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 DEPARTMENT OF ENERGY

 RESIDENTIAL WATER HEATER

 T.P. MEETING

 Friday, December 6, 2013

 9:00 a.m.

 Department of energy

 1000 Independence Avenue SW

 Forrestal Building

 Washington, DC 20585
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1 C O N T E N T S

2

3 SPEAKER/AGENDA ITEM: PAGE

4 Doug Brookman, Moderator/Welcome 4

5 Ashley Armstrong/Opening Comments 4

6 Introductions 5

7 Agenda Review 8

8 Opening Remarks 11

9 Regulatory History and Rulemaking Overview 13

10 Scope of Coverage 15

11 Test Setup 69

12 Test Conditions 82

13 Draw Patterns 105

14 Rated Values 129

15 (Lunch Break) 170

16 Energy Consumption/Conversion of

17 Existing Ratings 171

18 Closing Remarks 199

19

20

21

22
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Please take your seats.

3 We got to begin. You all set? Jack, Neal, yeah.

4 Okay. Good morning, everyone, and

5 welcome. This is the Test Procedure Notice of

6 Proposed Rulemaking Meeting for Residential and

7 Certain Commercial Water Heaters here at the

8 Department of Energy in Washington, DC. Today is

9 December 6, 2013. My name is Doug Brookman from

10 Public Solutions in Baltimore. Glad to see you

11 this morning. We're going to start off with

12 welcoming remarks from Ashley Armstrong.

13 MS. ARMSTRONG: I'd just like to welcome

14 everyone. Thank you for coming to DC in the

15 wonderful weather today, although it is a little

16 warmer for you.

17 We encourage you to speak up. I know

18 many of you in the room aren't too shy nor am I.

19 So we look forward to getting your comments and we

20 -- I hope to end before 4 today, get everyone out

21 of here before we get some pretty ugly weather

22 later. But, yeah, thank you for coming.
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1 MR. BROOKMAN: We're going to start with

2 introductions as we always do. I'll start to my

3 immediate left. You can get used to turning these

4 microphones both on and off. When it's on, that

5 green light is illuminated. Name and

6 organizational affiliation.

7 MR. BRUNDAGE: Don Brundage, Southern

8 Company.

9 MR. SANONIK: Frank Stanonik, Air

10 Conditioning Heating and Refrigeration Institute.

11 MR. ADAMS: Charlie Adams, AOC Smith

12 Corporation.

13 MR. KUSTERER: George Kusterer, Bock

14 Water Heaters, semi retired.

15 MR. BOROS: Joe Boros, Remanufacturing

16 Company.

17 MR. STARR: Louis Starr, Northwest

18 Energy Efficiency Alliance.

19 MR. ROSENSTOCK: Steve Rosenstock,

20 Edison Electric Institute.

21 MR. STEVENS: Philip Stevens, HTP.

22 MY. FRYER: Anthony Fryer, the Appliance
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1 Standards Awareness Project.

2 MR. SACHS: Harvey Sachs, American

3 Council for an Energy Efficient Economy.

4 MR. KLEIN: Gary Klein, Affiliated

5 International Management.

6 MR. HARMAN: Tom Harman, consultant and

7 prophet, University of Houston, Clear Lake.

8 MR. VILLARROEL: David Villarroel,

9 Natural Resources, Canada.

10 MR. WECKMAN: Tom Weckman, Northwest

11 Power and Conversation Council.

12 MR. STAS: Eric Stas, DOE General

13 Counsel's Office.

14 MS. ARMSRONG: Ashley Armstrong, DOE.

15 MR. CYMBALSKY: John Cymbalsky, DOE

16 MR. DARLINGTON: Adam Darlington,

17 (inaudible.)

18 MR. HEALY: Bill Healy, National

19 Institute of Standards in Technology.

20 MR. ROY: Robin Roy, National Resources

21 Defense Council.

22 MR. YILMAZ: Iykut Yilmaz, Air
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1 Conditioning, Heating and Refrigeration Institute.

2 MR. MARCIL: Henry Marcil, (inaudible).

3 MR. LEKOV: Alex Lekov, (inaudible).

4 MS. SHEPARD: Amy Shepard, Air

5 Conditioning, Heating and Refrigeration Institute.

6 MR. BROOKMAN: Thanks to all of you.

7 Again, welcome. Glad to see you h ere this

8 morning. I hope you received packet of

9 information as you checked in. I hope you gave

10 your business card to Brenda or whoever checked

11 you in. If you haven't given her a business card,

12 please do so. The Department likes to make a

13 Xerox copy of the attendees listed here. All of

14 you --

15 UNIDENTIFIED MALE: That mic ain't

16 working.

17 MR. BROOKMAN: This isn't working?

18 UNIDENTIFIED MALE: It's shattering

19 badly.

20 MR. ROSENSTOCK: Doug, I hate to say

21 this again, there's still that feedback from these

22 speakers over here.
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1 MR. BROOKMAN: I think it's we're just

2 stuck with it, Steve. I think that's --

3 (Off record comments.)

4 MR. BROOKMAN: I can see we're going to

5 have trouble with this meeting already.

6 FEMALE SPEAKER: Do you expect anything

7 different?

8 MR. BROOKMAN: Nothing, nothing

9 different.

10 MALE SPEAKER: Let's just get to the

11 point --

12 MR. BROOKMAN: All of you received a

13 copy of the packet. I'm going to do a very brief

14 agenda review. Immediately following this agenda

15 review is an opportunity for anyone that wants to

16 to make an opening remark, brief summary comments

17 about issues that matter to you.

18 Following that, a description of

19 regulatory history and rulemaking overview, then

20 moving on to scope. We'll take a break mid21 morning round about. It says here 11:00. We'll

22 see how we do, 10:25, 11 or so. And when we
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1 return from break, test setup, then test

2 conditions. We'll take lunch around about 12:30.

3 Returning from lunch, draw patterns, a mid4 afternoon break and then rated values for storage

5 volume, annual energy consumption and conversation

6 of existing ratings. At the end of the day,

7 another opportunity for you to make closing

8 remarks, issues that have not been fully covered.

9 So that's the agenda as written.

10 Questions and comments? As Ashley said, we'll

11 move as effectively and efficiently as we can

12 throughout the day and see where we end up, see if

13 we can get of here before 4:00.

14 I'd ask for your consideration. Please

15 speak one at a time. Please say your name for the

16 record each time you speak. There will be a

17 complete transcript of this meeting made

18 available. Please keep the focus here. Turn your

19 cell phones on silent mode, limit sidebar

20 conversations. There is a lot to cover today.

21 I've noticed in some of the last few meetings that

22 we've been pressed for time at the end of the day,
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1 so I'm going to be trying especially hard to

2 enforce sort of a germaneness rule. We're not

3 going to wander too far off topic today, with your

4 indulgence. So if you could be concise and share

5 the airtime, that's what that rule's all about.

6 And queuing and follow-on, wish to

7 encourage individuals to both follow on from one

8 another. Sometimes the back and forth between

9 individuals is very helpful for the Department as

10 it considers the content in this meeting.

11 I think that is the bulk of it. And

12 most of you have been here before. Restrooms are

13 at both ends of the hall. I've been asked to talk

14 about evacuation rules. We've had a fire alarm or

15 two in the last week. In the event we are asked

16 to evacuate, if there's a fire alarm or anything,

17 we go that-away to the stairs, down eight floors

18 to the first floor and then exit there. Okay?

19 Just so you know. You may recall after 911, we

20 did this a lot.

21 So that's, I believe, the overview.

22 Those of you listening via the web, we welcome
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1 you. The Department of Energy is trying very hard

2 to make these meetings accessible to those via the

3 web. We've had mixed success with individuals

4 being able to speak and be heard during the

5 meeting itself, but if you would keep your

6 telephones on mute and if you raise your hand,

7 we'll try and see if the software works today and

8 we can get your questions or comments inserted

9 into the meeting here in the Forrestal Building.

10 And if you can't speak, then our web master, Jack,

11 will write up your question and we'll insert it

12 into the content here. And I think that is the

13 bulk of it. Do you want me to do the purpose of

14 the public meeting?

15 MS. ARMSTRONG: Let's do opening

16 remarks.

17 MR. BROOKMAN: Let's do opening remarks.

18 Anybody that wishes to make opening statements,

19 key issues from your perspective. Harvey Sachs.

20 MR. SACHS: Harvey Sachs, ACEEE. It's

21 often remarked that the optimist looks at the half

22 full glass and is pleased. The pessimist looks at
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1 the half empty glass and is displeased. The

2 Engineer wonders how come marketing keeps

3 insisting on a glass that's twice as big as they

4 need. In that context, this meeting is a

5 culmination in a long process, the first really

6 serious revision since EF was initiated decades

7 ago, and I just want to complement everyone

8 involved from HRI, ***10:30:04(Ashreeve), the

9 Department, the contractors. I think we've gotten

10 90 percent. I think we're going to have a lot of

11 discussion about details of draw patterns and test

12 conditions and things like that.

13 But I personally just really gratified

14 at how much progress has been made in moving

15 toward realistic draw patterns and classifications

16 that will help consumers chose wisely.

17 MR. BROOKMAN: Thank you. Other

18 comments here at the outset? No additional

19 comments at this point?

20 (No response)

21 MR. BROOKMAN: Okay. We're going to

22 plunge then straight into the content. All of you
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1 received a packet. As you are familiar, we're

2 going to be following the content in the slides

3 and also be responding carefully and completely to

4 these issue boxes. Ashley Armstrong.

5 MS. ARMSTRONG: Yes. I am just going to

6 point out one thing before we get started.

7 Throughout the presentation, we have these little

8 yellow things. Many of you are aware that they're

9 issues DOE specifically seeks comment. Obviously,

10 you're welcome to comment on anything and

11 everything as part of the proposed rulemaking and

12 during the process. Doug will queue up multiple

13 people that want to speak, but the issues in the

14 yellow boxes, we specifically are asking for

15 feedback on.

16 Just a reminder: I'm sure you all are

17 aware but our deadline for submitting written

18 comments is January 21st of next year. Let the

19 fun begin.

20 So just to start out with a little bit

21 of the history. This will set the stage from some

22 of our scope discussions. ACEEE's amended --
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1 established the original program and gave the

2 Department the authority for consumer products

3 which include the residential water heaters.

4 Subsequent amendments gave the department

5 authority to cover commercial equipment which

6 include commercial water heaters, and it directs

7 the Department generally to establish test

8 procedures in conjunction with standards.

9 So one of the amendments in 2007, the

10 Emergency Independence and Security Act of 2007,

11 directed DOE to, if necessary, establish -- amend

12 the existing test procedures to incorporate

13 standby and off mode. It also required DOE to

14 periodically review all the test procedures at

15 least once every seven years to see if possible

16 amendments are warranted.

17 Following that, in December, the

18 American Energy Manufacturing and Technical

19 Corrections Act required DOE to establish a

20 uniform efficiency descriptor and accompanying

21 test methods for covered residential water heaters

22 and commercial water-heating equipment.
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1 So this is some of the history of what

2 DOE has done. As Harvey alluded to earlier, the

3 current test procedures for water heaters were

4 established in 1998. They are found in Appendix

5 E. That's for residential water heaters.

6 In May 2012, DOE issued a

7 ***10:33:04(funnel) rule establishing test

8 procedures for commercial water heaters. They are

9 found in 431.106, and we've subsequently issued to

10 RFI's. The first one was generally just about the

11 residential water heater test procedure as a whole

12 and what issues the Department should consider

13 when amendments to the current test procedure.

14 And the second one was specifically on the AEMTCA

15 Amendments which were regarding uniform

16 descriptor.

17 So just quick steps in the rulemaking

18 process today is the public meeting for the

19 proposal. We've put out a proposal. We hope to

20 get a lot of feedback at this meeting and in

21 written comments. We will consider all the

22 written comments and then we will go to a final
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1 rule. We expect to issue the final rule early in

2 2014.

3 So this is a summary of what we have

4 proposed to do. We have modified some of the

5 preparation for testing. We have modified the

6 water deliver temperature. We've modified draw

7 patterns. We've included requirements for certain

8 types of ratings including storage volume and hour

9 reading. We've defined a light commercial type of

10 characterization and we've slightly modified the

11 annual energy calculation which is used on the FTC

12 label. We'll go into each of these in a little

13 more detail throughout the day.

14 So the first issue we're going to talk

15 about is scope of coverage. The scope of coverage

16 of the existing test methods for residential water

17 heaters is narrower that DOE's existing authority

18 under EPCA. The proposed method would modify the

19 scope to eliminate those coverage gaps. One of

20 those examples is 2- to 20-gallon water heaters

21 would now be tested under the DOE test procedure.

22 The proposed changes would not expand the current
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1 scope of the energy conservation standards, so

2 even though there would be a test procedure, it

3 would not automatically require that those

4 products then become subject to the current

5 standard. We would have to go through our rules

6 subsequently to do that and we've made

7 clarifications to the standards section to make

8 that clear, proposed clarifications.

9 So as I noted, in AEMTCA amended the

10 statute to require DOE to develop a uniform

11 efficiency descriptor. It required that we do

12 three things. It includes all covered residential

13 and commercial water heaters and it applies --

14 it's supposed to apply to the maximum extent

15 practical to all water heating technologies in use

16 and future water heating technologies that will be

17 in use. It allows for exclusions for equipment

18 that does not have a residential us, is

19 effectively rating using the thermal efficiency

20 and standby loss descriptors which are the

21 commercial descriptors, and it can clearly be

22 described in the final rule.
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1 So DOE proposes to exclude from the

2 uniform descriptor the following types of

3 equipment: Those are unfired storage tanks, add4 on commercial heat pump water heaters, hot water

5 supply boilers and then commercial water heaters

6 that do not meet DOE's proposed definition of

7 light commercial water heater.

8 So first thing is what is DOE's proposal

9 for light commercial. And this is something that

10 we got a lot of feedback on from the RFIs. So we

11 proposed to add a definition of light commercial

12 in 431.12, and we've gotten some questions in

13 advance of this meeting as to why did DOE propose

14 to add the addition in Part 431. And I do want to

15 make a clarification right out the gate that while

16 AEMTCA Amendments did require DOE to come up with

17 a uniform descriptor and a uniform method to test,

18 it did not modify the definitions established in

19 the statute for what is residential and what is

20 commercial.

21 So light commercial, you know, those

22 definitions for commercial water heaters are still
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1 found in the commercial section and subject to the

2 commercial regulations. It's just that DOE was

3 allowed to define this commercial set of equipment

4 which we're defining as light commercial. It's

5 still going to be found in 431. They're intended

6 for residential use. They can be rated and tested

7 using the uniform descriptor test procedure and

8 method, but they're still subject to the

9 commercial standards and they're still considered

10 commercial equipment under DOE's regulations.

11 Go ahead. I know there's going to be

12 questions on that one, so.

13 MR. BROOKMAN: Gary.

14 MR. KLEIN: Yes.

15 MR. BROOKMAN: Please say your name for

16 the record.

17 MR. KLEIN: Gary Klein. Do you want the

18 name of the business, too, or just the name?

19 Okay, good. So that's at best confusing. Is that

20 the only logical pathway that's allowed given the

21 scope that you believe that DOE has to make

22 changes? I mean would it be possible instead of
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1 that light commercial category just defining a

2 more bright line between all big stuff and all

3 smaller stuff?

4 MS. ARMSTRONG: Right. So I think to

5 answer your question, and Eric can chime in, my

6 legal counsel over there, if I'm wrong or going

7 astray but, you know, DOE has the authority to

8 define this set of products that are commercial

9 under the statute but intended for residential as

10 it may. So defining it light commercial, maybe

11 that's not the right heading. Yes, we can call it

12 something else. We welcome suggestions for that.

13 But what we can't do is actually move

14 those products to 430. They're not consumer

15 products under the statute.

16 MR. KLEIN: Gary Klein again. So the

17 statute defines a list in residential --

18 MS. ARMSTRONG: It does.

19 MR. KLEIN: -- that is a lumpy list. It

20 has the certain sizes. It has certain capacities.

21 MS. ARMSTRONG: Correct. That list was

22 unchanged.
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1 MR. KLEIN: Okay. And you're not

2 allowed to change that under this?

3 MS. ARMSTRONG: Correct.

4 MR. KLEIN: At least that's your

5 understanding of the law?

6 MS. ARMSTRONG: Correct.

7 MR. KLEIN: Okay. I just want to be

8 clear. Thank you.

9 MR. BROOKMAN: Don Brundage.

10 MR. BRUNDAGE: Can you give me a little

11 flavor on why this is necessary and why it didn't

12 work well under the old definitions?

13 MS. ARMSTRONG: What -- I mean to the

14 extent why are we doing this?

15 MR. BRUNDAGE: Yeah.

16 MS. ARMSTRONG: The statute required DOE

17 to.

18 MR. BRUNDAGAE: Okay. You were required

19 to come up with the light commercial water heater?

20 MS. ARMSTRONG: We were required to look

21 at all residential water heaters and all

22 commercial water heaters and identify all those
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1 used in residential applications. And for those,

2 we were required to develop a uniform descriptor

3 and a uniform test method. And what we found was

4 that there are certain water heaters that are

5 currently characterized as commercial water

6 heaters under the statute because of the

7 definitions that are used in residential use. And

8 those are the ones that are subject to this light

9 commercial definition and ultimately the uniform

10 descriptor and test method.

11 MR. BRUNDAGE: Okay. I think I

12 understand now. It wasn't necessarily broken but

13 you're ordered to fix it.

14 MR. BROOKMAN: Steve Rosenstock.

15 MR. ROSENSTOCK: Steve Rosenstock, EEI.

16 I think it might also help in terms of what kind

17 of examples are you talking about, like a central

18 water heater for laundry rooms in a multi-family

19 building? I mean I think it might help to say what

20 kind of units are you kind of talking about, not

21 in the definition but just as examples, blank,

22 this type, this water heater would fall under this
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1 category in this application.

2 MS. ARMSTRONG: Yeah. So, I mean an

3 example would be anything just above the input

4 limits. So as Gary noted, there are pretty strict

5 input limits as to what's covered for residential

6 use. That being said, we know that there are

7 certain types of maybe gas storage water heaters

8 just about the input limit, maybe 80,000 BTUs per

9 hour that gets ***1:41:13, but those aren't

10 classified as residential water heaters under our

11 regs, but now they can be tested and rated with

12 the same test procedure and the same metric if we

13 were to go final with this proposal.

14 MR. ROSENSTOCK: Steve Rosenstock again.

15 I know I'm jumping the gun. Are you assigning a

16 certain draw pattern to those water heaters?

17 MS. ARMSTRONG: We'll get there.

18 MR. ROSENSTOCK: Okay. Thank you.

19 MR. BROOKMAN: Charlie, then Frank.

20 MR. ADAMS: Charlie Adams, A.O. Smith.

21 While we think that it would probably be less

22 confusing if you were able to pull them over into
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1 NICA and just declare them residential, I'll defer

2 to the legal experts that say we can't do that.

3 We do suggest that we do not use the

4 term "light commercial" because that's a term of

5 art that has probably two or three meanings within

6 the industry. Something like residential duty

7 commercial or something different than light

8 commercial would be helpful to distinguish between

9 -- or to reduce the confusion that is going to be

10 introduced by using the same term with yet another

11 meaning.

12 MR. STANONIK: Frank Stanonik. I'm

13 probably going to be redundant here but I guess I

14 want to make sure I've got this clear. So even

15 though AEMTCA directed DOE to test all water

16 heaters the same, you're -- the view is that you

17 do not have any, let's say, latitude to relocate

18 the residential duty, quote, "commercial water

19 heater" into part 430 --

20 MS. ARMSTRONG: Correct.

21 MR. STANONIK: Or to redefine what would

22 be covered by the residential test procedure?
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1 MS. ARMSTRONG: Right. What AEMTCA

2 didn't do is modify the statutory definitions of

3 what is a residential storage water heater.

4 MR. STANONIK: And there's nowhere else

5 in the legislation that gives the Secretary of

6 Energy some latitude to modify things?

7

8 MS. ARMSTRONG: Not of that --

9 MR. BROOKMAN: Eric Stas.

10 MR. STAS: Eric Stas, DOE. All the

11 AEMTCA provisions were limited to the test

12 procedure itself, the test methods, all that. And

13 it explicitly states that it leaves the standards

14 in place and arguably on both sides, the

15 commercial and residential.

16 MS. ARMSTRONG: Correct.

17 MR. BROOKMAN: Abigail Daiken wishes to

18 make a comment. Let's see if the software works.

19 Abigail, unmute your phone and speak clearly.

20 (No response)

21 MR. BROOKMAN: I guess it's not working.

22 Abigail, send your question to the webmaster and
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1 he'll insert it in the conversation. This

2 happened -- in the last few days, it's been in and

3 out, this capability. Frank Stanonik.

4 MR. STANONIK: Frank Stanonik. Just a

5 quick follow-up and actually I think I heard you

6 say this and obviously you were on a roll.

7 MS. ARMSTRONG: I got this one out right

8 out the gate. I knew it was coming, so.

9 MR. STANONIK: I thought I heard you say

10 that there is some DOE plan to amend the standards

11 for the quote, unquote, residential duty product.

12 MS. ARMSTRONG: So right now -- the

13 statute required us to do a lot of things all at

14 once. Right now we are triggered for commercial

15 water heaters as a whole. A subset of those would

16 be light commercial. Obviously, we need to see

17 what the finalization of the test procedure and

18 metric will be to be able to do that standards

19 analysis but yes, we are triggered on a commercial

20 water heather rulemaking, too.

21 MR. BROOKMAN: Charlie, in your written

22 comments, you'll tell the department in detail why
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1 light commercial is not the right term of our --

2 MR. ADAMS: Yes, we will. Thank you.

3 MR. BROOKMAN: Harvey Sachs.

4 MR. SACHS: Harvey Sachs, ACEEE.

5 Ashley, your second sub bullet is not capable of

6 delivering hot water at temperatures of 180

7 Fahrenheit or above. It seems ambiguous to me,

8 could mean is controlled so it won't or the

9 elements just won't do it and that becomes a very

10 weird thing in terms of inlet water temperature

11 and everything else.

12 What is the intent and will that be

13 covered in the final regs?

14 MS. ARMSTRONG: So the intent is as

15 written, that it cannot deliver water heater

16 temperatures above 180. I get your point but that

17 was the intent. To the -- I mean I get it. To

18 the extent you have suggestions or a better way to

19 do that, we got comments previously that we should

20 use the word "designed." We should use other

21 wording as well. We chose to use the word

22 "capable."
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1 MR. SACHS: Are you in the same stream

2 of content?

3 MR. BROOKMAN: Charlie and then to Tom.

4 MR. ADAMS: There is a problem

5 associated with that because any water heater can

6 be made to -- stack is the terminology -- to

7 deliver water above its intended deliver

8 temperature. This would turn -- cause a lot of

9 problems with the stacking test, and I would have

10 to go through the NOPR and find it, but there is

11 actually terminology in the NOPR early on that

12 used the phrase designed to deliver temperature or

13 water in excess of.

14 MS. ARMSTRONG: Yes.

15 MR. ADAMS: And then later in the NOPR

16 is the language "is not capable of delivering."

17 So we strongly support that the proper terminology

18 is "designed to deliver water in excess of 180,"

19 and I believe that language is already in NECA

20 when it's talking -- or in EPCA anyway when it's

21 talking about tankless water heaters.

22 MALE SPEAKER: In the definition of test
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1 procedures?

2 MR. ADAMS: Yes. So the right wording

3 is already in the law and in the NOPR somewhere.

4 We just need to be consistent and use the right

5 wording throughout.

6 MR. BROOKMAN: Okay. Thank you.

7 MS. ARMSTRONG: Charlie, I'm going to

8 ask you a question. As a manufacturer, how do you

9 convey what the design temperature range is or

10 what the maximum design temperature is?

11 MR. ADAMS: TP. Maximum outload

12 temperature. There's a test for it in the --

13 MS. ARMSTRONG: Isn't that what this

14 says?

15 MR. ADAMS: No. I stand --

16 MR. STANONIK: I'll wait in my queue but

17 --

18 MR. BROOKMAN: Yes. Well, no, follow on

19 right here, right now. Yeah, I'm coming back to

20 tom in just a second.

21 MR. STANONIK: All right. Well, okay,

22 in our comments on RFI, our recommendation was
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1 "designed to deliver water at a thermostatically

2 controlled temperature of 180 or more." That's

3 the key. To answer the question you asked

4 Charlie, the key is that the manufacturer, on some

5 products, does provide a thermostat where, in

6 fact, the user can select a setting that say I

7 want 180 degree water to be regularly provided as

8 the operating point of this water heater. So you

9 actually have the thermostat set to be delivering

10 water at that high temperature. That is a

11 commercial application in a residential product.

12 I'll say I can't envision any manufacturer who has

13 any inkling of understanding the American judicial

14 system who would knowingly send out a residential

15 water heater that had the capability for the

16 consumer to set it at 180. That's asking for more

17 trouble than anybody wants and actually, you know,

18 we have warnings on residential water heaters

19 about the dangers of high temperature water.

20 So the key is that it has that

21 thermostat that actually allows somebody to say I

22 want this thing in its operation to deliver 180
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1 water, not by, let's say, a happenstance of things

2 aligning, all of a sudden see some 180 water.

3 MR. BROOKMAN: Tom, you're next. Thanks

4 for being patient.

5 MR. HARMAN: Tom Harman. Since talking

6 about testing, I guess I'm confused. If you're

7 going to test these water heaters using the same

8 factors, the same descriptors, how does this light

9 commercial and residential fit into that? How

10 does it know that the water heaters in a store

11 versus in my home in terms of the test -- I

12 thought we were here to talk about test

13 procedures?

14 MS. ARMSTRONG: So I think what we do is

15 we propose this definition. We said light

16 commercial.

17 If we end up calling it residential duty

18 as been suggested, whatever we end up calling the

19 subset of the market, it would have to meet these

20 three criteria: You know, we said for

21 requirements that meet the following conditions,

22 right? So it uses single-phase power. It's not
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1 capable of delivering hot water temperatures above

2 180, and it does not bear the code symbol stamp

3 with the AS&E pressure vessel. So if it has one of

4 those, it would kick it out and make it commercial

5 and be tested per the commercial test procedure

6 and the commercial metrics.

7 If it meets those three criteria though,

8 it would automatically fall into the residential

9 definition or the resident -- tested as a

10 residential product and metric. So you would get

11 there first. Then you would move to how its tested

12 which is the next set of the --

13 MR. BROOKMAN: Keep going.

14 MR. HARMAN: Not quite that because for

15 -- if you look at, say, tankless electric, which I

16 know about, there's a limitation of 12 Kw.

17 MR. BROOKMAN: What page is that?

18 MR. HARMAN: This is on page whatever,

19 25.

20 MR. BROOKMAN: That's legislative.

21 MR. HARMAN: That definition is so

22 broad, it fits everything, doesn't it, that's not
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1 a boiler or some special --

2 MS. ARMSTRONG: Right. So that was the

3 intent, right. We have a legislated -- what

4 you're looking at on Slide 25 -- we might as well

5 just skip there -- is the 12 Kw limit is

6 statutory. It's what defines the electric limit

7 for what's a consumer product. But that being

8 said, anything above the 12 Kw input limit is

9 going to fall into this light commercial

10 definition, be tested with the residential metric

11 and test method if it otherwise does not get

12 excluded because of one of these three factors.

13 So there's not upper limit on the input for

14 electrics.

15 MR. BROOKMAN: Several people in the

16 queue. Eric Stas first.

17 MR. HARMAN: I just wanted to add her

18 that, you know, Congress gave us -- we could have

19 gone even broader than this. I mean we could have

20 taken all the residential and all the commercial

21 water heaters. There would have been no question

22 of, you know, which side the standards fall on.
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1 It could have been all covered under this uniform

2 test procedure, uniform metric. But Congress gave

3 us the ability to carve out exclusions where that

4 -- that, you know, one approach just might not

5 work for everything. So, you know, for what

6 that's worth.

7 MR. BROOKMAN: Is it Philip?

8 MS. ARMSTRONG: Hang on.

9 MR. BROOKMAN: Philip and then Harvey

10 and then to George.

11 MS. ARMSTRONG: I have a webinar thing,

12 too.

13 MR. BROOKMAN: Okay. Well, if you do --

14 MS. ARMSTRONG: No, go ahead.

15 MR. BROOKMAN: Go ahead, Philip.

16 MR. STEVENS: Philip Stevens. Back to

17 the temperature set point question.

18 MS. ARMSTRONG: Sure.

19 MR. STEVENS: The test that Charlie was

20 referring to is a construction test from an NANTSE

21 (ph) standard, so I would like a little bit of

22 clarification. Does the department want this to
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1 be identified through a method of test or a

2 calculation with a range and tolerance of

3 thermostats or how?

4 MS. ARMSTRONG: I think we're open. I

5 think we want a definitive way to -- as definitive

6 as possible for someone to be able to tell both

7 you all and us which bucket things fall into.

8 MR. BROOKMAN: Harvey.

9 MR. SACHS: Harvey Sachs, ACEEEE. I

10 want to follow on with a question for Frank.

11 Frank, you referred to the thermostat as being the

12 control variable and at least for tank equipment,

13 it seems to me that I would much prefer to have a

14 requirement that the TP valve be regulated to not

15 allow temperatures greater than 179 or 180 degrees

16 with voiding of the warranty if the TP valve is

17 changed out for a higher limit. That gives me

18 much better control than relying on the user to

19 not set the temperature above 180. Its' a very

20 inexpensive thing yet it's something most people

21 would rely on a plumber to sub out.

22 MR. BROOKMAN: Frank.
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1 MR. STANONIK: Frank Stanonik. He's

2 right. Harvey, I think the problem with that is

3 again, the real world operation in the field

4 can't, under the lets it call it the wrong set of

5 circumstances, as Charlie says, cause stacking or

6 other factors. And you can, on occasion, let's

7 say, get an excursion, if you will, that at least

8 in the higher reaches of the water heater, you

9 might see temperatures at 170, 180, whatever. You

10 know, I think -- and again, when you start playing

11 out what happens and how frequently and stuff, it

12 certainly -- it's some portion of the tank,

13 certainly not the whole tank or anything close to

14 the whole tank.

15 But I think your solution would,

16 unfortunately, likely cause more frequent opening

17 of relief values and we see nowadays -- and I

18 think just unnecessarily cause some people to be -

19 - to cause, let's say, service calls that may or

20 may not be necessary.

21 MR. BROOKMAN: These kind of different

22 approaches seem best to me, not to be debated here
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1 but submitted in detail written comments.

2 MR. SACHS: Will do.

3 MR. BROOKMAN: Thank you. Gary.

4 MR. SACHS: He's wrong.

5 MR. BROOKMAN: Gary -- and then did I

6 drop George out of the queue? George is next.

7 I'm sorry. Please.

8 MR. KUSTERER: George Kusterer, Bock

9 Water Heaters. Just to address that quick

10 question. The T and P valves are a construction

11 standard, so therefore the construction standard

12 would have to be changed.

13 Second of all, and I guess this is for

14 Ashley, I'm going to manufacture an oil-fired

15 water heater that's 120 gallons, and it's going to

16 have an input rate of 150,000 BTUs, but I'm only

17 going to put an aquastat on there that goes up to

18 160. Is that classified residential or commercial

19 or light commercial?

20 MS. ARMSTRONG: Single phase?

21 MR. KUSTERER: It's oil.

22 MS. ARMSTRONG: Okay. Yeah. I mean as
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1 long as it doesn't have the pressure

2 ***10:56:51(cuff).

3 MR. KUSTERER: As long as it doesn't

4 have what?

5 MS. ARMSTRONG: The ASME, yes.

6 MALE SPEAKER: That needs to be

7 standard.

8 MR. KUSTERER: Yes, okay.

9 MR. BROOKMAN: So is it residential or

10 is it light commercial?

11 MS. ARMSTRONG: It's light commercial

12 tested with the residential test procedure and --

13 MR. KUSTERER: Yes, but it doesn't go to

14 180 degrees.

15 MS. ARMSTRONG: Right, "not capable of

16 delivering," so be default, it's in the light

17 commercial. Anything that does.

18 MALE SPEAKER: It's written backwards.

19 You don't trip any of these, your light

20 commercial?

