UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

PUBLIC MEETING 

 

ENERGY CONSERVATION STANDARDS FOR 

 RESIDENTIAL CLOTHES DRYER AND ROOM AIR CONDITIONERS 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

 Room SE-098 

 Tuesday 

March 16, 2010 

 

Chair: 

Doug Brookman 

Department of Energy 

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Participants Identified: 

Jennifer Amann 

ACEEE 

Tim Ballo 

Earthjustice 

James Battaglia 

Navigant Consulting 

Brice Bowley 

General Electric 

Debra Brunk 

Association of Home Appliance Manufacturers 

Lane Burt 

NRDC 

John Cymbalsky 

DOE Appliance Standards 

Lance DeLaura 

Sempra Energy Utilities 

 

Rebecca Duff 

ICF International, representing Energy ... 

Tom Eckman 

Northwest Power and Conservation Council 

George Gallenhurst 

General Electric 

Sean Gouw 

Southern California Edison 

Elizabeth Joyce 

Energy Solutions 

PG&E 

Mohammed Khan 

Department of Energy 

Jeff Kingman 

Navigant Consulting 

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Betsy Kohl 

DOE General Counsel 

Alex Lekov 

Lawrence Berkeley National Laboratory 

Dave Liss 

Northeast Energy Efficient Partnerships 

Amanda Lowenberger 

American Council for an Energy Efficient Economy 

Shawn Mackay 

Whirlpool Corporation 

Phil Manthei 

Alliance Laundry Systems 

Joanna Mauer 

Appliance Standards Awareness Project 

Wayne Myrick 

SHARP 

Betsy Kohl 

DOE General Counsel 

Ted Pope 

Energy Solutions representing PG&E 

Judith Reich 

Navigant Consulting 

Mike Rivest 

Navigant Consulting 

Gregory Rosenquist 

Berkeley National Laboratory 

Steve Rosenstock 

Edison Electric Institute 

Celia Sher 

General Counsel 

DOE 

Lois Starkey 

Manufactured Housing Institute 

Christopher Stone 

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Intertek 

Meg Sullivan 

DOE 

Jennifer Tiedeman 

DOE 

Constantin von Wentzel 

Navigant Consulting 

Meg Waltner 

NRDC 

Detlef Westphalen 

Navigant Consulting 

Mack Whitten 

Northwest Power and Conservation Council 

Stephen Witkowski 

DOE Appliance Standards 

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I N D E X

AGENDA ITEMS PAGE

Welcome, Mr. Witkowski 6 

Opening Remarks, Introductions and 

Agenda Review, Mr. Brookman 8 

Rulemaking Overview, Mr. Witkowski 

Comments from Participants, Mr. Brookman 14 

Engineering Analysis, Ms. Reich 16 

Engineering Analysis for Room Air 

Conditioners, Mr. Westphalen 63 

Energy Use Analysis, Markup for Equipment 

Price Determination and Life-Cycle Cost 

Analysis, Mr. Lekov 82 

Shipments Analysis and National Impact 

Analysis, Mr. Lekov 136 

Trial Standard Levels and Preliminary 

Manufacturer Impact Analysis, 

Mr. Lekov and Mr. von Wentzel 147 

Manufacturer Impact Analysis, Mr. Kingman 171 

Utility Impact Analysis, Employment Impact 

Analysis, Environmental Assessment, Regulatory 

Impact Analysis, Mr. Lekov 174 

Discussion of Other Issues, Mr. Brookman 

Next Steps and Closing Remarks, Mr. Witkowski 181 

 

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

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 9:00 a.m. 

 MR. BROOKMAN: Good morning, everybody and 

welcome. So glad you could join us this morning. 

Stephen Witkowski is going to start us off with 

welcoming remarks. 

OPENING REMARKS, INTRODUCTIONS AND AGENDA REVIEW 

 MR. WITKOWSKI: Good morning, everyone. Can 

you hear me? Is this on? Okay. I want to thank you 

to this public meeting today on Energy Conservation 

Standards for Residential Clothes Dryers and Room Air 

Conditioners, to go over and discuss a preliminary 

activities and analysis. 

 I also would like to introduce a new member 

of the DOE team, John Cymbalsky over here, who is 

taking over the duties that Ron Lewis had and we're 

very happy to have John here and looking forward to his 

direction. 

