# W.C. Wo

# od 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

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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 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 ;' i 

## , 

# W.C. Wood CompanyLimited

HEAD OFFICE P. O. BOX 750 5ARTHUR 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 ofHearings and Appeals U.S. DepartmentofEnergy 1000 IndependenceAvenue, SW Washington, D.C. 20585-0107
Attention: Fred L. Brown 

### Deputy Assistant Director
Re: Case No.VEE

- 0054



### Dear Mr. Brown ::0 -D -D 3= ::r--- ;::;:::l


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Thankyou for the opportunity to commenton the 'Application for Exception', filed byAmana Appliances (Amana), 

### with respectto relieffrom the provisionsof 10C.F.R. Part430, Energy Conservation Program for Consumer Products: Energy Conservation Standards for Refrigerators, Refrigerators-Freezers andFreezers. 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 marketcomesfrom numeroussources, bothdomesticand offshore. The issues and concerns raised byAmana, in their 'Application for Exception', hold truefor 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 thatAmana was notthe only North American companyto 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 ofthis investmentwas 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 ofHCFC-141b and HCFC-22 as a replacement blowing agentforCFC-11 in the appliancefoam 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 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 energyefficiency of 10%to 12%. The availability ofHFC-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, letalone '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 isvery seriouslyevaluating and considering which refrigeration products may not be viable to manufacture due to technical. economic or market acceptance issues. This is duetothevery real possibility ofHFC-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 EnergyStandard deadline. Thankyou foryourtime, and please do hesitatetocontact meforanyfurther information or clarification required.
Sincerely,

cc: Alan F. Kessler VICe President, Engineering & Quality AmanaAppfl8nces

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