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 DEPARTMENT OF ENERGY

 APPLIANCE STANDARDS AND RULEMAKING

 FEDERAL ADVISORY COMMITTEE MEETING

 Department of Energy

 1000 Independence Avenue SW

 Forrestal Building

 Washington, D.C. 20585

 Tuesday, May 14, 2013

 10:00 a.m.

Reported by: Natalia Thomas,

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1 A P P E A R A N C E S

2 FACILITATOR

3 Neil Eisner, Navigant Consulting

4

5 PARTICIPANTS

6 Karim Amrane, Air-Conditioning, Heating, and

7 Refrigeration Institute (AHRI)

8 Viktor Anderson, CRM

9 Timothy Ballo, Earthjustice

10 Laura Barhydt, U.S. Department of Energy

11 Jeff Bauman, National Comfort Products

12 Rodney Beever, United CoolAir Corporation

13 Alex Boesenberg, National Electric Manufacturers

14 Association

15 Brice Bowley, GE Appliances

16 Dan Bramblett, Estes Services

17 Brian Buynacek, Emerson

18 Nia Crowder, SF Environment Commission

19 Mary Dane, Traulsen

20 Laura Degitz, Navigant

21 Jim del Toro, Carrier Corporation

22 Paul Doppel, Mitsubishi Electric
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1 A P P E A R A N C E S

2 Mark Fly, AAON Heating & Cooling Products

3 Jeremiah Freeman, New West Tech

4 Luke Hall-Jordan, EPA

5 Geoffrey Halley, SJI Consultants

6 Pantelis Hatzikaziakis, Lennox International

7 Bruce Helft, California Energy Commission

8 Bruce Hierlmeier, Zero Zone, Inc

9 Charles Hon, True

10 Jill Hootman, Trane

11 Larry Howington, Commercial Refrigeration

12 Marshall Hunt, Pacific Gas & Electric Company

13 Diane Jakobs, Rheem Heating and Cooling

14 Tom Johnson, Daikin McQuay

15 Athar Khan, United CoolAir Corporation

16 Jeff Kleiss, Lochinvar

17 Michael Kojak, UL LLC

18 Dominic Kolandayan, Daikin AC

19 Stephen Kowalski, Ingersoll Rand-Trane North America

20 Bill Larson, Norlake, Inc

21 Iyabo Lawal, An

22 Paul Lin, Regal-Beloit Corporation
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1 A P P E A R A N C E S

2 Bijou Lulla, Source Energy

3 Steven Ly, SoCalGas

4 John Mandyck, UTC Climate, Controls & Security

5 Aris Marantan, Navigant

6 John McLaughlin, McQuay International

7 David Mecadon, National Comfort Products

8 Mark Menzer, Intertek

9 Karen Meyers, Rheem Manufacturing Company

10 Peter Molvie, Cleaver-Brooks Product Development

11 Wahid Mohamed, Saudi Diyar Consultants

12 John Morris, Continental Refrigerator

13 Vince Mucciola, National Comfort Products

14 Frank Myers, PVI

15 Jeff Newel, Hill Phoenix Systems Division

16 Kent Peterson, P2S Engineering

17 Jay Perkins, MEUS

18 Mark Rabbia, Carrier Corporation

19 David Ransom, McDermott Will & Emery

20 Doug Reed, ASHRAE

21 Wes Roan, Bard Manufacturing Company

22 Carl Roberts, Zero Zone, Inc
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1 A P P E A R A N C E S

2 John Sabelli, Consulting Engineer

3 Harvey Sachs, ACEEE

4 Jason Sands, The Delfield Company

5 Tony Scardomp, MC Law School

6 Stephen Schaefer, Hoshizaki America

7 Ronald Shebik, Hussmann Corporation

8 Judd Smith, OnSpeX

9 Frank Stanonik, Air-Conditioning, Heating, and

10 Refrigeration Institute (AHRI)

11 Louis Starr, Northwest Energy Efficiency Alliance

12 (NEEA)

13 Phillip Stephens, HTP Advanced Heating and Water

14 Systems

15 Peter Strait, California Energy Commission

16 Mvuala Suami, NRCAN

17 John Sutphen Cleaver-Brooks Product Development

18 Rusty Tharp, Goodman Air Conditioning and Heating

19 Eric Truskoski, Bradford White Corporation

20 Tom Walsh, Daikin McQuay

21 Kevin Washington, Illinois Tool Works

22 Collin Weber, Navigant
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1 A P P E A R A N C E S

2 Andrew Welch, Johnson Controls

3 Robert Whitwell, Carrier

4 Kevin Washington, Illinois Tool Works

5 Michael Woodford, AHRI

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

2 MR. EISNER: Okay. Can everybody please take

3 their seats? We are going to get started in a couple

4 of minutes, so get your thoughts together.

5 Why don't we start off with the ground rules,

6 make sure everybody is comfortable with what came out

7 in the final version, or maybe I should say the final

8 draft, unless everybody is happy with it. There were a

9 few places in there where there was a little confusion

10 as to what had actually been agreed to.

11 So focus particularly on the areas under

12 three, I think it was, Decision-Making. There were a

13 few places where words were taken out that seemed

14 inappropriate, like the "working group" in some places

15 was refined as the "negotiating working group," other

16 places it's just the "working group." So I talked to

17 Laura about that, and DOE agreed there was no reason to

18 leave it in there and it could be confusing.

19 But other than that, just concentrate on

20 those sections with the substance and let me know if

21 you've got any problems. Why don't you take a minute

22 or two to make sure you've looked at it.
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1 (Pause.)

2 Does anybody have any questions about what's in there?

3 (No response.)

4 Okay. Everybody ready to say okay? Anybody have any

5 objections?

6 (No response.)

7 Okay. Seeing no objections, we now have ground rules

8 to operate under. So that takes us to the second

9 document that was circulated I think yesterday, the

10 scope of the working group negotiations, the list of

11 issues, and DOE I think is going to start off by going

12 through a PowerPoint and talking a little bit about

13 this issue. Everybody should have a copy of the

14 PowerPoint.

15 MS. BARHYDT: Actually, before we start the

16 PowerPoint, are there any questions about the list of

17 what is actually on the scope list?

18 MR. EISNER: Yes. Would you identify

19 yourself when you come to the mic?

20 MR. KLEISS: Jeff Kleiss with Lochinvar. I'm

21 the alternate for Neil Rolph. Curious about where this

22 was generated from. I don't recall all of these bullet
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1 points coming out in the meeting. There is a number of

2 these items -- the certification testing and things of

3 that sort -- that strike me as being some sort of

4 verification. But there is a significant -- I'm very

5 curious about what some of the intended items are,

6 particularly starting with the third bullet down

7 towards the bottom.

8 MS. BARHYDT: No. This is the list from --

9 it has been reordered and reorganized, but it is the

10 list from the last meeting. Certification testing is

11 the testing required to distribute prior to

12 distribution and commerce. DOE calls it certification

13 testing.

14 MS. ARMSTRONG: So the tolerance that you

15 would use to test your product.

16 MR. KLEISS: Okay. And following up to that,

17 if we can amend things, I believe that a discussion on

18 the voluntary industry programs should probably be a

19 prime point for discussion.

20 MS. BARHYDT: In what context?

21 MR. KLEISS: Recognition of them.

22 MS. BARHYDT: So I don't think that DOE sees
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1 those within the scope of this rulemaking. We have

2 said on several occasions that we want to do a

3 rulemaking on that issue, but I don't think that we see

4 that as within the scope of this negotiated rule.

5 Okay. So down at the very bottom, the

6 voluntary industry programs, and some sort of

7 recognition.

8 MR. KLEISS: Correct.

9 MS. BARHYDT: Okay.

10 MR. EISNER: Other questions? Other

11 concerns? Yes. Robert?

12 MR. WHITWELL: Bob Whitwell from Carrier.

13 One of the items that was on the list from the last

14 meeting up on the screen was inclusion of a discussion

15 of the treatment of items that improve the energy

16 efficiency of the building but can impact the

17 efficiency of the equipment at the -- in the current

18 standard rating condition, such as economizers, ERVs,

19 et cetera. I didn't see it on this list now.

20 MS. BARHYDT: So to the extent that it has to

21 do with the test procedure, that's an issue for a test

22 procedure rulemaking, not for the certification? To
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1 the extent that it deals with what variations on a

2 model have to be certified, that would be in the model

3 groupings basic model discussion.

4 MR. WHITWELL: Okay. So that is part of the

5 basic model discussion. Okay.

6 MR. EISNER: Other questions/concerns? And

7 this is not a binding document, as I see it; it's just

8 something that is going to -- we are going to tailor

9 our discussions around, go through this list in order.

10 If there are any discussions, other issues come up that

11 need to be resolved, we can add them to the list if

12 there is agreement.

13 Everybody is happy then? No objections to

14 starting with this list? Start off with AEDM?

15 MS. BARHYDT: So we had talked about starting

16 off today and tomorrow working on alternative

17 efficiency determination methods. As you all know, we

18 have issued a Notice of Proposed Rulemaking. The

19 slides go over what that proposal was. It also

20 includes some of the comments that we received in

21 response to that Notice of Proposed Rulemaking.

22 One caveat is that that rulemaking covered a
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1 broader range of equipment than this negotiated

2 rulemaking covers, and so only the products that are

3 part of this negotiated rulemaking will be discussed.

4 We won't be covering residential air conditioning

5 products, motors, any of that. That material will

6 remain within the AEDM rulemaking.

7 Did everyone have a chance to look through

8 the PowerPoint? I'm not sure whether it is worth going

9 slide by slide, if everyone has already looked at it.

10 But it certainly does highlight some of the issues and

11 maybe would provide a framework for discussion. It is

12 really kind of up to everyone around the table as to

13 how you want to go about doing it. We just thought

14 this might help provide a framework for discussions,

15 but we are not trying to dictate how we approach this.

16 MR. DOPPEL: Laura, Paul Doppel with

17 Mitsubishi Electric. I just want to make sure that it

18 is clear that VRF products are included within the

19 commercial HVAC definition.

20 MS. BARHYDT: Yes.

21 MR. DOPPEL: Okay. All right. Thanks.

22 MR. SACHS: Laura, this is Harvey Sachs,
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1 ACEEE. I appreciated this document. It was very

2 helpful to me. But at the same time, I am a little bit

3 concerned that I understand the AEDM discussion has to

4 deal with these products. Everything else is outside

5 the scope. But what we decide here can often be

6 illuminated.

7 The discussion can often be illuminated by

8 examples from outside, and I think a lot of people at

9 this table have concern that the precedent set through

10 our discussions here will be considered in discussions

11 for other products. So if somebody mentions

12 residential air conditioning, or some other non13 included product, I hope we don't just slap her fingers

14 immediately.

15 MS. BARHYDT: We'll docket the transcript

16 from this and the AEDM rulemaking. And so anything

17 that is said here, we will consider. But I don't want

18 us to get off track going onto extensive discussions

19 about other products. We have more than enough on our

20 plate as it is.

21 MR. SACHS: I am likely to agree, if you

22 promise never to use "docket" as a verb.
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1 MR. EISNER: Did I hear an agreement?

2 Okay. Any other issues on that? Do you want

3 to go through it briefly? I mean, you said you don't

4 want to stop on every slide. Do you want to do an

5 overall briefing, general briefing?

6 MS. BARHYDT: I think Ashley was going to

7 address sort of the product list real quick.

8 MR. EISNER: Okay.

9 MS. BARHYDT: Just to make sure everybody is

10 on the same page.

11 MS. ARMSTRONG: So this is Ashley from DOE.

12 We didn't add a slide at the outset. In retrospect, I

13 probably should have. But in terms of like -- I guess

14 on Slide 7 where it talks about applicable products --

15 and I'm jumping just a bit, we'll go back -- just to

16 clarify, for DOE, commercial air conditioning equipment

17 is a very large category.

18 This would include things like three-phase

19 less than 65,000, small, large, very large, unitary,

20 both split and package, VRFs of all types, PTACs,

21 MPTHPs, SPVUs, in terms of DOE's -- and then water22 cooled, evaporatively cooled water source. So
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1 everything that falls into that 431.96/97 range. Just

2 to clarify.

3 Now we can go back. DOE's lingo is a little

4 different than typical.

5 MR. SACHS: What about chillers?

6 MS. ARMSTRONG: Just a little different. Not

7 chillers, no. Chillers aren't covered.

8 MS. HOOTMAN: Split systems?

9 MS. ARMSTRONG: Yes. Commercial, split and

10 package.

11 MS. HOOTMAN: Split systems up to 240.

12 MS. ARMSTRONG: All the way up to 760, are on

13 the table at least, unless you guys want to narrow the

14 applicability. Does that help?

15 So do you guys want me to walk through this?

16 Or do you want to just go right to -- Neil can go

17 through the slides in terms of what we tried to do is

18 use the comments and come up with some issues for

19 discussion, and some of them are questions, some of

20 them are options for different people to talk around.

21 I don't know exactly how you want to tee this up, but

22 I'm happy to walk through it or, if you'd just like to
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1 go to that -- skip to each set of slides, those are the

2 issues, and, obviously, more options are welcome.

3 MR. EISNER: Any thoughts?

4 MR. THARP: This is Rusty Tharp with Goodman.

5 I will suggest that the six areas that DOE has outlined

6 are good areas to talk to, and we would just have a

7 general discussion about each section.

8 MS. ARMSTRONG: Okay.

9 MR. EISNER: Which is the first one that we

10 want to start with?

11 MS. ARMSTRONG: Preapproval is fine. So I'm

12 just going to go through these real quick, then. So

13 the first section to talk about is preapproval, whether

14 DOE should preapprove any type of simulation before it

15 is allowed for use. In the proposed rule, we propose

16 no preapproval process.

17 On Slide 4, you can see we have a variety of

18 comments, some in favor, some against. And, really, I

19 think Slide 5 is where we set up some of the issues for

20 discussion in terms of advantages and disadvantages to

21 preapproval.

22 From the Department's perspective, you know,
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1 a preapproval process, even if we were to add one,

2 would not exempt any manufacturer from potential

3 assessment or enforcement testing. So there is no real

4 guarantee from that. Even if we did preapprove, what

5 it would do is make you guys wait until we get through

6 all of that paperwork before you could actually use an

7 AEDM.

8 So there is a variety of questions on this

9 page. You know, I don't know how you want to tee them

10 up for discussion here, just to see what people think

11 and the different ideas that come about.

12 MR. EISNER: We can go through and brief on

13 each one of the issues and talk about the options, or

14 we can - - especially if you think they are intertwined

15 significantly. That may be the best way to go.

16 Otherwise, it seems that the logical way to do this is

17 to get a little background on each of the issues and

18 then start to discuss it.

19 It would be always good if we could start

20 with a simple, easy one to resolve, too. But let's

21 start with preapproval, whether it is or is not in that

22 category. You see the options; you see some of the
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1 issues. Questions? Comments? What does everybody

2 think of using the word "docket" as a verb?

3 MR. SACHS: It's okay if you're talking about

4 bringing the --

5 MR. EISNER: Very good, very good.

6 MS. BARHYDT: Do people think that DOE should

7 preapprove AEDMs?

8 MR. THARP: Rusty Tharp with Goodman. I will

9 say that the process today for AEDMs is no preapproval,

10 and we are fine with continuing not having it

11 preapproved.

12 MR. EISNER: Anybody want to speak in favor

13 of having preapprovals? Anybody think it's valuable or

14 important? Yes.

15 MR. HON: Charlie Hon, True Manufacturing. I

16 do not necessarily say it's necessary, but the problem

17 comes in the -- no preapprovals will also lead to

18 potential cheaters, somebody who will tweak it, because

19 we have yet to come up with any kind of validity

20 testing in this preapproval process. And without some

21 validation in your system, and a limit of maybe only

22 testing the biggest and the smallest unit and come up
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1 with some system between those two, it is almost

2 impossible to come up with any validity whatsoever.

3 MS. BARHYDT: So would you suggest an

4 alternative of -- or would you say that if there was

5 more checks on the back end, you would be more

6 comfortable with not having preapproval? Or it sounds

7 like you think those are intertwined?

8 MR. HON: Charlie Hon again. I do believe

9 that they are intertwined because if, by chance, we end

10 up with some people that are being reviewed because of

11 data that doesn't agree, and they have used this

12 process to come up with the numbers and they are 25

13 percent off of what was tested, then we ask a question

14 because it -- further on in the documents we discuss

15 multiple items that have failed to meet the standard.

16 We don't know what that means.

17 Is it the first time you end up with a big

18 difference tested that you get reviewed and your

19 process is reviewed? Or is it the second time? Or is

20 it the third time? When it says "multiple," it can

21 mean a lot, and that is a dangerous precedent to just

22 leave it open- ended, because then we will have one
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1 person, one company which has a broad spectrum of

2 products with only a few pieces tested, very vulnerable

3 to quick review because they didn't do as much testing

4 as they probably should have done. But when does that

5 trigger? That's my concern.

6 MS. BARHYDT: So if what I'm understanding

7 you to say is correct, you want to make sure that the

8 AEDMs that people use are generating good numbers. And

9 I think there may be a variety of ways to get there.

10 One is to have DOE check the models in advance. That's

11 the preapproval.

12 One of those is to require more testing in

13 the first place, but DOE not review all of those

14 documents up front, but that we could request those

15 documents and review them at a later date. And then

16 the third would be to have some kind of after-the-fact

17 testing.

18 And I think all three of those are on the

19 table for discussion today, and so it is -- I think it

20 is going to be some tradeoffs in terms of, do you want

21 DOE to review the documents up front before anyone can

22 use an AEDM? Do you want us to be reviewing documents
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1 during the course of ordinary business as your

2 manufacturing products? Or do you want to focus on

3 back end? And it is really a question for you as to

4 how you want that balance.

5 MS. DANE: Mary Dane, Traulsen. We agree

6 that there should be no preapproval, that this should

7 be talked about under enforcement and validation.

8 There is a lot of paperwork to be done, and it takes

9 too long to get things reported back to us. And it

10 kind of stops the market while we are waiting for

11 approval. I mean, you see how long it took us to get

12 slides and things like that. God forbid we have to

13 wait, you know, for the AEDM to come through. So we

14 would appreciate leaving that in, enforcement

15 validation, please.

16 MR. EISNER: If I could, I got a handwritten

17 comment from Ron -- hope I pronounce his last name

18 correctly -- Shebik. He says, "No preapproval

19 necessary. Validation is responsibility for each

20 manufacturer, but preapproval not necessary."

21 There seems to be a general feeling that

22 there shouldn't be any preapproval, that it's not
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1 necessary. Is that simple statement satisfactory, or

2 would you want DOE to add some clause to explain what

3 that means, or how it would be applied, or anything

4 like that? "Preapproval is not necessary, and this

5 means," for example. Are you happy with that simple

6 statement?

7 MR. SACHS: Harvey Sachs, ACEEE.

8 Conceptually, we could be satisfied without preapproval

9 if there is good verification and enforcement. But the

10 other reason I raised my hand was to throw out for

11 consideration one other option to the three that Laura

12 mentioned.

13 And we are focused on testing against sample

14 equipment, but another alternative would be for DOE or

15 other groups to build standard models for equipment

16 that could be used as benchmarks for the proprietary

17 models of those manufacturers who choose to design

18 their own proprietary models.

19 I 50 years ago interned at what was then the

20 Bureau of Standards, and is now NIST. And the culture

21 of how you do these things to get the assurance at the

22 front end, how a manufacturer can be sure at the front
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1 end that his AEDM will satisfy DOE, can be resolved in

2 a number of different ways. And the use of standard

3 models as benchmarks I think certainly ought to be on

4 the table if anyone else is interested in it.

5 MS. BARHYDT: When you say "benchmark," what

6 do you mean?

7 MR. SACHS: Harvey Sachs. What I mean by

8 that is a standard model and building simulation -- we

9 might think of a number of examples -- against which an

10 alternative model can be calibrated. And if it is --

11 if, in a series of trials covering different

12 capacities, different sufficiency levels, whatever, the

13 manufacturer's model is in close conformance to the

14 industry or DOE model, then it is considered to be an

15 appropriate vehicle for AEDM verification.

16 MS. ARMSTRONG: This is Ashley from DOE. I'm

17 actually going to turn the question around to the

18 manufacturers in the room that may have some type of

19 simulation they use now. I mean, could your simulation

20 that simulates the performance of your unique designs

21 today actually be compared to a standard model in any

22 type of way, with any type of tolerance to provide a
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1 validity check?

2 I think that's what Harvey is getting at,

3 more or less. And I don't think the Department can

4 answer that. I think we need you guys' help.

5 MR. SACHS: Thank you for translation.

6 MR. WHITWELL: This is Bob Whitwell from

7 Carrier. I get a little concerned about comparing a

8 model to another model.

9 MR. SACHS: Me, too.

10 MR. WHITWELL: And, you know, one of the

11 things that is in here that is discussed is testing,

12 validating the model -- the AEDM through testing, which

13 I think is a better method, because then you have some

14 actual data and you are comparing the AEDM to actual

15 data, as opposed to comparing two models where you've

16 got -- inherently there is inaccuracies in the model,

17 right?

18 And so how do you know, number one, that

19 the base model that is being used to compare it to is

20 accurate? The second point is that different

21 manufacturers with different products can have

22 different technologies across the manufacturer, but
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1 also within their product range. And so I think it

2 becomes very complicated if you try to develop a model

3 or a series of models that would be benchmarks that

4 would cover all of the various products that will have

5 to be covered by the

6 AEDM.

7 MR. SACHS: This is Harvey again.

8 MR. EISNER: Ron has a comment. He is on the

9 web and he wants to join us with a comment he wants to

10 make.

11 MR. SHEBIK. Hi. Good morning. Can you hear

12 me?

13 MR. EISNER: Yes.

14 MR. SHEBIK: I just wanted to comment.

15 Again, as a representative of a manufacturer, to create

16 a good AEDM you are going to have to understand your

17 product, and you are going to have to know how your

18 product runs. You really can't create a good AEDM

19 without any kind of testing, whether it be on a

20 component level or on a whole -- your whole product in

21 general.

22 So I come up kind of late because I think
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1 some of these things have already just been discussed

2 recently, but you are not going to miss out on anything

3 on an AEDM by -- you will have testing in order to

4 create it, and I think as you go -- as you progress in

5 time you can verify your AEDM with a series of tests

6 based on your product line. I just wanted to throw

7 that comment out there.

8 Now, tolerance and stuff, I think that is

9 going to come later in our discussion. Someone threw

10 out tolerances. But that is going to come later, I

11 believe.

12 MR. EISNER: Yes.

13 MR. MYERS: Yes. This is Frank Myers, PVI

14 Industries. The lead-in question here was whether or

15 not we support preapproval of an AEDM. And from a

16 custom equipment engineer-to-order/design-to-order

17 manufacturer who builds very complex and expensive

18 equipment, sells it, engineers it, builds it, and then

19 the customer expects delivery of that, having the delay

20 process in would be unworkable.

21 MR. EISNER: Let me ask again: is there

22 consensus that we should go ahead with the simple
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1 statement that preapproval is not necessary, not

2 required? Or do we want to talk about some more

3 substance? Anybody object to that simple approach?

4 MR. DOPPEL: Paul Doppel with Mitsubishi. I

5 agree with proceeding without preapproval, and

6 essentially that's what manufacturers are doing today

7 with certification programs at AHRI. So that would be

8 I think considered to be consistent with current

9 industry practice.

10 MR. EISNER: Yes.

11 MR. STARR: Louis Starr, Northwest Energy

12 Efficiency Alliance. I wonder if it might be possible,

13 maybe not requiring a preapproval process, but at least

14 some kind of documentation or at least kind of

15 anticipating what -- your AEDM and how it can be

16 organized.

17 So less of really -- it is more an intent of

18 what your AEDM is going to be, what this might help

19 with, as kind of identifying, making sure that someone

20 is coming up with a legitimate way of how they are

21 going to develop an AEDM. I'm wondering if that can

22 maybe be an alternate way of doing something.
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1 MR. EISNER: Ashley?

2 MS. ARMSTRONG: So what I think you are

3 asking - - and I'm going to try to translate -- is so

4 in the next couple of sections, we set out what we call

5 -- the Department uses nomenclature of what we call

6 substantiation requirements, and that is what types of

7 units have to be tested, how many units have to be

8 tested, how close the test values have to be to the

9 simulation values, to basically set up the AEDM.

10 Those records would need to be -- as they

11 exist today and as the proposal was written, those

12 records would need to be retained and provided if the

13 Department were to request them. But that package, in

14 and of itself, and all of the records, wouldn't need to

15 be sent in prior.

16 So I think what you are asking we will get

17 to, but it is kind of separate from whether the

18 Department should receive all of that information at

19 the outset.

20 MR. EISNER: Okay. Again, we can -- we say

21 in the ground rules we can go back to these issues if

22 it's necessary, especially with Ashley's caveat. What
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1 I would suggest we do, so there is a clear

2 understanding of what we've done, is have somebody from

3 DOE, as we go through each of these issues, write up a

4 simple one-sentence statement, if possible, of what we

5 agreed to and then we will have that as a working

6 document in front of us.

7 But on this particular first issue,

8 preapproval, we have agreement, so let's go on to the

9 next issue.

10 MR. SACHS: Neil?

11 MR. EISNER: Yes.

12 MR. SACHS: This is Harvey. And just one

13 last note on my lead balloon proposal. Didn't fly.

14 The Department does have a history of supporting the

15 development of some pretty elegant models that I

16 believe have been widely used as the basis in industry,

17 or for particularly to Keith Rice heat pump and air

18 conditioner model, which has been around and

19 continually improved for a couple of decades, developed

20 at Oak Ridge.

21 This ends my rant.

22 MR. EISNER: Okay. Ashley, do you want to do
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1 the next issue?

2 MS. ARMSTRONG: Sure. Jeremiah, can you go

3 to Slide 7 for me?

4 So I think this is generally the scope of

5 what we are talking about today in terms of what types

6 of equipment are on the table in terms of negotiation.

7 As I mentioned earlier, commercial air conditioning

8 equipment is a very broad category and subsumes quite a

9 number.

10 We got a variety of comments that are kind of

11 summarized on Slide 8 in terms of who should be allowed

12 to use AEDMs in response to the NOPR proposal and

13 whether there are other methods or, basically in my

14 mind, more direct methods that should be used instead

15 of an open- ended AEDM process for certain products.

16 So on Slide 9 we teed up the discussion of,

17 number one, whether we should explicitly -- you know,

18 for you guys to consider whether we should explicitly

19 just allow linear interpolation for commercial package

20 boilers and commercial water heaters instead of a

21 widely used AEDM. And then whether the AEDM should be

22 applicable to commercial air conditioning equipment,
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1 furnaces, and then refrigeration equipment.

2 And then there is a question about, is there

3 any certain types of equipment for which an AEDM should

4 not be applied? So that is the discussion to tee it up

5 for you guys.

6 MR. EISNER: Comments? Questions?

7 MR. SUTPHEN: This is John Sutphen, Cleaver8 Brooks. Can you just define the commercial package

9 boiler and the scope of what sizes are included?

10 MS. ARMSTRONG: Everything. Hold on one

11 second. This is Ashley, and I'm just reading from the

12 regs. But "commercial package boiler" means a type of

13 package, low pressure boiler, that is industrial

14 equipment with a capacity of 300,000 BTU per hour or

15 more, which to any significant extent is distributed in

16 commerce for heating or space conditioning applications

17 in buildings or for service water heating in buildings

18 but does not meet the definition of hot water supply

19 boiler. Does that help?

20 MR. SUTPHEN: What is your definition of "low

21 pressure"?

22 MS. ARMSTRONG: So we have a package --
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1 "package low pressure boiler" means a package boiler

2 that is a steam boiler designed to operate at or below

3 a steam pressure of 15 psig or a hot water boiler

4 designed to operate at or below a water pressure of 160

5 psig and a temperature of 250 degrees F, or a boiler

6 that is designed to be capable of supplying either

7 steam or hot water and is designed to operate under the

8 conditions at one and two above.

9 MR. SUTPHEN: Thank you.

10 MS. ARMSTRONG: Uh-huh.

11 MR. EISNER: Thoughts?

12 MS. ARMSTRONG: Jeff?

13 MR. KLEISS: Jeff Kleiss, Lochinvar. We are

14 encouraged by seeing the proposal to formally recognize

15 linear interpolation for commercial water heaters and

16 commercial boilers. I would like to hear reasons why

17 AEDM would be excluded as an option as well for

18 commercial water heaters and water boilers. We would

19 like to see that as an available option in addition to

20 linear interpolation.

21 MS. BARHYDT: Everything is on the table. We

22 are just throwing out ideas.
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1 MR. EISNER: I mean, I think it's appropriate

2 to ask why you think it should be.

3 MR. KLEISS: You're asking -- Jeff Kleiss.

4 MR. EISNER: What would be your justification

5 for extending it?

6 MR. KLEISS: Well, there are clearly two

7 different processes. One is based on testing. You

8 test two endpoints for linear interpolation. The AEDM

9 is more of a theoretical mathematical model that has a

10 few points tested for validation.

11 But either of those two have applicability,

12 depending on whether units are put together in discrete

13 product families or if you have a more diverse -- fewer

14 products built similar to I think what Frank Myers was

15 referring to, his type of products. One-off products

16 would probably be more suitable for an AEDM where you

17 are less likely to be able to generate samples of --

18 you know, on either endpoint.

19 But where it is -- you have smaller units

20 that are more likely to be built in larger quantities,

21 it is probably more practical to test two endpoint

22 products within a product family to validate linear
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1 interpolation.

2 MR. EISNER: Was there a reason you didn't

3 include it in your original list? Was there some

4 reservation you --

5 MS. BARHYDT: I believe the original proposal

6 just said AEDM, and we received a lot of questions

7 about, well, why isn't linear interpolation permitted?

8 And so our thought was, okay, what we are hearing is

9 that people are interested in having the option of

10 linear interpolation.

11 So it wasn't so much a -- we were trying to

12 put you in this bucket or that bucket. We were trying

13 to be responsive to some of the comments we received.

14 But is there a reason to not call it an alternative

15 efficiency determination method? Is there a reason why

16 linear interpolation is not just another way of

17 calculating -- of determining an efficiency other than

18 testing?

19 MR. KLEISS: Jeff Kleiss. A significant part

20 of that will come up I believe when we get into

21 substantiation and validation, because linear

22 interpolation is -- there are tests that are done,
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1 typically on the two endpoints of the spectrum, for a

2 product family. If we call it an AEDM, then we have to

3 have additional tests to substantiate the tests of the

4 linear interpolation. And if a product family is

5 discontinued or the program changes, then it changes

6 the validation based on the way the Federal Register is

7 currently written.

8 You're shaking your head no, but what I read

9 in print is quite different.

10 MS. ARMSTRONG: Go ahead.

11 MR. STANONIK: Frank Stanonik with AHRI. I

12 apologize for being late. I made the mistake of riding

13 Metro. In any case, I totally agree with Laura. We

14 should get over this little semantic thing.

15 Linear interpolation is most certainly -- it

16 may be a unique form of an AEDM, but it is an

17 alternative efficiency determination method. And,

18 Jeff, I think getting caught up in what the

19 requirements are going to be to have an acceptable

20 AEDM, whether it's linear interpolation or otherwise,

21 is something that will be resolved down the road.

22 But it is basically -- it is -- it is an
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1 alternative method, and it is one that in this case has

2 a lot of history and has -- and certainly in the case

3 of boilers has a -- let's say a fundamental principle

4 that gets applied, which is basically, you know, if I

5 have this much energy, I need roughly this amount of

6 heat exchange to get this much efficiency. It is

7 fairly straightforward.

8 Now, things change and there is things

9 evolving, but the underlying principle of the linear

10 interpolation is that my input and my heat exchange

11 surface area basically have roughly a linear

12 relationship in terms of what my efficiency comes out

13 to be.

14 And so I would -- if anything, as we develop

15 this, you know, maybe at some point we recognize linear

16 interpolation as a -- I don't know what to call it -- a

17 specific type of an AEDM, but I think we are getting

18 messed up by suggesting they are two different things.

19 They're not.

20 MS. BARHYDT: So what I would suggest, Jeff,

21 is not to get hung up with what you saw in the proposal

22 in terms of how much has to be tested of this or that.
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1 We are going to be discussing all of that. And so if

2 you can think of it not in terms of what our original

3 proposal was, but what you would like to see in terms

4 of requirements for testing when we get to that part of

5 the discussion, and whether or not that can all be

6 combined into one concept, or even if it is an

7 alternative efficiency determination method, but

8 perhaps there is a subset of different rules for linear

9 interpolation or just try and think more broadly about

10 how it would make sense to do it as opposed to, well,

11 this is what DOE proposed before.

12 MR. EISNER: Harvey?

13 MR. SACHS: There are a lot of people in the

14 room more knowledgeable about the area I'd like to

15 bring up than I am, and maybe they can reassure me.

16 But for some years I have been following from a

17 distance the discussions about the ASHRAE 155 rating

18 method proposed for commercial boilers, which among

19 other things, as I understand it, would change the

20 inlet temperature enough that we would start to see

21 strong effects of boilers that are able to do

22 condensing.
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1 Frank, for one, has been much more involved

2 in this than I am. And the question is, both for

3 condensing water heaters using the inlet water to

4 condense, and for package boilers, am I getting into

5 some second order effects as I get into lower rejection

6 -- condensation temperatures for the flue gases? And

7 are we confining ourselves to linear interpolation, or

8 is this going to enter at all if we see some change in

9 the test methods as condensing appliances become more

10 important?

11 MR. STEPHENS: Phillip Stephens, HTP. I

12 think that's the underlying premise that everyone seems

13 to be hitting on is that we are interested to know

14 DOE's opinion on if we can use empirical statistically15 based AEDMs, linear interpolation, possibly a quadratic

16 of some form, possibly something similar to the standby

17 loss requirements for storage tank water heaters where

18 it is a function of multiple variables. Is that on the

19 board?

20 MS. BARHYDT: So I think that when we talk

21 about how accurate your AEDM is, if you can generate

22 the model that will do it.
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1 MS. ARMSTRONG: This is Ashley. I think you

2 just explained our position pretty well. We don't care

3 what method you use, in and of itself, it is up to you

4 guys. You guys are the experts of your products. You

5 know, that is what the idea behind an AEDM is. It is a

6 simulation tool. Of what type, whether it's linear,

7 whether it's quadratic, whether it's something else,

8 whether it's, you know, first law based, whatever, that

9 is up to you. We don't have -- we didn't propose any

10 of those requirements for a reason.

11 So, you know, that was the Department's

12 position I think going in. Now, to the extent you want

13 to narrow the field to just linear, that is up to you

14 guys. But our opinion was that it is best left to

15 those who design the products.

16 MR. STEPHENS: Thank you.

17 MR. SACHS: This is Harvey again. Ashley, I

18 think the term "linear interpolation" has been red flag

19 in front of the bulls. We have hit on the linear side,

20 but the interpolation side also has an issue if we are

21 allowing the upper limit testing to be something within

22 25 percent of the largest unit, because then we are
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1 doing extrapolation to get to the big ones.

2 So I think if we could find another term,

3 you'd find several of us getting calmer.

4 MS. ARMSTRONG: Do you have a suggestion for

5 a term?

6 MR. SACHS: In a case of uncertainty, I try

7 to find a neutral term like "grape," which would mean

8 any method you want to use that you can verify.

9 MS. ARMSTRONG: That is -- I mean, we use

10 AEDM for that term, but yes, that's fine.

11 MR. EISNER: Let me read a comment from Ron

12 again. He says, "A combination of linear interpolation

13 and mathematical analysis can be combined to create an

14 AEDM. Interpretation of the Federal Register can be

15 clarified as we move forward."

16 And that's what I was starting to gather from

17 here is maybe we are talking about some rule text

18 language that we can agree to that it would be one

19 sentence or three sentences, and maybe we want to see

20 some guidance language that would go into the preamble

21 that would expand on that. So if anybody wants to

22 comment on that. We've got somebody at the microphone.
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1 MR. FLY: Well, this is a little different

2 subject. I would like to hear -- this is Mark Fly with

3 Aaon -- a little better definition of what commercial

4 air conditioning equipment, particularly the less than

5 five- ton area, because I think you have stated that it

6 is -- three-phase equipment is considered commercial,

7 but is single phase, package rooftop, is that a

8 commercial piece of equipment? It's typically used on

9 a commercial building, but it is -- you know, there are

10 chillers that are put on big residences, too, so what

11 is the Department's definition?

12 MR. EISNER: Everybody is testing Ashley's

13 knowledge of the CFR.

14 MS. ARMSTRONG: Yes. I am the CFR today.

15 Single phase, less than 65, is residential. I mean, I

16 can look up the specific definition, but single phase,

17 less than 65, is residential. Three phase, less than

18 65, is commercial, under our regs, air-cooled.

19 I understand they may get put in different

20 places in different situations, but under our regs

21 that's how our regulatory approach is.

22 MR. EISNER: Frank?
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1 MR. STANONIK: Ashley, one caveat, because I

2 just was schooled on this in the last couple of weeks.

3 When you are looking at residential products, the

4 hierarchy is consumer product, covered product, and

5 then unique products.

6 The legislation defines "consumer product" as

7 a product that is offered for sale for use by

8 individuals. And this came up in pool heaters, by the

9 way. That's where it all of a sudden hit me in the

10 face, if you will.

11 So if you had -- and unless there is

12 something different written about air conditioners, if

13 you had a single phase, less than 65,000 BTU air

14 conditioner, that you were not selling for use by

15 individuals, not to the consumer market, it is not a

16 covered -- well, we are going to have a debate here.

17 We can do it offline, too.

18 MS. ARMSTRONG: I think we need to move this

19 discussion offline, but that is incorrect.

20 MR. STANONIK: Okay. All right.

21 MR. COHEN: Who schooled you, Frank?

22 MR. STANONIK: Okay. That's fine.
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1 MR. SACHS: It was some engineering school in

2 Cleveland.

3 MR. STANONIK: Yeah. That's right.

4 MR. BAUMAN: This is Jeff Bauman from

5 National. I just want to get I guess a couple of

6 clarifications. My interpretation of like an ARM would

7 be something in my -- if you had it preapproved, it

8 would be something you could go buy a package off of a

9 shelf somewhere and say, "This is the software that has

10 been preapproved by DOE that I am going to go plug in

11 my -- for an ARM." Well, that's my interpretation of

12 an ARM.

13 So my interpretation, you know, whatever you

14 use as an AEDM, you have to validate that. As a

15 manufacturer, you have to validate that it is accurate

16 for your product, no matter where you got it, if you

17 bought it from somebody, if you made your own, if you

18 did a linear interpolation. And that's what I guess

19 I'm trying to -- to me, the only difference is -- would

20 there be any difference -- if somebody used a linear

21 interpolation, would the substantiation requirements be

22 different? So it is an AEDM.
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1 MS. BARHYDT: You would have to test some of

2 your products.

3 MR. BAUMAN: Right.

4 MS. BARHYDT: But as to what the ultimate

5 testing requirements might be, that's one or two --

6 MR. BAUMAN: Farther down.

7 MS. BARHYDT: -- segments down through the

8 slide package.

9 MR. STANONIK: Frank Stanonik with AHRI. And

10 one other comment in response to this question that was

11 called in, I think in trying to describe generically an

12 AEDM, I mean, there has to be -- there has to be some

13 I'll say mathematical underpinning to the AEDM, because

14 basically you are looking at models, and you are

15 applying the -- if you will, to whatever extent you

16 have, data from some models to other models, but there

17 has got to be some relationship that has been

18 established as to why you are confident that the model

19 you didn't test has this rating.

20 And underneath all of that there has to be

21 some basic -- not basic, but some math. Whether it's a

22 linear relationship, a quadratic relationship, or
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1 whatever, but there has got to be some connection

2 between how you -- when you are designing a product and

3 how you get Efficiency X for the one -- this one, and

4 how -- why you are comfortable saying, "Well, I know

5 from my experience in my technology, if you will, that,

6 okay, if this one has an efficiency of X, this one has

7 an efficiency of X plus .2 or something."

8 I mean, it's appropriate, but I think in

9 general there has to be -- you know, whether -- well,

10 it's obviously data, but there is also going to be some

11 establishment of the basic fundamental relationship

12 between the ones you measure and the ones you are

13 alternatively rating.

14 MR. EISNER: Other thoughts? Jill?

15 MS. HOOTMAN: Jill Hootman, Trane. A couple

16 more clarifications on covered equipment. You said

17 water source heat pumps. Geothermal? Ground source?

18 Yes?

19 MS. ARMSTRONG: I have to go back.

20 MS. HOOTMAN: That's the one I always forget.

21 Is it just geothermal, or is it geothermal and ground

22 source?
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1 MS. ARMSTRONG: It's both.

2 MS. HOOTMAN: Okay. And then, split systems,

3 you said systems up to 760,000, but what if it's a

4 condensed unit only? Test standard would be AHRI 365.

5 Isn't that up to 240?

6 MS. ARMSTRONG: Yeah. So split systems up to

7 240, A/Cs up to 760.

8 MS. HOOTMAN: A/C when it's an actual matched

9 system which --

10 MS. ARMSTRONG: Yeah.

11 MS. HOOTMAN: -- aren't sold. Okay.

12 MS. ARMSTRONG: Are you suggesting a new

13 covered product?

14 MS. HOOTMAN: No.

15 My point is that --

16 MS. ARMSTRONG: Just making sure I got that.

17 MS. HOOTMAN: -- typically, from 240 to 760,

18 they are matched in the field.

19 MS. ARMSTRONG: Right.

20 MS. HOOTMAN: They are not matched from the

21 company.

22 MS. ARMSTRONG: Gotcha. So just to wrap this
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1 up, I mean, it seems like generally there is support.

2 I'll let Neil take that part over. But I do want to

3 read our definition, because it seems to hinge around

4 our current definition as it stands in the CFR of an

5 AEDM. And I apologize for not putting this on the

6 slide, but it means "A method of calculating the

7 efficiency of a commercial HVAC and water heater

8 product that would then be extended to refrigeration."

9 In terms of the descriptor, use NRX

10 basically, paraphrasing the last part. Is there any

11 issues with that definition, such that it is extended

12 to the, you know, true product, all of the products

13 that it needs to be applicable to? Or is that simple

14 enough to cover it?

15 MR. EISNER: Do you need to see that on the

16 screen? Are you comfortable with what Ashley just

17 read?

18 MS. ARMSTRONG: It's in 431.2. All right.

19 MR. EISNER: Is everybody comfortable

20 with this definition? Would people like to see and

21 agree to some language, for example, a paragraph or so

22 that would go in a preamble explaining some of the
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1 things you were talking about, about how you establish

2 the reliability of the

3 AEDM?

4 MS. ARMSTRONG: We are going to get to that

5 next.

6 MS. BARHYDT: I think we are going to get

7 into that in more detail.

8 MR. EISNER: Is everybody comfortable, then?

9 Anybody object to the language that Ashley just read?

10 You'll get to see it typed up later as part of a

11 summary of what we have agreed to.

12 Okay. Let's go to the next issue.

13 MS. ARMSTRONG: Okay. Just to introduce this

14 topic -- this is Ashley from DOE again. What DOE terms

15 a "substantiation" in real terms just means, how many

16 units do I need to test? What type of units do I need

17 to test? And how close do my tested values need to be

18 to my simulated values? Those are really the three

19 questions at hand that we tried to answer with what we

20 call "substantiation requirements."

21 So if you look on Slide 11, this was our

22 original proposal in the Notice of Proposed Rulemaking.
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1 And in response to this, I think we had hours' worth of

2 conversation at the public meeting, as well as a number

3 of different comments that came in in terms of how many

4 units should be tested, what types of units from

5 different product classes, from different models, one6 offs, all types of different things.

7 I am not going to go through the details of

8 the comments here. We put them as background just to

9 tee them up.

10 But on Slide 17, we have tried to tee up some

11 of the issues for discussion. And this really gets to,

12 you know, what is the minimum level of number of tests,

13 types of tests, types of products to be tested, and the

14 tolerance that needs to be -- how close the test data

15 needs to be to the simulation. So put everyone

16 basically on a level playing field across the board,

17 and so that is really for you guys to discuss.

18 It didn't seem from the comments that there

19 was a single opinion shared by a same person, at least

20 from my review of them. Everyone kind of does

21 different things right now. So maybe the first issue

22 to talk about would be, how many of -- what is the
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1 minimum tests that even need to be done to substantiate

2 an AEDM before it can be used?

3 MR. EISNER: Before we get to the first --

4 MS. ARMSTRONG: Oh, sure.

5 MR. EISNER: -- comment, Ron has a question.

6 Is substantiation and validation the same?

7 MS. ARMSTRONG: No.

8 MR. EISNER: Did you hear that, Ron?

9 MR. SHEBIK: Yes, I did. Thank you, Ashley.

10 MS. ARMSTRONG: One is before it can be used,

11 so it is manufacturer-driven, right? So the

12 manufacturer would substantiate their AEDM. They would

13 do their own testing, they would, you know, determine

14 what types of units. If we had specific criteria, they

15 would determine which units they wanted to test. They

16 would come up with their model. They would compare

17 their model. This is all done by them in-house before

18 they then apply.

19 I look at validation, or maybe a better word

20 other than validation is verification, as on the back

21 end. Once an AEDM is widely used, then you can pull

22 products from market or products from distributors, or
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1 whatever, test them, and say, "Okay. You know, they

2 already are rated. How close is that?" You are

3 verifying at that point.

4 MR. SACHS: I'm sorry, but is --

5 MS. ARMSTRONG: I don't think it's the

6 wording so much as, what do they need to do before it

7 can be used?

8 MR. SACHS: The wording definitely threw me

9 off, because I am taking this as validation, which I

10 would expect to do as the owner of the model, to be --

11 MS. ARMSTRONG: That's fine. Maybe that's a

12 better word.

13 MR. WHITWELL: Verification, as you described

14 it, though, is that enforcement?

15 MS. ARMSTRONG: It can be. It can be

16 enforcement by the Department. It can be verification

17 that you do post in your lab. It can be verification

18 you do through a third party program. It would be

19 anything after an AEDM has already been applied.

20 So feel free to change this wording.

21 Everything is on the table, I mean, if you don't throw

22 it out. This is just what we use now and it was a part
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1 of the proposal. But if validation is better, or

2 whatever, anything is fine. Just a word.

3 MR. SACHS: Thank you.

4 MR. EISNER: Yes.

5 MR. STEPHENS: Phillip Stephens, HTP. I

6 think we are getting into the realm where we need to

7 have the discussion on what constitutes a basic model,

8 a basic model group, because this is where these become

9 important.

10 MS. BARHYDT: So I was hoping we could put

11 off the basic model discussion to the next time. Is it

12 possible to have this discussion in the context of for

13 you to run a model and make a representation about

14 something you want to make a representation about?

15 Whatever that thing is, can we have the discussion in

16 terms of how much do you have to test to come up with

17 your representations?

18 Irrespective of what ultimately gets turned

19 in to the Department for certification, just if you

20 want to make a representation and you are going to get

21 that representation from your model, how much do you

22 have to test to come up with that number?
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1 MR. EISNER: Guys?

2 MR. DOPPEL: Paul Doppel with Mitsubishi.

3 You know, it might have an impact, because I think at

4 this point we are not close on model number definition.

5 So that could impact I think maybe the number of units

6 that have to be tested. If we can get maybe, you know,

7 the -- what is the other term, the product class?

8 Maybe if we can at least get product class clarified,

9 because then that really has the impact because you

10 have to at least test one from each product class.

11 MS. BARHYDT: Do you have to test one from

12 each product class?

13 MR. DOPPEL: That is kind of what I

14 understood from --

15 MS. BARHYDT: Well, that was DOE's proposal.

16 That is not --

17 MS. ARMSTRONG: Why don't we just start the

18 discussion, what do you do now?

19 MR. EISNER: Somebody doing something right

20 now?

21 MS. HOOTMAN: I'll start. Jill Hootman from

22 Trane.
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1 MR. DOPPEL: Can we claim the Fifth? No.

2 MS. ARMSTRONG: We are trying to inform where

3 we should go here.

4 MS. HOOTMAN: Jill Hootman from Trane. So,

5 yeah, definition of "class" and what we all might call

6 a family. In our minds, what a family is, and each one

7 of these manufacturers probably does have a different

8 definition of what they consider a family, but they

9 have developed a set of products that has an outward

10 bound, has boundaries.

11 I would say that we test one to two of those

12 against a simulation program in development. So, in my

13 idea, a product family could be -- and I'm going to

14 give an example, a three- to 10-ton package heat pump.

15 I have probably tested the smallest and the largest,

16 because those are my outliers, and then simulated the

17 rest of the ratings for the simulation model.

18 Now, my definition and somebody else's

19 definition of a product family is going to be

20 different.

21 MS. ARMSTRONG: So how do we start to

22 standardize those for a given just subset or baseline
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1 of "This is the minimum that needs to be tested"? And

2 then, beyond that, you guys are welcome to test more or

3 --

4 MS. HOOTMAN: And then I would say, to add on

5 to that, your word of "validation," there is considered

6 validation every single time units are pulled for AHRI

7 testing or whatever, other reasons. There is

8 validation coming back against those models.

9 MS. ARMSTRONG: So are there common

10 components that are the same of a given product family?

11 I realize this will change between product types, but

12 in the case - - is the condensing unit always the same?

13 Is the compressor unit always the same? I mean, is the

14 heat exchanger area the same? I mean, what are we

15 talking about that really gets to, how do you do it

16 now? And it may be that everyone does it differently,

17 or every product is different, or every -- both. But

18 that's what we're trying to understand, so help us

19 learn.

20 MR. FLY: This is Mark Fly with AAON. For

21 AHRI testing, a basic model group, for let's say

22 unitary large, unitary small, is a compressor/condenser
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1 combination indicates a model. I think that is

2 correct, isn't it, Frank? So the compressor/condenser

3 area and then everything else is kind of appendages on

4 that theme, so that defines a basic model.

5 In an AHRI testing, validation testing, they

6 can pull any listed model, which there may be several

7 under each basic model, at random to do the validation

8 test. So you could have a four-row coil and a six-row

9 coil. It would be -- an evaporator coil, and that

10 would still be in the same basic model, but it would be

11 -- and they could pull a four or a six for their

12 testing.

13 MR. RIVEST: This is Mike Rivest. In reading

14 the comments, and in trying to find the common themes,

15 it seemed to me that the basic model grouping was sort

16 of a parallel to what is needed to do an AEDM. The

17 reason I bring that up is because we are talking about

18 what is the minimum number of tests, and that really

19 would depend on the scope of your AEDM.

20 You could call something an AEDM that

21 encompasses everything, if it's just one spreadsheet

22 with multiple tabs or it could be an AEDM that you
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1 tailor to a product family.

2 So if saying, like DOE says, five tests is

3 sufficient to validate an AEDM, that can be a very big

4 burden if you have defined your AEDM as applicable to

5 one family and you have 100 families, or it may be not

6 much of a burden at all if you define your AEDM as

7 encompassing all of your products.

8 I think the way these slides were prepared an

9 AEDM was envisioned as something that would be over all

10 of your product families. So the burden was quite

11 small. You know, we talk about going across -- in this

12 case, it's not product classes; substantiation classes

13 is the way it's defined.

14 So, and the discussion of the basic model

15 group and the compressor with the heat exchanger, that

16 really goes to the basic model. You know, your

17 simulation is going to model some physical system and

18 put a number on it. And that is really what this

19 conversation is about.

20 Your conversation has more to do with, well,

21 do I need to come up with a rating for all of my SKUs,

22 or only for the -- sort of the core model. And with
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1 the other ones, with all of the accessories, do I have

2 to model all of those and rate them all differently, or

3 can I just have one rating?

4 So there are two conversations here, and this

5 conversation is more about what is an AEDM, how broadly

6 does it apply, and how many tests do we need to

7 substantiate it? Is that helpful?