 Just a couple things very briefly, DOE is 

trying to reduce the length of some of these meetings, 

and it affects me directly today. It won't affect the 

other people so much at this meeting, but as you know, 

we normally start out where I go through a six or seven 

page overview of the rulemaking process. Since almost 

everyone here has heard this about 15 to 20 times, I 

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already see the smiles in the background, and it 

usually means that after ten minutes we have to wake 

people up and then get into the meat of the meeting. 

So I'm not going to cover that today. We'll assume 

that it's here in the presentation and you're all 

welcome, at your leisure, to look at it in the future 

if you want to. 

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 On that note, welcome, and I'll turn it over 

briefly again to Doug. 

 MR. CYMBALSKY: Thank you, Steve, and welcome 

everybody. This is my first public meeting, and my 

twelfth day on the job, so it's been a busy time. Just 

a little bit about myself. Before here, I worked at 

EIA for 20 years, and at EIA I was involved with the 

forecasting and the analysis, so this is a little bit 

different, and I'm thinking the reason they may have 

hired me is because my legacy at EIA was that I was 

never sued, either successfully or otherwise. And I'm 

here to sort of ward off the litigious ghosts of 

appliance standards past I think. 

 I'm going to do my best to keep us on track. 

 I know we've had some issues in the past. The good 

news about our time line, we're going to announce a 

final rule in the next couple of weeks on heating 

products, and that's going to be water heaters, direct 

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heating equipment, and pool heaters, should be in the 

next 15 days we'll have a final rule. We're on track 

to do that. 

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 So everyone, send your lawyers back home. 

We're okay. We're going to make the deadline. And 

with that, welcome to the meeting, and hopefully it'll 

be productive. 

 MR. BROOKMAN: Thank you, John. It's our 

tradition to give everyone a chance to introduce him or 

herself. If you'd say your name and organizational 

affiliation. This will not all be captured in the 

recorded public record, but we've got a -- when you 

registered, we got a full listing of who's here in the 

room. So I'll start over here. Your name and 

organizational affiliation. And these microphones, if 

you want to use them, the good old green LED light 

needs to be on. 

 SELF-INTRODUCTIONS 

 MS. JOYCE: Elizabeth Joyce, Energy 

Solutions, representing PG&E. 

 MR. BALLO: Tim Ballo, Earthjustice. 

 MR. ROSENSTOCK: Steve Rosenstock, Edison 

Electric Institute. 

 MS. MAUER: Joanna Mauer, Appliance Standards 

Awareness Project. 

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1 MR. BURT: Lane Burt, NRDC. 

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 MS. WALTNER: Meg Waltner, NRDC. 

 MR. DeLAURA: Lance DeLaura, Sempra Energy 

Utilities. 

 MR. GALLENHURST: George Gallenhurst, General 

Electric. 

 MR. MACKAY: Shawn Mackay, Whirlpool 

Corporation. 

 MS. BRUNK: Debra Brunk, Association of Home 

Appliance Manufacturers. 

 MS. KOHL: Betsy Kohl, DOE General Counsel 

 MR. CYMBALSKY: John Cymbalsky, DOE Appliance 

Standards. 

 MR. WITKOWSKI: Stephen Witkowski, DOE 

Appliance Standards. 

 MR. BROOKMAN: Please stand up. 

 MR. KINGMAN: Jeff Kingman, Navigant 

Consulting. 

 MS. REICH: Judith Reich, Navigant 

Consulting. 

 MR. WESTPHALEN: Detlef Westphalen, Navigant 

Consulting. 

 MR. LEKOV: Alex Lekov, Lawrence Berkeley 

National Laboratory. 

 MR. MANTHEI: Phil Manthei, Alliance Laundry 

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Systems. 

 MR. BOWLEY: Brice Bowley, General Electric. 

 MR. WHITTEN: I'm Mack Whitten, Northwest 

Power and Conservation Council. 

 MR. POPE: Ted Pope, Energy Solutions 

representing PG&E. 

 MR. LISS: Dave Liss, Northeast Energy 

Efficient Partnerships. 

 MR. GOUW: Sean Gouw, Southern California 

Edison. 

 MS. LOWENBERGER: Amanda Lowenberger, 

American Council for an Energy Efficient Economy. 

 MR. BATTAGLIA: James Battaglia, Navigant 

Consulting. 