21 MS. ARMSTRONG: Correct.

22 MR. KUSTERER: Yeah, okay.
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1 MALE SPEAKER: How's that backwards?

2 MALE SPEAKER: Well, inversely.

3 MR. BROOKMAN: Charlie, go ahead.

4 MR. ADAMS: I'm looking at the NOPR

5 Federal Register page 66210, first column, couple

6 of paragraphs down. It's "after considering the

7 comments from the RFIs, DOE proposes to amend its

8 water heater test procedure to include applicable

9 provisions for electric instantaneous," just a

10 convenient place that I found. And the definition

11 is "initiates heating based on sensing water flow,

12 is designed to deliver water at a controlled

13 temperature of less than 180 degrees F and has" so

14 forth.

15 That's the wording that's already in the

16 NOPR that I strongly support being used as the

17 discriminatory wording, that is the outlet

18 temperature testing that's done in the safety

19 standards and, yes, you can stack and you can get

20 some, I'll call them, abnormal excursions slightly

21 above the temperature setting. But in a nutshell,

22 it's -- if the max setting that the user can put
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1 on the thermostat is 180 or above, then it's

2 intended to deliver at or above 180. If the max

3 setting is 150 or 160 or 170, that that's the max

4 setting that the user can select, then it's

5 designed to deliver water at that temperature.

6 MS. ARMSTRONG: Okay.

7 MR. ADAMS: So I think we're getting in

8 trouble if we go to the "not capable of" because I

9 can take a heater in a lab and do some strange

10 things to it and get some strange temperatures out

11 of it.

12 MS. ARMSTRONG: Okay.

13 MR. BROOKMAN: Okay. Thank you. Final

14 comments here? I think we're starting to double

15 back on ourselves. Gary.

16 MR. KLEIN: I would also observe related

17 to the question of "capable." The thermostat is

18 not at the top point, right, in the way we build

19 water heaters? So the temperature above that

20 point could be hotter than the thermostat point.

21 So I could pick a thermostat setting at 170 and

22 the top of my water heater might be above 180 just
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1 because of the way it might work. And if that's

2 the case, then what's classify -- it's capable of

3 being some number above.

4 MS. ARMSTRONG: Correct.

5 MR. KLEIN: And so "capable" is not the

6 right word.

7 MR. BROOKMAN: Okay. We're about to

8 move on. Charlie.

9 MR. ADAMS: Charlie Adams. One

10 clarification on something you just said, Gary.

11 Many manufacturers, if not -- well, many

12 manufacturers, we calibrate the thermostat that is

13 down below actually to try to deliver the

14 temperature that's set on the knob out of the top

15 of the tank. In other words, if you took the --

16 you turned the knob to 160, we try to get 160

17 water out of the top of the tank. If you took

18 that thermostat and put it in a calibration

19 machine, it may or may not trip at exactly 160.

20 That's part of the design that we put into it,

21 just to clarify.

22 MR. BROOKMAN: Okay. Ashley.
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1 MS. ARMSTRONG: I just want to go back.

2 So Abbey's question from earlier was does this

3 mean that light commercial water heaters, this

4 category would potentially have different

5 standards than those for residential. And the

6 answer is, yes, at least out the gate. To the

7 extent the Department goes through subsequent

8 rulemakings and analyzes them and the levels come

9 out meeting our criteria and end up being

10 equitable, so be it. But at least right out the

11 gate, the standards are different right now as

12 they exist for residential and commercial and this

13 would not change the standards.

14 MR. BROOKMAN: Charlie.

15 MR. ADAMS: Charlie Adams. A follow on

16 to that for clarification: In April of 2015, what

17 a gas water heater above 75,000 BTUs -- I'm sorry

18 -- a gas water heater with a water capacity above

19 55 gallons is required to be condensing, in

20 essence.

21 MS. ARMSTRONG: Correct.

22 MR. ADAMS: Assuming that this
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1 regulation goes forward just like the NOPR, in

2 April of 2015, after NECA III takes effect, what

3 would be the minimum efficiency that is legal for

4 a 60-gallon, 100,000 BTU residential duty

5 commercial?

6 MS. ARMSTRONG: The commercial standard.

7 MR. ADAMS: Would still be 80 percent

8 thermal efficiency?

9 MS. ARMSTRONG: Yes, sir, whatever that

10 translates to under the new metric using the

11 crosswalk, yes.

12 MR. ADAMS: Thank you.

13 MR. BROOKMAN: Okay. Gary.

14 MR. KLEIN: In simple terms, what we're

15 doing is creating more market confusion than

16 fixing it.

17 MS. ARMSTRONG: The statute was limited

18 in nature to the metrics and the method only, not

19 to the definitions or standards.

20 MR. BROOKMAN: Frank.

21 MR. STANONIK: Frank Stanonik. He's

22 right. Is there any question in DOE's mind that
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1 the statute was also intended to, for lack of a

2 better word, drag in those products to also be

3 covered by the quote, unquote, residential minimum

4 standard?

5 MR. BROOKMAN: Eric Stas.

6 MR. STAS: There's nothing in the

7 statutory language that says that.

8 MR. BROOKMAN: Don Brundage.

9 MR. BRUNDAGE: I think I understand

10 where they're going with this and it's to -- I

11 mean let's be honest. There are a lot of products

12 coming onto the market that are designed to evade

13 the current standard. You do a burner just large

14 enough or a resistive element just large enough to

15 fall outside the range of the standard and it

16 doesn't have to meet the April 2015 rule. Now

17 this doesn't change that but it provides an

18 opportunity to set a standard for this lighter.

19 So I think this is a step in the right direction,

20 although they don't have statutory authority to

21 set a new efficiency standard for it without going

22 for the full rulemaking.
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1 MR. BROOKMAN: Gary.

2 MR. BRUNDAGE: I want to come back to

3 the point that was someone made about not having

4 authority to make definitions. I think that this

5 NOPR makes a definition. At least one on electric

6 tankless water heating, it defines it at least

7 once. In fact, it appears to define it twice so

8 I'm sorry if we have the authority to do that one,

9 we have the authority to make other ones. Maybe

10 I'm wrong.

11 MS. ARMSTRONG: I think you're referring

12 to the definitions that exist today. Is the rate

13 -- the electric instantaneous is defined in the

14 statute already. They're defined twice because

15 they're defined for residential and commercial.

16 What this is doing is defining this light

17 commercial category for the purposes of testing

18 for which some commercial electric instantaneous,

19 if not all, will now be tested under the

20 residential test procedure and metric. It's not

21 the same as re-defining the statutory authority

22 for what is a consumer product and what is a
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1 commercial or industrial equipment.

2 MR. BRUNDAGE: Okay.

3 MR. BROOKMAN: Okay. We're about to

4 move on. Everybody okay? Okay.

5 MS. ARMSTRONG: Okay. I'm going to the

6 next slides.

7 MR. BROOKMAN: Actually, someone had a

8 web --

9 MS. ARMSTRONG: I did it already. Thank

10 you for reminding me. So I'm going to go through

11 the next slides relatively quickly, but the reason

12 they're here is because the graphs really helped

13 me, and hopefully you find them helpful as well,

14 figure out what's covered now and what will be

15 covered where later in terms of a test procedure

16 applicability, because we're doing two things with

17 this rule and that's filling existing gaps within

18 residential as well as broadening the scope as

19 long as things meet those three criteria to make

20 the test procedure applicable to certain types of

21 commercial.

22 So the existing test method for gas-
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1 fired water heaters, it covers both storage and

2 instantaneous, we have several -- even those these

3 are covered water heaters, there's no test

4 procedure for storage between 2 and 20 gallons or

5 over 100 gallons or instantaneous below. We have

6 added a test procedure for those or we propose to

7 add a test procedure for those. So there's no

8 upper or lower storage volume limit for our

9 proposed method and there's no upper or lower

10 limit for input ratings.

11 So this is what the existing test

12 procedure applicability looks like, and this is

13 what the new one is. It's a little more complex

14 but everything is colorful.

15 MALE SPEAKER: To say the least.

16 MR. BROOKMAN: That's good. That's very

17 good. Steve Rosenstock.

18 MR. ROSENSTOCK: Steve Rosenstock, EEI.

19 This just might be a graphic issue but for the new

20 lighter blue color, I think I see the green, but

21 is the lighter blue color also -- is everything

22 all covered in the box now compared to what it was
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1 before? I'm just kind of confused by all the

2 different colors.

3 MS. ARMSTRONG: Correct. It's just

4 different colors because they're still

5 residential. They're not this new light commercial

6 category, but we have extended the test procedure

7 to them. Correct.

8 MR. ROSENSTOCK: And again, thank you.

9 That helps. Again, Steve Rosenstock, EEI. I'm

10 just kind of curious. You go back to the previous

11 slide, the -- yes, that slide right there --

12 you're kind of showing what's out there now.

13 Doesn't t his cover 95 percent of the products out

14 there in the marketplace?

15 MS. ARMSTRONG: I will let those in the

16 room answer.

17 MR. ROSENSTOCK: Ninety-eight percent?

18 MR. BROOKMAN: Gary.

19 MR. ROSENSTOCK: I'm just kind of

20 curious. I mean --

21 MR. KLEIN: Gary Klein. It covers a

22 large part of what's currently in the marketplace.
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1 The dilemma I think we face is that the gaps meant

2 that people are not producing water heaters that

3 might be better suited for certain applications in

4 the halls because there's no -- they're not

5 covered and there's test procedure for them to

6 follow to be rated. And so by making them covered

7 and making a test procedure for them, they now get

8 to compete in the marketplace. In general, from a

9 customer's point of view, I actually think there's

10 a bunch of water heaters that fall outside the

11 current bounds that would, in fact, be extremely

12 well suited to consumer desire.

13 I have to tell you I'm very confused by

14 the diagonal blue, and if you would explain that

15 piece to us, I'd be really happy.

16 MS. ARMSTRONG: The diagonal. You can

17 go ahead.

18 MR. STANONIK: You know, I'll just say

19 we're saddled with history. That is the classical

20 definition of instantaneous water heater, 4,000

21 BTUs per input per gallon of stored water. So if

22 you look at the 40 line as an example, okay, a 40-
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1 gallon gas water heater with 200,000 BTUs of input

2 is classified historically and for many years as

3 instantaneous. So that diagonal --

4 MS. ARMSTRONG: Correct.

5 MR. STANONIK: -- it's a product that

6 storage but it triggers the 4,000 BTUs per gallon.

7 MR. KLEIN: So it's really pulling off

8 the red line then? Is that correct? It might be

9 better suited to be pink as opposed to blue in

10 order for us to recognize that. That would --

11 MS. ARMSTRONG: Yes. I mean the red is

12 just what's -- yes. I get your point.

13 MR. KLEIN: Because I couldn't figure

14 out why I --

15 MS. ARMSTRONG: Sure.

16 MR. STANONIK: Okay. Thank you.

17 MS. ARMSTRONG: Fair enough.

18 MR. BROOKMAN: Don Brundage.

19 MR. BRUNDAGE: This is somewhat off

20 topic. I don't know where it is since we skipped

21 around between the slides. On Slide 17,

22 **11:09:37 you didn't throw passed, you said
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1 comments are due January 21st. You expect to

2 issue a final rule in early 2014. How long do you

3 expect to take to look at comments before issuing

4 a final rule? Hopefully, it's longer than a week

5 between Christmas and New Year's, like a

6 rulemaking earlier this week, but --

7 MS. ARMSTRONG: Your point is taken.

8 Thank you.

9 MR. BROOKMAN: Gary.

10 MR. KLEIN: To follow on the same

11 question, is this our only time, plus public

12 written comment, to participate and comment?

13 MS. ARMSTRONG: I would say that's a

14 good assumption at this point. If the comments

15 suggest that we need to do something alternative,

16 that's one thing we won't know. But at this

17 point, our plan is to go straight to final, so

18 this is your opportunity to comment.

19 MR. KLEIN: Thank you.

20 ***11:10:40(MALE SPEAKER: (Off mic)

21 MS. ARMSTRONG: Sure.

22 MR. KLEIN: That chart, let's stay with
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1 the charts. The charts are very helpful. So now

2 assuming that the diagonal is actually a light

3 pink for the moment, to make my logic clear, that

4 means that what's to the left -- let's see -- the

5 upper left of the lower pale blue box is now going

6 to be pink because that's technically

7 instantaneous in the category?

8 MS. ARMSTRONG: Correct.

9 MR. KLEIN: That, I think, would help.

10 MS. ARMSTRONG: And there's a consumer

11 product.

12 MR. KLEIN: And it's -- so the light

13 pink and the light blue will be consumer products

14 and everything in light green is something other

15 than that?

16 MS. ARMSTRONG: It's a commercial

17 product that's tested and rated as if it was

18 residential, correct.

19 MR. KLEIN: Okay. So now we've filled

20 in the holes, ***11:11:30 looking --

21 MS. ARMSTRONG: You've filled in the

22 holes.
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1 MR. KLEIN: -- but you've filled in the

2 holes?

3 MS. ARMSTRONG: Correct. We've done

4 everything.

5 MR. KLEIN: Everything's covered now?

6 MS. ARMSTRONG: Everything is subject to

7 testing, yes.

8 MR. KLEIN: Okay.

9 MS. ARMSTRONG: Everything has always

10 been covered. We just didn't have a test

11 procedure that was applicable.

12 MR. BROOKMAN: George.

13 MR. KUSTERER: Gorge Kusterer, Bock

14 Water Heaters. That -- of course, I can't see the

15 pink but I didn't see the elephant in the room

16 either, so. ***Did you leave your underwear in the

17 room or something? Now what's with this pink

18 stuff anyway? I'm sorry.

19 The green portion then is up to 250,000

20 BTUs and 120-gallon capacity, that is light

21 commercial?

22 MS. ARMSTRONG: So there's no upper
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1 limit period on input. We just --

2 MR. KUSTERER: Oh, infinity?

3 MS. ARMSTRONG: Infinity. I could have

4 put the sign. It's just practical but there's no

5 upper limit as long as it meets those three

6 criteria. So single-phase, pressure,

7 capable/designed, whatever will fill out there.

8 But, yes, there's no upper limit on gallon size or

9 input and there's no lower limit.

10 MR. KUSTERER: So in other words, if I

11 have a 1-1/2 million BTU water heater that

12 provides 180 gallons, that's going to be light

13 commercial?

14 MS. ARMSTRONG: Right.

15 MR. BROOKMAN: Well, George, I --

16 MR. KUSTERER: Excuse me? It's not

17 going to be -- I mean you're talking about a big

18 water heater that weighs probably 4,000 pounds. I

19 want to see get that in a one-family house.

20 MS. ARMSTRONG: You can suggest that we

21 add an upper limit in your comments. We just

22 declined to because we thought those three
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1 criteria would take care of it. If it doesn't, we

2 welcome.

3 MR. KUSTERER: It doesn't.

4 MS. ARMSTRONG: Okay.

5 MR. BROOKMAN: Frank Stanonik.

6 MR. STANONIK: Well, our reading of what

7 came out of the NOPR was that DOE appears to be

8 trusting that anything that has either a very

9 significant input or significant volume when it

10 will, in fact, end up being ASME stamped --

11 MS. ARMSTRONG: Correct.

12 MR. STANONIK: -- our recommendation did

13 include, I'm sure you recall, an upper limit.

14 We're still trying to -- I mean, you know, George

15 makes a good point but we're trying to just figure

16 out whether it's practical or not.

17 MR. BROOKMAN: Charlie.

18 MR. ADAMS: Charlie Adams. Follow on to

19 that, be advised that not all co-jurisdictions

20 require an ASME pressure vessel on this really

21 huge stuff we're talking about, that some

22 authorities having jurisdiction do not require
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1 that and some manufacturers -- I can speak with

2 assurance, that at least one manufacturer does

3 have some really big water heaters in both the

4 ASME vessel configuration and a non-ASME

5 configuration.

6 MR. BROOKMAN: Okay. Thank you. Yes,

7 Gary.

8 MR. KLEIN: So now I've got more

9 confusion with this chart. The -- would you

10 explain to me what happens after 120 gallons where

11 it's now blue? Tell me what happens? Do I now

12 have a new hole? Continue moving the green line

13 out to the right, please, like you did above the

14 200,000 --

15 MS. ARMSTRONG: It's just all green.

16 MR. KLEIN: It's going to continue green

17 all the way down to the zero gallons?

18 MS. ARMSTRONG: Correct, because -- and

19 it's just -- if you go all the way up to 150, 120,

20 whatever, it just goes green because our

21 residential is limited to 120. So it can be

22 tested as a residential product. It's just not a
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1 consumer product. It's green.

2 MR. KLEIN: Okay. It would be helpful

3 to show that here.

4 MS. ARMSTRONG: Yes. Arrows were meant

5 to show but okay, sure. I get the point.

6 MR. KLEIN: It would be really helpful

7 to show it like you did for the other side.

8 MS. ARMSTRONG: Okay, sure.

9 MR. KLEIN: ***11:15:34 side, be

10 helpful.

11 MR. BROOKMAN: David.

12 MR. VILLARROEL: Hi. David Villarroel,

13 Natural Resources Canada. I just had a question

14 to the manufacturers about this extremely large

15 tank. The safety standards that are in the United

16 States for this tank, are they also subject to a

17 certain limit that -- to have an ASME code or some

18 kind of, I guess, reassurance that, you know, this

19 major large tank is safe?

20 MR. BROOKMAN: Charlie.

21 MR. ADAMS: Yes. They're still tested

22 to AMSE's E21 10.3. They just are not necessarily
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1 required to have an ASME pressure vessel.

2 MS. ARMSTRONG: Okay. So I'm hoping gas

3 is the most complex one. Moving to electric,

4 currently our residential water heater test

5 procedure, it covers electric storage water

6 heaters. It has several coverage gaps in terms of

7 applicability of the test procedure even though

8 they're covered water heaters, 2 to 20 gallons,

9 over 120, and then we do not have a test procedure

10 currently for electric instantaneous.

11 So as we've done with the others, we've

12 proposed to expand that. So this is the current

13 one. It's fairly simple. And this would be the

14 new one.

15 MR. BROOKMAN: Tom.

16 MR. HARMAN: Tom Harman. Just a couple

17 of questions. It says "electric instantaneous

18 definition currently reserved." What does

19 "reserved" mean?

20 MS. ARMSTRONG: It does not exist.

21 MR. HARMAN: Sorry?

22 MS. ARMSTRONG: We do not have one
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1 currently. It means that we can amend it to have

2 one later.

3 MR. HARMAN: And then the other

4 question, and I'm not sure -- I understand there

5 was an environmental or energy group or so -- why

6 is instantaneous limited to 12 Kw since there are

7 many that are more than that that are in

8 residences? You said there's a difference --

9 what's the difference between residential and

10 consumer? You made a distinction between these

11 words.

12 MS. ARMSTRONG: I did.

13 MR. HARMAN: I don't understand that at

14 all.

15 MS. ARMSTRONG: So the 12 kilowatt

16 limit, you're -- is the definition of

17 instantaneous -- it's the definition of electric

18 water heaters, maximum input in this statute. So

19 by default, we call them consumer products. The

20 residential products in the statue are limited to

21 12 kilowatts. That being said, the test method,

22 we do not have an upper limit. The test method
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1 will be applicable to electric instantaneous with

2 no upper limit. It's just that if we were to set

3 standards, in a standards -- the standards rule --

4 or the standards that are there for electric

5 instantaneous are limited to 12 kilowatts.

6 MR. SACHS: By the legislation?

7 MS. ARMSTRONG: By the legislation.

8 That's not something DOE can change

9 MR. BROOKMAN: Harvey.

10 MR. SACHS: Tom, just for clarification,

11 there have been legislative proposals to modify

12 that 12 Kw limit but that is something which is,

13 as I understand it, hard in the law now for

14 tankless and tank electric water heaters --

15 MS. ARMSTRONG: Correct.

16 MR. SACHS: -- whether resistance or heat

17 pump or imaginary.

18 MR. HARMAN: Okay.

19 MS. ARMSTRONG: Yes.

20 MR. BROOKMAN: Gary.

21 MR. KLEIN: Okay. So back to some of my

22 chart confusions. Let's do the easy one first.
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1 Everything bigger than 120 gallons would be light

2 green, all the way down to zero Kw. Is that

3 correct?

4 MS. ARMSTRONG: correct. Same arrow,

5 same -- the arrows hold.

6 MALE SPEAKER: To me, it's not ASME

7 standard?

8 MS. ARMSTRONG: Right, as long as they

9 meet those three criteria.

10 MR. KLEIN: I understand. I'm just --

11 MALE SPEAKER: (Inaudible)

12 MR. KLEIN: Right. It's got to meet all

13 those other criteria.

14 MS. ARMSTRONG: Correct.

15 MR. KLEIN: I got that piece. Now we've

16 drawn in a red section meaning for consumer

17 products, and I'd like us to start using that word

18 as opposed to residential. George made a comment

19 to me many years ago that once he makes a water

20 heater, he has no idea where it's going to end up.

21 Neither does the water heater today. So if we

22 call them residential as a category and we then
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1 talk about where they get installed, we don't have

2 a clue. It's causing market confusion. We should

3 stop using it if we have the opportunity. So,

4 consumer, please.

5 So the consumer products in

6 instantaneous are red up to 12 Kw and then light

7 red along the diagonal line. Is that correct?

8 MS. ARMSTRONG: Correct.

9 MR. KLEIN: Okay. And there is a funny

10 part in the line where the line goes through zero

11 but there's actually up to two gallons. So I

12 think we have a water --

13 MS. ARMSTRONG: It's the definition.

14 MR. KLEIN: Okay. It's weird but that's

15 all right. Now, does the line continue diagonally

16 above the 12 Kw point?

17 MS. ARMSTRONG: No.

18 MR. KLEIN: Because there are electric

19 instantaneous water heaters above that point.

20 MS. ARMSTRONG: It does not.

21 MR. KLEIN: Because?

22 MS. ARMSTRONG: The definition is in the
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1 consumer product section of the legislation and

2 that is limited to 12.

3 MR. KLEIN: Okay.

4 MR. STANONIK: But it's covered by the

5 vertical line, not diagonally. It's covered by

6 the vertical.

7 MS. ARMSTRONG: All right. So --

8 MR. KLEIN: So --

9 MS. ARMSTRONG: -- they can be tested.

10 It just doesn't matter. There is no ratio limit

11 there.

12 MR. STANONIK: With -- where the heating

13 tubes, if you will, held less than two gallons,

14 it's there.

15 MR. KLEIN: I'm sorry. Isn't the -- no,

16 I get that. It's -- but the -- isn't part of the

17 definition that it's 4,000 BTUs per gallon?

18 Doesn't that also apply?

19 MR. STANONIK: Well, not in the electric

20 side, no.

21 MS. ARMSTRONG: Correct.

22 MR. KLEIN: Boy, that's illogical, too.
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1 MR. STANONIK: Oh, on.

2 MR. KLEIN: Okay.

3 MR. STANONIK: ***11:21:56(Off mic).

4 MR. KLEIN: Okay. So that same water

5 heater that Charlie described earlier as so many

6 gallons and so many BTUs and gas as being

7 instantaneous is not true in electric? That's

8 called a storage water heater even though it has

9 the same output capability.

10 MR. STANONIK: Frank Stanonik. He's

11 right. I mean you're dealing with what the market

12 historically has looked like and to a large extent

13 still looks like. I mean to -- I have to do the

14 math real quick here, but to -- let's say I had a

15 50-gallon electric, right. To get those 200,000

16 BTUs, I need something on the order of 50-some Kw

17 input.

18 MALE SPEAKER: That would be about 60.

19 MR. STANONIK: About 60 Kw. Up to this

20 point, that product's never showed up anywhere in

21 the U.S., I think.

22 MR. KLEIN: No dispute about the product
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1 not being there yet.

2 MR. STANONIK: Better not.

3 MR. KLEIN: I guess my question is if

4 somebody made such a product that --

5 MS. ARMSTRONG: It would be tested.

6 MR. KLEIN: It would be tested as what?

7 MS. ARMSTRONG: If it meets those three

8 criteria --

9 MR. KLEIN: No, no, no. I know but what

10 -- sorry -- would it be tested -- because we --

11 our test procedure has something on storage or

12 instantaneous.

13 MR. STANONIK: In our test procedure,

14 no, it wouldn't matter.

15 MR. KLEIN: Okay. But -- so it's just

16 going to get -- it's going to get tested?

17 MR. STANONIK: I mean this crazy water

18 heater I dreamed up, okay, I mean so if -- being

19 really practical about it, if it had -- we went

20 with a DPM, okay, it's going to be tested at a

21 high-use pattern, okay.

22 MS. ARMSTRONG: Right.
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1 MR. STANONIK: If you went by first hour

2 rating, it's going to be tested a high-use pattern

3 I think either way, it gets you to the same point.

4 MS. ARMSTRONG: Right.

5 MR. KLEIN: Okay.

6 MR. STANONIK: Maybe one of the

7 unintended things came out of this.

8 MR. KLEIN: Okay. My questions so far -

9 -

10 MS. ARMSTRONG: Okay. So I'm going to

11 move on to oil. Same thing here. We do not --

12 our existing test method covers oil-fired storage

13 water heaters. It does not have test method for

14 over 50 gallons or instantaneous oil. And as

15 we've done with the others, similar thing, blue

16 shows existing. Light blue is propose but would

17 be in the consumer product section. Green is

18 proposed but light. Gary, to your question,

19 arrows keep going. Above 120, keep going with the

20 green.

21 MR. KLEIN: Sorry. Back to one of my

22 questions: That -- there is no oil instantaneous
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1 in the definition, is there, but there's a

2 diagonal line drawn?

3 MS. ARMSTRONG: Statute. The statutory

4 --

5 MALE SPEAKER: Four thousand? That's

6 the

7 4,000?

8 MR. KLEIN: It's the 4,000 so that

9 should show up as pink to match the other colors,

10 please. No, it really will help explain this if we

11 keep our color coding similar.

12 MS. ARMSTRONG: Okay.

13 MALE SPEAKER: Okay. We just haven't --

14 right. Gotcha.

15 MS. ARMSTRONG: So I'm going to go just

16 to a summary real quick of what we've done. We've

17 proposed expanding the applicability of the test

18 method so that it's applicable to all products

19 that meet EPCA's definition of residential water

20 heaters. So as we've said, 2 to 20 gallons,

21 instantaneous, different types of things that

22 you've seen in the graphs previously.
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1 We've also proposed to cover certain

2 commercial water heaters such that they meet the

3 definition of that like commercial with those

4 three criteria.

5 So that's going to conclude the scope

6 stuff, so if anyone has further comments, I'll

7 open the floor.

8 MR. BROOKMAN: Frank.

9 MR. STANONIK: Quick question. So,

10 Ashley, back on Slide 17, the last bullet, the

11 proposed changes would not expand the scope of

12 coverage of current energy conservation standards.

13 We are not talking about the residential duty

14 commercial but the under 20-gallon that always has

15 been they could define as consumer product.

16 MS. ARMSTRONG: Correct, it would not.

17 MR. STANONIK: How does that statement

18 relate to those products?

19 MS. ARMSTRONG: It's exactly what it's

20 intended to address. If there are no test

21 procedures and standards on the book today, just

22 because we're adding a test, now that does not
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1 automatically extend the standards to them later.

2 And we clarify that with the amendments in 430.32,

3 the proposed amendments.

4 MR. STANONIK: All right. So the --

5 well, I would -- so we should expect that if there

6 will be minimum standards for the let's call it

7 the less than 20-gallon consumer product, there

8 will be another rulemaking to develop standards?

9 MS. ARMSTRONG: Yes, sir.

10 MR. BROOKMAN: Gary.

11 MR. KLEIN: Two questions. In the

12 interim, to follow Frank's question, if a

13 manufacturer wants to make a product that's 17

14 gallons, what are they rated against? They --

15 MS. ARMSTRONG: What do you mean by

16 rated against?

17 MR. KLEIN: How do they tell its

18 efficiency? How do they legally discuss it?

19 MS. ARMSTRONG: So once we have a final

20 test method, the test method will be required to

21 use -- this one's a little different because it

22 actually has an effective date in it -- but it
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1 will be required to use for representations to the

2 extent a manufacturer wishes to make

3 representations of those units. It just does not

4 have a standard to comply with.

5 MR. KLEIN: I'll let this follow the

6 logic and then come back to my next question.

7 MR. BROOKMAN: Okay. Yes, Charlie.

8 MR. ADAMS: To give a simple answer to

9 your question, we don't have an efficiency rating

10 on less than 20-gallon units today, if that was

11 your question.

12 MR. KLEIN: So I could pick any number I

13 want and just state what it is and use the test

14 procedure --

15 MR. ADAMS: We don't even -- we don't

16 tell you a number.

17 MR. KLEIN: Right. Okay, so --

18 MS. ARMSTRONG: But after this final

19 rule and once a test procedure is effective,

20 should Charlie decide to tell you a number, he

21 must use the test procedure to do so.

22 MR. KLEIN: Okay.
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1 MS. ARMSTRONG: So the method is set.

2 In other words, he can't just make up a number.

3 He doesn't have to tell you a number but he can't

4 make up a number.

5 MR. KLEIN: So --

6 MALE SPEAKER: ***11:28:13(Off mic)

7 MR. KLEIN: Okay. So to my next

8 question, we've covered electric water heaters.

9 Does that category include electric heat pump

10 water heaters?

11 MS. ARMSTRONG: Yes, always has.

12 MR. KLEIN: Okay. I just -- for those

13 that don't understand the proceeding, it might be

14 useful to add that to the category titles just --

15 MS. ARMSTRONG: We don't distinguish

16 them but they're --

17 MR. KLEIN: Again, you're -- we're

18 trying to -- we have to sell this to a lot of

19 folks to believe that it works, making it as clear

20 up front. Those pictures, if they're clear, will

21 help enormously to say what's covered and what's

22 not.
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1 MS. ARMSTRONG: Okay. I'm just going to

2 say before we get into the actual test method

3 itself, does anyone want to take a break?

4 MALE SPEAKER: Yes.

5 MS. ARMSTRONG: Or you want to keep --

6 there we go.

7 MR. BROOKMAN: So it's 10 minutes after

8 10. Let's resume at 10:25. The restrooms are at

9 both ends of the hall. To get to the coffee shop,

10 go quickly. It's on the ground floor and in that

11 direction. And good input already, very, very

12 good, and we'll resume at 10:25.

13 (WHEREUPON, a brief recess was

14 taken.)

15 MR. BROOKMAN: Okay. We're going to

16 resume. Bill.

17 DR. HEALY: Yes, correct. Bill Healy

18 from

19 NIST.

20 MR. BROOKMAN: But before you do, there

21 was a, just as we were breaking, Robert Wang

22 proposes a question which is if you run the
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1 residential test on a commercial unit, you yield

2 an EF, how does that tie back to commercial water

3 heater efficiency standards which I believe are

4 the thermal efficiency and standby losses?

5 MS. ARMSTRONG: So the second part of

6 what -- this is going to come later in the

7 presentation, but to answer the question real

8 quick -- this is Ashley from the Department -- the

9 statute also requires that we do a crosswalk, and

10 that is to look at what the existing ratings would

11 be as compared to water heaters at the new ratings

12 would be under the new method of testing. That

13 would address the light commercial and the

14 conversion and come up with a conversion of factor

15 so someone could tell.

16 MR. BROOKMAN: Okay. And Robert, we'll

17 be addressing this perhaps in more detail later

18 on. Okay, Bill.

19 DR. HEALY: Thanks, Doug. So now we're

20 going to shift from the scope to get some more of

21 the technical details of what DOE is proposing in

22 the test procedure. And the first thing we're
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1 going to deal with is the setup of the test.

2 So one of the things that DOE is

3 proposing, and this is in line with a comment that

4 was received, but DOE proposes to require storage

5 water heaters to be preconditioned for the energy

6 factor test by running the draw patterns on two

7 consecutive days. So the test is a 24-hour

8 simulated use period, but the proposal is to

9 convert it to a 48-hour period. The first 24

10 would be you draw the test but you do not take the

11 measurements.

12 The purpose of this was to try to make

13 the state of the water heater the same at the

14 beginning of the test as it is at the end. So

15 data have shown that there could be a very large

16 change in stored water temperature in storage

17 water heaters. So the proposal here is try to

18 minimize that difference and to make sure that the

19 water heater's at operational temperature.

20 There's a question?

21 MR. BROOKMAN: ***11:32:19 (Off mic).

22 What is the added burden, if any, in requiring a
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1 24-hour preconditioning period for storage tank

2 water heaters compared to current practice?

3 Charlie.

4 MR. ADAMS: Charlie Adams, A.O. Smith.

5 The added burden is extremely significant. There

6 is obviously a need to precondition the heater.