8 MR. SACHS: Well, Mike -- go ahead.

9 MS. HOOTMAN: Thanks, Harvey. Jill Hootman

10 at Trane. I would agree that it was looking at it,

11 especially if you are a manufacturer like myself, that

12 has multiple products everywhere, it probably is

13 looking more broad-reaching. But what if I'm a

14 manufacturer that only makes, in my example, three15 through 10-ton heat pumps. I now have to do five

16 tests, you know, to substantiate my AEDM? That could

17 be literally all of my products in that three- through

18 10-ton.

19 MR. RIVEST: And I do believe there is -- you

20 know, that is something that the Department is seeking

21 comment on. You know, if there is --

22 MS. HOOTMAN: Right.
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1 MR. RIVEST: -- a manufacturer with a

2 limited, you know, product offering, should it be

3 reduced?

4 MS. HOOTMAN: Yes.

5 MR. SACHS: This is Harvey. I guess I've

6 been part of hearings across a whole lot of products

7 for the last decade, as Frank and you have, Ashley. My

8 sense is that it -- across product classes, no, across

9 product types, these four terms may be used quite

10 differently in CRE, at DOE, in commercial unitary.

11 And we are going to continue to flail unless

12 we either have category commercial boiler -- let's call

13 that category -- category-specific definitions of these

14 terms, or all of industry is going to have to change

15 its vernacular, because any two people at this table

16 may mean something very different anywhere on the

17 spectrum from basic model to basic model group to

18 product class to product family.

19 And that, to me, has been part of the hurt.

20 And I don't -- I'm not sure that DOE would want to

21 impose its definition across all of these industry

22 products that are tested so differently, have such
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1 different market structures.

2 MS. ARMSTRONG: So just one clarification. I

3 think from the Department's perspective the name you

4 use to call something and whether it needs to be what

5 we are going to call covered product-specific, so by

6 refrigeration or HVAC, fine. You know, to the extent

7 we can come up with -- that's what this is for.

8 To the extent we can come up with a wording

9 definition that everyone agrees on, whether it's

10 specific to CRE, specific to boilers, specific to water

11 heaters, fine. I don't think the Department has an

12 opinion there.

13 Product class has a meaning under our regs,

14 so that one is a little unique to DOE, and it has a

15 generalized meaning, even though it is applied product

16 specifically. In our regs, when we set standards, it

17 is statutory, so that is something that it has, you

18 know, requirements. But to the extent we come up with

19 product family or Ashley model, or whatever, it is

20 fine. We don't care what we call it; we just want it

21 to work.

22 MR. SACHS: I'd take the next step and ask if
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1 it would be appropriate to ask each of the manufacturer

2 groups here to give us, if not now then at the next

3 meeting, their definitions of how they and their

4 industry use basic model, basic model group, and

5 product family.

6 MR. KLEISS: Jeff Kleiss, Lochinvar. Could I

7 suggest, to move this forward, that we start with the

8 current DOE definition of "basic model," discuss that,

9 see if we can agree to that as a definition, and use

10 that as a foundation to build from.

11 MS. ARMSTRONG: Sure. Although, so before we

12 do that, is everybody in agreement that they want to

13 transition this discussion from AEDMs to the basic

14 model issue? Because that is, on the list of issues, a

15 different issue.

16 MR. KLEISS: Jeff Kleiss, Lochinvar. It is

17 my belief that you are trying to build the second story

18 of the house without laying the foundation. Basic

19 model, basic model group, those are foundation issues.

20 MS. ARMSTRONG: It's up to you guys.

21 MR. DOPPEL: Paul Doppel with Mitsubishi.

22 You know, possibly, I mean, we are getting close to
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1 lunch, just as a thought, we could break into like

2 common type of products and have a working lunch to

3 come up with a definition. Just --

4 MS. ARMSTRONG: That's a great idea.

5 MR. DOPPEL: -- as a thought for -- basic

6 model for our various industries, and then come back

7 with that.

8 MR. EISNER: Break up now and --

9 MR. DOPPEL: I'm not saying now, but over

10 lunch.

11 MR. EISNER: Oh. To discuss it over lunch?

12 MR. DOPPEL: Yeah. Come up with a definition

13 over lunch of what the basic model is.

14 MR. EISNER: Comments/thoughts/objections?

15 Frank?

16 MR. STANONIK: Question, Paul. Are you

17 talking about a general definition of "basic model" or

18 a basic model air conditioner or a basic model boiler?

19 MR. DOPPEL: Right. For each of the --

20 MR. STANONIK: Five categories.

21 MR. DOPPEL: -- boiler, water heater, HVAC.

22 MR. STANONIK: Yeah. I think I would agree
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1 with -- that makes a lot of sense, because I think once

2 we see what each of you that knows your product has in

3 mind, we in fact may see where the similarities are, or

4 where they need to be distinguished.

5 MR. RIVEST: This is Mike Rivest. Before

6 everyone sort of defines it differently, because I know

7 that's what is going to happen, I think it's important

8 to keep in mind what the purpose of the basic model is.

9 And it may have nothing to do with, you know, the

10 common usage of basic model for your own purposes.

11 But DOE needs to have a product model number

12 and a rating next to it. And my experience has more to

13 do with white goods, so I'll speak to that, and then

14 you'll have to figure out how that works for your own

15 industries. But a clothes washer manufacturer

16 basically has the same platform, that it has all sorts

17 of additional features, if you will, that don't really

18 impact the rating. Okay?

19 So I'm not saying that's what -- the basic

20 model that you need to use, but that's how they do it.

21 And they have a catalog number that is this long, and

22 then there are a whole bunch of numbers after that that
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1 describe what those features are, but that are not

2 relevant to the rating. So DOE just needs a way to

3 track that particular model number to the unit of

4 certification.

5 So the unit of certification is the one that

6 you can test and rate. So if you pull something off

7 the shelf, there is a model number, and you want to

8 reference it back to a database. You would find what

9 that -- you know, those first digits are, and that's

10 what the rating should be.

11 So ultimately there is a need to have a

12 specific rating for basic models, as defined now.

13 Where there has been I think some controversy is

14 whether or not inside the box things have to be the

15 same. Right?

16 I know for a fact that ballast manufacturers

17 have multiple bills of materials. And for them a basic

18 model is interoperability, and you substitute one for

19 the other. But they can -- inside the box they can be

20 very different, depending on the price of materials.

21 Transformers is the same way. It's an interoperability

22 issue. Take one, put the other one, does it work. But
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1 they can be made out of different steels, completely

2 different designs.

3 Again, it's driven by the cost of materials

4 on any given day when they build it. So when I read

5 comments, sometimes people use the word "basic model"

6 as a way of saying, well we only -- there are a lot of

7 accessories, and in this industry it sounds like

8 sometimes those accessories can impact the rating.

9 And should they be certified individually

10 based on their own test results and their own modeling,

11 or should they be certified based on what you might

12 call the bare bones model. And so when you pull a

13 model out of distribution, you would -- you know, you

14 might test that unit, and you may not get the same

15 rating as the certified model, the basic model, because

16 those accessories were added.

17 So I think this becomes a discussion about,

18 when you test, which accessories should you be looking

19 at? Does that --

20 MR. EISNER: Karen?

21 MR. RIVEST: And it's different for white

22 goods, because they are -- it's different for white
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1 goods.

2 MS. MEYERS: On that we agree, yes.

3 MR. RIVEST: But a basic model, it has got to

4 be something that you can trace to a -- when you pull a

5 product and you test it, and you look in the

6 certification database, you can say, "Okay. This is

7 what we are measuring it against."

8 Whereas, I have seen in comments, definitions

9 of basic model, that say that you -- basic models can

10 have different ratings. Well, maybe as you apply it,

11 they can. But as far as DOE is concerned, it has to

12 have the same rating. It doesn't have to have the same

13 physical construction, but it has to have the same

14 rating. And I think interoperability is kind of

15 embedded in that. All right?

16 So you can't have a basic -- in DOE's mind,

17 having a two-ton unit and a 10-ton unit, that can't be

18 the same basic model. They can be certified using the

19 same AEDM. They could be part of the same basic model

20 group. And I don't even think we need the term "basic

21 model group" anymore. We just need an AEDM that can

22 come up with a rating for a particular product, and
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1 then we have to decide what a basic unit is, so that we

2 don't have to test everything.

3 MR. BAUMAN: This is Jeff Bauman from

4 National. I just want to get clarification also on -- a

5 manufacturer, the way I'm reading it, has -- and,

6 again, our discussion about basic models kind of came

7 out of how many tests we have to do to substantiate or

8 verify, or whatever you want to call it, pre-verify an

9 AEDM.

10 Whether you have 100 or 1,000 basic models,

11 that doesn't affect how many tests you have to do to

12 substantiate your AEDM. That just -- it goes to how

13 you apply your AEDM when you are using it. So my

14 opinion is we ought to stay on AEDMs. I think the

15 issue of basic models needs to be discussed as we move

16 along, but that doesn't affect how you are going to

17 substantiate an AEDM if that was the issue on the table

18 when we were first talking.

19 MR. EISNER: I have a comment from Ron. I

20 don't know if he might change his mind as a result of

21 earlier discussions, but he says, "We will not be able

22 to successfully move forward until everyone agrees to
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1 the BMG definition." Other thoughts?

2 MR. KLEISS: Jeff Kleiss, Lochinvar. I would

3 like if DOE would please read what the current

4 definition of a basic model is, and if we can get an

5 assessment from the manufacturers at the table whether

6 or not that is reasonable and useful, and then maybe we

7 can move forward.

8 MR. THARP: This is Rusty with Goodman. 10

9 CFR 431 actually has a different definition of "basic

10 model" for the various products; correct?

11 MS. ARMSTRONG: It's the same, though. It's

12 the same.

13 MS. BARHYDT: It's more or less the same.

14 MS. ARMSTRONG: Okay. Are you ready? "Basic

15 model means all units of a given type of covered

16 product, or class thereof, manufactured by one

17 manufacturer, having the same primary energy source,

18 and which have essentially identical electrical,

19 physical, and functional or hydraulic characteristics

20 that affect energy consumption, energy efficiency,

21 water consumption, or water efficiency." That one

22 happened to be the commercial package boiler one, but
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1 they're identical for the products we're speaking of

2 here.

3 MR. RIVEST: Mike Rivest again. As I read

4 that, as I hear that, I don't think so much about what

5 is inside the box as what is coming out of the box, the

6 interoperability, so the same electrical, mechanical.

7 That means that you can take out one and put the other

8 in, and it will provide, if it's a ballast, the same

9 voltage, the same amps.

10 MS. ARMSTRONG: Yeah. I mean, the Department

11 has clarified that, and the only thing we have said is

12 it has the same rating. So, in other words, you can

13 change out things as you may like, but at the end of

14 the day it comes out with the same efficiency.

15 MR. RIVEST: Right. Well, it has to have the

16 same --

17 MS. ARMSTRONG: It says "essentially," so

18 there is some --

19 MR. RIVEST: Essentially the same electrical,

20 mechanical.

21 MS. ARMSTRONG: Essentially.

22 MR. DOPPEL: Paul Doppel with Mitsubishi.
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1 That becomes problematic for split systems because what

2 -- you know, you've got the common condenser, but then

3 you end up matching that condenser with various air

4 handlers or things of that nature. And then you can

5 end up with different efficiency levels.

6 And also, within our product types, you have

7 different voltages, which essentially you get the same

8 ratings; you are just operating at a different voltage.

9 And so that would -- this would kind of imply that each

10 voltage would be a different model, and then each

11 efficiency level would be a different model.

12 MR. RIVEST: Not if it doesn't affect the

13 rating.

14 MR. EISNER: Can you go to the mic?

15 MS. ARMSTRONG: So can I ask you a question,

16 two questions. One is you said, "This is the issue."

17 What exactly is the issue? Is it that you want to rate

18 them at the same level? Is it that you need a single

19 simulation to rate them all, you don't want to test

20 them all? What is the issue?

21 MR. DOPPEL: The issue becomes a condenser

22 should be the base model. That should form the base
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1 model, because that is the primary --

2 MS. ARMSTRONG: For what, though? For

3 testing?

4 MR. DOPPEL: For testing. For every -- and

5 for model number and for a model, and then whatever it

6 is connected with, and then I think that in some way

7 applies to the package units, too, because there is --

8 like it's a basic unit, and then everything that you

9 connect that with comes off of that. So that, then,

10 should be the base model.

11 MS. ARMSTRONG: Okay. So --

12 MR. EISNER: Why should that be the base

13 model for testing, if I understand you to say each one

14 would give you a different result?

15 MR. DOPPEL: Because you can simulative off

16 of that.

17 MS. ARMSTRONG: So is it your opinion that

18 each base model should be tested to substantiate an

19 AEDM?

20 MR. DOPPEL: No. It's just coming up with

21 the definition of what a base model was.

22 MS. ARMSTRONG: So I think we're mixing
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1 terms, right? So there's two things -- and we can take

2 the terms off the table -- what you test and then what

3 you actually put a number on, how you rate, right?

4 So the question of basic model for DOE's

5 purposes is -- we have used them both ways, but it is -

6 - we have said they have to have the same rating. We

7 don't say every basic model has to be tested; we say a

8 subset of them. So it's a matter of --

9 MS. HOOTMAN: Say they have some rating that

10 -- the same rating -- sorry, this is Jill Hootman from

11 Trane. You say that they have to have the same rating,

12 but you also say that they have to have the essential

13 identical power. So here is the problem. You can have

14 - - I have a model number that has 47 digits; 19 of

15 those digits have something to do with energy.

16 Nineteen of those digits I can literally have

17 a different system kW; therefore, a slight difference

18 in SEER when I change motor vendors. And I have five

19 approved motor vendors.

20 So, yeah, you're right. I mean, I do shop

21 motor vendors. At any one time I could have different

22 motors in there. It is de minimis, I would say, in my
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1 definition. It's very de minimis. We are out into the

2 decimal points, but it is a different system kW.

3 So if you were to pull it, and you were to

4 test it, it would be a different system kW. We would

5 likely rate that in a grouping at the lowest common

6 denominator, but, still, it is a different system kW.

7 MR. RIVEST: You know, in transformers, for

8 example, some transformers have multiple voltages.

9 They can operate at -- you know, at -- they are called

10 TAPs, and we basically tell them to rate that -- the

11 one that gives you the least deficient rating.

12 MS. HOOTMAN: Right. And that's what I'm

13 saying is I --

14 MR. RIVEST: And that can be the same basic

15 model.

16 MS. HOOTMAN: -- likely would, but in

17 actuality it is not the same identical. It is not

18 essentially identical.

19 MR. RIVEST: Okay.

20 MS. HOOTMAN: So the definition --

21 MS. BARHYDT: So we can tweak the words

22 MR. RIVEST: Right.
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1 MS. ARMSTRONG: What are the words that we

2 want to --

3 MS. HOOTMAN: Well, that's where, I mean, I

4 sort of agree with Paul, if we can come to a common

5 description amongst our product or the manufacturer

6 groups, or however you want to --

7 MS. ARMSTRONG: Is your common description

8 for what has to be rated or what has to be tested?

9 Because they are very different things.

10 MR. RIVEST: I think we are talking rating

11 here, because testing -- you just have to test five and

12 get --

13 MS. HOOTMAN: Right. And we would also have

14 to have verification. And if that verification comes

15 in significantly different --

16 MR. RIVEST: That verification would be

17 against the --

18 MS. HOOTMAN: -- and one is significant

19 versus --

20 MR. STEPHENS: Phillip Stephens, HTP. Aren't

21 we really asking what the allowable tolerance is for

22 the AEDM?
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1 MS. HOOTMAN: Part of it is the tolerance.

2 MR. STEPHENS: Because if it's inside the

3 allowable tolerance, then it would be acceptable,

4 right?

5 MS. HOOTMAN: Part of it is that. I agree.

6 MS. BARHYDT: So some of this seems to me,

7 again, while I personally don't really understand why

8 the definition of "basic model" is important to AEDM,

9 and how much you have to test, because how you

10 ultimately end up making those determinations of these

11 -- if I switch out these five different motors, and

12 it's de minimis difference, is that going to change the

13 way you do your model?

14 MS. HOOTMAN: No. It's not going to change

15 the way we do our model. In fact, we wouldn't have

16 tested all of those five, and may not necessarily know

17 we are --

18 MS. BARHYDT: So the question for

19 substantiation --

20 MS. HOOTMAN: -- knowing that there is a

21 variation.

22 MS. BARHYDT: -- is how much do you have to
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1 test to be able to run your model? It's not -- we

2 don't have to say, "Test five basic models to have an

3 AEDM." We don't have to say, "Have three different

4 product classes to have an AEDM."

5 We can say -- for the purposes of discussion,

6 what we're saying is, "You tell us what you need to

7 test to be able to do your AEDM." If it's individual

8 models, if it's basic models, if it's basic model

9 groups, if it's product classes, if it's, oh, I can

10 have an AEDM that will predict CRE, HVAC, and

11 commercial package boilers."

12 We're saying, "You tell us what you need to

13 test to be able to come up with a good model." And

14 without the terminology, without the ideas of, well, I

15 grouped this way, and I grouped that way, what do you

16 need to test? How many tests do you need to have, and

17 how broad do you need to be testing to come up with a

18 good model?

19 MS. ARMSTRONG: And I think from the

20 Department's perspective, it is not that we have an

21 opinion on a minimum threshold. It's that a lot of the

22 comments seem to reveal that there should be some type
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1 of minimal level playing field. In other words, these

2 should be the minimum requirements that are required

3 across the board.

4 And then, from there you guys are the

5 experts. You guys come up with your models. You guys

6 pull -- you weight your tolerance versus your

7 manufacturing practices from there. But there did seem

8 to be some of the comments that say, "DOE should have a

9 minimum threshold at least for those people wanting to

10 use an AEDM to get into the market." What is that

11 minimum threshold? What should it be? What does it

12 look like?

13 MR. KLEISS: Jeff Kleiss, Lochinvar. In

14 terms of if testing is required for a basic model, DOE

15 has stated that there need to be a minimum --

16 MS. BARHYDT: Real quick. For clarification,

17 so we are talking the -- what do I have to test? I do

18 not have an AEDM? Or what do I have to test so I can

19 use an AEDM? Because those are different.

20 MR. KLEISS: Apart from an AEDM, if I have a

21 basic model, DOE has stated that you have to test --

22 run at least two tests, so that you can have
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1 statistical evaluation to validate that basic model.

2 Now, if we are using that basic model to

3 substantiate or validate an AEDM, therefore, you have

4 to have at least two tests of that basic model.

5 MS. ARMSTRONG: That's now how the regs are

6 proposed.

7 MR. KLEISS: Okay.

8 MS. ARMSTRONG: That's not how the existing

9 AEDMs are written, or regs are written, or what was

10 proposed. It was a single test for what we're calling

11 substantiations less validation.

12 MR. KLEISS: Okay. So then only if we are

13 going to define a product or a product family as a

14 basic model, then we would have to have two tests to

15 validate that --

16 MS. ARMSTRONG: If you are going to use the

17 route of testing, period, to come up with a rating,

18 certification testing requires two. If you are going

19 to use simulation methods to come up with your rating,

20 then you follow the simulation route. There are two

21 separate routes leading you ultimately to a rating.

22 You can pick which one you use. That's the premise
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1 behind our regs. That's not to say that -- but that's

2 the idea.

3 Manufacturers, at the outset, this is

4 everything I make. I can choose the testing, purely

5 testing route, in which Mike would be happy, or I can

6 choose, you know, a combination, mostly simulation with

7 some first behind testing, and then some subsequent

8 testing just to make sure.

9 And the question is, which route do you

10 choose is totally up to you. Our regs provide an

11 avenue for both right now, and that's what we're

12 discussing today.

13 MR. KOJAK: This is Mike Kojak with UL. I

14 had a question. Why should you set a minimum of

15 testing to set for an AEDM when it should be up to the

16 manufacturer because they want to be able to pass. If

17 they are being verified by the DOE, they want to make

18 sure that their AEDM is accurate.

19 So if they want to just do one test, and it's

20 not that accurate, well, when they get verified, then

21 they are going to be caught that it is not that

22 accurate, and they will have to do the testing and
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1 everything anyway.

2 MS. BARHYDT: So something that we received a

3 lot of comments on to the original proposal was that a

4 lot of manufacturers felt like if there wasn't some

5 minimum amount testing up front, it would be too easy

6 for manufacturers to pick numbers, stick it out there,

7 and gamble on whether or not they were caught, and that

8 there needed to be some minimum amount of testing up

9 front to make sure that there was at least some

10 disincentive for people to just make up numbers.

11 And so how much -- how to weigh that concern

12 against the burden of testing is an open question. But

13 that was the concern that was expressed by a lot of

14 different people in the comments.

15 MR. KOJAK: It's Mike Kojak again. So, but

16 wouldn't you think the manufacturers would want to have

17 as accurate AEDM as possible by doing plenty of

18 testing? So, you know, if the DOE so happens to --

19 MS. ARMSTRONG: I would say, ask them.

20 MR. KOJAK: -- to pick your product for a

21 third party lab to verify that it's actually going to

22 be hitting the numbers that you came up with with your
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1 AEDM?

2 MS. ARMSTRONG: I would say, ask you guys in

3 the room. I mean, we got comments that said there

4 should be some minimum amount. There should be some

5 minimum amount. Are you comfortable with not having a

6 minimum testing requirement and letting anyone, no

7 matter if they are new into the market or anything

8 else, using an AEDM at will, with no minimum

9 requirements on it?

10 MS. DANE: This is Mary Dane at Traulsen. I

11 have to go along with what Mike is saying. It is in

12 the best interest of a manufacturer to make sure that

13 their AEDM is very strong. And so, therefore, you

14 know, I don't -- I think that's why some people are

15 asking about the models is because, you know, depending

16 on the breadth of your model family, you would have to

17 test -- you could test one, you could test more.

18 It should be up to the manufacturer to decide

19 how we substantiate our own mathematical equation,

20 because when we get to verification the costs of these

21 tests, the time it takes to run, just the effort that

22 we put into it, is not going to mean -- I mean, we are
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1 not going to try to fudge the numbers and then get to

2 verification and find out we have products that don't

3 qualify.

4 So I think that the -- I understand what your

5 comments say, but I wonder if there was a disconnect

6 over whether they were talking about substantiation or

7 validation or enforcement, because they are all three

8 different things. And I would say at the

9 substantiation level it is the manufacturer's

10 responsibility to make sure that whatever mathematical

11 equation they choose is strong enough to pass

12 certification testing.

13 MR. THARP: Rusty Tharp with Goodman. I'd

14 like to throw in that, you know, one of the things I

15 think we all may not understand is that there is -- in

16 testing, there is uncertainty, uncertainty just from

17 the measurement aspect. And I think that it is --

18 there is enough uncertainty that we would not want to

19 say that a manufacturer could go in -- any manufacturer

20 could go in with one set of test data to base their

21 AEDM on.

22 And I think probably something I should have
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1 just said earlier, it would be good I think if we made

2 a differentiation between those manufacturers that are

3 part of a voluntary industry certification program and

4 those that are not, because those that are a part of

5 the VICP will have their products validated later, you

6 know, on a continual basis. But those that are not

7 part of a VICP, or those that can go for months or

8 years putting product in the field that are not

9 compliant, would not be caught.

10 So I would just suggest that maybe even to

11 the point of, you know, we already moved off the topic

12 of preapproval, but maybe we would say that preapproval

13 is not necessary if you are a VICP. But if you're not

14 part of a VICP, then you do need preapproval for --

15 MR. EISNER: Is that the nub of the issue,

16 that there will be -- it will be too difficult for DOE

17 to enforce or ensure compliance if there is not a

18 minimum level of testing required?

19 MR. THARP: If they are not part -- if their

20 manufacturer is not part of VICP, I would say yes.

21 MR. EISNER: But if you're part of one of

22 these special groups, I assume you are meeting the
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1 minimum level that DOE was suggesting.

2 MR. THARP: Correct. Yes, that is true.

3 MR. EISNER: So you're afraid others won't

4 meet that, if not required to, and it will be difficult

5 for DOE to pick up all of the violators.

6 MR. THARP: Correct. So I would say that,

7 you know, if one of my competitors that are in the room

8 who are part of AHRI, if they want to test one and do

9 their AEDM, I'm personally fine with that because I

10 know that they will be audited, and that I also have a

11 method through AHRI of challenging their ratings, and

12 also -- but if somebody is not part of AHRI

13 certification programs, then it is much more difficult

14 for me to challenge those ratings. It takes a little

15 bit longer to do that.

16 MR. EISNER: And does DOE have a perspective

17 on the minimum number, in terms of whether you can

18 enforce compliance satisfactorily if a manufacturer

19 determines how many tests it is going to do? Or do you

20 feel there has got to be some minimum level of testing

21 done?

22 MS. BARHYDT: Enforcement would be based on
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1 testing after the fact. It wouldn't be based on the

2 test -- well, I guess it could be based on the test up

3 front, if it turned out that they hadn't done the

4 testing, if we have minimum requirements, but --

5 MR. EISNER: If you have minimum

6 requirements, as I understand it, they are going to

7 have to meet that before you do any compliance checks.

8 MS. ARMSTRONG: We can check with --

9 MS. BARHYDT: We can check.

10 MR. EISNER: You can check what? I'm sorry.

11 MS. BARHYDT: We can do compliance testing

12 regardless of whether they are using an AEDM or not.

13 MR. EISNER: What I think I'm hearing around

14 the table is a concern that you can't do enough

15 compliance checking to get the bad guys in all

16 situations who wouldn't do enough testing. And are you

17 disagreeing with that, that you would have the

18 resources to get all of the bad guys out of the

19 marketplace? I mean, it's easier -- as I understand

20 it, it's easier to go and check a record and see, did

21 you do the two tests that were required, than it is to

22 go out and do the tests and find out they failed.
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1 MS. ARMSTRONG: So I think for the most part

2 -- I mean, there are some caveats, but for the most

3 part our enforcement regs would require us to test

4 anyway. So we would -- regardless of whether they

5 tested up front, you know, put aside the fact that they

6 didn't do anything, but if they did test, they had test

7 data that showed they were compliant or they had

8 substantiated their AEDM and met the minimum

9 requirements.

10 In order for us to show noncompliance, we

11 would have to test anyway. Period.

12 MR. EISNER: You would have to test anyway to

13 do it, but would there be a violation for failure to do

14 the required tests up front?

15 MS. BARHYDT: If there was a substantiation

16 requirement, yes.

17 MS. ARMSTRONG: But it's not noncompliance.

18 MS. BARHYDT: But it's a different kind of a

19 violation.

20 MR. EISNER: Any other reactions? Charlie?

21 MR. HON: Charlie Hon. Is there any --

22 because we as an industry test our competitors all of
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1 the time. It is an ongoing event. Everybody in this

2 room tests some of their competitive units. What

3 happens when we discover that our competitors we know

4 are cheating?

5 Do we turn them into you and then you proceed

6 with -- do you have an action process to do that? And,

7 if so, you will probably never get to your own

8 validation testing, because we have so many people

9 running around doing other things. They could easily

10 be pointed out to you.

11 MR. CYMBALSKY: We haven't gotten that email

12 yet.

13 MS. BARHYDT: We do have a process for

14 enforcement testing.

15 MS. ARMSTRONG: I mean, I think it's fair to

16 say to date we have plenty of bandwidth to do both.

17 MS. BARHYDT: Right.

18 MR. EISNER: Before we go on, Ron has a

19 question online. Or a comment, rather. Ron?

20 MR. SHEBIK: I'm sorry, Neil. Did you say

21 Ron?

22 MR. EISNER: Yes. Ron Shebik?
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1 MR. SHEBIK: Yeah. Actually, I'm kind of --

2 I had a comment kind of going along with what Charlie

3 just commented on. There is too much at stake for

4 manufacturers to just throw out numbers. And as

5 Charlie just mentioned, we would be nato think that we

6 are not watching what our competitors are doing.

7 So we kind of have a pretty good idea of what

8 our competitor case is, looking -- again, commercial

9 refrigeration, we have a pretty good idea of how our

10 competitors' cases operate. So kind of going back on

11 some earlier discussion, I think the need to focus so

12 hard on basic model groups, maybe that is not actually

13 a reality, because the AEDM that we develop is going to

14 be developed to make sure it includes all of our

15 products, regardless of how you define a basic model

16 group.

17 MR. EISNER: Any comments? Frank?

18 MR. STANONIK: Frank Stanonik with AHRI. I

19 think this conversation started with the question of

20 whether there should be some minimum criteria for an

21 AEDM. And I think if you are going to accept, which I

22 totally agree with, that there is no preapproval
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1 requirements, I think there needs to be a minimum.

2 You know, it is all true. Every

3 manufacturer, you know, certainly knows what they need

4 to do for their own products. Okay? But the fact is

5 that the test procedures have their nuances, okay? The

6 test procedure -- you have to learn how to do the test

7 procedures. Everybody's product may have their own

8 little unique little -- what they hope is little

9 advantages or whatever.

10 And I think that, yeah, everybody, you know,

11 wants to do everything that is right, but competition

12 is a double-edged sword, and certainly is a wonderful

13 thing, you know. But in any case, I think it is useful

14 to -- in the circumstances where there is no

15 preapproval requirements, they have some minimum

16 definition of what would be, let's say, an acceptable

17 AEDM.

18 Even in our own programs, if we have somebody

19 entering in the AHRI program who is totally new to

20 this, okay, so we have no knowledge that they, let's

21 say, have experience in running DOE test procedures, or

22 they are totally new to the program, we apply some
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1 different criteria to that new manufacturer entering

2 the program, because, you know, there just isn't that

3 history.

4 Now, you know, I think everybody sits there

5 and thinks, well, we're talking about, you know,

6 everybody who has been in the business. Well, let's

7 just say that, you know, I wanted to set up Frank's Air

8 Conditioning Company because I was insane I guess to

9 get into that business and didn't know anything about

10 air conditioning, but I'm going to be out there, you

11 know, competing with everybody else.

12 And, quite frankly, I would -- you know, if -

13 - well, certainly in my case, if you asked all of the

14 manufacturers, well, would you let Frank determine what

15 his AEDM is going to be? They'd better say no, because

16 I would probably -- you know, without the knowledge and

17 the experience, and the fact I'm trying to get into the

18 market, I'm probably going to undershoot what would

19 really be needed. I mean, to me that's just, you know,

20 a practical consideration.

21 MR. EISNER: I'm having trouble getting

22 through this gap here where DOE seems to believe it has
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1 enough of a compliance program to ensure that whatever

2 number of tests have to be done will have been done or

3 the product will fail and they will be able to go after

4 the company.

5 And I'm hearing from apparently the

6 manufacturers that they are not satisfied that this

7 will get the bad guys. Is it because they won't get

8 them quick enough, or they won't get them in the end,

9 and why? What is the concern?

10 Harvey, do you want to speak on behalf of the

11 manufacturers?

12 MR. SACHS: This is Harvey. I want to speak

13 on behalf of broader community, and we have a case

14 study within the last five years of a product class

15 that is not in itself regulated, but a component of mix

16 and match air conditioning systems where it appears

17 that one manufacturer really did use simulations to

18 consistently defy the laws of physics and got away from

19 it -- got away with it for a number of years for a

20 variety of reasons, including some reluctance of AHRI

21 to intervene and get tough for whatever reasons.

22 And I think that is the gorilla in the room
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1 now that -- how do we make it just difficult enough for

2 someone who is determined to cut corners to get away

3 with it for years? And I think everyone in the room

4 probably remembers that case, and I may not have all of

5 the particulars right, but there were an awful lot of

6 rebates given for products that were way deficient in

7 terms of their field measured performance and back

8 calculating to their test performance as well.

9 MR. EISNER: Others?

10 MR. SACHS: Let me just say I don't know what

11 the answer is, but I think that is the pervasive fear,

12 not only in industry but in other groups. Marshall

13 would probably verify that the utilities are not real

14 comfortable with giving rebates for defective

15 equipment, and things like that.

16 MR. MYERS: This is Frank Myers.

17 MR. HALLEY: Geoff Halley with American

18 Boiler Manufacturers Association. I have been sort of

19 struggling all morning with the fact that I am

20 representing a group of manufacturers who have very

21 different capabilities in terms of engineering and

22 testing, and so on and so forth.
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1 And, in fact, a lot of them have got a lot of

2 historical data based on certain rules that have

3 prevailed in the boiler industry for a long time. And

4 in many cases they can meet the DOE published minimum

5 efficiency standards with what they have. Does the

6 historical data play any part in this situation or not?

7 MS. BARHYDT: So the proposal of the

8 Department was that the testing had to be done in

9 accordance with the DOE test procedure. But there is

10 nothing that says it has to -- the testing has to start

11 at some point after the date in which the final rule is

12 published.

13 So if someone had test data that was done in

14 accordance with the DOE test procedure prior to the

15 date of the rule, there is no reason why that couldn't

16 be used.

17 MR. HALLEY: Right. The next thing is that

18 some of the people who are making larger units don't

19 have the capability of testing them in-house, and I

20 don't think there is a facility such as UL or people

21 like that who can verify their efficiency claims until

22 they put them in the field. At that point, the
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1 operating parameters could be entirely different to the

2 standards that DOE have set forth there, for example,

3 BTS 2000.

4 MS. BARHYDT: So the issue there is that

5 there is no realistic way to actually test the full

6 spectrum of products being offered.

7 MR. HALLEY: Right. And so you can't test

8 the extreme ends of a spectrum of sizes. You've got to

9 test some smaller sizes to verify the AEDM.

10 MS. BARHYDT: So DOE's original proposal was

11 to require testing I believe within 25 percent of the

12 top range.

13 MR. HALLEY: Yeah.

14 MS. BARHYDT: But, again, we are asking you,

15 what do you need to be able to test to be able to come

16 up with a valid simulation?

17 MR. HALLEY: Well, I think, you know, some

18 manufacturers, for example, who get into the

19 institutional marketplace may have boilers that have

20 got a 30 million BTU input. And their lab facilities

21 may only be able to accommodate, I don't know, nine or

22 10 million BTU input. I don't know whether anybody
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1 else wants to comment on that, but --

2 MR. SUTPHEN: This is John Sutphen at

3 Cleaver- Brooks. We make hot water boilers, 2,000

4 horsepower, which is very difficult to test in-house

5 without spending a little over a million dollars in

6 equipment. And to be able to test the lowest and the

7 highest range on certain boiler models of those

8 capacities is just -- it doesn't make sense using the

9 BTS 2000 parameters.

10 We have done for the last 60 years -- used

11 the ASME PTC-4 efficiency calculation method, and

12 through other testing we have verified that it is a

13 very accurate method of determining efficiency on fire

14 to boilers. We propose that it is included as an

15 alternate efficiency test in lieu of the BTS 2000 or

16 anything else that is proposed. It's just --

17 MS. BARHYDT: So I think that was one of the

18 test procedure issues that was raised in the first

19 meeting that we said would be a test procedure issue

20 for a rulemaking outside of the scope of this

21 rulemaking.

22 MR. SUTPHEN: Okay.
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1 MR. EISNER: We've got somebody at the

2 microphone, but, first, I've got three questions here,

3 two from Pantelis. Does DOE understand the process

4 AHRI is using to validate the published data? His

5 second question is, what would it take for DOE to

6 accept the existing AHRI process of validation for

7 VCIP?

8 MS. ARMSTRONG: VICP.

9 MS. BARHYDT: So I think that's a secondary

10 question. I mean, to the extent we still have the

11 issue of, what do you do for people -- I mean, to the

12 extent we get to the portion of the negotiation to talk

13 about verification programs, what they look like, what

14 do we accept, should the requirements be different, we

15 still have the issue of, what are the requirements for

16 those people that are not members?

17 And so what -- I mean, to Frank's point, you

18 said maybe there should be some or maybe you could

19 explain, what do you require in your program of new

20 entrants? And what are some ideas here? What should

21 be that minimum level for either people that aren't

22 getting regularly verified or for people that are new
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1 entrants to a verification program, or whatever it is?

2 That's really what we're talking about here.

3 And then, to the extent we want to differentiate later

4 between those and not, I mean, you still have this

5 minimum threshold that needs to be met always. So that

6 is where we are.

7 Ideas?

8 MR. MYERS: This is Frank Myers, PVI

9 Industries.

10 MR. EISNER: I've got one more question for

11 somebody who has been holding online. Bruce Helft has

12 a comment. Bruce? Are you still there, Bruce?

13 (No response.)

14 Okay. Go ahead. Did you want to -- we may have lost

15 him.

16 MR. MYERS: From the outside here, it has

17 really been interesting seeing the -- this is Frank

18 Myers, PVI Industries -- seeing the round and round of

19 this. We are going from how many tests are needed for

20 an AEDM to how do we catch the bad players to what test

21 program and how large a unit in a lab can be.

22 I would really like to attempt to have the
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1 group stay on task as close as possible. And to that

2 end, I agree with a much earlier statement by Frank

3 Stanonik -- and this is coming from a manufacturer who

4 works very closely with AHRI. I participate on the

5 rule-writing process as a non-voting member on how the

6 programs work, the certification programs work, but

7 make build-to-order type equipment that doesn't really

8 fit that program very well.

9 So I am kind of on both sides of that issue,

10 but I agree with Frank that there does need to be some

11 validation testing. I think that should be part of the

12 requirement. I think that information should be turned

13 into the Department, so that they know that it has been

14 done, but that you don't have to wait to sell the

15 product for that review to take place.

16 Now, whether that is one unit or five units

17 with two of them being in the most -- the highest

18 volume, and three being the manufacturer's choice of

19 what best validates their AEDM, I do think there should

20 be some, and I think that information should be turned

21 in.

22 With reference to a much earlier statement
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1 that I tried to comment on, I don't think this program

2 can be the technique by which we catch all of the bad

3 players. AHRI has a mechanism internally that can take

4 care of its own bad players. It also has the process

5 where you can take somebody that doesn't participate in

6 the program and check theirs.

7 Likewise, I think it is very potent for

8 manufacturers to be able to provide information to DOE,

9 so that they can take action. And I think if we have a

10 well-defined program, AEDM program, that has a certain

11 number of tests required and a part of that makes clear

12 to the manufacturers that must turn that validation

13 information into the Department, they are going to know

14 that they are at risk.

15 And if they are bad players, the industry

16 will catch them because we watch each other like a

17 hawk, and we will either turn it into AHRI or to DOE or

18 take those steps that will get those bad players out of

19 the market. I don't think we can do that on the front

20 end beyond making sure that they meet the minimum

21 requirements that this group establishes for the AEDM.

22 MR. EISNER: Other comments/suggestions? I
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1 agree, we do seem to be on a variety of different

2 places, and we don't seem to have much consensus on any

3 one of these positions so far. There was some talk

4 about having manufacturers at least get together during

5 lunch to talk about whether they can come up with an

6 approach. Anybody want to talk about that?

7 MS. HOOTMAN: I was just going to answer your

8 earlier question. Minimum is two tests for

9 qualification.

10 MS. ARMSTRONG: No matter the scope of the

11 AEDM?

12 MS. HOOTMAN: No. When you were asking about

13 how many for qualification into AHRI programs, minimum

14 is two tests. Some programs are more than that, but

15 the general OM is minimum two tests for qualification

16 to even get into a program.

17 MR. STANONIK: Are you asking about the

18 difference?

19 MS. ARMSTRONG: Yeah, yeah. So just help me

20 understand that. By "programs," do you mean like into

21 the small unitary? Is that a program?

22 MR. STANONIK: Yes.
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1 MS. HOOTMAN: Uh-huh.

2 MS. ARMSTRONG: And then large would

3 separate. So it's basically by the test procedure?

4 MS. HOOTMAN: 360 would be separate.

5 MS. ARMSTRONG: Okay. I mean, so that's --

6 yeah, that's pretty much like ours.

7 MS. HOOTMAN: That is just the minimum. Each

8 one of those programs might have something different.

9 For instance, VRF has something different, which

10 actually goes more than that. I would say that is the

11 minimum.

12 MR. RIVEST: Why don't we start with that.

13 MR. KLEISS: Jeff Kleiss, Lochinvar. I think

14 I have been one of the main drivers as far as the whole

15 basic model's foundational argument, and I'm willing to

16 set that aside and move forward. I'm recognizing that

17 how we use the basic model and how we substantiate our

18 products is test-based. What you are talking about is

19 AEDM-based.

20 And I believe that there is some

21 misunderstanding as far as what is -- how we believe

22 that AEDM applies to that or the potential test burden
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1 that it applies. I am willing to set that aside so we

2 can move forward and talk about substantiation and

3 validation, and then hopefully uncover those problems

4 there.

5 So I can -- I will quiet down about basic

6 model, so we can move forward.

7 MS. BARHYDT: So do you have a suggestion for

8 substantiation?

9 MS. ARMSTRONG: Hey, Jeremiah, could you put

10 up Slide 18?

11 So, yeah, to get to your point -- and this

12 doesn't match up identically to what you're talking

13 about exactly, but one of the options we just floated,

14 we are calling substantiation classes, but basically,

15 you know, you would test something from each of these

16 categories. And this is just to start the discussions

17 with an idea.

18 And maybe this level of disaggregated classes

19 isn't necessary -- maybe more is necessary; I don't

20 know -- but to start the conversation with an idea.

21 MS. HOOTMAN: So as you have them grouped

22 there -- this is Jill from Trane -- the air-cooled
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1 split systems and the air-cooled package obviously are

2 under one AHRI program, split by tonnages of course,

3 65,000 BTUs and less, and 65,000 BTUs and above.

4 MS. ARMSTRONG: All of them? All the way out

5 to --

6 MS. HOOTMAN: So the AHRI program for 210/240

7 would be a minimum of two for air-cooled split systems

8 and packages.

9 MS. ARMSTRONG: Okay.

10 MS. HOOTMAN: Likewise, for above 65,000 and

11 above, it's a minimum of two.

12 MS. ARMSTRONG: Okay.

13 MS. HOOTMAN: So it wouldn't be two splits

14 and two packages I guess is what we are trying to say.

15 MS. ARMSTRONG: But it would be four for that

16 category. Is that accurate?

17 MS. HOOTMAN: No, it would actually only be

18 two.

19 MS. ARMSTRONG: But even though you have

20 small -- even though you have less than 55 --

21 MS. HOOTMAN: Oh, okay. Yeah, you're right.

22 Minimum of four across all of that. You're right.
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1 MS. ARMSTRONG: And that would carry you all

2 the way up to 72 tons, 70 tons, whatever.

3 MS. HOOTMAN: Right, right.

4 MS. ARMSTRONG: Okay.

5 MS. HOOTMAN: Right, right. You know, we

6 really don't have water-cooled split systems right now

7 in a certification, nor water-cooled packages, nor

8 evaporatives. One of those things we still have to get

9 done.

10 Single package, vertical unit, those would be

11 a minimum, too, and package thermal air conditioning

12 would be a minimum, too.

13 MS. ARMSTRONG: And then, VRFs aren't on

14 there, but they would be the same, a minimum of two?

15 MS. HOOTMAN: And I didn't see water source

16 heat pumps up there. Or are you just saying that those

17 are in the water-cooled split systems?

18 MS. ARMSTRONG: Yeah. They are not separated

19 out. Okay. So they would be a minimum of two separate

20 from --

21 MR. DOPPEL: Paul Doppel with Mitsubishi. So

22 with the air-cooled package, then that would include
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1 gas packs, A/C, and heat pumps, all in one. So the

2 water- cooled split system could include VRF, and the

3 air-cooled split system could include VRF.

4 MS. ARMSTRONG: But does AHRI have separate

5 certification programs for VRFs?

6 MR. DOPPEL: Yes.

7 MS. ARMSTRONG: Okay. And it would be the

8 same, two.

9 MS. HOOTMAN: Minimum of two.

10 MS. ARMSTRONG: Minimum of two.

11 MS. HOOTMAN: There is actually rules in some

12 of these cases where we've got more than that, but --

13 MS. ARMSTRONG: And is that allowed to be

14 done in a manufacturer's lab, or does that have to be

15 done in a third party lab?

16 MR. DOPPEL: Third party.

17 MS. HOOTMAN: Third party lab.

18 MR. DOPPEL: Third party.

19 MR. STANONIK: When they are entering the

20 program.

21 MS. HOOTMAN: When they are -- yeah, the

22 qualification process, yeah.
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1 MS. ARMSTRONG: So are those good minimum

2 qualification requirements that we should consider for

3 any entrant, as a minimum threshold? Why or why not?

4 MR. STEPHENS: When you say "minimum," do you

5 mean testing in a third party lab?

6 MS. ARMSTRONG: No, no, no. I just mean

7 generally what you just laid out for what is required

8 to enter an AHRI --

9 MR. STEPHENS: For the AEDM.

10 MS. ARMSTRONG: Yes.

11 MS. HOOTMAN: Sorry. Jill from Trane. If

12 somebody wasn't already in a VICP, yes, I think that

13 that would be a good minimum requirement. But if we're

14 already there, I don't feel like we need to step up

15 more testing.

16 MS. BARHYDT: If you're already there, do you

17 already have those tests?

18 MS. HOOTMAN: In some cases, we've been there

19 for 50 years, so probably. I'm a little doubtful if

20 that paper is still around, but anyway.

21 MS. ARMSTRONG: But in theory, you would also

22 have verification tests from a percentage of units from
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1 the past couple of years that could also supplement.

2 MS. HOOTMAN: So that's HVAC. Does anyone

3 want to explain how it works for CRE?

4 MR. HATCHER: Charlie Hatcher, manufacturing.

5 A quick one for you, because you have eight models

6 listed there. There are air crawl (ph) versions and

7 remote versions of each of these. There are

8 refrigerators, and there are freezers of each of these.

9 So, therefore, we're sending you up into the 20s. But

10 some of these categories are so broad-spectrum that

11 they really are not the same products within product

12 categories.

13 We will sell a four-cubic-foot countertop

14 refrigerator. We will also sell a 74-cubic-foot roll15 in refrigerator, all which that falls into the closed16 door category; certainly not within realm of each

17 other. We will see display cases with a single glass

18 door, with glass door and glass on each side, with two

19 glass doors, one opposing the other, and glass on each

20 side, all of which are totally different products.

21 In third-party verified testing, Energy Star

22 covers a lot of these products. We have 68 -- no, 78
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1 products which have been third-party verified

2 completely, and most of them would fall into separate

3 categories, and variations from that that take it 107

4 even more. So the categories get quite large.

5 MS. BARHYDT: So based on that test data, can

6 you model it? And what pieces do you need to include

7 in order to be able to come up with that model?

8 MR. HATCHER: In some cases, we could model

9 that. In a lot of cases, we've developed models to

10 predict, but we still have variation within the test as

11 well, because that's where we get into these

12 discussions, which we started. With all these

13 different possibilities we have, we probably end up

14 with 80 or 90 base models. There's maybe 180 base

15 models, depending on how we split them out.

16 And then we have validation testing within

17 those units, and then we also have done -- we've done a

18 lot more validation testing than that, but it is -- it

19 -- the numbers just keep amplifying, because if you

20 take our basic SKUs, you can come up with 18,000

21 possibilities. And if we use the word "identical" in

22 that 18,000, we have a real problem.
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1 Yeah. But it is -- it is in the regs, so

2 that's where our problems come in.

3 FEMALE SPEAKER: (Inaudible).

4 MR. HATCHER: Right. Yes. So that's where

5 we get into these questions of, you know, when you're

6 building a boiler, they just get progressively larger.

7 When you get into decorative and marketing tools, they

8 go in multiple directions. That's where it becomes

9 very, very difficult to break out when you get a base

10 model. We can develop, and we have developed, a fairly

11 sophisticated system to understand what goes on in our

12 equipment, because we make a lot of it, yet we have --

13 we don't know the definition of how accurate is

14 acceptable.

15 MS. ARMSTRONG: That's next.

16 MR. HATCHER: That's the problem that we're

17 now getting into, because we have a lot of test data,

18 and we know where we're headed with our ideas of what

19 we consider validation of a model, but we also have the

20 spectrum of tolerance within that validation, because

21 we have done tests on a single unit.

22 They take a unit and put it in the test room
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1 and change one condition in the test which is within

2 the specification of the test range, and change 8 to 12

3 percent inside that range, with one variable condition

4 change, all within the standard.

5 If we get to 12 percent variation in that

6 unit, even within the same piece of equipment, we have

7 a problem, because we can change 4 variables and make

8 it change 15 percent, well within the same spectrum and

9 legal test.

10 MS. ARMSTRONG: So -- this is Ashley. So,

11 Charlie, a question from you -- for you. I think you

12 said you had between 80 and 90, roughly, base models.

13 MR. HATCHER: That's being -- that's being --

14 MS. ARMSTRONG: Okay. On the conservative,

15 let's just say it's 80 or 90 for --

16 MR. HATCHER: Yes.

17 MS. ARMSTRONG: -- discussion purposes. Are

18 you proposing that someone, at a minimum, would need to

19 test that amount of models to have a valid AEDM, and if

20 not, what --

21 MR. HATCHER: Well --

22 MS. ARMSTRONG: -- would a fraction of that
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1 look like?

2 MR. HATCHER: The question is, do you have to

3 develop an AEDM for each base model, because there are

4 differences in the way they react.

5 MS. ARMSTRONG: Wouldn't that be dependent

6 upon you?

7 MR. EISNER: Yes.

8 MR. HATCHER: In some, it would.

9 MR. EISNER: If you were -- if you were DOE,

10 what would you feel was necessary?

11 MR. HATCHER: That's the problem, is that I

12 believe we need to not necessarily build a number, but

13 build a statistical validity model. That is the

14 standard clear practice in statistics, is you build

15 your base model. You verify your base model. You

16 verify how far off your statistical normality is, if --

17 by a test, and if it's too far off, then you have to

18 bring your -- you have to modify your model.

19 MR. EISNER: So for the 80 or 90, how many

20 base models would you have? One or --

21 MR. HATCHER: Oh, we would have 80 or 90 base

22 models.
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1 MR. EISNER: But I thought you said no to the

2 question of would you have to test all 80 or 90.

3 MR. HATCHER: Well, I think that we would

4 have to test at least some sample of every one of these

5 base models, and we've already done that, because a lot

6 of these products were regulated in 2007 and have yet

7 to be reported. So we've had the data sitting in the

8 queue for a long time. We have a lot of information.

9 And that's one of the problems we've had with the DOE

10 is the fact that there's never been any real submittal

11 because of delays and other issues that are going on.

12 MR. EISNER: So how would you write the rule

13 to cover your segment of the industry? What would you

14 say?

15 MR. HATCHER: I would say that you would have

16 to be at least 90 percent confidence level of your

17 model, of your modeling, within a 12 to 15 percent

18 variance as far as the unit -- because the units

19 themselves, I can take the same model, the same --

20 right off the line and end up with 5 or 6 percent

21 variation all the time. That is inherent in the

22 components, as much as 10 percent variation from one to
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1 the other.

2 So we have to come up with a discussion here,

3 statistical validity versus capability of the system.

4 And statistically, we keep looking at 15 percent

5 variance as normal, and I don't know how the government

6 deals with that.

7 MR. EISNER: Government?

8 MS. ARMSTRONG: Well, can I ask a question

9 first? This is -- this is going to Frank. Frank, do

10 you guys have an up-and-running program for commercial

11 refrigeration equipment?

12 MR. STANONIK: Running? Yeah.

13 MS. ARMSTRONG: And what is your minimum

14 threshold and categories for which you guys run it, and

15 what is your tolerance?

16 MR. STANONIK: This is Frank Stanonik with

17 AHRI. I'd have to check back at the office. I don't

18 have that --

19 MS. ARMSTRONG: Does anyone that's --

20 MR. STANONIK: -- that knowledge.

21 MS. ARMSTRONG: Does anyone know that's

22 either on the phone or
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1 MR. EISNER: Ron, are you on the phone? This

2 is something --

3 MR. SHEBIK: Yeah. Yes. This is Ron Shebik,

4 Hussmann. Yes, I'm on the phone, but I do not have the

5 answer for that.

6 MR. EISNER: Is this something we can

7 MS. HOOTMAN: (Inaudible).

8 MR. EISNER: Is this something we can get

9 over lunchtime, or is it harder to get than that?