 MS. DUFF: Rebecca Duff, ICF International, 

representing Energy ... 

 MR. KHAN: Mohammed Khan, Department of 

Energy. 

 MS. SULLIVAN: Meg Sullivan, DOE. 

 MS. SHER: Celia Sher, General Counsel, DOE. 

 MS. AMANN: I'm Jennifer Amann, ACEEE 

 MR. BROOKMAN: Thank you. Anybody else? Did 

we miss anybody? So glad you could make it here this 

morning, and we're almost at an on-time start. 

 AGENDA REVIEW 

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 MR. BROOKMAN: I'm going to do a very brief 

agenda review. As you came in, you received a packet 

that included the agenda, the slide presentation, and 

4 the Federal Register notice for today's meeting. 

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 Immediately following this agenda review, 

we're going to have a Rulemaking Overview, by Steve 

Witkowski, and immediately following that there's an 

opportunity for anybody who wishes to do so, to make 

brief summary of remarks citing issues that are of key 

interest to you. Brief summary of remarks, an 

opportunity, an open forum for that. 

 Immediately following that, we'll go straight 

into the engineering analysis. How many of you are new 

to these proceedings? Not many. So then most of you 

now know that the bulk of -- all the content in the 

presentation is in your packet, in the form of 

PowerPoint slides, and the Department has also taken 

the initiative to cue you to specific questions that 

they'd like to see addressed. So to the extent that 

you do that, that's very helpful to the Department. 

 Following the engineering analysis, around 

about eleven o'clock or so, we'll take a break and then 

we'll continue with the engineering analysis. We'll 

take a lunch break around about noon-ish, maybe a 

little after noon. 

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 Following that, energy use analysis, markups 

for equipment price determination, life cycle cost 

analysis, shipments analysis, national impact analysis, 

trial standard levels, and preliminary manufacturing 

impact analysis. We'll take a break mid-afternoon, and 

the manufacturing impact analysis, and you can see a 

whole host of other analyses, utility impact, 

employment impact, environmental assessment, and 

regulatory impact. 

 There's another opportunity late in the day 

just before we close for people to raise other issues 

that they wish to raise, things you don't think you've 

covered sufficiently, things that the Department needs 

to hear at this stage in the process. So there's that 

opportunity for you to do that, and then we'll have a 

few next steps and closing remarks. And that's what 

we've planned for the day. 

 So questions and comments on the plan? Any 

particular -- any issues that people need to raise that 

wouldn't fit into the proposed agenda? 

 Okay. So I ask your consideration, what has 

emerged, I think, as good manners during the span of 

these years, it applies, please speak one at a time. 

If you'd say your name for the record. You don't need 

to say your organizational affiliation every time. We 

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know you're here, just say your name so it's clear 

who's speaking. I'm going to be cuing people to the 

extent I can. Speak, and I also encourage follow-on 

comments. So sometimes that enlivens and enriches the 

discussion. 

 There will be a full transcript of this 

meeting today, and that will be made available on the 

EERE website. More on that later. 

 If you could try to be concise, please share 

the air time. There's lots to be said, I'm certain, 

about this issue today, and if you keep the focus here, 

please turn your cell phones on silent mode. If you 

need to have a sidebar conversation with a friend or 

someone next to you, keep it very brief. These 

microphones work pretty well. We can hear you. It 

might even show up on the record, you never know. And 

you need to turn on the microphone, on and off. I 

think they're -- you can leave it on, so if you're 

going to comment a lot, that's great. 

 I think that is it. I think that's all that 

I need to cover at this point. Questions and comments 

here at the outset? Steven Witkowski. 

 MR. WITKOWSKI: Well, we're skipping the 

overview, as I mentioned, so we're moving right to the 

comments from the participants. 

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 MR. BROOKMAN: You don't have to do any 

overview at all? Okay. So then this is an opportunity 

for people to raise issues that matter for them. Yes, 

Lane. 

COMMENTS FROM PARTICIPANTS 

 MR. BURT: Lane Burt, NRDC. NRDC is a 

national environmental, non-profit, representing 1.3 

million members and on-line activists. And in the runup to this rulemaking, we commissioned Ecos Consulting 

to dig into clothes dryer efficiencies, specifically. 

And this report is in final draft form and we are happy 

to make it available to the Department for the purposes 

of this rulemaking. 