7 There's no argument there but to precondition it

8 by sending it through the same draw cycle is, what

9 we believe at least, adds a considerable burden.

10 To be more specific, a test stand that's devoted

11 to being able to control the heater with the data

12 control and data acquisition, computer and the

13 instrumentation to put it through the draw cycle

14 is a more significant investment in time, space

15 and instrumentation. We believe that a

16 preconditioning, you can fill the heater up. You

17 can bring it up to temperature or you can

18 thermally soak the heater for a 24-hour period

19 without it being on the test stand and taking up

20 instrumentation and test time. You have to run a

21 first hour test to determine which draw cycle

22 you're going to test the heater to anyway.
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1 We think that by just thermally soaking

2 the heater off the test stand, running the first

3 ho your test, letting it recover from the first

4 hour test and then moving it on to the DOE -- or

5 the EF test stand, the cycle test stand and

6 putting it through the draw cycle will achieve the

7 same intent of having the heater at an appropriate

8 initial state to start the cycle without having to

9 devote a second 24-hour period, taking up space

10 that could be testing another heater at the same

11 time. We do that type of thing today with

12 preconditioning in filling it up with water and

13 letting it come up to temperature, but we don't

14 need to take up the EF test station in order to do

15 that.

16 MR. BROOKMAN: Thank you. My microphone

17 wasn't on. What we're responding to here is the

18 question box at the bottom of Slide 32. We're

19 talking about any added burden and we're taking

20 comments on that. George.

21 MR. KUSTERER: George Kusterer, Bock

22 Water Heaters. I concur with my colleague. It is
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1 an added burden for manufacturers. It's an added

2 burden for third-party testing people, and most

3 significant is the fact that the costs of the test

4 procedure are probably going to double because

5 you're taking up one test stand for 48 hours. Who

6 is paying for that?

7 MALE SPEAKER: Right.

8 MR. KUSTERER: We are.

9 MR. BROOKMAN: George, do you agree with

10 Charlie's prescription, what he suggested as the

11 way, the fix, how this could be done

12 appropriately?

13 MR. KUSTERER: Absolutely.

14 MR. BROOKMAN: Okay. Joe.

15 MR. BOROS: Joe Boros with

16 Remanufacturing Company. I concur with the prior

17 comments related to the added burden for

18 conducting such tests, and I think I also agree

19 with Charlie's comments on the approach to

20 reducing that burden.

21 Furthermore, I would suggest that we

22 have to have a preconditioning warm-up time prior
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1 to conducting the first hour test. Perhaps you'll

2 cover that in a later slide but products in the

3 sequence as described here would have the first ho

4 your test conducted first and then the 24-hour

5 test. We would recommend that prior to the

6 operation of the first hour test, then you would

7 have a preconditioning time as well.

8 MR. BROOKMAN: Okay. Thank you.

9 MR. KLEIN: Can I ask for -- oh, I don't

10 know if Phil wants to speak first, then I'll ask

11 for clarification.

12 MR. BROOKMAN: Philip.

13 MR. STEVENS: Yes. Philip Stevens. I

14 agree with all the statements made so far and I

15 would also like to point out requiring this for

16 the various sizes of manufacturers will have a

17 significant impact with the throughput and being

18 able to respond in a timely fashion.

19 A lot of manufacturers don't have any

20 internal test stations to do this and rely on all

21 outsourced testing. Several manufacturers have

22 one or two test stations while the larger
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1 manufacturers may have four, six test stations.

2 That's a tremendous different amount of burden

3 that the small manufacturers will be placed under.

4 MR. BROOKMAN: Okay. Thank you.

5 MR. HEALY: A point of clarification I

6 request from Charlie: Some data have shown that

7 if you start a 24-hour energy factor test shortly

8 after a recovery, you run the risk of introducing

9 errors because the temperature measurement right

10 at the beginning is challenging.

11 So the way you had mentioned that you

12 would run the first hour rating, then run the 24-

13 hour test shortly thereafter, would you require a

14 wait period between the end of recovery following

15 the first hour rating and the beginning of the 24-

16 hour test?

17 MR. ADAMS: Charlie Adams. Quite

18 possibly but I was flying at 30,000 feet and

19 pretty fast with my comment. The technical

20 community is looking at making a recommendation on

21 the best way to do that. I was just outlining.

22 Conceptually, there's a better way to get there
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1 that doesn't cost a lot of time, money and test

2 station time.

3 MR. BROOKMAN: Excellent. Frank.

4 MR. STANONIK: Frank Stanonik. He's

5 right. In fact, this idea of doing a trial run SUT

6 was part of our recommendations to RFI. If you

7 haven't figured out, we've -- first, we evaluated

8 that and realized it may not be a good idea and we

9 will be doing our best to recommend a better

10 procedure that isn't nearly as burdensome but gets

11 you to the same starting point.

12 MR. BROOKMAN: Thank you. A timeline,

13 Frank, for that?

14 MR. STANONIK: Well, comments are due by

15 the 21st.

16 MS. ARMSTRONG: January 21st.

17 MR. BROOKMAN: That's what I'm

18 confirming here. David.

19 MR. VILLARROEL: Hi. David Villarroel.

20 One of the things that the CSA P3 Committee in

21 Canada has been proposing for this preparation in

22 the test to get to the same point as what the
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1 criteria is. To get the beginning of test to the

2 same point at the end of the test is to take just

3 a few of the end draw patterns, draws at the end,

4 so either three or four of the last draws, and to

5 have that as a kind of a preconditioning part of

6 the test procedure.

7 MR. BROOKMAN: Thank you. Charlie, did

8 you want to comment additional?

9 MR. ADAMS: I was just going to expand

10 on Frank's comment that in the original comments

11 where the HRI group was recommending the two 24-

12 hour periods, we had gotten rid of the six

13 thermocouple tree at the same time, so when we

14 figured out maybe we didn't want to get rid of the

15 six thermocouple tree, we got rid of the second

16 24-hour.

17 MR. BROOKMAN: Thank you. Gary.

18 MR. KLEIN: Gary Klein. So I have a --

19 I'm looking through the test preparation

20 discussion and I don't see it, so here's a good a

21 spot as any to ask. We talked earlier about the

22 instantaneous water heaters that have large
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1 volumes. How do you -- what -- I'm confused what

2 you're going to prep them as. Do they start with

3 stored water at a high -- at a set temperature or

4 do they start cold, because if they got 50 gallons

5 of cold, it's real different than if it's got 50

6 gallons that's hot.

7 DR. HEALY: This is something that might

8 need some clarification so we would definitely

9 welcome your input. The intention that was that

10 would be a storage water heater but we welcome

11 input on how to best test those types of units.

12 MR. BROOKMAN: Harvey.

13 MR. SACHS: Harvey Sachs, ACEEE. I

14 start with a question. The present test for tank

15 units has a 24-hour preconditioning it but not

16 withdraws? Is that correct?

17 MR. HEALY: There's nothing specified in

18 the test procedure for the 24-hour for any sort of

19 preconditioning. There are some optional things

20 you can do a the beginning but there's nothing to

21 mandate a 24-hour wait in the current test

22 procedure.
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1 MR. SACHS: But it is -- let me address

2 it, Bill, to the manufacturers. This is something

3 that you normally do or?

4 MR. BROOKMAN: Philip was ready to

5 respond here, Harvey. Philip.

6 MR. STEVENS: There is nothing in the

7 regulations that prevent us from doing that and it

8 provides more consistent results, so yes.

9 MR. BROOKMAN: And then Frank can follow

10 on.

11 MR. STANONIK: Harvey, the test

12 guidelines that we wrote for all of the testing

13 that the ***11:41:26 or I did on water heaters

14 since the very early days that we wrote for

15 Intertech to use, those specifically spell out

16 this 24-hour, if you will, soaking period.

17 MR. BROOKMAN: Go ahead.

18 MR. SACHS: Thank you. That's very

19 helpful and it brings me to two points. One, the

20 issue is not whether we're doing a 48-hour run or

21 not but whether all of it has to be in the test

22 chamber and whether the draws are necessary. And
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1 I think I speak for all in our community that we

2 do want an unbiased test across technologies, but

3 we don't care if there is any draw in that first

4 24 hours. This is just something to get, as Frank

5 alluded to, consistent results.

6 Now that leads me, though, to sort of a

7 polling questions which is whether the

8 manufacturers of both and tankless, and for that

9 matter, heat pump and resistance, are all

10 comfortable that this would lead to -- this set of

11 conditions for testing will lead to a test that's

12 fair between competing technology approaches.

13 MR. BROOKMAN: Frank.

14 MR. STANONIK: On this particular aspect

15 which I'm going to characterize as eliminating the

16 influence of transfer of heat between the water

17 and the mass of the unit, okay, I think on this

18 particular aspect, yes, the industry agrees this

19 is an equitable approach.

20 MR. SACHS: This is Harvey. Thank you,

21 Frank, and that sort of says that I will urge our

22 community to support substitution of 24-hour soak
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1 instead of the big pre-run of the simulated use

2 test.

3 MR. BROOKMAN: Thank you, Harvey. Thank

4 you. Other comments here or I'm going to get back

5 to Bill. Bill.

6 DR. HEALY: Just quickly. Also, we have

7 the second bullet point. We're proposing for

8 instantaneous water heaters that we require a 1-

9 hour idle period prior to that. The reason for

10 that is we don't want to have pre-heating of the

11 heat exchanger. So theoretically, it could be run

12 right before the test started to pre-heat it. So

13 the proposal here is to require a 1-hour idle

14 period of instantaneous water heaters.

15 MR. BROOKMAN: Gary.

16 MR. KLEIN: So instantaneous water

17 heaters will, in some cases, have two gallons or

18 less and in other cases could have larger gallon

19 amounts?

20 DR. HEALY: Right. As I just mentioned,

21 it may need clarification but the intent was for

22 the ones with significant volume, more than two
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1 gallons. Those would be tested for the energy

2 factor under the storage water heater provisions.

3 MR. KLEIN: So if you have two gallons

4 of stored water, if you've built your water heater

5 with a two-gallon tank, with two gallons of water

6 within it, then if you were the consumer, you

7 would start out with that as hot water if it was

8 built in. It would not start out as cold water

9 under some circumstances. In other circumstances,

10 if it's passing through, then you would want it to

11 start out cold because that would be its normal

12 condition. How are we going to -- do you have any

13 thoughts on how we're supposed to deal with that

14 problem?

15 DR. HEALY: So this would be a unit that

16 has thermostatic control and flow control?

17 MR. KLEIN: Yes.

18 DR. HEALY: Okay.

19 MR. KLEIN: And there's at least one out

20 there.

21 DR. HEALY: The way it's defined now is

22 below two, you start essentially with it in its
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1 operational state, so it would not -- it would

2 fall under the instantaneous test procedure, but

3 you would actually have it running in its idle

4 period. So if it's thermostatically controlled,

5 that two gallons should be warmed up to whatever

6 its operational state is. I would encourage you

7 to read through it. If that's not clear, we might

8 need to clarify that as well.

9 MR. KLEIN: Okay. It seems to me that

10 the test procedure should mimic the operational

11 state that a consumer would see.

12 MS. ARMSTRONG: I think it's fair to say

13 that's what we were trying to propose, so.

14 MR. BROOKMAN: Okay. Thank you.

15 Additional comments here?

16 DR. HEALY: Okay, great. The next thing

17 we'll discuss are test conditions and we'll try to

18 hit some of the key ones that DOE would like some

19 comment on.

20 One of the key ones is the DOE is

21 proposing to lower the set point temperature of

22 residential water heaters in the test procedure
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1 down to 125 degrees F from the current value of

2 135 degrees F. And the reason why this was done

3 was to better represent conditions that have been

4 observed in recent studies. Most notably, the

5 technical support document to the 2010 standards,

6 they did a study of installations and the field

7 estimate was about 124 degrees Fahrenheit. Other

8 studies have supported this type of number. So to

9 be representative of what is seen in the field,

10 DOE is proposing to drop that temperature down to

11 125.

12 Along with that, DOE is actually

13 proposing instead of setting the storage water

14 heater temperature to be 125 plus or minus 5,

15 they're proposing to find a way to set the

16 temperature control on the water heater so that

17 the water heater delivers temperature at 125

18 degrees. So the way that the proposal is written

19 is for water heaters -- or it's the intent of it -

20 - is that for water heaters with a single control,

21 so the user has one way to change the set point

22 temperature on the water heater following cutout,
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1 a complete cutout, after the water heater

2 recovers, the test lab would draw water from the

3 tank and monitor the outlet temperature for 2

4 minutes for smaller water heaters under 20

5 gallons, for 5 minutes for those above 20 gallons.

6 The flow rates will be 1 GPM for the

7 smaller water heaters, 1.7 GPM for the later water

8 heaters. And in this 5-minute period or 2-minute

9 period, the maximum outlet temperature must be 125

10 plus or minus 5. So it would be based on the

11 outlet temperature as opposed to the stored water

12 temperature. Question.

13 MR. ROSENSTOCK: Hi. Steve Rosenstock,

14 Edison Electric Institute. Just a question about

15 the flow rates. If you're assuming the same

16 residential occupants, why would the -- and you're

17 -- why wouldn't the flow rates be the same if it's

18 the same occupants, they just, for whatever

19 reason, decide on a smaller water heater?

20 DR. HEALY: Sure. The way these flow

21 rates have been determined, this was a comment

22 presented to DOE to do I at 1.7 GPM. We feel
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1 that's an appropriate level. Testing done on

2 smaller water heaters, for example, a storage

3 water heater that has 2.5 GPM, we found that it's

4 not designed to deliver 1.7 GPM really. Thos

5 point of use water heaters are really more

6 appropriate at the 1 GPM level. If you would

7 suggest that we do both at 1 GPM, I think that

8 might be a reasonable number. We saw some drop9 off in the temperatures. That's why we're

10 proposing the 1 GPM. With the smaller water

11 heaters especially, when you start getting a big

12 flow rate, there is so much mixing going on that

13 it disrupts the operation of the water heaters.

14 MR. BROOKMAN: Gary.

15 MR. KLEIN: So I'm confused. Current

16 product can't -- because of what we've been

17 making, if it's small in volume, has issues of the

18 type you're describing of put too high a flow rate

19 in, it mixes too much, it doesn't come out right.

20 But that's in part a function of when the burners

21 choose to come on or the elements choose to come

22 on. The control strategies we've picked are not
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1 designed for higher capacity outputs, but that

2 doesn't mean they couldn't be. And consumers

3 might hook them up to a higher flow rate. So

4 they're going to get lesser performance unless

5 than we're testing against.

6 So it seems to me that any water heater,

7 and later any test pattern, can have exactly the

8 same flow rates regardless of the higher or low

9 use for the size of the water heater with a couple

10 of exceptions. And the primary exception is if

11 it's really small, a one- gallon water heater just

12 isn't going to have, under typical circumstances,

13 much capacity for the test piece.

14 MR. BROOKMAN: Frank.

15 MR. STANONIK: Frank Stanonik. He's

16 right. A 15-gallon electric storage water heater

17 practically is not going to be hooked up to much,

18 maybe at most two points of use, neither of which

19 will be a very heavy load.

20 MR. KLEIN: Gary Klein. To follow the

21 thought, I could put a 15-gallon water heater for

22 two lavatory sinks. Each lavatory sink could
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1 legally today be 2.2 gallons per minute. That's

2 the law. I could hook it up to that and I could

3 use it for that purpose. Would it sustain that

4 load for very long? No. That's a different

5 problem, but it could easily have that load

6 attached to it. Heck, I could put it attached to

7 a shower and run it for eight seconds and I'd

8 still have a legitimate flow.

9 I guess I would request that, you know,

10 for the point of setting, the temperature control,

11 you know, I would request comments from you about

12 is 1 or 1.7 appropriate. Is it sufficient and

13 things like that for this specific point.

14 MR. SACHS: Gary, this is Harvey Sachs.

15 Your proposing that we might have two folks

16 running 7.5 gallons each out of that 15-gallon

17 water heater for the lavatory faucet?

18 MR. KLEIN: Yes.

19 MR. SACHS: Thank you.

20 MS. ARMSTRONG: So we had a question

21 from the webinar. What determines whether our

22 product is classified according to first hour
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1 rating or max flow?

2 DR. HEALY: That's something we may need

3 some clarification on. The intention is that a

4 max flow would be those water heaters that are

5 designed to deliver water continuously, that

6 they're -- and so that would be the max GPM

7 whereas other water heaters would be under first

8 hour rating. And we would welcome --

9 MS. ARMSTRONG: Great. So to clarify

10 that one, it would be instantaneous in nature and

11 not have a whole lot of storage capacity and the

12 other would also have instantaneous along with

13 storage capacity, so.

14 DR. HEALY: Right.

15 MR. BROOKMAN: Yes, Charlie.

16 MR. ADAMS: Charlie Adams, A.O. Smith.

17 On the water heaters with two or more thermostatic

18 controls, I don't have a solution to deliver but I

19 have a comment to make. Most heaters that have

20 two thermostats or resistance heaters with an

21 upper and lower element that has a thermostat on

22 each element, not all but predominantly, that
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1 would be the case. Most of those two-element

2 heaters are what we call non-simultaneous elements

3 meaning both of them can't run at the same time.

4 The lower element runs and then when it can't keep

5 up with the need to replenish the water, heat the

6 water fast enough, it transfers control from the

7 bottom element and thermostat to the upper element

8 and thermostat. So not always -- there are

9 simultaneous element heaters available, but most

10 residential resistance electric heaters with two

11 thermostats only operate under the control of one

12 thermostat at a time.

13 We think there's an opportunity to treat

14 that kind of like a single control that during the

15 course of the cycle, it may transfer from one

16 control to the other, but at any given time, it's

17 only operating under one control. So stay tuned.

18 We may be back to you with some suggestions on --

19 or certain two-element heaters. You can still use

20 the same outlet temperature method that you're

21 proposing for one thermostatic control which, by

22 the way, we readily endorse. That's -- the water
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1 coming out is what you're interested in so what's

2 going on in the tank is kind of up to the

3 manufacturer on what they do to achieve the water

4 coming out. So we applaud that approach. We just

5 think there may be an opportunity to use it on

6 certain two-element devices or two- element

7 heaters also.

8 MALE SPEAKER: Thank you.

9 MR. BROOKMAN: Charlie, is that a common

10 industry practice, that two element heater array?

11 MR. ADAMS: Yes, it is.

12 MR. BROOKMAN: Okay. Philip.

13 MR. ADAMS: And to follow on with that,

14 most of the time, I'll say if an installation has

15 a properly sized two-element electric heater,

16 short of having a really heavy long draw here you

17 deplete pretty much all of the hot water that's in

18 the tank for some reason, most of the time, the

19 top element never runs, never runs.

20 MALE SPEAKER: Interesting.

21 MR. BROOKMAN: Philip.

22 MR. STEVENS: Philip Stevens. HTP
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1 actually ahs a gas-fired product with two

2 completely separate and isolated control systems,

3 electronic control systems with thermistors. I'm

4 assuming from the NOPR that this would be

5 considered in the same class as the standard

6 electric products. We are working on a method and

7 proving it in our lab before we, of course,

8 forward it on. But I think we have a solution

9 that our preferred option would be just as Charlie

10 said, that if you can demonstrate that the unit

11 operates off of one of the systems predominantly,

12 then there is no need to include the other one.

13 But as a backup, we're doing some investigation.

14 We think we have a possible solution.

15 MR. BROOKMAN: Okay. Thank you.

16 Charlie.

17 MR. ADAMS: Along those same lines, a

18 question. We have a heater that has a single

19 thermostatic control that happens to have two

20 sensing elements attached to it so it can do a

21 weighted average on what's going on in the tank.

22 But there is only one set of electrical contacts,
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1 one switch that says, go, don't go. It just

2 happens to have two sensors associated with it.

3 We would interpret that to be a single thermostat.

4 How would you interpret that?

5 DR. HEALY: The intention was that it is

6 a single point of control that the user can change

7 the temperature on. If you have better

8 terminology -- we acknowledge it right not it's

9 written as thermostats, so if you have better

10 terminology that would represent that, the fact

11 that it would be a control that somebody outside

12 could change, we would welcome that terminology.

13 MR. ADAMS: Thank you.

14 MR. KLEIN: To continue the

15 clarification if I might?

16 MR. BROOKMAN: Yes, Gary.

17 MR. KLEIN: Gary. It seems to me that

18 the distinction you just made is the problem we're

19 having with the interpretation which is that

20 you're saying if the outside of the box has more

21 than one thermostat that's controllable, do this,

22 not what's inside the box?
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1 DR. HEALY: That is correct, what the

2 user is able to adjust.

3 MR. KLEIN: That's not clear from

4 reading the sentences here.

5 DR. HEALY: Okay, thank you. I would

6 encourage other terminology.

7 MR. BROOKMAN: Did you finish presenting

8 this slide?

9 DR. HEALY: Pretty much. I think we

10 dived into the two thermostats, so I think, yes,

11 we're fine.

12 MR. BROOKMAN: Okay. I wasn't sure you

13 covered it all. Okay. Any additional comments on

14 this slide before we move on? Harvey.

15 MR. SACHS: Just a comment. Harvey

16 Sachs, ACEEE. To support the change in test

17 temperature from 135 to 125, we think this is

18 beneficial.

19 MALE SPEAKER: Thank you.

20 MALE SPEAKER: And I see some heads

21 nodding around the room.

22 MR. BROOKMAN: Yes, Gary.
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1 MR. KLEIN: We've -- I don't think

2 there's a slide discussing the input temperature,

3 is there?

4 DR. HEALY: The inlet temperature has

5 not changed form 58 degrees. We have not received

6 any information that would suggest an inlet

7 temperature that should be different from that.

8 So it's being maintained at 58.

9 MR. KLEIN: So I guess I have a question

10 for the folks w ho do the testing. Does it matter

11 if it's 58, whatever it is, or could it just be

12 55? Does it make any difference what that lower

13 number is because you have to recalibrate

14 everything? I mean if it changes the delta T you

15 have to raise it to, but is that the only --

16 what's the issue then that I'm missing. I would

17 think it would be just as simple to make it a 70-

18 degree delta T and pick the lower bound and the

19 upper bound.

20 MR. BROOKMAN: Charlie.

21 MR. ADAMS: Charlie Adams. If you're

22 asking is it a complicated thing to incorporate
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1 into the test setup, the answer to that question

2 is probably not. But the me nodding my head yes,

3 it makes a difference was we're not sure what

4 impact it would have on what we're about to talk

5 about, things like first hour and maximum recovery

6 capacity and the physics of what's going on with

7 the water. It would make some impact on that,

8 good, bad, or otherwise that we don't know --

9 don't know how to answer the question.

10 Can we recalibrate the test setups and

11 the refrigeration systems that we have that make

12 sure we have 58-degree water to make it 55? Sure.

13 MR. BROOKMAN: Okay. Other comments

14 here?

15 DR. HEALY: I think there was a question

16 from the web. So question from the web: Troy

17 Trant from Rheem, he asks "Will setting tanks on

18 an outlet temperature basis insure that the status

19 of the tank is understood?"

20 I must admit I don't exactly understand

21 the question.

22 MR. BROOKMAN: Yes, Charlie.
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1 MR. ADAMS: Charlie Adams. We've still

2 got the thermocouples in the tank so we're still

3 measuring, I'll call it, the calorific content of

4 what's in the tank. So, so unless I misunderstand

5 the question, I'm going to say, yes, it just

6 doesn't necessarily mean that the tank has to be

7 at an average temperature of 125. It's just set

8 so that what's coming out is 125 but we're still

9 measuring what's going on in the tank I think.

10 Are we?

11 MR. BOROS: Joe Boros. I was wondering

12 if I could comment.

13 MR. BROOKMAN: Get closer to the mic,

14 Joe.

15 MR. BOROS: Perhaps what Troy is saying

16 is that the outlet temperature may not necessarily

17 reflect the mean tank temperature. If you're

18 targeting a 125 outlet and you take the sixth

19 thermocouple probe, initially, you're not going to

20 have -- you may have a condition where the average

21 tank temperature, mean tank temperature may be

22 different than the outgoing temperature.
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1 MR. ADAMS: This is Charlie. Okay.

2 MR. BOROS: Well, and I think to follow

3 on -- Joe Boros here again -- is that a concern?

4 I think that's what Troy is asking in the overall

5 calculation and the way it affects the efficiency.

6 DR. HEALY: One of the things that is

7 still in the test procedure is that there is a

8 correction if the mean tank temperature during

9 standby mode does not stay at 125 degrees. We

10 would be open to comments whether you believe that

11 is an appropriate correction to make.

12 MR. BROOKMAN: Additional comments here?

13 DR. HEALY: So to account for this 125-

14 degree set point, a number of changes are

15 proposed, first of all, the first hour rating

16 test. The current first hour rating test which

17 assumes the water heater starts at a nominal

18 temperature of 135, draws water until the outlet

19 temperature of the water drops 25 degrees, so

20 that's a nominal temperature of 110 degrees, so

21 that's inherently, sort of an inherent assumption

22 that that is a useful temperature, 110 degrees.
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1 Because we're starting 10 degrees lower at 125

2 degrees, DOE is proposing to terminate the draws

3 when that water drops still to 110 degrees or a

4 nominal temperature drop of 15 degrees. So I

5 don't know if we want to have comments on this

6 now?

7 MR. BROOKMAN: Why not. Comments on

8 this? Joe?

9 MR. BOROS: Joe Boros with Rheem. My

10 comment really -- or maybe my question is in terms

11 of starting the first DR. HEALY: our test, it

12 gets back to our prior discussion of having to

13 condition the tank. We find that if we take a

14 tank, let's say, from the warehouse that's cold

15 and it's not at temperature, if you will, that

16 would definitely affect the first hour outcome.

17 So we believe there needs to be a heating up or

18 conditioning period where the tank and materials

19 of the tank would come up to temperature prior to

20 running the first hour test.

21 DR. HEALY: Thank you.

22 MR. BROOKMAN: Thank you, Joe. Gary.
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1 MR. KLEIN: I have a question that I'm

2 not sure is on this slide, but Ashley, some

3 minutes ago, you talked about something that

4 sounded like first hour ratings. It wasn't on

5 this slide and I didn't catch what you were trying

6 to describe. You were talking about -- something

7 about instantaneous versus storage and I don't --

8 it was a comment that sounded like it was related

9 to this slide but was on two prior actually.

10 DR. HEALY: Was it related to the

11 question of do you test max GPM or first hour

12 rating?

13 MR. KLEIN: Yes, that one.

14 MS. ARMSTRONG: Yes.

15 DR. HEALY: We got that question. Once

16 again, we encourage you guys to look through it

17 and provide us comments. Perhaps we need to

18 clarify things. For anything that is meant to

19 deliver water continuously, we would propose not a

20 first hour rating but a max GPM rating.

21 MS. ARMSTRONG: Okay.

22 MR. BROOKMAN: Harvey? Okay.
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1 MALE SPEAKER: (Off mic)

2 MR. BROOKMAN: Okay. Philip.

3 MR. STEVENS: Philip Stevens. Can you

4 define continuously? How long is continuously?

5 DR. HEALY: Sure. We have not defined

6 that so I don't want to propose something right

7 now. But once again, we would welcome comments on

8 that.

9 MR. BROOKMAN: Harvey.

10 MR. SACHS: I'm not yet completely

11 comfortable with the preconditioning criteria. On

12 one hand is the consumer. I've got a strong

13 interest in seeing that nobody is doing that

14 preconditioning at 150 degrees and storing some

15 energy in the tank, however little it might be.

16 On the other hand, I don't particularly care how

17 long that preconditioning is done if it's done at

18 no higher temperature than the test temperature.

19 It seems to me that it's just -- it ought to be

20 long enough to satisfy the manufacturer that it's

21 steady state. Is that a parameter that needs to

22 be in the regulations for the test method?
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1 DR. HEALY: I'm thinking through the

2 calculations and the way it's written. I think it

3 makes sense that it is conditioned at the -- you

4 know, you don't change the -- essentially, you're

5 not changing the thermostat right before doing a

6 first hour rating test. I don't recall how it's

7 written. It mandates no change thermostat or

8 something but I think that is a logical, you know,

9 assumption in the test procedure but I don't know

10 if it's written there.

11 MS. ARMSTRONG: Yes.

12 MR. SACHS: This is Harvey again. And

13 if Philip wants to precondition for 24 hours

14 before doing the first hour test, and Charlie

15 thinks that 30 minutes is good enough, do I care?

16 MS. ARMSTRONG: So I'm going to jump in

17 here if you don't mind. I think the answer is the

18 manufacturers are going to want DOE, if we're

19 testing their products, to do what they did. So,

20 as long as there are criteria governing that, it

21 doesn't necessarily have to be time dependent, so

22 it doesn't make -- maybe 30 minutes is sufficient,
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1 maybe 24 hours is sufficient. As long as it says

2 it's -- you know, we agree that there is some

3 level of preconditioning that meets a specific set

4 of criteria and we have a general understanding of

5 what each other is doing.

6 MR. BROOKMAN: Okay. Charlie.

7 MR. ADAMS: Follow-up on Ashley's

8 comment. That's very important because if heater

9 that we're about to has been in our unconditioned

10 warehouse in Tennessee in June or it's been in

11 ETL's unconditioned warehouse in Cortland, New

12 York in January, it may be a different amount of

13 time that it takes to thermally soak this thing

14 and get it ready to run.

15 MALE SPEAKER: I see.

16 MR. ADAMS: That's a big issue.

17 MS. ARMSTRONG: Right. So like I said,

18 I don't -- you know, if you guys have ideas when

19 you're writing comments about the preconditioning,

20 to what it means to be thermally soaked rather

21 than a time period, we're open to that to the

22 extent it would reduce your burden and stuff like
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1 that. But I do think we would like -- you know,

2 to Harvey's point, we would like some regulation

3 saying at a minimum, this is what we would both be

4 doing, and you would know what we would do, too.

5 MR. ADAMS: And we want that, too.

6 MS. ARMSTRONG: I agree.

7 MR. BROOKMAN: Charlie.

8 MR. ADAMS: Back to the slide that's up

9 here on the 125 set point and the first hour

10 rating, everything that's on this slide makes

11 sense. I mean, you know, we've got some delta T's

12 that -- below a certain temperature, hot water is

13 no longer useful and we need to maintain that, and

14 this is just kind of doing the math to make sure

15 that even though we're starting with 125 instead

16 of 135, that it still quits being useful at the

17 same point. So heartily endorse this.

18 I skipped ahead to make sure there were

19 slides on it. The conversion of today's first

20 hour to tomorrow's first hour at 135 versus first

21 hour at 125, we'll have a more protracted

22 discussion in a few slides on that, but so far, so
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1 good.

2 MR. BROOKMAN: Okay. Additional

3 thoughts here? Okay.

4 DR. HEALY: We alluded to this earlier

5 and this slide does not good on the screen here.

6 MR. BROOKMAN: Or on paper by the way.

7 DR. HEALY: Is that correct? Okay.

8 MS. ARMSTRONG: It looks fine on my cell

9 phone.

10 DR. HEALY: Okay.

11 MS. ARMSTRONG: For some odd reason, the

12 PowerPoint version and the Copy Center does not

13 like --

14 MR. BROOKMAN: ***12:09:34(Off mic)

15 DR. HEALY: The key --

16 MALE SPEAKER: But it'll look better

17 when we post it on the web, right --

18 FEMALE SPEAKER: It's right --

19 MALE SPEAKER: -- and in the docket.

20 MS. ARMSTRONG: It's their version.

21 DR. HEALY: Sorry. This is just to

22 stress that some of the calculations need to
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1 change because there is 125-degree set point. So

2 the top one is the maximum GPM rating that was

3 currently 135. And then the bottom three apply to

4 the simulated use test. The first one relates to

5 the difference between the stored water

6 temperature and the ambient. The second one

7 relates to the fact that the inlet or outlet

8 temperature might deviate from the nominal value

9 of 125, so that's a correction for that. And then

10 the final one is the energy factor computation.

11 MR. BROOKMAN: Steve.

12 MR. ROSENSTOCK: Steve Rosenstock, EEI.

13 So to you, the equation 66241 and 66242 are the

14 Federal Register notice? Basically, those -- just

15 double checking here. Maybe the page before as

16 well, 66240.

17 MALE SPEAKER: The fact that it's -- 125

18 is circled in red means that you're substituting

19 125 (inaudible).