10 MR. STANONIK: I can get it at lunchtime.

11 Yeah, Frank Stanonik, AHRI. I can get it at lunchtime.

12 MR. EISNER: You want to wait until we have

13 that information before we go on to the rest of what

14 Charlie was talking about?

15 MS. ARMSTRONG: No, I mean, I think at some

16 point, we're at -- I mean, we are at the point where if

17 I did my math correctly, Jill, you know, you're between

18 testing 14 and 16 at a minimum if you make products

19 that span the whole range for HVAC.

20 MS. BARHYDT: But if you only make a small

21 subset of that, it would be as low as two.

22 MS. HOOTMAN: Yes.
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1 MR. MUCCIOLA: This is Vince Mucciola. I

2 wanted to back on commercial, if I could, for one

3 second. You talked about SPVUs, but earlier I heard

4 you say that under 65,000 single phase, that would be

5 residential. Could you clear that up, Ashley? Or is

6 SPVUs a separate class all on its own and doesn't

7 qualify under residential? I just wanted to clear

8 MS. ARMSTRONG: So the answer is yes, SPVUs

9 are a separate product class all on their own. They

10 can be single-phase and three-phase. However, they do

11 have to meet the definition of SPVU, and they cannot

12 meet the definition of central air conditioner and heat

13 pump. So the short answer is yes, but there are some

14 subtleties there, so we should probably further flesh

15 that out offline.

16 MR. EISNER: We're getting close to offline

17 time. Anybody else have any comments? Maybe we should

18 think about taking a break for lunch.

19 MS. DANE: Mary Dane, Traulsen. Just as a

20 point of clarification for my own -- have we -- we

21 decided substantiation and verification are two

22 different things? Because I'd prefer not to use them
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1 interchangeably, because substantiation, I feel, is a

2 manufacturer's responsibility. Verification is what we

3 turn over to you.

4 MS. BARHYDT: So substantiation, I think, the

5 way we're using it, is testing required prior to using

6 the AEDM for commercial purposes.

7 MS. DANE: Okay.

8 MS. BARHYDT: And verification is anything

9 after that.

10 MS. DANE: Right. So given that, based on

11 part of what Charlie said, and it runs true in

12 commercial refrigeration, especially with different

13 kinds of refrigerators and display cases, I would say

14 that we would want to just control that ourselves

15 without having that dictated to us, and then what is

16 verified would be something different.

17 MS. BARHYDT: With no minimum?

18 MS. DANE: No minimum. It would be --

19 MS. BARHYDT: Zero?

20 MS. DANE: -- up to the -- that -- well, it's

21 up to the manufacturer to decide how many models to

22 test to strengthen and validate his own AEDM. I mean,
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1 we've got to start somewhere, so -- because, I mean, if

2 I have to do 80 miles, it takes a week to run a test.

3 We're a small -- you know, we're a smaller

4 company, and, you know, maybe some of these are higher

5 sellers, lower sellers, low -- valid -- you know, low

6 quantity of numbers. We don't want to build everything

7 we have an inventory -- or a SKU for to run a test on,

8 so as far as limiting myself to the word

9 "substantiation," that should be up to a manufacturer,

10 and then we'll discuss verification testing, because

11 we're part of an Energy Star program where we do

12 testing already for that for our other -- our other

13 models. So, yeah, substantiation, zero.

14 MR. SACHS: Oh, I'm referring direct -- this

15 is Harvey Sachs -- referring directly back to Charlie's

16 urging us to take a statistical validity approach, and

17 then the AHRI dogma of two units, unless you're a new

18 guy, and --

19 MS. HOOTMAN: Two units when you are a new --

20 MR. SACHS: It's who -- yeah, it's when you

21 are a new guy. Excuse me. And just sort of the

22 historical question -- Frank may be the only one old
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1 enough to know -- was that -- was that based on some

2 sort of statistical analysis, or was that just an

3 arbitrary threshold that was chosen?

4 MR. STANONIK: What, the two number? Frank

5 Stanonik, AHRI.

6 MR. SACHS: Two.

7 MR. STANONIK: Yeah, I don't know. It goes

8 further back than me, so it must be like going back to

9 who knows when, but I think it was just better than

10 one. I think it was --

11 MR. SACHS: Well, it's just --

12 MR. STANONIK: -- that was about it. I mean

13 MR. SACHS: There's just sort of an irony

14 here that in the standard-setting processes, there's an

15 enormous amount of very detailed analysis and Monte

16 Carlo simulations and all this sort of stuff. When it

17 comes to this ADM -- AEDM process, we're sort of voting

18 on hunches. Just an observation. I don't know any

19 other way to do it right now.

20 MR. STANONIK: Just -- Laura, just -- Frank

21 Stanonik, AHRI. I have to react to Harvey's comment.

22 I mean, that's kind of true, but I think we all should
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1 not lose sight of the fact -- certainly in the case of

2 the manufacturers that I know, they're all painfully

3 aware that, okay, yeah, there's all this AEDM stuff and

4 everything, but there's a pretty big stick at the end

5 of the line there and so that if, in fact, they don't

6 have their proper ratings and they can't validate that

7 stuff, you know, there -- there's a very significant

8 potential penalty that I don't think they ignore.

9 MS. MEYERS: And then this is Karen with

10 Rheem, and just to follow on to what Frank said,

11 there's an annual requirement that you test a third of

12 your basic models every years. So in addition to once

13 you get validated, a third of your basic models are

14 getting tested every year.

15 MS. HOOTMAN: Depends on the program.

16 MS. MEYERS: That's true.

17 MS. HOOTMAN: Twenty to thirty.

18 MS. MEYERS: Twenty --

19 MS. HOOTMAN: Say 20 to 30.

20 MS. MEYERS: Twenty to thirty.

21 MS. HOOTMAN: Yeah.

22 MS. MEYERS: Twenty to thirty.
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1 MS. ARMSTRONG: And that's condenser -- for

2 your industry, condenser/compressor combinations,

3 right?

4 MS. HOOTMAN: And the packaged units.

5 MS. MEYERS: Okay. Water heaters, boilers.

6 MS. BARHYDT: And that's in-house?

7 MR. THARP: No.

8 MS. MEYERS: No.

9 MS. BARHYDT: Third party?

10 MS. MEYERS: That's third party.

11 MS. BARHYDT: Okay.

12 MS. MEYERS: That's done at a third party, so

13

14 MR. THARP: Rusty Tharp with Goodman. I'll

15 throw in that if -- again, it probably should be a

16 function of whether you're part of a VICP or not.

17 MS. ARMSTRONG: Okay. So I'm going to take

18 this back one more time, just to see if we can at least

19 get something -- an agreement. Take verification aside

20 and whether you're part of a program aside, because we

21 will deal with that. That is on the table, and how to

22 deal with that is on the table.
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1 But say you're not. Our minimum set of

2 requirements are for those that aren't. They need to

3 apply across the board. Is there a majority, or do we

4 have some type of consensus where there should be

5 minimum requirements?

6 MS. MEYERS: This is Karen with Rheem, and

7 I'm going to say yes, and I'm going to say those

8 minimums should be higher if you are not a member of a

9 VICP, where you've got constant checking going on and

10 validation of those. So what Jill gave you was a

11 minimum of two, and I think that's great if you're, you

12 know, getting into a VICP program. But if you're not,

13 I think your requirements should be that -- higher.

14 MS. ARMSTRONG: Can you suggest something?

15 MS. MEYERS: Well, first let's go -- let's go

16 to the first-level part.

17 MS. ARMSTRONG: Do we have consensus that,

18 yes or no, that there should be a minimum set of

19 requirements?

20 MR. STEPHENS: Phillip Stephens, HTP. I

21 would have -- I would agree with minimum requirements,

22 yes. I would be concerned with having smaller,
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1 innovative companies with significantly higher

2 requirements for initial product releases, because

3 typically, by the time an industry is mature, most of

4 the players are members of the AHRI and do participate,

5 but the smaller manufacturers that possibly only have a

6 few SKUs, those are typically the ones that don't

7 participate in AHRI.

8 MS. ARMSTRONG: Okay.

9 MR. EISNER: Does anybody disagree with

10 having minimum requirements? Because earlier there was

11 some disagreement. So nobody --

12 MS. DANE: Because the minimum is zero. And

13 I knew at the start, so --

14 MS. ARMSTRONG: That would be disagreeing.

15 MS. DANE: Oh, okay, then I disagree.

16 MR. EISNER: You disagree with

17 MS. DANE: Well, if zero is not -- if zero is

18 considered minimum --

19 COURT REPORTER: Can you turn on the mic,

20 please?

21 MS. DANE: Mary Dane. Oh, I'm sorry. Mary

22 Dane, Traulsen. As long as zero's considered a
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1 minimum, then I would be in agreement.

2 MR. EISNER: Say that again just one --

3 MS. DANE: If zero is the minimum, then I

4 guess I don't disagree.

5 MR. EISNER: So you disagree if people think

6 that "minimum" means something other than zero? I

7 think you're talking about something other than zero.

8 So you - - one person disagrees. Anybody else

9 disagree?

10 MS. ARMSTRONG: So can I ask a question, just

11 a follow-on?

12 MR. EISNER: Can we first see if anybody else

13 disagrees? Okay. Right now, we just have one person

14 who disagrees, so we do have consensus --

15 MR. BAUMAN: Can I -- can I ask a

16 MR. EISNER: Oh, wait. We've got somebody on

17 the phone who's apparently disagreeing.

18 MR. BAUMAN: This is Jeff Bauman from

19 National Refrigeration. I just want to confirm that

20 the number we're talking about is minimums for

21 substantiating an

22 AEDM?
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1 MS. ARMSTRONG: Yes. Uh-huh.

2 MR. BAUMAN: All right.

3 MR. EISNER: Disagree with Karen, minimum

4 requirement. I'm not sure -- Ron, can you explain what

5 you're saying?

6 MR. SHEBIK: Yes. Ron Shebik, Hussmann. I

7 just -- going back to Karen's comment, I disagree with

8 Karen's comment as far as the number that must be

9 tested based on whether or not you're part of a VICP.

10 I don't think whether or not you're in a VICP should

11 come into play on this. There's other factors that are

12 going to hold you in check. So whether or not you're

13 in a VICP, I would disagree that that has any kind of

14 factor on how many tests you need to supply.

15 MR. EISNER: So you agree that there should

16 be minimum requirements, so we just have one --

17 MR. SHEBIK: I agree that the minimum -- but

18 that minimum should be the same for everyone in that

19 product category.

20 MR. EISNER: Okay. Right now, I think we're

21 trying to figure out whether everybody -- whether

22 there's consensus that there should be minimum
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1 requirements, and then we can get back into what the

2 minimums are. Let me just -- we have two other things

3 from Bruce Helft.

4 One, to clarify this discussion, is the

5 verification of a basic unit by the DOE a, quote, "test

6 method verification" or -- I'm not sure what this word

7 is -- or using the manufacturer's developed AEDM?

8 MS. ARMSTRONG: It's a -- it's a test.

9 MR. EISNER: Bruce, did you hear that?

10 MS. ARMSTRONG: It's a spot-check test.

11 MR. EISNER: Okay. Bruce had another

12 question. "Where may we look to understand more about

13 the verification testing for performance that is

14 conducted by DOE; that is, how much of the budget is

15 allocated for these verification testing programs?

16 Under what unit is this conducted (legal, or is this

17 contracted outside)? Where is the enforcement testing

18 program statistic described for public reference?"

19 MS. ARMSTRONG: I think we can get back to

20 him offline, just to get back on topic. I'm happy to -

21 - I mean, they're in our regs, so we're happy to --

22 that's kind of -- I just have a follow-on question to
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1 Mary. Would your answer be different if it's a company

2 that participates in no verification, no AHRI, no

3 Energy Star, nothing? There is no verification they do

4 whatsoever. It is left solely on their own.

5 MS. DANE: I would think you would catch them

6 -- Mary Dane, Traulsen. I would think you would catch

7 them in the -- in the enforcement and the verification.

8 Maybe my answer would be different -- could you tell

9 me, under substantiation, who's going to police that

10 I've -- under substantiation that I've run 80 times 2

11 tests?

12 MS. BARHYDT: I am.

13 MS. DANE: You're going to come and live in

14 Fort Worth with me? I do have a spare bedroom.

15 MS. BARHYDT: No, but, realistically, I mean,

16 I'm going -- I would love to go to Fort Worth.

17 The reality is that we request test data on a

18 regular basis.

19 MS. DANE: So you're actually going to --

20 MS. BARHYDT: And so we would request

21 information saying, you know, "We're doing a spot

22 check, and we'd like to see the test data underlying
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1 your AEDM," and you'd better have it.

2 MS. DANE: Oh, okay. Well, I don't think

3 that you should have to become a member of a voluntary

4 program just to get special points, because it's not

5 the DOE's job to recruit for Frank. My apologies, but

6 it's not up to you to, you know, bolster his

7 membership. We should have a set of -- you know, if

8 you're going to set a set of rules, they should apply

9 to everybody, but

10 MR. EISNER: But I think, again, we're

11 talking right now about should there be a minimum

12 requirement that they can then verify and take action

13 again for failure to meet.

14 MR. EISNER: Other than zero.

15 MS. DANE: Other than zero.

16 MS. BARHYDT: I mean, realistically --

17 MR. EISNER: That's different from whether or

18 not --

19 MS. BARHYDT: -- how is somebody going to

20 have a model --

21 MS. DANE: Well --

22 MS. BARHYDT: -- if they have no tests? I
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1 mean, there must be some --

2 MS. DANE: Well, no, we would -- we would --

3 MS. BARHYDT: -- relationship between --

4 MS. DANE: Yeah, I understand the argument

5 you're getting to. I guess I would have to say that if

6 you -- if your AEDM is strong enough -- and it's going

7 to go back to the how we define basic models, but, you

8 know, okay, I can move off of zero, but, you know, my

9 point is, is it's -- then we have to -- we have to hold

10 the line for tolerances, and we have to hold the line

11 for the basic model group.

12 But I still think it should be up to the

13 manufacturer to decide the breadth of his testing

14 program, and then when it gets to verification, you

15 know, then -- and enforcement, then if we were bad, we

16 would have to, you know, take our whoopings there.

17 MR. EISNER: We have consensus on minimum

18 requirements, so I think that's --

19 FEMALE SPEAKER: (Inaudible).

20 MR. EISNER: That's -- yeah. That was going

21 to be the next issue. Anybody disagree that we should

22 go to lunch now? Good.
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1 How long do you need, based on last week?

2 You need an hour, 45 minutes? We're going until six

3 o'clock today, so we'll take a break in mid-afternoon.

4 Everybody okay with 45 minutes? Okay.

5 MR. SACHS: I have a quick question before we

6 break. There was some discussion about some subgroups.

7 Is there an assignment, or did we decide not to do

8 that?

9 MR. EISNER: Well, I think if there are

10 enough people who want to meet and talk about the

11 issue, they can do that, but there seemed to be

12 disagreement about whether that was the appropriate

13 thing to do at this stage. This is the perfect time to

14 go talk to your counterparts --

15 MS. ARMSTRONG: Yeah. I was going to say

16 that the next thing we're going to talk about is how

17 many and of what type have to be tested, so to the

18 extent that people want to talk about that during lunch

19 in the same - - you know, in the same product

20 categories, I think that would definitely be helpful.

21 MR. EISNER: Okay. See everybody back here

22 at about --
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1 MS. BARHYDT: Neil, give them a little more

2 than 45. The lines are going to be worse on Tuesday.

3 MR. EISNER: Okay. We will start right on

4 the button --

5 MR. EISNER: You can take until 1:30.

6 (Whereupon, the meeting was recessed from

7 12:35 p.m. until 1:36 p.m.)

8 MR. EISNER: If I could call this august body

9 to order. We reached agreement on minimum standards,

10 that we should have them. Now we have to start working

11 on those standards, I think. Did you want to say

12 anything to start off the discussion of those

13 standards? Would you like to start in a particular

14 place?

15 MS. BARHYDT: So did folks at lunch talk

16 about what you thought those numbers might ought to be?

17 I know for the commercial HVAC, we've had a suggestion

18 of a minimum of two, but we also had a suggestion that

19 that number might ought to vary, depending on whether

20 or not the manufacturers participated in a VICP.

21 We've also heard from commercial

22 refrigeration that there is a very wide range of
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1 products, and so there's both the issue of whether the

2 regulation should specify a minimum number to be

3 tested, but also whether or not the regulation should

4 specify a breadth of what should be tested.

5 DOE really does want to allow manufacturers

6 to apply their expertise to their products. We're not

7 looking for -- there's no magic number in our minds.

8 We want to hear from you as to what you think would be

9 reasonable for a manufacturer to have underlying their

10 simulation method.

11 It is a -- it would be a regulatory

12 requirement, but I think that all of you have in the

13 back of your mind that, "Well, yeah, but anyone who has

14 a valid simulation is going to have to have something

15 behind it." And that's really what we want to get at

16 is not, in this particular case, it needs to be this

17 set of parameters or in that set of parameters, but

18 there's some general underlying principles of anyone

19 who has a valid simulation method is going to have to

20 have something behind that.

21 And it's -- that's what we're really trying

22 to get at here, is what is it that you need to know as
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1 a manufacturer to come up with a method that is going

2 to be able to make consistent predictions of

3 efficiency?

4 MR. DOPPEL: Paul Doppel with Mitsubishi.

5 Not specifically rated -- related to this, but a point

6 that I think was, I know, on the list to cover later,

7 but if someone is doing a verification that two --

8 let's say it's two minimum tests, and they turn in the

9 test data to DOE, does that information, then, become

10 accessible under

11 FOIA?

12 MS. BARHYDT: Test data that is provided to

13 the Department by the manufacturer is subject to --

14 it's Exemption 4, confidential business information.

15 They're -- it's a legal standard, and the way the

16 analysis works is you can't say the whole document is

17 confidential. You would have to identify which pieces

18 of information were confidential.

19 DOE would not be proactively publishing this

20 information. We would have to receive a specific

21 request to which the document was responsive, and then

22 we actually contact the manufacturer who provided us
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1 with the information and say, "Here's your document

2 that you provided to us. What are your views on what

3 in this document is confidential business information?"

4 So the manufacturer has that opportunity to provide

5 their specific views before anything goes out.

6 MR. DOPPEL: Thank you.

7 MS. BARHYDT: And that's all in the DOE

8 regulations.

9 MR. HON: From a customer viewpoint, how much

10 information is going to be available? Because say you

11 have commercial refrigerators. You have a model

12 number, you have internal volume, which is critical for

13 the calculation, you have total energy consumption.

14 Is that the type of information that would be

15 public knowledge on a normal base -- not the database -

16 - not the test data behind that information, but the

17 final few characteristics of what the product is?

18 Because under the present scenario, the request to fill

19 out the data form is -- I'm assuming that is entirely

20 public knowledge.

21 MS. BARHYDT: Right now, brand is considered

22 public, but OEM is not necessarily. And for various
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1 products, the regs actually spell out what is

2 considered public and what would be subject to

3 additional review. And I don't recall offhand.

4 So for CRE, the information that we collect,

5 it would be public except for the OEM. And on the

6 certification tab of the templates, there is a place

7 for a submitter name, phone number, email address. If

8 that information reveals the OEM, that information is

9 also subject to additional review. And that is a case10 by-case basis. It's not always withheld or always

11 released. It's a case-by-case basis.

12 MR. HON: Charlie Hon again. That -- but

13 that would still -- the brand name would appear -- not

14 necessarily who built it, but the brand name and the --

15 all the information that is being submitted in the

16 standard data form.

17 MS. BARHYDT: Uh-huh. Right.

18 MR. HATCHER: Good. That's fine. Thank you.

19 MS. ARMSTRONG: So I'm going to go back. I

20 put up a different slide, which doesn't have these --

21 it doesn't have the different -- what I'm -- what we're

22 calling substantiation classes, validation classes,
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1 whatever we want to call them. But these are really

2 the issues at hand. I think we -- before lunch, we

3 reached consensus on, yes, there should be a minimum

4 number of units tested, whatever term we want to use.

5 Moving forward beyond that, what should this minimum --

6 what does this minimum sample look like?

7 And, you know, we could take as the first

8 step, for the commercial A/C manufacturers in the room,

9 should it be the two minimum and the corresponding

10 classes that get to -- get you to 16 total if you

11 manufacturer in all of them, that the AHRI program

12 requires? We could see if that's a good place to

13 start. I'm sorry?

14 MS. HOOTMAN: So within those programs -- so

15 Jill Hootman at Trane. So within those programs, they

16 aren't necessarily specific which ones would be of the

17 two?

18 MS. ARMSTRONG: Nope. And that's -- this is

19 kind of a slide that lays out an option, right, that we

20 would test at least -- the requirement would be you

21 test at least one unit of a specified minimum number.

22 If we took the AHRI requirements for HVAC, as I
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1 understood them to be, it would be -- there would be a

2 -- 16 total would be the minimum if you manufactured

3 across the entire span of programs.

4 The choice of basic models would be a the

5 manufacturer's discretion, or we could -- another

6 option would be, you know, are there certain

7 characteristics that -- you know, is it a minimum

8 capacity, is it a high sales volume, or do you want to

9 leave it wide open? Those are options on the table for

10 discussion, but to move it forward, that is one

11 proposal.

12 MR. EISNER: Would you like to focus on this

13 alternative? Anybody disagree? Anybody see it too far

14 off? Yes?

15 MR. MYERS: Two comments. That first line,

16 if we were to do that, wouldn't that be thousands of

17 models that would have to be tested if it was at least

18 one of a specified minimum number of basic models as

19 opposed to the 18 that you were mentioning? Basic

20 model is anything that doesn't have a change that

21 significantly changes the efficiency.

22 MS. ARMSTRONG: So I think it -- no, because
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1 it would be test at least one unit of -- we'd specify

2 what that minimum number is. So, in other words, this

3 isn't the language you would use. This is just general

4 language. Right?

5 But if we'd say -- if, for example, in Jill's

6 suggestion earlier, we'd say test at least one unit of

7 the following categories: air-cooled, small; air-cooled

8 - - in ours, it's large and very large. Water-cooled,

9 evaporatively cooled, SPVUs, PTACs, VRFs.

10 MR. MYERS: Gotcha. I was going by that, but

11 I understand what you're saying, and that would be --

12 MS. ARMSTRONG: Yeah. I can write an

13 alternative proposal on that if

14 MR. MYERS: Yeah. And the other point that -

15 -

16 MS. ARMSTRONG: Go ahead.

17 MR. MYERS: The other point that I wanted to

18 make is that this is one choice, that it's at least a

19 certain number for each category, or however you were

20 defining that.

21 I had mentioned earlier a recommendation of a

22 total of five tests be conducted to validate the -- or
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1 I shouldn't say validate -- to substantiate a

2 particular AEDM, two would be to select the two

3 highest-volume models that you use, and three would be

4 to, at the manufacturer's discretion, looking for

5 inflection points where there might be some question

6 about the validity of the AEDM so that you're actually

7 using it to validate the

8 AEDM.

9 If we went with a specific number, not

10 necessarily in air conditioning, but if we used that --

11 if we drew the same kind of chart for water heating or

12 boilers, there's so much similarity between different

13 product types, that if you tested those different

14 product types, you know, it's a big one of these with

15 the same parameters and a small one of these with the

16 same parameters, you wouldn't really be seeing much

17 difference in the data, and that's why I think it's

18 important to leave that side of it to the manufacturer.

19 MR. WHITWELL: Bob Whitwell, Carrier. Could

20 you -- Ashley, could you just clarify the 16 that you

21 spoke about? Maybe if we go to Slide 18.

22 MS. ARMSTRONG: I'm doing this based on my
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1 understanding, so for those involved in the AHRI

2 program, correct --

3 MR. WHITWELL: And the reason for -- one of

4 the reasons I'm asking the question is in the NOPR,

5 there was a proposal, which was five -- minimum of

6 five, but it included testing at least one model of

7 every product class. And if you look at the templates

8 for submitting the commercial HVAC website that's on

9 the DOE website, there's like 58 different product

10 classes.

11 And, for example, for the air-cooled split

12 system and air-cooled package, there's a total of, I

13 think it's maybe 21 product classes that would be

14 covered by those --

15 MS. ARMSTRONG: Yeah.

16 MR. WHITWELL: -- in the template. So I want

17 to understand, are we talking about those each being a

18 product class, or are we talking about multiple product

19 classes included in each one of those items?

20 MS. ARMSTRONG: The latter.

21 MR. WHITWELL: Okay.

22 MS. ARMSTRONG: So this is Ashley from DOE.
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1 We specifically used yet another term, only because

2 product classes have a distinct meaning with different

3 standards in our regs, and you are -- for commercial

4 A/Cs, depending on whether you're air-cooled or you're

5 small or you're large or you have electric resistance

6 or not, you get to a different number.

7 So you're right, there are 50 some reflected

8 in our -- so this is just an option for consideration,

9 but if I understand it, the way the AHRI program is

10 run, you have basically air-cooled systems, split and

11 packaged in one. Less than 65 would require 2, greater

12 than 65 would require 2, for a total of 4 for air13 cooled.

14 Then you have water-cooled, which there is no

15 program for, but that would require two. You have

16 evaporatively cooled, which there is no program for,

17 but that would require two. You have SPVUs, for which

18 the requirement would be two. You have PTACs, for

19 which the requirement would be two. And then you have

20 VRFs, which the requirement would be two. And then you

21 have water source heat pumps, for which the requirement

22 would be two. Two, four, six, eight, ten, twelve, plus
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1 four is sixteen.

2 MR. WHITWELL: So if we were --

3 MS. ARMSTRONG: I got that right.

4 MR. MUCCIOLA: I think SPVUs, Ashley, I think

5 is (inaudible).

6 MS. ARMSTRONG: That's for verification, or

7 is that for -- to get into the program?

8 MR. MUCCIOLA: I think we have to --

9 COURT REPORTER: Could you use the mic,

10 please? Can't hear you.

11 MR. MUCCIOLA: I'm Vince with National

12 Comfort Products. I'd like to check to make sure. I

13 thought that SPVUs was only one.

14 MR. STANONIK: Well, Frank Stanonik with

15 AHRI. Jill's checking it, but I'm pretty sure, if

16 you're a totally new entrant --

17 MR. MUCCIOLA: New?

18 MR. STANONIK: Not a new model. You're a

19 totally new manufacturer entering -- it's two.

20 MR. MUCCIOLA: Two? Okay.

21 MS. ARMSTRONG: So, I mean, this is one

22 example. It doesn't have to be that way. And I'm happy
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1 to write up a slide real quick that shows this, if it'd

2 be easier for the purposes of discussion, but that's

3 one example.

4 MR. WHITWELL: Okay. This is Bob with

5 Carrier again. Just to follow up, then, so, for

6 example, if somebody had air-cooled split, air-cooled

7 package, and water-cooled packaged --

8 MS. BARHYDT: Six.

9 MR. WHITWELL: That would be six?

10 MS. BARHYDT: If they had small and large,

11 less than 65 and greater than 65.

12 MS. ARMSTRONG: Which one is working this?

13 MR. WHITWELL: Right. Yeah, which most

14 everybody --

15 MS. BARHYDT: Yeah, which makes you say like

16 --

17 MR. WHITWELL: You have one or -- an air18 cooled split system

19 MS. BARHYDT: Uh-huh.

20 MR. THARP: This is Rusty Tharp with Goodman.

21 I would suggest that, for the purpose of AEDM

22 substantiation, that the technologies used in split
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1 systems and single-packaged product are essentially

2 identical, and those would not -- for the purpose of

3 substantiation of an AEDM, those would not need to be

4 separate classes.

5 MS. BARHYDT: So I think --

6 MR. WHITWELL: Carrier --

7 MS. BARHYDT: -- what -- oh, sorry.

8 MR. WHITWELL: Carrier would agree with that.

9 MS. BARHYDT: Yeah. So I think what Ashley

10 just described did group the split system and packaged,

11 and it just broke it out by air, water, and

12 evaporatively cooled.

13 MS. HOOTMAN: Right. This is Jill from

14 Trane. I mean, what I was trying to describe was AHRI

15 210/240, which, as we know, is splits and packages

16 together. Two. AHRI 2 -- you know, 340/360, 2. Now,

17 340/360 really doesn't cover water-cooled, even though,

18 you know --

19 MR. DOPPEL: 210/240 also --

20 MS. HOOTMAN: And the water-cooled would have

21 to -- because there's not a certification program for

22 it.
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1 MR. DOPPEL: Yeah. Paul Doppel with

2 Mitsubishi Electric. The way VRF is set up right now,

3 it would be a minimum of four.

4 MR. WHITWELL: For air-cooled and water5 cooled? It would cover both air-cooled and water6 cooled?

7 MR. DOPPEL: It would be -- again, it's based

8 on the modular, so it would be four air-cooled.

9 MR. KLEISS: Ashley, as long as you're

10 updating that, would you mind putting up boilers and

11 water heaters and that?

12 MS. ARMSTRONG: Yeah, that'll be next. I was

13 going to do one product at a time.

14 MR. KLEISS: Thank you.

15 MS. ARMSTRONG: Can you come up with an idea

16 for me, though?

17 MR. RIVEST: How about if you make that font

18 black?

19 MS. ARMSTRONG: Sure.

20 MR. FLY: While -- this is Mark Fly with

21 AAON. While Ashley's typing, does DOE have a test

22 procedure for evaporative-cooled equipment, because I'm
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1 --

2 MS. ARMSTRONG: In the regs, we do.

3 MR. FLY: -- not aware of any independent

4 labs, anyway, that are capable of especially going up

5 to 63 tons on that.

6 MS. ARMSTRONG: I'm not spelling things

7 right. Water-cooled, two, four, six, eight. SPVUs, two

8 units. External air conditioners and heat pumps, two

9 units. Water source, two units. VRFs, four units. So

10 first -- two, four, six, eight, ten, twelve, thirteen,

11 fourteen, eighteen, since Paul recommended four for

12 VRFs.

13 MR. WHITWELL: The air-cooled, split, and

14 packaged includes air conditioners and heat pumps.

15 MS. ARMSTRONG: Correct.

16 MR. WHITWELL: Correct.

17 MS. ARMSTRONG: But I just put "all" for

18 shorthand.

19 MR. WHITWELL: Yeah. Okay.

20 MS. ARMSTRONG: But I can clarify that in the

21 -- so this is what we're looking at for HVAC.

22 Thoughts?
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1 MR. KLEISS: For commercial water heaters,

2 two units.

3 MS. ARMSTRONG: All types, regardless of fuel

4 source?

5 MALE SPEAKER: Ashley, for us old guys, can

6 you blow it all up?

7 MS. ARMSTRONG: Sure. Is that good?

8 MALE SPEAKER: Thank you, ma'am.

9 MR. EISNER: Does that cover what everybody

10 wants?

11 One product.

12 MR. KLEISS: Yes. All types of commercial

13 water heaters.

14 MS. ARMSTRONG: We'll go there next. Hold on

15 one second.

16 MR. KLEISS: Okay.

17 MS. ARMSTRONG: Do we have agreement?

18 MR. EISNER: No objections on this?

19 MALE SPEAKER: Is this the minimum for

20 anyone?

21 MS. ARMSTRONG: Minimum for anyone, and

22 there's nothing associated, as written right here,
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1 about lab requirements, so whether it's an owned lab or

2 a third- party lab. Do you want there to be?

3 MS. DANE: Mary Dane from Traulsen. If we're

4 only talking substantiation, can't we self-test?

5 MS. ARMSTRONG: Absolutely. Yeah, I'm just

6 asking.

7 MS. DANE: Then I would vote for self8 testing.

9 MS. ARMSTRONG: Okay.

10 MR. EISNER: All right. Is there agreement

11 on the list?

12 MALE SPEAKER: As far as the quantity of

13 units, yes.

14 MR. EISNER: Okay. No disagreement.

15 MR. DOPPEL: Ashley, Paul Doppel with

16 Mitsubishi. If, for the VRF, if you could make that 4

17 a 2/2.

18 MS. ARMSTRONG: Two air, two water --

19 MR. DOPPEL: Yeah.

20 MS. ARMSTRONG: -- is what you want?

21 MR. DOPPEL: It's actually more AHRI --

22 MS. ARMSTRONG: Okay.
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1 MR. DOPPEL: Yeah.

2 MR. SACHS: Okay. That's -- that was my

3 question.

4 MR. DOPPEL: It's actually -- again, for

5 AHRI, it's actually four for -- it's four for air and

6 four for water, but

7 MS. ARMSTRONG: Is that what you want?

8 MR. FLY: Mark Fly with AAON. Does all of

9 this go to 63 tons on every category?

10 MS. ARMSTRONG: No.

11 MR. FLY: The top two --

12 MS. ARMSTRONG: Oh, the top --

13 MR. FLY: The top two, it does.

14 MS. ARMSTRONG: Just the top two.

15 MR. FLY: The rest of them, no. Water.

16 MS. ARMSTRONG: Oh, PTACs

17 MR. FLY: Water source, and -- but it does

18 include heat pumps up to 63 tons.

19 MS. ARMSTRONG: I have to have the regs to

20 know the exact --

21 MR. FLY: Because that's not the AHRI

22 program. That's the only reason I'm asking.
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1 MS. ARMSTRONG: Do you want to come answer?

2 MS. BARHYDT: I've got it in front of me. I

3 can sit here and read off the numbers, but I can't

4 confirm.

5 MS. ARMSTRONG: Water source heat pumps is

6 less than 135.

7 MR. FLY: Okay.

8 MS. ARMSTRONG: Water-cooled and

9 evaporatively cooled air conditioners does go all the

10 way up to 760. And I guess what's missing from the list

11 that we didn't discuss, to the extent it applies to

12 anyone here, is computer room air conditioners. Should

13 they be added?

14 MR. EISNER: When you say should they be

15 added, would they -- would they be covered someplace

16 else if they weren't added to this list?

17 MS. ARMSTRONG: So we have adopted

18 regulations for them. I don't believe they're required

19 for compliance quite yet, so that's probably why

20 they're not in the discussion, but they will be.

21 They're coming, so while we're doing this

22 MR. STARR: I'm wondering, is that an ASHRAE-
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1 covered product?

2 MR. EISNER: Say your name.

3 MR. STARR: Oh, Louis Starr with NEEA.

4 MS. ARMSTRONG: Yes.

5 MR. STARR: Okay. Well, I don't know how it

6 works in the context, but, yeah, it would be definitely

7 helpful to have some kind of rating or be part of the

8 rating systems.

9 MS. ARMSTRONG: Is it two; do you know?

10 MALE SPEAKER: Good place to start.

11 MS. ARMSTRONG: Okay.

12 MS. HOOTMAN: Hang on. I mean, go ahead.

13 I'll

14 MS. ARMSTRONG: Do you want four for VRFs for

15 each, just to match?

16 MR. STARR: Well, this is a different -- I

17 mean, this is a different type of situation, and it

18 would be -- what we're talking about here is tests that

19 would be shown to DOE in order to get into a program,

20 so that's kind of a different

21 MS. ARMSTRONG: It would be tests that a

22 manufacturer has to run, keep their data on hand, and
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1 it would have to meet a certain set of requirements to

2 use an AEDM, and we may ask for that test data at some

3 point. But we voted for a no preapproval process so you

4 wouldn't submit it before you used your AEDM.

5 So the question is for AHRI, are you okay

6 with an AHRI -- you know, to the extent someone wants

7 to use an AHRI program, they need four and four, but

8 someone who doesn't needing two and two.

9 MR. STARR: Well, we may have -- after this,

10 we may go back and change what we have at AHRI because

11 of the -- I mean, we'd have to change all the

12 certification programs based on an AEDM.

13 MS. ARMSTRONG: Okay.

14 MR. STARR: It wound seem

15 MR. SACHS: This is Harvey. And I guess,

16 Ashley, I think our focus must be on what is required

17 to validate the AEDM, rather than what AHRI currently

18 asks for.

19 MS. ARMSTRONG: Correct. That's what this

20 is, right? Well, he's using validation for --

21 MR. SACHS: Yeah.

22 MS. ARMSTRONG: He's not using it as
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1 verification.

2 MS. DANE: But we agreed -- I asked before we

3 went to lunch -- this is Mary from Traulsen, and I

4 asked before we went to lunch if substantiation -- that

5 substantiation and verification meant verification.

6 MS. ARMSTRONG: Correct. That's correct.

7 MR. STANONIK: Yeah. And Frank Stanonik,

8 AHRI. Verification, there's no miscommunication about.

9 What was confused was substantiation and validation.

10 MS. ARMSTRONG: Right.

11 MR. STANONIK: You validate that your AEDM is

12 correct. Verification, I think we all consider that

13 down the road, when you're out there producing models,

14 as many as you -- or units, as many as you would like

15 to produce, at some point, somebody picks one up and

16 checks your rating, that's verification.

17 MR. RIVEST: Ashley, it's Mike Rivest. I

18 just want to confirm that beyond the number of units

19 per class, there aren't any additional requirements as

20 to, you know, whether those two units need to be at the

21 ranges of something like that. Okay. Jill's nodding

22 her head "no," so
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1 MS. HOOTMAN: I would not be in -- Jill

2 Hootman, Trane. I would not be in favor of any

3 restrictions on what those models are.

4 MR. RIVEST: Okay. Are there any within the

5 AHRI program?

6 MS. HOOTMAN: No.

7 MR. RIVEST: Okay.

8 MR. STANONIK: Frank Stanonik, AHRI. But,

9 again, I mean, this is what we do for the program, but

10 it -- you know, but programs aren't validating AEDMs.

11 And -- but so if we're looking -- look -- I would say

12 if we're looking at a potential that let's say if I'm

13 skilled enough -- or not skilled enough -- if I have

14 enough information and I have enough technical basis to

15 be able to create, let's say, an AEDM for all of my

16 models, you know, all my models that were given

17 substantiation class, I guess as I'm thinking out loud

18 here, I mean, are we comfortable saying, well, you can

19 -- you can pick -- you can pick any two from that huge

20 -- from that huge population, as -- I'm going to call

21 them your validation points.

22 I mean, again, I'm just thinking out loud,
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1 and, I mean, it seems to me that somewhere in here,

2 you'd like -- the product that's -- well, again, maybe

3 in the commercial side, it doesn't make sense to say

4 this, but the product that you produce most often --

5 no? Okay.

6 MS. HOOTMAN: I'm just saying -- this is Jill

7 from Trane -- no, I disagree. The high-selling volume

8 combination or tested model inside of those is not

9 necessarily what you would do for engineering in

10 validating the simulation. It's going to be more what

11 we call outliers. It might be what you are putting --

12 you know, the largest cabinet size. It might be the --

13 where you're restricting airflow.

14 But those are going to be the parameters that

15 you're going to look at in an engineering, you know,

16 means to look at validating a simulation, and it

17 doesn't always mean it's the high-selling combination.

18 So I think those are kind of arbitrary things that

19 really don't have any relationship to what you're doing

20 to validate a simulation.

21 MR. RIVEST: Ashley, Mike Rivest again. If

22 you can come back to the previous slide
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1 MS. ARMSTRONG: Yeah, sorry.

2 MR. RIVEST: I think in this presentation,

3 the word "unit" refers to units of the same model. You

4 probably mean two models here.

5 MS. ARMSTRONG: Yes, I do. That's correct.

6 That's a good change. Thank you. So it's one unit per

7 model. In other words, it can't be the same model.

8 MR. RIVEST: Right.

9 MR. STEPHENS: Phillip Stephens, HTP. So

10 just for clarification, that means you could not test

11 the exact same product twice?

12 MS. ARMSTRONG: Correct.

13 MR. STEPHENS: Thank you.

14 MS. ARMSTRONG: Two separate tests, two

15 separate tests -- two separate models.

16 MR. EISNER: Go ahead.

17 MR. STARR: This is Louis Starr. Just also

18 on the computer room air conditioning -- conditioners,

19 there's -- I don't know exactly, but there's a similar

20 kind of split-out that is with the commercial packaged

21 air -- equipment. It's a similar type thing. I don't

22 know exactly what those classes are, but it's -- there
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1 essentially a lot of times are just commercial air

2 conditioning but have certain things in them that make

3 them a little more resistant to failure.

4 MS. ARMSTRONG: So

5 MR. STARR: So you basically may need more

6 than what you've identified there in your computer room

7 air conditioner for models.

8 MS. ARMSTRONG: Okay. So this is Ashley from

9 DOE. So if I look at 4 -- Table 7 in the regs, it's

10 431.97, and these are the standards we adopted in

11 response to ASHRAE 90.1's last adoption, so ASHRAE 90.1

12 2010. Computer room air conditioners are broken out by

13 air-cooled, water-cooled, and then glycol-cooled, and

14 they're also differentiated between whether they have a

15 fluid economizer or not, and then they're also

16 differentiated by cooling capacity.

17 So I don't know if we want to split it out

18 like we did similarly to the other ones or if we want

19 to leave it, or at least at a minimum have the air20 cooled, water- cooled, and glycol-cooled be two each?

21 I don't know if anyone has an opinion there? But

22 that's just through our regs.
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1 MR. STARR: I think the efficiencies change

2 for quite a bit between small and big models. I mean,

3 essentially, if it exists there in commercial air

4 equipment, it's a very similar product, so I would --

5 you know, to the extent that it's the same reasoning in

6 those, I would think a similar kind of split-out

7 MS. ARMSTRONG: So

8 MR. KOLANDAYAN: Dominic Kolandayan with

9 Daikin. My comment as whether we should just limit this

10 to just models, or should we allow components -- let

11 the manufacturer -- you know, where you have the last

12 bullet saying, "Particular model selection at

13 discretion of manufacturer," can we expand that to say

14 "components," but, you know, components, meaning

15 probably, you know, at least to comprise of components

16 for two models? You know, we'll keep the models the --

17 the quantity of models the same, but why not do the

18 AEDM based on components? Thank you.

19 MR. EISNER: Any comments on components?

20 MS. ARMSTRONG: I don't know what it means.

21 MR. KOLANDAYAN: It says "model discretion,"

22 so I want to make sure that we expand model to include
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1 components. Right. It is at the discretion of the

2 manufacturer, but that doesn't clarify components could

3 be used. No. Right. No.

4 MS. ARMSTRONG: So should the model

5 requirements be that each model has to have a different

6 rating?

7 MS. BARHYDT: Maybe engines around heat

8 exchange?

9 MS. ARMSTRONG: I don't know where we're

10 going --

11 MR. EISNER: Because what are we talking

12 about here on models? We're defining models as having

13 a different rating.

14 MR. THARP: Rating being efficiency level or

15 capacity?

16 MS. ARMSTRONG: I don't know. I'm just

17 trying to -- I don't know what clarification to put

18 here to reflect his comment of components well.

19 MR. STANONIK: But in terms of an AEDM, if

20 we're not talking about models that have different

21 ratings, let's all go home. I mean, that's the whole

22 point, right, that you can extrapolate ratings to --
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1 that have -- for models that have different ratings.

2 MS. HOOTMAN: I think this is back to -- a

3 little bit back to what you describe as your basic

4 model. In data engines, in engineering data engines, we

5 might literally have data engines that are around coil

6 -- you know, heat exchangers, around compressors, et

7 cetera, and we tend to -- we could switch out one of

8 those, and we can tend to correlate that and make up a

9 new model, literally, right there.

10 So, you know, when we're looking at

11 validation of those engineering records, they might be

12 various different databases that are actually being

13 looked at. We would have to have some rules or

14 validation rules that would then say, "Well, these

15 models look at this kind of engineering database to do

16 that simulation."

17 So if -- a basic model, back to this

18 definition of basic model, I realize, it would have to

19 be what we all know to be a unit. Okay? It can't be

20 components. But you could be validating against various

21 different simulation models. There's a compressor

22 model, there's a heat exchanger model, there's a fan
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1 model. You can be validating components against all of

2 those kind of things to build up --

3 MS. ARMSTRONG: Right. We're talking about a

4 system here, not just -- not a component. So your

5 system would have to be modeled a minimum of two -- you

6 actually clarify that. Two systems have to be tested.

7 MS. HOOTMAN: That's fair, systems.

8 MS. ARMSTRONG: The component cannot be

9 tested, and you can't just correlate the component part

10 of it?

11 MR. THARP: Agreed. This is Rusty with

12 Goodman, and we also somewhere ought to define that a

13 system consists of a compressor, condensing coil,

14 evaporating coil, expansion device, and air-moving

15 systems -- air- moving devices.

16 MS. HOOTMAN: And that's why I want a basic

17 model defined.

18 MR. THARP: Yeah.

19 MR. DOPPEL: Paul Doppel with Mitsubishi.

20 VRF has a definition for a system as tested

21 combination.

22 MS. MEYERS: So this is Karen with Rheem. I
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1 just have a question. Let's say you're trying to

2 validate, slash, substantiate your AEDM, and you do two

3 different models, and you really don't -- it doesn't

4 come out quite like you thought, so you do three

5 models. Is that okay?

6 And then it kind of -- you know, then you get

7 your confidence level that you need. You didn't get

8 your confidence level that you needed when you did it

9 with two, but you got it with three.

10 MS. ARMSTRONG: We don't have what a

11 confidence level is yet. We'll get there. But you can

12 always do more.

13 MS. MEYERS: You've got two models up here,

14 but, you know, so --

15 MS. ARMSTRONG: You can always do more

16 testing, if you want to do 3 or if you want to do 300.

17 The minimum you have to do is two.

18 MS. MEYERS: So that --

19 MR. RIVEST: Right. So there are no

20 statistics applied to the very simple 5 percent per

21 model and 5 percent average? There is no confidence

22 interval to that. So adding models is not going to
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1 help you if one model fails the 5 percent, if that's

2 the rule, whereas if you're talking about certification

3 testing, that's where it helps to have --

4 MS. ARMSTRONG: It would help, right. So it

5 depends on what we decide, ultimately, for what is a

6 valid rating in terms of tolerance. But if you use the

7 AHRI concept of 5 percent against a single test of

8 what's popped out of your AEDM, you know, it is what it

9 is for that given model. There's no averaging, there's

10 no statistics.

11 MR. RIVEST: Got it.

12 MS. ARMSTRONG: Okay.

13 MR. FLY: Just going back to the computer

14 room, and I don't really have a dog in this fight,

15 because I don't make computer-room units, although I

16 won't say that my unit hasn't been misapplied to a

17 computer room from time to time, do you really want to

18 relate glycol separate from water-cooled, because

19 you're on a real slippery slope there of what

20 percentage of glycol, what kind of glycol, is it

21 glycol, or is it brine, one of the other generic

22 fluids?
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1 That -- most of the water-cooled equipment is

2 rated as water, and then we use engineering models,

3 basically, to adjust for other fluids, which is fairly

4 well-known and defined.

5 MS. ARMSTRONG: I have no opinion on this

6 whatsoever, other than we have different standards for

7 them, for -- we specifically -- yeah, there's different

8 tests and different levels. We specifically separate

9 out glycol-cooled. So this is -- but no opinion.

10 MR. STARR: This is Louis Starr with NEEA.

11 Whatever the breakout, it makes sense that -- part of

12 the deal is that down the road, these things will be

13 used for incentive programs as well, so part of -- you

14 know, this is why it's good that it reflects those --

15 whatever is in the register in front of those equipment

16 tables. So whatever AEDMs you have, it's kind of

17 important for that reason.

18 MR. KOLANDAYAN: I'd like to clarify on the

19 components that I commented on. We would -- the

20 comment is manufacturer can still test two units, but

21 then all the statistical calculations are based on

22 components, and then the ratings developed from
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1 components is adjusted to the tested systems, and then

2 the final rating is derived after they've been

3 compared.

4 So basically, you develop your AEDM using

5 components. So basically, why not leave it to the

6 discretion of the manufacturer to decide how he wants

7 to come up with his rating? Ultimately, that rating

8 must pass.

9 MS. ARMSTRONG: So I think what we're saying

10 is -- that -- this is -- that is definitely allowed by

11 this construct, but what we're saying is you at least

12 have to test two systems in a lab per the DOE test

13 procedure or come up with a system rating and -- and

14 then compare that system rating to the system rating

15 output by your AEDM, and if that system rating output

16 by your AEDM is built upon component, you know, models

17 within itself, that's up to you completely.

18 MR. KOLANDAYAN: Oh, okay. Yeah.

19 MS. ARMSTRONG: But at the end of the day,

20 we're comparing system rating to tested system rating.

21 MR. KOLANDAYAN: Okay.

22 MR. WHITWELL: System performance.
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1 MS. ARMSTRONG: Sure. Better word.

2 MR. MYERS: This is Frank Myers with PVI.

3 Again, I don't have a dog in the race here with air

4 conditioning equipment, but referencing the computer

5 room air conditioners, doing air-cooled and water6 cooled, again, for validation of the AEDM, not for a

7 particular standard, those are the two basic types of

8 equipment. Extending or using a different fluid from

9 water, I don't think would make a difference in your

10 validation of your

11 AEDM.

12 So it would seem to me in this case you would

13 be looking at similar to VRFs, where you'd have two

14 air- cooled and two water-cooled and scratch glycol.

15 You may have to do a dozen glycol tests to validate

16 your AEDM, but in terms of after the fact, determining

17 is that AEDM selecting accurate numbers, then I think

18 just air-cooled and water-cooled would do it.

19 MR. STEPHENS: Phillip Stephens, HTP. I

20 think Frank's alluding to something that we touched

21 upon briefly before lunch. If we have an AEDM that

22 covers multiple product classes and we have an
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1 equation, basically, to relate it between different

2 mediums, we can have one AEDM to cover all this.

3 At that point, would we need four to cover

4 two -- four test points to cover two product classes,

5 or just two to cover one AEDM?

6 MS. ARMSTRONG: So this is Ashley. Based on

7 what's on this slide, if you had -- if they didn't fall

8 into whatever -- we're -- I'm calling them categories,

9 for lack of a better term. If they didn't fall into

10 two separate categories, then the answer is two. If

11 they fall into two discrete categories which have two

12 individual requirements of two each, then the answer

13 would be four. So it depends.

14 MR. KOJAK: This is Mike Kojak with UL. I

15 just wanted to ask a question. If I was a new

16 manufacturer and I wanted to do the AEDM route, I would

17 only have to test two models, and then I can have an

18 AEDM to rate everything?

19 MS. ARMSTRONG: In that --

20 MR. KOJAK: Okay.

21 MS. ARMSTRONG: In a single category.

22 MR. STEPHENS: If you wanted to accept that
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1 risk.

2 MS. HOOTMAN: Yes. There you go.

3 MR. KOJAK: Then why set the minimum like

4 that? Because, you know, it's human nature, if there's

5 a minimum set, I'm going to think that that minimum was

6 set because that's okay, that I'll get enough data

7 where I will have an accurate AEDM. Won't someone

8 that's new be like, "Oh, the minimum's two. That

9 should be enough testing. I'm going to do two because

10 the DOE says two," and then rate everything according

11 to this AEDM, but it might not be accurate?

12 MR. STANONIK: If -- Frank Stanonik, AHRI.

13 All right. But if you're a new -- if you're a new

14 manufacturer, where does the rest of your information

15 come from to write the AEDM? I mean, this is -- I

16 mean, you know, we kind of talk in these theoretical

17 things. It's like, "Oh, well, you know, I've got two

18 points, and I just do Y=MX+B kind of thing," you know.

19 It's not -- you know, there's a lot more

20 behind that. And so if you're a new manufacturer,

21 where do you -- you're going to have to get that

22 information somewhere, sort of the technical knowledge,
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1 the engineering, the design to be able, in fact, to

2 create an AEDM that will -- I don't want to say will be

3 correct. I mean, so, you know, we say minimum two. I

4 just can't see -- you know, to me, if you really were

5 new into the business, you're going to be doing a lot

6 of testing.

7 MS. HOOTMAN: Jill Hootman at Trane. But

8 isn't that up to the manufacturer to decide what risk

9 they need to do? That's their risk assessment and how

10 much they feel they need to do in order to prove out a

11 new program, a new AEDM. And, you know, if they do

12 only go to the minimum and they aren't accurate and

13 they get tested, I believe there are civil penalties

14 behind this. So how much do you want to assess

15 MR. EISNER: We have agreement on the list?

16 MR. SACHS: I -- this is Harvey, and I do

17 have one other concern. Earlier on this morning, we

18 were talking about the smallest capacity and within 25

19 percent of the largest, and Kojak and others have

20 really been bringing up things, and Jill, that relate

21 to guidance to manufacturers rather than requirements.