 The report had some initial findings that are 

very interesting. Actual measured efficiencies for 

clothes dryers varied between 17 and 85 percent across 

the models tested. And as such, the report finds 

serious concerns with the Department of Energy's test 

method for clothes dryers, mainly the assumptions on 

field use factor, and the ending of the test with five 

percent remaining moisture content, rather than 

allowing the sensors to actually perform their job. 

 So one of the major questions that we would 

like to raise at the outset is what is the process for 

updating the test procedure? What are DOE's thoughts 

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on the test procedure? 

 And one other comment is that Ecos also found 

significant impact on heating and cooling energy use in 

this paper, and we would like to encourage the 

Department to explore that today. 

 MR. BROOKMAN: Thank you. Okay. Are there 

comments at the outset? Yes, Debra Brunk. 

 MS. BRUNK: Debra Brunk. I just want to 

first of all thank the Department of Energy for having 

this meeting today. I recognize this is kind of a 

replacement for the Advanced Notice of Proposed 

Rulemaking. I think having this preliminary review is 

helpful. 

 I do want to mention, though, and I already 

mentioned this to Stephen, that AHAM is a consensusbased organization. In order for us to speak at these 

meetings, we need to obtain consensus from all of our 

members. Given the timeframe that we had on this 

particular rulemaking, where the presentation and the 

specific issues for comment were made available late 

last week, and the executive summary yesterday, we have 

not had time to obtain a full consensus. So I just 

want to make that clear that if, in the future, those 

documents could be provided a little bit earlier, I 

think we can certainly be happy to provide a lot more 

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information than we will be able to do today. 

 MR. BROOKMAN: Are there some issues you feel 

like you can characterize AHAM's response, or are you 

now -- 

 MS. BRUNK: We will have some questions. I 

think it depends where the discussion goes, but again, 

I will not be free to make a lot of comments, just 

because we have not received full member confirmation 

on our position. Thank you. 

 MR. BROOKMAN: Other comments here at the 

outset in this opening round? Okay. Then, let's 

proceed with the engineering analysis. Judith Reich. 

 ENGINEERING ANALYSIS 

 MS. REICH: Well, good morning. I'm Judith 

Reich from Navigant Consulting, and I'm going to be 

starting out the discussion of the analyses that were 

conducted at the preliminary stages of this rulemaking. 

 In the light of what Steve has expressed, the desire 

to expedite the meetings, and in light of the fact that 

so many of you are very familiar with the process, I'm 

going to move quickly over some of the more generalized 

discussions of the process, and focus on the results 

and the steps that we took in the analysis. 

 So, the first three that I'll be discussing, 

portions of the analysis are the first the market and 

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technology assessment, and that is initially to first 

of all, define what exactly are the products that are 

under consideration in the rulemaking, how DOE intends 

to analyze them in terms of grouping them into product 

classes, and then to take a look at the regulatory 

landscape that they're currently facing. 

 The second piece of the market and technology 

assessment is to get a snapshot of the industry in 

terms of who the key players are, the manufacturers, 

and what their market shares are, and also to look at 

historical trends in the industry. 

 And then the final piece of that technology 

assessment that's very important is to define all of 

the technologies that are available to improve the 

efficiency of the products in question. 

 The next step is to take that large set of 

technologies and screen them according to some very 

specific criteria to determine which subset of those 

technologies can be evaluated as part of the 

engineering analysis. Which then, of course, in the 

engineering analysis, the ultimate goal is to 

characterize how much it's going to cost at each 

incremental efficiency level, up to the maximum 

technologically feasible level. 

 Let's talk about the market for residential 

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clothes dryers. Although there are about 14 

manufacturers of clothes dryers that sell into the 

U.S., it's a quite concentrated market. As you can 

see, there are three key players, and of those, 

Whirlpool -- the combined Whirlpool-Maytag entity 

accounts for about three-quarters of both the electric 

clothes dryer and gas clothes dryer market. It's also 

interesting that those market shares for those three 

manufacturers have remained relatively constant, as 

long as you consider Whirlpool and Maytag together, 

since they did merge a few years ago. 

 And clothes dryers are manufactured both in 

the U.S. and internationally, and there are some 

manufacturers that rebrand for others. 