20 DR. HEALY: And it's also in 6.1.6

21 because they're separate for storage and

22 instantaneous, so.
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1 MR. BROOKMAN: Okay. You can see the

2 question boxes there. Maybe we covered them.

3 MS. ARMSTRONG: Yes, I think we did.

4 MR. BROOKMAN: Yes. Any additional

5 comments before we move on? Garrett doss has his

6 hand raised. Garrett, unmute your phone and let's

7 hope we can hear you in the room.

8 MR DOSS: Hello, can you hear me?

9 MR. BROOKMAN: Yes, we can hear you.

10 Excellent. Welcome.

11 MR. DOSS: We'll be behind because I was

12 typing in my response when we were talking about

13 the preconditioning but we got back in that

14 discussion. I agree with the concept that Charlie

15 introduced and others have talked about. I think

16 we could be somewhere maybe in the 20-hour

17 timeframe of a pre- warm-up and then have

18 ***12:11:37 know how we move the stand to do first

19 hour and use that to complete the 24 hours

20 beforehand. I think we need to work up details

21 but I agree with that concept, and need to make

22 sure that we have the tank up ***12:11:53 first
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1 hours ***12:11:54 dated.

2 MR. BROOKMAN: Okay. Thank you very

3 much. So no comments relative to item 67. We're

4 moving on.

5 DR. HEALY: Great. The next topic we're

6 going to talk about are draw patterns. So

7 currently, we have a single draw pattern for all

8 water heaters that are covered by the test

9 procedure. DOE is proposing to revise that, so

10 instead of doing a single draw pattern, do four

11 different draw patterns that are based on the

12 capacity of the water heater. And those draw

13 patterns will be categorized as a point of use,

14 low use, medium use, and high use.

15 Classification will be based on a test

16 of the delivery capacity, either the first hour

17 rating for storage water heaters or the maximum

18 flow rate for instantaneous water heaters or water

19 heaters that are intended to deliver water

20 continuously. A definition will be needed, I

21 guess.

22 This table describes the cutoffs. The
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1 ranges are based on a few things. They are based

2 on first hour rating data for existing models and

3 requirements of the current plumbing code

4 recommend the cutoffs proposed by commenters to

5 RFI. Let me stick with that. So we acknowledge

6 that the first hour rating has changed because it

7 goes from 135 to 125. Our testing at this point

8 show that they are comparable and that's why we

9 chose to stick with these first hour ratings to

10 differentiate the categories.

11 MR. BROOKMAN: Charlie:

12 MR. ADAM: Based on the -- let me say it

13 this way. We're in agreement, more or less, with

14 the -- we are in agreement with the four draw

15 pattern profiles. We could argue a lot about is

16 it exactly right or should we tweak the numbers

17 one way or the other. There's probably 40 ways to

18 do it right and 2 ways to do it wrong. Let's not

19 pick one of the 2, let's pick one of the 40. So

20 this is reasonable.

21 The only caveat that I want to throw in

22 is back to a comment I made a minute ago. When we
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1 get to converting new first hours into old first

2 hours, the outcome of that discussion may need to

3 jockey these first ho your boundaries a little bit

4 one way or the other. But notionally, we're on

5 the right track.

6 MR. BROOKMAN: Gary.

7 MR. KLEIN: Gary Klein. I'm trying -- I

8 was reading through the NOPR and I was reading

9 through what the UPC says for first hour ratings,

10 and I'm not sure that the category sizes you --

11 I'm not sure how to match the first hour ratings

12 in this table with the ones that are there. If

13 you would explain that, please?

14 DR. HEALY: I'm sorry, the first hour

15 ratings or the maximum flow rates? First hour

16 ratings or --

17 MR. KLEIN: Yes Well, UPC, according to

18 the NOPR says something to four different millimil

19 values are implemented by the code of 42, 54, 67

20 and 80 gallons.

21 DR. HEALY: So the Uniform Plumbing Code

22 breaks it down by number of bedrooms, number of
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1 bathrooms, sets different levels of first hour

2 ratings. So these are cutoffs for different

3 points. There are multiple cutoffs in the Uniform

4 Plumbing Code. These were cutoffs that we felt

5 were appropriate and I don't have that,

6 unfortunately, right in front of me what that

7 cutoff is, but there is a cutoff at 80 gallons for

8 bedrooms above a certain size and bathrooms above

9 a certain size. There's also a cutoff at 55 as

10 well.

11 The 20 number is not in there but we

12 felt that low-use water heaters should deliver in

13 the 20 to 55 range, so that one was based on

14 comments that we received to the RFI, the 20

15 galls. But the 55 and the 80 are in the Uniform

16 Plumbing Code.

17 MR. KLEIN: Okay. So what that tells me

18 is that if I needed 42, I'd have to pick from the

19 low category? I'm reading -- the Uniform Plumbing

20 Code has some lower boundary limits and it ended

21 up picking what's called low here for those.

22 DR. HEALY: Correct.
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1 MR. KLEIN: One of my suggestions would

2 either be to match their criteria numbers -- how

3 to describe this -- it looks like you've got 80

4 and bigger. You've got up to 80 and then you

5 picked 55. Okay, so that covers the range that's

6 shown. It's not horrible.

7 DR. HEALY: And I think your point was -

8 - I don't know if this was your point, but if you

9 do a lower limit of 42 for the low, then that

10 means you're point of use has to go up to 42. And

11 it was DOE's opinion that that is too much for a

12 point of use water heater.

13 MR. KLEIN: I would observe that a water

14 heater that's capable of giving a half a gallon

15 per minute is going to give 30 gallons an hour,

16 and that would be a point of use water heater.

17 MR. BROOKMAN: That's ***12:17:12 (off

18 mic). Charlie.

19 MR. ADAMS: Charlie Adams. Not all

20 point of use water heaters are instantaneous.

21 We've got --

22 MR. KLEIN: I understand that.
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1 MR. ADAMS: You know, 10-gallon tanks

2 with 4-1/2-Kw and elements that are in the point

3 of use category, too.

4 MR. BROOKMAN: Frank.

5 MR. STANONIK: It'll wait.

6 MR. BROOKMAN: So wait? Okay.

7 Additional thoughts, comments here? Yes, Joe.

8 MR. BOROS: Joe Boros with Rheem. We

9 agree with the general approach of the first hour

10 rate, the categories. However, we're seeing the

11 first hour rate at 125 to be slightly different or

12 somewhat different than at the 135 set point, so

13 these values that are presented here, I would

14 suggest we may want to revisit to determine if

15 these appropriately translate at the lower

16 temperature.

17 DR. HEALY: Thank you.

18 MR. BROOKMAN: Harvey?

19 MR. SACHS: Harvey Sachs here, ACEEE.

20 With all due respect to those who have worked on

21 the UPC, I think there's been a great deal of

22 effort put into to developing these numbers and in
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1 developing other sets of numbers such as Mike

2 Gearebrandt's (ph) effort and the work of the HRI

3 and ESHROW (ph) committees. And if it winds up

4 that UPC is out of step with the world, then

5 that's not the greatest of my concerns right now

6 in terms of this categorization.

7 MR. BROOKMAN: Additional thoughts here?

8 MR. KLEIN: Yes, if I may?

9 MR. BROOKMAN: Gary, yes.

10 MR. KLEIN: Any water heater of any --

11 if it's a storage water heater, I can draw a high

12 flow rate out of it for a short duration if it's

13 small, right? So I'm confused about why the

14 maximum flow rate -- I don't get it. I'm confused

15 about something. I don't understand the piece of

16 the table that describes the maximum flow rates.

17 DR. HEALY: This will be the maximum

18 flow rate for an instantaneous water heater, so

19 the case you mentioned, a small volume water

20 heater that is not designed this continuous, that

21 would be a first hour rating test. So this would

22 be a water heater that's designed to continuously
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1 provide hot water.

2 MALE SPEAKER: This is meant to

3 differentiate the capacity?

4 DR. HEALY: correct.

5 MR. KLEIN: But if I put 4000 BTUs per

6 hour per gallon per minute -- per gallon into the

7 unit, then I have an instantaneous water heater

8 but I also have storage. And so I'm able to

9 provide continuousness. In fact, all water

10 heaters have a continuousness rate. They just

11 don't happen to be very big under certain

12 circumstances. 40,000 BTUs per hour is roughly a

13 gallon a minute of continuousness, but it's not

14 designed -- I could run it forever and get about

15 that many gallons per minute out of it.

16 MS. ARMSTRONG: Correct. It's --

17 MR. BROOKMAN: Frank.

18 MR. STANONIK: But Gary, this is simply

19 to tell you what test is going to be applied to

20 your product.

21 MR. KLEIN: Okay.

22 MR. STANONIK: And your question
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1 indicates what might seem to be confusing but at

2 the end point, I think that product -- again, that

3 product's going to end up being tested at the high

4 flow pattern. I mean we can run the numbers but I

5 think in almost all cases, you get to the same

6 input.

7 MR. KLEIN: Okay. And so the purpose of

8 this table is to make a decision as to which

9 category you get tested under?

10 MS. ARMSTRONG: Correct.

11 DR. HEALY: Yes.

12 MS. ARMSTRONG: Which draw pattern you

13 use.

14 MR. BROOKMAN: Tom.

15 MR. HARMAN: Tom Harman. What's the

16 definition of point of use?

17 DR. HEALY: It is defined based on the

18 first hour rating or maximum flow rate, so

19 wherever it fits in, that's how it would be

20 defined.

21 MS. ARMSTRONG: Right. So if you fit

22 those criteria, you would then go to the point of
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1 use draw pattern. If you fit into the, say, a 60-

2 gallon first hour rating, you know, and some

3 maximum flow rate, you would think go to medium or

4 some maximum -- you would go to medium. It's

5 meant to say how do you get to the next step of

6 what is my draw pattern. So when you run the test

7 -- these are based on rated values, but if your

8 rated value is such that it falls into this

9 bucket, this is how you know which draw pattern to

10 apply to run the test.

11 MR. BROOKMAN: Gary.

12 MR. KLEIN: All right. So now to one of

13 my next confusions. Point of use, when I use the

14 word, means location of the water heater relative

15 to the uses. It could be big or small. Sorry,

16 that's my definition and I use it because its

17 locational (sic) specific. Our terminology has

18 been point of use means something other than that.

19 Is point of use defined in our regs somewhere?

20 MS. ARMSTRONG: Go ahead.

21 MR. STANONIK: It's, in fact, defined by

22 these parameters. If the water heater essentially
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1 is low capacity, in other words it can't provide

2 1.7 gallons per minute heated to a 67 degree rise

3 -- this is current?

4 DR. HEALY: Correct, 67 degrees.

5 MR. STANONIK: -- 67 degree rise, okay,

6 then this saying that product is only suitable for

7 point of use use.

8 MR. KLEIN: So I guess I would like to

9 make a suggestion that we have instead of point of

10 use, low, medium and high, we have very small,

11 low, medium and high or something like that,

12 because it's about the capacity of the water

13 heater, not its location. Again, it causes less

14 market confusion when I have to teach what it

15 means.

16 MR. BROOKMAN: Steve Rosenstock.

17 MR. ROSENSTOCK: Steve Rosenstock, EEI.

18 If someone makes a product that's first hour

19 rating of 18 but the maximum flow rate is 1.8, do

20 they get to choose which draw they have?

21 MS. ARMSTRONG: No.

22 MR. ROSENSTOCK: No.
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1 MS. ARMSTRONG: So it gets to the point

2 of you'd use rated first -- our rating for storage

3 water heaters and then you use maximum flow rate

4 for instantaneous. So, Steve, your point is

5 really how do you figure whether you're storage or

6 instantaneous. Once you've down that, it's one of

7 the other to figure out which draw pattern you're

8 using. Okay?

9 MR. ROSENSTOCK: Okay.

10 DR. HEALY: So once we've characterized

11 them, then we run an energy factor test which is

12 still a 24-hour simulated use test. The draw

13 patterns would have different daily draw volumes

14 and numbers of draws that DOE feels better

15 captures how water is used in residences while

16 still yielding a test that we feel is repeatable,

17 so it's not overly burdensome.

18 First of all, right now the draw

19 patterns include a single flow rate of 3 GPM. DOE

20 is proposing to implement draw patterns with three

21 different flow rates. Also, the draws no longer

22 are a uniform length. There are a variety of draw
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1 lengths and there is also a variety of spacing

2 between the draws. And the attempt was made to

3 distribute the draws to mimic the timing of uses

4 in residences, so something in the morning,

5 something maybe around the evening and something

6 late at night. The volume and the number of draws

7 for each of the four draw patterns is shown on the

8 slide during the simulated use pattern. Frank?

9 MR. BROOKMAN: Frank.

10 MR. STANONIK: Frank Stanonik. He's

11 right. First of all, I think this is the

12 appropriate time. I want to echo what Harvey had

13 said much earlier this morning. We very much

14 appreciate what the Department has done up to this

15 point. I think, you know, the concepts and the

16 basic structure of what's being proposed we agree

17 with. We're just, I think, discussing things to

18 finish filling the glass.

19 Having said all that, in this particular

20 case, HRI had recommended that the total volume

21 for the medium draw be roughly 64 gallons. I just

22 want to explain our thinking there was that this
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1 is -- everyone recognize this is a huge change,

2 huge change and there are many ripples that are

3 going to come off this, more work for everybody

4 including the Department. Our purpose in keeping

5 it at 64 was at this point admittedly more of a

6 hope but an intent that at least for the, let's

7 call it, the bulk of products that have been

8 marketed as residential storage water heaters and

9 which many people have in their homes, the need

10 for the conversion factor might be minimized. And

11 so I would just perhaps ask again the Department

12 to think about we would maintain, you know, 64, 55

13 as Charlie said, there are 40 right ones. We think

14 64 would be one of the right ones also, granted

15 it's a little higher, but we think there may be

16 some other very significant benefits to keeping

17 that average water heater test close to something

18 what we're doing today for, again, let me call it

19 the standard water heater, whether it's a 40-

20 gallon gas or a 50-gallon electric or whatever.

21 MR. BROOKMAN: Steve Rosenstock.

22 MR. ROSENSTOCK: Steven Rosenstock. I'm
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1 looking at the actual patterns in the Federal

2 Register Notice on page 66216. Just a couple of

3 things and I'm just trying to get the process out.

4 I do think it's nice the way there are some kind

5 of peaks and valleys in terms of water heater

6 usage. I tend to support that. I have seen data

7 from utilities that did some end use metering

8 that, you know, the usages diurnal where there's,

9 you know, big water draw in the morning and then

10 at night when people, you know, getting ready for

11 work, coming home from work, etcetera.

12 But I'm just kind of curious. In terms

13 of this point of use pattern, it looks like it

14 shows just the constant flow rate versus a

15 variable flow rate for the other draw patterns and

16 then it's over a 9-hour period versus a 17-hour

17 period. I have another follow-up question. I'm

18 just kind of curious about the thought process in

19 terms of both of those compared to the other ones

20 where there is variability in the flow rate and

21 I'll say over a longer period of time.

22 DR. HEALY: One of the intensions was to
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1 minimize the number of flow rates that were

2 required to reduce the burden, so we felt that

3 three flow rates over the whole battery of

4 possible tests was an appropriate value. The

5 point of use pattern, therefore, we really

6 couldn't go above the 1 GMP for the single one.

7 So for example, we couldn't go up to 1.7 because

8 their point of use that by the maximum GPM rating,

9 they could not achieve 1.7. So we felt that it

10 wouldn't have made that much of a difference in

11 terms of the resulting energy factor by changing

12 flow rates.

13 To your second point, the point of use

14 draw pattern was based on input from comments and

15 it does mimic usage perhaps by a point of use

16 water heater which might not be used similar to a

17 whole house water heater might be used. But

18 that's the intention here, that they would be at

19 basically two peaks, about 8 hours apart.

20 MR. ROSENSTOCK: Thank you. That helps

21 a lot. I just want to kind of understand the

22 reasoning and the other question I had, the other
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1 though I had was, again, I know this is -- I

2 understand Frank's concern about, you know, having

3 one of them being 64 gallons to make it easier for

4 conversion and similarity, but I will notice, an

5 applied standards geek, that dishwasher standards

6 went up this year, efficiency water use which

7 limited water usage of dishwashers, clothes

8 washers go up, I believe in 2015, then again in

9 2018. I think there are studies that have shown

10 the average water use per day has declined over

11 time and these other appliance standards might

12 push that down anyway. Of course, there's the

13 water fixture standards that I think DOE is

14 working on as well. Was there any thought -- I'll

15 just say, you know, to leaving one of the patterns

16 at 64 gallons, of reducing the gallons for the

17 other ones because of these appliance standards

18 impacts?

19 DR. HEALY: No. I will say that most of

20 his is based on field data, especially the

21 excelling work done by Lawrence Berkeley National

22 Laboratory which showed these values, for example,
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1 the 55 and the 38, as being representative of

2 usage. So that's why we chose those. The high,

3 there wasn't as much data on that. We feel like

4 it's an appropriate value. We haven't taken that

5 specifically into consideration in the new

6 standards that you mentioned.

7 MR. ROSENSTOCK: Steve Rosenstock.

8 Thank you.

9 MR. BROOKMAN: Gary.

10 MR. KLEIN: To comment on the

11 characterization of the categories, I think I'd

12 recommend something like very small, small, medium

13 and large just to keep -- I was trying to work

14 through logic, not having had all this nice

15 discussion -- rather than point of use, low,

16 medium and high. But my key point is on the point

17 of use, it should be renamed.

18 And then to the draw patterns that are

19 shown, I think that the flow rate -- how to

20 describe this -- on the ones with stored volume,

21 right, the ones that are going to go under the

22 volume portion of the test, there is going to be
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1 biggish draws and smallish draws, right? The

2 category doesn't require that the -- bear with me

3 a minute -- if I have a 2- gallon storage water

4 heater, because I don't have the high enough input

5 rate, it's going to be tested as 2 gallons, right,

6 as a storage water heater? I won't be able to

7 take 2 gallons of hot water out of it, won't

8 happen.

9 DR. HEALY: I forget if it's less than

10 or equal to, but are you saying it's a 1.99 or a

11 2.001 --

12 MR. KLEIN: Well, just under 2.

13 DR. HEALY: Just under 2, okay.

14 MR. KLEIN: But it's got a BTU rating

15 that doesn't make it instantaneous; therefore,

16 under the current discussion, it's a very small

17 water heater that's intended for a point of use,

18 tiny admittedly, right, but I can't draw two

19 gallons out of it of hot water. It's not -- I

20 don't think it's physically capable of pulling it

21 out unless the re-heat rate is high enough and if

22 it's not, I'm pretty sure it won't be able to, so
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1 I'm going to fail the test to start with. I won't

2 be able to take heated water out. It won't meet

3 the criteria of hot enough out.

4 DR. HEALY: As far as -- from my

5 recollection, I don't think there is anything in

6 there that precludes that. So you're saying

7 outlet water temperature is going to drop from 125

8 to some other temperature.

9 MR. KLEIN: Below 110.

10 DR. HEALY: The way it's written now is

11 that you still compute the energy removed based on

12 those outlet temperatures. And so right now, the

13 way you set the thermostat to deliver water at

14 125, if the water heater does fall below that 120

15 level, you still run the test and you consider

16 that thermal energy delivered in the water as part

17 of the calculation.

18 MR. KLEIN: Right.

19 MR. STANONIK: Two comments on both

20 Steve's comment and Gary's comment. Again, the

21 big change we're making here is, in fact, to, if

22 you will, perhaps emphasize more strongly the need
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1 for proper sizing in selecting water heaters in

2 residential applications. So the issue of whether

3 other products in the household are using more or

4 less hot water doesn't necessarily effect what

5 total amount I use to test the water heater. What

6 it should effect is what water heater that

7 household selects for its use. And so if they do

8 have a new washer and a new dryer, and they

9 perhaps have had historically a 50-gallon

10 electric or 40-gallon gas, if we ever get to that

11 point, they may realize well, when I replace it,

12 and there are only two people in the house, maybe

13 I only need a 40-gallon electric or a 30-gallon

14 gas with some reasonable input. But I mean the

15 things you're -- the trends you're talking about

16 may move more residences to have quoted, unquote,

17 the low-use water heater rather than the medium.

18 And then to Gary's point which -- the

19 thing I think we need to hopefully recognize, low,

20 medium, high category water heaters, those are

21 intended to be central units. Those are intended

22 to be units that will fulfill the needs of a
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1 household. The point of use or whatever we want

2 to call it is not intended for that. It is

3 intended to be only used -- to have limited points

4 of use or limited connections lets cal them, and

5 so that's the big distinction.

6 MR. KLEIN: I hear that. It's just

7 exceedingly confusing water heaters en someone

8 asks me what size water heater to put where.

9 Ideally, you would actually put a big water heater

10 near a big point of use if it's far from other big

11 or small point of water heating need. And so

12 that's part of the problem, so.

13 DR. HEALY: I think w got it. Yes, got

14 it.

15 MR. BROOKMAN: Are there any -- so I

16 think we've addressed all comments to this point?

17 MALE SPEAKER: I think we had one more.

18 MR. KLEIN: Okay, on this one. On the

19 flow rate rated water heaters, under the point of

20 use pattern that's here, I think that a fair

21 number of the products have a minimum flow rate

22 that they can sustain if they're instantaneous
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1 points of use water heaters. And I think that

2 they need to be tested at their minimum --

3 whatever that minimum number that they're capable

4 of sustaining is is approximately what they need

5 to be tested at at the low end so that they're --

6 they only have certain capability and you can't

7 test them below that capability and they may have

8 an upper bound above which you can't test them.

9 But picking -- I'm not sure how I'm supposed to

10 pick this here. If I was -- I'm not trying -- I

11 don't understand how I'm supposed to --

12 DR. HEALY: Well, for a water heater

13 which maximum GPM is below one, you can't expect

14 to have a flow rate of one, so DOE is proposing to

15 test at that maximum GPM during the energy factor

16 test, the simulated use test.

17 MR. SACHS: This is Harvey. Bill, I

18 think Gary's asking a separate question. If I

19 caught it right, he's asking for a second metric

20 for performance at minimum flow rate, and I think

21 that gets us into the whole question of dual

22 metrics and things like that, or am I
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1 misunderstanding?

2 MR. KLEIN: I'm confused at the moment.

3 We'll leave it at that.

4 DR. HEALY: Right now it's a single

5 metric energy factor. For a point of use water

6 heater, it would be tested at a single flow rate

7 which would be the maximum GPM if the maximum GPM

8 is below one. There's no provision to have a

9 second test at the minimum GPM.

10 MR. BROOKMAN: Frank, go ahead.

11 MR. STANONIK: Frank Stanonik. He's

12 right. Are you suggesting that some of the -- in

13 the draw pattern for the point of use, whatever

14 we're going to call it --

15 MR. KLEIN: You can continue to use

16 point of use for today.

17 MR. STANONIK: Are you suggesting that

18 the draw pattern should include some draw rates

19 that are maybe a half a gallon of two-thirds of a

20 gallon or something different than one?

21 MR. KLEIN: Yes, and I'll give my

22 reasoning. The small water heaters that we're
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1 describing here are almost never used in single2 family homes. They're added in somewhere. I see

3 them more often in commercial applications, my

4 dentist's office, whatever it might be, or even

5 the airport, right. So I see that this category

6 is used where the water demands are small whether

7 they're small in quantity or small in current flow

8 rate, whatever that is. So a fair number of these

9 heaters are put under sinks with half GPM

10 airoraters. If I'm going to put them under a sink

11 with a 1-1/2 or a 2 GPM airorater called my

12 private lavatory, which is the application

13 describing, right, then I have to be able -- I'm

14 going to have flow rates of that water heater that

15 are higher than one. And so I need to be able to

16 test the range that it's going to serve if it's

17 the same purpose.

18 I realize it's not central water

19 heating, but the category of water heater we're

20 describing gets used for 3/8 gallon per minute

21 flow rates, water gallon per minute, 1/2 gallon

22 per minute, all the way up to, in principle, 2.2
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1 legal. And so the distinctions we've made in this

2 category don't, in my opinion, yet cover the

3 nature of where it's going to be served.

4 MR. BROOKMAN: Charlie.

5 MR. ADAMS: I think we got to be careful

6 trying to apply that only to point of use. I

7 think we need a single rating point for each

8 category. I can make an argument that a whole9 house storage heater, I can put a heater in a

10 house with a family that lives there and it's

11 exactly the right application and is sized for

12 that amount of water use, and they sell the house

13 and a single person that's an airline pilot that's

14 never there moves in, then all of a sudden, it's

15 the wrong application. So we still need to not

16 try to put the application of where it's going to

17 be used and what's its possible applications can

18 be under this. We need a rating point that is

19 measured by -- that a comparison can be made by.

20 MR. KLEIN: Fair enough and I'm not

21 attempting to try and put it in an application.

22 I'm trying to describe the application -- need to
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1 think -- sure that the test process -- that the

2 volumes in the pattern are correct.

3 MR. BROOKMAN: Final comment, Tom.

4 MR. HARMAN: I was going to say to your

5 comment, then the point of use is talking about a

6 location if I look at it that way, which is

7 exactly an application. I mean I guess my idea is

8 when you talk about point of use, I mean it's

9 sitting here and I'm using it there. That's not

10 necessarily how some of these are used though,

11 right, not necessarily the way all of them used?

12 You're talking about an application --

13 MS. ARMSTRONG: Ready?

14 MR. BROOKMAN: We're moving on.

15 MR. HARMAN: -- an application where

16 everybody else is talking about a flow rate.

17 Well, whatever.

18 MR. BROOKMAN: Okay. Go on.

19 MS. ARMSTRONG: Okay. So, I am going to

20 move on from our draw patterns to maybe an equally

21 talked about topic of rated values.

22 So, due to some of the changes we've
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1 made to the test method, especially since the draw

2 patterns and such will now be based on the first

3 hour rating or the max GPM, DOE proposed to

4 establish rating requirements for storage volume

5 for first hour rating and for maximum GPM.

6 We put the new requirements in 429 which

7 is where you can find our rating requirements for

8 water heaters today. And we did this because of

9 several reasons. One is you test multiple samples

10 and we understand those samples can give you

11 different numbers, so we provide an averaging.

12 And then we had 63 water heaters tested at

13 independent labs over the past couple of years.

14 We understand that AMSE and you all (ph) standards

15 prescribe allowable differences between the

16 measured volumes and the rated volumes. And so DOE

17 proposed to require that any representative value

18 of rated storage volume must be calculated as the

19 mean of the volumes within the units of the

20 samples.

21 And so this is what we found when we

22 tested. These are the electric water heaters. We
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1 found a range in between 5 percent to 10 percent

2 difference in storage volume and that only went

3 one way, that the rated storage volumes were

4 always over-stated as compared to their measured,

5 on average about 9.4 percent.

6 And the same thing happened for gas. We

7 tested about 44 of them. They were between 1.5

8 and 15.6 percent higher, on average about 4.8 and

9 obviously, it also only went one way. The rateds

10 were always over-stated.

11 So, our proposal would make the rated

12 volumes equal to the measured volumes of the

13 sample.

14 MR. BROOKMAN: Frank.

15 MR. STANONIK: And the problem you

16 believe you're trying to solve is what? Let me

17 follow-up. In the case of a water heater, the

18 consumer is buying a product that has a certain

19 capability to provide heated water. It's not like

20 you're going to the grocery store and buying a

21 gallon of milk or a 6-pack of beer and you expect

22 to get -- you bought the volume of whatever
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1 product you purchases. A 40-gallon gas water

2 heater, whether it's actual volume is 38 or 39 or

3 40 or whatever, those products across the industry

4 all essentially represent products that have the

5 capability to deliver heated water like a 40-

6 gallon gas water heater, same situation with a 50-

7 gallon electric. And so the suggestion that DOE

8 is going to impose on the industry that rated

9 volumes will now be the average of the measured

10 volumes is an incredibly huge shift that without

11 major justification -- there's no other way to put

12 it -- is unacceptable.

13 MR. CYMBALSKY: This is John Cymbalsky

14 from DOE. So let's just flip that around. So why

15 isn't a 50 a 50? I'm sorry, I'm just -- and you

16 know, what strikes me from what we've tested is

17 that not only is a 50 not a 50, but a 50 is almost

18 exactly the entire tolerance band of what you're

19 allowed to rate at. So I guess -- I understand

20 from your remarks that this is standard industry

21 practice, the data bears that out, and I guess,

22 you know, I'm going to take off my DOE hat for a
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1 second and become a consumer and say, "Why would a

2 water heater be any different than, say, a clothes

3 washer? If I look for 10 cubic foot of washing

4 capability and I know my bedspread needs 10 cubic

5 feet and I go and I buy one that's 10 cubic feet

6 and I come and it doesn't fit and there's an extra

7 cubic foot hanging out the top -- and I know these

8 aren't directly comparable, but I guess what I'm

9 asking is what's the reason for almost every water

10 heater that we looked at in our sample to be

11 almost exactly at the tolerance level.

12 MR. BROOKMAN: Charlie.

13 MS. ARMSTRONG: This is Charlie Adams,

14 A.O. Smith. As a consumer, you don't really care

15 -- you're not buying a can that holds 50 gallons

16 of water. You're going to use 67 gallons of water

17 an hour and you want to device that's capable of

18 delivering 67 gallons an hour.

19 MR. STANONIK: Is that to do his

20 bedspread.

21 MR. ADAMS: Could be. So what we are

22 selling you is a can that is capable of heating
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1 water that will deliver your 67 gallons of an hour

2 first hour rating which is what you're really

3 interested in, and we're calling it a 50, and

4 under the allowable criteria that's imposed upon

5 the industry on how we measure that, the can may

6 hold 45 gallons or it may hold 50 gallons or it

7 may 52 gallons, and we're going to call it a 50.

8 So we're still providing the utility that you're

9 actually going to buy, which is somewhat different

10 than your washing machine example.

11 MR. CYMBALSKY: Okay. But you are

12 saying that a 50 is not a 50, it's a 45 in the

13 industry based on the data here?

14 MR. ADAMS: It can be we can have a 50

15 that holds 52.

16 MR. CYMBALSKY: All right. Well, we

17 haven't -- that's -- don't see that here but --

18 MR. BROOKMAN: Frank, keep going.

19 MR. CYMBALSKY: But wait a minute. I'm

20 not done yet.

21 MR. BROOKMAN: (Off mic)

22 MR. CYMBALSKY: So I guess my question
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1 is why is the tolerance there? The data here

2 shows me that everyone can build with a very

3 little variance to a measured volume. It's just

4 that they're reporting it 10 percent. I mean this

5 is the way the data read. It's just being reported

6 10 percent higher than what it holds, and so I

7 guess my question is why not just say it's 45 if

8 it's 45? Why say it's 50?

9 MR. STANONIK: Okay, first of all, the

10 allowable tolerance on the difference between

11 measured and rated volume has its origins in the

12 safety standards and well, you know --

13 MALE SPEAKER: Describes to me why it's

14 unsafe if you call a 50 a 50?

15 MR. STANONIK: Okay. Well -- but let me

16 -- all right, so, that has been there since the

17 early days of the safety standards --

18 MR. ADAMS: Can I make a quick comment

19 for clarification?

20 MR. BROOKMAN: Charlie.

21 MR. ADAMS: This is Charlie Adams.

22 Before you guys came along, the standards were
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1 safety and performance.

2 MR. STANONIK: That's exactly where I

3 was going to go but, but the standards originally

4 started out to be more than just safety. They

5 were safety and performance. So in fact, going

6 back further than anyone I think in this room goes

7 back, for whatever, you know, reasons they would

8 put in, they were requirements put in that said,

9 okay, your measured volume in the case of the gas

10 standards has to be within five percent of the --

11 nameplate rated volume for electric, it was 10

12 percent, okay.. And so we're talking about

13 something that goes back probably into the 1950s,

14 maybe 60's. I don't know, okay. And so that was

15 there and no question manufacturing techniques

16 were different, all right. So this is just a

17 vestige that's been brought forward and it's not

18 been changed in the safety standards, again,

19 because the issue is really not whether the

20 consumer receives 40 gallons of water or 38

21 gallons of water. In terms of storage water

22 heaters, it is just a reflection of water heaters
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1 that have a certain capability and, you know, that

2 would get compared to comparable water heaters

3 that have similar capability.

4 And one other thing to think about is

5 not so much in the case of electrics but in the

6 case of a 40- gallon gas product, okay, here's

7 another reason why it's not that important.

