savings gets invested elsewhere

-- Energy production creates fewer jobs than EE related jobs

RE: STRANDED INVESTMENT

When does it stop being a problem?

-- 20 year old investment may be fully depreciated

(should not be considered stranded)

-- Maybe stranded investment should be added to analysis

Timing of application of new standards need to be considered more (ex. CFC)

(Coordinate so manufacturers will only re-tool once)

Process to date has ignored energy source competition . This may be due to the statute.

 EE-PI-96-001 COMMENT 05

WAYS TO IMPROVE MANUFACTURERS ANALYSIS 

Much of this comes down to consultation. There is no process to resolve these model 

differences and results. Create a new step in the process. Previously, discussion has not 

led to path toward resolution. 

Foregone investment: Mandated investments cause industry to forego other investments. 

Meeting Standards can create a large resource requirement. There may be ways to solve 

this - demand side, other capital sources, etc. 

Stranded assets - Rulemakirigs can cause existing plant, equipment and personnel to be 

changed. 

Competition impacts vs. elimination of manufacturers 

Company to company advantage 

-- Competitiveness vis a vis world competition 

Jobs impact 

-- Energy 'efficiency creates lots of jobs 

-- Savings gets invested elsewhere 

-- Energy production creates fewer jobs than EE related jobs 

RE: STRANDED INVESTMENT 

When does it stop being a problem? 

- 20 year old investment may be fully depreciated 

(should not be considered stranded) 

-- Maybe stranded investment should be added to analysis 

Timing of application of new standards need to be conSIdered more (ex. CFC) 

(Coordinate so manufacturers will only re-tool once) 

Process to date has ignored energy source competition. This may be due to the statute. 
ONE THING YOU WOULD CHANGE

More open process in input/analysis, done earlier with Peer Review

No. data analysis, until have good data

Concrete definition of significant energy savings , limit on number of product standards, end

point for product standards

Appropriate source of data - e.g. typical product and usage of product energy profiles

Focus on manufacturer practicality vs. technology forcing or max. technology

Focus on what is commercially practicable in definition standards, not prototypes

Early and more frequent Peer Review . Use negotiation to reach consensus when possible.

Rather have that than Garbage In-Garbage Out

Different approach to selection of contractors

 EE-PI-96-001 COMMENT 05

ONE THING YOU WOULD CHANGE 

More open process in input/analysis, done earlier with Peer Review 

No data analysis, .until have good data 

Concrete definition of significant energy savings, limit on number of product standards, end 

point for product standards 

Appropriate source of data - e.g. typical product and usage of product energy profiles 

Focus on manufacturer practicality vs. technology forcing or max.. technology 

Focus on what is commercially practicable in definition standards, not prototypes 

Early and more frequent Peer Review. Use negotiation to reach consensus when possible. 

Rather have that than Garbage In-Garbage Out 

Different approach to selection of contractors 
ONE THING YOU WOULD CHANGE

More open process in input/analysis, done earlier with Peer Review

No data analysis, until have good data

Concrete definition of significant energy savings, limit on number of product standards, end

point for product standards

Appropriate source of data - e.g. typical product and usage of product energy profiles

Focus on manufacturer practicality vs. technology forcing or max. technology

Focus on what is commercially practicable in definition standards, not prototypes

Early and more frequent Peer Review. Use negotiation to reach consensus when possible.

Rather have that than Garbage In-Garbage Out

Different approach to selection of contractors

ASHRAE 90.1 METHODOLOGY

Product of relative production costs versus efficiency improvement curves is an alternative

to current methods.

 EE-PI-96-001 COMMENT 05

ONE THING YOU WOULD CHANGE 

More open process in input/analysis, done earlier with Peer Review 

No data analysis, until have good data 

Concrete definition of significant energy savings, limit on number of product standards, end 

point for product standards 

Appropriate source of data - e.g. typical product and usage of product energy profiles 

Focus on manufacturer practicality vs. technology forcing or max. technology 

Focus on what is commerCially practicable in definition standards, not prototypes 

Early and more frequent Peer Review. Use negotiation to reach consensus when possible. 

Rather have that than Garbage In-Garbage Out 

Different approach to selection of contractors 

ASHRAE 90.1 METHODOLOGY 

Product of relative production costs versus efficiency improvement curves is an alternative 

to current methods.