22 But I'm a little concerned that we don't seem
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1 to have here anything about the diversity of the

2 products that are tested, the difference from each

3 other, and I wonder if that would be an appropriate --

4 rather than it being entirely manufacturers' risk.

5 I can imagine, to take it out of this, that I

6 could test -- but into residential air conditioning, I

7 could do a single compressor CYR 13 (ph), a single8 state compressor, CYR 13 5 (ph), and then attempt to

9 use that AEDM across a wide spectrum of compressor

10 types, efficiencies, and everything else. So I'm not

11 yet comfortable with that and hope somebody can make me

12 comfortable.

13 MR. EISNER: Are you talking about putting

14 something in the preamble as guidance on how to use

15 this list?

16 MR. SACHS: I'm not sure if it belongs in --

17 that's a good point, Neil, and I'm just not sure how it

18 -- whether it belongs in guidance or we really ought to

19 have a requirement that I'm calling diversity, but

20 there may be a better term for it, the differences of

21 the products tested, if we're requiring two within that

22 product class. You know, I don't have a good answer,
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1 but I think it's something that we need to return to.

2 MR. EISNER: I mean, you wouldn't right now

3 want to vote for this unless you saw something on here

4 that DOE draws attention to the diversity of this list,

5 and in making a judgment call, that should be

6 considered type of thing?

7 MR. SACHS: I'm actually putting the issue

8 out for consideration by those who are involved with

9 this on a daily basis, and that includes DOE. I find

10 myself concerned that I could calibrate -- I'm sorry,

11 substantiate my AEDM with a training set that comprised

12 two almost identical models and then use it on a much

13 more diverse suite. And Frank is shaking his head as

14 though he understands what I'm trying to say. So maybe

15 Frank could translate.

16 MR. BAUMAN: If I could -- can I -- this is

17 Jeff Bauman from National. Ashley, does this -- the

18 information on Page 19 that we had -- and that was

19 regards to testing one basic of five models, the 25

20 percent and all that -- does this -- that still goes

21 along with this? This would replace that?

22 MS. ARMSTRONG: This is it.
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1 MR. BAUMAN: Okay.

2 MS. ARMSTRONG: That all goes away.

3 MR. EISNER: So there should the "ing" be

4 deleted there?

5 MS. ARMSTRONG: Yes, sorry. Thank you.

6 MR. EISNER: What we're -- I think what we're

7 talking about is there should be -- there -- should

8 there be an asterisk here that would end up in the

9 rule, in some way describing how this list should be

10 used? Harvey seems to be saying can somebody else give

11 us the words to put up here to say, "Beware, using this

12 list, to not do the following with it."

13 MR. BAUMAN: This is Jeff Bauman from

14 National again. I guess I'd say -- again, I don't have

15 a -- my dog's not in this part of the show, but he's in

16 a different part, but I think the things that are --

17 were listed on Page 19 with the minimum of five units,

18 we can discuss each of those points and the 25 percent.

19 I think we ought to consider those, perhaps,

20 one by one, because that may address the things that

21 Harvey's talking about, concerns for minimum -- again,

22 if you had -- okay, one category, you only had to test
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1 two, but overall you had to test five, so that one guy

2 that only -- that Mike was concerned about that only

3 had to test two for all of his stuff, well, maybe he

4 should test at least five. I don't know the answer.

5 I'm just saying that may be a way to address some of

6 the concerns I'm hearing.

7 MR. EISNER: Well, again, an alternative

8 would be to agree to this list, subject to coming back

9 and changing it if we have to after we go through the

10 other criteria. The other criteria may take care of

11 Harvey's concern. Yes?

12 MR. HUNT: Marshall Hunt, Pacific Gas and

13 Electric Company. The elephant we have in this game is

14 that it was millions of dollars, even hundreds of

15 millions of dollars, in the utilities going to higher16 efficiency equipment.

17 And so the key thing that I think Harvey was

18 trying to say is because your baseline, let's say,

19 rooftop package unit just barely meets the standard.

20 If your super-duper package unit -- can you really

21 claim the AEDP (sic) covers that and all the

22 technologies?
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1 Because it's amazing. We're going to have,

2 what, microchannel heat exchangers. We're going to

3 have various kinds of optimizing controls that are

4 coming up. So I just ask the manufacturers to think

5 about this, because we have to justify spending

6 ratepayers' money on these rebates.

7 MS. HOOTMAN: This is Jill Hootman from

8 Trane. Aren't we saying that this is the minimum? The

9 manufacturer can still decide to do more and would

10 probably do more with that diversity. But I don't like

11 using terms like "high-selling volume combination,"

12 because that may have nothing to do with the

13 engineering of that product and will not likely hit the

14 diversity issue, or even the 25 percent of the largest,

15 that doesn't always hit the diversity issue either, so

16 MR. SACHS: (Inaudible).

17 MS. HOOTMAN: I will say that -- I can say

18 for our company, yeah, we're going to have more than

19 those two models, but that would be the minimum.

20 MR. SACHS: This is Harvey again. Jill, I

21 appreciate that, but I do want to come back to

22 Marshall's point that we've been -- and express it
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1 slightly different. We've been expressing this in

2 terms of compliance assurance, and some innovation and

3 an awful lot of sales is also being driven by what I

4 might call a vertical assurance that if we have an EER

5 of 10, that the EER 12 product is really that much

6 better, and we're depending on the AEDMs for that.

7 So it -- Marshall can't go back and knock on

8 a lot of doors and ask for the rebates back, but his

9 shareholders can get dinged for something that wasn't

10 his fault. He used the best information available in

11 the AHRI directory or the CEC directory. So I think

12 it's something which is on a lot of our minds, and I

13 don't -- again, I don't have an answer.

14 MR. STARR: There's another aspect of that

15 too. Companies that spend a lot of money on research

16 and development are generally producing high-efficiency

17 equipment. You may be competing with someone that's

18 using an AEDM that's two that's maybe overstating their

19 savings.

20 Meanwhile, you're spending lots of your money

21 in R&D on a product that really does get the efficiency

22 rating. Meanwhile, someone else is taking some --
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1 meeting these minimum standards, and at the same time

2 coming in at a price point less than your product and

3 not really as efficient as your product.

4 The utilities have to base it upon not -- you

5 know, it's not just like, "Huh, we like Trane

6 equipment; therefore, we'll use it." It's based upon

7 whatever the rating comes out of, you know, these

8 voluntary standards.

9 So there's some interest, then, from the

10 manufacturers' side to be concerned about how efficient

11 your -- the -- how the actual numbers really relate to

12 the true efficiency of the equipment. And I'd be

13 thinking about that too from the equipment side as

14 well.

15 MR. STANONIK: Frank Stanonik with AHRI.

16 When Harvey was making his point -- and I just don't

17 quite have the words, but it seems to me that -- well,

18 at least in my opinion, there's almost an underlying

19 fundamental principle that the models that are included

20 that are covered by a single AEDM, the models that are

21 covered by a single AEDM, have, at some basic

22 fundamental point, some commonality.
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1 And I don't know how to describe it, but they

2 have some commonality, I'll say, of design or critical

3 functional component or something of that nature,

4 because, you know, going to the -- we were talking at

5 lunch. I can't -- I can't envision using something --

6 it looks a little simple to understand, at least for

7 me.

8 I can't envision writing an AEDM that would

9 cover a commercial multi-tube -- multi-flue tube

10 storage water heater and a fin tube hot water boiler.

11 They're just too different designed to -- maybe

12 somebody could, but I can't see how you would have an

13 AEDM that would -- that would cover that whole range.

14 And so I think there is -- you know, we'd say

15 minimum of two, and we talk about an AEDM, but I think,

16 you know, when you start to get, again, into some of

17 the details, there is this -- also this common thread

18 that connects all of the models that are wrapped up in

19 that one AEDM. There's something you can say, "Oh,

20 yeah, when you get to this critical aspect of their

21 performance, they all have this same characteristic."

22 MR. EISNER: Rodney Beever asks a question:
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1 "What happens if, the following year, the highest2 selling volume changes? Would the manufacturer have to

3 go back and retest?"

4 FEMALE SPEAKER: It's definitely not

5 verification.

6 MR. EISNER: Any thought about it?

7 MS. BARHYDT: So that is -- that comment

8 appears to be a reflection of DOE's original proposal,

9 and the current discussion is leaning away from that

10 type of a requirement, so I think that it ends up not

11 being an issue.

12 MR. EISNER: Can we go back to the chart?

13 MS. ARMSTRONG: Yes, sir.

14 MR. EISNER: We agree -- put an asterisk up

15 here to add a caveat, if necessary. Subsequent

16 conversations will determinate that. We can go on now

17 and start to see whether we can take care of that with

18 some of the other criteria. Anybody disagree?

19 MR. MYERS: Would you repeat the first part

20 of that again?

21 MR. EISNER: We're going to put an asterisk

22 up here that'll say "Caveat: Add language if
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1 necessary," along the concerns that you raised, Harvey.

2 That's a reminder we're agreeing to this, with that

3 caveat up there that we might have to add some more

4 language. And then we'll see if, when we get to these

5 other criteria, we resolve the problem that's been

6 raised.

7 Any disagreement?

8 MR. THARP: This is Rusty with Goodman. I

9 would agree with that and would also suggest that there

10 would be some language adding in about the uncertainty

11 of test results.

12 MS. ARMSTRONG: That's the next topic.

13 That's the next set of like five slides.

14 MR. EISNER: Well, I think it still is

15 applicable, because if --

16 MS. ARMSTRONG: Absolutely. We'll get there.

17 I promise.

18 MR. DOPPEL: Ashley, I thought you were

19 throwing him out.

20 MS. ARMSTRONG: No, no. Nope.

21 MR. MYERS: Ashley, would we consider -- this

22 is Frank Myers, PVI Industries.
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1 MS. ARMSTRONG: I'm out of room. I'm out of

2 room on this slide.

3 MR. MYERS: Would we consider -- are there

4 manufacturers that produce -- I'm looking at your last

5 two entries, VRFs and computer room air conditioners.

6 Might there be manufacturers that only make air-cooled

7 or that only make water-cooled that -- would we want to

8 separate those into two categories, since they don't

9 change the quantities? You're adding all that you make

10 up, so

11 MS. ARMSTRONG: I think that's what this

12 means. Two for air -- I just don't show them on

13 separate bullets. Sorry, I'm running out of room.

14 MR. EISNER: Two for each. Two for this --

15 MS. HOOTMAN: I'm a manufacturer that does

16 two VRF air (ph). I do two models.

17 MS. ARMSTRONG: So if you make air and water,

18 it's four; if you only make air, it's two; and if you

19 only make water, it's two. Is that what -- that's what

20 you meant, right?

21 MR. MYERS: That's what I was --

22 MS. ARMSTRONG: Okay.
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1 MR. MYERS: Yeah.

2 MS. ARMSTRONG: So that's how I read this. I

3 just ran out of --

4 MR. MYERS: So you're just leaving it as a

5 single bullet for convenience, but it actually would be

6 two bullets --

7 MS. ARMSTRONG: Yeah.

8 MR. MYERS: -- if you will?

9 MS. ARMSTRONG: Correct.

10 MR. STANONIK: All of it is as applicable.

11 MR. EISNER: Okay. Next issue?

12 MS. ARMSTRONG: Water heaters. So to start

13 the conversation, these are our, for lack of a better

14 term, product classes. We have different standards for

15 fuel type, storage versus instantaneous versus hot

16 water supply boilers, and then just unfired water

17 tanks.

18 MR. MYERS: So this is Frank Myers. One

19 observation right off the bat; that is that, at least

20 in the AHRI program, hot water supply boilers are in

21 the same program as water heaters.

22 MS. ARMSTRONG: Correct.
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1 MR. MYERS: They're -- seem to be the same

2 thing. So certainly from a validation point of view,

3 you shouldn't have to do a hot water supply boiler

4 separately from an -- from a water heater.

5 MS. ARMSTRONG: So do you propose grouping

6 storage, instantaneous, and hot water and just

7 differentiating by fuel type, or just grouping hot

8 water supply boilers with storage?

9 MR. MYERS: Hot water supply boilers

10 generally are more instantaneous than storage, but from

11 a -- from a design point of view, from a validation

12 point of view, I think probably putting it together

13 with instantaneous would be the closest.

14 MS. ARMSTRONG: Okay.

15 MR. STANONIK: And, Ashley, this is Frank

16 Stanonik with AHRI. Because of how -- well, because of

17 the historical industry definitions, I think you

18 actually might be better off categorizing them as

19 storage water heaters and tube-type water heaters.

20 MS. ARMSTRONG: Can I just put that in

21 parentheses next to instantaneous and hot water?

22 MR. MYERS: Frank, I think you're probably
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1 better leaving it like it is, because there are

2 instantaneous storage-type water heaters.

3 MR. STANONIK: Yeah. That's what I'm saying,

4 those would end up being storage. A 40-gallon, 250,000

5 BTU fired water heater is, by historical definition,

6 instantaneous, but it's a storage product.

7 MS. ARMSTRONG: But in our regs, it's

8 instantaneous.

9 MR. STANONIK: Yes. Right. Yeah, you're

10 right. Yes.

11 MS. ARMSTRONG: So, I mean, if we were

12 compare -- I don't know. We can definitely add new

13 terms, but that's more definitions we need to then add.

14 MR. STANONIK: All right. Okay.

15 MR. KLEISS: Jeff Kleiss, Lochinvar. This

16 brings up a very good point. From gas-fired storage

17 hot water heaters, we have a product family that

18 qualifies -- the single product family qualifies in the

19 two different categories. So it's a similar design.

20 The same test procedure is done for determining

21 efficiency, but it crosses the line of two different

22 categories.
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1 I would like to see it so that we could run

2 two models that would qualify both the size that rates

3 as an instantaneous water heater and the storage water

4 heater. Same test methodology applies to both of those.

5 MS. ARMSTRONG: That's up to you guys. Do

6 you guys think we should combine storage,

7 instantaneous, and hot water supply boilers into two

8 models for that total category?

9 MR. KLEISS: As long as the test methodology

10 is the same, I would suggest that we should be able to

11 have two models to substantiate

12 MS. ARMSTRONG: Frank, what does the program

13 do? Do you differentiate, or do you just say two?

14 MR. STANONIK: Frank Stanonik, AHRI. As far

15 as what I don't get -- I didn't get the question here.

16 MS. ARMSTRONG: Do you -- so for a new

17 entrant into your water heater program, do you

18 differentiate between your certification program for

19 like storage type versus other types, or it's all just

20 water heater certification program?

21 MR. STANONIK: It's all just water heater

22 certification program. So if you had -- if you had a -
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1 - again, a totally new manufacturer, and they were

2 offering commercial storage water heaters and

3 commercial instantaneous water heaters, whatever, we

4 would just pick two of one of -- one of that flavor to

5 test.

6 MS. ARMSTRONG: Regardless of gas and oil as

7 well, and electric?

8 MR. STANONIK: I'm not sure on the fuel

9 thing, but probably yeah. I'd have to double-check

10 that.

11 MR. KLEISS: Yeah, gas and oil would be

12 substantially different. I would not propose combining

13 those two into the same set of tests.

14 MS. ARMSTRONG: So this is what you would

15 propose?

16 MR. STANONIK: Frank Stanonik, AHRI. Again,

17 I mean, you have -- you have commercial water heaters

18 that are essentially a tank with lots of flue tubes

19 inside them and the burners underneath. Most of those

20 models are called storage. Some of those models can be

21 called instantaneous by the historical industry

22 definitions.
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1 You have other commercial water heaters where

2 basically you're running the water through a tube, and

3 the flames are going over the tubes. Those are always

4 instantaneous.

5 MS. ARMSTRONG: Okay.

6 MR. STANONIK: And in terms of -- thinking in

7 terms of an AEDM, I -- you know, I -- I don't -- I

8 can't see how I could write an AEDM for design when

9 I've basically got tubes full of water, and I'm running

10 the heat of flames over those, how I can write an AEDM

11 for that product that would also cover this tank that

12 looks like this with lots of flue tubes in the middle.

13 And so that's what I was trying to

14 distinguish. And while -- before I lose the thought,

15 you probably need a separate substantiation category

16 for commercial heat pump water heaters, although

17 they're not covered yet, right?

18 MR. MYERS: This is Frank Myers with PVI.

19 Frank Stanonik, I believe the essential difference that

20 you're talking about is the storage volume greater than

21 10 gallons. That's the point at which you have to

22 begin using standby loss test, which is traditionally
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1 for storage. It's not really instantaneous or non2 instantaneous. It's less -- equal to or less than 10

3 gallons or greater than 10 gallons, or I guess it's up

4 to 10 gallons and then 10 gallons or greater. Yeah,

5 greater than 10.

6 Because you could have a full line of product

7 that was instantaneous by the current definition;

8 starts out with more input for the same amount of

9 storage, but then you put a bigger and bigger burner in

10 it. So it's very easy to model within the same product

11 type, but you're crossing that border between

12 instantaneous and storage. Those should all be in one

13 group for validation purposes, and then the ones less

14 than 10 gallons in the other group.

15 MS. ARMSTRONG: Did I get it right?

16 MR. MYERS: Yes.

17 MR. KLEISS: I disagree. Sorry, Jeff Kleiss.

18 We -- I'm dealing with a unit that does have greater

19 than 10 gallons but still qualifies as an instantaneous

20 water heater. The definition is 4,000 -- greater than

21 4,000 BTUs per hour input per gallon of storage.

22 Now, the standby loss only comes into play
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1 when you're above the 10-gallon mark, but the test

2 procedure for thermal efficiency does not change with

3 the -- whether you're classified as instantaneous or

4 not.

5 I understand what you're saying as far as the

6 different types of design as far as fire tube, a water

7 tube or circulating, non-circulating, things of that

8 sort. But I want to avoid adding additional test

9 burden for a product that has -- that does have a

10 similar type of design, but still crosses that boundary

11 of storage to instantaneous.

12 MS. ARMSTRONG: But this isn't tests you're

13 required to do for each model, so it's not a particular

14 model. This is the minimum amount of tests you are

15 supposed to do before you use simulations going

16 forward. So just because you have one model that

17 crosses over doesn't mean you're going to have to test

18 that model twice.

19 MR. STEPHENS: Phillip Stephens, HTP. This

20 gets back to the question that I had previously about

21 an AEDM that spans -- what are we calling these,

22 categories?
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1 MS. ARMSTRONG: Uh-huh.

2 MR. STEPHENS: Whether it's -- the number of

3 minimum tests required is additive or minimum.

4 MS. ARMSTRONG: It's additive.

5 MR. STEPHENS: So --

6 MS. ARMSTRONG: All right? So if you have --

7 MR. STEPHENS: -- to --

8 MS. ARMSTRONG: If you have -- say you have -

9 - you make ten models. They span three categories.

10 You need six tests. And then you can rate the other

11 four with your simulation.

12 MR. STEPHENS: Okay. To Jeff's point, if he

13 has one product in that category that crosses that

14 boundary for BTUs per gallon, then he will, by default,

15 have to have two additional tests. And there's no

16 physical construction other than maybe a couple more

17 windings in the heat exchanger to reach a higher BTU.

18 MS. ARMSTRONG: That is an option. Well, if

19 he falls into a different category, though, he has to

20 pick up that category. So if his product offering by

21 default spans another category, then he has to pick up

22 the requirements for that category.
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1 MR. STEPHENS: Right. And in order -- in --

2 MS. ARMSTRONG: But he doesn't have to test

3 that particular unit.

4 MR. KOJAK: There's no other -- there's no

5 other models in that other category whatsoever?

6 MS. ARMSTRONG: There are, for him.

7 MR. EISNER: Could we use "or" language?

8 MR. STEPHENS: But that's --

9 MR. EISNER: Can we use either/or language --

10 MS. MEYERS: You just -- yeah, you just

11 wouldn't use --

12 MR. EISNER: -- to take care of test problem?

13 MS. MEYERS: That model wouldn't be part of

14 the AEDM.

15 MR. KLEISS: In which case we would still

16 have to run additional tests to substantiate that

17 product, which is what we're trying to avoid. If we

18 run tests that are appropriate for that family of

19 products, for that type of design, then

20 MR. MYERS: This is Frank Myers, PVI.

21 Ashley, I agreed with what you put up, but in now

22 reading it again, what I was actually meaning is gas-
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1 fired water heaters greater than 10 gallons and gas2 fired water heaters less than -- less than or equal to

3 10 gallons. And I forget exactly which side of the

4 equal -- I think it's greater -- the first one would be

5 greater than or equal to 10 gallons, and then gas-fired

6 water heaters less than 10 gallons. And there's no

7 "and instantaneous." It's just lumping all water

8 heaters into those two categories.

9 MR. STANONIK: Frank Stanonik, AHRI. Again,

10 for the -- for the purposes of this, which is trying to

11 determine what you -- your minimums for an AEDM, I

12 really think it's -- really should be categorized, at

13 least in the -- in the gas and oil versions, by is it

14 tank type or tube type?

15 And that's all we need, because, again, going

16 to my idea that there's some common -- some thread of

17 commonality in all the models that get bunched into the

18 AEDM, I just can't see -- and that may be the limits of

19 my imagination, but I can't see how I could write an

20 AEDM that's going to cover tube-type water heaters,

21 whatever they look like, and tank-type water heaters at

22 the same time.
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1 MR. KLEISS: Jeff Kleiss, Lochinvar. We make

2 a tube-type water heater that is integrally mounted on

3 top of a storage tank.

4 So that is the unit that has, depending on

5 the input versus the volume of storage, is classified

6 as either a storage water heater or as an instantaneous

7 water heater. It would be categorized as a storage

8 water heater, in general, because it has that water

9 storage volume, but it crosses those two classification

10 boundaries.

11 But as far as testing, there's no reason why

12 that testing should not be -- why the same AEDM should

13 not be able -- be allowed to apply to that product,

14 even though it crosses from the boundaries of product

15 classification.

16 MR. STEPHENS: Phillip Stevens, HTP. My

17 recommendation in that case would be to pick one and

18 stick with it. Would the DOE have any opinion on

19 guidance for a product in that situation? Because,

20 generically speaking, we're in the same situation with

21 combined appliances with storage tanks, and that's

22 going to -- that's one of the things that I want to --
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1 one of the categories I want to propose.

2 MR. EISNER: Could we have language such as,

3 "If you have combined appliances, you may," and tell

4 them what they can do?

5 MS. ARMSTRONG: So, first of all, I think it

6 depends on how they map to the standards that are

7 required. I mean, I think that's fundamentally -- if

8 you have to run a standby loss test in addition to a

9 thermal efficiency test because you've crossed the

10 boundary, it's a different -- I mean, it's a different

11 test. It's another metric.

12 MR. KLEISS: The thermal efficiency test that

13 is conducted on this --

14 MS. ARMSTRONG: It gives you -- I understand

15 where we're going here.

16 MR. KLEISS: -- is the same test.

17 MS. ARMSTRONG: It gives you -- but you get -

18 - you have to report different numbers. You are now

19 subject to a thermal efficiency standard and a standby

20 loss standard.

21 MR. KLEISS: There is an additional number

22 that is reported, which is the standby loss test. And
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1 in the case of an instantaneous -- the instantaneous

2 water heater that has greater than 10 gallons of

3 storage and the storage water heater that has greater

4 than 10 gallons of storage, we have to report standby

5 loss on both of those, and we have to report thermal

6 efficiency done according to the exact same test on

7 both of those.

8 So my complaint is that I would be forced to

9 run an additional two tests on one model because it

10 falls into a different product class, even though it's

11 got consistent --

12 MR. STANONIK: Frank Stanonik, AHRI. First

13 of all, there's no -- absolutely don't have to run two

14 tests, but the product you describe, in my

15 categorization of tube-type products and tank-type

16 products, that is a tube-type product. You're running

17 water through tubes, and heat is being applied to the

18 water in the tubes. That's where the heating's

19 occurring. That's -- that is the -- where the critical

20 function of water heating occurs.

21 In a tank-type product, the water's in the

22 tank, and the heat is traveling through tubes within
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1 the tank to heat the water. Those are two very

2 fundamental different concepts, and, to me, two very

3 fundamental ways to define AEDMs that would fit one way

4 to heat water and another way to heat water. And then

5 you don't have to worry about what the water heater

6 looks like from the outside.

7 MR. STARR: This is Louis Starr with

8 Northwest Energy Efficiency Alliance. Kind of to go

9 with Frank, if the technology is substantially

10 different, I mean, what he's saying is that the

11 computer model to model a hot water tank, which you

12 heat the water from the bottom of the tank, as opposed

13 to water that you flow through a tube and boil it that

14 way, it seems like it's going to have two different

15 computer models; therefore, you need to have two

16 separate category -- or two test -- two models for

17 those things.

18 It doesn't seem -- I mean, I understand

19 reducing testing burden, but if the technology is

20 essentially different, then it seems like there needs

21 to be separate tests for them.

22 MR. KLEISS: Jeff with Lochinvar. I totally
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1 agree with what you're saying; however, the way that

2 the product classes are set out by DOE, we would not be

3 allowed to apply the same AEDM, or else we would have

4 to run separate tests for the instantaneous versus the

5 storage water heater.

6 MS. ARMSTRONG: That's what we're talking

7 about right now, right?

8 MR. KLEISS: Yes.

9 MS. ARMSTRONG: So, I mean, it's not -- this

10 is different than product classes, because our product

11 classes are much different than this. There's no two

12 tests. I mean, to the extent you manufacture a

13 product, your entire product offering, everything

14 Lochinvar makes, spans three of these categories, you

15 need six tests total, period.

16 MR. RIVEST: Ashley --

17 MS. ARMSTRONG: And then you can use your

18 AEDM.

19 MR. RIVEST: I'm not sure -- what are -- are

20 you saying that if you have a product that spans two

21 categories, you would like to use the test result for -

22 - in two categories? I don't see why you couldn't do
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1 that. I mean, the requirements are additive in term --

2 they're not necessarily additive if -- I think if the

3 product is the -- applies to both categories. I mean,

4 you can just decide that right now, that the

5 MR. KLEISS: I -- Jeff Kleiss, Lochinvar. I

6 think part of this is also that there's, I think, a

7 misconception --

8 MS. ARMSTRONG: Uh-huh.

9 MR. KLEISS: -- at how advanced our AEDMs

10 are, because, again, this is going back to sort of the

11 interpolation, where we would be applying an AEDM to a

12 single product family and substantiating that with two

13 tests, and then we would have another product family

14 and substantiate that with two tests, and

15 MS. ARMSTRONG: Why? Why are we talking --

16 you don't need two per product family.

17 MR. KLEISS: Because we are dealing with

18 different types of products; fire tube, water tube,

19 circulating. And we develop our -- again, our AEDMs

20 are not as advanced and developed, because we don't

21 deal with quite the breadth of product that maybe some

22 of the air handling air conditioning systems are. So
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1 we have a much simpler estimation, and we base it on

2 test data for that product family.

3 So because we are doing that type of testing

4 and validation for estimating efficiency just within

5 one product family, because of the trying to shoehorn

6 what we've been using as linear interpolation into the

7 AEDM label, we're being forced to do additional testing

8 --

9 MS. ARMSTRONG: I don't think so. I don't

10 think it -- I actually think you're doing more testing

11 than this requires.

12 MR. KLEISS: We are doing more testing.

13 MS. ARMSTRONG: So I don't think you would

14 need anything additional. And if your -- if your

15 models are subject to the AHRI verification program

16 annually, I think you would already have the testing.

17 MR. KLEISS: The issue is that we do not have

18 one AEDM that applies to all of our instantaneous water

19 heaters. We do not have one AEDM that applies to all

20 of our hot water supply boilers. We do it based -- we

21 do our ratings based on design, on product family. And

22 by -- because some of those product families cross
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1 product -- DOE product categories or product

2 classifications, that splits apart those families and

3 does require additional test burden.

4 MR. RIVEST: (Inaudible).

5 MR. KLEISS: Correct. We do -- because we do

6 not have a universal AEDM.

7 MS. ARMSTRONG: So in that case, I say you

8 can use them -- I mean, this is specific to --

9 MR. RIVEST: (Inaudible).

10 MS. ARMSTRONG: No. He wants to use -- if he

11 has a single test point that spans two product --

12 MR. RIVEST: That's not what he's saying.

13 MS. ARMSTRONG: Yes, he is.

14 MR. RIVEST: You're saying you don't have two

15 test points that fit in those categories, the lower and

16 the upper.

17 MS. ARMSTRONG: He doesn't have two unique

18 ones.

19 MR. RIVEST: No. No, that's not what he's

20 saying. If he did, that wouldn't be a problem.

21 MR. EISNER: Who's right, who's wrong?

22 MR. KLEISS: Jeff Kleiss. I don't know.
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1 MS. ARMSTRONG: If I told him he could use

2 that exact same test, which is a single-unit test, and

3 it count twice --

4 MR. RIVEST: Yes.

5 MS. ARMSTRONG: -- then it works?

6 MR. RIVEST: Yes. That's

7 MS. ARMSTRONG: Because he's defining an AEDM

8 as a specific AEDM for a product family.

9 MR. RIVEST: That's what I thought I

10 understood.

11 MS. ARMSTRONG: And he may have --

12 MR. RIVEST: But is that what it is?

13 MS. ARMSTRONG: He may have ten AEDMs. So

14 he's looking at this as, "I need 4 for each AEDM, and

15 that's 40 models," if you had 10 individual product

16 family AEDMs.

17 MR. RIVEST: And that's true. I mean, if you

18 -- if a manufacturer, for whatever reasons, had ten

19 distinct AEDMs, each one of those has to be validated.

20 I mean, that's, you know --

21 MS. ARMSTRONG: That's the difference here.

22 MR. RIVEST: And that's -- I mean, I work for
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1 manufacturers, but that's their choice. I mean, gee.

2 MR. STEPHENS: Philip Stephens --

3 MR. EISNER: If you're saying yes, are you

4 accepting the conclusion?

5 MS. ARMSTRONG: And in that case, I do think

6 that you can use the single test point to count twice.

7 MR. KLEISS: That really does get it. We're

8 dealing with basically six different AEDMs that we

9 have, one AEDM for each product family. What we're

10 trying to avoid is being forced to now have a seventh

11 AEDM because one of those families crosses a boundary,

12 and then an eighth because another one crosses a

13 boundary of product class.

14 MS. ARMSTRONG: You can use the same test

15 data.

16 MR. KLEISS: That's what you're saying. That

17 is not what --

18 MS. ARMSTRONG: We can write that.

19 MR. KLEISS: Okay. Good. That's what --

20 that's what I want. And I'm glad that we have

21 understanding now. That's what I was --

22 MR. EISNER: Let's put it up, and let's see
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1 if everybody agrees.

2 MS. ARMSTRONG: Let me think about that for a

3 minute, how to write this.

4 MR. EISNER: We can have the record read back

5 to you.

6 MS. ARMSTRONG: I see the --

7 MR. MYERS: This is Frank Myers, PVI

8 Industries. While she's typing that up, let me clarify

9 something with Jeff. As it's currently up on the

10 screen right up at the top, gas-fired water heaters

11 greater than 10 gallons, all AEDMs that if you have --

12 if your AEDM is going to cover all of that product, you

13 need two models.

14 MS. ARMSTRONG: Correct.

15 MR. MYERS: If you have one AEDM that covers

16 -- and you can group those AEDMs together in terms of

17 how they work, if they cover gas-fired water heaters

18 greater than 10 gallons, then that would be two models.

19 So it would seem that if you just put your

20 AEDMs together so that they were -- you characterized

21 them as a single entity, you would, for all gas-fired

22 water heaters, no matter instantaneous, storage-type,
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1 all of the traditional characterizations, you'd have

2 four test models. That seems pretty reasonable. If,

3 as a manufacturer, you need to do more work than that

4 to validate the sub-AEDMs within this main AEDM, do

5 whatever you think you need. But at the end of the

6 day, if this is what we want with --

7 MS. ARMSTRONG: You want that?

8 MR. MYERS: No, I was saying two there and

9 two in the next one equals a total of four. And that

10 seems reasonable in terms of the groupings. It doesn't

11 get at exactly what Frank Stanonik was talking about,

12 because you could have a tube-type water heater that

13 has more than 10 gallons, but they're not very common.

14 This is -- this is -- the vast majority of tube-type

15 water heaters would be those less than 10 gallons, and

16 the vast majority of the storage-type water heaters

17 would be those with greater than 10 gallons of water.

18 So it largely gets at what Frank was talking

19 about, and I think it is a very simple way to do it,

20 and all of these characterizations are a part of the

21 product categories, so it's easy to see what test

22 procedure goes to it.
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1 So what you have up there, other than the

2 fact that I would change those to say gas-fired water

3 heaters and hot water supply boilers greater than, and

4 the same thing in the second line, as opposed to a

5 separate entity. Right. And then one of those, of

6 course, is -- has an equal -- greater than or equal, I

7 believe.

8 MS. ARMSTRONG: Right. Yeah, I don't know

9 what it is, but

10 MR. MYERS: Whichever one it is.

11 MS. ARMSTRONG: Okay.

12 MR. EISNER: Do we need both, or do we just

13 need the last change and delete the last bullet on the

14 page?

15 MR. MYERS: I'm sorry. What was that?

16 MR. EISNER: Well, the question is this was

17 put in to take care of the problem, and it sounds like

18 now you might be fixing the problem here, or do you

19 need both?

20 MR. MYERS: I think -- this is Frank Myers

21 again. From my perspective, the bottom bullet is still

22 valid. If you have separate AEDMs, then you need to do
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1 whatever is up in the upper section to -- that's

2 required to validate it.

3 If you put different components of an AEDM,

4 which may have previously been called separate AEDMs,

5 if you put those into a single AEDM, then that single

6 AEDM would have to comply with what's up at the top.

7 So I think that's a valid statement down

8 there, but each AEDM does need to be substantiated.

9 But if you put those into a single thing that you

10 characterize as an AEDM, then you still validate that

11 with the numbers above.

12 I didn't get to it, but I would propose the

13 same groupings when we're talking about oil.

14 MS. ARMSTRONG: Yeah, I made them the same, I

15 think.

16 MR. KLEISS: What you have on the screen

17 satisfies me. Thank you.

18 MR. STEPHENS: Phillip Stephens, HTP. The

19 last sentence, if there is a manufacturer who has

20 separate AEDMs for, say, a fire-tube product and a

21 water-tube product and the fire-tube -- the water-tube

22 product spans residential boilers and commercial
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1 boilers, then what you're saying there is we can use

2 the same test data for residential and commercial?

3 MS. ARMSTRONG: This only applies to

4 commercial.

5 MR. STEPHENS: I'm sorry?

6 MS. ARMSTRONG: This only applies to

7 commercial, period. I don't know if the last bullet's

8 the best way to say this, but it's a starting point for

9 something, for the idea.

10 MR. STARR: I just had a couple questions.

11 So I guess heat pump water heaters are not part of

12 this, and then the other thing is the small electrical

13 instantaneous water heater, like underneath faucets and

14 things, is that in the same category as electric water

15 heater at the 40-gallon, or does it need its own

16 separate category?

17 MS. ARMSTRONG: So commercial heat pump water

18 heaters are separated out. Residential ones are off

19 the table. And I don't exactly know what you mean by

20 "under the faucet," but if it's a 2 to 20-gallon --

21 MR. STARR: Yeah.

22 MS. ARMSTRONG: -- then it's a residential
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1 unit that is just not -- so that wouldn't be on the

2 table either. We're talking about like those hybrid

3 units.

4 MR. HUNT: Hi, this is Marshall Hunt with

5 PG&E. You do have boosters on dishwashers for

6 restaurants that are huge loads, a lot of kW thrown in

7 there to boost it to the right temperature. Are those

8 covered? Electric resistance, booster heaters --

9 MS. ARMSTRONG: I know. So right now -- it's

10 complicated is the best answer. So right now, DOE is

11 in a rule -- a separate rule to take a look at coverage

12 as it relates to water heaters from the December energy

13 bill. Right now, under 12 kW electric instantaneous

14 are residential in nature, even though we realize some

15 are marketed as whole-house, all the way up to like 25,

16 which I think is about what you're talking about

17 boosters, more or less.

18 So I would say that that's not to be dealt

19 with here, but is being dealt with somewhere --

20 MR. SACHS: This is Harvey, and --

21 MS. ARMSTRONG: -- by the Department.

22 MR. SACHS: -- Marshall, I think we can moot
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1 this one on the basis that it's really hard to make an

2 inefficient 25 kW resistance heater. It's got to go

3 somewhere.

4 MS. ARMSTRONG: So are we happy with water

5 heaters?

6 MALE SPEAKER: It's a starting point. Louis?

7 MR. STARR: Just one last -- on the heat pump

8 water heaters, I know they have two different tiers, a

9 northern tier --

10 MS. ARMSTRONG: Uh-huh.

11 MR. STARR: -- and a southern tier. Does

12 that need to be split out? Because they -- the

13 performance changes, depending upon that.

14 MALE SPEAKER: (Inaudible).

15 MR. STARR: Oh, that's true.

16 MS. ARMSTRONG: But there's not for

17 commercial.

18 MR. STARR: Not commercial. Never mind.

19 MS. ARMSTRONG: They're mostly just add-on

20 heat pump water heaters.

21 MR. EISNER: Okay. Any other thoughts?

22 MR. KLEISS: Jeff Kleiss, Lochinvar, once
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1 again. Sorry. Unfired hot water storage tanks, what

2 are we testing?

3 MS. ARMSTRONG: R value. R value.

4 MR. KLEISS: Based on what?

5 MS. ARMSTRONG: The footnote in the table,

6 footnote in the definition somewhere. Hold on. I'll

7 find it.

8 MR. MYERS: This is Frank Myers at PVI.

9 That's a whole new concept for the industry. What the

10 industry has done for the last -- well, since there was

11 a requirement for the amount, has been to get a copy of

12 the test report from the vendor that provides the

13 insulation. We keep that on file to verify that we meet

14 the insulation requirement in the standard. The

15 industry has never conducted independent tests for the

16 insulation that wraps a unit, so

17 MS. BARHYDT: So are you suggesting that this

18 is a product that should not have an AEDM provision?

19 MR. MYERS: I agree that it should not have

20 an AEDM provision. It should not have a test

21 requirement beyond that that the insulation provider

22 conducts.
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1 MS. BARHYDT: So the only part of that that

2 would be within the scope of this rulemaking would be

3 the AEDM part of it? The standard is there, and I

4 don't know what we have or have not said in -- with

5 respect to testing in the past, but I know, generally

6 speaking, we are perfectly fine with people relying on

7 representations from suppliers, so

8 MR. MYERS: Probably the safest thing to do,

9 since we're not talking about the test requirements, is

10 to leave it in, and our AEDM would use whatever method

11 we determine as technically feasible to make that

12 judgment; that way, we're not stuck with having to

13 actually physically conduct tests on insulation that we

14 get from an insulation vendor because we're water

15 heater or boiler manufacturers.

16 MS. BARHYDT: I agree with that. We should

17 leave it in.

18 MS. ARMSTRONG: Next up.

19 MR. STEPHENS: Phillip Stephens, HTP.

20 MS. ARMSTRONG: Oh, sorry.

21 MR. STEPHENS: One other question to make

22 Harvey's day. Combined appliances, we haven't
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1 addressed them anywhere. Do we want to? Can we?

2 MS. ARMSTRONG: Combined commercial

3 appliances?

4 MR. STEPHENS: Yes. For hot water and

5 domestic heat.

6 MS. ARMSTRONG: Can we think about that as we

7 move through? Do you have a suggestion? I mean, right

8 now we have specific covered categories. So you know,

9 to the extent it's a combined appliance that also meets

10 the definition of a water heater, it has to be

11 compliant with the water heater regs. To the extent it

12 meets the definition of boiler, it has to be compliant

13 with the boiler regs. One appliance has covers, too.

14 Not separated out right now. But these allow you to

15 use an AEDM for a separate function.

16 MR. STEPHENS: So by the last point, if a

17 manufacturer uses multiple AEDMs, the same single unit

18 test may be applied to substantiate separate AEDMs. So

19 for a combined appliance, we could use the same test

20 report for both AEDMs, whether it be for commercial

21 water heating or space heating.

22 MS. ARMSTRONG: If --
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1 MS. BARHYDT: So would that be the same test

2 procedure?

3 MR. STEPHENS: No, no.

4 MS. BARHYDT: Then how would you use the same

5 test report for both?

6 MS. ARMSTRONG: They just run the tests at

7 the same time.

8 MR. STEPHENS: Or we could use something

9 similar to the fan curves. We could develop a

10 correlation; if it's this on an AFUE test or a thermal

11 efficiency test for the boiler, then it will be this

12 for the thermal efficiency for the water heater side.

13 MR. STANONIK: Frank Stanonik with AHRI. I

14 mean, up to this point, all the DOE discussions of

15 combination have been in the context of either the

16 residential boiler standards or the residential furnace

17 and boiler efficiency test procedures. On this

18 particular issue, if we're going to drag this into this

19 discussion of commercial certification, I think we've

20 gotten way ahead of the, of the horse or the cart way

21 ahead of the horse because I've never heard discussion

22 about test procedures for commercial combination
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1 equipment.

2 MS. ARMSTRONG: I think that's what I was

3 trying to say, right?

4 MS. BARHYDT: Yeah. I --

5 MS. ARMSTRONG: Right now we just have water

6 heaters --

7 MS. BARHYDT: Yeah.

8 MS. ARMSTRONG: -- and we have boilers and to

9 the -- we don't have a separate covered combined

10 appliance category.

11 MR. SACHS: This is Harvey Sachs from SA.

12 Thank you.

13 MR. EISNER: Marshall.

14 MR. HUNT: Hi. Marshall Hunt, PGD. One last

15 thing on the heat pumps, I think as we move towards

16 zero net energy in California, we're going to be seeing

17 hot water heat pumps commercial with ground source or

18 water source. What is the status of those kinds of

19 appliances? Do we have a test standard even? I don't

20 know as a ground source hot water heater dedicated.

21 MS. ARMSTRONG: DOE doesn't have a regulatory

22 test procedure for heat pump water heaters, period.
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1 MR. HUNT: Okay.

2 MS. ARMSTRONG: Commercial.

3 MR. DOPPEL: Paul Doppel with Mitsubishi

4 Electric. The only standard I know of that tries to

5 deal with multiple types of components combined is

6 ASHRAE. It's a draft ASHRAE Standard 206 which is out

7 for public comment at this time.

8 MALE SPEAKER: Isn't that Wayne Reedy's Air

9 Solutions?

10 MALE SPEAKER: Also --

11 MR. DOPPEL: It includes --

12 MALE SPEAKER: -- been modified to cover

13 water.

14 MALE SPEAKER: Okay.

15 MR. DOPPEL: You could put almost any kind of

16 combination in that.

17 MALE SPEAKER: Right.

18 MR. DOPPEL: Okay.

19 MR. EISNER: Any disagreement with this list?

20 MS. ARMSTRONG: I should go back to the right

21 list.

22 MR. EISNER: Huh?
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1 MS. ARMSTRONG: I have the wrong list up.

2 Sorry.

3 MR. EISNER: No disagreement, no objections?

4 (No audible response.)

5 MR. EISNER: All right. Let's go to the next

6 one.

7 MS. BARHYDT: Four each?

8 MS. ARMSTRONG: Shall we just keep in line?

9 MR. EISNER: Comments? Questions?

10 MR. KLEISS: Jeff Kleiss, Lochinvar. The

11 commercial packaged -- or packaged boilers, once you

12 cross the 2.5 million BTU per hour threshold, the test

13 procedures change.

14 MR. MYERS: What threshold?

15 MR. KLEISS: 2.5 million. Based on this, are

16 we being allowed to, if we have a unit that is smaller

17 than that, test to both procedures, and if a unit is

18 larger than that, test to both procedures, and then use

19 -- develop an AEDM based on those tests?

20 MS. ARMSTRONG: No.

21 MR. KLEISS: Then I don't like it.

22 MR. STANONIK: Frank Stanonik, AHRI. If you
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1 didn't have the different metric applied to the 2.5

2 million BTU per hour in less models then, in fact, at

3 least my information is that in fact you could in fact

4 develop an AEDM that would cover both steam and hot

5 water boilers if you didn't have an efficient --

6 different metric. But you do. So you can't, you can't

7 develop an AEDM on steam boilers from 3 million to 10

8 million and apply it to hot water boilers at 2 million

9 to 500,000. It's a different metric.

10 MR. KLEISS: Where you have a substantially

11 different design, steam to water, I agree. When we're

12 talking about water boilers, and we have a group of

13 products that are, you know, 1 million, 2 million BTUs

14 per hour, and then you have the same type of design

15 that goes up to a 5 million, 10 million BTU per hour

16 unit, is there a justifiable reason why we couldn't

17 test both for thermal or a small one for thermal and

18 combustion, and test a large one for thermal and

19 combustion, and use the thermal to create a thermal

20 AEDM and the combustion to create a combustion AEDM?

21 Even though they're in the different product classes

22 it's the same design. That way you only set up two
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1 units. You don't have to produce these very low2 volume, potentially custom units and reduce the test

3 burden in that way where you're applying the

4 appropriate test procedures to create an AEDM on two

5 models.

6 MR. STANONIK: Frank Stanonik with AHRI. So

7 there -- okay. I think I heard what you said. So

8 they're basically the same design. The fact that the -

9 - at some point of input they have a different

10 descriptor is a -- that's an accident of test

11 efficiency or whatever and not necessarily design. So

12 I guess if you were willing to run the unnecessary

13 thermal efficiency test on a -- sake of a discussion

14 here, a 5 million BTU unit and the unnecessary

15 combustion efficiency test on a 500,000 unit, it

16 certainly is foreseeable you could develop the

17 information that would validate the AEDM, yes.

18 MR. KLEISS: For the very large sizes,

19 typically the actual conduct of a thermal efficiency

20 test, the conduct of a combustion efficiency test is

21 very minor compared to the expense of constructing,

22 installing and setting up for a test, a unit. So
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1 running dual tests on appliances is common practice.

2 MR. MYERS: This is Frank Myers, PVI. I

3 would very much disagree with how Ashley has split

4 those into above and below 2.5 million. As has been

5 stated, you frequently have the exact same design

6 product which has the same heat transfer

7 characteristics. All that is changing is the metric,

8 and that's easily extendable in an AEDM. So it would

9 seem to me having all the sizes lumped together would

10 be appropriate.

11 MS. ARMSTRONG: We had that originally.

12 MR. MYERS: When you're wanting to validate

13 the AEDM, the key here is looking at the product type,

14 not what the metric is.

15 MS. ARMSTRONG: Happiness?

16 MR. KLEISS: I'm sorry if I didn't

17 communicate that clearly enough for --

18 MS. ARMSTRONG: I started this one. This is

19 how I started, right? And we agree that natural and

20 mechanical drafts should all be lumped together as

21 well.

22 MR. SUTPHEN: This is John Sutphen, Cleaver-
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1 Brooks. Historically and currently, we use actual test

2 data from steam tests and use that to create an AEDM

3 for hot water. Grant you that the design is the same

4 from the steam, the hot water vessel.

5 MS. ARMSTRONG: This would not allow you to

6 do that.

7 MR. SUTPHEN: Then I disagree with what you

8 have up there.

9 MS. ARMSTRONG: At least you would have to --

10 for this one, you would have to test for hot water

11 before you could do it. And then you could do it

12 freely after that.

13 MR. SUTPHEN: I still disagree. It's just

14 not financially feasible for most boiler companies that

15 build hot water boilers in the range that we do to buy

16 the capital equipment involved with testing the actual

17 hot water boiler.

18 MR. KLEISS: And specific, you're dealing

19 with such a high output you need to be able to exhaust

20 the steam to atmosphere rather than cool and

21 recirculate water, hot water. Is that correct?

22 MR. SUTPHEN: Correct. It would apply for
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1 both the low-pressure steam; we can't even do that. We

2 usually run the test at 100 psi, do a stack-over-steam

3 method, and based on independent test data we proved

4 that the formulas that we use are very reliable, and we

5 can extrapolate that down to the low-pressure steam and

6 the hot water for same design.

7 MR. RIVEST: Mike Rivest. I think there's a

8 precedent here for collapsing the product classes where

9 the engineering is the same. So rather than having a

10 product from one category qualify another category, you

11 should just collapse the categories and do two of water

12 or steam. In this case, it would be two steam.

13 MR. MYERS: This is Frank Myers, PVI. What

14 are you proposing then when you say collapse?

15 MS. ARMSTRONG: Well, what he wants -- what

16 he needs is this.

17 MR. MYERS: Oh. I'm not sure that that would

18 work because you do have steam-only units that don't

19 collapse into water heaters or hot-water boilers. What

20 would be a better solution, if we can do it this way,

21 would to say for commercial steam package boilers,

22 whether they're oil fired or gas fired, that you can
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1 use the same data to represent compliance with hot

2 water; I'm not sure what the right words would be; that

3 you test it on steam and those numbers. If you're

4 willing to accept those numbers which are almost always

5 lower than the, than the correlating water boiler, then

6 if you're willing to accept those steam number

7 efficiencies as water efficiencies, you don't have to,

8 you don't have to do additional tests. It's what AHRI

9 does. That's what the industry has done for over 40

10 years.

11 MS. ARMSTRONG: So I can do it as a sentence,

12 or I mean really this covers the same thing.

13 MR. KLEISS: But isn't that still an AEDM?

14 MS. ARMSTRONG: Yes.

15 MR. MYERS: How many miles do you have to --

16 MR. SUTPHEN: This is John Sutphen, Cleaver17 Brooks. The whole hot water part of it would be an

18 AEDM. There would be no --

19 MS. ARMSTRONG: Right --

20 MR. SUTPHEN: -- actual testing.

21 MS. ARMSTRONG: He needs this in order to do

22 what he wants to do because he would only test the
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1 steam side. His four models would be all steam.

2 MR. KLEISS: And I think what Frank is

3 referring to is just the methodology of determining

4 that AEDM, but it still is an AEDM that's based on the

5 steam testing.

6 MR. MYERS: This is Frank Myers, PVI. What

7 I'm saying is if someone has only units that are both

8 steam and water, they shouldn't have to test -- that

9 are gas, they shouldn't have to test four models to

10 verify their AEDM. They should only have to test two

11 models to verify their AEDM.

12 MS. ARMSTRONG: I think this does it --

13 MR. STEPHENS: Phillip Stephens, HTP. I

14 think if we took the last sentence off the previous

15 slide that we developed and added it to this one --

16 MS. ARMSTRONG: It's a single AEDM.

17 MR. STEPHENS: If a manufacturer uses

18 multiple AEDMs.

19 MS. ARMSTRONG: It's a single AEDM.

20 MR. STEPHENS: Well, if -- right now,

21 apparently John has multiple AEDMs, one for steam, one

22 for hot water.
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1 MS. ARMSTRONG: No, it's the same.

2 MR. SUTPHEN: No --

3 MR. STEPHENS: The same. Well --

4 MS. ARMSTRONG: They just use the one tub.

5 MR. STEPHENS: If we took the last sentence

6 here, and it approved that you could use the same test

7 for two AEDMs, it would achieve his goal.

8 MR. EISNER: It already says that.

9 MS. ARMSTRONG: I don't think so. I mean --

10 MR. EISNER: It already says it.

11 MR. STANONIK: Frank Stanonik with AHRI.

12 Ashley, in this case it might be easier to simply say

13 hot -- well, that's going to be a little crude -- hot

14 water only commercial package boilers, steam only, and

15 then you'd have a third line that would be steam/hot

16 water --

17 MS. ARMSTRONG: Oh. That's a good idea.

18 MR. STANONIK: -- meaning those models that

19 can be -- that come in both --

20 MS. ARMSTRONG: Got you.

21 MALE SPEAKER: And/or.

22 MR. STANONIK: No, not and/or. If you --
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1 MS. ARMSTRONG: I got you.

2 MR. STANONIK: -- had a series of models, if

3 you had a series of models that are only hot water

4 models and an AEDM, you'd have to test two. If you had

5 a series of models that were only steam models, and you

6 had an AEDM for those, you'd have to have test two.