8 People used to make -- I don't know if anybody

9 still makes one -- used to make a 40-gallon gas

10 that only fired like a 28,000 BTUs per hour, maybe

11 26,000 BTUs per hour. That 40-gallon water heater

12 did not have the same capability as the 40-gallon

13 water that used to fire at like 55,000 BTUs per

14 hour. So the question of the size of the water

15 heater was absolutely secondary. The input became

16 much more significant.

17 So in any case, I mean, that's just the

18 history and so as the industry has evolved and

19 manufacturing techniques improved, the tolerance

20 was there in the safety standard. You've seen the

21 data, okay. Most everyone does hit at the

22 tolerance. Offline, I'd love to know who the heck
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1 built two water heaters that were that far off,

2 okay. That, to me, is defective. That's not

3 normal. But be that as it may -- and so that's

4 just where we are. And again, it is not any kind

5 of -- if you will, in the final point of what the

6 consumer gets, it's not a misrepresentation.

7 MR. CYMBALSKY: So if the consumer

8 doesn't care and nobody cares but the data say

9 that a 50 is a 45, why don't we call it what it

10 is? I mean I guess I'm still -- I appreciate the

11 history here but the data show me that you guys

12 can really be very consistent about what the

13 volume is on your water heater.

14 MR. BROOKMAN: The manufacturers first.

15 Charlie and then to George.

16 MR. ADAMS: What determines the measured

17 volume -- and let's take a 40-gallon gas -- that's

18 a good example -- manufacturers are going to tool

19 up a top and bottom head for a 40-gallon tall unit

20 that's 16 inches in diameter, okay. And we're

21 going to shear the blank for the shell of the tank

22 and weld it to stuff the heads in it and stick a
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1 flue up the middle of it. In a given 40-gallon

2 size tank, to Frank's point, we can have a 28,000

3 BTU per hour or a 60,000 BTU per hour. One of

4 those takes a 3-inch diameter center flue. One of

5 them takes a 5-inch diameter center flue. Most

6 everything in between takes a 4- inch diameter

7 center flue. When you stick the little cylinder

8 up the center of the big cylinder, that changes

9 the water capability some. In a manufacturing

10 process, if you shove the top head down a little

11 further than you intended but still within

12 tolerance, and the bottom head up a little

13 further, you've reduce the effective height of the

14 cylinder ability to hold water. If you shear the

15 wrapper for the outer shell shorter or longer and

16 then shove the heads in slightly different and

17 then put a different size tube in it for your 40-

18 gallon heater, under the approach you guys are

19 proposing, we may have a 37-gallon heater or a 41-

20 gallon heater and it's all over the place.

21 And if we advertise it as that, you as a

22 consumer go in and you want a 67-gallon first hour
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1 heater, that's what you really want to buy, you're

2 interested in how much water comes out. Well, do

3 I want to buy this 37-gallon or a 39-gallon? Why

4 is that one 51. It's easier and it's less

5 confusing to the consumer that here's a 40-gallon

6 heater, here's the options in 40-gallon heaters.

7 This one supplies 67 gallons. This one doesn't.

8 You need 67 gallons, you should buy this 40-gallon

9 heater, not that one. And we utilize the only

10 requirement and method of test that the industry

11 has ever had, which is what's in the safety

12 standards, safety and performance standards

13 originally, to get there.

14 So it's not to cheat and get around --

15 you know, we've all done the math. A 50-gallon

16 electric heater today is supposed to be 90. A 45-

17 gallon heater today is supposed to be 91. We're

18 not doing it to cheat that other point and not

19 have to get there, because we know how to do it.

20 We're selling it, representing and delivering it

21 and the people are buying it and using it as a 50-

22 gallon heater that has the performance of a 50-
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1 gallon heater. And if we put different elements

2 in it, we might displace more or less water and

3 change it if we're going by -- we put a fatter

4 anode in it, we're going to displace some water.

5 So our high warranty heater with a fat anode may

6 hold less water than the standard warranty heater

7 with a little anode in it, and if we have to

8 measure that and report on that, we're going to

9 confuse everybody.

10 MR. BROOKMAN: George, you're next and

11 then to Tom.

12 MR. KUSTERER: I agree with Charlie. I

13 mean from a manufacturing standpoint of view, I

14 can make 50 water heaters off the same line and

15 each one is going to have a different rated volume

16 simply because of what Charlie said. You got an

17 8-ounce coffee cup. If you can't get 8 ounces,

18 are you going to complain about it? Probably.

19 Yeah, you're shaking your head and I agree.

20 ***12:57:45(Crosstalk)

21 MR. KUSTERER: Your car has a

22 speedometer that goes to 160 miles an hour. Are
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1 you going to make sure that it goes 160 miles an

2 hour? I don't think so. But again, it's not what

3 goes into the heater, it's what comes out of the

4 heater. And as far as using a clothes dryer as an

5 analogy, I'll tell you what, if it's 9 point

6 whatever, I'm going to stuff that blanket in

7 there, so don't --

8 (Laughter)

9 MR. KUSTERER: The consumer doesn't

10 care. Now, the other big burden is we as

11 manufacturers, am I going to have to test every

12 heater that comes off my line to give it a rated

13 volume? Am I going to have to put out every piece

14 of literature that's going to say this tank is 37

15 gallons, this thing is 38-1/2 gallons? I mean is

16 DOE getting ridiculous or what?

17 MR. CYMBALSKY: I mean I get that point

18 but I guess I keep looking at these graphs and you

19 say this and that with the manufacturing, but

20 clearly there's not -- it's not hard to

21 manufacturer these things to the exact measured

22 volume here. I mean I'm not seeing that in the
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1 data. Now if you had some variance along the 10

2 percent or the 5 percent depending on the water

3 heater type, I'd say, look, guys, I get it; it's

4 hard to get these things to the right volume but,

5 in fact, that isn't the case from the data and

6 it's -- the only difference here, from what I've

7 heard, is you've done it this way always and you

8 had this tolerance always. But the fact is you

9 build your mold for a 50-gallon tank and it either

10 holds 50 gallons of water or it holds 45 gallons

11 of water. Clearly, everyone here has figured out

12 how to make it hold 45 gallons of water, the data

13 say that, and --

14 MR. BROOKMAN: I wish to speak here.

15 I'm going to let Tom go in the queue and then I'm

16 going to go back to George and then Philip and Don

17 also.

18 MR. CYMBALSKY: And my last question.

19 At some point, if you can relate it back to why

20 this is important in a safety standard, if someone

21 can add -- I mean because I'm all about safety.

22 So if you can tell me how that relates to safety,
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1 too, that would be good for the public record.

2 MR. ADAMS: Performance standards.

3 MR. BROOKMAN: Tom.

4 MR. HARMAN: Let's go back to the

5 electric one. I think it's more illustrative of

6 this, because Charlie raised the point about the

7 difference in the flue diameter and the anodes --

8 to me, don't take up anywhere close to a 5-gallon

9 differential in terms of fatness. So in the

10 electric side, this is a pretty consistent line,

11 and what's striking to me is it's all positive.

12 Manufacturing tolerances are plus or minus, so why

13 is it always, on both these charts, positive?

14 MR. ADAMS: Well, again, the safety

15 standards --

16 MR HARMAN: I mean Charlie was talking

17 about this one and this one. That's a plus and

18 minus.

19 MR. ADAMS: The safety standard criteria

20 was always that the measured volume could not be x

21 percent less than the rated. That was the only

22 criteria. And so I can't, again, can't talk about
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1 what might have been going on 40-50 years ago, but

2 certainly in recent times, the manufacturers' only

3 concern was that my measured volume was not too

4 small.

5 MR. BROOKMAN: Philip, you're next.

6 MR. STEVENS: I just had a question

7 about your sample selection. I think that may

8 have something --

9 MR. BROOKMAN: Let's -- no. I --

10 MS. ARMSTRONG: Other questions.

11 MR. BROOKMAN: Okay. I thought you were

12 shifting it. Okay.

13 MALE SPEAKER: No, no, no.

14 MR. STEVENS: No. For the volumes.

15 MR. BROOKMAN: Okay.

16 MR. STEVENS: There are a tremendous

17 number of models. Did you simply pick the high

18 runners, because those are the ones that most

19 manufacturers build --

20 MR. CYMBALSKY: No, not at all.

21 MR. STEVENS: -- their products off of.

22 MR. CYMBALSKY: Completely random
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1 selections.

2 MR. STEVENS: Okay.

3 MS. ARMSTRONG: It's a variety.

4 MR. CYMBALSKY: A variety of

5 manufacturers, a variety of models, a variety of

6 energy factors.

7 MR. STEVENS: Okay. For our case, I

8 know we don't have any center flues in our

9 products, so we literally use the same top and

10 bottom head and for the majority of our products

11 the same shells, for our gas- fired products, for

12 our electric products, for our indirect water

13 heaters. And every one of those heat exchangers,

14 everything that goes inside of the product

15 consumes a different volume just like Charlie was

16 mentioning. So when you get to the point of

17 checking our products, you're probably going to

18 see plus and minus. It's going to be all over the

19 place but it's within the accepted industry

20 practices.

21 MR. CYMBALSKY: Right, and I understand

22 that. But going back to the variance in the
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1 manufacturing, I mean you don't have to answer

2 this if you don't want, but I mean would you say

3 it's difficult for you to -- and again, the data

4 doesn't show me this -- but is it difficult as a

5 manufacturer to say I'll build a measured 50-

6 gallon gas water heater? Is it hard for you to do

7 that over and over again or not?

8 MR. BROOKMAN: Yes, George, you're next.

9 MR. KUSTERER: All right. Yes, my

10 question to you, John, have you ever seen a water

11 heater manufactured?

12 MR. CYMBALSKY: ***13:03:00(Off mic)

13 MR. KUSTERER: No, no, no, manufactured.

14 MR. CYMBALSKY: Yeah --

15 MR. KUSTERER: I know she has. Have

16 you? I strongly invite you to visit Bock Water

17 Heaters so you can see how water heaters are

18 manufactured, and I think that will answer all

19 your questions.

20 MR. CYMBALSKY: Okay. And again, I go

21 back to the data that, again, if there is a large

22 --
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1 MR. KUSTERER: Sir, the data --

2 MR. CYMBALSKY: -- variance around --

3 MR. KUSTERER: -- doesn't mean anything.

4 It's real life how we manufacture water heaters.

5 MR. CYMBALSKY: I get that but when we

6 measure them, there is zero variance in what the

7 measured volume is. So I'd -- to me, that says

8 that you guys can build them to a volume that

9 you're picking unless I'm missing something in the

10 data.

11 MR. BOROS: Joe Boros with Rheem. I'd

12 like to go back to the question that Frank

13 Stanonik asked originally. What is DOE's intent

14 in controlling this capability or this

15 requirement, adding this requirement? How does

16 the variance that you're seeing in the measured

17 capability affect the efficiency of the product?

18 During the test, we measure the actual capability

19 and we use the actual capability to run the

20 calculations. The product that is selected and

21 measured, the actual volume is reflected in the

22 calculations. So I don't understand where that
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1 variance is actually affecting the efficiency.

2 That's the first question.

3 The other is through the data, it's

4 clear that we are complying with a safety standard

5 and that standard includes construction

6 provisions. And one of the construction

7 provisions is the tolerance that's in there. And

8 if it's deemed that that tolerance should be

9 tightened, I think there's a method, a form

10 through the AMSE standards process to do that.

11 Again, I don't understand DOE's intent in making

12 the adjustment here and adding this as an

13 additional requirement.

14 MS. ARMSTRONG: So, I'm actually going

15 to turn the question back around on you a bit.

16 What happens -- and so now that we're moving to at

17 least the proposal goes to move to different

18 patterns based on measured first hour -- well,

19 it's rated in there not but let's say it's

20 measured for the purposes of this discussion, and

21 I pull a unit and I get a different answer than

22 you did. I pull a unit for a test and that
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1 automatically throws me to a different bucket for

2 my draw pattern, what do I do?

3 MR. BOROS: Joe Boros again. You would

4 pull a unit and the first thing you would do is

5 measure the first hour rating.

6 MS. ARMSTRONG: That's what you have to

7 do determine which --

8 MR. BOROS: Yes.

9 MS. ARMSTRONG: -- draw pattern. And

10 I'm saying you used one because you got a certain

11 measured first hour rating. And what I'm hearing

12 from the room is that those numbers, whether it be

13 volume first hour rating, max GPM, are not that

14 repeatable. What if your teetering right on that

15 line and I get a different answer?

16 MR. BOROS: Ultimately --

17 MS. ARMSTRONG: Should I run a different

18 pattern and that's what you go for compliance?

19 That's what you're measured against?

20 MR. BOROS: Ultimately, the first hour

21 would be tape based on the proposal that we have

22 here. It's the first hour measurement that would
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1 tell us which draw pattern to follow.

2 MS. ARMSTRONG: So we did it based on

3 rated and there was a reason for that.

4 MR. BOROS: If you pulled a unit that

5 did not meet the first hour that was claimed --

6 MS. ARMSTRONG: What does that mean

7 though? What does it mean to not meet the first

8 hour that is claimed? That is what we're trying

9 to do here. We put bounds about what the claims

10 could be because if we go down to a situation,

11 we're picking draw patterns and if get different

12 answers, compliance is going to be a very

13 different thing if I'm running a different draw

14 pattern than you are.

15 MR. BROOKMAN: Charlie:

16 MR. ADAMS: I think we're mixing a

17 couple of things here. But to answer your

18 question, if I claim a first hour rating and you

19 pull it and you don't get the same first hour

20 rating, then I haven't met a performance claim but

21 you're not -- so we get to use yours.

22 MS. ARMSTRONG: With what tolerance?
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1 MR. ADAMS: Pardon?

2 MS. ARMSTRONG: With what tolerance?

3 MR. ADAMS: Well, let's -- we'll get to

4 first hour in a minute, okay, but back to the

5 rated storage volume, what's that got to do with

6 how you're going to select making the test? If

7 you can get -- if I have a rated first hour out of

8 a 50-gallon heater that holds 48 gallons, but I

9 meet my first hour rating, you're going to run the

10 same cycle SUT test that I did and get the same

11 result.

12 MS. ARMSTRONG: It matters because what

13 standard applies.

14 MR. ADAMS: Why? How?

15 MS. ARMSTRONG: Because the EF is a

16 function of rated storage.

17 MR. ADAMS: What's that got to do with

18 rated storage volume? Nothing. First hour

19 controls.

20 FEMALE SPEAKER: No.

21 MS. ARMSTRONG: First hour is the draw

22 pattern.
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1 MALE SPEAKER: I think I just heard

2 something.

3 MS. ARMSTRONG: So EF is not.

4 MR. BROOKMAN: I'm turning away from the

5 manufacturers here momentarily. Steve and then

6 Gary.

7 MR. ROSENSTOCK: I think Don was in the

8 queue first. I think there were a couple of

9 people --

10 MR. BROOKMAN: Actually, thank you.

11 Don, you're in the queue.

12 MR BRUNDAGE: Well, I've got a totally

13 question related to the manufacturing issues.

14 When you run those to ground, I'll come back to --

15 MR. BROOKMAN: Stick with this to ground

16 first. Steve.

17 MR. ROSENSTOCK: Okay. Steve

18 Rosenstock, Edison Electric Institute. A couple

19 of things I want to say. Again, as an appliance

20 geek, just got the latest Consumer Reports, had a

21 thing about refrigerators. You have a 25-cubic

22 foot refrigerator and 29-cubic foot refrigerator.
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1 Consumer Reports says they're measurements.

2 Sometimes that 29-cubic foot refrigerator has less

3 storage space than the 25-cubic foot refrigerator.

4 And we're talking about 30 or 40 percent lower

5 than what they're advertising. That happens in

6 the marketplace. That's one thing. Consumers are

7 used to it. Consumers are used to not everything

8 being perfect as advertised. I'll just say that

9 as a consumer.

10 Second thing I wanted to say is under

11 the 2015 standard for electric water heaters under

12 55 gallons, if you're 50 gallons, I did -- you

13 know, that .96 minus .003 times volume, at 50

14 gallons, it's .945 energy factor. At 30 gallons,

15 it's .951. And at 45 gallons, it's .9465.

16 They're all rounded to .95. In terms of energy

17 factor, does it really make a difference? They

18 still have to meet that .95 whether at 50 gallons

19 or 45 gallons. Or am I missing something?

20 MR. BROOKMAN: Gary.

21 MR. KLEIN: I think I heard, when Ashley

22 just spoke, what the question they're after here
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1 is. And Ashley, correct me if I'm wrong but I

2 think that part of the reason for this concept

3 you've proposed is to determine whether you fall

4 within commercial, light commercial or residential

5 standard for test, not the first hour rating

6 question. And so the first hour rating will tell

7 us which bucket you fall in for the uniform

8 descriptor standard. But if I heard you right,

9 the rated volume determines whether you are at the

10 break point to go into the commercial category.

11 That's what I thought I heard in the discussion.

12 MR. BROOKMAN: Charlie.

13 MR. ADAMS: Charlie Adams. To respond

14 to Gary's comment, volume was taken out of the

15 criteria for determining applicability of

16 anything, right?

17 MS. ARMSTRONG: That's not correct. By

18 default, the -- I mean in the regs -- in the

19 statute, the statute has volume. We cannot take

20 that out in the definitions.

21 MR. ADAMS: Right.

22 MS. ARMSTRONG: So what is that compared
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1 to? I mean he's got a point, right? I mean if you

2 -- yes, we took it out in the terms of providing a

3 uniform descriptor and a uniform test method, but

4 you need it to determine where you fall for

5 standards.

6 MR. ADAMS: Whether you're NECA or EPAC

7 covered?

8 MS. ARMSTRONG: Absolutely.

9 MR. ADAMS: Okay. I'll give you that.

10 MR. CYMBALSKY: So let's assume for a

11 minute it's May 2015 and you make a water heater

12 that measures exactly 55 gallons. Will you rate

13 that at 60, because if you do you'll fail the

14 standard. Just saying, because it has to be a

15 heat pump, right, at that point in the equation,

16 right? So if you're over 55 gallons, you're

17 required to meet the 2.0 energy factor.

18 MR. ADAMS: If my rated storage volume

19 is over 55 gallons, then I have to meet the

20 equation.

21 MR. CYMBALSKY: So if you make 55's, I

22 guaranty you this won't happen and --
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1 MR. BRUNDAGE: That was my question that

2 I was deferring until later --

3 MR. CYMBALSKY: Right.

4 MR. BROOKMAN: Don.

5 MR. BRUNDAGE: -- which is suppose you've

6 got a water heater out there, retail for sale

7 rated at 60 gallons, electric water heater, it's

8 very tight tolerance that's over rating the

9 capability by 9.4 percent, so that will measure

10 out at 54 gallons or 55 gallons measured

11 capability, so is what you're saying is what's

12 currently on the market, typically a 60- gallons,

13 will probably get rated under this new definition

14 a 54 or 55 and could be sold as a resistance water

15 heater? You're not redoing -- when you do the

16 reshuffling, you're not redoing that part, are

17 you?

18 MR. CYMBALSKY: Right. So that was just

19 my last point that I guarantee you that they won't

20 do that come April 2015. If they would, they'd

21 have to make it as a --

22 MR. BRUNDAGE: It's what they rate it.
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1 That's why I find this opposition ***13:13:06 kind

2 of puzzling, because I think it's actually going

3 to help them --

4 MR. CYMBALSKY: Only when it hits that

5 point. Only when --

6 MR. BRUNDAGE: For those right in that

7 area, it helps them a great deal.

8 MR. BROOKMAN: Go head, Frank.

9 MR. STANONIK: One thing I think is very

10 important here, and I think John's made -- sorry

11 to get personal -- but I think you made a little

12 bit of a leap here in logic, okay. DOE ran tests

13 on individual models and saw that in this basket

14 of models, low and behold, they were electric.

15 They all came in around less than 10 percent, gas

16 less than five. What you didn't do, and in what

17 some of what's been discussed, is -- and I'm not

18 suggesting you do this, okay -- but as an example,

19 you didn't look at a Rheem production run or an

20 A.O. Smith production run where they just produced

21 over the last day and a half thousands of a 40-

22 gallon gas water heater and measured the volume of
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1 every one of those. Because John asked a question

2 --

3 MS. ARMSTRONG: Exactly.

4 MR. STANONIK: -- asked a question why

5 can't you rate it at exactly the measured volume,

6 and my point is that this measured volume is not

7 an exact number. Over the course of mass

8 producing whatever size they produce, okay,

9 there's going to be variation. It can't be exact.

10 MS. ARMSTRONG: Right, and --

11 MALE SPEAKER: ***13:14:31(Off

12 mic/crosstalk) out here?

13 MS. ARMSTRONG: So what I think we're --

14 so I think that's why he asked the question. What

15 is that variation?

16 MALE SPEAKER: I'd like to know.

17 MS. ARMSTRONG: What we're seeing -- I

18 think we're trying to differentiate between the

19 variations for the identical product. You're

20 making the same flue, same top, same bottom, same

21 rounds, what is the variation unit to unit coming

22 down the line versus, you know, more or less same
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1 end shields, same wrapper but you're changing out

2 the end sides or you may be doing slightly things

3 which are impacting the measured volume plus or

4 minus a gallon here or there, but you're

5 fundamentally doing different design changes so

6 you can offer a variety of, say, inputs maybe but

7 the same rated volume. So we're trying to

8 differentiate -- what the data doesn't s how here

9 is the difference between the two, and so what

10 John was asking earlier is what is the variance in

11 actual volume for a given unit.

12 MR. STANONIK: Actually, first of all,

13 you know, you mentioned -- and I -- you partially

14 maybe intentionally answered my question.

15 Clearly, the situation where we're creating boxes

16 of how you're going to get tested based on first

17 hour rating, we need to address the situation,

18 whereas, an example, I might claim my rating is 55

19 because, in fact, I'm going to get a better energy

20 factor at that when, in fact, it's only let's say

21 42, okay. I'm exaggerating here, okay. We've got

22 to address that situation and at the moment, my
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1 present suggestion would be the DOE enforcement

2 criteria would be applied to that first hour

3 rating and it either meets or it doesn't.

4 MS. ARMSTRONG: You can't even -- I'm

5 not sure that you can -- well, so how do you apply

6 -- so that would argue for measured equals because

7 there's no --

8 MR. STANONIK: No, no --

9 MS. ARMSTRONG: -- that's based on the

10 variability within the sample and there's only one

11 unit.

12 MR. STANONIK: On a first hour rating.

13 MS. ARMSTRONG: There's no good -- yes -

14 -

15 MR. STANONIK: On a first hour rating,

16 okay --

17 MS. ARMSTRONG: I'm telling you that's

18 exactly what would happen.

19 MR. STANONIK: So I would test --

20 MS. ARMSTRONG: It's measured flat out,

21 no tolerance if I do that.

22 MR. STANONIK: I know. I'm saying if
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1 there was a discrepancy. I claim 55 and you

2 measured 42.

3 MS. ARMSTRONG: It's one unit from --

4 MR. STANONIK: I don't -- I'm saying if

5 there was a discrepancy, what would have to be

6 done is the first -- would be to validate that

7 first hour rating, so then we'd basically stop the

8 energy factor test and say, okay, we're going to

9 pick up some more samples and we're going to find

10 out whether it's either 55 --

11 MS. ARMSTRONG: So you think that in of

12 itself is a reason to believe to go to

13 enforcement, a unit may not meet standards? So

14 the proposal for manufacturers be at that point,

15 they think they should get a test notice from the

16 Department to send units?

17 MR. STANONIK: If I drag this unit in

18 for checking the EF, and I got -- my example was

19 exaggerated --

20 MS. ARMSTRONG: Careful what you're

21 saying here.

22 MR. STANONIK: I know. My example was
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1 exaggerated. I got a significant discrepancy in

2 first hour rating that pushed me from one box to

3 the other, yes, but now --

4 MS. ARMSTRONG: If you're right on the

5 cusp, it doesn't even take significant.

6 MR. STANONIK: I was going to say let's

7 get real. So I'm on the cusp, okay. The answer

8 to that is yes, there's going to have to be -- I

9 believe there will have to be built in some --

10 MS. ARMSTRONG: We propose that

11 specifically in 429.

12 MR. STANONIK: First hour rating, first

13 hour rating.

14 MS. ARMSTRONG: It's the same thing with

15 rated volume.

16 MR. STANONIK: Oh, no, it's not. Oh,

17 no, it's not.

18 MS. ARMSTRONG: Will you hold on one

19 second?

20 MR. STANONIK: Yes.

21 MS. ARMSTRONG: It is the same thing for

22 rated volume when you're trying to determine
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1 whether you're less than 120 gallons. I it's an

2 EF, you -- well, if it's an EF, you're going to

3 crosswalk to thermal efficiency. I mean it gets

4 to be the same point at some -- we put -- you

5 know, I think we put bounds around these things

6 because they matter in other aspects of the DOE

7 program and how they might be applied. The test

8 procedure is one, but determining what standards

9 apply is two. Determining which bucket you fall

10 in, consumer or commercial, is three. I mean it

11 all kind of goes together. They're performance12 related metrics.

13 MR. STANONIK: Okay. And for the --

14 with the exception of which bucket I fall into,

15 okay, the other issues that you mentioned have

16 existed since the first DOE minimum efficiency

17 standards for water heaters, and they have not

18 been a problem. They haven't. I mean there is

19 not -- and I'll just -- you know, again, I can --

20 MS. ARMSTRONG: Okay, so --

21 MR. STANONIK: -- well, I can tell you -

22 - let me --
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1 MS. ARMSTRONG: -- so I can go to --

2 MR. STANONIK: I get to finish now.

3 MS. ARMSTRONG: Yes, sir, sorry.

4 MR. STANONIK: I can tell you what --

5 again, certainly what we did years ago in the

6 gamma water heater program, and I have to check if

7 we're still doing it today, but if we pulled in a

8 residential water heater to test, and you have to

9 measure the volume, because you need it to do your

10 calculations right, and we saw the volume was

11 outside the tolerance, we would not test that unit

12 because, in fact, the issue -- because it was --

13 you know, there's no question if you didn't have

14 some control, and we're maintaining there is

15 control, but if you didn't have some control, I

16 could claim this higher rated volume to get a

17 lower energy factor. That's how it works out,

18 right. That's acknowledged, okay.

19 And what we're saying is the controls

20 that have been in place have worked, and the

21 suggestion here is to say that for some reasons,

22 all of a sudden, we need to reconsider them.
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1 MS. ARMSTRONG: I mean, Frank, you make

2 the point that you think the existing system has

3 worked to date? Okay, so then I take Joe's point.

4 I base everything on measured and I pick my draw

5 pattern based on the single unit measurement, and

6 if I get a different answer, I get a different

7 answer and that's how it's working today?

8 MR. STANONIK: Could you say that again?

9 MS. ARMSTRONG: So if your argument that

10 everything's working today's and Joe's point is

11 everything today is based on measured, right, I

12 will go and pull a water heater and from that, I

13 will run the first hour rating test or whatever, I

14 mean I will run the measurement, a volume test to

15 see where I fall. Based on that answer, I will

16 then move forward. Whatever bucket it is in, if

17 it's different than the one the one you used, so

18 be it, that's how it is today?

19 MR. STANONIK: But today the measurement

20 of the volume doesn't have any -- they all get

21 tested as 64.3 gallons. They all get tested at

22 64.3 gallons.
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1 MS. ARMSTRONG: Right. But you're

2 telling me to keep going with the way it is today,

3 and so I'm saying that's what's going to happen.

4 There's a reason DOE moved away from that and we -

5 - if you read the proposal, things are based on

6 rated, not measured, and we put bounds around what

7 rated could be. There's a reason we moved from

8 that because I understand that when I'm testing,

9 I'm not you. I'm in a different lab. I'm not in

10 your lab. I will -- we all know things will

11 happen and I may very well get a different answer.

12 MALE SPEAKER: I'm going to -- this --

13 Philip, you're next.

14 MR. STEVENS: Philip Stevens. With

15 respect to the 5 percent tolerance, you see very

16 clearly that some tanks have 10 percent tolerance,

17 some tanks have 5 percent tolerance. Why did you

18 go with 5 percent as opposed to 10 percent,

19 because the 10 percent would cover --

20 MALE SPEAKER: ***13:21:54(Off mic)

21 MR. STEVENS: But in your proposal, you

22 proposed 5 percent.
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1 MS. ARMSTRONG: Across the board.

2 MR. STEVENS: Across the board.

3 MS. ARMSTRONG: Equitable.

4 MR. STEVENS: Well, why not 10 PERCENT?

5 Then everything --

6 MS. ARMSTRONG: Is it necessary?

7 MR. STEVENS: Obviously, for the gas8 fired products.

9 MR. BROOKMAN: Charlie.

10 MR. ADAMS: Just to answer a question

11 that you asked earlier, John, why this stuff is in

12 the safety standard, I'm reading from the preface

13 of the 2009 edition of Z21 10.1 which is not a

14 residential water heater standard. It is a

15 storage heaters under 75,000. Word search for the

16 word residential and you won't find it in here

17 anywhere.

18 MALE SPEAKER: **813:22:43(Off mic)

19 MR. ADAMS: No. This publication

20 represents a basic standard for safe operation,

21 substantial and durable construction and

22 acceptable performance of storage gas water
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1 heaters with input ratings of 75,000 BTUs per hour

2 and less. It is a result of years of experience

3 and manufacturer testing, installation,

4 maintenance, inspection and research on storage

5 gas water heaters with inputs under 75,000. So

6 it's not just a safety standard. We all say that

7 but we also say it's the residential standard and

8 it's not that either.

9 MR. CYMBALSKY: Okay. So then what I

10 would hope, and I don't know if you'll do this,

11 but if you can provide us some of your

12 manufacturing statistics on this volume to show

13 that there is variance coming off the line for a

14 particular model, that would be very helpful.

15 Thank you.

16 MR. BROOKMAN: Yes, so Harvey. I'm

17 going to suggest in a little bit we go to lunch.

18 Harvey.

19 MR. SACHS: I might make the same

20 suggestion.

21 MALE SPEAKER: The volume of your

22 stomach's getting --
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1 MR. SACHS: This is Harvey and I

2 certainly don't feel that I have an answer to

3 offer, but one of the things that does come up and

4 echoed in my mind is that several of us, including

5 Philip and Ashley, set through a lot of the ADRAC

6 (ph) working group meetings this summer and one of

7 the things that clarified compliance obligations

8 was moving a single sided test so it, for example

9 -- and it's opposite this practice now -- it might

10 be that DOE says, gee, it can't be more than x

11 gallons, the tolerance band on capacity of the

12 water heater is such and such, but it's only one13 sided. If you want to make it smaller, it's okay,

14 or lager, but it's only one-sided because that

15 manufacturing problem easier.

16 The other thing that's much more

17 important is that I'm not following through all

18 the ramifications of measured versus nominal

19 capacity when it comes to the volume metric

20 correction and everything else. I'm not tracing

21 out the tree of how it affects EF to be using

22 measured versus nominal in the case where measured
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1 is less than nominal versus the case where

2 measured is larger than nominal. I need some help

3 with that if I'm going to respond at all today

4 instead of working it out and coming back in

5 January.

6 MR. BROOKMAN: Maybe we should go to

7 lunch and then dedicate 15 minutes only to revisit

8 this when we return from lunch and give everyone a

9 chance to make their -- give some thought to their

10 best arguments. Shall we do that?

11 MALE SPEAKER: Yes.

12 MR. BROOKMAN: Let's do that. So it's

13 almost 12:30. It takes an hour if you go

14 expeditiously to eat lunch in this place. Please

15 make sure you've got -- which means we'll resume

16 at 1:30. Please make sure you've you got your

17 badge visible. This room will be secure. You can

18 leave your stuff. There's a big cafeteria about

19 100 yards -- ground floor, 100 yards that way.

20 There's a Subway shop where the coffee shop is.

21 The restrooms, you know where they are located.

22 You'll need to go through a security portal when
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1 you leave the big cafeteria, so you might need an

2 ID. Sometimes you do, sometimes you don't.

3 So we'll see you back here to resume at

4 1:30. We'll dedicate a little bit of time to

5 revisiting this subject and then we're moving on.

6 Let me remind those of you that are

7 joining us online, we'd like to include you in the

8 conversation. If you wish to join us, as I

9 promised before we broke for lunch, 15 minutes is

10 what I'm thinking we should devote to what we are

11 covering before lunch.

12 MS. ARMSTRONG: No, we're moving on.

13 MR. BROOKMAN: We're moving on?

14 MS. ARMSTRONG: Yes.

15 MR. BROOKMAN: You won't allow any final

16 comment before we move on? I asked these guys

17 over here if they had anything additional to

18 contribute, and basically they said, not sure.

