W.C. Wood Company Limited

HEAD OFFICE

GUELPH (519) 823-9663

(905) 457-5354

(416) 861-0178

CORP. FAX (519) 767-1458

1999-March-12

Office of Hearings and Appeals

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, D.C. 20585-0107

Attention: Fred L. Brown

Deputy Assistant Director

Re: Case No. VEE - 0054

Dear Mr. Brown

P. O. BOX 750

5 ARTHUR ST. SOUTH

GUELPH. ONTARIO

CANADA N I H 6L9

-

aThank you for the opportunity to comment on the 'Application for Exception', filed by Amana

Appliances (Amana), with respect to relief from the provisions of 10 C.F.R. Part 430, Energy

Conservation Program for Consumer Products: Energy Conservation Standards for

Refrigerators, Refrigerators-Freezers and Freezers.

W. C. Wood Company is a privately owned North American appliance manufacturer with

manufacturing facilities in Ontario, Canada and Ohio, U.S.A. While not a 'full line'

manufacturer of appliances, W. C. Wood does manufacture a complete line of chest and

upright household freezers as well as compact and 'niche market refrigerators and

freezers. W. C. Wood competes in the North American and the international marketplace.

W. C. Wood shares the North American freezer market with virtually its only competitor,

Frigidaire (parent company Electrolux). Competition in the compact and 'niche' refrigerator

market comes from numerous sources, both domestic and off shore.

The issues and concerns raised by Amana, in their'Application for Exception', hold true for

W. C. Wood Company as well and we believe that the data supplied by Amana is correct

and unbiased and further data from W. C. Wood Company is not required. It should be

noted that Amana was not the only North American company to cease the manufacture of

freezers as a result of the 1990 and 1993 energy standard requirements. As previously

mentioned, only W. C. Wood and Frigidaire made the decision to invest in the redesign

required to manufacture freezers which would meet the energy regulations of the United

States and Canada. A continuation of this investment was required when the industry was

required to phase out of CFC's for 1996/01/01. At that time W. C. Wood moved from

CFC-12 to HFC-134a in the refrigeration system and a blend of HCFC-141b and HCFC-22

as a replacement blowing agent for CFC-11 in the appliance foam insulation.

MANUFACTURERS OF FREEZERS, KITCHEN COMPACTS, REFRIGERATORS

HUMIDIFIERS AND DEHUMIDIFIERS

 EE-RM-93-801 COMMENT 337

;' 

i , 

W.C. Wood Company Limited 

HEAD OFFICE P. O. BOX 750 

5 ARTHUR ST. SOUTH 

GUELPH. ONTARIO 

CANADA NIH 6L9 

GUELPH (519) 823-9663 

(905) 457-5354 

(416) 861-0178 

CORP. FAX (519) 767-1458 

1999-March-12 

Office of Hearings and Appeals 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, D.C. 20585-0107 

Attention: Fred L. Brown 

Deputy Assistant Director 

Re: Case No. VEE - 0054 

Dear Mr. Brown 

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Thank you for the opportunity to comment on the 'Application for Exception', filed by Amana 

Appliances (Amana), with respect to relief from the provisions of 10 C.F.R. Part 430, Energy 

Conservation Program for Consumer Products: Energy Conservation Standards for 

Refrigerators, Refrigerators-Freezers and Freezers. 

W. C. Wood Company is a privately owned North American appliance manufacturer with 

manufacturing facilities in Ontario, Canada and Ohio, U.S.A. While not a 'full line' 

manufacturer of appliances, W. C. Wood does manufacture a complete line of chest and 

upright household freezers as well as compact and 'niche markef refrigerators and 

freezers. W. C. Wood competes in the North American and the international marketplace. 

W. C. Wood shares the North American freezer market with virtually its only competitor, 

Frigidaire (parent company Electrolux). Competition in the compact and 'niche' refrigerator 

market comes from numerous sources, both domestic and off shore. 