7 But if you're like most people in the business where

8 many of your models can be ordered either steam or hot

9 water, and you write an AEDM for that group of models,

10 you still only need two.

11 MS. ARMSTRONG: And they can be steam or hot

12 water at your discretion.

13 MR. STANONIK: Right.

14 MS. ARMSTRONG: Yeah. There you go.

15 MR. STANONIK: Well, I put hot water/steam.

16 You know, when you order it's only going to do --

17 MS. ARMSTRONG: Yeah, yeah, yeah.

18 MR. STANONIK: -- one or the other. It's not

19 going to do both for you. At least not by design.

20 MS. ARMSTRONG: I just meant that --

21 MR. SACHS: This is Harvey with a

22 hypothetical. What happens if DOE and industry move to
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1 a test where we have a low-temperature return instead

2 of the existing artificial system, so we're starting to

3 test units as though they were condensing? Is this

4 going to change particularly the question of hot water

5 steam package boilers?

6 MR. KLEISS: Jeff Kleiss, Lochinvar. I

7 understand what you're saying. It would probably --

8 the AEDM that would apply to the condensing boilers

9 would probably not be the same AEDM that would be

10 applying to these steam/hot water boilers.

11 MR. SACHS: Does that mean that we should

12 reserve for an AEDM for possible future use or just not

13 bother with it?

14 MR. KLEISS: Jeff Kleiss, Lochinvar. I think

15 that what we're looking at is a much broader view of

16 AEDMs and validation of -- or number of tests needed to

17 substantiate an AEDM and that you're talking about

18 something that's a -- I don't think we need to create a

19 regulation or a rule based on --

20 MALE SPEAKER: (Inaudible.)

21 MR. KLEISS: Yeah. Or demanding that

22 manufacturers set up separate AEDMs. Rather, allow
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1 them the opportunity to do that when that test

2 methodology materializes.

3 MR. STANONIK: Yeah. Frank Stanonik

4 from AHRI. Harry, I think that what we're talking about

5 is hopefully we can get an AEDM that is useful. And I

6 think what you're talking about is a change in

7 circumstance which may cause people to develop some new

8 AEDMs because they'll have a new metric. But I don't

9 think the AEDM concept we've come up with here should

10 in any way hamper or conflict with whatever procedure

11 might come out of 155.

12 MR. SACHS: This is Harvey. Thank you.

13 MR. EISNER: Do we have any disagreement with

14 this?

15 (No audible response.)

16 MR. EISNER: Okay. Perfect timing, Ashley.

17 MS. ARMSTRONG: I'm coming.

18 MR. EISNER: We got agreement on this list.

19 MS. ARMSTRONG: Furnaces is next.

20 MS. BARHYDT: Actually, one question on I

21 think it was this one. I made a mental note to come

22 back, and I forgot about it. Is this the one where we
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1 talked about there being different metrics applicable

2 based on size? So we might add a note that it's testing

3 of two models, but it's testing for all applicable

4 metrics. It's not just somehow doing a test for one

5 metric.

6 MR. KLEISS: That should probably be true for

7 all the slides.

8 MS. BARHYDT: So just a general principle?

9 MR. EISNER: So we want to see that on the

10 charts?

11 MS. ARMSTRONG: I don't think that would be a

12 valid test if they don't have the right metrics there.

13 I don't think you need it to be.

14 MS. BARHYDT: If you don't mind putting it up

15 there, I'm worried about forgetting to put language in

16 at a later date.

17 MR. HUNT: This is Marshall Hunt from PG&E.

18 Is gas understood to be both propane and pipeline

19 natural gas?

20 MS. ARMSTRONG: Yes.

21 MR. HUNT: Okay.

22 MR. STANONIK: What company are you with,
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1 Pacific Gas and Electric?

2 MALE SPEAKER: Is gas defined in the regs?

3 MR. HUNT: Propane does not exist.

4 MR. EISNER: Do we want to add something that

5 -- do we want to add something that gas includes

6 propane?

7 MR. CYMBALSKY: Gas is gas.

8 MR. EISNER: I'm just --

9 MR. BAUMAN: It's a transportation --

10 MR. EISNER: Okay. Gas-fired furnaces, oil11 fired furnaces.

12 Seeing no hands, I assume everybody approves

13 this chart?

14 MR. STANONIK: Yeah, those are easy.

15 MR. EISNER: Quiet.

16 MS. ARMSTRONG: All right. Back to the hard

17 one which I didn't fill out.

18 SPEAKER: This would be a good time for a

19 break, don't you think?

20 MS. ARMSTRONG: Yes.

21 MR. EISNER: Is this the last of the list?

22 MS. ARMSTRONG: Yes. This is --
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1 MR. EISNER: Oh, this is the harder --

2 MS. ARMSTRONG: -- what I would guess is the

3 most difficult.

4 MR. EISNER: Oh. Keep them going.

5 MS. ARMSTRONG: I thought water heaters was

6 going to go easy, but ...

7 MR. EISNER: All right. Why don't we take a

8 ten-minute break?

9 MS. ARMSTRONG: So while we have a break,

10 maybe people can think of ideas for this one.

11 MR. EISNER: Make it look simple to start

12 off.

13 MS. ARMSTRONG: Well -- I agree.

14 (Off the record at 3:26 p.m.)

15 (On the record at 3:44 p.m.)

16 MR. EISNER: All right. Is everybody ready

17 to get started? We have Ron Shebik who wants to make a

18 comment before we get going with the next list.

19 Ron?

20 MALE SPEAKER: (Inaudible.)

21 MR. EISNER: Oh, you don't know? Let me know

22 when he comes back. Okay.
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1 All right. We've lost him for a few minutes.

2 We're on our next list, ice cream freezers, which I'm

3 assured will be quite simple and easy to get through.

4 MALE SPEAKER: Just ice cream freezers --

5 MR. EISNER: Maybe we should ...

6 (Crosstalk)

7 MR. EISNER: You ready?

8 We got agreement on ice cream freezers.

9 MS. ARMSTRONG: Great. Who's bringing one?

10 MR. EISNER: Okay. Do you want to do any

11 introduction on this list, any comments?

12 MS. ARMSTRONG: Well, sure. I can do some

13 introduction on this list.

14 So right now we have regulations for all

15 types of commercial refrigeration equipment, self16 contained, remote condensing, their orientation,

17 whether they're open or closed, whether they're

18 transparent, their rating temperatures in terms of

19 refrigerators versus freezers versus ice cream

20 freezers. So it's a question of, you know, we have a

21 wide variety of product classes, and similar to

22 commercial air conditioning we condensed a lot of into
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1 discrete categories.

2 So the first question is what are discrete

3 categories that need to be separated out just as

4 minimum testing requirements?

5 MR. HON: There's no way you can apply the

6 different temperatures to the same set of calculations

7 because the units are not built to handle multiple

8 temperatures, so whatever temperature you test at, that

9 is a separate model.

10 MS. ARMSTRONG: And we have three rating

11 temperatures, right?

12 MR. HON: Yes.

13 MS. ARMSTRONG: So that covers refrigerators,

14 freezers and ice cream freezers.

15 MR. HON: Yes.

16 MS. ARMSTRONG: So do I have it here? Is

17 this enough, or do I need to go to -- I mean this

18 covers self- contained remote and then the three

19 temperatures, and that's it.

20 MR. HON: It is physically impossible to rate

21 an open-air vertical refrigerator with a glass door

22 vertical refrigerator. They do not compare in any way.
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1 Basically, if you take all your categories which are

2 presently in the standard, almost every one of those is

3 a separate group.

4 MS. ARMSTRONG: So you're of the opinion that

5 each separate category in our regulations, and I'll

6 count them in a minute; there's like --

7 MALE SPEAKER: Thirty-eight.

8 MS. ARMSTRONG: -- thirty some -- 38? You

9 think you need at a minimum 38 models to substantiate

10 an AEDM?

11 MR. HON: They're not related to each other.

12 There's no way around it.

13 MS. ARMSTRONG: So the proposal on the table

14 is 38.

15 MR. BAUMAN: I'm going to say less than 38.

16 I do think, as Charlie said, there's comparisons. But

17 when you're creating an AEDM, you're going to -- you

18 may have a formula for calculating your door and the

19 type of door you had, the type of -- so I think there

20 are some commonalities again where you, you know, we

21 might talk about, again, what variety you have to have

22 within there. But I think you could use the same AEDM
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1 to calculate a glass door cabinet and a solid door

2 cabinet. Be two separate sets of calculations because

3 your door insulation is different, your condensing is

4 different, your heating system may be different.

5 I agree on refrigerators and freezers

6 possibly, but I think even freezers and low-temp

7 freezers, again, you may be different size unit. You

8 may be different type of defrost. But if you can

9 validate against one of those classes, again, you have

10 to -- when you actually run the AEDM they're different

11 models that you have to do within it. But I think for

12 validation you could, you could put ice cream freezers

13 and freezers together, and you could put glass door and

14 solid door together. But again, they'd have to be --

15 they're different basic models. So when you do the

16 calculations you have to run them separately.

17 MR. EISNER: Before we go too far, I want to

18 give Ron a chance because I think it pertained to what

19 we were talking about before the break.

20 Ron, are you on the line now?

21 MR. SHEBIK: I'm on. I apologize. I had to

22 redial back in, so I missed some of the conversation.
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1 I just wanted to point out that I -- as far as the

2 number -- the testing required for substantiation with

3 the use of an AEDM, I think we need to be conscious on

4 a CRE that, again, to minimize the amount of testing

5 we're pushing to do, there's enough push from our

6 customers; customers are very knowledgeable and aware

7 of energy efficiencies. So we have enough push from

8 our customers as well as checks and balances amongst

9 our competition to keep us in check. So I'm just

10 trying, you know, looking at what the other groups

11 discuss in your various tables, looks like you got

12 quite a large number of tests are being required and

13 I'm just -- I'm of the opinion that for CRE that's not

14 necessarily the case.

15 Again, I apologize, I missed -- Charlie was

16 just starting to speak when I had to redial, so I

17 missed everything that Charlie said.

18 MS. ARMSTRONG: The highlight was --

19 MR. SHEBIK: I do have --

20 MS. ARMSTRONG: -- that you should test 38 at

21 a minimum was the highlight.

22 MR. SHEBIK: Okay. I do have one question
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1 for Ashley, I believe, and that is, and just to make

2 sure -- and again, I'm not sure the --

3 MS. ARMSTRONG: Was it something in the

4 middle?

5 MR. SHEBIK: -- but Ashley, if you have a

6 case you're testing on our basic -- to represent a

7 basic model group, and in that case you can vary your

8 components in the case as far as standard efficiency

9 and high efficiency components, would that be

10 considered two different cases or two different tests?

11 Or would you be able to substantiate the more efficient

12 model via the AEDM without doing additional testing?

13 MS. ARMSTRONG: The way this is written, as

14 long as you -- well, so first of all, we're trying to

15 decide what's that minimum number of tests. But

16 assuming you had that minimum number of tests done, you

17 could just use your AEDM.

18 MR. SHEBIK: Okay. Very good. And by that,

19 you could -- the information that you gain as far as

20 your efficiency numbers, that could be made public,

21 that could be published information without additional

22 testing?
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1 MS. ARMSTRONG: Correct. That's what we're

2 going for here, allowing for rating based solely on

3 simulations once the minimum amount of testing has been

4 done.

5 MR. SHEBIK: Very good. Thank you. I just

6 wanted to verify that. Thank you.

7 MS. ARMSTRONG: So I've kind of come up with

8 maybe a middle solution, consolidating at least the

9 orientation. This does still separate out self10 contained versus remote, open versus closed and then

11 refrigerators versus freezers but not vertical versus

12 horizontal versus -- is this a reasonable start? Can

13 we further consolidate?

14 MS. BARHYDT: Another possibility could be to

15 have the self-contained to self-contained refrigerator

16 to freezer to remote to remote refrigerator to remote

17 freezer to -- but then have as a separate line item

18 that the tests for the AEDM have to have at least one

19 open and one solid and one glass door, if those are in

20 your product offerings, so that instead of having the

21 duplication of two open and two closed, you could kind

22 of hit multiple points using a single test.
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1 MR. HON: This is Charlie Hon. Basically, we

2 have -- I think we have several things going on here.

3 Number one is that the self-contained units have been

4 regulated and supposedly enforceable regulations since

5 2007 or 2008. And those of us who have been in the

6 industry that long and have actually done our homework

7 already have test data for all this, or we wouldn't be

8 selling product or shouldn't be selling product. So I

9 don't know what the big deal about it is. Two models

10 is not statistically valid. It should be at least

11 three. But we should have already had all this testing

12 done four years ago. So why are we fighting over how

13 many units we have when we should have already had

14 hundreds more than this done?

15 MS. DANE: Mary Dane, Traulsen. I'm sure

16 this is going to be no surprise, but I disagree with

17 Charlie.

18 MR. HON: About what?

19 MS. DANE: Well, just the -- well, I agree

20 that we have, we have a lot of, a lot of fractions

21 within the types. We're in agreement on that. The

22 point is is that we're still at substantiation, and I
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1 know that -- I want to see how to say this right. We

2 have a lot of historical data, and I believe we can use

3 that for our strengthening our models. But I have a

4 problem with requiring us at the substantiation level

5 to do 3, 4, 36, 16. I mean, that way -- I mean that's

6 very burdensome. It would tie up the labs. We'd never

7 be able to develop a new product. You know, it is just

8 too much testing to do at that level.

9 MS. BARHYDT: If you have a new product

10 offering, and you already have an AEDM, it wouldn't

11 require additional testing unless it was in a new

12 product area that you didn't already have

13 substantiation for.

14 MR. STARR: This is Louis Starr with NEEA.

15 You know, to the way we've done the last products to

16 date, that we've just covered earlier today, is that we

17 sort of split it out based upon where a likely AEDM is

18 there. So unfortunately, there may be a lot of classes

19 here. But it seems like that -- seems like the logical

20 thing. And even just what you have here, I mean

21 there's low-, medium-, and high-temperature

22 refrigeration systems which work -- all three of those
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1 work at different head pressures. And then there's

2 other factors that come in there where you have closed

3 and open doors. And so all those things are different

4 models, kind of like the same discussion of the hot

5 water tanks, and so, you know, they -- the one AEDM is

6 probably not going to describe those, at least between

7 medium-, low- and high- temperature refrigerations.

8 And then I don't know about the models, the

9 doors and the not doors. Maybe there is -- I think he

10 was alluding to that; there is ways to account for that

11 that maybe could be counted in through an AEDM. But

12 when you're doing mathematical models describing

13 systems that are different levels or different

14 operation and refrigeration pressures and things, it

15 doesn't seem like a good idea. So I'd say at least

16 splitting it up to those three, and then to the extent

17 that you can add more of the other items that can

18 really be accounted for, but at least medium-, low- and

19 high-temperature refrigeration systems basic minimum

20 for those.

21 MR. HON: Charlie Hon. A couple other things

22 that you also have to consider is that we may be
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1 different in this industry because we have two other

2 side groups that are involved in the same -- in

3 discussions because right now we have Energy Star

4 coverage of about half of the category that is up

5 there, and we also have Canadian standards which are

6 covered by about two-thirds of what's up on that wall.

7 All those require third-party verification testing, not

8 just modeling, but third-party verification testing.

9 So we're forced into a corner of testing a lot of stuff

10 besides what a basic two units would be.

11 And what happens then is that those of us who

12 are going to be exporting to Canada, those of us who

13 are willing to go to the extra mile to get the Energy

14 Star listings to help out our customers and to help out

15 the utilities are going to be penalized by somebody who

16 gets away with two models. And their validity won't be

17 there. And we already have the law on the books which

18 should have already been tested. So what's the big

19 fight if we can't have categories because if you're

20 already making it, you've already tested more than two

21 models. I don't understand this.

22 MR. BAUMAN: I guess the reason I'm going
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1 back -- this is Jeff Bauman from National -- a little

2 bit, Charlie, is if we're talking about how you

3 validate an AEDM, what do you need to validate, you

4 know, what do you need to validate the AEDM? That's

5 what I go back to a little bit. I think some of the

6 things we took about previously about volumes and

7 things like that might be applicable for our products

8 more so than others. I think some of those are more

9 important for us to consider than necessarily again

10 freezers at low temp, freezers that are -- and

11 depending how we work through that even versus two or

12 three per test as long as you have the biggest or the

13 smallest. I think we go to, you know, for our -- for

14 commercial refrigeration I think we got to go back and

15 look at those items again to see because those, I

16 think, have validity in this product area.

17 MR. STEPHENS: Phillip Stephens, HTP. Just a

18 point of clarification from the Department. We don't

19 have to do new testing. We can use historical test

20 data for these, right? So --

21 MR. HON: Charlie Hon. That's why I'm saying

22 this. We in the industry should have already had
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1 enough data that we wouldn't care two hoots about what

2 level they put on there. If we put in ten in some of

3 these categories it wouldn't be -- bother us because we

4 have it if we've done our homework already which should

5 have been done four years ago.

6 But there are so many different nuances in

7 our industry that are vastly different. I can have an

8 open- style, coffin-type ice cream freezer that runs

9 four times as efficiently as a vertical open-air

10 cooler, you know, freezer, delivering the same product,

11 consuming four times the energy. They need to know

12 that. And that's just the physics of the beast.

13 MR. STEPHENS: Phillip Stephens, HTP. I

14 think the important corollary for this is as the

15 efficiency changes -- the minimum efficiencies are

16 about to change, and the method of test may be changing

17 -- this will be massive for all of us in the coming

18 year and a half, two years. So at that point, yeah, it

19 becomes a major issue, especially for the smaller

20 manufacturers.

21 MR. SACHS: I'm listening avidly and sort of

22 hearing three very different perspectives from three
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1 manufacturers, and I guess the question I have is

2 what's the theoretical likelihood that if the CRE

3 manufacturers were locked in a room without food that

4 they'd come out with a consensus? Because if they

5 aren't likely to, having the rest of us in the room

6 isn't likely to help.

7 MR. BAUMAN: You want us to go home?

8 MR. SACHS: It's a serious question because

9 I'm hearing two pretty big differences in perspective

10 among you all.

11 MR. EISNER: And are the differences simply

12 explained by small and large or other factors?

13 MS. ARMSTRONG: I think it goes two ways,

14 right? I mean, so Charlie's point, he has a lot of test

15 data so to the extent he's okay with large

16 requirements. But to the point Phillip made, if we

17 change the test procedure completely, and all of your

18 tests become invalid, and all of a sudden you -- if I

19 tell you, you know, Charlie, we're back to the 72 tests

20 for resubstantiating your AEDM. And oh, by the way,

21 you have to do it in a couple years. Is that still

22 okay?
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1 MR. HON: Two tests for each of those

2 categories, yes, it is okay. The reason for it is is

3 that I cannot validate anything without those --

4 minimum of what the -- it was broken out for a reason.

5 The reason the DOE has separate categories is because

6 the units are that different.

7 MR. BAUMAN: This is Jeff Bauman. I'll agree

8 with you, Charlie, but I think the difference there is

9 more on the, on the energy efficiency level that they

10 should be expected to have. You're right, your glass

11 door unit and a solid door unit, you're not going to

12 expect the same efficient. You wouldn't expect the

13 same minimum efficiency level. I think that's really

14 where, you know, they had to break it out to as many as

15 they did.

16 Now, if you're trying to develop a model for

17 those two, and you have variations with that, you could

18 build a model that's still valid to calculate what

19 those two are. You'll get again, you know, it doesn't

20 mean you can use the -- you can run that AEDM on the

21 solid door and use the same number for the glass door.

22 It mean, you know, I think that's where the difference
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1 is and why my understanding is as why DOE had so many

2 categories is because it had to do with the efficiency

3 levels they had to require.

4 I just wanted to add that.

5 MR. HON: Charlie Hon. I agree with you to

6 some level but not completely because just because it's

7 a self-contained refrigerator, there are so many

8 different variations of that because I can give you six

9 or seven different categories that could easily be made

10 as a self- contained refrigerator. How do you model by

11 testing two of those and figure out a model for the

12 other five?

13 MR. BAUMAN: And that's I think a little bit

14 where I was going back and talking about some of the

15 other considerations with volumes and things like that.

16 And again, I'm trying to look at that we've got just --

17 we've got a ton of test data, too, Charlie, and then

18 we've got -- we've been waiting and asking DOE for the

19 last three, four years how do -- where do we send this

20 stuff? Where do we send this stuff? So I'm on board

21 with you on that.

22 And what I'm trying to look at it, though, is
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1 if we're looking at how do you validate an AEDM is --

2 that's the question I'm trying to -- or get the best

3 answer I can help with is how -- what's the right way

4 to validate an AEDM and break down the categories? And

5 that's where I think volume of the cabinet and things,

6 there's so much differences in there that those are

7 things we have to consider that others don't.

8 MR. EISNER: If the standards are increased

9 that you have to meet, what are the chances you'll

10 still have 38 different types of pieces of equipment,

11 because will all of them be able to meet a much higher

12 standard?

13 MS. ARMSTRONG: It would be a separate --

14 well, it would be evaluated as part of the rule, but in

15 theory, if we maintain products costs using the same

16 rationale previously, be 38 different standards.

17 MR. EISNER: What I'm getting at is would you

18 be able to make, for example, an open cabinet holding

19 ice cream if you're increasing efficiency standards or

20 you'll have to -- will you be basically killing off

21 that kind of equipment?

22 MS. ARMSTRONG: No.
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1 MR. EISNER: So you just make it a much lower

2 standard?

3 MS. ARMSTRONG: We'd have to maintain

4 utility.

5 MR. EISNER: And for the concern over the

6 cost of conducting all the tests, would more time help

7 meet that requirement if you didn't have to do it in a

8 two- year period, if you had four years, if you had six

9 years?

10 MS. ARMSTRONG: Regs from the statute. The

11 lead times are in the statute. I just made up a number

12 but --

13 MR. EISNER: What are the lead times? They

14 may not be aware.

15 MS. ARMSTRONG: So it depends. It depends on

16 A, if -- it's five years for standards for commercial

17 refrigeration equipment. But it depends on, you know,

18 for test procedure changes, if they don't drastically

19 impact the measures of consumption then it's much less.

20 So it just depends on the scenario.

21 MR. EISNER: What about you said that smaller

22 can get additional time? Is that not in this area?
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1 MS. BARHYDT: So there is a small business

2 provision, but it's limited to businesses that I

3 believe make -- actually think it's gross revenue, but

4 I can check it if anyone has any questions -- 8 million

5 or less. So it's --

6 MS. ARMSTRONG: Really small.

7 MS. BARHYDT: -- very, very, very small.

8 MR. EISNER: Before we go on, Ron is online,

9 ha a comment.

10 Ron?

11 MR. SHEBIK: Yeah. Hi. Thank you. Ron

12 Shebik, Hussmann.

13 Charlie, I think it's important for the rest

14 of the members of the group that they understand your

15 comments pretty much are just concerning self-contained

16 cases, not remote cases. I just wanted to clarify

17 that. Remote cases are quite a different animal.

18 They're essentially building blocks. An 8-foot case is

19 twice a 4-foot case. A 12-foot case is three times a

20 4-foot case. The need to have testing for each one of

21 those is not just necessary. Mathematical modeling is

22 perfectly -- should be perfectly acceptable. I just
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1 wanted to make sure the rest of the group realizes that

2 self-contained and remote should be handled differently

3 when it comes to that.

4 I understand the requirements for self5 contained have been there for a while now and that, you

6 know, and testing was required. I'm not disagreeing

7 with that. But just keep in mind, remotes are --

8 remotes should be handled differently.

9 MR. HON: This is Charlie Hon. I have no

10 problem with what Ron just said because they are not

11 involved in the Energy Star, the Canadian standards and

12 other things going on. And as such, it may be able to

13 pare down our number in half -- well, not quite half

14 but near half if you're using remotes versus self15 containeds as a separate category.

16 MS. ARMSTRONG: All right. So can I ask

17 generally, just do we have consensus over the fact that

18 self-contained should be separate than remotes? Does

19 anyone disagree there?

20 (No audible response.)

21 MS. ARMSTRONG: Do we have consensus that

22 refrigerators, freezers and ice cream freezers need to
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1 be separate?

2 MR. BAUMAN: I would disagree with that.

3 This is Jeff from National. I think, again, if you're

4 modeling your temperature, your temperatures you're

5 running and possibly your components you're running a

6 freezer and an ice cream freezer at are different but

7 the way you -- if your model is prepared properly, and

8 it can compensate for that, they could be -- they can

9 be put together.

10 MS. ARMSTRONG: So you don't think ice cream

11 freezers need to be broken out?

12 MR. BAUMAN: I don't think ice cream freezers

13 need to be separate from freezers.

14 MR. MYERS: This is Frank Myers, PVI

15 Industries. I just wanted to remind those that are

16 talking about this that this is to verify the AEDM, not

17 to create the AEDM. Obviously, you have to do a

18 tremendous amount of modeling in order to create your

19 AEDM. But the question it at the point -- at right now

20 is how many tests need to be run to validate the AEDM?

21 MS. ARMSTRONG: Yeah. Okay. So we're down

22 to refrigerators and freezers, self-contained and
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1 remote.

2 Now to go to the next one, do we think open

3 versus closed needs to be differentiated? We can

4 either add them as categories here, or we can say that

5 of the eight models above, one needs to be open, and

6 one needs to be closed. Two different ways to do it.

7 MR. SACHS: This is Harvey, and I'm certainly

8 no expert here, but first of all, we have another

9 category coming in of night closed. And I don't know

10 quite how the cycle plays with that. And secondly, it

11 seems to me that there's a pretty fundamental

12 difference in that modeling the air flow with an open

13 cabinet, particularly a semi-sloping or vertical, is a

14 whole different animal from modeling the airflow inside

15 a closed container, whether it's glass front or solid.

16 So I can understand that I would need a more

17 sophisticated model to parameterize that airflow in the

18 convective losses for an open front than I would need

19 to do either of the closed fronts.

20 MS. ARMSTRONG: So you're advocating

21 differentiating between open and closed?

22 MR. SACHS: I'm not so much advocating as
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1 asking whether it is necessary, for example, if a

2 manufacturer chose not to make open fronts, to have the

3 capacity, and I'm really trying to draw out from the

4 manufacturers whether my mental model of the airflow

5 around an open one is at all realistic.

6 MR. HON: Charlie Hon, True Manufacturing.

7 Airflow on a vertical or a semi-vertical is critical.

8 If you have an air conditioning duct or a heating duct

9 flowing directly into the unit, all bets are off. If

10 you have a coffin type which is basically near

11 horizontal, you don't really disturb the air nearly so

12 much no matter what you do to it.

13 MR. SACHS: Now I've always looked at an open

14 freezer as just being a large room air conditioner.

15 MR. HON: They become a dehumidifier

16 sometimes as well.

17 MS. ARMSTRONG: So --

18 MR. BAUMAN: This is Jeff Bauman from

19 National again. I agree that open and closed should

20 definitely be separate, and then I'm not sure about

21 vertical open versus semi-vertical versus horizontal

22 open, whether we need three separate there. Maybe we
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1 do on those.

2 MS. ARMSTRONG: So one way to do -- so

3 there's a couple ways, right? We can say of -- so

4 right now, if we do two models in each category we're

5 up to 2, 4, 6, 8, 10, 12, 14, 16 total. We can say of

6 those 16, they need to be comprised of at least, you

7 know, a vertical model, a semi-vertical model, a

8 horizontal model, so you're not adding tests, but

9 you're making sure that all those categories are

10 spanning the range of your offering. That's one option.

11 We can take the two models down to one and

12 add more categories, another option.

13 MR. EISNER: And Ron Shebik says, "I am for

14 minimizing the number of tests for substantiation so I

15 can okay keeping VOC and VCI together."

16 MS. ARMSTRONG: Vertical open-closed and

17 vertical --

18 MR. EISNER: VCT or VCI?

19 MALE SPEAKER: It's ice cream.

20 MS. ARMSTRONG: Ice cream.

21 MR. EISNER: Oh, ice cream.

22 MS. ARMSTRONG: Vertical ice cream together
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1 or transparent, something. Vertical open --

2 MR. EISNER: Ron, your Is look like Ts.

3 MS. ARMSTRONG: Ron, you want to just say

4 your acronym?

5 MR. SHEBIK: Yeah. Thanks for un-muting me.

6 I'm at a disadvantage here.

7 No. I'm just trying to say -- I used the

8 wrong terminology, I guess. But the verdict -- again,

9 if we're looking at just substantiation, that's all

10 we're looking at, substantiation, substantiating your

11 AEDM, I -- again, I'm focusing just on the remote side

12 of this -- I don't see the reason to increase the

13 number of tests which is going to increase the burden

14 on the manufacturer and reduce the amount of time you

15 have for innovation. Again, that's for substantiation.

16 The manufacturer is able, whether it be a Hussmann, a

17 Hillphoenix, True Manufacturing, whatever, is able to

18 test as many as they want to where they feel

19 comfortable with the accuracy of their AEDM. But I

20 think the requirement should be such that we don't need

21 to overdo it and overburden the manufacturer.

22 I mean, we can break it down into every
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1 single equipment classification but then, I mean,

2 you're really going to increase your number of tests by

3 a large amount.

4 MS. ARMSTRONG: So what we tried to do is

5 based on the discussion here, tried to consolidate at

6 least some of the equipment classes so that I'm down to

7 16 total tests, and then at the bottom the models must

8 be -- those 16 models must span, depending on your

9 product offering, transparent, solid, vertical, semi10 vertical, horizontal, service over the counter, as

11 applicable. Is 16 reasonable?

12 MR. HON: Charlie Hon, True Manufacturing.

13 Sixteen doesn't even cover all the categories that we

14 have a standard for.

15 MS. ARMSTRONG: And we're hearing from others

16 that maybe covering all the categories independently

17 may not be necessary. So --

18 MR. HON: Well, the question is much more

19 important than all this. We can discuss all this

20 because the question being is validity. And if we're

21 verifying this process, there is a question of how do

22 we verify this process if we don't do certain amount of
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1 testing? And with all these possibilities which all

2 give you different results within a test process, how

3 are you going to verify a model?

4 I go back to my statistics in college, and

5 this category should have 100 numbers in it, not 16.

6 But I can understand that you can manipulate around if

7 you're doing a good modeling job and you're calculating

8 a lot of different factors into your models, which may

9 be six or seven separate factors, you can get it down

10 to 16 or so. And I could live with that category up

11 there. But if you start paring it down from there,

12 we're going to be putting ourselves in a situation

13 where nobody's model will be worth a hoot and every --

14 as soon as we want to get back at somebody, we send a

15 unit out for independent testing, then send the test

16 results saying they're -- they don't know what they're

17 doing. And I can guarantee it will happen.

18 MR. SHEBIK: Charlie, isn't it the --

19 MR. HON: Because --

20 MR. SHEBIK: Charlie, isn't it the

21 responsibility of that manufacturer to make sure their

22 AEDM is substantial, I mean to make sure that their
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1 AEDM holds up? I mean if you put together an AEDM that

2 is baseless, that has no, that has no teeth in it -- to

3 it, it's only going to hurt the manufacturer that put

4 it out there in the first place.

5 MR. HON: It is a risk that a lot of

6 companies are willing to take.

7 MR. STARR: This is Louis with NEEA. The

8 other aspect of it, if you're going to reduce the

9 amount of testing, the other end that you may be

10 opening up is your air band. So if you have crappy

11 tests, you just open it up plus or minus 50 percent,

12 and every AEDM will pass. And so while you're reducing

13 the number of models you're testing, you're also

14 getting your accuracy down so you have a rating that's,

15 you know, ten plus or minus five.

16 And then, you know, for incentive programs,

17 for the accuracy of, you know, and then even the better

18 manufacturers may have it really dialed in, and they'll

19 start working inside of they know that, you know,

20 because the air band is so wide that they can actually

21 overstate their savings. And so to me, by reducing the

22 number of tests, you're just creating -- it solves the
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1 problem right here on this slide. But then the slides

2 five slides down it will have another problem.

3 MS. ARMSTRONG: Sure.

4 MR. STARR: So I think I would try to keep it

5 -- if there is legitimate things that can be removed

6 from -- that can be modeled of those 36 models if

7 there's really -- doesn't require 36 AEDMs, then that's

8 fine. But I think just choosing a compromise is

9 somewhere between zero and 36, and we end up with 18,

10 it's probably not a good way to go.

11 MS. DANE: Mary Dane, Traulsen. I'd like to

12 see half of that number.

13 MALE SPEAKER: What is the question?

14 MS. DANE: That while we're at 16 now, I

15 still say that's too many because, again, you're going

16 to, you're going to -- we're talking about

17 substantiating your AEDM. We're going to use

18 mathematical modeling. We don't need to test every

19 single, every single type that we make because that

20 defeats the purpose of having an AEDM. So I'm still at

21 it being very burdensome to small manufacturers, and I

22 would like to see no more than eight, if we're going to
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1 do that.

2 And one other thing, wasn't remote supposed

3 to be outside of the scope of this in the original

4 noper (ph)? Wasn't it or was it something I -- maybe

5 have two different Federal Registers mixed up that I

6 thought remotes was taken out of this one.

7 Okay. Thank you.

8 MS. BARHYDT: So given that this is dealing

9 with substantiation, so you have whatever test data you

10 may have to be helping develop your model. Maybe you

11 have all kinds of different information about the --

12 (Interruption by computerized voice)

13 MS. BARHYDT: About the thermal properties of

14 the glass versus the solid door? Maybe you have all

15 kinds of little pieces of component information you're

16 taking into account. Would one of each of those be

17 enough to be the check to substantiate your AEDM?

18 MR. BAUMAN: This is Jeff Bauman from

19 National again. I want to defend Charlie and say yeah,

20 we should have at least this many. But the reason I

21 would say that at this point is that if you can come up

22 with an AEDM that calculates an open and a closed,
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1 that's a pretty darn good -- I can't imagine an AEDM

2 that would do both. In reality, you're talking about

3 two separate AEDMs anyway. So I don't think, you know,

4 you're going to end up with two, one for open that

5 would have eight and one for closed that would have

6 eight. You'd end up with that anyway. So I don't

7 think we're really -- I don't think the number's as bad

8 as we see it here. And I don't know if Ron has more

9 because he builds more of those cases than we do in the

10 open.

11 MR. HON: This is Charlie Hon --

12 MR. SHEBIK: You can -- this again is Ron

13 Shebik, Hussmann. You can look at -- I mean we have an

14 understanding of what the refrigeration load is on a

15 per linear foot for each one of our cases. We know the

16 load of each of our components, electrical components

17 that goes into our case as well as the effect that that

18 has on the refrigeration load. Based on all that we,

19 you know, we -- and again, we got a lot of years of

20 research and a lot of data on these numbers. So we

21 know we can fall back on these numbers, and they're

22 pretty accurate. We're pretty comfortable with these
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1 numbers.

2 So again, I'm throwing it out there. Can go

3 back and, you know, require substantiated tests for,

4 you know -- or I'm sorry, an additional test for

5 substantiation for the AEDM. That was my basis for not

6 doing 36 different tests.

7 I mean, as far as whether it be a closed case

8 or an open case, you know, again, we're basing on years

9 of, years of data that we have built up on how our case

10 performs, whether, you know, the refrigeration load as

11 well as all the components that go into the case. I'm

12 pretty confident that our competitors are doing

13 likewise.

14 MR. HON: This is Charlie Hon. Do I believe

15 you can build a model, glass doors and solid doors, a

16 model that will cover them both? Yes, I do. It would

17 be tricky, but you'd have to build some database, but

18 you can do it because the environment in which they're

19 operating with the doors opened or closed is the same.

20 You just have to calculate the difference in

21 efficiencies of the doors, which one's more -- a better

22 insulator.
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1 Do I believe you can build a model that takes

2 in open cases and closed cases? No, I do not.

3 MR. EISNER: Is there a way to look at open

4 and closed cases for existing models and see what

5 results you get from the, from the tests you run now

6 and use that for some new standard in the future, or

7 are they not related enough to do that? So if you had

8 a new standard come out in the future, could you use

9 the data from the old equipment and extrapolate it to

10 form conclusions about what the, what the -- what you

11 would achieve with the new equipment?

12 MR. HON: Charlie Hon. Yes. Even if we were

13 to change the test standard, you could take the -- you

14 could do some extrapolations on some of these to come

15 up with some information from it. Yes.

16 MR. EISNER: Any other thoughts?

17 MR. BAUMAN: I don't know if that's a point

18 we ought to make. I was just -- to your point there,

19 Neil, I just asked Laura about whether is that

20 something DOE would accept is --

21 MS. BARHYDT: So if there was a standard

22 change, one of the things that was in the original
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1 proposal was that all of the test data to substantiate

2 the AEDM would actually have to meet the new standard.

3 You couldn't use test data that didn't meet the

4 standard to substantiate your new AEDM. But that's

5 another one of the aspects we haven't --

6 MR. EISNER: I'm not talking about -- you may

7 be misunderstanding. I'm not talking about comparing

8 one without a door under the old standard to one

9 without a door under the new standard but rather the

10 relationship between the one with a door and the one

11 without a door. You're now building two new ones, one

12 with a door and one without a door --

13 MS. ARMSTRONG: No, that relationship --

14 MR. EISNER: Can you use the one with the

15 door as comparison to the old one and figure out what

16 the one would be without the door?

17 MS. BARHYDT: Yes.

18 MR. EISNER: You might have fewer tests that

19 you'd have to do.

20 MS. ARMSTRONG: I don't know if that's the

21 case.

22 MR. EISNER: Well, that's Charlie's --
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1 MR. HON: Charlie Hon. Because in the

2 future, you're going to be -- all of us are going to be

3 doing fewer and fewer tests as we get better at

4 developing this and using this process. We all

5 understand that that's why we want this process. But

6 the baseline information required to build the valid

7 system can be overlooked if we just come up with, okay,

8 let's just do two models for all of the refrigerators

9 and two models for all the freezers and two models for

10 all the ice cream freezers and say that's good enough

11 because there are people who will not be able to

12 statistically validate their systems but are small

13 enough manufacturers that they just glide under the

14 edge for a long, long time. And when they do get

15 caught, they could put them out of business. And I

16 know that the DOE doesn't like that sound because then

17 we end up with big legal battles. Correct?

18 MS. ARMSTRONG: So to the slide. Do we have

19 suggestions for modifications, or is this something we

20 can live with? Is this something we can't live with?

21 What can I type?

22 SUE'S SECTION HERE
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1 MR. EISNER: Right now, there's 16.

2 MS. ARMSTRONG: I've typed a lot, a lot of

3 ideas.

4 MR. EISNER: It could be 38; it could be 16.

5 I heard some people say before they want it down to

6 eight. People that want it down to eight still want it

7 to come down to eight?

8 MR. STARR: Question. If this change wasn't

9 coming off in the new rulemaking, I think it would

10 change all this argument; correct? I mean, if there

11 wasn't a pending change here in a year or two, because

12 we're talking about the burden of testing --

13 MR. EISNER: Well, there was an argument made

14 or a statement made earlier that lots of tests would be

15 required and Laura's response was, "No, you could rely

16 on your old data." So I think, unless there's still a

17 concern about that, we're now just on new testing and

18 new requirements requiring new testing.

19 MS. ARMSTRONG: Yeah. But there's on caveat

20 that if the test procedure changes in a manner that

21 would substantially change their ratings, then they

22 would need to come up with test data to re-substantiate
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1 their AEDM based on these criteria.

2 MR. EISNER: Right.

3 MS. ARMSTRONG: So, for example, their

4 ratings would no longer be valid.

5 MR. EISNER: The ratings for old equipment?

6 MS. ARMSTRONG: It just --

7 MR. EISNER: Would a new standard require you

8 get rid of all your old equipment, or it would only

9 apply to newly manufactured equipment?

10 MS. ARMSTRONG: So, I'm going to change the

11 wording a little bit. A new test procedure, which

12 completely changed the measures of consumption, which

13 made units that you wanted to still manufacture those

14 existing ratings invalid, would need to be retested and

15 re-rated.

16 MR. EISNER: All right. And my question was

17 a little different. If you wrote a new standard that

18 they had to meet, not a new testing requirement, would

19 it only apply to newly manufactured equipment?

20 MS. ARMSTRONG: Yes. But the re-ratings are

21 going to be based on the test procedure.

22 MR. EISNER: So, you're going to do both at
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1 the same time?

2 MS. ARMSTRONG: Sometimes. Some -- we've

3 already done the CRE test procedure and the standard's

4 still in flux right now. So, sometimes we do one well

5 in advance.

6 MR. EISNER: So, people who might have to do

7 16 new tests, under what's on the board, might have to

8 do 32 new tests, possible scenario, because --

9 MS. ARMSTRONG: They wouldn't have to do them

10 twice. It would -- the minimum would still be 16,

11 period.

12 MR. EISNER: I'm confused, because if I'm

13 manufacturing equipment now that has to meet a new

14 testing requirement, that may come out before the new

15 standard comes out, why would I not have to do two sets

16 of tests?

17 MS. ARMSTRONG: Because just because a new

18 standard comes out does not trigger you to retest. If

19 that rating is still valid, because the test procedure

20 either didn't change of you've already revised the

21 rating to reflect the new test procedure, just because

22 a new standard level comes out, does not trigger a
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1 rerate or re-test or --

2 MR. EISNER: Existing equipment?

3 MS. ARMSTRONG: Of newly, period.

4 MR. EISNER: When does it -- why'd you write

5 a new standard if it doesn't apply? That's what I'm --

6 I'm having a little trouble understanding --

7 MS. ARMSTRONG: That talks about what you can

8 manufacture, not about what you can test. You can't

9 sell it.

10 MR. EISNER: That's what I'm talking about.

11 Newly manufactured equipment would have to meet the new

12 standard? Am I missing something?

13 MR. HON: This is Charlie Hon. Let me -- I

14 think I can -- okay. Basically, right now we have

15 ratings out there, they may increase the efficiency

16 requirements, without changing the test standard. If

17 that's the case, you already know the number anyway.

18 The same test standard would still apply, so you don't

19 have to do anything except look down your table and

20 said, "Okay, this one doesn't meet it, I'm going to

21 have to redesign."

22 MR. EISNER: Just sell a new piece of
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1 equipment?

2 MR. HON: Well, a new piece of equipment

3 you're going to have to do something, either in a

4 validation process, AEDM or a test, one or the other,

5 to prove that it meets the standard, as long as the

6 standard hasn't changed.

7 But if by chance they decide that they're not

8 happy with the way the test standard works, and it is

9 not representative of the market, they can -- they have

10 the right to change the method of test. And the method

11 of test, by being changed, may totally throw all your

12 numbers out of kilter, one to the other, relative to --

13 one unit to another. At that point then we talk into

14 new modeling.

15 Does that -- do you understand what I'm

16 saying there?

17 MR. STARR: I have a question. How much

18 testing -- so since 2007, there's had to be some amount

19 of testing that's occurred. In these 36 categories,

20 how many models have been set up in order to produce

21 that? What I was getting at is that it seems like it's

22 really this question of what is going to happen with
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1 the future test procedure. If that was out of the way

2 then all the -- because the future test procedure could

3 create a lot of test burden, and that's kind of why

4 this is getting pared down now, and so it's kind of

5 doing a lot of "what ifs." And so my thought is, let's

6 address the "what if," if that test standard changes

7 substantially, such as it creates a problem, and then

8 deal with that, rather than paring down what material's

9 already been collected.

10 I mean, maybe you can answer that, of those

11 36 categories, how many models have been tested in

12 those 36 categories? Would it be two per category or

13 where are we at?

14 MR. HON: Charlie Hon. In our systems, we

15 don't have a single category that we haven't tested

16 more than five, because we had -- we have a burden

17 which should have already been tacked and reporting is

18 the only thing that hasn't happened on models that are

19 requirement to meet a standard.

20 And at that time, our present rules are every

21 model is tested twice. Is this correct? Every base

22 model is twice tested, each of the same one. So --
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1 MR. STARR: Well, it almost sounds like we're

2 talking about a test burden that doesn't exist, is what

3 I'm getting at --

4 MR. HON: In the present --

5 MR. STARR: -- because it's already there.

6 MR. HON: In the present scenario, there

7 should be no major test burden, because it should have

8 already been done by 2008 in the self-contained and by

9 2010 in the remotes.

10 MR. STARR: So, that kind of brings up why do

11 we need to pare down the number of testing, if this

12 information already exists?

13 MR. HON: But the question comes up -- and it

14 is valid, if by chance they change the test criteria,

15 then we start from scratch.

16 MR. BAUMAN: This is Jeff Bauman from

17 National. I guess in trying to get to kind of the next

18 step here, in good negotiation nobody should be happy

19 with everything, right? If we started out with 38 and

20 somewhere between zero and 38 and we've talked about

21 16, I don't know that anybody's completely happy with

22 16, but is -- I mean, I personally think that's a
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1 reasonable number. I mean, it doesn't meet everything.

2 But I also try to look at also -- again, I have a bunch

3 of test data that I can -- you know, no problem, we can

4 produce the information, but also trying to be fair to

5 somebody -- you know, do we want to keep anybody out,

6 if they were going to come into this industry or a

7 manufacturer was going to come in, a good manufacturer

8 was going to come into this industry, what would he

9 have to do to validate his information?

10 Again, I'm trying to focus on what do we do

11 to validate an AEDM that we can be reliable for. And I

12 think the things that we've talked about here in

13 breaking up the categories, those are major differences

14 and I don't think we have a bad proposal up there, I

15 guess.

16 MR. HON: If you want to negotiate, I would

17 say let's look at one other thing. The differences

18 between an ice cream freezer and a regular freezer, the

19 construction is almost identical all the time. And if

20 you want to pare down, the ice cream freezer market is

21 very, very minimal compared to the other markets.

22 MS. BARHYDT: I think we've already collapsed
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1 ice cream freezer and freezer.

2 MR. HON: So, you can pare down a few things

3 but --

4 MS. ARMSTRONG: Can we live with that paring?

5 MR. EISNER: Harvey, I think you had a

6 comment and then we can take a vote.

7 MR. SACHS: This Harvey. And Laura scared

8 me, which happens occasionally, when she said that in

9 the event of a new standard models that did not meet

10 the new standard, that is pieces of equipment that did

11 not meet the new standard, could no longer be used to

12 validate the AEDM.

13 MS. BARHYDT: What I said was that was in

14 DOE's original proposal.

15 MR. SACHS: Okay, right. Thank you for the

16 clarification.

17 What concerns me is there must be a reason

18 for that, because it's implying that there's some

19 nonlinearity in those old models between the old

20 standard and the new standard. And by symmetry, that

21 would seem to imply that these AEDM's might not be good

22 for stuff that's a bunch better than the minimum
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1 standard and that starts to scare Marshall and Louis

2 and I'm not sure we want to go there.

3 MS. BARHYDT: I think we're going to maybe

4 hit on that issue a little later. Can we table it

5 until we get to --

6 MR. SACHS: If you promise it'll be tomorrow

7 instead of today.

8 MS. ARMSTRONG: I promise we will not get

9 tolerances to get to that issue. I'm 100 percent

10 certain about it.

11 MR. STARR: The point I was making that the

12 tolerances and the amount of testing are directly

13 related. I mean, it's like you pass by the gas station

14 and --

15 MS. ARMSTRONG: Yes. Tolerance is next.

16 MR. STARR: -- you run out of gas and say,

17 "Hey, we'll go back, we ran out of gas." And I'm like,

18 "No, because they are paired together."

19 MS. ARMSTRONG: So, these are just -- so,

20 this is our working position. Is this a good working

21 position to have before we move to tolerances?

22 MR. EISNER: How many people object to 16?
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1 MR. STARR: How many people who have skin in

2 this came, the CRE game?

3 MR. EISNER: Well, that's not the way the

4 voting is set up.

5 MS. ARMSTRONG: So, what would you change,

6 though? What would you change?

7 MR. STARR: I would say we should have the

8 same testing we have and keep focused on it, there's

9 going to be increased burden testing down the road. My

10 suggestion is that we should keep with the testing that

11 we have for the 36 models and that if we're going to

12 have increased model or a test burden down the road,

13 worry about that aspect of it.

14 I mean, you know, maybe it doesn't need to be

15 36, but to me, it looks like we just went half way

16 between zero and 36. And we're hearing now maybe two

17 models, that's not really -- I mean, two models may

18 have worked in stuff less complicated, but really, two

19 models probably isn't sufficient enough.

20 So, it seems like the manufacturers have this

21 information of the 36 ones and what the concern is, is

22 that all of a sudden here in three years they're going
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1 to be having to test a whole bunch more models. And

2 that's a reasonable concern. So my thought is, let's

3 address that future testing concern model. You know,

4 and I don't know if we can address that in the DOE

5 standards or not. But if there's an increased, huge

6 testing burden, then we can give them additional time,

7 do something else.

8 But part of the problem doing it this way is

9 that -- I think it has a question of really affecting

10 the validity of the efficiency rating you give to the

11 equipment and that's my main concern.

12 MS. ARMSTRONG: So, just to be clear, though,

13 the amended test procedure is on the books already.

14 Compliance isn't required yet, but we have an amended

15 test procedure which will have certain aspects of

16 lighting that are different, night curtains are

17 different, at different -- a revised age or I

18 procedure. And the reason that compliance is required

19 down the road is because DOE did make a determination

20 that it will impact the measures of consumption.

21 The reality is, it does take us a while to

22 get through the rulemaking process. To say that, you
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1 know, future testing or what should be used to

2 substantiate an AEDM should be kicked, because they

3 have valid -- they have testing now, not sure that's

4 the best way to do things. Only because it's going to

5 take us a while to get through that process again. And

6 we're going to be the same situation we are today.

7 MS. BARHYDT: The idea is to come up with the

8 framework that is going to work for a long time --

9 MS. ARMSTRONG: Going forward, period.

10 MS. BARHYDT: -- that shouldn't have to be

11 revisited every single time that we do a new test

12 procedure. We want to come up with a framework that

13 works, that manufacturers understand and can rely on,

14 without having to revisit this every single time we do

15 a test procedure.

16 MR. STEPHENS: Stephens, HTP. Two points I'd

17 like to make. The first one is, statistically

18 speaking, these are the minimums; right? When we're

19 talking about the confidence level and the accuracy of

20 the data, the manufacturer's taking on the risk

21 associated. If we want 80 percent confidence level, we

22 have to test so many units. If we want 95 percent
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1 confidence, we'll do that and we'll take care of that.

2 So, it's related, but it's not a direct relationship in

3 this case, because what the DOE's laying out is just

4 the minimums.

5 And the second point I'd like to make is when

6 we're comparing the smaller manufacturers to the larger

7 manufacturers, in my case, I know I have a direct

8 competitor whose lab staff is large -- just the lab

9 staff that works in the lab, is larger than my entire

10 engineering department. So, I sympathize with the

11 smaller manufacturers. It's a valid concern.

12 MR. HUNT: Of course I'm Marshall Hunt,

13 Pacific Gas and Electric. I'm really interested in the

14 Energy Star products. And so, Charles, could you

15 explain more how I'd feel comfortable with -- let's say

16 this goes, and this is a minimum for the AEDM, how

17 would the Energy Star testing be different?

18 MR. HON: Charlie Hon. Energy Star requires

19 third-party validated testing, irrelevant of any

20 statisticals. It is 100 percent tested unit. If that

21 model is tested, you cannot apply it to any other

22 model, unless it is basically the same model. You do
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1 not have any of this discussion at all in Energy Star,

2 because the same with Canada, it requires testing.

3 That makes it a lot clearer for you, I'm sure.

4 MR. HUNT: Thank you. Yes.

5 FEMALE SPEAKER: That's not true.

6 MR. STARR: I'm just hearing it's not true

7 over here. I would like some elaboration on it.

8 MR. HON: In what way?

9 MS. ARMSTRONG: So, a couple things for

10 Energy Star. One is Energy Star does require third11 party testing, or at least manufacture witness testing.

12 It's not on an every model basis, it's a single model

13 that has to go through that, not multiple models. And

14 it can be applied across the product family as they

15 define it more broadly.

