DOE F 1325.

EFG (079) EE-RM/STD-98-440 t i ]l

Un1ited States Government Department of Energy

E*-/zm/M/ST -t'cD memorandum

DATE:/ /

REPLY TO

ATTN OF: T alic~I e,'E -1

SUBJECT:

Meeting Concerning Central Air Conditioner Standards

TO:

Docket No. EE-RM-94-003

On December 1, 2000, Dan Reicher, Assistant Secretary for Energy Efficiency and Renewable

Energy, met with representatives of a number of organizations to discuss the Department's

rulemaking regarding energy efficiency standards for central air conditioners and heat pumps.

(Docket No. EE-RM-94-003).

Attending the meeting were the following:

DOE: Dan Reicher, Barbara Sisson, Michael J. McCabe, Ed Levy

Others: Chris Neme (NEEP), David Nemtzow (Alliance to Save Energy), Andrew deLaski

(Appliance Standards Awareness Project), Howard Geller and Steve Nadel (American

Council for an Energy-Efficient Economy), and by phone Art Rosenfeld, John Wilson

and Mike Martin (California Energy Commission), David Goldstein (Natural Resources

Defense Counsel), Jeff Harris (NWPPC), Marshall Hunt (PG&E) and Valeri Hall.

Since the comment period on the proposed rule had not closed, Dan Reicher and Ed Levy

provided an overview of the procedures under which we could meet. They explained that the

Department could not discuss the specifics of the rulemaking but was interested in their comments

on the process and overview.

The following items were discussed:

Nemtzow, representing all the participants, discussed:

* The participants believe all the comments they have provided are accurate and meaningful

to the rulemaking and encourage Dan Reicher and the Department to consider them;

· They are anxious for DOE to issue all of the standards rules on time, particularly the

central air conditioner standards rule;

* The standards rules are particularly important given the failure of the Climate Change

discussions in The Hague;

* He encouraged the Department to review the comments submitted by the Trane Company;

* Urged the Department to make sure OMB is aware of the status of the appliance

standards rules so that DOE does not lose out to other agencies in trying to get the rules

through OMB; and

* DOE should revisit the record on the "flawed" central air conditioner analysis.

Q:\EE-41\Equipment, Materials, Tools\Appliance9tds\Residential\Central Air and Heat Pumps\Standard\advocates 12_1.wpd

EE-RM-STD-98-440 COMMENT 127

DOEF1325.8 

(8-89) • :. 

EFG (07-$0) ~ 

U-nited States Government ~.,-. . ' , 

EE-RM/STD-98-440 *1 'J..7 

Department of Energy 

memorandum 

DATE: 

REPLY TO 

ATTN OF: 

SUBJECT: 

TO: 

-'~~°-tar..;e·, EllMeeting Concerning Central Air Conditioner Standards 

Docket No. EE-RM-94-003 

On December 1, 2000, Dan Reicher, Assistant Secretary for Energy Efficiency and Renewable 

Energy, met with representatives of a number of organizations to discuss the Department's 

rulemaking regarding energy efficiency standards for central air conditioners and heat pumps. 

(Docket No. EE-RM-94-003). 

Attending the meeting were the following: 

DOE: Dan Reicher, Barbara Sisson, Michael J. McCabe, Ed Levy 

Others: Chris Neme (NEEP), David Nemtzow (Alliance to Save Energy), Andrew deLaski 

(Appliance Standards Awareness Project), Howard Geller and Steve Nadel (American 

Council for an Energy-Efficient Economy), and by phone Art Rosenfeld, John Wilson 

and Mike Martin (California Energy Commission), David Goldstein (Natural Resources 

Defense Counsel), Jeff Harris (NWPPC), Marshall Hunt (PG&E) and Valeri Hall. 

Since the comment period on the proposed rule had not closed, Dan Reicher and Ed Levy 

provided an overview of the procedures under which we could meet. They explained that the 

Department could not discuss the specifics of the rulemaking but was interested in their comments 

on the process and overview. -

The following items were discussed: 

Nemtzow, representing all the participants, discussed: 

• The participants believe all the comments they have provided are accurate and meaningful 

to the rulemaking and encourage Dan Reicher and the Department to consider them; 

• They are anxious for DOE to issue all of the standards rules on time, particularly the 

central air conditioner standards rule; 

• The standards rules are particularly important given the failure of the Climate Change 

discussions in The Hague; 

• He encouraged the Department to review the comments submitted by the Trane Company; 

• Urged the Department to make sure OMB is aware of the status of the appliance 

standards rules so that DOE does not lose out to other agencies in trying to get the rules 

through OMB; and 

• DOE should revisit the record on the "flawed" central air conditioner analysis. 

Q:\EE-41 \Equipment, Materials, Tools\Appliance'~!ls\Residential\Central Air and Heat Pumps\Standardladvocates 12 _1.wpd 
EE-RM/STD-98-440- t .

Nadel commented:

* He urged DOE to review the NAECA criterion, which, in his view, would support his

position on standards included in their written comment; and

* He pointed out that ACEEE has been able to collect actual data to support their

contention.

Geller commented it was essential that the central air conditioner rule get completed as well as the

clothes washer and water heater rules.

Martin commented about the circumstances in California with regard to generating capacity and

mentioned activities the State is considering to address the situation. His discussion was cut short

to avoid discussing particular actions the State is considering regarding appliance standards.

Goldstein remarked that he appreciates the effort the Department is putting into this program and

commented how his organization will continue to support the Department in this area.

Reicher commented:

* The central air conditioner standards rule is his single highest priority activity;

* He has committed to the Secretary and Deputy Secretary that EERE will finish on time;

* He has asked Barbara Sisson to report on the rulemaking status twice a week;

* EERE is putting all resources necessary to completing the rulemakings; and

* EERE is doing everything in our control to meet the schedule.

McCabe commented that our goal is to get each of the rules over to the Federal Register the first

week in January so that they will be published by January 19th.

Q:\EE-41\Equipment, Materials, Tools\Appliance'[tds\Residential\Central Air and Heat Pumps\Standard\advocates 12_1 .wpd

EE-RM-STD-98-440 COMMENT 127

- -:; 

EE-RM/STD-98-440 - it l;t 7. 

Nadel commented: 

• 

• 

He urged DOE to review the NAECA criterion, which, in his view, would support his 

position on standards included in their written comment; and 

He pointed out that ACEEE has been able to collect actual data to support their 

contention. 

Geller commented it was essential that the central air conditioner rule get completed as well as the 

clothes washer and water heater rules. 

Martin commented about the circumstances in California with regard to generating capacity and 

mentioned activities the State is considering to address the situation. His discussion was cut short 

to avoid discussing particular actions the State is considering regarding appliance standards. 

Goldstein remarked that he appreciates the effort the Department is putting into this program and 

commented how his organization will continue to support the Department in this area. 

Reicher commented: 

• The central air conditioner standards rule is his single highest priority activity; 

• He has committed to the Secretary and Deputy Secretary that EERE will finish on time; 

• He has asked Barbara Sisson to report on the rulemaking status twice a week; 

• EERE is putting all resources necessary to completing the rulemakings; and 

• EERE is doing everything in our control to meet the schedule. 

McCabe commented that our goal is to get each of the rules over to the Federal Register the first 

week in January so that they will be published by January 19th. 

Q:\EE-41 \Equipment, Materials, Tools\Applianct!" iltls\ResidentiallCentral Air and Heat PumpslStandardladvocates 12 1. wpd