19 Frank.

20 MR. STANONIK: I mean all seriousness,

21 to the extent there is a -- things that need to be

22 resolved so that the system can't be
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1 ***13:27:15(gamed), we're certainly interested in

2 helping DOE find those solutions. To us, we don't

3 see that rated volume versus measured volume is

4 part of the solution.

5 MR. BROOKMAN: Okay. Summary comment.

6 Okay.

7 MS. ARMSTRONG: Right, so --

8 MR. BROOKMAN: Well, then let's move on.

9 MS. ARMSTRONG: This is just a summary

10 aside. I'm actually going to move pretty quickly

11 through this one. We talked about it earlier.

12 It's the same point. DOE put rated values around

13 first hour rating and that matched GPM. As I

14 said, this matters quite a bit because now that's

15 what the test procedure, the draw patterns are

16 going to be based on. And we did this for the

17 reasons that I explained earlier, so I'm not going

18 to get into it again. If you have suggestions on

19 different ways to do it, better ways, I encourage

20 you to propose them in your comments and we're

21 open to considering.

22 So the next section is on annual energy
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1 consumption, and I'm just going to highlight this

2 just briefly. We proposed to revise the

3 calculations for AEC so that it is now based on

4 the EF ratings. This is what input into the

5 labeling requirement that you guys, at least for

6 residential product. For consumer products that

7 are in --

8 MALE SPEAKER: Currently --

9 MS. ARMSTRONG: -- part for -- yes. For

10 consumer products that are in 430 that are

11 currently FTC labeled, this is what it would be

12 applicable to. So separate estimates for fossil

13 fuel energy use and electrical energy use and to

14 go from there. Here's the calculation for those

15 that are "wow, this equation worked." Not sure

16 why this one did and the other one didn't, but.

17 And then ultimately, the annual operating costs

18 for the label would be -- so I'm going to open the

19 floor to comment. This wouldn't be applicable

20 until the new procedures take effect.

21 MR. BROOKMAN: Comments. Yes, Gary.

22 MR. KLEIN: I need clarification as to
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1 the applicability of this method. It applies only

2 to the stuff that was in blue? Those diagrams are

3 helpful. Does it apply to stuff that's also in the

4 green?

5 MS. ARMSTRONG: So we're going to have

6 to talk to Hanson about that from FTC. I'm going

7 to say it definitely applies to things that are

8 currently labeled today. As far as its future

9 applicability to cover products that would not be

10 subject to standards, I would need to ask Hanson

11 for clarification. We can do that. He's at FTC.

12 We can do that. No issue.

13 MR. BROOKMAN: Garrett Doss on line

14 wishes to speak. Garrett, unmute your phone and

15 give it a try. Nothing yet, Garrett. Unmute your

16 phone.

17 ***(Software not working/technical

18 difficulty.)

19 MS. ARMSTRONG: Okay.

20 MR. BROOKMAN: Sorry, we're not hearing

21 you. Okay.

22 MS. ARMSTRONG: If you want to type in
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1 your question or comment, we're welcome to read

2 it.

3 So the next section is really the next

4 step and this is just forward the game, because I

5 figured we'd probably get questions about what is

6 DOE going to do. So after we develop -- decide

7 what's in and what's out in terms of the uniform

8 descriptor and the uniform test method, AEMTCA

9 required DOE to develop a mathematical conversion

10 factor to translate from existing metrics to this

11 uniform descriptor. And those existing metrics

12 would be EF to what we're considering new EF or

13 thermal efficiency as applicable, the commercial

14 metrics to new EF or back and forth.

15 So, we will begin a separate rulemaking

16 to do that. That will not be covered as part of

17 this test procedure rulemaking. DOE's intent is

18 to finalize the test procedure and begin that

19 rulemaking concurrently. So target completion of

20 the, for lack of a better term, crosswalk

21 conversion rulemaking will be end of 2014. The

22 manufacturers would then use the conversation
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1 factor to rate models in existence prior to the

2 effective date of the uniform descriptor until one

3 year after publication or December 31st, 2015,

4 whichever is the latter. That's in the statute.

5 And then the conversion factor must not

6 affect the minimum efficiency requirements for

7 converted water (inaudible). So the statue makes

8 clear that we cannot actually change the standards

9 in existence today.

10 So I'm not sure, the second blast that

11 we sent out, I don't know if you guys realize the

12 one that didn't have the pre-publication notice

13 but actually had the Federal Register version of

14 the Notice, there was another bullet that provided

15 a link to the testing we have done to date. And

16 it was a separate Word file. It's in the docket.

17 It's on our website. And it's just a test report.

18 It shows we have tested 20 water heaters to date.

19 It shows that there are general characteristics,

20 and it shows the results of the testing under the

21 new method as proposed.

22 So, Bill, do you want to describe the
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1 graphs or I can through them if you guys are

2 interested or if you have comments. I don't know,

3 there's not a whole lot to say other than to date

4 -- we included them because this is what we found

5 in terms of this is what's happened. At this

6 point in time, I think it's fair to say we have no

7 conclusions over what the conversion factor might

8 be, whether it should change, whether -- so we

9 have no conclusions from the data. We just wanted

10 to put it out there for people to consider. To

11 the extent people want to share their data to be

12 included in our conversation factor analysis, we

13 welcome that. Of course, we are committed to

14 doing additional testing as well going forward for

15 the conversion factor, so we will be continuing to

16 test. Yes.

17 MR. STEVENS: Philip Stevens. Just a

18 clarification. In reviewing the report, no

19 condensing gas-fired products were included in

20 this initial analysis?

21 MS. ARMSTRONG: You want to talk?

22 DR. HEALY: Okay. Bill Healy. No
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1 condensing storage water heaters have been

2 ***13:33:49(off mic).

3 MS. ARMSTRONG: Correct.

4 MR. BROOKMAN: Steve Rosenstock.

5 MR. ROSENSTOCK: Steve Rosenstock, EEI,

6 and this is for the next few slides. I appreciate

7 this information. Unfortunately -- is this seat

8 available where just a scale is basically from .6

9 to 1.4 so we can really see what the real impact

10 is, because I'll just say for the one diamond, and

11 I'll say 63 first hour rating, is that 30 percent?

12 Is that 25 percent. I mean, you know, that --

13 MS. ARMSTRONG: I'm going to refer you

14 to the actual report which contains a lot more

15 information. It's like 15 or so pages long. Take

16 a look. If you find what's in that is not what

17 you need, let me know.

18 MR. ROSENSTOCK: And the link was in the

19 NOPR somewhere?

20 MS. ARMSTRONG: It's not. It's on our

21 website right under the NOPR.

22 MR. ROSENSTOCK: On the website?
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1 MS. ARMSTRONG: Yes. So it's a separate

2 report in the docket.

3 MR. BROOKMAN: Saw Charlie first.

4 MR. ADAMS: This is Charlie Adams, A.O.

5 Smith. This is the topic that I alluded to much

6 earlier in the morning on the first hour and the

7 difference in 125 and 135 degree water

8 temperatures and the impact on first hours. If --

9 the way I read the NOPR, the position of DOE in

10 the NOPR is after running tests on these, in the

11 case of first hour, I guess, it would be the 15

12 storage water heaters, that the average was only 3

13 percent different so that was deemed to be not

14 significant enough to change anything?

15 MS. ARMSTRONG: I think when we say not

16 significant enough to change anything, I think we

17 thought our proposal would be applicable to the

18 buckets you fall into later. In other words, the

19 first hour ratings, whether it be point of use,

20 low, medium, high, that would still be valid with

21 first hour ratings coming out of the new tests at

22 125.
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1 Now that being said, whether that

2 subsequently -- we had not made a conclusion as to

3 whether, you know, the EFs need a crosswalk or

4 not.

5 MR. ADAMS: Okay. I think I understand.

6 MS. ARMSTRONG: Sorry.

7 MR. ADAMS: The concern I have about

8 these test results and the implication that has

9 back on the question of is it okay to drop the

10 test temperature from 135 to 125 and what impact

11 does that have -- I agree that the average here is

12 within 3 percent and that's probably not enough to

13 move you appreciably from one bucket to the other

14 unless it's a real oddball circumstance. But the

15 fact that out of 15 heaters that have an average

16 difference of 3 percent, the range is 43 percent

17 concerns us greatly on what problems are going to

18 be encountered with changing the 135 degree test

19 temperature to 125.

20 I'm not smart enough to have any more

21 insight than that today because we're looking at

22 it and analyzing and trying to understand it, too.
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1 I just want to put it on the record that this data

2 from this report on the change in first hour from

3 new to old test at 125 to 135 causes us pause as

4 to whether we're opening up some issues that

5 haven't been fully addressed and have some

6 problems with the 125 test temperature.

7 Philosophically, we support the idea

8 that 125 makes more sense than 135 because of the

9 filed measurements and there are some technology,

10 like heat pumps and condensing gas, that purposely

11 have a cold slide of water in the bottom of the

12 tank to perform like we intend them to and all of

13 that, and our RFI comments supported dropping the

14 test temperature. So we're on board with it but

15 this data and our tests, too -- we're not in the

16 30 percent range, we're in the give or take 10 or

17 12 percent change in first hour rating. That's

18 significant. That concerns us. I don't have a

19 whole lot more details for today other than we'll

20 be back in touch.

21 MR. BROOKMAN: Frank and then George.

22 MR. KUSTERER: Our lab has conducted a
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1 number of tests regarding the 125 degree

2 temperature; again, oil-fired product, not gas.

3 We have seen a 25 percent reduction in the first

4 hour and one of the other things that concerned

5 us, and again, more testing is required -- and I

6 apologize -- this is George from Bock -- is that

7 the test method was difficult as far as

8 repeatability goes.

9 MR. BROOKMAN: Thank you. Frank and

10 then back to Joe.

11 MR. STANONIK: Well, first of all, I

12 want to echo Steve's comment and maybe in the big

13 picture, it doesn't matter, but it would be nice

14 to have all of the graphs that are in the report,

15 if you will, expanded around the unitary line, if

16 you will, and just cut out the bottom part so that

17 we can actually get a better sense of the effect

18 of the difference, but that's a minor thing.

19 But as far as this whole issue, I think

20 as you've heard, you know, our members are doing

21 some of their own tests. We certainly plan to sit

22 down and between what tests have been done try and
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1 apply what I'll call a matrix kind of approach to

2 try and see if there are trends. I mean, at this

3 point, everybody's just looking at what they want

4 to look at, what interests them so to speak. And

5 I think one of the things, to the extent time and

6 everything else allows us to, as an example, would

7 make some sense to look at is okay, again, I've

8 got this 40-gallon water heater, same

9 configuration, I fired at this input, I fired at

10 this one and this one, now what do see as effect.

11 So everyone at the moment is doing their own test

12 but after this meeting, we're going to have an HRI

13 meeting and try and see if we can coordinate

14 something that allows at least to see if there are

15 trends. And we'll certainly, to the extend we can

16 get that done by January, we'll give you what we

17 can give you.

18 MS. ARMSTRONG: Great. And I get

19 Charlie's point to the extent that, you know, the

20 changes in first hour, the set points I'm sure --

21 the changes that you're subsequently seeing at

22 first hour could give you pause with some of the
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1 methods. That's really what we're looking for

2 now. Now don't get me wrong. We will take all

3 data and all input, but right now, in conclusion

4 into January, we're looking at are there any of

5 the proposed methods that need to change. Now, to

6 the extent we need to characterize how they will

7 change the EF ratings you see today and the

8 crosswalk, luckily we have a year to do such

9 things and hopefully, we can do that together.

10 MR. BROOKMAN: Joe.

11 MR. ROROS: Joe Boros with Rheem. I

12 would just like to add that based on our limited

13 testing of 30, 40 and 50-gallon storage gas and

14 electric water heaters, we are seeing a reduction

15 in the first hour rating. Am I to understand --

16 and we'll share that data as well. It does lead

17 us to concern in that some models may -- it may

18 move those models, some that have been tested,

19 from one bin to the next bin, lower them. And as

20 you know, that would have a significant impact in

21 terms of EF and repositioning of those models. So

22 that's a concern that we have right now.
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1 But our tests will continue and we'll

2 share that data.

3 MR. BROOKMAN: Thank you. Harvey.

4 MR. SACHS: Thank you. Harvey Sachs,

5 ACEEE. Frank, I think it would really be helpful

6 to us and I suspect to the Department if you

7 could, sort of the HRI custom, aggregate -- you

8 referred to it as a matrix thing -- so we do get a

9 sense by volume bin with different technologies

10 treated different so we can see what kinds of

11 corrections are warranted for which products.

12 MR. STANONIK: And Harvey, I think yes,

13 that's kind of what we have in mind. I mean,

14 again, part of what I'm hopeful to be able to do

15 is take what people have done already, map it out,

16 if you will, and then first of all, see where our

17 data points -- we should have information and we

18 don't have and try and work to get that

19 information and then once we get that, as you say,

20 kind of lay it out and again, I don't -- you know,

21 see if there are trends. I mean right now, all we

22 see is it's all over the map, 43 percent spread.
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1 It appears to be all over the map and yet if you

2 just start thinking about how water heaters work

3 and everything -- you know, I want to sit here and

4 say there's got to be some kind of something you

5 can figure out, that you can predict. And right

6 now, it just isn't there.

7 MR. BROOKMAN: Gary, then Philip.

8 MR. KLEIN: So on a simple math test, it

9 would appear to me -- it's Gary Klein -- sorry --

10 it would appear to me that an approximately 13

11 percent drop in output capacity would result by

12 the change in temperature.

13 MALE SPEAKER: For some.

14 MR. KLEIN: Well, just this first -- all

15 other things being equal, one might expect around

16 13 percent, but I'm not sure that all other things

17 are actually equal in the new test procedure. Do

18 we still pull water out at the same maximum rate?

19 For the first hour rating, what's -- that's done

20 at some flow rate, right?

21 MALE SPEAKER: Right.

22 MALE SPEAKER: For water ***13:44:15(off
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1 mic) -- for presently covered water heaters, yes,

2 it's still pulling 3 GPM. For water heaters that

3 are under 20 gallons, those are 1 GPM. But for

4 the data that we've shown here which has existing

5 first hour ratings, it is the same (inaudible) --

6 MR. KLEIN: Still at 3 GPM?

7 MALE SPEAKER: Yes.

8 MR. KLEIN: So then back to my point. I

9 think that the average one might expect to see a

10 reduction in the first hour rating would e on the

11 order of 3 percent. That's basically

12 proportioning the degrees difference between 135

13 and base and 125 and base and then looking at the

14 number. That's how I got that number. But I also

15 suspect that at the lower temperature, the impact

16 is, in part, when the thermostats choose to kick

17 on the burner to pick up some of the residual

18 because the way we've got it now, it starts at

19 135. Well, I got 10 degrees to lose heat from

20 before I start to drop my total temperature that I

21 no longer have at the 125. And that capacity

22 difference is not being -- some of the controls
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1 may be picking up that and others will not just

2 because of when they're set to come on. That's my

3 suspicion in the way that they're -- why you see

4 such a big difference.

5 MR. BROOKMAN: Philip.

6 MR. STEVENS: Philip Stevens. We are

7 predominantly convincing and we support the 125

8 for the reasons Charlie mentioned. The convincing

9 technology requires stratification or stacking to

10 achieve higher efficiencies. With the lower

11 temperatures at the bottom of the tank where the

12 flue exhaust comes out, you condense more. You

13 make sure more energy stays in the hot water where

14 it's intended to be.

15 As far as the reduction in the

16 percentage, one thing that you should be aware of,

17 North Carolina has a limitation and they kind of

18 set the standard for the industry. You can't sell

19 a product to North Carolina with a thermostat

20 setting above 125 degrees I believe it is. So for

21 that reason, most manufacturers sell every product

22 across the country with that thermostat setting
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1 out of the box. And considering all the other

2 test methods are based on "as received," that

3 gives further support for this position.

4 MR. BROOKMAN: Yes, Dave.

5 MR. VILLARROEL: David Villarroel. I

6 just had a question in regards to the products

7 that were tested. There wasn't any mention on the

8 type of technology and so I was just curious of

9 what the technology of some of them -- and if

10 there was a new variance in that as well.

11 DR. HEALY: Other than the way that it's

12 already characterized?

13 MS. ARMSTRONG: So there's --

14 MR. VILLARROEL: Yes, because I'm

15 looking at the report, right, and you have in

16 Section 1.3 all the tested products, and I was

17 just curious if for example, the power vented ones

18 performed a little bit different than, you know,

19 of the same volume or whatever of that.

20 MS. ARMSTRONG: We're not going to be

21 able to answer that here, but we have the data, so

22 we can talk offline.
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1 MR. BROOKMAN: If you're going to -- do

2 you want to wait or you want to give it a short

3 shot here, Bill?

4 MS. ARMSTRONG: No --

5 MR. BROOKMAN: No. We don't have it.

6 Okay, great. So maybe you can connect on this

7 point. George.

8 MR. KUSTERER: Just one quick comment.

9 George Kusterer from Bock Water Heaters. And that

10 invitation, John, to come out to Bock Water

11 Heaters is cordially extended.

12 MR. CYMBALSKY: Where are you located?

13 MR. KUSTERER: Madison, Wisconsin but

14 you don't want to come out now.

15 MR. CYMBALSKY: Oh, okay.

16 MS. ARMSTRONG: I came in January.

17 MR. KUSTERER: I know you did.

18 MS. ARMSTRONG: It was lovely. It's the

19 first time I ever saw ice fishing.

20 (Laughter)

21 MR. CYMBALSKY: Actually, I've always

22 wanted to do that.
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1 MS. ARMSTRONG: I didn't know what it

2 was before then.

3 MR. CYMBALSKY: I appreciate the

4 invitation, honestly.

5 MR. KUSTERER: It's an honest

6 invitation. I'm not joking around. With regard to

7 the 125 and the 135, I just want to bring out one

8 point. Again, with the 13 as opposed to the 125,

9 we did see a significant change in the first hour.

10 And my thought is that it could be the controlling

11 devices that shut the heater off, turn the heater

12 back on again, which generally can have a 10-

13 degree differential, so here we're pulling water

14 at 125, it won't come back on until it's 110. At

15 that point, it really can't keep up with the draw.

16 You following what I'm saying? I think we have a

17 better chance at the 135 number. This way, at

18 least if there is a 10-degree differential, the

19 device has a chance to kick back up again and

20 provide the -- and I think that's where the loss

21 is coming from from the first hour. Just a

22 thought.
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1 MR. CYMBALSKY: Okay. Thank you.

2 Additional thoughts here on these many different

3 rating curves, plots actually? Harvey.

4 MR. SACHS: Ashton, Eric, John, I'm

5 hearing Bock's concerns about this and remembering

6 that the market for tank oil units is

7 substantially smaller than the rest, and if this

8 really is differentially effecting oil relative to

9 other energy sources, we certainly would be

10 willing to think about a waiver on the test method

11 for oil if it actually needs a 135 and that's the

12 way they're generally operated in the field as

13 opposed to electric and gas water heaters. I

14 don't think we should set 135 for the multimillion

15 unit industry based on special needs for a much

16 smaller niche product. Thank you.

17 MR. CYMBALSKY: Other comments on this

18 section? Can I move to the next flow rating

19 piece?

20 MR. BROOKMAN: Yes.

21 MR. CYMBALSKY: Those look absolutely

22 proportional to the change in temperature so lets'
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1 move past those. We're done with them. That's

2 what ought to happen and they look pretty

3 consistent and about the mathematical estimate,

4 so.

5 MS. ARMSTRONG: I'm not --

6 MR. BROOKMAN: Are you at 55 now?

7 MS. ARMSTRONG: I wasn't planning to go

8 side-by-side. I'm happy to -- we're happy to grab

9 comments on them generally but --

10 MR. CYMBALSKY: Well, I just figure we

11 ought to spend one minute and move on to the last

12 one which is the energy factor one which is also

13 at a spread.

14 MR. BROOKMAN: Okay. Steve.

15 MR. ROSENSTOCK: Do you want to go

16 first?

17 MALE SPEAKER: No, go.

18 MR. ROSENSTOCK: Steve Rosenstock, EEI.

19 Many thanks to Philip for showing me the full

20 report. He brought a copy and in terms of the

21 energy factor -- I'll just stat with -- I guess

22 I'm kind of looking at both 58 and 59. I'm
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1 looking a the DOE report and in the report, it

2 does show that for the energy factors, there are

3 some ***13:51:59(N8) fields where some of the

4 water heaters, there's no data for low, medium or

5 high usage for the storage water heaters. So I'm

6 wondering does DOE plan to run more tests at the

7 different draw patterns to kind of show the

8 variation in energy factors. Really, if you look

9 at slide 59, it shows that, you know, certain

10 types of water heaters, most of the water heaters

11 were tested t high usage but fewer were tested at

12 medium or low usage. And then you look at the

13 report and then it's kind of bundling together but

14 it's bundling incomplete data in chapter 5.

15 MS. ARMSTRONG: I think generally, we

16 plan to do more testing. You're not going to see

17 the testing though probably the close of the

18 current period. So the idea would be that this is

19 what we have to date. This is all the that we've

20 done on the proposed method. We're committed to

21 doing more testing. We're committed to working

22 through additional testing. We're happy to accept
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1 testing, help inform our decisions for the final

2 rule. I'm just -- that testing will be done over

3 a longer period of time and will be used for the

4 crosswalk.

5 MR. BROOKMAN: Bill, do you want to --

6 DR. HEALY: (Off mic)

7 MR. BROOKMAN: Get close to that mic,

8 please?

9 DR. HEALY: Okay. One other point of

10 clarification on the plots that are up here --

11 MALE SPEAKER: It's not on --

12 DR. HEALY: -- comparing the --

13 MR. BROOKMAN: You're not on, Bill.

14 DR. HEALY: The data that are showing up

15 here are comparing the measured results to

16 existing ratings. There are some water heaters

17 for which there are not existing ratings, so for

18 example, in the point of use category. So the

19 data we've shown here is an example and we've

20 referred you more to the document that's on the

21 website for more details. This was an example.

22 MR. ROSENSTOCK: Steve Rosenstock. And
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1 again, there does seem to be -- it's a very

2 interesting variation, at least, you know,

3 especially slide 59. But I guess I'm trying to

4 think of, you know, for certain water heaters that

5 are in that home where it was a family of five,

6 then a single pilot and then, I don't know, a

7 family of three where they could go low, medium or

8 high usage when you get right down to it, I'm just

9 kind of -- eventually, I'm just kind of wondering

10 what information is going to be out there or, you

11 know, what -- I'm just kind of -- you got all this

12 wonderful information but there's such a huge

13 spread, it can make quite a bit of difference in

14 terms of what's going to happen to the FTC energy

15 label compared to --

16 MS. ARMSTRONG: Yeah, but they're only

17 going to be tested with the draw pattern based on

18 the first hour rating from the storage, so they're

19 not going to be -- you're not going to have the

20 information. Every water heater out there, a

21 storage water heater, is not going to be required

22 to run point of use, low usage, medium usage and
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1 high usage draw patterns and then show all the

2 ratings for such. The idea here is for storage

3 water heaters, you do the first hour test. You see

4 which bucket you fall into. You run that bucket

5 and you create your rating.

6 MR. ROSENSTOCK: Okay.

7 MS. ARMSTRONG: We ran a bunch of

8 different ones to inform our decisions about which

9 buckets things should fall into, see how sensitive

10 things were, but I'm not going to go tell George

11 for every water heater he makes, or at least the

12 proposal wasn't, "George, you have to test four

13 different draw patterns for every water heater you

14 make."

15 MR. BROOKMAN: Frank.

16 MR. STANONIK: Following up on that, I

17 mean, again, the concept of this is information

18 for the consumer when they're purchasing the water

19 heater. You know, in the ideal world, they're

20 going to be purchasing the water heater for the

21 condition they are in at the moment. The issue of

22 what the efficiency looks for the product under
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1 any other usage pattern I'm going to say can't be

2 addressed. You know, that soapbox, I think, is

3 reserved for me. I was speaking -- ***13:56:11 to

4 that one enough.

5 MS. ARMSTRONG: And so Frank's point, I

6 think what we tried to do, for lack of a better

7 term, with those buckets is characterize -- it

8 won't be the most realistic -- the most common

9 position those would be in for the generation of

10 the rating.

11 MR. BROOKMAN: Jim Lutz wishes to speak.

12 Jim, unmute your phone and we'll hope to hear you.

13 Good -- your good.

14 MR. LUTZ: Obviously, you can't. Some

15 people -- there were people commenting in the

16 audience occasionally, and this was a while back,

17 that I couldn't hear because they weren't speaking

18 in the microphone. That's all I wish to say.

19 MR. BROOKMAN: Okay. We're trying to --

20 this is a rowdy bunch and --

21 MR. LUTZ: Yeah, I know.

22 MR. BROOKMAN: Frank.
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1 MR. STANONIK: Just one other thing I

2 wanted to put out and it is not a problem created

3 by this test procedure, maybe a little more

4 highlighted, but something that just I want to

5 point out. Talk about a new home, new home,

6 unoccupied. Today's practice is its water heater

7 gets sized not by who lives in it but what it

8 looks like. And so, you know, with this process,

9 well, it's going to maybe highlight that a lot of

10 homes are going to have high usage water heaters

11 in them just because they got that many bedrooms

12 or that many bathrooms and that's just the way it

13 is.

14 MR. BROOKMAN: Philip.

15 MR. STEVENS: Philip Stevens. Just a

16 clarification of something Ashley said a few

17 minutes ago. You said the additional testing the

18 Department's going to do will not be available

19 before the comment period expires. A lot of

20 manufacturers have issues with our current test

21 bands. We -- from my understanding, the majority

22 of us use test bands from a few limited numbers of
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1 suppliers. Our version of the test band cannot be

2 expanded to cover the additional draw patterns

3 that some of these -- the new profiles use. So

4 we're going to be severely limited and

5 handicapped, and our conclusion is that we'll have

6 to make recommendations for regulations on -- will

7 have a lot more uncertainty in them. So I'm not

8 sure if that's a question or a comment.

9 MS. ARMSTRONG: Thank you.

10 MR. BROOKMAN: Yes, Joe.

11 MR. BOROS: Joe Boros. I have a quick

12 question. Could we request the raw data that was

13 generated with this report, excess data?

14 MS. ARMSTRONG: Yes. I can make the raw

15 data available. We will not say, you know, which

16 manufacturer, which model number. It will be some

17 type of ***13:59:08 but yes, we can make

18 additional details available.

19 MR. BOROS: That would help us with

20 understanding the data.

21 MS. ARMSTRONG: sure.

22 MR. BOROS: Another comment. On the
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1 next slide, I think it's Slide 59, we're showing

2 energy factor versus the different point of use,

3 low, medium and high use. In our testing, we have

4 found that gas- fired storage water heaters in the

5 medium and especially in the low use, those that

6 have for some reason classified to low use are

7 seeing a significantly higher reduction in energy

8 factor than that reported in the test data. So

9 getting back to the first hour and how that

10 impacts the EF, we're definitely seeing a certain

11 size of storage water heaters more significantly

12 impacted than that being reported. And that leads

13 us, obviously, to a concern.

14 MS. ARMSTRONG: So I'm going to ask the

15 same question back of you is if you would be

16 willing to share your data with us.

17 MR. BOROS: We'll share that data either

18 directly or through HRI depending on the approach

19 that is more convenient.

20 MR. BROOKMAN: Frank.

21 MR. STANONIK: Just one little follow on

22 to Joe's request and maybe he meant to include it.
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1 In terms of the water heaters you tested, if you

2 can, tell us whether it's, let's say, a standard

3 height, tall or short.

4 MR. BROOKMAN: Yes, George.

5 MR. KUSTERER: George Kusterer from

6 Bock.

7 Question for Ashley: How will that

8 information be made available to us?

9 MS. ARMSTRONG: We'll put it in the

10 docket but we can do an email blast so that you

11 know when it's there. Does that work?

12 MR. KUSTERER: Yes, great. Thank you.

13 MALE SPEAKER: Thank you.

14 MS. ARMSTRONG: Harvey.

15 MR. BROOKMAN: Harvey.

16 MR. SACHS: Harvey Sacks, ACEEE. Just a

17 comment on Frank's comment that the builders may

18 be choosing oversized ones because they get few

19 callbacks. It may be true but we're trying to

20 think about this over the life cycle of the house

21 and also with information that we keep getting

22 from our friends at HRI that with the collapse of
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1 the new housing market, almost every water heater,

2 4 out of 5, is going into a replacement situation

3 now anyhow. So this is -- it's collateral damage

4 perhaps, but it's inevitable, and your fear is

5 that we may be getting oversized ones in new

6 houses, and my fear is that the builders may go

7 undersized because it saves them five bucks.

8 Neither of us can really predict the builders and

9 segments.

10 MR. BROOKMAN: Okay. Final comments on

11 this segment because I think we're about to move

12 to the opportunity to make closing remarks.

13 Anybody that wishes to raise issues that haven't

14 been fully explicated, described, now is the time.

15 Yes, Charlie.

16 MR. ADAMS: Charlie Adams, A.O. Smith.

17 I've got a couple of them but I'll take them one

18 at a time. In our response to the RFI, we

19 suggested giving this, the new uniform descriptor,

20 a new name. And I know DOE addressed that and

21 chose to stay with EF. In thinking about it

22 further, we'd like to suggest that there is
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1 utility to the consumer if, in making a decision,

2 if we can -- and we're fine with staying with an

3 EF if that's the direction we're going to go, but

4 to prevent a consumer from trying to compare a

5 low-use EF to a high-use EF without knowing that

6 they're comparing something different, there may

7 be some benefit to having -- and I'm going to say

8 subscripts -- but you can do it any number of

9 ways, an EFL, an EFH, an EFM and an EFP so that

10 when I'm a consumer and I'm standing there looking

11 at -- presumably this one finds its way under the

12 yellow energy guide, but by whatever -- wherever

13 I'm looking at these representations of energies,

14 the EF will tell me which bucket I'm looking at,

15 and if I need to be looking in the high bucket,

16 I'm not going to -- start comparing that to EFs

17 that came out of another bucket. Selfishly, that

18 has the extra added benefit, in our view, of an EF

19 with no subscript as the old one and an EF with a

20 subscript as one of the new ones or is the new

21 one, so we see it as also helping to address a

22 question we raised in our RFI comments.
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1 But in thinking about it from a consumer

2 point of view, I really see a lot of value in

3 making that more clearer to the decision maker.

4 MR. CYMBALSKY: Can you suggest a way

5 that a consumer would know if they're low, medium

6 or high, because I mean I just think of my own

7 water use. I don't know. I think I use a lot of

8 water but there are only two people in my house,

9 so probably --

10 MR. ADAMS: I can address that in a

11 minute, John.

12 MR. CYMBALSKY: You can?

13 MR. ADAMS: Yes.

14 MR. BROOKMAN: Neil

15 MR. ADAMS: I yield five minutes to my

16 colleague, Dr. Sachs.

17 MALE SPEAKER: Gentleman from the

18 District who therefore has no vote.

19 (Laughter)

20 MALE SPEAKER: Harvey's a low water

21 user. I'm going to go --

22 MR. SACHS: This is Harvey Sachs. I
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1 guess I should respond to that one. I also want

2 to go back to the more general nomenclature

3 issues. Would you rather stay on that topic

4 first?

5 MALE SPEAKER: Either one --

6 MR. SACHS: All right. Nomenclature --

7 in fact, I'll catch -- I'd like to do that one.

8 We also feel that during the transition period in

9 particular, retaining the use of the term "EF" is

10 problematic, that it just is going to keep us

11 confused as we try to work things out internally

12 and explain it downstream to all of the

13 distributors, all of the contractors, all of the

14 builders, everyone else. In terms of -- and we

15 prefer to change EF out completely, because we

16 think it would be easier for consumers but we

17 could be wrong.

18 In terms of Charlie's particular

19 question, what I have been thinking about this

20 afternoon is using terms like PEF, SEF, MEF, and

21 LEF. These automatically carry the size

22 classification within the term and would respond,
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1 I think, to Charlie's major concern and to my

2 concern about confusion. So that's a specific

3 request that we do change nomenclature in a way

4 that also identifies the product class to which

5 its assigned.

6 MR. BROOKMAN: Harvey, I think Steve

7 would like to respond briefly to that.