16 What else was -- it's more or less the DOE

17 test procedure right now. It will be identical in the

18 future. So, it's not every model.

19 MR. HON: Mike, would you care to step in on

20 that? As a third-party certifier, how do you certify

21 different models.

22 MS. ARMSTRONG: And the scope is much, much,
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1 much narrower than the DOE regulatory program, for CRE.

2 Do you certify every single individual model

3 or can you group -- or can you test a single one

4 through a third-party and use that an extend the

5 ratings all through? I mean, I can read from the

6 directive. Now, how it's applied may be a different --

7 but I can read you the language from the directive that

8 says that specifically.

9 MR. KOJAK: This is Mike Kojak with UL. I'm

10 not sure how to answer that question. We have a

11 separate department that deals Energy Star testing. I

12 deal mostly with the lab and actually getting it done.

13 MS. ARMSTRONG: That's good, Mike.

14 MR. KOJAK: So, I would have to find out

15 about that from our CO department and get back to you.

16 MS. ARMSTRONG: Great.

17 MR. EISNER: Let me ask you --

18 MS. ARMSTRONG: I think regardless of it, I

19 mean --

20 MR. BAUMAN: This is Jeff Bauman from

21 National. Our experience has been more to Charlie's

22 too, I think. In discussions we had with EPA and when
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1 we went through this is the way they defined a basic

2 model, the only difference you can have from one model

3 to another is an esthetic difference, it has nothing --

4 and again, getting to your fabulous wording about

5 identical versus similarly identical or whatever the

6 wording was, that that's been interpreted that if it's

7 not exactly the same size, even doors and things like

8 that, it's got to be a completely separate test.

9 MR. EISNER: Let me ask the question --

10 MR. BAUMAN: So if you know more, I'll get

11 with you after.

12 MS. ARMSTRONG: I'm getting into a DOE versus

13 EPA thing here.

14 MR. EISNER: Let me ask the question we asked

15 earlier, but a little -- slightly different this time.

16 How many people think the number should be above 16?

17 (1 person) How many people think the number should be

18 below 16? (3 persons) So, is that three?

19 MR. STARR: I have a thought here. You know,

20 I don't necessarily -- the model 16, you know, I don't

21 work in refrigerators all day long, so my only thought

22 is, is that generally essentially to me this is an
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1 engineering decision about what makes sense. And so,

2 if there's some logical -- I mean, the other part about

3 it, this is the DOE standard for the next three cycles

4 or whatever or however many others. So, to me, I

5 guess, if these 16 models really make sense, in terms

6 of what it is, then that's fine.

7 But if it's just something that was made, a

8 decision this afternoon, but it's going to go through

9 three more cycles, I would kind of want a little bit

10 more -- similar to what an ASHRAE committee or

11 something where there's be some reasoning behind, you

12 know, "This is why, you know, we should test these

13 models, but we don't need to test the open refrigerator

14 cases. And the coffin style are fine, but you couldn't

15 (inaudible) between those two."

16 So, to me it's just really -- is there

17 engineering vetting behind this, or is this just a

18 consensus process in terms of I could have had 20

19 people in here and we'd come up with the same thing,

20 that knew nothing about refrigeration.

21 MR. EISNER: Regardless of consensus, DOE's

22 going to have to come up with a justification that
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1 would support it in any court challenge. So, I think

2 they're aware of that and believe they can justify it

3 or they wouldn't -- I assume wouldn't have put it

4 forward.

5 The problem right now is we don't have enough

6 votes for anything, 16 or lower. Apparently it has to

7 be some place above 16 to get consensus.

8 MR. STARR: Well, does DOE feel very

9 comfortable with all or feel the reasoning behind

10 these, you feel pretty solid in the engineering and why

11 they're there?

12 (No audible response.)

13 MR. STARR: Okay.

14 MR. EISNER: All right. Now we have three

15 negative votes. Are you saying we shouldn't be 16.

16 MS. HOOTMAN: Well, you shouldn't really

17 count me. I don't really have a dog in this race, but

18 I --

19 MR. SHEBIK: This is Ron Shebik with

20 Hussmann.

21 MR. EISNER: Hold on. We got --

22 MR. SHEBIK: You're saying there's three
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1 negative votes on the quantity of 16, that there should

2 be more? Or three negative votes on 16 because there

3 should be less?

4 MR. EISNER: I asked -- there were three

5 people where oppose 16 or lower.

6 MR. SHEBIK: I'm sorry, I --

7 MR. EISNER: We can take another vote.

8 There's an indication we should take another vote to

9 see how it is.

10 But before I do that, are any other people

11 who are going to vote no, do they have an idea for

12 something else or are they limited to 38 -- excuse me,

13 are they limited to being low 36? I've been putting

14 this in the wrong way.

15 Three people who want it to be below 16. Do

16 you have alternative that would be acceptable to the

17 other people in the room, because otherwise we don't

18 have any recommendation to put forward on this

19 particular issue.

20 MR. STARR: You know, based upon Department

21 of Energy being comfortable with 16, then I -- my

22 concern was is that it was a decision that was not
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1 really based upon solid reasoning, but they're

2 indicating that it is. And so, if that's the case I'm

3 comfortable with 16.

4 MR. EISNER: Let me take a vote. How many

5 people oppose the recommendation that is up on the

6 board right now? Nobody opposes?

7 So, we go with 16 tests based on DOE's being

8 able to justify the standard. Okay. We got agreement?

9 GROUP: Yeah.

10 MR. CYMBALSKY: You all get ice cream.

11 MR. EISNER: I think that would be

12 appropriate.

13 MR. CYMBALSKY: It's on you.

14 MS. ARMSTRONG: Do we need a break before

15 tolerances --

16 MR. CYMBALSKY: No. Let's go.

17 MR. EISNER: No, they just said --

18 MS. ARMSTRONG: -- or are you ready to go?

19 I completely second that vote. But

20 unfortunately --

21 MR. CYMBALSKY: You're going to want pickles

22 with the ice cream.
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1 MS. ARMSTRONG: Stop it. My maternity leave

2 is just getting longer and longer by the minute.

3 MR. EISNER: Okay, next?

4 MALE SPEAKER: Be nice, John.

5 MS. ARMSTRONG: True, that is true.

6 MALE SPEAKER: Be nicer.

7 MS. ARMSTRONG: Okay. I'm going to skip

8 right to the slide that --

9 MR. EISNER: 33?

10 MS. ARMSTRONG: 33. Tolerances. So, this

11 really gets to what is a valid rating. I take a unit,

12 I test it, you test it; you have your AEDM, it

13 simulates it.

14 MS. BARHYDT: 27 in our packets, because you

15 inserted --

16 MS. ARMSTRONG: Oh yeah, sorry. What is a

17 valid rating? DOE currently has an individual

18 tolerance as well as an average tolerance. We propose

19 the same contract but different numbers in the

20 proposal. We could maintain this idea of an individual

21 tolerance and an average tolerance. We could say --

22 MS. BARHYDT: It's 28. Sorry.
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1 MS. ARMSTRONG: -- and individual tolerance

2 is all that's needed. We can go to one-sided versus

3 two- sided. There's a lot of issues on the table.

4 So -- and then obviously, it's what should

5 the number be. It seemed like a lot of the comments

6 were for a one-sided tolerance only. In other words,

7 you can rate conservatively, no problem there. All the

8 way down to the standard. I see a lot of nods. Do we

9 generally agree there?

10 MR. EISNER: Does anybody oppose it?

11 MR. WHITWELL: Well, I just want to

12 understand that. This is Bob Whitwell from Carrier.

13 The AEDM result, the testing versus the AEDM result,

14 that doesn't necessarily tie to the rating, right? I

15 mean, you can always rate less than what the AEDM comes

16 out. So, I don't understand how the one-sided versus

17 two-sided relates to the rating.

18 MS. ARMSTRONG: No, you can't. The way we

19 wrote it.

20 So, the way it works is, the rating is what's

21 coming out of your AEDM. The valid rating is what's

22 intolerant. So, the way the proposal was written
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1 constrains you to plus or minus say three percent or

2 plus or minus five percent. So no, you couldn't rate

3 all the way down to the standard level if that three

4 percent was above -- was beyond that tolerance.

5 What we're saying is maybe that's not the

6 right way to go. Take away the -- just make it one7 sided, you can't over rate.

8 MS. BARHYDT: I think the distinction you're

9 making is that -- does the number coming out of the

10 simulation have to be plus or minus a certain

11 percentage, just to show that the model is predicting

12 the test result within a certain tolerance as opposed

13 to what you're allowed to rate for representations and

14 certification? Is that --

15 MR. WHITWELL: Right. My understanding of

16 these --

17 MS. ARMSTRONG: But for the proposal they're

18 one and the same thing.

19 MR. WHITWELL: My understanding was these

20 tolerances are to make sure that your AEDM is

21 predicting correctly; right? So, you're comparing the

22 test data with the AEDM. And it can be either above or
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1 below. The AEDM can either be above or below the

2 actual test data. Right? Correct?

3 MS. ARMSTRONG: That's correct.

4 MR. WHITWELL: And then --

5 MS. ARMSTRONG: I think we're saying why do

6 we care if it's below, if it's still within the

7 standard range?

8 MR. WHITWELL: Well, if it's -- I mean, if

9 it's only a one-sided tolerance, then that's going to

10 drive manufacturers to skew their AEDM so that it

11 always comes out one way. Right? Isn't it?

12 MS. ARMSTRONG: I don't think so. I don't

13 think so.

14 MR. WHITWELL: As opposed to -- well, I guess

15 I'm just confused about why it would be a one-sided.

16 MS. ARMSTRONG: So, can you explain that

17 because as I understand it, the AHI program uses a five

18 percent one-sided tolerance.

19 MS. HOOTMAN: Right. We aren't validating

20 (inaudible).

21 MS. ARMSTRONG: You're validating a rating,

22 which is coming out of simulations. It's the same
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1 thing you're doing here.

2 MR. THARP: There's a difference.

3 MS. ARMSTRONG: Why?

4 MR. THARP: Well, again, you have rating

5 versus simulated value -- simulated or tested value and

6 if you have -- say example, we have a ten ton unit,

7 110ER, your AEDM says 11.05, your other sample is going

8 to be heat pump at also 11, your AEDM says 12.05 but

9 you've rated it 11 and your test is actually 11, then

10 that's telling me that your AEDM isn't really accurate.

11 And I think that's what you're saying; correct?

12 MR. WHITWELL: Yeah, I mean, you could have -

13 - if you're testing one sample -- if your AEDM says

14 11.05, you test your one sample, it might be 11.05 or

15 .06 or it might be 11.04. Right? So, that's a plus or

16 minus tolerance there. And if it's a one-sided

17 tolerance, you're only allowing the one side, which I

18 don't understand how that makes sense.

19 MR. KLEISS: Jeff Kleiss, Lochinvar. From

20 the standpoint of what we're trying to do here, as long

21 as the published ratings that come out are either

22 accurate or conservative, should it matter? And I
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1 would suggest, no.

2 MR. WHITWELL: Right. But that's a different

3 -- to me, that's a different question than whether you

4 have a plus/minus tolerance on comparing the AEDM to

5 the test -- to one single test.

6 MR. STARR: The problem that I potentially

7 see with it is that if you're not accurate in those two

8 points, what makes you think you're accurate in other

9 places in the ranges? So, maybe in the two test points

10 you go conservative on those, but the midrange is maybe

11 fine or a little less. So, in other words, if it

12 doesn't accurately model the actual performance line

13 across a number of tonnages or whatever, then it seems

14 like that, you know, you might just move up.

15 You have basically a bad AEDM, but you kind

16 of model it very slockily and it passes, in order to

17 get it, but maybe another range that you're not

18 testing, it's not -- you know, you're getting a more

19 inefficient piece of equipment. And that's what my

20 concern would be.

21 I mean, just in engineering, in general, you

22 want your model and your actual performance to model
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1 closely. So, why all of a sudden -- I mean, outside of

2 the world of engineering I know it makes sense, but

3 inside the world of engineering, you want your model

4 and reality to match up as much as possible. And when

5 it doesn't, it brings into real question what the

6 validity of your thing is.

7 MR. STANONIK: Frank Stanonik, AHRI. First

8 of all, which tolerance are we talking about? Could

9 you be clear on that.

10 MS. ARMSTRONG: So, I think that's -- it

11 seems to be where the discussion is going is saying

12 there should be, I'm going to say, two different

13 methodologies. So one should be the tolerance for, I

14 test a unit of a model and I'm comparing it to my AEDM

15 results and it needs to be within plus or minus x

16 percent. So, that's one. Whatever the x is, is to be

17 determined.

18 And then there's another one that says, "How

19 can I rate my products?" And maybe that is whatever is

20 coming out of the AEDM, as long as it's valid, meets

21 its tolerance, all the way down to the standard level.

22 MR. FLY: Mark Fly with AAON. The thing --
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1 my thing I'm concerned about --

2 MS. ARMSTRONG: Did I get it right?

3 MR. FLY: -- is that you can't have that

4 tolerance less than the uncertainty of the testing

5 procedure, because if you're looking at your model

6 versus your test procedure, and your test is plus or

7 minus ten percent, then your tolerance has to be plus

8 or minus ten percent. Because you could be anywhere in

9 there on any given day.

10 MR. RIVEST: Mike Rivest here. Let me

11 explain a little bit where this one-sided thing comes

12 in. And that's actually straight out of the comments.

13 And it's also consistent with, I think the -- well,

14 potentially how the AHRI verification program is run.

15 So, right now a unit that is below five percent, fails

16 the verification test. Is that correct?

17 So, if the AEDM has a variance of plus or

18 minus ten percent on the mean, for example, you know,

19 the -- your actual computations, plus or minus ten

20 percent, that means 20 percent, now you can add, after

21 the AEDM, a re- centering which will give you minus --

22 you know, the plus minus is confusing, depending on if
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1 it's an efficiency rating or losses. But essentially

2 re-centers so that on one side you've got five percent

3 and on the other side you have 15.

4 And what I read in the comments is, we don't

5 want to be punished for being conservative. So, really

6 what matters is that we never rate lower than five

7 percent of the test.

8 So, it doesn't matter, really, what your

9 ability to predict is, so long as you know what that

10 uncertainty is and you account for it in your rating.

11 Now, that accounting for can be by being very

12 conservative in the AEDM itself, or you may try to have

13 all that conservativeness be an adder to what comes out

14 of your AEDM.

15 You know, as far as I'm concerned, the two

16 together is what's the AEDM. Right?

17 MS. ARMSTRONG: Right.

18 MR. RIVEST: So, and that's the difference.

19 So, really a one-sided requirement is much less

20 stringent than a two-sided requirement.

21 MR. STEPHENS: Phillip Stephens, HTP.

22 MR. EISNER: Before we move on, we have a
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1 comment from Bruce Hierlmeier. "DOE wrote regs for CRE

2 equipment, based on calculations and not product

3 testing. What tolerance did they use for their

4 calculations?"

5 Nobody from DOE?

6 MS. ARMSTRONG: That's beyond anything we

7 have here.

8 MR. HON: Could you read that again, please?

9 MR. EISNER: "DOE wrote regs for CRE

10 equipment based on calculations and not product

11 testing. What tolerance did they use for their

12 calculations?"

13 MR. HON: This is Charlie Hon. I disagree

14 with his statement. The numbers that DOE used were

15 from databases which were test databases, the

16 California database and Energy Star databases were all

17 included. Weren't they, Matt?

18 MS. ARMSTRONG: That's correct.

19 MR. HON: So, I disagree with his statement.

20 There were other units that were not -- that had not

21 been reported to California or a few other places, that

22 would have been missed in the database, but the base
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1 information came from statistics of tested units.

2 I wish to defend DOE on that, because they

3 did that.

4 MR. EISNER: Harvey?

5 MR. SACHS: I speak in favor of the one-sided

6 test at each stage, for reasons of public policy. The

7 one-sided test puts the responsibility for encouraging

8 the test labs to be good, encouraging the models to be

9 good and everything else that helps to control costs

10 while delivering a complying product, where it belongs,

11 on industry.

12 The two-sided test, on the other hand,

13 increases the testing burden, makes things harder all

14 around and I'm not sure I see a benefit except at the

15 margin increasing confidence that the models are good

16 models. Well, I'm not sure I care if the model is a

17 good model, as long as it never gives me the answer

18 that something qualifies that shouldn't be. It's not

19 my business. End of rant.

20 MR. STEPHENS: Phillip Stephens, HTP. In the

21 residential boiler program we are allowed to rate

22 through AHRI, less than the linear interpellation.
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1 Right? So, we do our tests, we can always rate lower

2 than what the test value is.

3 MS. ARMSTRONG: That's what the second --

4 MR. STEPHENS: Right?

5 MS. ARMSTRONG: You would be allowed to rate

6 between the standard level and to whatever the AEDM

7 valid rating would be.

8 MR. STEPHENS: And when we publish our

9 rating, for that is a ceiling, so the one-sided is 95

10 percent of our rating is the minimum. Right?

11 MR. EISNER: Does anybody disagree with the

12 proposal that we go with just the one-sided rating?

13 MR. WHITWELL: Yeah, so I'm confused. You've

14 confused me again. I'm sorry. You've confused me

15 again with what you've written up there, saying, "A

16 valid rating is equal to individual tolerance," because

17 in the original rule and in the NOPR, the individual

18 tolerance between the test data an the AEDM model

19 result had nothing -- was not tied to a rating. So, now

20 you're tying this to a rating, so I'm not quite sure

21 what you're trying to say here.

22 MS. MEYERS: Yeah, I had the same question.
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1 MS. BARHYDT: So, it could be my terminology,

2 right? But we could call this --

3 MR. WHITWELL: Because I thought that --

4 MS. BARHYDT: -- an AEDM result.

5 MR. WHITWELL: -- the tolerances that we're

6 talking about is when you run your let's say however

7 many tests and the NOPR was five, when you run your

8 five tests, first you do your -- you run your AEDM or

9 you run the test, whichever comes first.

10 And for each of those individual tests, when

11 you compare the result from the AEDM, it has to be

12 within five percent. Is that the -- plus or minus five

13 percent. Is that the tolerance that we're talking about

14 now?

15 MS. BARHYDT: That is --

16 MR. WHITWELL: Or is this something new?

17 MS. BARHYDT: That is correct. That's what

18 we're talking about now.

19 So, but we're talking about making it one20 sided, right? So, you're --

21 MR. WHITWELL: So, making it one-sided means

22 that your -- if you have your test data, your AEDM
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1 would always have to predict higher than the actual

2 test?

3 MS. BARHYDT: No.

4 MR. WHITWELL: It would always predict lower.

5 So, your test results must always be higher than the

6 AEDM.

7 MS. BARHYDT: No.

8 MR. RIVEST: No. Let me -- Mike Rivest.

9 One- sided means that you can be off by a considerable

10 amount, in other words, your test result can be more

11 than five percent off on the side of conservativeness.

12 But on the side of under rating, you can only have five

13 percent.

14 So, if the standard is --

15 MR. WHITWELL: Okay, so again, we're tying it

16 to a rating. So, it's a different concept than what

17 was in the NOPR?

18 MS. BARHYDT: Right. Typing validation and

19 rating.

20 MS. MEYERS: Yeah, so this is different than

21 --

22 MS. ARMSTRONG: It's not -- I mean, we use
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1 them as -- so, you may see them as two different

2 things, but we're using them as the same thing.

3 So, I guess the question becomes --

4 MR. RIVEST: The AEDM isn't to rate.

5 MS. ARMSTRONG: Right. The AEDM is your

6 mechanism to come up with a valid rating. Now, to the

7 extent beyond that you decide to further rate

8 conservatively, our regs currently allow that and the

9 proposal was to future allow that.

10 But the AEDM is coming up with a number, that

11 number is a valid rating. So, the question becomes,

12 what is valid? And what Mike's trying to say, from a

13 lot of the comments and from the AHRI program or

14 whatever, one proposal on the table would be a five

15 percent one-sided. You cannot over rate more than five

16 percent.

17 MR. RIVEST: Under. Under rate.

18 MS. MEYERS: Well, can you under rate?

19 MS. ARMSTRONG: Well, I say -- I call it over

20 rate, but you can go down to the standard. You can

21 conservatively rate by more than --

22 MS. MEYERS: Can you under rate more than
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1 five percent?

2 MS. ARMSTRONG: If that five -- if the

3 standard level is more than five percent, yes.

4 MS. MEYERS: The standard level is more than

5 five.

6 (Crosstalk.)

7 MS. MEYERS: So, let's just say,

8 hypothetically.

9 MS. ARMSTRONG: Pick numbers.

10 MR. RIVEST: Lets' say the --

11 MS. ARMSTRONG: Let's pick numbers.

12 MS. MEYERS: All right, let's say I developed

13 a line of Energy Star rooftop units, gas packs, which

14 is what EER --

15 MS. ARMSTRONG: I'm just going to make up --

16 MS. MEYERS: --12 EER.

17 MR. RIVEST: Pretend it's ten. Pretend it's

18 ten.

19 MS. MEYERS: Yeah, okay, I think --

20 MS. ARMSTRONG: Ten makes easier math.

21 MS. MEYERS: -- I think it's 12.

22 MR. RIVEST: Make it ten.
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1 MS. MEYERS: So, if I wanted to then just

2 reclassify those products under a different model

3 number and rate them at 11 EER, just for marketing

4 purposes, so that I didn't have to -- could I do that,

5 because I would be under rating more than five percent.

6 MR. RIVEST: Yes.

7 MS. ARMSTRONG: Because the consumer's going

8 to get that or better. That is the whole idea. What

9 you couldn't do is remarket them at 13.

10 MS. MEYERS: So, you're one-sided --

11 MS. ARMSTRONG: Is to the --

12 MS. MEYERS: -- is to the --

13 MR. RIVEST: To the benefit of the -- no, no,

14 I'm sorry.

15 MS. MEYERS: But okay, so --

16 MS. ARMSTRONG: So here I did a little scale.

17 Right? Say ten's the standard, 14 would be more

18 efficient, ten would be less efficient and your rating

19 came out -- your AEDM spit out a 12.

20 MS. MEYERS: Right.

21 MS. ARMSTRONG: What you couldn't do is then

22 call it a 14.
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1 MS. MEYERS: Okay. Yeah.

2 MS. ARMSTRONG: You could go anywhere between

3 12 and 10.

4 MR. RIVEST: What do you mean?

5 MS. ARMSTRONG: That would be okay, because

6 your --

7 MR. RIVEST: That's 20 percent.

8 MS. ARMSTRONG: -- you could still -- if it's

9 one-sided. Now, if you tested it and it came out at

10 11, you have an issue.

11 MR. RIVEST: Ashley, put ten in the middle.

12 Okay?

13 MS. ARMSTRONG: Yes, sir.

14 MR. RIVEST: Put ten in the middle. That's

15 the -- so pretend that's the standard. Okay? If

16 you're AD, you can test at 9.5 and pass. That's five

17 percent, right? But couldn't you put 9.5 instead of 9?

18 MS. ARMSTRONG: Yes, but that doesn't give a

19 good --

20 MR. RIVEST: Okay, so that -- so if the AEDM

21 predicted a 10 -- now, when I say AEDM it just means

22 your computation. It can be the computer plus an adder
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1 or it could just be a conservative computer. If we

2 test it at 9.5 you pass. If we test it at 11 you pass.

3 That's the one-sided. It only comes into play on the

4 negative.

5 MR. WHITWELL: Okay. I understand this, but

6 I -- so this is -- the 9.5 is the DOE test or is it's a

7 --

8 MR. RIVEST: It's the test you run.

9 MR. WHITWELL: Yes, it's our test. Right.

10 MR. RIVEST: Your test.

11 MS. ARMSTRONG: Or a DOE test. I mean, it

12 could be either/or. It could be a verification.

13 MR. RIVEST: Or any -- or --

14 MR. STANONIK: It's the test of a production

15 sample. A production sample.

16 MS. ARMSTRONG: A test, a valid rating is

17 within five percent.

18 MR. STEPHENS: But this is discussing

19 production, this is enforcement type testing, not

20 development testing. And that's --

21 MS. ARMSTRONG: It's both --

22 MR. STEPHENS: -- I think the word -- there's
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1 a difference.

2 MS. ARMSTRONG: -- the way this is. Well, it

3 could be both. Why would there be --

4 MR. RIVEST: It's the test you use to certify

5 your AEDM.

6 MS. MEYERS: It needs to be both. It needs -

7 - they need to be identical.

8 MS. HOOTMAN: Development testing? You can

9 have development testing that's all over the map.

10 MS. ARMSTRONG: Whatever test they do you

11 want to use -- whatever you want to call it --

12 MS. BARHYDT: For your substantiation.

13 MS. ARMSTRONG: -- to what your

14 substantiation, the 12 or whatever.

15 MS. HOOTMAN: Okay.

16 MS. ARMSTRONG: Whatever that is. Not -- and

17 it could also be DOE initiated tested, or industry

18 testing.

19 MR. RIVEST: A two-sided five percent would

20 be 9.5, 10 and 10.5.

21 MS. ARMSTRONG: Right.

22 MR. RIVEST: So, you see, in that case, you
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1 know, you're tighter, you're working under tighter,

2 very -- total variability in your model.

3 MS. ARMSTRONG: And you cut off something

4 that tests out at a 10 and rated at a 10.5.

5 MR. DOPPEL: Paul Doppel, Mitsubishi. So, if

6 you're developing your AEDM and you're going to do your

7 five tens, you're essentially doing those tests to see

8 what the results are. So, there's not really a plus or

9 minus five percent yet.

10 MALE SPEAKER: Correct.

11 MR. DOPPEL: And what you're trying to do is

12 see what your line is. But the results of those five

13 tests all have to be whatever you decide all have to be

14 obviously above the federal minimum and above -- well,

15 they have to be above the federal minimum.

16 MS. ARMSTRONG: At five percent.

17 MR. DOPPEL: No, no, no, no, no. You're not

18 going to let us rate anything -- wait a minute, you're

19 confusing the thing.

20 MS. ARMSTRONG: You can't certify --

21 MR. DOPPEL: There's no way we can put a

22 rating less than the federal minimum.
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1 MS. ARMSTRONG: That is correct. But if your

2 AEDM comes out five percent, right, and you decide

3 then, based on that, to switch out a compressor or

4 something, do something in your manufacturing process,

5 that's up to you to get it back up.

6 MR. DOPPEL: Right. But I wasn't saying that

7 we were -- what I was saying, that we would have to

8 rate above the federal minimum. I wasn't saying

9 anything about the test results.

10 MS. ARMSTRONG: Right. The standard level is

11 the lowest.

12 MS. BARHYDT: Right. It's your test result.

13 MS. HOOTMAN: This is Jill from Trane.

14 You're right, pure development test results are going

15 to be all over the map. They could very well be below

16 federal minimums. You're going to turn around and say,

17 "Probably I'm not going to use that unit. I'm going to

18 change some component about it to make that unit more -

19 - you know, to fall within it."

20 But you are going to actually have test

21 records within yourselves that would probably show all

22 over the map.
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1 MR. DOPPEL: Okay. But if you -- if your

2 AEDM showed that it was a 10.5 is what it should be

3 rated at, and you tested out at 9.8 and then that's a

4 failure.

5 MS. ARMSTRONG: Yes.

6 MR. DOPPEL: And it's below federal minimum

7 and you're in trouble.

8 MR. SACHS: Yes. Trouble. You're in

9 trouble.

10 MS. ARMSTRONG: Especially if you send us in

11 that information.

12 MR. DOPPEL: Okay. We wouldn't do that.

13 MS. ARMSTRONG: Just saying.

14 MR. THARP: Rusty Tharp with Goodman. If 10

15 is the conservation standard and I do -- I'm testing

16 two samples to validate my AEDM. For both samples, my

17 AEDM says 10.0 One sample tests at 10.0 the other

18 sample tests at 14.0 then I'm personally not okay with

19 that because that's telling me that my AEDM is not very

20 accurate. And that's my concern over the one-sided

21 tolerance and developing or creating your AEDM.

22 MS. HOOTMAN: Validating.
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1 MR. THARP: Validating that it functions

2 properly.

3 MR. SACHS: This is Harvey, and Rusty, let me

4 see if I can flip that around. I understand that

5 concern. You know, am I going to get billed for the

6 extra good compressors that Emerson sent me, or

7 whatever. I understand that.

8 But you might choose not to use that generic

9 of the AEDM but to refine your AEDM you may decide that

10 this was a product imperfection. We're only talking

11 about -- and Jill talked about these as development

12 tests. We're only talking about the ones you're

13 telling DOE are being used to validate, my term --

14 MR. THARP: Right.

15 MR. SACHS: -- I don't like substantiate, to

16 validate the AEDM.

17 MR. THARP: Correct.

18 MR. SACHS: And those then, as the outcome of

19 this product, we're saying DOE should look at one20 sided, conservatively. You certainly should look at it

21 internally, two-sided, for your own quality control

22 standards. But I don't have any visibility into your
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1 factor.

2 MR. KLEISS: Jeff Kleiss, Lochinvar. I'll

3 amplify that a little bit from the standpoint of the

4 small manufacturer that has a very low budget, that it

5 may be necessary for them to have a very

6 unsophisticated AEDM, not very well developed, and to

7 protect themselves, to then be very conservative in

8 what they consider.

9 A more developed engineering department, of

10 course we would want to squeeze every bit of efficiency

11 out of that and have as tight of an AEDM as possible.

12 But to protect the small manufacturers I think we need

13 to have one-sided.

14 MR. EISNER: Okay. Any disagreement with

15 that?

16 (No audible response.)

17 MR. EISNER: All right.

18 MS. BARHYDT: So, that's one-sided. What

19 percentage?

20 MALE SPEAKER: Thirty.

21 MS. HOOTMAN: Five percent's up there.

22 MR. THARP: This is Rusty Tharp again. Now
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1 this, I think, goes back to the uncertainty of the

2 tests. And based on a lot of work that the Unitary

3 Large and Unitary Small Equipment sections of AHRI have

4 been doing, as relative to the uncertainty of the

5 testing itself, I think that the test values probably

6 have certainties in the range of eight to ten percent,

7 probably somewhere high single digit to low double

8 digit range, as far as the uncertainty.

9 So, I think for the individual test samples,

10 that something in that range would be acceptable.

11 MR. RIVEST: That's why we're one-sided;

12 right? If your uncertainty is actually 20 percent, then

13 you re- center in your AEDM so that 15 is on one side

14 and five is on the other. Your AHRI verification

15 program is at five percent. So, there is a logic there

16 to that one-sided five percent. Effectively that's

17 what you're running is a one-sided five percent.

18 So, this eight percent variability may very

19 well be there, but it's captured in this re-centering

20 process.

21 MR. HON: Charlie Hon. Energy Star is

22 running five percent as well on equipment. You have a
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1 five percent variance allowed. And if you're running

2 the risk, you just -- you rate yourself slightly.

3 Again, there's no penalty for being better than what

4 the standard says. So, you could set this number at

5 one percent or zero percent, it's irrelevant, we just

6 have to know where to set it so that we know where to

7 put our uncertainty characteristics.

8 MR. STANONIK: Frank Stanonik, AHRI. I think

9 this is -- we get to a point where this isn't one size

10 fits all, and I kind of understood what Mike was

11 saying, but I just can't dismiss the tolerance -- the

12 inaccuracy of every -- each test procedure is unique.

13 I mean, you test air conditioners differently than you

14 test commercial refrigeration equipment, different than

15 you test water heaters. And they have their own

16 inaccuracies.

17 And, yeah, there's some -- you know, you kind

18 of have to just, in a sense, live with that or accept

19 it. But at the same time, that's to me a little

20 difficult to say we'll just deal with it and we're

21 going to apply the same tolerance to the test of any

22 particular piece of equipment and it's going to be the
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1 same number. I just don't -- to me, that has to be a

2 little more thought out.

3 And as Rusty was saying, you know, if there's

4 a larger inaccuracy, when you're testing certain types

5 of commercial HVAC equipment, or not larger, just a

6 different one, then, like, when I'm testing a boiler

7 for combustion efficiency or whatever, that needs to be

8 factored in.

9 But I think we need a little more work here

10 than just say, "Oh, it's going to be five percent

11 across the board." I don't think that works,

12 especially in the commercial products, and we haven't

13 even started talking about -- I mean, first of all, you

14 know, we've got to get rid of the idea these are off

15 the shelf stuff. I mean, yeah, you all have products

16 that you can sell readily, but everybody, in some form

17 or another, has stuff that, "Hey, if you want one, I'll

18 make you one." And some companies, that's their only

19 business. And now you're starting getting into that.

20 And again, I think I'm just really not at all

21 comfortable with the idea that there's a one size

22 tolerance fits all.
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1 MR. RIVEST: Frank, this is Mike Rivest.

2 This is really more a question. In the world of

3 transformers, they talk about losses as opposed to

4 efficiency. And apply a five percent to a ten EER

5 doesn't swing you that much. Apply five percent to an

6 EF of .9-something on a water heater sounds almost

7 ridiculous.

8 So, five percent of the rating, you know,

9 that's our understanding of what AHRI does. Am I -- do

10 they do that for water heaters as well? How does that

11 work?

12 MR. STANONIK: Yeah, but not all the programs

13 exactly -- not all of them have five --

14 MR. RIVEST: Well, I think the first effort

15 here is to understand what you guys do.

16 MR. STANONIK: Well, yeah, we do apply it to

17 the rating. So, it's an x percent to the rating. And

18 I think especially when you get into the commercial

19 side of stuff we have a little more variation.

20 MR. RIVEST: But it's always to the rating?

21 MR. STANONIK: Right.

22 MR. RIVEST: But you see how five to going
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1 from ten to 9.5 to 10.5 isn't huge. But when you're

2 talking about -- what's an electric water heater rated

3 at?

4 MR. SACHS: It's .9 and goes down to a .5,

5 essentially.

6 MR. RIVEST: Point nine, right.

7 MR. STANONIK: Excuse me, Mike, but that's --

8 I mean, you picked a good example, fortunately a.)

9 because it was talking about residential. But the

10 other point is, in fact when we had somebody in this do

11 an error analysis, and we started talking about .95

12 electric resistance water heaters, we found out that we

13 were getting pretty close to -- the error of the test

14 itself was about a plus or minus -- I don't remember

15 exactly, I think it was plus or minus 04 or something,

16 or something in that area. And so, this was some time

17 back and so we actually tried to look at some things to

18 perhaps make the test more accurate.

19 But that's kind of my point is that, at some

20 point -- well, again the test procedures do have their

21 own inaccuracies and we -- admittedly, I think as an

22 industry, completely we all haven't really -- whether
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1 it's time, money or the desire, we've never really took

2 a hard look at how accurate are any of these DOE tests.

3 MR. FLY: Mark Fly with AAON. I agree with

4 you, Frank, it's not really -- it's not a one size fits

5 all. And as the complexity of the test, the number of

6 parameters that go together to make a rating, the

7 higher it's going to be. And I know one of the things

8 that's under consideration by DOE, in a separate

9 rulemaking is - - or process anyway, I don't know that

10 it's a rulemaking yet. Is, IER, where we're doing four

11 tests for -- rather than one test, and even at AHRI

12 we've got a higher tolerance on IER ratings than we do

13 on ER ratings because we can't do four tests and get

14 the same kind of accuracy that we can get with one.

15 MR. THARP: Rusty Tharp with Goodman. And

16 that's ten percent AHRI has a ten percent tolerance on

17 IER.

18 MR. SACHS: Let's go back to why we're here,

19 this is Harvey, and continue with that hypothetical

20 example. It's like a ceramic pot that has an

21 efficiency standard of ten. That, by law, is the

22 minimum for something to be sold in commerce. The
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1 advantage of using the one-sided tolerance band is it

2 now gives an incentive to industry, at every level,

3 from the testing labs, to the testing methods, to the

4 rating methods, to drive for things which have narrower

5 inherent tolerances so that we can get more -- it

6 drives us toward quality manufacturing processes.

7 So that my own preference would be to say

8 that we should have compliance with the law, a zero

9 tolerance, and you guys have the responsibility of

10 designing and testing to meet that. And the better

11 manufacturer will figure out how to do that and how to

12 work with his testing lab to get those error bands

13 down, to get more consistent products. Twenty years

14 ago we started calling those Toyotas.

15 Now, I realize there are problems that are

16 different here. But I do think the responsibility

17 belongs with the manufacturer to meet the law.

18 MR. STEPHENS: Phillip Stephens, HTP.

19 There's a case with commercial water heaters, the

20 stand-by loss test is notoriously inaccurate.

21 MR. SACHS: Then let's fix it.

22 MR. STEPHENS: It's very difficult to fix.
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1 We routinely have swings of 20, 25 percent. And that's

2 from testing at one manufacturer's location, to sending

3 it to the third-party lab to test. And it's very

4 difficult to manage.

5 So, what every manufacturer does is write

6 very conservatively.

7 MR. SACHS: And that's -- this is Harvey

8 again. Phillip, I appreciate that. And the responses

9 are to rate conservatively or to work with DOE and

10 others on a substitute for that out of loss test that

11 will give us the information we need, with the lower

12 test burden and better results. I don't regard that

13 particular test method as having been handed down to

14 Moses.

15 MR. STEPHENS: But the interesting and the

16 very detailed point we really need the Department to

17 recognize is the fact that this is the uncertainty from

18 lab to lab. So, when you're doing your random audits,

19 labs don't use the same environmental conditions as

20 other labs do. Right? The boiler test method has

21 totally a wide range of variables that we use. And not

22 all manufacturers use the same settings and not all
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1 test labs use the same settings.

2 MS. ARMSTRONG: So, a couple things. One is,

3 can somebody -- does anyone know, off hand, what the

4 different tolerances are by product, for the AHRI

5 program?

6 MR. KLEISS: Can we speak to each of our own

7 --

8 MS. ARMSTRONG: Yeah, yeah. I mean, you can

9 all speak freely. And then secondly, why should they

10 be different for DOE?

11 MR. SACHS: Because of the law.

12 MS. ARMSTRONG: Well, if five percent is okay

13 there, and that's what they're calling a valid rating,

14 and that's done at a third-party lab, with supposedly

15 manufacturer variation, using a DOE test procedure, why

16 should it be different for DOE?

17 MR. STEPHENS: I think the question revolves

18 around the Department using the same test lab, because

19 a lot of manufacturers have used -- they know their lab

20 and they know the third-party lab. So, if a different

21 lab comes into play, there's a totally different

22 uncertainty that comes into play.
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1 MR. THARP: This is Rusty with Goodman. I'll

2 say that I think we're mixing tolerances here, because

3 only one thing -- I just realized we need to remember

4 that the tolerances we're discussing are the tolerances

5 for developing your AEDM and that's different than the

6 tolerances for --

7 MALE SPEAKER: Test lab certification.

8 MR. THARP: -- or for enforcement testing

9 down the road.

10 MS. BARHYDT: That is different from

11 enforcement testing.

12 MR. THARP: So, that's two different things.

13 And actually for thinking about -- for an AEDM, all the

14 testing I'm going to do to validate my AEDM is going to

15 be done in my lab and so I'm fine -- I think with that

16 I'm fine with the one-sided five percent.

17 MS. ARMSTRONG: And if I do a test that --

18 there's no standard compliance issue, but if I do a

19 test and it's more than five percent off, and I come

20 knocking on your door and say, "Hey Rusty, I have this

21 third- party, you know, test lab result --"

22 MALE SPEAKER: (Inaudible).
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1 MS. ARMSTRONG: Well, no, no, no. I mean, it

2 still gets to what is a valid rating.

3 MR. THARP: Right.

4 MS. ARMSTRONG: I mean, regardless --

5 MR. THARP: And it goes back to --

6 MS. ARMSTRONG: -- of whether you want AHRI

7 to tell us when there's been an invalid reading or if

8 you want us to determine when there's a valid reading,

9 want you guys to determine whether there's a valid

10 reading, it all gets to what is a valid reading.

11 MS. HOOTMAN: And this what -- and when

12 you're talking about rating, you're talking about

13 enforcement of that rating?

14 MS. ARMSTRONG: So, I would take enforcement

15 off the table. Right? That's not on the discussion

16 right now. This is just about --

17 MS. HOOTMAN: Okay, so --

18 MS. ARMSTRONG: -- what, coming out of your

19 AEDM is valid. Is it -- should there be a different

20 number, whether it's your testing in your lab, or

21 testing done in someone else's lab, whether it's a

22 third-party program, whether it's a DOE program, a spot
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1 check, whether it's an Energy Star spot check, should

2 there be a different number or is the five percent one3 sided okay for that. Enforcement off the table; we'll

4 deal with that later.

5 MS. HOOTMAN: Okay, so this is Jill at Trane.

6 To answer one of your questions about, you know, AHRI

7 and the five percent, I realize that this is in your

8 enforcement part, but with AHRI program, we have the

9 right to witness test every single one of those. We

10 have a right to be there, we have a right to see

11 whether they have actually performed the test

12 correctly, done measurement calibrations correctly,

13 done all of that correctly. And note it.

14 And we also have the right to have defective

15 claims. So, you know, when we see a test that has

16 happened and we know for sure that it was due to a

17 manufacturing defect, and we prove it to a

18 manufacturing defect, we have defective claims. So,

19 both of those processes are not in enforcement, nor do

20 I see them necessarily being supported in even the

21 validation.

22 MR. WHITWELL: But validation is within our
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1 labs, but we don't have --

2 MS. HOOTMAN: And you're right, it is within

3 our labs.

4 MR. WHITWELL: We don't have all those issues

5 and concerns.

6 MS. HOOTMAN: Validation is always within our

7 labs and not with AHRI.

8 MS. ARMSTRONG: So, is that five percent of

9 one- sided, across the board, regardless of product,

10 for your lab validation of your AEDM; okay?

11 MR. THARP: Rusty Tharp, Goodman says yes.

12 MR. EISNER: Eric Truskowski had a comment in

13 support of Frank's comments earlier for water heaters.

14 "Inaccuracies in the test procedures results in five to

15 seven percent error."

16 MR. STANONIK: So, actually -- again, so

17 you're specifically -- your question is, the test that

18 a manufacturer runs in their own facility that is part

19 of it, I'll call it the AEDM development, and let's say

20 the final step that confirms they've got the right

21 AEDM, that would be a five percent tolerance?

22 MS. ARMSTRONG: That's what I asked.
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1 MR. STANONIK: And it's not enforcement

2 testing?

3 MS. ARMSTRONG: Correct.

4 MR. KLEISS: Jeff for Lochinvar. For fired

5 water heaters and all boilers, the tolerance is five

6 percent and we would support that.

7 MR. DOPPEL: Paul Doppel with Mitsubishi.

8 So, just to make sure we're talking one-sided five

9 percent? That's fine.

10 MR. EISNER: Anybody disagree?

11 MS. BARHYDT: Well, I think we've heard from

12 HVAC and water heaters, what about the refrigeration

13 equipment? I haven't heard from any of you.

14 MR. HON: Charlie Hon. Basically five

15 percent is not really doable. We have proven that in

16 our labs, because we have taken a single unit, no

17 changes in the unit whatsoever, changing the lab

18 conditions within the test and found greater than a

19 five percent variation.

20 But, does a five percent, one-sided bother me

21 at all? No. Because if we validate our process to

22 plus or minus eight percent, which is a 16 percent
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1 total swing, I know that I cannot be off that five

2 percent at the top end. So, I might have to move mine

3 up three percent to cover it, but that's all I have to

4 do. My rating may have to be adjusted three percent as

5 a cushion to allow for that.

6 And as long as that's acceptable to the DOE,

7 you can say zero tolerance and we can just have to move

8 our numbers around. It doesn't bother me a bit. Just

9 tell us what we have to do.

10 MR. BAUMAN: Yeah, it's Jeff Bauman from

11 National. As Mike said, too, and as Charlie's saying,

12 we can offset the -- you know, our plus and minus

13 tolerance. And, you know, again we're just talking

14 about validation of the AEDM, so I mean, what we're all

15 going to be watching as manufacturers is are the

16 numbers you're going to be providing to DOE going to be

17 able to be validated by DOE.

18 So, in some ways this really doesn't matter,

19 because unless you want to take that chance in not

20 meeting what the tolerance is going to ultimately be on

21 validation, you know, later testing after you've

22 submitted it.
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1 So, I'm fine with the one-sided five percent.

2 MS. DANE: Mary from Trauslen.

3 MR. SHEBIK: Ron Shebik from Hussmann.

4 MS. DANE: At this level --

5 MR. SHEBIK: I agree with Charlie.

6 MS. DANE: Go ahead, Ron.

7 MR. SHEBIK: Oh, I'm sorry. Yeah, I agree as

8 well. Two-sided with five percent, might be -- I might

9 look at it a little bit differently, but for one-sided,

10 I see no problem.

11 MS. DANE: And Traulsen agrees at this step.

12 MR. EISNER: No one else disagrees? Okay,

13 five percent.

14 MR. SACHS: I want zero. One-sided. I will

15 not prohibit consensus on that.

16 MS. ARMSTRONG: Where are we?

17 MR. EISNER: At ratings validation?

18 MR. THARP: Well, that's the individual test,

19 though; right?

20 MS. ARMSTRONG: Correct. You need an average

21 or an individual cover. I mean, your testing is

22 (inaudible).
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1 MR. THARP: In your test, though, there's no

2 restriction on average; correct?

3 MS. ARMSTRONG: Are you asking for one?

4 MR. THARP: No.

5 MS. ARMSTRONG: Does the committee --

6 MR. THARP: You're saying -- well --

7 MS. ARMSTRONG: -- want a restriction on

8 average, in addition to individual?

9 MR. SACHS: Putting a restriction on average

10 would just tell manufacturers they've got to be careful

11 in selecting and do more and more until the average

12 drops to the point below five percent that you

13 specified.

14 MS. ARMSTRONG: Correct.

15 MR. SACHS: It's just --

16 MS. ARMSTRONG: So, it's seemingly --

17 MR. HON: And you're assuming that we have

18 control of the vendors.

19 MS. ARMSTRONG: -- no average.

20 MR. HON: Which is impossible. Work harder

21 at it.

22 MS. ARMSTRONG: So, I'm going to ask you
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1 guys, now that we've come to, here's the valid AEDM,

2 here's what we test and how many we test, and here's

3 how my test data has to compare to the -- what's spit

4 out of the AEDM, we kind of move into the realm of,

5 "Okay, what did DOE test." Is that something we want

6 to start at 5:35 p.m.?

7 MULTIPLE SPEAKERS: No.

8 MR. EISNER: Hold on. Is there another small

9 issue we could discuss or is that the last -- that's

10 the last one, isn't it?

11 MS. BARHYDT: Well, there's a lot of aspects

12 of it.

13 MS. ARMSTRONG: There's a lot of different

14 aspects of it, so that's why I say just pick it up

15 first thing tomorrow morning.

16 MR. EISNER: No, but I'm saying is there

17 anything after that? I think that's the last issue.

18 MS. ARMSTRONG: They're all together.

19 MR. EISNER: They're all together.

20 MS. ARMSTRONG: It all becomes then what does

21 DOE -- what does DOE determine is valid and then what

22 happens if DOE determines something is invalid.
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1 MR. EISNER: All right.

2 MR. STANONIK: Excuse me, this is Frank of

3 AHRI, explain that a minute. When you say "DOE tests,"

4 are we talking about DOE testing to -- however it

5 happened, the question is raised, manufacturer's X AEDM

6 seems a little squirrely. So, are we talking about DOE

7 doing tests to validate the AEDM or are we just talking

8 about DOE doing a test to check a rating of a

9 particular model?

10 MS. ARMSTRONG: The latter.

11 MR. STANONIK: Oh, okay.

12 MS. ARMSTRONG: Which could invalidate a

13 result coming from an AEDM.

14 MR. STANONIK: Yeah.

15 MS. ARMSTRONG: But DOE wouldn't validate an

16 AEDM, the way we have this set up, that's totally up to

17 the manufacturer. What we would do would

18 invalidate your rating.