The issues and concerns raised by Amana, in their 'Application for Exception', hold true for 

W. C. Wood Company as well and we believe that the data supplied by Amana is correct 

and unbiased and further data from W. C. Wood Company is not required. It should be 

noted that Amana was not the only North American company to cease the manufacture of 

freezers as a resuH of the 1990 and 1993 energy standard requirements. As previously 

mentioned, only W. C. Wood and Frigidaire made the decision to invest in the redesign 

required to manufacture freezers which would meet the energy regulations of the United 

States and Canada. A continuation of this investment was required when the industry was 

required to phase out of CFC's for 1996/01/01. At that time W. C. Wood moved from 

CFC-12 to HFC-134a in the refrigeration system and a blend of HCFC-141b and HCFC-22 

as a replacement blowing agent for CFC-11 in the appliance foam insulation. 

MANUFACTURERS OF FREEZERS, KITCHEN COMPACTS, REFRlGERATORS 

HUMIDIFIERS AND DEHUMIDIFIERS 
Both of these changes resulted in additional loss of energy efficiencies which had to be

overcome in order to have our freezer products continue to meet the DOE 1993 Energy

Standard.

As correctly stated in the Amana application, at the time of the 'energy standards'

negotiations, the industry believed that HFC-245fa would be available and could provide

manufacturers with an alternative blowing agent which would not further compromise

refrigeration appliance energy efficiency. The already significant challenge of meeting the

new 2001/07/01 energy standards now appears to be even more difficult. The current

situation has the two best blowing agent alternatives for appliance foam insulation (on

EPA's SNAP list), R134a and cyclopentane, demonstating to have a negative impact on

energy efficiency of 10% to 12%.

The availability of HFC-245fa as a comparable alternative blowing agent is very uncertain at

this time. In fact, at this point in time, we do not believe that HFC-245fa has been peer

reviewed, let alone 'SNAP' listed. -

W. C. Wood Company is not opposing the Amana application, nor contemplating a similar

application on its own behalf, at this time. It must be noted however, that W. C. Wood

Company is very seriously evaluating and considering which refrigeration products may not

be viable to manufacture due to technical, economic or market acceptance issues . This is

due to the very real possibility of HFC-245fa not being commercially available, and virtually

all products requiring a redesign to meet 2001 /07/01 and then another redesign to

overcome the additional 10% energy penalty which would be incurred with the 2003101/01

phase out of HCFC-141 b. Product decisions -and designs must be 'finalized', and tooling

and plant modifications started in the next few months for products to be ready for the

2001/07/01 Energy Standard deadline.

Thank you for your time, and please do hesitate to contact me for any further information or

clarification required.

Sincerely,

David M. Sheach

Manager, Corporate Engineering and Quality

cc: Alan F. Kessler

Vice President, Engineering & Quality

Amana Appliances

 EE-RM-93-801 COMMENT 337

Both of these changes resulted in additional loss of energy efficiencies which had to be 

overcome in order to have our freezer products continue to meet the DOE 1993 Energy 

Standard. 

As correctly stated in the Amana application, at the time of the 'energy standards' 

negotiations, the industry believed that HFC-24Sfa would be available and could provide 

manufacturers with an alternative blowing agent which would not further compromise 

refrigeration appliance energy efficiency. The already significant challenge of meeting the 

new 2001/07/01 energy standards now appears to be even more difficult. The current 

situation has the two best blOwing agent alternatives for appliance foam insulation (on 

EPA's SNAP list), R134a and cyclopentane, demonstating to have a negative impact on 

energy efficiency of 10% to 12%. 

The availability of HFC-24Sfa as a comparable alternative blowing agent is very uncertain at 

this time. In fact, at this point in time, we do not believe that HFC-24Sfa has been peer 

reviewed, let alone 'SNAP' listed. 

w. C. Wood Company is not opposing the Amana application, nor contemplating a similar 

application on its own behalf, at this time. It must be noted however, that W. C. Wood 

Company is very seriously evaluating and considering which refrigeration products may not 

be viable to manufacture due to technical. economic or market acceptance issues. This is 

due to the very real possibility of HFC-24Sfa not being commercially available, and virtually 

all products requiring a redesign to meet 2001/07/01 and then another redesign to 

overcome the additional 10% energy penalty which would be incurred with the 2003101/01 

phase out of HCFC-141b. Product decisionscand designs must be 'finalized', and tooling 

and plant modifications started in the next few months for products to be ready for the 

2001/07/01 Energy Standard deadline. 

Thank you for your time, and please do hesitate to contact me for any further information or 

clarification required. 

Sincerely, 

cc: Alan F. Kessler 

VICe President, Engineering & Quality 

Amana Appfl8nces 

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