8 MR. ROSENSTOCK: Steve Rosenstock.

9 Isn't there another appliance with MEF now? Is it

10 clothes washers or isn't there another appliance

11 with that same acronym?

12 MS. ARMSTRONG: There are several.

13 MR. ROSENSTOCK: That might be the only

14 issue with that one.

15 MR. SACHS: Thank you, that's --

16 MALE SPEAKER: (Off mic)

17 (Off mic/crosstalk)

18 MR. SACHS: That would be one of the

19 considerations and I appreciate Steve bringing

20 that up. It's --

21 MS. ARMSTRONG: (Off mic). We got them

22 all.
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1 MR. SACHS: So I don't want to suggest

2 UD but MUD and LED, SED --

3 MALE SPEAKER: (Off mic)

4 MR. SACHS: and BED would also be -- no,

5 PUD and SUD --

6 MALE SPEAKER: -- PED.

7 MR. SACHS: -- PUD, so it's -- these

8 would also be available with the term uniform

9 descriptor.

10 Moving right along to capacity classes,

11 I guess I have assumed that all parties that are

12 interested would be working with FTC on that side

13 where there simply would be a descriptor that says

14 a small capacity water heater is appropriate for

15 typical families up to three inhabitants, medium

16 and so on, that that's the way it would be

17 handled, is just with that kind of consumer

18 guidance on the FTC level label and that that

19 would be a relatively easy thing to work out based

20 on the work that Mike Gearebrandt has don and a

21 number of other people have been involved with to

22 assign capacity classes to housing types.
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1 MR. CYMBALSKY: Okay. Thank you. Did

2 you have a second one. Charlie, you did, yes.

3 MR. ADAMS: On the -- and it's addressed

4 in the NOPR and I think in one of the slides I saw

5 earlier, on electric resistance water heaters that

6 a given 50-gallon heater can be offered with

7 multiple combinations of element --

8 MS. ARMSTRONG: (Off mic/crosstalk)

9 MR. ADAMS: -- wattage -- you didn't

10 think you were going to get away without hearing

11 about this, did you, Ashley?

12 MS. ARMSTRONG: (Off mic)

13 MR. ADAMS: To require that all element

14 combinations be tested is going to -- there ain't

15 enough test stands in the world for us to get

16 caught up with that because of the number of

17 element combinations that we offer, all of us

18 pretty much, on resistance water heaters. I

19 understand the position that with different

20 element combinations, the first hour rating

21 changes which may put you in a different bin.

22 MS. ARMSTRONG: Yes.
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1 MR. ADAMS: But I would encourage us to

2 come let us reason together and find a solution.

3 And here for just an -- for what it's worth,

4 something to consider, there are probably several

5 element combinations that have different first

6 hours but those first hours all fall in the same

7 bin. So maybe instead of having to run all first

8 hours and all EF tests, one for each combination,

9 we do a first hour rating and for all the element

10 combinations that fall into the same bin, we do a

11 -- I'll say the term -- basic model approach that

12 we select a representative unit or element

13 combination that falls in that bin, lack of a --

14 and I'm going to make up numbers here -- if a 3 Kw

15 over 3 Kw combination falls in the same bin as a 4

16 Kw over 4 Kw, the 4 over 4 is more predominant,

17 let's run the EF test on the 4 over 4 and use that

18 for the 3 over 3 and we've -- we can talk about,

19 you know, is there a mathematical way to get the

20 first hour. Do we have to run a first hour test

21 on all combinations which is itself going to be

22 problematic but that's less onerous than having to
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1 run a first hour test on all combinations and then

2 run a 24-hr SUT on all combinations, because that

3 just -- even if we all went into it with the

4 purest of intentions and we're going to try to,

5 we're not going to get finished between now and

6 April 2015.

7 MS. ARMSTRONG: Yes. This is Ashley

8 from DOE. We're open to the extent -- I mean you

9 explained for me why we did what we did. It is

10 our opinion that the way the regs work today could

11 not be ***14:10:59 when you're picking draw

12 patterns based on first hour. So to the extent you

13 have ideas or proposals that we should consider to

14 reduce burden but would also address that issue,

15 we're open.

16 MR. BROOKMAN: Harvey.

17 MR. ADAMS: Okay. And I understand the

18 problem. I'm just raising the practicality

19 aspects of the impact of them.

20 MR. BROOKMAN: Harvey, hang on one

21 second. Neil McDonald wishes to join the

22 conversation. Neil, if you succeed, you will push
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1 us close to 500 for the day. Go ahead, unmute

2 your phone.

3 MR. McDONALD: I'm unmuted. Can you

4 hear?

5 MR. BROOKMAN: Yes, good.

6 MR. McDONALD: Great. No, I guess I've

7 been trying to seen comments, but I appreciate you

8 moving me in the -- I guess the one thing I've

9 been trying to do here is kind of put the hat of

10 the consumer on. And I guess that's one of the

11 things I'm having a hard time kind of trying to

12 glean out of this. Exactly what kind of

13 communication we're going to have required, you

14 know, to the consumer? We got three new reporting

15 classes now or categories of product for high,

16 medium and low, and I guess as far as selecting

17 product based on that, I would think that would be

18 the natural evolution, I guess, of this change.

19 So I guess one of the suggestions I'm

20 having is just to see exactly what the final

21 product would be and how we would communicate all

22 these changes to the consumer and just to verify
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1 our primary goal of trying to teach the consumer

2 or better educate the consumer on how to select a

3 product for what their needs are, you know, is

4 actually met. I guess when I look at the -- you

5 know, I thought what I heard on here with the EF

6 being the primary number that calculates the

7 annual usage, I guess what I was believing is that

8 every category would have a different calculation

9 such that, you know, it's obvious that a consumer

10 knows that an 80-gallon water heater is going to

11 use 80 gallons of water, is going to be a more

12 expensive product to have on an annual basis than

13 a 50-gallon water heater. But I guess I'm not

14 sure that that's truly what's going to come out of

15 this. So I guess I'm just trying to make that

16 connection, making sure that a consumer, you know,

17 if there's a focus group or something or we can

18 see the final product and how we're going to be

19 able to communicate this is vague.

20 MS. ARMSTRONG: Yes. This is Ashley

21 from DOE. I think the answer is we don't know

22 yet. To the extent that we do these changes,
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1 obviously, DOE talks to FTC regularly but FTC will

2 have to go forward and figure out what information

3 should be on a label, if there should be any

4 subsequent disclosures, etc.

5 MR. BROOKMAN: Back to Harvey.

6 MR. SACHS: Thank you. Harvey Sachs,

7 ACAEEE. Charlie mentioned a magic term, basic

8 model, and great minds tend to run in the same

9 gutter. And I'm looking at Ashley because Ashley

10 and Phillip and some of the rest of us, Louis,

11 spend a fair amount of time wrestling with basic

12 models and what to do with them. And I wonder if

13 it's time to perhaps break out of this process and

14 do a little bit of a mini reg neg to think through

15 issues of how to use what we now call AEDMs for

16 everything for handling the problem that Charlie

17 is bringing up in a way that's fair to everybody,

18 because this really is a question of how far we

19 can push simulation without extrapolating beyond

20 what the physical testing does.

21 MR. BROOKMAN: Thank you. Frank.

22 MR. STANONIK: I just had a quick
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1 question. Do we happen to know was Hampton

2 listening in today?

3 MS. ARMSTRONG: I don't know. So I did

4 talk to Hampton this morning and yesterday. I

5 didn't anticipate a whole lot of discussion on the

6 content of the label so I told him what I thought

7 was going to happen today. But I don't know if

8 he's on but if not, we'll make the transcript

9 available and I will give him a call. And I know

10 he talks to Eric too, so we'll loop him in. No

11 problem.

12 MR. SACHS: Wait a minute. Frank, you

13 took Ashley and John off the hook. I was looking

14 for some response.

15 MR. STANONIK: I'm sorry.

16 MS. ARMSTRONG: Moving right along.

17 MR. BROOKMAN: Philip.

18 MR. STEVENS: Philip Stevens. I've got

19 your back, Harvey. Along the lines of the ASRAC

20 (ph) activities, I would strongly like to

21 encourage the Department to at least apply the

22 AEDM concepts to the light commercial category.
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1 That was a swift kick in the seat of the pants

2 when I read that one, and it says specifically in

3 there "AEDMs are not considered for the light duty

4 commercial."

5 For a second point, moving on to kind of

6 get you off the hook, ambient conditions: reading

7 through the standards -- let me take a step back.

8 HTP fully supports high efficiency products and

9 one of my main focuses here is to make sure that

10 all the standards in upcoming regulations, to the

11 extent that I can, are technology neutral. My

12 concern right now is that the heat pump water

13 heater specification is only tested at one

14 combination of temperature and humidity. Every

15 other heat pump, any type of performance metric

16 I've been able to find, references a combination

17 of various temperatures and humidities because

18 they're installed throughout the country. And

19 heat pump water heaters are no longer only

20 considered to be installed -- especially in 2015,

21 they won't only be installed inside homes in a

22 controlled environment. They will be installed in
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1 garages where the door is left open, and attics

2 and places that we can't even imagine right now.

3 So I think in order to have a technology neutral

4 efficiency metric, that really needs to be taken

5 into account.

6 MR. BROOKMAN: Tom Weckman.

7 MR. WECKMAN: I'll support Philip's

8 position on that. About one-third of our electric

9 water heaters are actually inside conditioned

10 space, about one-third are in basements that are

11 unconditioned, about one-third are out in the

12 garage, so it's a fairly significant temperature

13 excursion in the winter months, in the teens out

14 there right now and the garage is probably in the

15 30's. So that heat pump water heater is going to

16 be struggling at the moment, if it's running at

17 all, on a compressor.

18 So I think over the course of the year,

19 to get a farer comparison, at least -- you know,

20 NEA (ph) suggested a 50-degree temperature test

21 point in addition to the standard test point and I

22 think, to Philip's point, that at least one other
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1 test point at a lower temperature so we can get an

2 idea of what the performance curve looks like.

3 Whether it's rated there or not is a different

4 issue, but at least getting the information made

5 available from the test so that we can make use of

6 it.

7 MR. BROOKMAN: Steve Rosenstock.

8 MR. ROSENSTOCK: Steve Rosenstock, EEI.

9 Again, to be technology neutral, I have to imagine

10 that there's also some fossil fuel water heaters

11 that are in the same conditions, so if you're

12 going to do it for certain water heaters, you do

13 it for all of them based on -- if it's based on

14 field studies that show a third of water heaters

15 are in the garages, you want to change the ambient

16 conditions, then do it for all water heaters, not

17 just certain water heaters, because otherwise,

18 then all of a sudden, you're kind of mixing and

19 matching ambient conditions that'll make a big

20 difference. Thank you.

21 MR. CYMBALSKY: Garrett Doss, unmute

22 your phone. We're ready to hear.
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1 MR. DOSS: Hello, can you hear me?

2 MR. BROOKMAN: Yes.

3 MR. DOSS: Thank you. I was trying to

4 comment earlier. I actually had put my question

5 before Charlie made the comment. I think we can't

6 over emphasize the effect of testing all electric

7 storage water heaters at the different wattages.

8 Even doing something with just testing first hours

9 would be greater than the last capacity. And

10 we're talking about a very small part of the

11 energy pile when we start talking about some of

12 these different wattage options. Something has to

13 be worked out where we're really testing the main

14 runner and doing some kind of formula adjustment

15 for the others. It really would cripple the

16 testing industry if we were to do that.

17 MR. BROOKMAN: Okay. Harvey.

18 MR. SACHS: In support of Garrett's

19 comment, I would certainly work to assure that the

20 advocates are supportive as long as these

21 equation-based approaches or alternatives -- I

22 won't use the dirty term "AEDM" -- as long as
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1 these are backed by enough physical testing to

2 show the trend lines accurately, we're strongly in

3 favor of getting this thing done.

4 MR. BROOKMAN: Okay. Thank you.

5 Additional or perhaps final remarks? Yes,

6 Charlie.

7 MR. ADAMS: A good point to end the day

8 on, there's a math error in your conversion from

9 50 feet per minute to meters per second.

10 MS. ARMSTRONG: (Off mic). From the

11 National Institutes.

12 (Laughter)

13 MS. ARMSTRONG: I'm just kidding. No.

14 MR. ADAMS: Thrown under the bus.

15 MS. ARMSTRONG: I'll take it.

16 MALE SPEAKER: I don't accept it.

17 MS. ARMSTRONG: I'll take that one.

18 We're a good team.

19 MR. ADAMS: It was only one decimal

20 point.

21 MS. ARMSTRONG: And you had to do it on

22 the record. On that note, I hope you guys all
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1 have safe flights home.

2 (Laughter)

3 MR. ADAMS: (Off mic)

4 MR. BROOKMAN: I think this concludes

5 the meeting. We can push the last slide. It's up

6 there. Turning it back to Ashley for additional

7 closing remarks.

8 MS. ARMSTRONG: Just thank everyone for

9 coming. Hopefully, as you continue to work

10 through the NOPR, as you continue to test, we look

11 forward to additional feedback. I think the

12 discussion was pretty good today and any data you

13 want to send us, we will consider, obviously,

14 along with all the comments. Any data we have that

15 we can share and additional details, we will. And

16 I'm sure we'll all be in touch. But have a Happy

17 Holiday for all those in case I don't talk to you

18 before then.

19 (WHEREUPON, the meeting was

20 adjourned at 2:30p.m.)

21

22
1 

2 

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3 CERTIFICATE OF TRANSCRIPTION 

4 I, LUCY T. TURNBULL, hereby certify that I 

5 am not the Court Reporter who reported the 

6 following proceeding and that I have typed the 

7 transcript of this proceeding using the Court 

8 Reporter's notes and recordings. The 

9 foregoing/attached transcript is a true, correct, 

10 and complete transcription of said proceeding. 

11 

12 

13 December 11, 2013 

14 Date 

15 

16 

17 

18 

19 

20 

21 

22 

LUCY T. TURNBULL 

Transcriptionist 

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231 
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1 CERTIFICATE OF COURT REPORTER 

2 I, ERICK MCNAIR, the Court Reporter before 

3 whom the foregoing proceeding was taken, do hereby 

4 certify that the proceeding was recorded by me; 

5 that the proceeding was thereafter reduced to 

6 typewriting under my direction; that said 

7 transcript is a true and accurate record of the 

8 proceeding; that I am neither related to nor 

9 employed by any of the parties to this proceeding; 

10 and, further, that I have no financial interest in 

11 this proceeding. 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

ERICK MCNAIR 

Digital Court Reporter 

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232 
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003 162:13

1

1 84:8 88:6

89:6,7,10 91:12

126:6 196:3

1.3 198:16

1.4 187:9

1.5 139:7

1.7 88:7,22 89:4

91:12 121:2

126:7,9

1.8 121:19

1.99 129:10

1/2 135:21

1:30 179:16 180:4

1:41:13 22:9

10 71:7,8 102:1

139:1 141:3,4,5

143:4,6 144:11

151:1 166:15

175:16,18,19

176:4 190:16

196:19 200:12

10.1 176:13

10.3 56:22

10:25 7:22 71:8,12

10:30:04

(Ashreeve 11:8

10:33:04(funnel

14:7

10:56:51(cuff 37:2

100 46:5 179:19

100,000 42:4

1000 1:11

105 2:13

10-degree 200:18

10-gallon 116:1

11 2:8 7:22 231:13

1-1/2 53:11 135:11

11:00 7:21

11:09:37 49:22

11:10:40(MALE

50:20

11:11:30 51:20

11:15:34 56:9

11:21:56(Off 63:3

11:28:13(Off 70:6

11:32:19 73:21

11:41:26 82:13

110 101:20,22

102:3 130:9

200:14

12 31:16 32:5,8

58:6,15,21

59:5,12 61:6,16

62:2 190:17

12:09:34(Off

108:14

12:11:37 110:18

12:11:53 110:22

12:11:54 111:1

12:17:12 115:17

12:30 8:2 179:13

12:57:45

(Crosstalk

149:20

120 36:15

55:10,19,21 57:9

60:1 65:19

130:14 172:1

120-gallon 52:20

124 87:7

125 87:1,11,14,17

88:9 97:17

100:7,8,18

101:9,13 102:1

107:9,15,21

109:9,17,19

112:7 116:11

130:7,14

188:7,22

189:10,19

190:3,6,8 191:1

196:13,21

197:7,20

200:7,8,14

125-degree 109:1

129 2:14

13 2:9 195:10,16

200:8

13:03:00(Off

155:12

13:13:06 166:1

13:14:31(Off

167:11

13:21:54(Off

175:20

13:27:15(gamed

181:1

13:33:49(off 187:2

13:44:15(off

195:22

13:51:59(N8 203:3

13:56:11 207:3

13:59:08 209:17

135 87:2 97:17

101:18

107:16,20 109:3

112:7 116:12

188:7 189:10,18

190:3,8

196:12,19

200:7,17

201:11,14

14:10:59 220:11

15 2:10 102:4

179:7 180:9

187:15 188:11

189:15

15.6 139:8

150 39:3 55:19

104:14

150,000 36:16

15-gallon 90:16,21

91:16

16 146:20

160 36:18 39:3

40:16,19 149:22

150:1

17 49:21 67:10

68:13

170 2:15 35:9

39:3,21

171 2:17

179 34:15

17-hour 125:16

18 121:19

180 26:6,16 27:18

29:2,7,16,22

30:2 31:2

34:15,19 35:9

37:14 38:13

39:1,2,22 53:12

1950s 144:13

199 2:18

1998 14:4

1-hour 84:13
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2 15:20 46:4 57:8

66:20 88:3

112:18,19

129:3,5,7,12,13

135:11

2.0 164:17

2.001 129:11

2.2 91:1 135:22

2.5 89:3

2:30p.m 230:20

20 46:4 57:8 66:20

88:4,5

114:11,13,14

185:18 196:3

200,000 49:1 55:14

63:15

2007 13:9,10

2009 176:13

2010 87:5

2012 14:6

2013 1:7 3:9

231:13

2014 15:2 50:2

184:21

2015 41:16 42:2

43:16 127:8

162:11 164:11

165:20 185:3

220:6 225:20

2018 127:9

20585 1:13

20-gallon 15:20

67:14 68:7 69:10

20-hour 110:16

21st 12:18 50:1

79:15,16

24 73:9 78:12,15

80:11 83:4

105:13 106:1

110:19

24-hour 73:7

74:1,18 75:9

77:4 78:7 80:16

81:15,18,21

82:16 83:22

122:12

24-hr 220:2

25 31:19 32:4

101:19 187:12

191:3

250,000 52:19

25-cubic 161:21

162:3

26,000 145:11

28,000 145:10

147:2

29-cubic 161:22

162:2

2-minute 88:8

3

3 122:19 188:12

189:12,16

196:2,6,11

219:14,15,18

3/8 135:20

30 105:15,22

115:15 162:4,14

187:11 190:16

193:13

30,000 78:18

30-gallon 131:13

30's 226:15

31st 185:3

32 75:18

37 150:14

37-gallon 147:19

148:3

38 128:1 140:2

144:20

38-1/2 150:15

39 140:2

39-gallon 148:3

3-inch 147:4

4

4 2:4,5 3:20 147:6

212:2

219:15,16,17

4,000 48:20 49:6

53:18 62:17

66:7,8

4.8 139:8

4:00 8:13

40 48:22 112:17,19

124:13,19

140:3,5 144:20

145:6 147:17

162:4 166:21

193:13

40,000 118:12

4000 118:5

40-50 153:1

40-gallon

131:10,13 140:1

145:9,11,12

146:17,19 147:1

148:5,6,8 192:8

41 147:19

4-1/2-Kw 116:2

42 113:19 114:18

115:9,10 168:21

170:2

429 138:6 171:11

43 189:16 194:22

430 19:14 23:19

182:10

430.32 68:2

431 17:14 18:5

431.106 14:9

431.12 17:12

44 139:7

45 142:6,12

143:7,8 146:9

148:16

151:10,12

162:15,19

48 76:5 160:8

48-hour 73:9

82:20

5

5 2:6 87:14 88:5,10

139:1 151:2

175:15,17,18,22

203:14 212:2

50 65:14 81:4,5

140:6,15,17

141:15

142:3,6,7,12,14

143:8,14 146:9

148:21,22

149:14 151:10

155:5

162:12,13,18

229:9

500 221:1

50-degree 226:20

50-gallon 63:15

124:20 131:9

148:15 151:9
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160:8 193:13

218:6 222:13

50-some 63:16

51 148:4

52 142:7,15

54 113:19

165:10,14

55 41:19 98:12

99:12

114:9,13,15

115:5 124:12

128:1 162:12

164:12,16,19

165:10,14

168:18 170:1,10

202:6

55,000 145:13

55's 164:21

58 98:5,8,11

202:22

58-degree 99:12

59 202:22 203:9

205:3 210:1

5-gallon 152:8

5-inch 147:5

5-minute 88:8

6

6 1:7 3:9 187:8

6.1.6 109:20

60 63:18,19 120:1

164:13 165:7,12

60,000 147:3

60-gallon 42:4

60's 144:14

63 138:12 187:11

64 123:21

124:5,12,14

127:3,16

64.3 174:21,22

66210 38:5

66216 125:2

66240 109:16

66241 109:13

66242 109:13

67 111:3 113:19

121:2,4,5

141:16,18 142:1

148:7,8

67-gallon 147:22

69 2:11

6-pack 139:21

7

7.5 91:16

70 98:17

75,000 41:17

176:15 177:1,5

8

8 2:7 126:19

149:17

80 42:7 113:20

114:7,15 115:3,4

222:11

80,000 22:8

80-gallon 222:10

813:22:43(Off

176:18

82 2:12

8-ounce 149:17

9

9 150:5

9.4 139:5 165:9

9:00 1:8

90 11:10 148:16

91 148:17

911 9:19

945 162:14

9465 162:15

95 47:13 162:16,18

951 162:15

96 162:13

9-hour 125:16

A

a.m 1:8

A.O 22:20 74:4

92:16 141:14

166:20 188:4

212:16

Abbey's 41:2

Abigail

24:17,19,22

ability 33:3 147:14

able 10:4 22:22

25:18 34:6 74:11

77:18 97:2 118:8

129:6,22 130:2

135:13,15

194:14 198:21

222:19 225:16

abnormal 38:20

absolutely 76:13

145:15 164:8

201:21

ACAEEE 223:7

accept 203:22

229:16

acceptable 176:22

accepted 154:19

accessible 10:2

accompanying

13:20

according 91:22

113:17

account 101:13

226:5

accurate 232:7

accurately 229:2

ACEEE 10:20

26:4 81:13 97:16

116:19 194:5

211:16

ACEEEE 34:9

ACEEE's 12:22

achieve 75:6 94:3

126:9 197:10

acknowledge 96:8

112:5

acknowledged

173:18

acquisition 74:12

acronym 216:11

across 83:2 140:3

176:1,2 197:22

Act 13:10,19

activities 224:20

actual 71:2 125:1

140:2

156:18,19,21

168:11 187:14

actually 19:13

25:5 27:11

29:9,17,21 40:13

45:7 48:9 51:2

61:11 68:22 86:3

87:12 95:1 103:9
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157:1,14 161:10

166:2 168:12

181:10 185:8,13

191:17 195:17

199:21 201:3,11

222:4 226:9

228:4

Adam 5:16 112:12

Adams 4:11 22:20

26:2 27:4,15

28:2,11,15 38:4

39:7 40:9

41:15,22 42:7,12

54:18 56:21

69:8,15 74:4

78:17 80:9 92:16

94:11,13 95:17

96:13 98:21

100:1 101:1

106:7,16 107:5,8

115:19 116:1

136:5 141:13,21

142:14

143:18,21

146:16

152:2,14,19

159:16

160:1,3,14,17

163:13,21

164:6,9,18

176:10,19 188:4

189:5,7 212:16

214:10,13,15

218:3,9,13 219:1

220:17

229:7,14,19

230:3

add 17:3,11,14

32:17 46:7 53:21

70:14 151:21

193:12

added 46:6 73:22

74:5 75:19

76:1,17 135:2

213:18

adding 67:22

156:15 157:12

addition 17:14

226:21

additional 11:18

80:8 86:15 97:13

101:12 108:2

110:4 116:7

117:7 157:13

180:17 186:14

201:2 203:22

208:17 209:2,18

229:5

230:6,11,15

address 36:9 67:20

72:13 82:1

168:17,22

213:21 214:10

220:14

addressed 132:16

190:5 207:2

212:20 218:3

addressing 72:17

adds 74:9

adjourned 230:20

adjust 97:2

adjustment 157:12

228:14

admit 99:20

admittedly 124:5

129:18

ADRAC 178:5

advance 17:13

advertise 147:21

advertised 162:8

advertising 162:5

advised 54:19

advocates 228:20

AEC 182:3

AEDM 224:22

228:22

AEDMs 223:15

225:3

AEMTCA 14:14

16:9 17:16 23:15

24:1,11 184:8

affect 102:16

156:17 185:6

affecting 157:1

affects 101:5

178:21

Affiliated 5:4

affiliation 4:6

afternoon 8:4

215:20

against 68:14,16

90:5 158:19

agenda 2:7 7:14

8:9

aggregate 194:7

ago 11:7 60:19

103:3 112:22

153:1 173:5

208:17

agreement

112:13,14

ahead 18:11

33:14,15 38:3

48:17 82:17

107:18 120:20

134:10 221:1

ahs 95:1

ain't 6:15 218:14

Air 4:9 5:22 6:4

airline 136:13

airorater 135:11

airoraters 135:10

airport 135:5

airtime 9:5

alarm 9:14,16

Alex 6:3

aligning 30:2

Alliance 4:18

allow 34:15 180:15

allowable 138:15

142:4 143:10

allowed 18:3,20

20:2 140:19

allows 16:17 29:21

192:6,14

alluded 14:2 83:5

108:4 188:5

already 7:5 27:19

28:3 38:15 44:14

45:9 71:11

194:15 198:12

alternative 50:15

alternatives

228:21

am 3:18 12:5

133:22 137:19

150:11,13

162:19 193:15

231:5 232:8

ambient 109:6

225:6 227:15,19

ambiguous 26:7

amend 13:11

25:10 38:7 58:1
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amended 12:22

16:9

amendments

13:4,9,16

14:13,15 17:16

68:2,3

American 5:2

13:18 29:13

amount 78:2

106:12 131:5

136:12 223:11

amounts 84:19

AMSE 138:14

157:10

AMSE's 56:22

Amy 6:4

analogy 150:5

analysis 25:19

186:12,20

analyzes 41:8

analyzing 189:22

annual 8:5 15:11

181:22 182:17

222:7,12

anode 149:4,5,7

anodes 152:7

answer 19:5 29:3

41:6 47:16 69:8

72:7 99:1,9

105:17 155:1,18

157:21 158:15

159:17 171:7

174:6,7,15

175:11 176:10

178:2 198:21

222:21

answered 168:14

answers 159:12

Anthony 4:22

anticipate 224:5

anybody 10:18

29:17 145:8

212:13

anyhow 212:3

anyone 7:15 67:6

71:3 144:6

anything 7:6 9:16

12:10 22:3 32:8

35:13 37:17 54:8

103:18 130:5

156:3 163:16

180:17

188:14,16

anyway 27:20

52:18 74:22

127:12

anywhere 63:20

152:8 176:17

AOC 4:11

apart 126:19

apologize 191:6

appear 195:9,10

appears 44:7 54:7

195:1

Appendix 14:4

applaud 94:4

appliance 4:22

127:11,17

161:19 216:9,10

applicability

45:16 46:12 57:7

66:17 163:15

183:1,9

applicable 38:8

45:20 52:11 59:1

66:18 182:12,19

184:13 188:17

application 22:1

29:11 135:12

136:11,15,16,21,

22 137:7,12,15

applications 21:1

48:3 131:2 135:3

136:17

applied 118:19

127:5 169:2

172:7

applies 16:13

160:13 183:1,7

apply 16:14 62:18

109:3 120:10

136:6 169:5

172:9 183:3

192:1 224:21

appreciably

189:13

appreciate 123:14

146:10 187:6

200:3 216:19

221:7

approach 33:4

76:19 83:19 94:4

116:9 147:18

192:1 210:18

219:11

approaches 35:22

83:12 228:21

appropriate 75:7

89:1,6 91:12

101:11 114:5

123:12 126:4

128:4 217:14

appropriately

76:12 116:15

approximately

133:4 195:10

April 41:16 42:2

43:16 165:20

220:6

aquastat 36:17

area 166:7

aren't 3:18 22:9

141:8

arguably 24:14

argue 112:15

169:6

argument 74:7

136:8 174:9

arguments 179:10

ARMSRONG

5:14

Armstrong

3:12,13 5:14

10:15 12:4,5

19:4,18,21

20:3,6,13,16,20

22:2,17 23:20

24:1,8,16

25:7,12 26:14

27:14 28:7,13

30:14 32:2

33:8,11,14,18

34:4 36:20,22

37:5,11,15,21

39:6,12 40:4

41:1,21

42:6,9,17 44:11

45:5,9 47:3,15

48:16

49:4,11,15,17

50:7,13,21

51:8,10,16,21

52:3,6,9,22

53:3,14,20

54:4,11 55:15,18

56:4,8

57:2,20,22

58:12,15
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60:4,8,14

61:8,13,17,20,22

62:7,9,21

64:5,7,22

65:4,10

66:3,12,15

67:16,19

68:9,15,19 69:18

70:1,11,15

71:1,5 72:5

79:16 86:12

91:20 92:9

103:14,21

105:11,16

106:17 107:6

108:8,11,20

110:3 118:16

119:10,12,21

120:20 121:21

122:1 137:13,19

141:13 153:10

154:3 157:14

158:6,9,17

159:2,6,22

160:2,12,15,21

161:3 163:17,22

164:8

167:3,10,13,17

169:4,9,13,17,20

170:3,11,20

171:4,10,14,18,2

1 172:20 173:1,3

174:1,9 175:1

176:1,3,6

180:12,14

181:7,9 182:9

183:5,19,22

186:21

187:3,13,20

188:1,15 189:6

192:18

198:13,20

199:4,16,18

200:1 202:5,7

203:15 205:16

206:7 207:5

209:9,14,21

210:14 211:9,14

216:12,21

218:8,12,22

220:7 222:20

224:3,16

229:10,13,15,17,

21 230:8

Armstrong/

Opening 2:5

array 94:10

arrow 60:4

arrows 56:4 60:5

65:19

art 23:5

AS&E 31:3

Ashley 2:5 3:12

5:14 8:10 12:4

26:5 36:14 40:22

67:10 72:8 103:2

162:21 163:1

178:5 208:16

211:7 218:11

220:7 222:20

223:9 224:13

230:6

Ashley's 106:7

Ashton 201:4

aside 181:10

ASME 37:5

54:10,20 55:4

56:17 57:1 60:6

aspect 83:14,18

aspects 172:6

220:19

ASRAC 224:19

assign 217:22

assigned 216:5

assigning 22:15

associated 27:5

96:2

assume 164:10

assumed 217:11

assumes 101:17

assuming 41:22

51:2 88:15 95:4

assumption 50:14

101:21 105:9

assurance 55:2

assure 228:19

astray 19:7

attached 91:6

95:20

attempt 123:2

attempting 136:21

attendees 6:13

attics 226:1

audience 207:16

authorities 54:22

authority 13:2,5

15:17 19:7 43:20

44:4,8,9,21

automatically 16:3

31:8 68:1 158:1

215:21

available 8:18

93:9 187:8

208:18

209:15,18 211:8

217:8 224:9

227:5

Avenue 1:11

average 95:21

100:7,20 124:17

127:10 139:5,8

140:9 188:12

189:11,15 196:9

averaging 138:11

aware 12:8,17

197:16

Awareness 5:1

away 161:4 175:4

218:10

B

backed 229:1

backup 95:13

backwards 37:18

38:1

bad 99:8

badge 179:17

badly 6:19

Baltimore 3:10

band 140:18

178:11 209:1

bands 208:21,22

base 174:4 196:13

based 38:11 88:10

111:11,15

112:1,12 114:13

119:17 120:7

126:14 127:20

130:11 138:2

142:13 157:18

158:21 159:2

168:16 169:9

174:5,11,15

175:5 181:16

182:3 193:12

198:2 201:15

205:17 217:19

220:12 221:17

227:13
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basements 226:10

basic 123:16

176:20 219:11

223:7,11

basically 109:14

126:19 170:7

180:18 187:8

196:11

basis 99:18 222:12

basket 166:13

bathrooms

114:1,8 208:12

battery 126:3

bear 31:2 129:2

bears 140:21

became 145:15

become 16:4 141:1

becomes 26:9

BED 217:4

bedrooms 113:22

114:8 208:11

bedspread

141:4,20

beer 139:21

beforehand

110:20

begin 3:3 12:19

184:15,18

beginning 73:14

78:10,15 80:1

81:20

behind 110:11

behold 166:14

believe 9:21 18:21

27:19 70:19 72:3

74:9,15 101:10

102:17 127:8

139:16 170:12

171:9 197:20

believing 222:7

beneficial 97:18

benefit 213:7,18

benefits 124:16

Berkeley 127:21

best 18:19 35:22

78:21 79:9 81:11

179:10

better 26:18 34:18

43:2 48:3 49:9

64:2 78:22 79:9

87:3 96:7,9

108:16 122:14

168:19 181:19

184:20 191:17

200:17 207:6

222:2

beyond 223:19

bigger 60:1 115:4

biggish 129:1

Bill 5:18 71:16,17

72:18 82:2 84:5

133:17 185:22

186:22 199:3

204:5,13

bin 193:19 194:9

218:21

219:7,10,13,15

bit 12:20 33:21

113:3 157:15

166:12 177:17

180:4 181:14

198:18 205:13

223:14

blank 21:21

146:21

blanket 150:6

blast 185:10

211:10

blue 46:20,21

48:14 49:9

51:5,13 55:11

65:15,16 183:2

board 176:1,2

190:14

Bock 4:13 36:8

52:13 75:21

155:16 191:6

199:9,10 211:6

Bock's 201:5

boiler 32:1

boilers 17:5

book 67:21

Boros 4:15 76:15

100:11,15

101:2,3 102:9

116:8 156:11

158:3,8,16,20

159:4 193:11

209:11,19,22

210:17

bottom 75:18 93:7

109:3 146:19

147:12 154:10

167:20 190:11

191:16 197:11

bought 139:22

bound 98:18,19

133:8

boundaries 113:3

boundary 114:20

bounds 48:11

159:9 172:5

175:6

box 46:22 51:5

75:18 96:20,22

171:2 198:1

boxes 12:4,14

110:2 168:15

Boy 62:22

break 2:15 7:20

8:1,4 71:3

163:10 223:13

breaking 71:21

breaks 113:22

Brenda 6:10

brief 7:13,16

71:13

briefly 182:2

216:7

bright 19:2

bring 74:17 200:7

bringing 216:19

223:17

brings 82:19

broad 31:22

broadening 45:18

broader 32:19

broke 180:9

broken 21:12

Brookman 2:4

3:2,9 4:1 6:6,17

7:1,4,8,12 10:17

11:17,21

18:13,15 20:9

21:14 22:19

24:9,17,21 25:21

26:3 27:3

28:6,18 30:3

31:13,17,20

32:15

33:7,9,13,15

34:8,22 35:21

36:3,5 37:9 38:3
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41:14 42:13,20