19 How we do that is for 8:00 a.m. tomorrow.

20 (Whereupon, at 5:35 p.m., the Appliance

21 Standards and Rulemaking Federal Advisory

22 Committee Meeting was concluded.)
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193:2,4 199:15

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100 57:5 67:10

219:2 255:5

273:9 277:20

1000 1:7

107 108:3

10-gallon 187:1

10-ton 54:14

58:15,18 66:17

11 48:21 289:8,9

301:3 302:10

303:2

11.04 289:15

11.05 289:7,14

110ER 289:7

12 110:2,5 112:17

174:5 206:13

252:5 300:16,21

301:19 302:3

304:14

12.05 289:8

12:35 130:7

12-foot 247:19

13 169:7,8 301:9

135 149:6

14 1:10 114:18

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112:17 113:4

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237:5 252:5,6

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264:1,4 266:7,10

270:21,22

273:22

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281:5 282:6,7,15

283:1,2,5,15,21

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215:1 217:4

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20 119:19 281:18

292:20 302:7

310:12 317:1

2000 94:3 95:9,15

2007 112:6 236:5

268:18

2008 236:5 270:8

2010 156:12 270:9

2013 1:10

20585 1:9

206 213:6

20-gallon 205:20

20s 107:9

21 139:13

210/240 103:6

143:15,19

240 15:11

46:5,7,17

25 19:12 39:22

94:11 168:18

170:19 171:18

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3:44 228:15

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4 16:17 110:7

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101:19

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20:16

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alternate 8:21

27:22 95:15
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10:9,20 11:15

12:20 13:15

14:6,9 18:6 19:3

20:6 23:5 32:21

34:5 36:20 38:20

44:1,4,7 48:6

52:10 53:11,15

68:13 73:21

75:6,18,22 77:16

80:2 84:22

85:9,11 86:15,18

87:13,17 93:7

94:4,10,14 95:17

96:9 102:7

106:16 108:5

114:20

116:4,8,17,19

120:6,9,11

126:12,15,20

127:16,19,22

128:3 130:1,15

132:12 133:7,21

134:17

142:8,10,15,19

143:5,7,9 149:2

158:7 177:7

208:17 209:1,16

211:1,4 212:4,7

214:7 225:20

226:8,14 235:14

237:9 247:1,7

258:8,13 261:21

262:17 271:22

272:13 273:3

276:7,10

285:14,22 287:8

297:1,4,15,17

298:3,7,18

304:12 306:12

309:18 319:10

323:11 327:11

base 24:19 70:22

71:10,12,18,21

82:20 108:14

109:9 110:12

111:3,15,20,21

112:5 133:15

175:4 197:1

269:21 294:22

based 26:6 33:7

35:6 38:15 39:8

65:10,11 84:22

85:1,2 93:2

108:5 116:10
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197:20,21 208:4

214:15,19 219:3

221:4 224:19

226:2 235:2

237:17 254:5

259:18 265:1,21

283:20 284:1,7

294:2,10 306:3

310:2

baseless 256:2

baseline 54:22

172:18 263:6

basic 11:3,5 44:21

45:11 52:7,8,11

55:21

56:4,7,10,15

57:14,16 59:17

61:4,8,13,18,19

62:5,13,17,18

63:8,10,19

64:12,17 65:5,15

66:3,9,16,18,19,

20 67:1,6,10,15

68:4,9,14 71:8

72:4,7 73:14

75:8 76:2,8

77:14,21

78:1,2,4,14

88:12,15

101:15,17 102:5

108:20

119:12,13 125:5

128:7,11

136:4,18,19

159:3,17,18

160:16 165:7

170:19 175:21

232:15 234:6,7

238:19 239:10

280:1

basically 28:9

30:13 35:22

36:4,11 44:14

47:10 49:16

63:16 73:10

101:3 102:14

140:10 156:5

163:3 164:4,5

166:1 185:2,9

200:8 216:8

231:1 236:1

245:20 251:10

267:14 277:22

290:15 323:14

basing 260:8

basis 29:16 83:6

126:18

134:10,11

153:14 170:9

207:1 260:5

278:12

bat 180:19

battles 263:17

Bauman 2:11 43:4

44:3,6 67:3

123:15,18 124:2

170:16,17

171:1,13 227:9

231:15 239:22

240:1 242:7

243:7 244:13

249:2,12 251:18

258:18 261:17

270:16 279:20

280:10 324:10

beast 241:12

become 38:9 52:8

127:3 132:9

242:18 251:15

becomes 25:2

65:17 70:1,21

109:8 241:19

299:3,11 327:20

bedroom 126:14

Beever 2:12

176:22

begin 185:22

behalf 91:10,13

behind 39:5 79:1,7

131:15,20

133:16 167:20

168:14

281:11,17 282:9

belief 61:17

believe 9:17 19:8

26:11 29:16

34:5,20 58:19

90:22 94:11

101:20,21

111:12 149:18

168:13 185:19

203:7 234:1

237:2 247:3

260:14 261:1

282:2

belongs 169:16,18

295:10 316:17

benchmark 23:5

benchmarks 22:16

23:3 25:3

benefit 295:14

301:13

besides 239:10

best 17:15 39:14

81:12 98:19

174:10 205:8

206:10 245:2

276:4

bets 251:9

better 24:13 41:3

50:19 51:12 52:1

90:15 118:9

127:1 165:1

166:9 169:20

174:6 180:13

181:18 182:1

219:20 256:17

260:21 263:3

272:22 301:8

311:3 316:10

317:12

Beware 171:11

beyond 55:2 99:20

135:5 152:18

208:21 287:4

294:6 299:7

bigger 186:9

biggest 18:22

240:12

Bijou 4:2

bill 3:20 206:13

billed 308:5

bills 64:17

binding 11:7

bit 8:12 13:2 14:15

84:15 157:2

159:3 240:2,5

244:13 265:11

281:9 292:11

309:3,10 324:8

325:9

black 144:18

blocks 247:18

blow 146:6

BMG 68:1

board 38:19 49:16

77:3 121:3

244:20 266:7

284:6 312:11
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Bob 10:12 24:6

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286:12

body 130:8

Boesenberg 2:13

boil 194:13

boiler

31:9,12,13,19

32:1,2,3,5 59:12

62:18,21 68:22

92:18 93:3 95:7

109:6 176:10

181:3 209:15

210:12,13

211:11,16,17

218:14,17 220:5

295:21 312:6

317:20

boilers 30:20

32:16,18 36:3

37:18,21 38:4

60:10 76:11

94:19 95:3,14

120:5 138:12

144:10

180:16,20

181:8,9 183:7

197:20 203:3

204:22 205:1

212:8 214:11

215:5,7,8,12

218:15

219:19,21

222:14

224:5,8,10 323:5

bolster 127:6

bones 65:12

books 239:17

275:13

boost 206:7

booster 206:8

boosters 206:5,17

border 186:11

bother 224:13

241:3 323:20

324:8

bottom 9:7 10:5

194:12 203:21

254:7

bought 43:17

bound 54:10

boundaries 54:10

191:10,14

boundary 187:10

188:14 192:10

200:11,13

Bowley 2:15

box 64:14,19 69:5

Bradford 5:19

Bramblett 2:16

brand 133:21

134:13,14

breadth 81:16

128:13 131:4

196:21

break 62:1,8 109:9

115:18 129:3,6

227:19 228:8,9

232:19 243:14

245:4 253:22

284:14

breaking 271:13

breakout 163:11

Brian 2:17

Brice 2:15

brief 17:12

briefing 14:5

briefly 14:3

165:21

brine 162:21

bring 37:15 56:17

111:18

bringing 18:4

168:20 229:9

brings 182:16

270:10 291:5

broad 20:1 30:8

76:17

broader 12:1

91:13 224:15

broadly 37:9 58:5

278:15

broad-reaching

58:13

broad-spectrum

107:10

broke 143:11

broken 156:12

243:4 249:11

Brooks 31:8 95:3

218:1 220:17

Bruce 3:7,8

97:11,12

125:3,9,11 294:1

BTS 94:3 95:9,15

BTU 31:14 42:13

94:20,22 182:5

188:17 214:12

215:2,15 216:14

BTUs 103:3

186:21 188:14

215:13

bucket 34:12

budget 125:14

309:4

build 22:15

61:10,17 65:4

111:12,13,14

117:6 160:2

218:15 243:18

260:15,17 261:1

263:6

building 1:8 10:16

23:8 41:9 109:6

247:18 262:11

buildings 31:17

builds 26:17,18

259:9

build-to-order

98:7

built 33:14,20

134:14 164:16

230:7 260:9

bullet 8:22 9:6

157:12 180:5

203:13,21

bullets 179:13

180:6

bullet's 205:7

bulls 39:19

bunch 63:22 271:2

272:22 275:1

bunched 190:17

burden 57:4,6,10

80:12 101:22

187:9 194:19

198:3 216:3

253:13 264:12

269:3,16 270:2,7

274:9,12 275:6

295:13 317:12

burdensome 237:6

257:21

Bureau 22:20
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burners 184:19

business 21:1

90:6,9 132:14

133:3 168:5

223:7 247:1

263:15 295:19

312:19

businesses 247:2

button 130:4

buy 43:8 218:15

Buynacek 2:17

by-case 134:10

C

cabinet 154:12

232:1,2 245:5,18

250:13

calculate 232:1

243:18 260:20

calculates 258:22

calculating 34:17

47:6 92:8 231:18

255:7

calculation 95:11

133:13

calculations

163:21 230:6

232:2,16

294:2,4,10,12

calibrate 170:10

calibrated 23:10

calibrations

321:12

California 3:7

5:15 212:16

294:16,21

calmer 40:3

Canada 239:12

278:2

Canadian 239:5

248:11

capabilities 92:21

capability 93:19

113:3

capable 32:6 145:4

capacities 23:12

95:8

capacity 31:14

136:8 156:16

158:15 168:18

251:3

capital 1:16

218:16

captured 310:19

care 39:2 60:20

99:4 172:10

177:17 189:12

203:17 241:1

277:1 278:19

288:6 295:16

careful 326:10

Carl 4:22

Carlo 118:16

Carrier 2:21 4:18

6:3 10:12 24:7

138:19 142:5

143:6,8 286:12

carry 104:1

cart 211:20

case 35:13 36:1,2

40:6 55:12 57:12

88:8 89:13 90:13

91:13 92:4 119:1

131:16 134:9

165:12 189:15

191:17 193:1

198:7 200:5

219:12 222:12

233:14 234:6,7,8

247:18,19,20

259:17

260:7,8,9,11

262:21 267:17

277:3,7 284:2

304:22 316:19

case-by-case

134:11

cases 88:10 93:4

105:12 106:18

107:17 108:8,9

116:13 234:10

247:16,17

259:9,15 261:2,4

281:14

catalog 63:21

catch 97:20

99:2,16 126:5,6

categories 62:20

102:16

107:10,12

108:3,4 113:14

129:20 137:7

166:8,10,11

179:8 182:19,22

187:22 188:9

190:8 192:1

195:14,21,22

196:3 198:1,15

202:21 210:8

219:11 230:1,3

231:1 239:19

241:3 243:2,5

244:2,9 245:4

250:4 252:9,12

254:13,16

268:19

269:11,12

271:13

categorization

193:15

categorized

190:12 191:7

categorizing

181:18

category 14:17

17:22 30:8

59:12,13 103:16

107:16 124:19

137:19 148:9

166:21 171:22

183:8 185:15

188:13,19,20,21,

22 189:5 194:16

205:14,16

212:10 219:10

231:5 239:4

248:15 250:9

252:4 255:5,10

269:12,15

category-specific

59:13

caught 35:18

79:21 80:7 83:9

263:15

cause 225:7

caveat 11:22 28:22

42:1 177:15,22

178:3 264:19

caveats 86:2

CEC 174:11

ceiling 296:9

center 310:13

centering 292:21

central 115:12

ceramic 315:20

certain 30:15 31:3

93:2 95:7 99:10

136:6 137:19
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certainly 12:10

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89:3,12 90:13

107:16 119:1

181:2 216:16

250:7 308:20

certainties 310:6

CERTIFICATE

330:1 331:1

certification

9:2,10,12 10:22

27:7 52:19

64:4,5 66:6

78:18 82:12 83:3

84:13 98:6 104:7

105:5 134:6

143:21 151:12

162:2

183:18,20,22

211:19 287:14

319:7

certified 11:2

65:9,11,15 66:18

certifier 278:20

certify 278:20

279:2 304:4

305:20 330:4

331:2

cetera 10:19 159:7

CFR 41:13,14 47:4

68:9

challenge 84:14

282:1

challenging 84:11

chance 12:7 19:9

232:18 268:7

270:14 324:19

chances 245:9

change 36:8 37:19

38:8 51:20 55:11

59:14 67:20

69:13 72:18

75:12,14

110:1,2,4,7,8

136:20

151:10,11 155:6

157:1 179:9

187:2 203:2,13

214:13 224:4

225:6 241:16

242:17

261:13,22

264:8,10,11,21

265:10 266:20

268:10 270:14

274:5,6 306:18

changed 265:12

268:6,11

changes 35:5

136:21 177:2

207:13 241:15

246:18 264:20

269:6 323:17

changing 172:9

217:7 241:16

267:16 323:17

characteristic

176:21

characteristics

68:19 133:17

136:7 217:7

311:7

characterizations

202:1,20

characterize

204:10

characterized

201:20

Charles 3:9

277:14

Charlie 18:15 19:8

86:20,21 88:2,5

107:4 110:11

114:14 116:11

134:12 231:16

233:15,17

236:1,17 238:21

240:2,21 242:19

243:8 244:5,17

247:13 248:9

251:6 254:12

255:18,20

258:19 259:11

260:14 261:12

263:1 267:13

269:14 277:18

294:13 310:21

323:14 325:5

Charlie's 117:15

242:14 262:22

279:21 324:11

chart 138:11

177:12 227:13

charts 226:10

cheaters 18:18

cheating 87:4

check 20:10 24:1

85:8,9,10,20

99:6 113:17

124:12 126:22

141:12 233:9

247:4 258:17

321:1 328:8

checking 85:15

121:9 141:15

checks 19:5 85:7

152:16 233:8

chillers 15:5,7

41:10

choice 98:18 136:4

137:18 200:1

choose 22:17

79:4,6,10 82:11

308:8

choosing 257:8

chose 251:2

chosen 118:3

circulated 8:9

circulating 187:7

196:19

circumstance

225:7

circumstances

89:14

civil 168:13

claim 54:1 172:21

claims 93:21

321:15,18

clarification 60:2

67:4 77:16

115:20 155:10

158:17 240:18

272:16

clarifications 43:6

45:16

clarified 40:15

53:8 69:11

clarify 14:16 15:2

125:4 138:20

145:20 158:2

160:6 163:18

201:8 247:16

class 53:7,8,10,12

54:5 59:18 60:13

68:16 91:14

115:6,9 139:7,18

152:19 153:17
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200:13

classes 49:5 57:12

59:8 76:4,9

102:14,18

134:22 135:10

139:10,13,19

140:2 143:4

155:22 165:22

166:4 180:14

195:2,10,11

215:21 219:8

229:21 232:9

237:18 254:6

classification

191:9,15 254:1

classifications

198:2

classified 187:3

191:5

clause 22:2

clear 12:18 29:1

99:11 111:14

115:5,7 275:12

291:9

clearer 278:3

clearly 33:6

217:17

Cleaver 31:7 95:3

217:22 220:16

Cleaver-Brooks

4:10 5:17

Cleveland 43:2

Climate 4:4

close 23:13 28:8

48:17 49:14 51:2

53:4 61:22 98:1

115:16 314:13

closed 107:15

229:17

235:10,21 238:2

250:3,6,9,15,19,

21 251:19

258:22 259:5

260:7,19 261:2,4

closely 98:4 291:1

closest 181:13

clothes 63:15

CO 279:15

coffin 251:10

281:14

coffin-type 241:8

COHEN 42:21

coil 56:8,9 159:5

160:13,14

collapse

219:11,14,19

collapsed 271:22

collapsing 219:8

collect 134:4

collected 269:9

college 255:4

Collin 5:22

combination 40:12

56:1 79:6

154:8,17 160:21

173:11

211:15,22

213:16

combinations

120:2

combine 183:6

combined 37:6

40:13 191:21

192:3 209:22

210:2,9,19 212:9

213:5

combining 184:12

combustion

215:18,19,20

216:15,20 312:7

comes 18:17 36:12

69:14 71:9 74:14

118:17 175:7

186:22 228:22

248:3

266:15,18,22

270:13 286:15

288:11 292:11

293:13 297:9

303:3 306:2

318:21,22

Comfort 2:11

4:7,13 141:12

comfortable 7:6

19:6 45:4

47:16,19 48:8

81:5 92:14

153:18

169:11,12

253:19 259:22

277:15 282:9

283:21 284:3

312:21

coming 9:1 27:20

55:8 69:5 71:20

98:3 149:21

172:8 173:4

175:2 225:17

241:17 250:9

264:9 286:21

287:9 288:22

291:20 299:10

320:18 328:13

comment 21:17

25:8,9,14 26:7

40:11,22 44:10

50:5 58:21 67:19

87:19 88:2 95:1

97:12 99:1

118:21 124:7,8

157:9 158:18

163:20 177:7

213:7 228:18

247:9 272:6

294:1 322:12

commented 88:3

163:19

comments 11:20

15:18 16:18 18:1

30:10 31:6 34:13

49:3,8,18 56:14

65:5 66:8 76:22

77:8 80:3,14

81:3 82:5 88:17

115:17 136:15

157:19 214:9

229:11 247:15

286:5 292:12

293:4 299:13

322:13

comments/

suggestions

99:22

Comments/

thoughts/

objections 62:14

commerce 9:12

31:16 315:22

commercial 3:11

12:19 14:16 15:9

30:7,19,20,22

31:8,12

32:15,16,18

37:18

41:3,6,8,9,18

47:7 59:10,12

68:22 76:11 88:8

113:10 115:2

116:6,12

130:17,21

133:11 135:8

139:8 140:3
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155:20 156:1

157:3 176:9

184:2,3,17

185:1,16 204:22

205:2,4,7,17

207:17,18

210:2,20

211:19,22

212:17 213:2

214:11 219:21

222:14

229:15,22

240:14 246:16

311:14 312:5,12

313:18 316:19

Commission 2:18

3:7 5:15

committee 1:4

281:10 326:5

328:22

common 55:9

56:14 62:2 63:10

70:2 73:5 74:4,7

176:17 190:16

202:13 217:1

commonalities

231:20

commonality

175:22 176:2

190:17

communicate

217:17

community 91:13

companies 122:1

174:15 218:14

256:6 312:18

company 1:16

3:12 4:9,21 5:4

20:1 46:21 90:8

91:4 117:4 126:1

172:13 173:18

226:22

compare 24:19

50:16 164:14

182:12 230:22

297:11 327:3

compared 23:21

164:3 216:21

271:21

comparing

24:7,14,15

164:20 262:7

277:6 287:21

290:4 291:14

comparison

262:15

comparisons

231:16

compensate 249:8

competing 90:11

174:17

competition 89:11

233:9

competitive 87:2

competitor 88:8

277:8

competitors 84:7

86:22 87:3

88:6,10 260:12

complaint 193:8

complete 331:7

completely 65:1

108:2 164:17

242:17 244:6

265:12 270:21

280:8 284:19

314:22

complex 26:17

complexity 315:5

compliance 83:17

84:18 85:7,11,15

91:1 149:19

174:2 220:1

275:14,18 316:8

319:18

compliant 83:9

86:7 210:11,12

complicated 25:2

206:10 274:18

comply 204:6

complying 295:10

component 25:20

91:15 160:4,8,9

164:16 176:3

258:15 306:18

components 55:10

112:22

157:10,14,15,18,

19 158:1,2,18

159:20 160:1

163:19,22

164:1,5 204:3

213:5 234:8,9

249:5 259:16

260:11

compressor 55:13

57:15 159:21

160:13 169:7,8,9

306:3

compressor/

condenser 55:22

56:2

compressors 159:6

308:6

comprise 157:15

comprised 170:11

252:6

compromise 257:8

computation

302:22

computations

292:19

computer 149:12

155:18 156:6,12

162:13,17 165:4

179:5 194:11,15

302:22 303:1

computerized

258:12

computer-room

162:15

concentrate 7:19

concept 37:6 162:7

208:9 225:9

298:16

concepts 194:2

Conceptually 22:8

concern 13:9 20:5

80:11,13 85:14

91:9 168:17

172:11 246:5

264:17 274:21

275:2,3,11

277:11 283:22

290:20 307:20

308:5

concerned 13:3

24:7 66:11

121:22 168:22

170:10 172:2

175:10 292:1

293:15

concerning 247:15

concerns 10:11

171:21 172:6

178:1 272:17

322:5

concluded 328:22

conclusion 200:4

conclusions
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condensation 38:6

condense 38:4

condensed 46:4

229:22

condenser

70:2,3,21 120:1

condenser/

compressor

120:2

condensing 37:22

38:3,9 55:12

160:13 224:3,8

229:16 232:3

condition 10:18

110:1,3

conditioner 29:18

42:14 62:18

115:12 156:7

251:14

conditioners 42:12

145:8,14

149:9,12 155:18

156:12 165:5

179:5 311:13

conditioning 5:18

12:4 13:12 14:16

30:7,22 31:16

41:4 90:8,10

91:16 104:11

138:10 155:18

156:2 165:4

169:6 196:22

229:22 251:8

conditions 32:8

317:19 323:18

conduct 209:13

216:19,20

conducted

125:14,16

137:22 192:13

208:15

conducting 246:6

conducts 208:22

confidence 112:16

161:7,8,11,21

276:19,21 277:1

295:15

confident 44:18

260:12

confidential

132:14,17,18

133:3

confining 38:7

confirm 123:19

149:4 152:18

confirms 322:20

conflict 225:10

conformance

23:13

confused 152:9

266:12 288:15

296:13,14

confusing 7:18

292:22 305:19

confusion 7:9

connect 71:9

connected 71:6

connection 45:1

connects 176:18

conscious 233:3

consensus 26:22

100:2 121:4,17

123:14 124:22

128:17 135:3

242:4 248:17,21

281:18,21 282:7

325:15

conservation

307:15

conservative

110:14 289:22

290:10 293:5,12

303:1 309:7

conservatively

286:7 299:8,21

308:20 317:6,9

conservativeness

293:13 298:11

consider 13:17

30:18 54:8 106:2

109:19 152:12

171:19 178:21

179:3 238:22

240:9 245:7

309:8

considerable

298:9

consideration

22:11 90:20

140:8 170:8

315:8

considerations

244:15

considered 13:10

23:14 27:8 41:6

55:5 122:18,22

133:21 134:2

170:6 234:10

consistent 27:8

132:2 193:11

292:13 316:13

consistently 91:18

consists 160:13

consolidate 235:13

254:5

consolidating

235:8

constant 121:9

constitutes 52:7

constrains 287:1

construct 164:11

constructing

216:21

construction 66:13

188:16 271:19

Consultants 3:5

4:11

Consulting 2:3 5:2

consumer

42:4,6,15

consumer's 301:7

consuming 241:11

consumption

68:20,21 133:13

246:19 265:12

275:20

contact 132:22

contained 229:16

230:18 235:10

244:10 248:5

containeds 248:15

container 250:15

context 9:20 52:12

150:6 211:15

Continental 4:12

continual 83:6

continually 29:19

continue 59:11

315:19

continuing 18:10

contract 285:19

contracted 125:17

control 116:14
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controversy 64:13

convective 250:18

convenience 180:5

conversation 49:2

57:19,20 58:5

88:19 102:20

180:13 232:22

conversations 58:4

177:16

cool 218:20

CoolAir 2:12 3:15

cooled 14:22 105:2

137:9 140:13,16

142:18 143:12

144:5,6 149:9

156:20 165:6,14

cooler 241:10

cooling 3:2,13

156:16

copy 8:13 208:11

core 57:22

corner 239:9

corners 92:2

corollary 241:14

Corporation

2:12,21 3:15,22

4:18 5:7,19

correct 10:8 20:7

56:2 68:10

84:2,6 139:2

145:15,16

151:19 152:6,12

155:5,12 168:3

180:9,22 198:5

201:14

218:21,22 235:1

263:17 264:10

269:21 288:2,3

289:11 292:16

294:18 297:17

305:10 306:1

308:17 323:3

325:20 326:2,14

331:7

correctly 21:18

114:17 287:21

321:12,13

correlate 159:8

160:9

correlating 220:5

correlation 211:10

corresponding

135:9

cost 65:3 246:6

costs 81:20 245:15

295:9

count 199:3 200:6

231:6 282:17

counted 238:11

counter 254:10

counterparts

129:14

countertop 107:13

couple 7:3 28:4

29:19 42:2 43:5

45:15 107:1

188:16 205:10

238:21 242:21

252:3 278:9

318:2

course 21:1 103:2

203:6 277:12

309:10

court 122:19 141:9

282:1 330:1,2,15

331:3,5

cover 25:4 47:14

112:13 132:6

143:17 144:5

146:9

166:2,3,4,5

176:9,13 185:11

190:20

201:12,17

213:12 215:4

254:13 260:16

324:3 325:21

coverage 206:11

239:4

covered 11:22

15:7 25:5

42:4,16 45:16

46:13 60:5 68:15

139:14 149:15

150:1 175:20,21

185:17 206:8

210:8 212:9

237:16 239:6

covering 12:4

23:11 254:16

covers 12:2 107:22

165:22 172:21

201:15 210:13

220:12

230:13,18

crappy 256:10

crawl 107:6

CRE 59:10 60:10

76:10 107:3

134:4 233:4,13

242:2 266:3

274:2 279:1

294:1,9

cream

229:2,4,8,19

230:14 232:12

241:8 245:19

248:22

249:6,10,12

252:19,20,21,22

263:10

271:18,20 272:1

284:10,22

create 25:15,18

26:4 40:13

153:15 168:2

215:19,20 216:4

218:2 224:18

249:17,18 269:3

creates 269:7

creating 231:17

256:22 307:21

criteria 50:14

88:20 90:1

172:10 177:18

178:5 265:1

270:14

critical 133:12

176:2,20 193:19

251:7

CRM 2:8

cross 197:22

214:12

crossed 192:9

crosses 182:21

187:10,17

188:13 191:9,14

200:11,12

crossing 186:11

Crosstalk 229:6

300:6

Crowder 2:18

crude 222:13

culture 22:20
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current 10:17 27:8

47:4 61:8 68:3

177:9 186:7

currently 35:7

151:17 201:9

218:1 285:17

299:8

curtains 275:16

curves 211:9

cushion 324:5

custom 26:16

216:2

customer 26:19

133:9

customers 233:6,8

239:14

cut 92:2 305:3

cycle 250:10

cycles 281:3,9

CYMBALSKY

87:11 227:7

284:10,13,16,21

CYR 169:7,8

D

D.C 1:9

Daikin 3:14,18

5:20 157:9

daily 170:9

Dan 2:16

Dane 2:19 21:5

81:10 115:19

116:7,10,18,20

122:12,15,17,21,

22 123:3

126:5,6,13,19

127:2,15,21

128:2,4 147:3,7

152:2 236:15,19

257:11,14

325:2,4,6,11

dangerous 19:21

darn 259:1

data 19:11

24:14,15 44:16

45:10 49:14

82:20 86:7

93:2,6,13 96:4

108:5 109:17

112:7 126:17,22

132:9,12

133:16,19

134:16 138:17

150:22 151:2

159:4,5 167:6

197:2 200:15

205:2 218:2

219:3 220:1

236:7 237:2

240:20 241:1

242:15 244:17

258:9 259:20

260:9 261:9

262:1,3

264:16,22 271:3

276:20 287:22

288:2 296:18

297:22 327:3

database 64:8 66:6

133:15 159:15

260:17

294:16,22

databases 159:12

294:15,16

date 20:15 87:16

93:11,15 226:16

237:16 331:10

David 4:7,19

day 65:4 69:14

164:19 202:6

209:22 280:21

292:9

de 72:22 73:1

75:12

deal 13:4

120:21,22

163:12 196:21

213:5 236:9

269:8 279:12

311:20 321:4

dealing 186:18

196:17 200:8

218:18 258:8

deals 11:1 113:6

279:11

dealt 206:18,19

debate 42:16

decade 59:7

decades 29:19

December 206:12

decide 13:5 67:1

81:18 116:21

128:13 129:7

162:5 164:6

168:8 173:9

196:4 234:15

268:7 299:7

305:13 306:2

308:9

decided 115:21

decimal 73:2

decision 281:1,8

283:22

Decision-Making

7:12

decorative 109:7

dedicated 212:20

default 188:14,21

defeats 257:20

defect 321:17,18

defective 92:14

321:14,18

defend 258:19

295:2

deficient 73:11

92:6

define 31:8 57:6

78:13 88:15

128:7 160:12

194:3 278:15

defined 57:4,13

64:12 160:17

163:4 227:2

280:1

defines 42:6 56:4

63:6

defining 137:20

158:12 199:7

definitely 51:8

129:20 150:6

164:10 177:4

182:12 251:20

definition 12:19

31:18,20

41:3,11,16

47:3,4,11,20

53:4

54:5,8,18,19

59:21 60:9

61:8,9

62:3,12,17

68:1,4,9 71:21

73:1,20 75:8

89:16 109:13

115:11,12

159:18 160:20

182:5 186:7,20
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definitions 59:13

61:3 66:8 181:17

182:13 184:22

defrost 232:8

defy 91:18

Degitz 2:20

degrees 32:5

dehumidifier

251:15

del 2:21

delay 26:19

delays 112:11

delete 203:13

deleted 171:4

Delfield 5:4

delivering 241:10

295:10

delivery 26:19

demanding 224:21

denominator 73:6

department 1:1,6

2:10 24:3

28:5,13,18 29:14

51:16 52:19

58:20 60:11

69:10 93:8 98:13

99:13 132:13

206:21 240:18

277:10

279:11,15

283:20 309:9

317:16 318:18

Department's

16:22 39:11

41:11 60:3 76:20

depend 56:19

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depending 33:12

64:20 81:15

108:15 130:19

140:4 174:6

191:4 207:13

240:11 254:8

292:22

depends 119:15

162:5 166:13

192:6

246:15,17,20

derived 164:2

describe 44:11

64:1 143:14

159:3 176:1

193:14 238:6

described 51:13

125:18 143:10

describing 171:9

238:12

description 74:5,7

descriptor 47:9

216:10

design 22:17 39:15

168:1 176:2

181:11 182:19

185:8 187:6,10

189:19 197:21

215:11,14,22

216:8,11 217:5

218:3 219:6

223:19

designed

32:2,4,6,7

176:11

designing 45:2

316:10

designs 23:20 65:2

desire 315:1

detail 48:7

detailed 118:15

317:16

details 49:7 176:17

determinate

177:16

determination

11:17 34:15

35:17 37:7

275:19

determinations

75:10

determine

50:13,15 90:14

190:11 209:11

320:8,9 327:21

determined 92:2

291:17

determines 84:19

327:22

determining 34:17

95:13 165:16

182:20 221:3

develop 25:2 27:21

36:14 88:13

109:10 111:3

164:4 196:19

211:9 214:19

215:4,7 216:16

225:7 237:7

243:16 258:10

developed 29:19

54:9 88:14 108:9

109:10 125:7

163:22 196:20

221:15 300:12

309:6,9

developing 263:4

305:6 307:21

319:5

development 4:10

5:17 29:15 54:12

174:16 303:20

304:8,9 306:14

308:11 322:19

device 160:14

devices 160:15

dialed 256:18

Diane 3:13

dictate 12:15

dictated 116:15

difference 19:18

43:19,20 72:17

75:12 100:18

138:17 165:9

169:2 185:19

199:21 243:8,22

250:12 260:20

280:2,3 289:2

293:18 304:1

differences 111:4

169:20 242:9,11

245:6 271:13,17

different 15:4,6,20

17:11 23:2,11,12

24:20,21,22 33:7

35:9 36:18 37:8

41:1,19,20 42:12

43:22

49:3,5,6,21

54:7,20 55:17

59:16 60:1 61:15

64:20

65:1,2,21,22

66:10 68:9

70:5,7,8,10,11

71:14 72:17,21

73:2,4,6 74:9,15

75:11 76:3 77:19

80:14 82:8 86:18

90:1 92:21 94:1

96:14 100:1
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108:13 115:22

116:12,16

126:1,8 127:17

134:20,21

138:12,13 139:9

140:2,6

150:16,17,20

158:5,13,20

159:1,12,21

161:3 163:6,7,8

165:8 166:1

171:16 174:1

176:11 180:14

182:19,21

184:12 187:6

188:19

192:10,18

193:10

194:2,10,14,20

195:10,11

196:18 200:8

204:3 207:8

215:1,6,9,11,21

216:9 226:1

230:6

232:3,4,7,8,10,1

5 234:10

238:1,3,13 239:1

241:6,7,22 243:6

244:8,9

245:10,16

247:17 249:6

250:6,14 255:2,8

258:5,11 260:6

265:17

275:16,17

277:17 278:21

279:6 280:15

285:19 290:2,3

291:12

298:16,20 299:1

301:2 311:14

312:6 316:16

318:4,10,16,20,2

1 319:5,10,12

320:19 321:2

327:13

differentiate 97:3

183:13,18

differentiated

156:14,16 250:3

differentiating

181:7 250:21

differentiation

83:2

differently 55:16

58:2 59:10,22

63:6 248:2,8

311:13 325:9

difficult 83:16

84:4,13 92:1

95:4 109:9 228:3

311:20 316:22

317:4

digit 310:7,8

Digital 330:15

digits 64:9

72:14,15,16

dinged 174:9

direct 30:14

117:14 277:2,7

direction 330:6

directions 109:8

directive 279:6,7

directly 117:15

251:9 273:12

directory 174:11

disadvantage

253:6

disadvantages

16:20

disaggregated

102:18

disagree

122:9,15,16

123:4,5,9

124:3,7,13

128:21 136:13

154:7 177:18

186:17 217:3

218:7,13 236:16

248:19 249:2

294:13,19

296:11 323:10

disagreeing 85:17

122:14 123:17

248:6

disagreement

122:11 129:12

147:14 178:7

213:19 214:3

225:13 309:14

disagrees

123:8,13,14

325:12

disconnect 82:5

discontinued 35:5

discover 87:3

discrete 33:12

166:11 230:1,2

discretion 136:5

138:4 157:13,21

158:1 164:6

223:12

discuss 17:18

19:14 49:17 61:8

62:11 117:10

149:11 171:18

233:11 254:19

327:9

discussed 12:3

24:11 26:1 67:15

discussing 37:1

79:12 303:18

319:4

discussion 9:17,19

10:14 11:3,5

12:11 13:3,7

15:19 16:7,20

17:10 20:19 26:9

30:16 31:4 37:5

42:19 49:11

52:7,11,12,15

53:18 57:14

61:13 65:17 67:6

76:5 88:11

110:17 113:2

125:4 129:6

130:12 136:10

142:2 149:20

177:9 211:19,21

216:13 238:4

254:5 278:1

291:11 320:15

discussions

11:9,10 12:14

13:10,18 37:17

67:21 102:16

108:12 211:14

239:3 279:22

dishwashers 206:5

disincentive 80:10

dismiss 311:11

display 107:17

116:13

distance 37:17

distinct 140:2

199:19

distinction 287:8

distinguish 185:14

distinguished 63:4

distribute 9:11
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distribution 9:12

65:13

distributors 50:22

disturb 251:11

diverse 33:13

170:13

diversity 169:1,19

170:4

173:10,14,15

Division 4:15

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doable 323:15

docket 13:15,22

18:2

document 8:9 11:7

13:1 29:6

132:16,21

133:1,3

documentation

27:14

documents 19:14

20:14,15,21,22

DOE 7:17 8:11

9:12,22 14:11,16

16:5,14 18:6

20:10,13,21

22:2,14

23:1,14,16 29:3

37:11 43:10

48:14 57:2

59:10,20 60:14

61:8 63:11 64:2

66:11 68:3

77:8,14,21 79:17

80:18 83:16

84:1,5,16 89:21

90:22 93:4,9,14

94:2 96:3,5

99:8,17 111:9

112:9 125:5,14

131:5 132:9,19

133:7 139:9,22

144:21 150:19

156:9 164:12

167:10 170:4,9

191:18 195:2

198:1 206:10

211:14 212:21

223:22 243:5

244:1,18 261:20

263:16 275:4,19

278:16 279:1

280:12 281:3

282:8 285:17

294:1,5,9,14

295:2 303:6,11

304:17

308:13,19

315:2,8 317:9

318:10,15,16

320:22

324:6,16,17

327:5,21,22

328:3,4,6,8,15

DOE's 14:21 15:3

38:14 53:15

66:16 72:4 94:10

127:5 177:8

272:14 277:3

281:21 284:7

dog 162:14 165:3

282:17

dogma 117:17

dog's 171:15

dollars 95:5

172:14,15

domestic 210:5

Dominic 3:18

157:8

done 20:4 21:8

29:2 34:22

50:1,17 84:21

85:3 91:2

93:8,13 95:10

98:14 104:9

105:14,15

108:17 109:21

112:5 120:12

182:20 193:6

208:10 220:9

234:16 235:4

236:6,12,14

237:15 241:4,5

266:3 270:8

279:12 318:14

319:15 320:21

321:12,13

door 107:16,18

230:21

231:18,19

232:1,3,13,14

235:19

243:11,21

258:14

262:8,9,10,11,12

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doors 107:19

174:8 238:3,9

260:15,19,21

280:7

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12:16,21 27:4

53:2,13 54:1

61:21

62:5,9,12,19,21

69:22 70:21

71:4,15,20

104:21

105:6,16,18

132:4 133:6

143:19 144:1,7

147:15,19,21

148:1,4 160:19

178:18

213:3,11,15,18

305:5,11,17,21

306:6 307:1,6,12

323:7

double 310:7

double-check

184:9

double-edged

89:12

doubtful 106:19

Doug 4:20

dozen 165:15

draft 7:8 213:6

drafts 217:20

drag 211:18

drastically 246:18

draw 251:3

draws 170:4

drew 138:11

drive 288:10 316:4

driven 65:3 174:3

drivers 101:14

drives 316:6

drops 326:12

dual 217:1

duct 251:8

due 321:16

duplication

235:21

during 21:1 100:4

129:18

E

earlier 30:7 67:21

83:1 88:11

98:2,22 100:8

115:3 122:10
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237:16 264:14

280:15 322:13

Earthjustice 2:9

easier 85:19,20

142:2 222:12

300:20

easily 87:9 217:8

244:9

easy 17:20 80:5

186:10 202:21

227:14 228:6

229:3

economizer

156:15

economizers 10:18

edge 263:14

EER 174:4,5

300:14,16 301:3

313:4

EF 313:6

effect 259:17

Effectively 310:16

effects 37:21 38:5

efficiencies 157:1

169:10 220:7

233:7 241:15

260:21

efficiency 5:11

10:16,17 11:17

27:12 34:15,17

35:17 36:6,12

37:7 45:3,6,7

47:7 68:20,21

69:14 70:5,11

93:5,21

95:11,13,15

132:3 136:21

158:14 172:16

174:21 175:12

182:21 187:2

192:9,12,19

193:6 194:8

197:4

211:11,12,17

216:11,13,15,19,

20 234:8,9,20

241:15 243:9,13

244:2 245:19

267:15 275:10

293:1 309:10

312:7 313:4

315:21

efficient 175:3,10

215:5 234:11

243:12 301:18

efficiently 241:9

effort 81:21

313:14

eight 107:5 140:22

145:7,10 250:5

257:22 259:5,6

264:6,7 310:6,18

323:22

eighteen 145:11

eighth 200:12

Eisner 2:3 7:2

8:18 10:10 11:6

14:1,8 16:3,9

17:12 18:5,12

21:16 25:8,13

26:12,21 27:10

28:1,20 29:11,22

31:6 32:11

33:1,4 34:2

37:12 40:11

41:12,22 45:14

47:15,19 48:8

50:3,5,8 52:4

53:1,19

62:8,11,14 65:20

67:19 70:14

71:12 83:15,21

84:3,16

85:5,10,13

86:12,20

87:18,22 88:17

90:21 92:9 96:1

97:10 99:22

111:7,9,19

112:1,12 113:7

114:1,6,8,12

115:16 122:9,16

123:2,5,12,16

124:3,15,20

125:9,11

127:10,14,17

128:17,20

129:9,21

130:3,5,8 136:12

146:9,18

147:10,14

149:14 150:2

155:16 157:19

158:11 168:15

169:13 170:2

171:3,6 172:7

176:22

177:6,12,14,21

178:14 179:14

180:11

189:7,9,12 192:2

198:21 200:3,22

201:4 203:12,16

207:21 212:13

213:19,22

214:3,5,9

222:8,10

225:13,16,18

226:9

227:4,8,10,15,21

228:1,4,7,11,16,

21 229:5,7,10

232:17 242:11

245:8,17

246:1,5,13,21

247:8

252:13,18,21

253:2 261:3,16

262:6,14,18,22

264:1,4,13

265:2,5,7,16,22

266:6,12

267:2,4,10,22

272:5 273:22

274:3 279:17

280:9,14 281:21

282:14,21

283:4,7

284:4,11,17

285:3,9 286:10

293:22 294:9

295:4 296:11

309:14,17

322:12 323:10

325:12,17

327:8,16,19

328:1

either 32:6

33:11,18 59:12

96:21 99:17

113:22 173:15

191:6 206:2

211:15 223:8

250:4,19 266:20

268:3 287:22

288:1 289:21

either/or 189:9

303:12

elaboration 278:7

electric 2:13,22

3:12 12:17 140:5

144:2 172:13

184:7 205:14

206:8,13 213:4

227:1 277:13

314:2,12

electrical 68:18

69:6,19 205:12

259:16
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elegant 29:15

elephant 172:13

else 13:4 23:4 39:7

56:3 81:8 90:11

95:1,16 115:17

123:8,12 149:16

169:10 171:10

174:22 195:3

275:7 278:16

283:12 295:9

325:12

else's 54:18 320:21

email 87:11 134:7

embedded 66:15

Emerson 2:17

308:6

Emery 4:19

empirical 38:14

employed 330:8

encompasses

56:21

encompassing

57:7

encouraged 32:14

encouraging

295:7,8

endpoint 33:18,21

endpoints 33:8

35:1

energy 1:1,6 2:10

3:7 4:2 5:11,15

10:15 27:11 36:5

68:17,20 72:15

107:21 117:11

126:3 133:13

194:8 206:12

212:16 233:7

239:3,13 241:11

243:9 248:11

277:14,17,18

278:1,10 279:11

283:21 294:16

300:13 310:21

321:1

enforce 83:17

84:18

enforceable 236:4

enforcement 17:3

21:7,14 22:9

51:14,16 82:7

84:22 86:3 87:14

125:17 126:7

128:15 303:19

319:8,11

320:13,14

321:3,8,19 323:1

Engineer 5:2

engineering 4:16

43:1 92:21

154:9,15

159:4,11,15

163:2 168:1

173:13 219:9

277:10 281:1,17

282:10 290:21

291:2,3 309:9

engineers 26:18

engineer-to-order/

design-to-order

26:16

engines 158:7

159:4,5

enormous 118:15

ensure 83:17 91:1

enter 38:8 106:8

entering 89:19

90:1 105:19

141:19

entire 136:3

195:13 277:9

entirely 94:1

133:19 169:4

entity 201:21

203:5

entrant 106:3

141:16 183:17

entrants 96:20

97:1

entries 179:5

environment 2:18

260:18

environmental

317:19

envision 176:5,8

envisioned 57:9

EPA 3:4 279:22

280:13

equal 186:2

190:2,4,5 203:6

296:16

equals 202:9

equation 81:19

82:11 166:1

equipment 10:17

12:1 14:16

22:14,15

26:16,18

30:6,8,22

31:1,3,14

41:4,6,8 45:16

92:15 95:6 98:7

109:12 110:6

113:11 144:22

155:21 157:4

163:1,15 165:4,8

172:16 174:17

175:6,12,13

212:1 218:16

229:15

245:10,21

246:17 254:1,6

261:9,11

265:5,8,9,19

266:13 267:2,11

268:1,2 272:10

275:11 290:19

294:2,10

310:3,22

311:14,22 312:5

323:13

ER 315:13

Eric 5:19 322:12

error 314:11,13

316:12 322:15

ERVs 10:18

especially 17:14

28:22 58:11

116:12 145:4

241:19 307:10

312:12 313:18

essential 72:12

185:19

essentially 27:6

68:18

69:17,19,21 70:7

73:18 143:1

156:1 157:3

184:18 194:20

247:18 280:22

293:1 305:7

314:5

establish 48:1

established 44:18

establishes 99:21

establishment

45:11

Estes 2:16

esthetic 280:3
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estimating 197:4

estimation 197:1

et 10:19 159:6

evaluated 245:14

evaluation 78:1

evaporating

160:14

evaporativecooled 144:22

evaporatively

14:22 137:9

140:16 143:12

149:9

evaporatives

104:8

evaporator 56:9

event 87:1 272:9

everybody 7:2,6,8

8:4,13 11:13

14:9 18:1 41:12

47:19 48:8 61:12

87:1 89:10

90:4,6,11 124:21

127:9 129:4,21

142:14 146:9

201:1 227:12

228:16 312:16

Everybody's 89:7

everyone 12:7,9,12

38:12 49:15,20

55:16 60:9 63:6

67:22 92:3

124:18

everything 13:4

15:1 31:10 32:21

51:21 56:3,21

67:2 71:8 79:4

80:1 89:11 117:6

119:4 166:18

167:10 169:10

195:13 233:17

270:19 271:1

295:9

everywhere 58:12

evolving 36:9

exact 148:20

155:11 193:6

199:2 217:5

exactly 15:21

70:17 102:13

155:19,22 190:3

202:11 205:19

280:7 313:13

314:15

example 22:5

47:21 54:14

58:14 73:8

94:2,18 137:5

139:11 141:22

142:3,6 245:18

251:1 265:3

289:6 292:18

314:8 315:20

examples 13:8

23:9

except 134:5

267:19 295:14

exchange 36:6,10

158:8

exchanger 55:14

57:15 159:22

188:17

exchangers 159:6

173:2

excluded 32:17

excuse 117:21

283:12 314:7

328:2

exempt 17:2

Exemption 132:14

exhaust 218:19

exist 28:11 227:3

270:2

existing 78:8 96:6

224:2 261:4

265:14 267:2

exists 157:3

270:12

expand 40:21

157:13,22

expansion 160:14

expect 51:10

243:12

expected 243:10

expects 26:19

expense 216:21

expensive 26:17

experience 45:5

63:12 89:21

90:17 279:21

expert 250:8

expertise 131:6

experts 39:4 77:5

explain 22:2 96:19

107:3 124:4

277:15 288:16

292:11 328:3

explained 39:2

242:12

explaining 47:22

explicitly 30:17,18

exporting 239:12

express 173:22

expressed 80:13

expressing 174:1

extend 279:4

extendable 217:8

extended 47:8,11

extending 33:5

165:8

extensive 13:18

extent 10:20 11:1

31:15 39:12

44:15 60:6,8,18

96:10,12 97:3

129:18 149:11

151:6 157:5

195:12 210:9,11

238:16 242:15

299:7

External 145:8

extra 239:13 308:6

extrapolate 158:22

219:5 261:9

extrapolation 40:1

extrapolations

261:14

extreme 94:8

F

fabulous 280:4

face 42:10

FACILITATOR

2:2

facilities 94:20

facility 93:20

322:18

fact 63:3 64:16

75:15 85:1 86:5

89:4 90:17 92:19

93:1 112:10

119:1,5 165:16

168:1 203:2

215:2,3 216:8
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248:17 314:10

317:17

factor 124:14

309:1

factored 312:8

factors 124:11

238:2 242:12

255:8,9

fail 91:3

failed 19:15 85:22

fails 162:1 292:15

failure 86:13

127:13 156:3

307:4

fair 87:15 160:7

271:4

fairly 36:7 109:10

163:3

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166:7,9,11

259:21 306:19

falls 15:1 107:15

188:19 193:10

families 33:13

57:5,10 197:22

198:2 200:11

family 33:22

35:2,4

54:6,8,13,19

55:10 57:1,5

59:18 60:19 61:5

78:13 81:16

182:17,18

189:18

196:12,13,16

197:2,5,21

199:8,16 200:9

278:14

fan 159:22 211:9

Farther 44:6

faucet 205:20

faucets 205:13

fault 174:10

favor 16:18 18:12

153:2 295:5

fear 92:11

feasible 209:11

218:14

features 63:17

64:1

federal 1:4 35:6

40:14 258:5

305:14,15,22

306:8,16 307:6

328:21

feel 51:20 84:20

106:14 111:10

116:1 168:10

253:18 277:15

282:8,9,10

feeling 21:21

felt 80:4

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128:19 177:4

278:5

fewer 33:13

262:18 263:3

field 39:13 46:18

49:16 77:1 83:8

92:7 93:22

Fifth 54:1

fight 162:14

239:19

fighting 236:12

figure 63:14

124:21 244:11

262:15 316:11

file 208:13

fill 133:18 227:17

fin 176:10

final 7:7 93:11

133:17 164:2

322:20

financial 330:9

financially 218:14

fine 16:11 18:10

40:10 42:22

51:11 52:2

60:6,11,20 84:9

134:18 209:6

257:8 281:6,14

290:11

319:15,16 323:9

325:1

fingers 13:13

fire 95:13 187:6

196:18

fired 182:5

190:1,2 219:22

227:11 323:4

fire-tube

204:20,21

first 16:9,13 19:17

20:13 29:7 39:8

49:21 50:3 64:9

67:18 79:7 95:18

96:2 113:9

121:15 123:12

135:7 136:15

145:10 177:19

190:4 192:5

193:12 230:2

234:14 250:8

256:4 276:17

291:7 297:8,9

312:13 313:14

327:15

first-level 121:16

fit 98:8 194:3

198:15

fits 311:10 312:22

315:4

five 41:5 57:2

58:15 62:20

72:18 74:11

75:11,16 76:2

91:14 98:16

137:22 139:5,6

170:19 171:17

172:1,4 178:13

244:12 246:16

256:15 257:2

269:16 287:2

288:17 292:15

293:2,6

297:7,8,12

298:11,12

299:14,15

300:1,2,3,5

301:5 302:16

303:17 304:19

305:7,9,12,16

306:2 309:21

310:14,15,16,17,

22 311:1 312:10

313:4,5,8,13,22

318:12

319:16,19

321:2,7

322:8,14,21

323:5,8,14,19,20

324:1 325:1,8,13

326:12

fix 316:21,22

fixing 203:18

flag 39:18

flail 59:11

flames 185:3,10
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flavor 184:4

flesh 115:14

flip 308:4

floated 102:13

flow 194:13

250:12

flowing 251:9

flue 38:6 184:18

185:12

fluid 156:15 165:8

fluids 162:22

163:3

flux 266:4

fly 3:2 29:13

41:1,2 55:20

144:20 145:3

148:8,11,13,15,1

7,21 149:7

162:13 291:22

292:3 315:3

focus 7:11 21:2

88:11 136:12

151:16 271:10

focused 22:13

274:8

focusing 253:11

FOIA 132:11

folks 130:15

follow-on 123:11

125:22

font 144:17

food 242:3

foot 259:15

footnote 208:5,6

forbid 21:12

forced 193:8 197:7

200:10 239:9

foregoing 330:3

foregoing/

attached 331:6

foreseeable 216:16

forget 45:20 190:3

forgetting 226:15

forgot 225:22

form 35:16 38:16

70:22 133:19

134:16 261:10

312:16

formally 32:14

formula 231:18

formulas 219:4

Forrestal 1:8

Fort 126:14,16

forth 92:22 94:2

fortunately 314:8

forward 40:15

61:7 67:22 68:7

101:16 102:2,6

135:5 136:10

187:16 276:9

282:4 283:18

foundation

61:10,18,19

foundational

101:15

four-cubic-foot

107:13

four-row 56:8

fourteen 145:11

fraction 110:22

fractions 236:20

framework

12:11,14

276:8,12

Frank 4:14 5:9

26:13 33:14

35:11 38:1 41:22

42:21 44:9 56:2

59:7 62:15

88:17,18 90:14

92:16 97:8,17

98:2,10 113:9,16

114:11 117:22

118:4,20 119:10

127:5 141:14

152:7 153:8

165:2 167:12

170:13,15

175:15 178:22

180:18

181:15,22

183:12,14

184:16

185:18,19

189:20 190:9

193:12 194:9

201:7 202:11,18

203:20 208:8

211:13 214:22

216:6 217:2

219:13 221:2,6

222:11 225:3

249:14 291:7

311:8 313:1

315:4 328:2

frankly 90:12

Frank's 90:7

96:17 165:20

322:13

free 51:20

freely 218:12

318:9

Freeman 3:3

freezer 235:16,17

241:8,10 249:6

251:14

271:18,20 272:1

freezers 107:8

229:2,4,8,19,20

230:14

232:5,6,7,12,13

235:11 240:10

248:22

249:11,12,13,22

263:9,10

frequently 217:5

front 20:14,21

22:22 29:6 39:19

80:5,9 85:3

86:5,14 99:19

149:2 163:15

250:15,18

fronts 250:19

251:2

fudge 82:1

fuel 146:3 180:15

181:7 184:8

full 94:5 185:9

186:6

function 38:18

120:16 193:20

210:15

functional 68:19

176:3

functions 308:1

fundamental 36:3

45:11 175:19,22

194:2,3 250:11

fundamentally

192:7

furnace 211:16

furnaces 31:1

225:19

227:10,11

future 224:12
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261:6,8 263:2

269:1,2 275:3

276:1 278:18

299:9

G

gain 234:19

gallon 186:21

188:14

gallons 185:21

186:3,4,14,19

190:1,3,5,6

193:2,4

201:11,18

202:13,15,17

gamble 80:7

game 172:13 274:2

gap 90:22

gas 3:12 105:1

172:12 184:6,11

189:22 190:1,13

219:22 221:9

226:18,19

227:1,2,5,7

273:13,16,17

277:13 300:13

gases 38:6

gas-fired 182:16

190:5

201:10,17,21

203:2 227:10

gather 40:16

GE 2:15

gee 200:1

general 14:5 16:7

21:21 25:21 45:9

62:17 100:15

131:18 137:3

191:8 226:8

290:21

generalized 60:15

generally 30:4

47:1 106:7

174:16 181:10

209:5 248:17

280:22 286:9

generate 33:17

38:21

generated 8:22

generating 20:8

generic 162:21

308:8

generically 44:11

191:20

Geoff 92:17

Geoffrey 3:5

geothermal

45:17,21

gets 36:4 49:11

52:18 55:15

128:14 187:20

202:18 239:16

285:11 320:2,10

getting 24:2 35:18

36:17 38:4 40:3

52:6 61:22 90:21

96:22 109:17

115:16 119:14

121:12 128:5

245:17 256:14

268:21 269:4

270:3 279:12

280:4,12 285:2

290:18 312:19

314:13

given 54:22 55:10

65:4 68:15 92:6

116:10 153:16

162:9 258:8

292:9

gives 73:11

192:14,17

295:17 316:2

giving 92:14

glad 200:20

glass 107:17,18,19

230:21 232:1,13

235:19

243:10,21

250:15 258:14

260:15

glide 263:13

glycol

162:18,20,21

165:14,15

glycol-cooled

156:13,20 163:9

goal 222:7

God 21:12

Goodman 5:18

16:4 18:8 68:8

82:13 120:14

142:20 160:12

178:8 307:14

315:15 319:1

322:11

goods 63:13 65:22

66:1

gorilla 91:22

Gotcha 46:22

137:10

gotten 87:11

211:20

government

113:5,7

Grant 218:3

grape 40:7

great 62:4 121:11

229:9 279:16

greater 140:11

142:11 185:20

186:3,4,5,18,20

190:1,4,5

193:2,3

201:11,18

202:17 203:3,6

323:18

gross 247:3

ground 7:5 8:7

28:21 45:17,21

212:17,20

group 7:14,15,16

8:10 52:8 55:21

57:15 59:17

61:4,19 66:20,21

88:16 92:20 98:1

99:21 128:11

143:10

186:13,14

201:16 215:12

223:9 231:3

234:7 247:14

248:1 279:3

284:9

grouped 76:15

102:21

grouping 56:15

73:5 181:5,7

groupings 11:3

202:10 204:13

groups 22:15 61:2

74:6 76:9 83:22

88:12 92:12

233:10 239:2

guarantee 17:4

255:17

guess 14:13

43:5,18 59:5

85:2 90:8 103:14
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123:4 128:5

149:10 151:15

153:17 171:14

186:3 205:11

216:12 228:2

239:22 242:1

253:8 270:17

271:15 281:5

288:14 299:3

guidance 40:20

168:21

169:14,18

191:19

guy 117:18,21

172:1

guys 15:13,15 17:5

24:4 30:18 31:5

39:4,14 49:17

53:1 55:2 61:20

77:4,5 81:2

85:15,18 91:7

113:10,14 146:5

183:5,6 313:15

316:9 320:9

327:1

H

ha 247:9

half 239:4 241:18

248:13,14

257:12 274:15

Halley 3:5 92:17

93:17 94:7,13,17

Hall-Jordan 3:4

hamper 225:10

hand 22:10 48:19

135:2 150:22

295:12 318:3

handed 317:13

handle 230:7

handled 248:2,8

handlers 70:4

handling 196:22

hands 227:12

handwritten 21:16

Hang 150:12

happen 63:7

255:17 268:22

happened 68:22

269:18 321:16

328:5

happens 80:18

87:3 177:1

223:22 239:11

272:8 327:22

Happiness 217:15

happy 7:8 11:13

15:22 22:5 79:5

125:20,21

141:22 207:4

268:8 270:18,21

hard 88:12 207:1

227:16 315:2

harder 114:9

228:1 295:13

326:20

Harry 225:4

Harvey 5:3 12:22

22:7 23:7 24:2

25:7 29:12 37:12

39:17 58:9 59:5

91:10,12 117:15

151:15 168:16

171:10 172:17

173:20 175:16

178:1 206:20

212:11 223:21

225:12 250:7

272:5,7 295:4

308:3 315:19

317:7

Harvey's 118:21

171:21 172:11

209:22

Hatcher 107:4

108:8 109:4,16

110:13,16,21

111:2,8,11,21

112:3,15 134:18

Hatzikaziakis 3:6

haven't 87:11

209:22 262:5

269:15 312:12

314:22 323:13

having 18:10,13

19:6 26:19 34:9

66:17 68:17 81:5

90:21 100:4

116:15 121:22

122:10 158:12

209:12 217:9

219:9 235:20

242:5 257:20

267:6 275:1

276:14 317:13

hawk 99:17

head 35:8 152:22

170:13 238:1

headed 109:18

hear 14:1 25:11

32:16 41:2 50:8

69:4 125:9 131:8

141:10

heard 115:3

130:21 211:21

216:7 264:5

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180:4 182:1

legal 110:9 125:16

132:15 263:17

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legitimate 27:20

257:5

Lennox 3:6

less 14:19 24:3

27:17 33:17

41:4,15,17 42:13

68:13 78:11

103:3,20 140:11

142:11 149:6

175:2 186:2,13

190:2,6 202:15

206:17 215:2

231:15 246:19

247:5 274:18

278:16 283:3

286:15 290:11

292:4 293:19

295:22 301:18

305:22

let's 17:20 29:8

36:3 55:21 59:12

89:16,20 90:6

110:15 121:15

132:8 153:12,15

158:21 172:18

200:22 263:8

269:5 271:17

275:2 277:15

297:6 300:7,12

316:21 322:19

Lets 300:10

Let's 48:12 161:1

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315:18

letting 81:6

level 25:20
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70:11,18 77:1

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102:18 112:16

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243:9,13 244:6

266:22

276:19,21 287:3

291:21 296:6

300:3,4 306:10

316:2 325:4

levels 23:12 70:5

163:8 238:13

244:3

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likely 13:21

33:17,20 73:5,16

173:13 237:17

242:5,6

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103:10 260:13

limit 18:21 39:21

157:9

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Lin 3:22

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119:5 128:10

136:15 182:21

186:6 203:4

214:8 222:15

232:20 235:17

290:12 300:13

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linear 30:19

32:15,20 33:8,22

34:7,10,16,21

35:4,15,20

36:9,11,15 37:8

38:7,15

39:6,13,18,19

40:12 43:18,20

44:22 197:6

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lines 130:2

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9:8,10 10:13,19

11:9,11,14 14:7

34:3 61:14 132:6

147:11

149:10,16

168:15 169:15

170:4 171:9,12

172:8 213:19,21

214:1 225:18

227:21 228:18

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171:17

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72:16 159:5,9

little 7:9 8:12 13:2

15:3,6 17:17

24:7 35:14

41:1,3 60:14

84:14 89:8 95:5

106:19 130:1

156:3 159:3

168:22 176:6

222:13 240:1,5

244:13 258:15

265:11,17 267:6

273:4 280:15

281:9 290:11

292:11 301:16

309:3 311:19

312:2,9 313:19

325:9 328:6

live 126:13 255:10

263:20 272:4

311:18

LLC 3:17

load 259:14,16,18

260:10

loads 206:6

location 317:2

Lochinvar 3:16

8:20 32:13

61:6,16 68:2

77:13 101:13

182:15 191:1

194:22 195:14

196:5 207:22

214:10 224:6,14

289:19 309:2

323:4

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237:19 281:2

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93:3 112:8

122:22 129:1

144:9 183:9

234:14 236:6

240:12 263:14

268:5 276:8

280:21 289:20

291:20 293:9

295:17 324:6

longer 84:15 265:4

272:11 285:2

lose 119:1 185:14

loss 38:17 185:22

186:22

192:8,20,22

193:5 316:20

317:10

losses 250:18

293:1 313:3

lost 97:14 229:1

lot 13:8 19:21 21:8

34:6 36:2 37:13

59:6 63:1 65:6

76:21 80:3,4,13

92:5 93:1 107:22

108:9,18

109:12,17

112:5,8 156:1

167:19 168:5

174:3,8,12,15

206:6 229:22

236:20 237:2,18

239:9 242:14

255:8 256:5

259:19,20 264:2

269:3,5 278:3

286:3,5,8 299:13

310:2 318:19

327:11,13

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185:12 264:14

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Louis 5:11 27:11

150:3 155:17

163:10 194:7

207:6 237:14

256:7 273:1

love 126:16

low 31:13,20 32:1

114:21 117:5

216:1 237:21

238:7,18 240:10

283:13 309:4
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lower 38:5 117:5

198:15 220:5

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283:5 293:6

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317:11

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219:1,5

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224:1

Luke 3:4

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62:1,2,10,11,13

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128:22 129:18

130:15 135:2

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176:5

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114:9,10,11

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ma'am 146:8

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213:8,10,12,14,1

7 222:21 224:20

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195:12 265:13

267:8 278:11

manufactured

68:16 136:2

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manufacturer

17:2 21:20 22:22

24:22 25:15

26:17 43:15

50:12 58:11,14

59:1 61:1 63:15

67:5 68:17 74:5

79:16 81:12,18

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116:21 117:9

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204:19 210:17

221:17 251:2

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255:21 256:3

271:7 309:4

316:11,17 317:5

318:15 322:18

328:17

manufacturerdriven 50:11

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22:17 23:18

24:21 27:6 54:7

64:16 68:5

80:4,6,16 83:2

88:4 90:14

91:6,11 92:20

94:18 99:8,12

100:4 119:2

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131:5 135:8

168:21 169:4

173:4 175:10

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317:22 318:19

324:15 326:10

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23:13 82:9 98:18

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Manufacturers

2:13 79:3 92:18

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4:9,21 18:15

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251:6 253:17

254:12 266:13

306:4 316:6

321:17,18

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306:15,22

Marantan 4:5

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mark 3:2 4:8,18

41:2 55:20

144:20 148:8

187:1 291:22

315:3

market 21:10

42:15 50:22 60:1

77:10 81:7 90:18

99:19 268:9

271:20

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301:3

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94:19

markets 271:21

Marshall 3:12

92:12 172:12

174:7 206:4,22

212:13,14

226:17 273:1

277:12

Marshall's 173:22

Mary 2:19 21:5

81:10 115:19

122:21 126:1,6

147:3 152:3
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102:12 150:15

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69:13 75:16

82:15 89:7 92:4

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117:22 125:12

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190:18 192:3

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231:18 232:4,7,8

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266:14 267:15

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36:15 37:15

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41:15 44:12 45:8

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55:13,14 59:16

61:22 69:10

72:20 74:3

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86:2 87:15 90:19

96:10,11,17 97:4

100:20 101:5

106:5,6

114:15,16

116:22 117:1

118:12,22

125:21 126:15

127:16 128:1

141:21 143:14

150:12,17

151:11

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170:2 182:11

184:17 187:17

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194:10,18

195:9,12 196:1,3

198:8

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200:1 205:19

210:7 211:14

220:12 222:9

224:11 230:17

237:5,20 242:14

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mechanism 99:3
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129:3

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63:5 69:3

79:5,13 80:15

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172:2 219:7

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311:10 313:1

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216:14 217:4

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66:16 67:20

131:13 144:10

207:18 226:14

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271:21

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73:1 75:12

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50:1 55:1 56:18

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79:14 80:5,8

81:4,5,6,8 83:18

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88:20 89:1,15

93:4 96:21 97:5

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100:8,13,15

101:7,11

103:7,11,22

104:11,12,14,19

105:9,10

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110:18 113:13

114:18

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188:3 230:4

231:9 233:21

234:15,16 235:3

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243:4,13 266:10
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minimums 121:8

123:20 125:2

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12:17 27:4 53:2

61:21 69:22

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160:19 213:3

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319:2

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23:8,10,13,14,21

24:8,12,16,19

25:2 29:18 33:9

38:22 44:18

50:16,17 51:10

52:7,8,11,13,21

53:4 54:17 55:21

56:1,4,6,7,10,15

57:14,16,17,22

58:2 59:17 60:19

61:4,8,14,19

62:6,13,17,18

63:8,10,11,20

64:3,7,18

65:5,12,13,15

66:3,9,18,19,21

68:4,10,15

70:10,11,22

71:1,5,10,13,18,

21 72:4,7,14

73:15 75:8,13,15

76:1,8,13,18

77:14,21

78:1,2,4,14

81:16 88:12,15

101:17 102:6

108:6,7,8

109:10,19

111:3,13,15,18

112:17,19

127:20 128:11

133:11 136:20

139:6 141:18

154:8 155:3,7

157:12,21,22

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159:4,9,17,18,22

160:1,17 161:21

162:1,9 186:10

187:13,14,16,18

189:13 193:9

194:11 230:9

234:7,12

243:16,18

244:10,11 249:7

250:17 251:4

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258:10

260:15,16 261:1

269:21,22

274:12 275:3

277:21,22

278:12,18 279:2

280:2,20 287:11

290:12,16,22

291:3,14 292:5

295:16,17

296:18 301:2

305:2 328:9

modeled 160:5

257:6

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112:17 239:8

247:21 249:4,18

250:12,14 255:7

257:18 268:14

models 20:10

22:15,17,18 23:3

24:15 25:3 29:15

44:14,16 49:5

55:8 64:12 66:9

67:6,10,15

76:2,8 77:5

81:15 95:7 107:5

108:9,14,15

110:12,19

111:20,22 112:5

116:21 117:13

119:12,13 128:7

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138:3 152:13

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155:4,15 156:7

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158:12,20

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161:3,5,13,22

163:2 164:16

166:17

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176:18 179:16

183:2,8,11

184:20 188:9

189:5 190:17

194:15,16

197:15 199:15

201:13,18 202:2

215:2 216:5

221:1,9,11

222:18

223:2,3,4,5,8,9

226:3 231:9

232:11,15 236:9

237:3 238:4,8,12

239:16,21 250:5

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263:8,9 268:20

269:11,18

272:9,19

274:11,17,19

275:1 278:13,21

281:5,13

295:8,15,16

model's 101:15

modifications

263:19
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modify 111:18

modular 144:8

Mohamed 4:11

Molvie 4:10

money 173:6

174:15,20 315:1

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months 83:7

moot 206:22

morning 25:11

92:19 168:17

327:15

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mostly 79:6

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motor 72:18,19,21

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75:11

mounted 191:2

move 40:15 42:18

61:7 67:15,22

68:7 101:16

102:2,6 128:8

136:10 210:7

212:15 223:22

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115:1

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38:18 56:22

58:12 64:17 73:8

109:8 139:18

165:22 210:17

213:5 221:18,21

230:7 235:22

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multi-tube 176:9

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33:14 92:16

97:8,16,18

136:15

137:10,14,17

165:2 177:19

178:21,22

179:3,21

180:1,4,8,18

181:1,9,22

185:18 186:16

189:20 201:7,15

202:8

203:10,15,20

208:8,19 209:8

214:14 217:2,12

219:13,17

220:15 221:6

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myself 58:11 117:8

170:10

N

narrow 15:13

39:13

narrower 279:1

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4:7,13 43:5 67:4

123:19 141:11

170:17 171:14

240:1 249:3

251:19 258:19

270:17 279:21

324:11

nato 88:5

natural 217:19

226:19

nature 70:4 167:4

176:3 206:14

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4:5 5:22

nearly 251:11

necessarily 18:16

75:16 111:12

133:22 134:14

135:16 138:10

154:9 196:2

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240:9 280:20

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past 107:1 209:5

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plate 13:20

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print 35:9

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99:1,6,10

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question 19:13
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31:2 38:2 44:10

50:5 62:16 70:15

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251:5

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310:19

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recognition 9:21

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101:16

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184:6 279:18
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regards 170:19

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163:15

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rerate 267:1
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re-rated 265:15

re-ratings 265:20

research 174:15

259:20

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169:6 204:22

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264:22

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result 67:20 71:14

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roughly 36:5,11

110:12
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route 78:17,20

79:5,9 166:16

routes 78:21

routinely 317:1

rule 10:4 16:15

40:17 93:11,15

112:12 162:2

171:9 206:11

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10:1,3,22

11:18,21,22

12:2,3,6 13:16

48:22 95:20,21

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37:8 93:2 105:11

127:8 159:13,14

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run 52:13 76:1

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113:14 117:2,7

126:10 140:10

150:22 183:1

189:16,18 192:8

193:9,13 195:4

211:6 216:12

219:2 232:10,16

243:20 249:20

261:5 273:16

292:14

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running 87:9

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179:13 185:2,9

193:16 217:1

249:5 310:17,22

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runs 25:18 116:11

241:8 322:18

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120:14 142:20

160:11 178:8

307:14 308:3

309:22 312:3

315:15 319:1,20

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Sachs 5:3 12:22

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22:7 23:7 24:5,9

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37:13 39:17 40:6

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58:8 59:5 60:22

91:12 92:10

117:14,15,20

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170:7 173:16,20

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224:11 225:12

241:21 242:8

250:7,22 251:13

272:7,15 273:6

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308:3,15,18

314:4 315:18

316:21 317:7

318:11 325:14

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112:4 135:6

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84:18

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satisfies 204:17

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Saudi 4:11

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256:21

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246:20 266:8

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seems 17:16 21:21

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171:10 175:17

194:14,20
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seen 66:8

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simulated 48:18
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180:5 182:18

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sizes 31:9 94:8,9

216:18 217:9

SJI 3:5

skew 288:10

skilled 153:13

skin 274:1

skip 16:1 285:7

SKU 117:7

SKUs 57:21

108:20 122:6

slap 13:13

slash 161:2

slide 12:9

14:4,12,14

16:17,19

30:3,11,16 44:8

47:6 48:21 49:10

102:10 134:20

135:19 138:21

142:1 154:22

166:7 179:2

221:15 257:1

263:18 285:8

slides 11:19 15:17

16:1 21:12 57:8

178:13 226:7

257:1,2

slight 72:17

slightly 174:1

280:15 311:2

slippery 162:19

slockily 290:16

slope 162:19

small 14:19 55:22

57:11 100:21

103:20 114:20

117:3 137:7

138:15 140:5

142:10 157:2

205:12 215:17

242:12 247:1,6,7

257:21 263:12

309:4,12 310:3

327:8

smaller 33:19 94:9

117:3 121:22

122:5 214:16

241:19 246:21

277:6,11

smallest 18:22

54:15 168:18

240:13

Smith 5:8

SoCalGas 4:3

software 43:9

sold 46:11 315:22

solely 126:4 235:2

solid 232:1,14

235:19

243:11,21

250:15 254:9

258:14 260:15

282:10 284:1

solution 219:20

235:8

Solutions 213:9

solves 256:22

somebody 13:11

18:18 29:2 40:22

43:17,20 53:19

54:18 84:12

89:18 96:1 97:11

99:5 106:12

123:16 127:19

142:6 152:15

169:11 171:10

176:12 239:15

255:14 271:5

314:10 318:3

somehow 226:4

someone 26:9

27:19 92:2 93:13

110:18 132:7

151:6,8 167:7

174:17,22 221:7

320:21

someplace 149:15

somewhere 43:9

117:1 154:1

160:12 167:22

206:19 207:3

208:6 257:9

270:20 310:7

sophisticated

109:11 250:17

sorry 51:4 72:10

85:10 87:20
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135:13 143:7

155:1 170:10

171:5 179:13

186:17 203:15

205:5 208:1

209:20 214:2

217:16 260:4

283:6 285:16,22

296:14 301:14

325:7

sort 9:3 10:6 14:7

56:15 57:22 63:6

74:4 92:18

117:21

118:2,13,16,17

167:22 187:8

196:10 237:17

241:21

sorts 63:16

sound 263:16

sounds 19:6 65:7

203:17 270:1

313:6

source 4:2 14:22

45:17,22 68:17

104:15 140:21

145:9 146:4

148:17 149:5

212:17,18,20

southern 207:11

space 31:16

210:21

span 114:19 136:3

188:9 254:8

spanning 252:10

spans 187:21

188:21

195:14,20

198:11 204:22

spare 126:14

speak 18:12 63:13

91:10,12 233:16

295:5 318:6,9

SPEAKER 109:3

128:19

146:5,8,19

147:12 150:10

177:4 207:6,14

213:8,10,12,14,1

7 222:21 224:20

227:2,18 228:20

229:4 231:7

252:19 257:13

278:5 285:4,6

305:10 309:20

319:7,22

SPEAKERS 327:7

speaking 69:1

191:20 209:6

276:18

special 83:22

127:4

specific 36:17

41:16 50:14

60:10 64:12

132:20 133:5

135:16 138:9

198:8 199:8

210:8 218:18

specifically 60:16

132:5 140:1

163:7,8 279:8

322:17

specification

110:2

specified 135:21

136:18 326:13

specify 131:2,4

137:1

spectrum 20:1

35:1 59:17

94:6,8 109:20

110:8 169:9

spell 134:1

spelling 145:6

spend 174:15

spending 95:5

173:5 174:20

spit 301:19 327:3

split 14:20

15:8,9,11 46:2,6

70:1 103:1,2,7

104:6,17 105:2,3

108:15 139:11

140:10

142:6,18,22

143:10 145:13

156:17 207:12

217:3 237:17

split-out 155:20

157:6

splits 103:13

143:15 198:2

splitting 238:16

spoke 138:21

spot 126:21 320:22

321:1

spot-check 125:10

spreadsheet 56:21

SPVU 115:11

SPVUs 14:21

115:3,6,8 137:9

140:17 141:4,13

145:7

squeeze 309:10

squirrely 328:6

stack-over-steam

219:2

staff 277:8,9

stage 129:13 295:6

stake 88:3

standard 10:18

19:15 22:15

23:2,8,21 46:4

110:4 111:14

132:15 134:16

165:7 172:19

192:19,20

208:14 209:3

212:19 213:4,6

231:2 234:8

245:12 246:2

254:14

261:6,8,13,21

262:2,4,8,9

265:7,17

266:15,18,22

267:5,12,16,18

268:5,6,8

269:6,19

272:9,10,11,20

273:1 281:3

284:8 286:8

287:3 288:7

291:21 296:6

298:14 299:20

300:3,4 301:17

302:15 306:10

307:15 311:4

315:21 319:18

standardize 54:22

standards 60:16

93:5 94:2

130:9,11,13

140:3 156:10

163:6 175:1,8

180:14 192:6

211:16 239:5

245:8,16,19

246:16 248:11

275:5 308:22
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standard's 266:3

Standards 1:3

22:20 328:21

standard-setting

118:14

standby 38:16

185:22 186:22

192:8,19,22

193:4

stand-by 316:20

standpoint 289:20

309:3

stands 47:4

Stanonik 5:9

35:11 42:1,20,22

43:3 44:9

62:16,20,22

88:18 98:3

100:17,22

105:19

113:12,16,20

114:10,11

118:4,5,7,12,20,

21 141:14,18

152:7,11 153:8

158:19 167:12

175:15 180:10

181:15,16

182:3,9,14

183:14,21

184:8,16

185:6,19 190:9

193:12 202:11

211:13 214:22

216:6

222:11,18,22

223:2,13,15,18

225:3 226:22

227:14 291:7

303:14 311:8

313:12,16,21

314:7 322:16

323:1

328:2,11,14

Star 107:21

117:11 126:3

239:3,14 248:11

277:14,17,18

278:1,10 279:11

294:16 300:13

310:21 321:1

Starr 5:11 27:11

149:22

150:3,5,16

151:9,14 155:17

156:5 157:1

163:10 174:14

194:7 205:10,21

207:7,11,15,18

237:14 256:7

257:4 264:8

268:17

270:1,5,10

273:11,16

274:1,7 278:6

280:19 282:8,13

283:20 290:6

start 7:5 8:11,15

11:14 16:10

17:18,19,21

37:20 53:17,21

54:21 61:7 93:10

101:12

102:16,20 117:1

122:13

130:3,10,12,13

135:13 150:10

176:16 177:17

180:12 228:11

235:12 255:11

256:19 270:15

327:6

started 7:3 88:19

108:12

217:18,19

228:17 270:19

312:13 314:11

316:14

starting 9:6

11:14,15 40:16

205:8 207:6

224:2 233:16

312:19

starts 186:8 273:1

state 169:8

stated 41:5

77:15,21 217:5

statement 22:1,6

27:1 29:4

98:2,22 204:7

264:14

294:14,19

station 273:13

statistic 125:18

statistical 78:1

111:13,16 113:3

117:16 118:2

163:21

statistically 38:14

113:4 236:10

263:12 276:17

statisticals 277:20

statistics 111:14

161:20 162:10

255:4 295:1

status 212:18

statute 246:10,11

statutory 60:17

stay 67:14 98:1

steam 32:2,3,7

215:4,7,11

218:2,4,20

219:1,5,12,21

220:3,6

221:1,5,8,21

222:14

223:5,8,11 224:5

steam/hot 222:15

224:10

steam-only 219:18

steels 65:1

step 60:22 106:14

135:8 270:18

278:19 322:20

325:11

Stephen 3:19 5:6

Stephens 5:13

38:11 39:16 52:5

74:20 75:2

106:4,9 121:20

155:9,13 165:19

166:22 187:19

188:2,5,7,12

189:1,8 191:16

200:2 204:18

205:5 209:19,21

210:4,16 211:3,8

221:13,17,20

222:3,5 240:17

241:13 276:16

293:21 295:20

296:4,8

303:18,22

316:18,22

317:15 318:17

steps 99:18

Steven 4:3

Stevens 191:16

stick 80:6 119:4

191:18

stop 14:4 285:1

stops 21:10

storage 38:17

176:10 180:15
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181:6,8,10,19

182:4,6,16

183:3,6,19

184:2,20 185:20

186:1,9,12,21

187:11

191:3,5,6,7,9,21

193:3,4 195:5

208:1

storage-type 182:2

201:22 202:16

story 61:17

straight 292:12

straightforward

36:7

Strait 5:15

strengthen 116:22

strengthening

237:3

strike 9:3

stringent 293:20

strong 37:21 81:13

82:11 128:6

structures 60:1

struggling 92:19

stuck 209:12

stuff 26:8 118:16

119:3,7 172:3

239:9 244:20

272:22 274:18

312:15,17

313:19

style 241:8 281:14

Suami 5:16

sub-AEDMs 202:4

subgroups 129:6

subject 41:2

132:13 134:2,9

172:8 192:19

197:15

submit 151:4

submittal 112:10

submitted 134:15

324:22

submitter 134:7

submitting 139:8

subsequent 79:7

177:15

subset 37:8 54:22

72:8 114:21

substance 7:20

27:3

substantial 255:22

substantially

184:12 194:9

215:10 264:21

269:7

substantiate 35:3

50:1,12 58:7,16

67:7,12,17 71:18

78:3 81:19

101:17 138:1

161:2 170:11

183:11 189:16

196:14 210:18

224:17 231:9

234:11 258:17

262:1,4 276:2

308:15

substantiated 86:8

204:8 260:3

substantiating

123:21 196:12

253:10 257:17

substantiation

28:6 34:21 43:21

48:15,20 50:6

57:12 75:19

82:6,9 86:15

102:2,8,14

115:21 116:1,4

117:9,13

126:9,10 134:22

142:22 143:3

147:4 152:4,5,9

153:17 185:15

233:2 236:22

237:4,13 252:14

253:9,10,15

258:9 260:5

304:12,14

substantiations

78:11

substitute 64:18

317:10

subsumes 30:8

subtleties 115:14

successfully 67:22

sudden 42:9

242:18 274:22

291:1

SUE'S 263:22

sufficiency 23:12

sufficient 57:3

274:19

suggest 16:5 19:3

29:1 36:20 61:7

83:10 121:14

142:21 178:9

183:10 290:1

suggesting 36:18

46:12 84:1

208:17

suggestion 40:4

102:7 130:17,18

137:6 210:7

274:10

suggestions

263:19

suitable 33:16

suite 170:13

summarized 30:11

summary 48:11

super-duper

172:20

supplement 107:1

suppliers 209:7

supply 31:18

124:14

180:16,20

181:3,8,9 183:7

197:20 203:3

supplying 32:6

support 26:15

47:1 282:1

322:13 323:6

supported 321:20

supporting 29:14

supposed 187:15

258:2

supposedly 236:4

318:14

sure 7:6,22

12:8,17 14:9

20:7 22:22 27:19

30:2 46:16 50:4

59:20 61:11

79:8,18 80:9

81:12 82:10

88:14 99:20

124:4 125:6

141:12,15

144:19 146:7

157:22 165:1

169:16,17 184:8

195:19 219:17

220:2 229:12
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234:2 236:15

248:1 251:20

252:9 255:21,22

257:3 273:2

276:3 278:3

279:10 287:20

295:14,16

296:20 321:16

323:8

surface 36:11

surprise 236:16

Sutphen 5:17

31:7,20 32:9

95:2,22 217:22

218:7,13,22

220:16,20 222:2

SW 1:7

swing 313:5 324:1

swings 317:1

switch 75:11 159:7

306:3

sword 89:12

symmetry 272:20

sympathize 277:10

system 18:21 19:1

46:9 57:17 72:17

73:2,4,6 105:2,3

109:11 113:3

139:12 142:18

143:10

160:4,5,13,20

164:13,14,15,20,

22 224:2 232:4

263:7

systems 4:15 5:14

15:8,11 46:2,3,6

70:1 91:16

103:1,7 104:6,17

140:10 143:1

150:8 160:6,7,15

164:1,12 196:22

237:22

238:13,19

263:12 269:14

T

tab 134:6

table 12:12 13:9

15:13 20:19 23:4

30:6 32:21 51:21

59:15 67:17 68:5

72:2 85:14

120:21,22 136:9

156:9 205:19

206:2 208:5

231:13 267:19

273:4 286:3

299:14 320:15

321:3

tables 163:16

233:11

tabs 56:22

tacked 269:17

tailor 11:8 57:1

taking 51:9 115:18

174:22 258:16

276:20

talk 15:20 16:6,13

17:13 27:2 38:20

49:22 57:11

96:12 100:3,5,6

102:2

129:10,14,16,18

130:15 167:16

176:15 231:21

268:13 313:3

talked 7:16 11:15

21:7 115:3 226:1

270:20 271:12

308:11

talking 8:12 18:3

30:5 40:17 48:1

55:15 56:17

62:17 67:18

74:10 77:17 82:6

90:5 97:2 101:18

102:12 114:14

123:7,20 127:11

139:17,18 147:4

150:18

158:11,20 160:3

162:2 168:18

169:13 171:7,21

176:4 185:20

195:6 196:15

202:11,18

204:13 206:2,16

209:9 215:12

224:17 225:4,6

232:19 240:2

244:14 249:16

257:16 259:2

262:6,7 264:12

267:10 270:2

276:19 291:8

297:6,13,18,19

308:10,12

312:13

314:2,9,11

320:12 323:8

324:13 328:4,6,7

talks 14:14 267:7

tank 38:17 184:18

185:11 190:14

191:3 193:22

194:1,11,12

tanks 180:17

191:21 208:1

238:5

tank-type 190:21

193:15,21

TAPs 73:10

task 98:1

Tech 3:3

technical 153:14

167:22

technically 209:11

technique 99:2

technologies 24:22

142:22 172:22

technology 45:5

194:9,19

tee 15:21 17:9 31:4

49:9,10

teed 30:16

teeth 256:2

temp 240:10

temperature 32:5

37:20 206:7

230:8 238:7

249:4

temperatures 38:6

229:18

230:6,8,11,19

249:4

template 139:16

templates 134:6

139:7

ten 140:22 145:10

188:9 199:13,18

241:2 256:15

289:6

292:7,8,18,19

300:17,18,20,22

301:18

302:11,14 310:6

313:4 314:1

315:16,21

tend 159:7,8

ten-minute 228:8

tens 305:7
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ten's 301:17

term 39:18

40:2,5,7,10 53:7

66:20 135:4

140:1 166:9

169:20 180:14

196:1 308:13

terminology 76:14

253:8 297:1

terms 14:13,21

15:17 16:20

20:20 30:5,6,11

36:12,22 37:2,3

47:9 48:14,15

49:3 52:16

59:9,14 72:1,2

77:14 84:17

92:7,21 158:19

162:6 165:16

173:11 174:2

182:13 185:6,7

201:16 202:10

229:18 281:5,18

test 9:15 10:21

28:8 33:8,21

38:9 44:1,19

46:4 48:16,17

49:14 50:15 51:1

52:16,22

53:10,11 54:11

55:2 56:8 64:6

65:10,14,18 66:5

67:2 70:19 72:2

73:4 74:11 75:9

76:1,2,7,13,16

77:17,18,21

78:10 79:19

81:17 82:20 84:8

85:2

86:3,6,11,12,22

89:5,6,21 92:8

93:9,13,14

94:5,7,9,15

95:4,6,15,18,19

97:20 101:3,22

102:15 108:5,10

109:17,22

110:1,2,9,19

111:17 112:2,4

116:22 117:2,7

119:11

125:5,8,10

126:17,22

132:9,12 133:16

135:20,21

137:1,6 144:21

151:2 155:10

162:7 163:20

164:12 166:4,17

169:6 171:22

172:1,3,4 178:11

182:20 183:4,9

184:5 185:22

187:1,8,17

189:2,12

192:8,9,11,12,16

,22 193:6 194:16

195:21 197:2

198:3,11,15

199:2 200:6,14

202:2,21 205:2

208:12,20 209:9

210:18,19

211:1,5,10,11,17

,22 212:19,22

214:12,17,18

215:17,18

216:2,4,10,13,15

,20,22 218:1,10

219:2,3 220:3,22

221:8,9,10 222:6

223:4,6 224:1,3

225:1 226:4,12

230:8 233:20

235:22 236:7

240:12,19

241:16

242:14,17

244:17 246:18

253:18 255:2,15

257:18 258:9

260:4 261:13

262:1,3

264:20,22

265:11,21

266:3,19,21

267:8,16,18

268:4,8,10,11

269:1,2,3,6

270:2,7,14 271:3

274:12

275:1,13,15

276:11,15,22

278:17 279:3

280:8 281:12,13

285:12

287:12,22 288:2

289:9,14 290:5,9

291:14 292:6,16

293:7 294:15

295:6,7,8,12

296:2,18

297:9,22

298:2,5,10

302:16

303:2,6,8,9,10,1

1,14,16 304:4,10

306:9,12,14,20

310:5,9

311:12,13,14,15,

21 314:13,18,20

315:5,11 316:20

317:3,10,12,13,2

0 318:1,15,18

319:7,17,19,21

321:9,11,15

322:14,17

323:18 325:18

326:1 327:2,3,5

328:8

test-based 101:18

tested 19:13,18

20:2 28:7,8

33:10 36:22

48:17 49:4,13

53:6 54:15 55:1

59:22 71:18 72:7

74:8 75:16 86:5

119:14 124:9

129:17 131:3,4

135:4 136:17

138:13 154:8

160:6,9,20

164:1,20 168:13

169:2,21

239:18,20

269:11,15,21,22

277:20,21 289:5

295:1 302:9

304:17 307:3

testing

9:2,10,11,13

17:3 18:20,22

20:3,12,17 22:13

24:11,12 25:19

26:3 33:7 34:18

37:4 39:21 41:12

44:5 50:13

55:7,21 56:5,12

71:3,4,13 74:11

76:17 77:14

78:17,18

79:4,5,7,8,15,22

80:5,8,12,18

81:6 82:12,16

83:18 84:20

85:1,4,11,16

87:8,14 92:22

93:8,10,19 94:11

95:12 98:11

106:5,15 107:21

108:16,18

114:18 116:5

117:10,12

125:13,15,17

128:13 139:6
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147:8 161:16

162:3 167:9

168:6 170:19

191:11,12

194:19

197:3,7,10,12,16

208:2 209:5

218:16 220:20

221:5 226:2,3

230:4 233:2,4

234:6,12,22

235:3 236:11

237:8,11

239:7,8,9 240:19

244:11 247:20

248:6 255:1,15

256:9,13

264:12,17,18

265:18 266:14

268:18,19

270:11 273:12

274:8,9,10

275:3,6 276:1,3

277:17,19

278:2,11 279:11

286:13 289:13

290:18 292:4

294:3,11 295:13

303:19,20

304:8,9,18

307:15 310:5

312:4,6

316:3,10,12

317:2

319:8,11,14

320:20,21 323:2

324:21 325:21

328:4

tests 26:5 34:22

35:3 49:12,13

50:1 56:18 57:2

58:6,16 67:7,11

76:16 77:22

78:4,14 81:21

84:19 85:21,22

86:14 87:2 91:2

97:19 99:11

100:8,14,15

106:17,22

109:21 124:14

126:11 127:22

132:8 137:22

150:18,21

155:14,15 163:8

165:15 184:13

187:12,14

188:3,10,15

189:16,18

193:9,14 194:21

195:4,12,15

196:13,14

208:15 209:13

211:6 214:19

217:1 218:2

220:8 224:16

233:12

234:10,15,16

235:18

242:18,19 243:1

246:6 249:20

252:8,14 253:13

254:2,7

256:11,22

260:3,6 261:5

262:18 263:3

264:14

266:7,8,16 284:7

296:1 297:7,8,10

305:4,7,13

307:17,18

308:12 310:2

315:2,11,13

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text 40:17

Thank 24:5 32:9

39:16 50:9 52:3

133:6 134:18

144:14 146:8

155:6,13 157:18

171:5 204:17

212:12 225:12

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278:4

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253:5

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18:8 68:8 82:13

83:19 84:2,6

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158:14

160:11,18 178:8

289:2,4 307:14

308:1,14,17

309:22 315:15

319:1,8,12

320:3,5 322:11

325:18 326:1,4,6

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177:22

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20:5,10 24:2

27:6 38:12

40:10,16 41:21

42:9,22

43:3,11,18 44:5

45:20 51:11

55:18 60:7 62:4

63:7,19,20 64:9

73:12 74:3

78:5,8,22

79:1,11 81:14

90:19 96:9 97:2

101:5,6 107:2

108:11

109:2,4,8,15,16

110:13 111:11

112:9 113:19,21

118:22 119:16

120:1,6,10,12

121:11 125:22

127:17

128:18,20

131:15,21 133:7

134:18

135:12,18

138:17 139:8

141:6 142:2

148:2,21,22

149:19 150:20

151:19 152:6,16

154:2 155:5,6

156:22 158:21

160:7,16 162:1,3

164:17 167:6,8

168:9 169:17

174:17,18

178:2,5,12,13

179:11,19,21

180:2 182:3,13

183:5 185:13,21

189:8 190:15,20

191:21,22 192:7

193:18,19 195:6

198:12,19

199:6,9,15,17,20

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200:1,16,19,20,2

1 204:1,7 206:18

207:15 208:9

212:2 216:10

217:8 220:9

221:4 222:13,17

224:18 230:19

233:13 235:1

237:5 240:4,21

241:12

243:13,18,22

244:13 245:2,5

252:10 253:9,15

256:14 257:7,15

259:1 261:17

262:4,20,22

263:5,10

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292:12 293:18

294:6,18 296:3

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303:3,20 304:9

306:5

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309:18

310:11,16

311:19 312:18

313:9 314:7,19

315:8,16 317:1,7

318:13,14

319:5,12 320:15

322:22 323:9

324:3,6 325:18

327:9,14,17

328:16

theirs 99:6

theme 56:4

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309:7

theoretical 33:9

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theory 106:21

245:15

thereafter 330:5

therefore 72:17

78:3 81:13 107:9

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thereof 68:16

there's 72:1

108:14 112:10

118:13,14

119:3,4,7,11

124:11,22

131:1,7,18

138:12 139:9,12

143:21 146:22

152:8 155:19

159:21,22 162:9

163:7 167:4,19

174:14 175:9,18

176:19 188:15

189:4 190:6,16

191:11 193:13

195:11 196:6

207:16 219:7

230:5

231:6,12,16

233:5 237:21

238:1 245:6

250:11 252:3

257:7

264:1,16,19

268:18 272:18

274:8 275:5

281:2,11 282:22

283:8 286:3

289:2 291:18

303:22 305:8,21

311:3,17

312:3,21 316:19

318:21 319:18

320:7,8,9 326:1

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187:2

192:9,12,19

193:5 211:10,12

215:17,18,19

216:13,19

258:13

they'd 90:15

232:14 242:4

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256:18

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119:2 125:21

132:15

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156:14,15

176:11 181:1

185:17 196:2

202:13 207:19

215:21 216:8

219:22 229:17

231:11

232:10,15

247:18 255:16

259:21 260:18

268:7 274:22

282:2,11 284:1

287:17 318:13

327:18,19

they've 164:2

322:20 326:10

third 9:6 19:20

20:16 51:18

80:21

105:15,16,17,18

106:5 119:11,13

120:9,10,12

147:2 222:15

278:10 319:21

third-party 107:21

108:1 239:7,8

277:19 278:20

279:4 317:3

318:14,20

320:22

thirteen 145:10

thirty

119:17,20,22

231:8 309:20

Thirty-eight 231:7

Thomas 1:15

330:2,14

thoughts 7:4 16:3

32:11 45:14 68:1

145:22 207:21

261:16

thousands 136:16

thread 176:17

190:16

three-phase 14:18

41:6 115:10

threshold 76:21

77:9,11 97:5

106:3 113:14

118:3 214:12,14

threw 26:9 51:8

throw 22:10 26:6

51:21 82:14 88:4

120:15 268:11

throwing 32:22

178:19 260:2

thrown 206:6

tie 237:6 286:14

tied 296:19

tier 207:9,11

tiers 207:8

tight 309:11

tighter 305:1

Timothy 2:9

today 11:16 18:9

20:19 23:21 27:6

28:11 30:5 41:14

79:12 129:3

237:16 273:7

276:6

tolerance 9:14

23:22 26:8 49:14

74:21 75:1,3
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113:15 162:6

273:15

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289:16,17 290:4

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292:4,7 294:3,11

296:16,18

297:13 307:21

311:11,21

312:22

315:12,16

316:1,9 322:21

323:5

324:7,13,20

tolerances 26:10

128:10

273:9,12,21

284:15 285:10

287:20 297:5

316:5 318:4

319:2,4,6

Tom 3:14 5:20

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273:6 327:15

328:19

ton 41:5 244:17

289:6

tonnages 103:2

290:13

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148:9,18

Tony 5:5

tool 5:21 6:4 39:6

tools 109:7

top 94:12

148:11,12,13,14

191:3 201:10

204:6 324:2

topic 48:14 83:11

125:20 178:12

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total 133:13

135:10 136:2

137:22 139:12

140:12 183:8

195:15 202:9

252:5 254:7

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totally 35:13 79:10

88:22 89:19,22

107:20

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194:22 268:11

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328:16

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tough 91:21

toward 316:6

towards 9:7

212:15

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track 13:18 64:3

tradeoffs 20:20

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traditionally

185:22

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Trane 3:10 45:15

53:22 54:4 58:10

72:11 102:22

106:11 135:15

143:14 153:2

154:7 168:7

173:8 175:5

306:13 321:5

transcript 13:15

330:6 331:4,6

transcription

331:1,7

Transcriptionist

331:11

transfer 217:6

transformers

64:21 73:7,8

313:3

transition 61:13

translate 28:3

170:15

translation 24:5

transparent

229:18 253:1

254:9

transportation

227:9

Traulsen 2:19

21:5 81:10

115:19 122:22

126:6 147:3

152:3 236:15

257:11 325:11

Trauslen 325:2

traveling 193:22

treatment 10:15

tremendous

249:18

trials 23:11

tricky 260:17

tried 15:17 48:19

49:10 99:1

254:4,5 314:17

tries 213:4

trigger 20:5

266:18,22

trouble 90:21

267:6 307:7,8,9

true 3:9 18:15

47:12 84:2 89:2

116:11 118:22

119:16 175:12

199:17 207:15

226:6 251:6

253:17 254:12

278:5,6 285:5

330:6 331:7

Truskoski 5:19

Truskowski

322:12

try 25:2 28:3 37:9

40:6 82:1 257:4

271:2 293:12

trying 12:15

34:11,12 43:19

44:11 54:2 55:18

56:14 61:17

90:17 103:14

124:21 131:21

143:14 158:17

161:1 170:14

172:18 185:13

189:17 190:10

197:5 200:10

212:3 233:10

234:14 243:16

244:16,22 245:2

251:3 253:7

270:17 271:4,10

289:20 296:21

299:12 305:11

Ts 253:2

tub 222:4

tube 176:9,10

185:2 187:6,7

190:14 194:13

196:18

tubes 184:18

185:3,9,12
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tube-type 181:19

190:20 191:2

193:15,16

202:12,14

Tuesday 1:10

130:2

turn 23:17 87:5

99:12,17 116:3

122:19 132:8

306:16

turned 52:18 85:3

98:12,20

tweak 18:18 73:21

twelve 140:22

145:10

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119:17,18,20,22

316:13

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187:18 199:3

200:6 247:19

266:10

269:21,22

two-sided 286:17

293:20 295:12

304:19 308:21

325:8

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two-ton 66:17

tying 296:20

298:15

type 16:14

23:18,22 31:12

33:15 36:17 39:6

48:16 62:2 68:15

76:22 98:7 121:4

129:17 133:14

150:17 155:21

170:6 177:10

180:15 181:7

183:19 186:11

187:10 189:19

190:14 197:3

215:14 217:13

231:19 232:8

251:10 257:19

263:21 303:19

typed 48:10 264:2

331:4

types 14:20 28:6

30:5 31:3

49:4,6,13 50:14

55:11 59:9 70:6

138:13,14

146:3,12 165:7

169:10 183:19

187:6 196:18

213:5 229:15

236:21 245:10

312:4

typewriting 330:5

typical 15:4

typically 35:1 41:8

46:17 122:3,6

216:19

typing 144:21

201:8 298:18

U

U.S 2:10

Uh-huh 32:10

101:1 124:1

134:17 142:19

188:1 196:8

207:10

UL 3:17 79:13

93:20 166:14

279:9

ultimate 44:4

ultimately 52:18

64:11 75:10

78:21 162:5

164:7 324:20

uncertainty 40:6

82:16,18 178:10

292:4 293:10

310:1,4,8,12

311:7 317:17

318:22

uncover 102:3

underlying 36:9

38:12 126:22

131:9,18 175:18

underneath 44:20

184:19 205:13

underpinning

44:13

undershoot 90:18

understand 13:3

25:16 37:19

41:19 55:18

71:13 75:7

82:4,15 85:6,19

96:3 100:20

109:11 125:12

128:4 137:11

139:17 140:9

176:6 187:5

192:14 194:18

224:7 239:21

247:14 248:4

250:16 255:6

263:5 268:15

276:13

286:12,16

288:17 289:18

303:5 308:4,7

313:15

understanding

20:6 29:2 139:1

200:21 244:1

259:14 267:6

287:15,19 313:9

understands

170:14

understood 53:14

136:1 199:10

226:18 311:10

unfired 180:16

208:1

unfortunately

237:18 284:20

unique 23:20

35:16 42:5 60:14

89:8 198:17

311:12

unit 18:22 39:22

46:4 55:12,13

64:3,5 65:14

66:17 67:1 71:8

97:21 98:16

104:10

109:21,22 110:6

112:18 125:5,16

135:21 137:1,6

155:3,6 159:19

162:16

172:19,20

186:18 189:3

191:4 206:1

208:16 210:17

214:16,17

215:16

216:14,15,22

232:7 243:11

251:9 255:15

268:13 277:20

285:11 289:6

291:14 292:15

306:17,18

323:16,17

unitary 14:19

55:22 59:10

100:21 310:2,3
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United 2:12 3:15

units 28:7

33:12,19 48:16

49:4 50:14,15

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71:7 87:2 93:18

98:16 106:22

108:17 112:18

117:17,19 120:4

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146:2 147:13

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155:3 162:15

163:20 171:17

206:3 216:1,2

219:18 221:7

224:3 230:7

236:3,13 239:10

243:6 265:13

276:22 294:20

295:1 300:13

universal 198:6

unless 7:8 15:13

42:11 59:11

117:17 170:3

237:11 264:16

277:22 324:19

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unnecessary

216:12,14

unsophisticated

309:6

unworkable 26:20

up-and-running

113:10

updating 144:10

upon 111:6 164:16

165:21 175:4,6

207:13 237:17

283:20 284:1

upper 39:21

198:16 204:1

urging 117:16

usage 63:10

useful 68:6 89:13

225:5

usually 219:2

UTC 4:4

utilities 92:13

172:15 175:4

239:15

utility 246:4

V

valid 94:16 110:19

117:5 131:14,19

162:6 203:22

204:7 226:12

236:10 243:18

263:6 265:4

266:19 270:14

276:3 277:11

285:11,17

286:21 291:20

296:7,16

299:6,11,12

303:16 318:13

320:2,8,9,10,19

327:1,21

validate 33:22

43:14,15 57:3

78:1,3,15 96:4

116:22 119:6

137:22 138:1,7

151:17 152:11

154:20 161:2

165:15 202:4

204:2,10 216:17

217:12 232:9

240:3,4 243:3

245:1,4 249:20

263:12 271:9,11

272:12 307:16

308:13,16

319:14 323:21

328:7,15

validated 83:5

119:13 199:19

277:19 324:17

validates 98:19

validating 24:12

153:10

154:10,16

159:20 160:1

288:19,21

307:22 308:1

validation 18:21

21:7,15,19 33:10

34:21 35:6

50:6,19,20 51:9

52:1 55:5,6,8

56:5,7 78:11

82:7 87:8 96:6

98:11 99:12

102:3 108:16,18

109:19,20

121:10 134:22

151:20 152:9

153:21

159:11,14

165:6,10

181:2,11 186:13

197:4 224:16

232:12 268:4

298:18

321:21,22

322:6,10

324:14,21

325:17

validity 18:19 19:2

24:1 111:13

113:3 117:16

138:6 239:16

240:16 254:20

275:10 291:6

valuable 18:13

value 208:3 289:5

296:2

values 28:8,9

48:17,18 310:5

variability 305:2

310:18

variable 110:3

variables 38:18

110:7 317:21

variance 112:18

113:5 292:17

311:1

variation 75:21

108:10 110:5

112:21,22

313:19 318:15

323:19

variations 11:1

108:3 243:17

244:8

variety 16:17 17:8

20:9 30:10 91:20

100:1 229:21

231:21

various 25:4 62:6

68:10 70:3

133:22

159:12,20 173:3

233:11

vary 130:19 234:7

vast 202:14,16

vastly 241:7

VCI 252:15,18

VCIP 96:7

VCT 252:18

vehicle 23:15

vendor 208:12
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vendors

72:18,19,21

326:18

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verification 9:4

22:9 23:15 50:20

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74:14,16 81:20

82:2 96:13 97:1

106:22 115:21

116:2,8 117:10

120:19

125:5,6,13,15

126:2,3,7 128:14

132:7 141:6

152:1,5,8,12,16

177:5 197:15

239:7,8

292:14,16

303:12 310:14

verified 79:17,20

95:12 96:22

107:21 108:1

116:16

verify 26:5 40:8

67:8 80:21 92:13

93:21 94:9

111:15,16

127:12 208:13

221:10,11 235:6

249:16 254:22

255:3

verifying 51:3

254:21

vernacular 59:15

version 7:7

versions 107:6,7

190:13

versus 74:19 77:6

113:3 180:15

183:19 191:5

195:4 229:19

235:10,11,12

240:11 248:14

250:3 251:21

258:14 280:5,12

286:2,13,16

289:5 292:6

vertical 104:10

174:4 230:21,22

235:11 241:9

250:13 251:7,21

252:7,16,17,22

253:1 254:9,10

vessel 218:4

vetting 281:17

via 234:12

VICP

83:5,7,13,14,20

96:8 106:12

120:16 121:9,12

124:9,10,13

130:20

view 181:2,11,12

224:15

viewpoint 133:9

views 133:2,5

Viktor 2:8

Vince 4:13 115:1

141:11

violation 86:13,19

violators 84:5

visibility 308:22

VOC 252:15

voice 258:12

voltage 69:9

70:8,10

voltages 70:7 73:8

volume 98:18

133:12 136:8

154:7 173:11

177:2 185:20

191:5,9 216:2

245:5

volumes 240:6

244:15

voluntary 9:18

10:6 83:3 127:3

175:8

vote 147:7 170:3

272:6 283:7,8,11

284:4,19

voted 151:3

votes 282:6,15

283:1,2

voting 118:17

274:4

VRF 12:18 101:9

105:2,3 144:2

147:16 160:20

179:16

VRFs 14:20

104:13 105:5

137:9 140:20

145:9,12 150:14

165:13 179:5

vulnerable 20:2

W

Wahid 4:11

wait 17:5 21:13

98:14 114:12

123:16 305:18

waiting 21:10

244:18

walk 15:15,22

wall 239:6

Walsh 5:20

washer 63:15

Washington 1:9

5:21 6:4

wasn't 34:11 80:4

106:12 174:9

258:2,4 264:8,11

306:6,8

watch 99:16

watching 88:6

324:15

water 5:13

14:21,22 30:20

31:17,18

32:3,4,7,15,18

38:3,17 45:17

47:7 60:10 62:21

68:21 95:3

104:15 105:2

120:5 138:11

140:21 143:11

144:4,5,11 145:9

146:1,13 147:18

148:6,15,17

149:5 156:20

163:2 165:5,9

176:10

179:17,19

180:12,16,20,21

181:3,4,6,8,9,19,

21 182:2,5,17

183:3,7,17,20,21

184:2,3,17

185:1,2,9,16

186:20 187:6

190:1,2,6,7,20,2

1 191:2,6,7,8

193:2,3,17,18,20

194:1,4,5,11,12,

13 195:5 196:18

197:18,20
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202:12,15,16,17

203:2,3

205:11,13,14,17

206:12

207:4,8,20 208:1

209:14

210:4,10,11,21

211:12

212:5,17,18,20,2

2 213:13

215:5,8,11,12

218:3,4,10,15,17

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220:2,5,7,17

221:8,22

222:14,16

223:3,9,12

224:4,10 228:5

238:5 311:15

313:6,10

314:2,12 316:19

322:13 323:5,12

water/steam

223:15

water-cooled

104:6,7,17 137:8

140:14 142:7

143:17,20 145:7

149:8 156:13

162:18 163:1

165:14,18 179:7

water's 193:21

water-tube 204:21

Wayne 213:8

ways 20:9 23:2

72:5 194:3

238:10 242:13

250:6 252:3

324:18

web 25:9

Weber 5:22

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