43:5,8 44:1

45:3,7 46:16

47:18 49:18 50:9

52:12 53:15

54:5,17 55:6

56:11,20 57:15

59:9,20 67:8

68:10 69:7

71:7,15,20 72:16

73:21 75:16

76:9,14 77:8,12

78:4 79:3,12,17

80:7,17 81:12

82:4,9,17 83:13

84:3,15 86:14

89:14 90:14

92:15 94:9,12,21

95:15 96:16

97:7,12,22 98:20

99:13,22 100:13

101:12 102:7,22

103:22 104:2,9

106:6 107:7

108:2,6,14

109:11 110:1,4,9

111:2 112:11

113:6 115:17

116:4,6,18

117:7,9 118:17

119:14 120:11

121:16 123:9

124:21 128:9

132:15 134:10

136:4

137:3,14,18

139:14 141:12

142:18,21

143:20 146:14

149:10 151:14

152:3

153:5,9,11,15

155:8 159:15

161:4,10,15

162:20 163:12

165:4 166:8

176:9 177:16

179:6,12

180:13,15

181:5,8 182:21

183:13,20 187:4

188:3 190:21

191:9 193:10

194:3 195:7

197:5 198:4

199:1,5 201:20

202:6,14

204:5,7,13

206:15

207:11,19,22

208:14 209:10

210:20 211:4,15

212:10 214:14

216:6 220:16,20

221:5 223:5,21

224:17 226:6

227:7 228:2,17

229:4 230:4

brought 144:17

202:20

BRUNDAGAE

20:18

Brundage 4:7

20:9,10,15 21:11

43:8,9 44:2 45:2

49:18,19 161:12

165:1,5,22 166:6

BTU 42:4 53:11

129:14 147:3

BTUs 22:8 36:16

41:17 48:21

49:1,6 52:20

62:17 63:6,16

118:5,12

145:10,11,13

177:1

bucket 34:7 120:9

158:1 163:7

172:9,14 174:16

189:13 206:4

213:14,15,17

buckets 188:18

206:9 207:7

bucks 212:7

build 39:18 143:2

151:9 153:19

155:5 156:8

builders 211:17

212:6,8 215:14

building 1:12 10:9

21:19

built 85:4,8 146:1

171:9

bulk 9:11 10:13

124:7

bullet 26:5 67:10

84:7 185:14

bunch 48:10 206:7

207:20

bundling

203:13,14

burden 73:22

74:5,9 75:19

76:1,2,17,20

78:2 106:22

126:2 150:10

220:14

burdensome 79:10

122:17

burner 43:13

196:17

burners 89:20

bus 229:14

business 6:10,11

18:18

buy 141:5 142:9

148:1,3,8

buying 139:18,20

141:15 148:21

C

cafeteria 179:18

180:1

cal 132:4

calculated 138:18

calculates 222:6

calculation 15:11

34:2 101:5

130:17 182:14

222:8

calculations 105:2

108:22

156:20,22

173:10 182:3

calibrate 40:12

calibration 40:18

callbacks 211:19

calorific 100:3

Canada 5:9 56:13

79:21

capability 25:3

29:15 63:9

133:6,7 139:19

140:5 141:4

145:1,3,12 147:9

156:14,17,18,19

165:9,11

capable 26:5,22

27:16 31:1 37:15

39:8,17 40:2,5

115:14 129:20

133:3 141:17,22

capable/designed

53:7

capacities 19:20
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capacity 41:18

52:20 90:1,13

92:11,13 99:6

111:12,16 118:3

121:1,12

178:11,19

195:11 196:21

217:10,14,22

228:9

captures 122:15

car 149:21

card 6:10,11

care 54:1 83:3

104:16 105:15

141:14 146:8

150:10

careful 136:5

170:20

carefully 12:3

cares 146:8

Carolina

197:17,19

carry 215:21

carve 33:3

case 40:2 93:1

117:19 123:20

139:17 144:9

145:5,6,17 151:5

154:7 178:22

179:1 188:11

230:17

cases 84:17,18

119:5

catch 103:5 215:7

categories 112:10

116:10 128:11

221:15

categorization

117:6

categorized

111:13

category 19:1 22:1

41:4 44:17 47:6

51:7 60:22

70:9,14 113:10

114:19 116:3

119:9 129:2

131:20 135:5,19

136:2,8 163:10

204:18 222:8

224:22

caught 133:19

218:16

cause 27:8

35:5,16,18,19

causes 121:13

190:3

causing 61:2

caveat 112:21

cell 8:19 108:8

center 108:12

147:4,5,7,8

154:8

central 21:17

131:21 135:18

certain 3:7 15:7

19:20 21:4

22:7,16 45:20

48:3 56:17 67:1

93:19 94:6

107:12 114:8,9

118:11 133:6

139:18 145:1

158:10 203:9

205:4 210:10

227:12,17

certainly 35:12,13

153:2 173:5

178:2 181:1

191:21 192:15

201:9 228:19

CERTIFICATE

231:3 232:1

certify 231:4 232:4

challenging 78:10

chamber 82:22

chance 179:9

200:17,19

change 20:2 41:13

43:17 59:8 73:16

87:21 96:6,12

97:16 105:4,7

109:1 124:1,2

130:21 149:3

185:8 186:8

188:14,16

190:2,17 193:5,7

195:12 200:9

201:22 215:15

216:3 221:18

227:15

changed 34:17

36:12 98:5 112:6

144:18

changes 15:22

18:22 67:11

98:14 101:14

137:22 147:8

168:5 192:20,21

218:21 221:22

222:22

changing 105:5

126:11 168:1

189:18

chapter 203:14

characteristics

185:19

characterization

15:10 128:11

characterize 83:15

193:6 207:7

characterized 21:5

122:10 198:12

Charlie 4:11

22:19,20 25:21

27:3 28:7 29:4

33:19 35:5 38:3

40:8,9 41:14,15

54:17,18 56:20

63:5 69:7,20

74:3,4 78:6,17

80:7 92:15,16

94:9 95:9,16

98:20,21 99:22

100:1 101:1

105:14 106:6

107:7 110:14

112:11

115:18,19

124:13 136:4

141:12,13

143:20,21

146:15

149:12,16

152:6,16 154:15

159:15

163:12,13 176:9

188:3,4 197:8

212:15,16 218:2

223:7,16 228:5

229:6

Charlie's 76:10,19

192:19 215:18

216:1

chart 50:22 55:9

59:22

charts 51:1 152:13

cheat 148:14,18

check 173:6

checked 6:9,10

checking 109:15
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chime 19:5

choose 89:21

121:20 196:16

choosing 211:18

chose 11:16 26:21

112:9 128:2

212:21

Christmas 50:5

circled 109:18

circumstance

189:14

circumstances

35:5 85:9 90:12

118:12

claim 159:18,20

168:18 170:1

173:16

claimed 159:5,8

claims 159:9

clarification 17:15

33:22 40:10

41:16 59:10

77:11 78:5 81:8

84:21 92:3 96:15

143:19 182:22

183:11 186:18

204:10 208:16

clarifications

16:7,8

clarified 178:7

clarify 40:21 68:2

86:8 92:9 103:18

class 95:5 216:4

classes 217:10,22

221:15

classical 48:19

classification

111:15 215:22

classifications

11:15

classified 22:10

36:18 49:2 91:22

210:6

classify 40:2

clear 5:7 16:8 20:8

23:14 51:3

70:19,20 86:7

97:3 157:4 185:8

clearer 214:3

clearly 16:21

24:19 150:20

151:11 168:15

175:16

close 35:13 124:17

152:8 203:17

204:7 221:1

closer 100:13

closing 2:18 8:7

212:12 230:7

clothes 127:7

141:2 150:4

216:10

clue 61:2

code 31:2 56:17

112:3 113:19,21

114:4,16,20

coding 66:11

coffee 71:9 149:17

179:20

co-jurisdictions

54:19

cold 81:4,5 85:8,11

102:14 190:11

collapse 211:22

collateral 212:3

colleague 75:22

214:16

color 46:20,21

66:11

colorful 46:14

colors 47:2,4 66:9

column 38:5

combination

219:8,13,15

225:14,16

combinations

218:7,14,17,20

219:5,10,21

220:1,2

comes 148:2

150:3,12 178:19

197:12

comfortable 83:10

104:11

coming 3:14,22

25:8 28:19 43:12

94:1,4 100:8

125:11 167:21

177:13 179:4

188:21 200:21

230:9

comment 12:9,10

24:18 50:12,18

60:18 73:3 78:19

80:8,10 86:19

88:21 92:19

97:15 100:12

102:10 103:8

106:8 112:22

128:10 130:20

137:3,5 143:18

163:14 180:16

181:5 182:19

184:1 191:12

199:8 208:19

209:8,22 211:17

228:4,5,19

commenters 112:4

commenting

207:15

comments 2:5 3:19

7:3,16 8:10 10:8

11:18,19 12:18

14:21,22 25:22

26:19 28:22 36:1

38:7 39:14

50:1,3,14 53:21

67:6 75:20

76:17,19 79:14

80:10 84:4 86:15

91:11 97:13

99:13 101:10,12

102:5,7 103:17

104:7 106:19

110:5 111:3

114:14 116:7

126:14 130:19

132:16 181:20

182:21 186:2

190:13 201:17

202:9 212:10

213:22 221:7

230:14

commercial 3:7

13:5,6,22 14:8

15:9 16:13,21

17:4,5,7,9,11,20,

21,22

18:1,2,3,4,9,10

19:1,8,10

20:19,22 21:5,9

23:4,7,8,18

24:15

25:14,16,19 26:1

29:11 30:9,16

31:4,5,6 32:9,20

36:18,19

37:10,11,17,20

41:3,12 42:5,6
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45:1,21 47:5

51:16 52:21

53:13 67:2,3,14

72:1,2,13 135:3

163:4,10 172:10

184:13 224:22

225:4

committed 186:13

203:20,21

Committee 79:20

committees 117:3

common 94:9

207:8

communicate

221:21 222:19

communication

221:13

community 78:20

83:1,22

Company 4:8,16

76:16

comparable 112:8

141:8 145:2

compare 213:4

compared 46:22

72:11 74:2

125:19 139:4

145:2 163:22

205:15

comparing

204:12,15

213:6,16

comparison

136:19 226:19

compete 48:8

competing 83:12

complain 149:18

complement 11:7

complete 8:17

88:1 110:19

231:10

completely 12:3

95:2 104:10

153:22 215:15

completion 184:19

complex 46:13

57:3

compliance 158:18

159:12 178:7

complicated 98:22

comply 69:4

complying 157:4

compressor

226:17

computation

109:10

compute 130:11

computer 74:12

concept 110:14,21

163:2 206:17

concepts 123:15

224:22

Conceptually

78:22

concern 101:3

127:2 153:3

189:7 193:17,22

210:13 216:1,2

225:12

concerned 191:4

concerns 117:5

189:17 190:18

201:5

concise 9:4

conclude 67:5

concludes 230:4

conclusion 189:2

193:3 209:5

conclusions

186:7,9

concur 75:22

76:16

concurrently

184:19

condense 197:12

condensing 41:19

186:19 187:1

190:10

condition 85:12

100:20 102:13

206:21

conditioned 105:3

226:9

conditioning 4:10

6:1,5 102:18

conditions 2:12

8:2 11:12 30:21

83:11 86:17 87:3

225:6

227:11,16,19

conducted 77:4

190:22

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definitions
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128:19 129:5,21

132:19,21

133:14,20 134:6

135:8 137:16

140:19 164:12

165:22 167:5

185:1 195:18,20

rated 2:14 8:4 18:6

22:11 48:6 51:17

68:14,16 120:7,8

122:2 132:19

137:21

138:16,18

139:3,11 140:8

143:11 144:11

149:15 150:12

152:21 157:19

159:3

160:5,7,16,18

163:9 164:18

165:7,13 168:7

171:15,22

173:16 175:6,7

181:3,12 227:3

rateds 139:9

rates

88:6,15,17,21

90:8 113:15

117:16 122:21

126:1,3,12

134:18

135:14,21

rather 106:20

128:15 131:17

215:3

rating 16:19 65:2

69:9 78:12,15

92:1,8 101:15,16

103:12,20 105:6

107:10 109:2

111:17 112:2,6

117:21 119:18

120:2 121:19

122:2 126:8

129:14 136:7,18

138:3,4,5,7

142:2

158:5,11,13

159:18,20 160:9

163:5,6 165:8

168:17,18

169:3,12,15

170:7

171:2,12,13

174:13 181:13

187:11 190:17

193:15 195:19

196:10 201:3,18

205:18 206:5

207:10 218:20

219:9

ratings 2:17 8:6

15:8 46:10

72:10,11 103:4

112:9

113:9,11,15,16

114:2 177:1

182:4 188:19,21

193:7 196:5

204:16,17 206:2

ratio 62:10

raw 209:12,14

reaches 35:8

readily 93:22

reading 15:9 54:6

97:4 113:8
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225:6

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66:16 72:7 81:5

156:4 171:7

187:9 189:14

realistic 11:15

207:8

realize 131:11

135:18 185:11

realized 79:8

really 11:5,13

45:12 48:15 49:7

54:20 55:3 56:6

64:19 66:10

89:4,5 90:11

94:16 102:10

122:5 126:5

141:14 142:2

144:19 146:12

148:1 162:17

184:3 187:9

193:1 194:5

200:15 201:8

203:8 212:8

214:2 223:18

226:4 228:13,15

reason 45:11 84:9

87:2 88:19 94:18

108:11 141:9

145:7 159:3

163:2 170:12

175:4,7 197:21

210:6 219:2

reasonable 89:8

112:20 131:14

reasoning 126:22

134:22

reasons 138:9

144:7 173:21

181:17 197:8

reassurance 56:18

recalibrate 98:13

99:10

recall 9:19 54:13

105:6

received 6:8 7:12

12:1 73:4 98:5

114:14 198:2

receives 144:20

recent 87:4 153:2

recess 71:13

recognize 49:10

124:1 131:19

recollection 130:5

recommend 77:5

79:9 112:4

128:12

recommendation

28:22 54:12

78:20

recommendations

79:6 209:6

recommended

123:20

recommending

80:11

reconsider 173:22

record 7:3 8:16

18:16 152:1

190:1 229:22

232:7

recorded 232:4

recordings 231:8

recover 75:3

recovers 88:2

recovery 78:8,14

99:5

red 49:8,11 60:16

61:6,7 109:18

redefine 23:21

re-defining 44:21

redoing 165:15,16

reduce 23:9

106:22 126:2

147:13 220:14

reduced 232:5

reducing 76:20

127:16

reduction 191:3

193:14 196:10

197:15 210:7

redundant 23:13

refer 187:13

references 225:16

referred 34:11

194:8 204:20

referring 33:20

44:11

reflect 100:17

reflected 156:21

reflection 144:22

refrigeration 4:10

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refrigerator

161:22 162:2,3

refrigerators

161:21

reg 223:14

regard 200:6

regarding 14:15

191:1

regardless 90:8

regards 198:6

Register 38:5

109:14 125:2

185:13

regs 22:11 26:13

120:19 163:18

220:10

regularly 29:7

223:1

regulated 34:14

regulation 42:1

107:2

regulations

18:2,10 82:7

104:22 209:6

225:10

regulatory 2:9

7:19

re-heat 129:21

relate 67:18

151:19

related 39:16

76:17 103:8,10

161:13 172:12

232:8

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151:22

relative 111:3

120:14 201:8

relatively 45:11

217:19

relief 35:17

relocate 23:17

rely 34:21 77:20

relying 34:18

Remanufacturing
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remark 7:16

remarked 10:21

remarks 2:8,18

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212:12 229:5

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201:5

remind 180:6

reminder 12:16

reminding 45:10

removed 130:11

renamed 128:17

repeatability

191:8

repeatable 122:16

158:14

replace 131:11

replacement 212:2

replenish 93:5

report 149:8

185:17 186:18

187:14 188:2

190:2 191:14

198:15 202:20

203:1,13 209:13

reported 143:5

210:8,12 231:5

Reporter 231:5

232:1,2,16

Reporter's 231:8

reporting 143:4

221:14

Reports 161:20

162:1

repositioning

193:21

represent 87:3

96:10 140:4

representations

69:1,3 213:13

representative

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138:17 219:12

representing

148:20

represents 176:20

request 78:6

91:9,11 209:12

210:22 216:3

require 16:3,10

17:16 54:20,22

73:4 78:13

84:8,13 129:2

138:17 218:13

required 13:13,19

16:11

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25:13 41:19 57:1

68:20 69:1 126:2

164:17 184:9

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148:10 156:15

157:13 182:5

requirements 15:7

30:21 112:3

138:4,6,7 144:8

185:6

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197:9

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77:15

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207:3

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residences 58:8

122:15 123:4

131:16

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residential 1:4 3:6

13:3,21 14:5,11

15:16 16:12,18

17:19 18:6

19:9,17 20:21

21:1,7 22:5,10

23:1,6,18,22

24:3,15 25:11

29:11,14,18

30:9,17 31:8,10

32:10,20 36:18

37:9,12 41:5,12

42:4 43:3

44:15,20 45:18

47:5 51:18

55:21,22 57:4

58:9,20 60:18,22

66:19 67:13 72:1

86:22 88:16

93:10 124:8

131:2 163:4

173:8 176:14,16

177:7 182:6

residual 196:17

resistance 59:16

83:9 92:20 93:10

165:14 218:5,18

resistive 43:14

resolved 180:22

Resources 5:9,20

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175:15

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82:5 163:13

179:3 215:1,22

216:7

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24:20 110:12

212:18 224:14

rest 201:7 223:10

restrooms 9:12

71:8 179:21

result 160:11

177:2 195:11

resulting 126:11

results 82:8 83:5

185:20 189:8

204:15

resume 71:8,12,16

179:15 180:3

retail 165:6

retaining 215:9

retired 4:14

return 8:1 179:8

Returning 8:3

review 2:7 7:14,15

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reviewing 186:18

revise 111:9 182:2

revision 11:6

revisit 116:14

179:7

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RFI 28:22 79:6

112:5 114:14

190:13 212:18

213:22

RFIs 17:10 38:7
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Rheem 99:17

102:9 116:8

156:11 166:19

193:11

rid 80:12,14,15

ridiculous 150:16

ripples 124:2

rise 121:2,5

risk 78:8

Robert 71:21

72:16

Robin 5:20

roll 25:6

room 3:18 47:16

52:15,17 97:21

110:7 144:6

158:12 179:17

rooms 21:18

ROROS 193:11

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6:20 21:14,15

22:14,18

46:17,18

47:8,9,17,19

88:13 109:12

121:16,17,22

122:9 124:21,22

126:20 128:7

161:7,17,18

187:4,5,18,22

202:15,18

204:22 206:6

216:8,13 227:7,8

roughly 118:12

123:21

round 7:21

rounded 162:16

rounds 167:21

rowdy 207:20

Roy 5:20

rule 9:2 14:7 15:1

16:22 43:16

45:17 50:2,4

59:3 69:19 204:2

rulemaking 2:9

3:6 7:19 12:11

14:17 25:20

43:22 50:6 68:8

184:15,17,19,21

rulemakings 41:8

rules 9:14 16:5

rule's 9:5

run 71:22 74:20

78:8,12 79:5

82:20 84:11 91:7

93:3 106:14

118:14 119:4

120:6,10 122:11

130:15 156:19

158:17 160:9

161:14

166:19,20

174:13,14 203:6

205:22 206:4

219:7,17,20

220:1,2 223:8

runner 228:14

runners 153:18

running 73:6 75:2

86:3 91:16

102:20 159:13

188:10 226:16

runs 93:4 94:19

S

Sachs 5:2 10:19,20

26:3,4 27:1 34:9

36:2,4

59:6,10,16 81:13

82:1,18 83:20

91:14,19

97:15,16 104:10

105:12 116:19

133:17 177:19

178:1 194:4

201:4 211:16

214:16,22 215:6

216:15,18

217:1,4,7 223:6

224:12 228:18

Sacks 211:16

saddled 48:19

safe 56:19 176:20

230:1

safety 38:18 56:15

143:12,17

144:1,4,5,18

145:20

148:11,12

151:20,21,22

152:14,19 157:4

176:12 177:6

sale 165:6

sample 139:13

141:10 153:7

169:10

samples

138:9,10,20

170:9

SANONIK 4:9

satisfy 104:20

saves 212:7

saw 89:8 166:13

173:10 188:3

199:19 218:4

scale 187:8

scope 2:10 7:20

12:22 15:15,19

16:1 18:21 45:18

67:5,11 72:20

screen 108:5

search 176:15

seat 187:7 225:1

seats 3:2

second 14:14 26:5

28:20 36:13 72:5

75:9 80:15 84:7

109:6 126:13

133:19 134:9

141:1 162:10

171:19 185:10

218:2 220:21

225:5 229:9

secondary 145:15

seconds 91:7

Secretary 24:5

section 16:7 18:1

60:16 62:1 65:17

181:22 184:3

198:16 201:18

secure 179:17

security 13:10

179:22

SED 217:2

seeing 104:13

116:10 150:22

156:16 167:17

192:21 193:14

210:7,10

seeks 12:9

seem 35:22 119:1

205:1

seems 26:7 34:13

86:9 90:6 96:17

104:19

seen 66:22 87:9
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155:10 191:3

221:7

SEF 215:20

segment 212:11

segments 212:9

select 29:6 39:4

160:6 219:12

222:2

selected 156:20

selecting 131:1

221:16

selection 153:7

selections 154:1

selects 131:7

Selfishly 213:17

sell 70:18 136:12

197:18,21

selling 141:22

148:20

semi 4:14

send 24:22 29:14

170:16 230:13

sending 74:8

sense 105:3 107:11

190:8 191:17

192:7 194:9

sensing 38:11

95:20

sensitive 206:9

sensors 96:2

sent 185:11

sentences 97:4

separate 95:2

109:21 133:18

182:12 184:15

185:16 188:1

sequence 77:3

serious 11:6

seriousness 180:20

serve 135:16

served 136:3

service 35:19

sets 114:1 117:1

setting 29:6

38:21,22

39:3,4,21 87:13

91:10 99:17

197:20,22

setup 2:11 8:1

73:1 99:1

setups 99:10

seven 13:15

several 32:15 46:2

57:6 77:21 138:9

178:4 216:12

219:4

severely 209:4

shaking 149:19

share 9:4 186:11

193:16 194:2

210:16,17

230:15

shattering 6:18

shear 146:21

147:14

shell 146:21

147:15

shells 154:11

Shepard 6:4

shields 168:1

shift 72:20 140:10

shifting 153:12

shop 71:9 179:20

short 94:16 117:12

199:2 211:3

shorter 147:15

shortly 78:7,13

shot 199:3

shove 147:10,16

showed 63:20

127:22

shower 91:7

showing 47:12

202:19 204:14

210:1

shown 73:15 78:6

115:6 123:7

127:9 128:19

196:4 204:19

shows 65:16

125:14 143:2

185:18,19,20

203:9

shut 200:11

shy 3:18

sic 120:17

sidebar 8:19

side-by-side 202:8

sided 178:8,13

sides 24:14 168:2

sign 53:4

significant 54:9

74:5,14 76:3

77:17 84:22

124:16 145:16

171:1,5

188:14,16

190:18 193:20

200:9 226:12

significantly

210:7,11

silent 8:19

similar 65:15

66:11 126:16

145:3

similarity 127:4

simple 42:14 57:13

69:8 98:17 195:8

simply 118:18

149:16 153:17

217:13

simulated 73:8

84:1 109:4

122:12 123:8

133:16

simulation 223:19

simultaneous 93:9

single 36:20 87:20

93:14 95:18

96:3,6 111:7,10

122:19 126:6

134:4,6 135:1

136:7,13 174:5

178:8 205:6

single-phase 30:22

53:6

sink 90:22 135:10

sinks 90:22 135:9

sir 42:9 68:9 156:1

173:3

sit 191:21 195:3

sitting 137:9

situation 140:6

159:10

168:15,17,22

212:2

six 78:1 80:12,15

sixth 100:18
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size 53:8 90:9

114:8,9 132:8

145:14 147:2,17

167:8 210:11

215:21

sized 94:15 136:11

208:7

sizes 19:20 77:16

113:10

sizing 131:1

skip 32:5

skipped 49:20

107:18

slide 32:4 47:11

49:21 67:10

75:18 77:2

97:8,14 98:2

103:2,5,9

107:8,10 108:5

123:8 190:11

203:9 205:3

210:1 230:5

slides 12:2 45:6,11

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187:6 218:4

slightly 15:10

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147:16 168:2

small 78:3 89:17

90:11 117:13,19

120:15 121:10

128:12 129:16

132:11 134:22

135:6,7 153:4

217:14 228:10

smaller 19:3

88:4,7,19

89:2,10 178:13

201:7,16

smallish 129:1

smart 189:20

Smith 4:11 22:20

74:4 92:16

141:14 166:20

188:5 212:16

soak 74:18 83:22

106:13

soaked 106:20

soaking 75:1 82:16

soapbox 207:2

software 10:7

24:18 183:17

sold 165:14

solution 35:15

92:18 95:8,14

181:4 219:2

solutions 3:10

181:2

solve 139:16

somebody 29:21

64:4 96:11

someone 34:6 44:3

45:7 72:15

121:18 132:7

151:20

somewhat 49:19

116:12 142:9

somewhere 28:3

110:16 120:19

135:2 187:19

sorry 36:7 41:17

44:8 52:18 57:21

62:15 64:10

65:21 108:21

113:14 120:15

140:15 166:10

173:3 183:20

189:6 195:9

224:15

sort 9:2 81:18

83:6,21 101:21

194:7

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sources 201:9

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space 74:14 75:9

162:3 226:10

spacing 123:1

speak 3:17 8:15,16

10:4,10 12:13

24:19 55:1 77:10

83:1 151:14

183:14 192:4

207:11

SPEAKER 7:6,10

27:22 37:6,18

38:1,2 46:15

50:20 60:6,11

63:18 66:5,13

70:6 71:4 76:7

94:8,20 97:19,20

104:1 106:15

108:16,18,19

109:17 118:2

132:17 143:13

153:13 160:20

161:1 167:11,16

175:12,20

176:18 177:21

179:11 182:8

195:13,21,22

196:7 202:17

204:11 211:13

214:17,20 215:5

216:16 217:3,6

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SPEAKER/

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speakers 6:22

speaking 207:3,17

special 32:1

201:15

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91:13 106:3

120:17 216:2

specifically

12:9,14 14:14

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171:11 225:2

specification

225:13

specified 81:17

speedometer

149:22

spell 82:15

spend 202:11

223:11

spoke 162:22

spot 80:21

spread 194:22

202:13 205:13

stack 27:6 38:19

stacking 27:9 35:5

197:9

stage 12:21

stairs 9:17

stamp 31:2

stamped 54:10

stand 28:15

74:10,19 75:2,5

76:5 110:18

standard 16:5

33:21 36:11 37:7

42:6

43:4,13,15,18,21

60:7 69:4 95:5

124:19 140:20

145:20 149:6
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157:4,5 160:13

162:11 163:5,8

164:14

176:12,14,20

177:6,7 197:18

211:2 226:21

standards 5:1,19

13:8 16:1,7 18:9

24:13 25:10,18

32:22 38:19

41:5,11,13 42:19

56:15 59:3,4

67:12,21

68:1,6,8 72:3

87:5

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128:6 138:14

143:12,17,22

144:3,10,18

148:12 152:2,15

157:10 164:5

170:13 172:8,17

183:10 185:8

225:7,10

standby 13:13

16:20 72:4 101:9

standing 213:10

standpoint 149:13

stands 218:15

Stanonik 4:9

23:12,21 24:4

25:3,4,9

28:16,21 35:1

42:21 48:18

49:5,16

54:5,6,12

62:4,12,19

63:1,3,10,19

64:2,13,17

65:1,6 67:9,17

68:4 79:4,14

82:11 83:14

90:15 116:5

118:18,22

120:21 121:5

123:10 130:19

134:11,17

139:15 141:19

143:9,15 144:2

156:13 166:9

167:4 168:12

169:8,12,15,19,2

2 170:4,17,22

171:6,12,16,20

172:13,21

173:2,4 174:8,19

180:20 191:11

194:12 206:16

208:1 210:21

223:22 224:15

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start 3:11 4:1,2

12:20 35:10

60:17 75:8 78:7

81:2,4,14

85:7,8,11,22

89:11 130:1

195:2 196:20

213:16 228:11

started 12:6 84:12

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starting 39:14

79:11 102:1,11

107:15

starts 101:17

196:18

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stat 202:21

state 69:13 73:13

75:8 86:1,6,11

104:21

statement 67:17

statements 10:18

77:14

states 24:13 56:16

station 75:14 79:2

stations 77:20,22

78:1

statistics 177:12

statue 58:20 185:7

status 99:18

statute 16:10

17:19 19:9,15,17

20:16 21:6 25:13

42:17 43:1 44:14

58:18 66:3 72:9

163:19 185:4

statutory 24:2

32:6 43:7,20

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stay 50:22 93:17

101:9 212:21

215:3

staying 213:2

stays 197:13

steady 104:21

step 43:19 117:4

120:5 184:4

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121:16,17 122:4

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153:6,14,16,21

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176:2,4,7 186:17

197:6 208:15

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stomach's 177:22

stop 61:3 170:7

storage 8:4 15:8

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46:1,4,8 49:6

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65:12 73:4,16

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90:6,9,11,16,21

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93:5,6,22

94:3,17 99:7,12

101:17,18,19

102:3 103:19

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130:2,7,13,14,16

131:1,4,5,6,17,2

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Capital Reporting Company

Residential Water Heater T.P. Metting 12-06-2013

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