 Right now -- well, I should say according to 

data that was submitted in 2008 by AHAM, back in 2006, 

there were approximately eight million clothes dryers 

sold in the U.S., the vast majority are standard 

electric dryers, with about 1.6 million gas dryers, and 

a very small fraction, about 100,000 compact electric. 

 For the purposes of the preliminary analysis, 

DOE proposes to categorize clothes dryers into six 

different product classes, which can be grouped as 

vented clothes dryers, and ventless or condensing 

clothes dryers. The product classes that are proposed 

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for the vented units are existing product classes which 

form the basis of the current federal energy 

conservation standards, and these are the electric 

standard, which is a capacity greater than 4.4 cubic 

feet, two compact electric classes which are 

differentiated by the voltage that they require, and 

gas clothes dryers. 

 Newly proposed for this rulemaking are two 

ventless product classes, one being an electric compact 

at 240 volts, and again, using the same criteria of 

less than 4.4 cubic feet in capacity, and combination 

washer-dryers. And DOE -- yes -- 

 MR. BROOKMAN: Let's let her finish with this 

slide, yes. 

 MS. REICH: DOE recognizes that right now the 

current test procedure does not accommodate testing of 

ventless units, so DOE is considering at this time, 

amending the test procedure with provisions that would 

allow ventless units to be tested. 

 MR. BROOKMAN: Debra Brunk. 

 MS. BRUNK: Debra Brunk. I just want to 

note on the product classes, that in the framework 

document, AHAM had suggested also including a new 

product class for the electric standard ventless size. 

 In this document DOE noted that those are not 

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currently on the market, and we would agree with that. 

 I think what we were looking at is if we were going to 

propose these new classes, we also know that clothes 

dryer capacities have been going up. It just would 

seem like it would be a good idea so it would decrease 

the waivers -- request for waivers that DOE would -- 

may expect to see in the future on these products. And 

based on how the electric compact was determined, 

obviously there's no data there, it was sort of 

extrapolated. We believe the same sort of approach 

could be done for an electric standard product class. 

 MR. BROOKMAN: Thank you. Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock. For the 

ventless dryers, again, you're talking about amending 

the test procedure which obviously makes sense, but 

again, there is a timing issue. What is the timing of 

DOE's decision on modifying the test procedure, just 

because of the way the pace of the rulemakings has 

been, what is the timing of that decision? 

 MR. WITKOWSKI: I'm looking at ... It looks 

like the final rule is near the end of this year. 

 MR. ROSENSTOCK: Final rule for the clothes 

dryer efficiency standard, or final rule for the test 

procedure? 

 MR. WITKOWSKI: For the test procedure. 

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 MR. ROSENSTOCK: And how about -- Steve 

Rosenstock, yeah -- and how about for the efficiency? 

 MR. WITKOWSKI: Excuse me for interrupting, 

but we have on our website a complete updated schedule. 

 I'm sorry, I don't have it here, but you're certainly 

willing to check with that, because the schedule that I 

have is just a partial schedule, and we can get you 

more accurate information. 

 MR. ROSENSTOCK: Thank you. 

 MR. BROOKMAN: Thank you. Okay. Judith. 

 MS. REICH: All right. Talk a little bit 

further about why ventless clothes dryers are being 

considered. It's believed that they have unique 

utility because it offers consumers the possibility of 

installing them in locations that don't have access to 

the outside, so no external vent is required. And the 

utility that's associated with combination washer and 

dryers are that first of all, they are a single unit 

that washes and dries the laundry in the same basket, 

in a combined cycle. And DOE's research has suggested 

that all such units are ventless so that they would be 

categorized strictly in the ventless class or category, 

and so therefore they too would be able to be installed 

in locations that would not have external venting 

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available. 

 MR. BROOKMAN: Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock. Just out 

of curiosity, are they considered -- for the clothes 

washer category, are they considered separate products 

as well. 

 MS. REICH: There is currently no separate 

product class for a combination washer-dryer. 

 MR. ROSENSTOCK: Thank you. 

 MS. REICH: For clothes washers. 

 MR. BROOKMAN: Yes, Lane. 

 MR. BURT: Lane Burt. General question on 

the test procedures for combination units. Are they 

going to be tested in drying mode only, or are they 

going to be tested as a unit with washing and drying 

capability? Because one of the conclusions of the 

previously mentioned report is that there is the 

potential for energy savings if manufacturers are 

allowed to test units together that work together, 

because it is more efficient to mechanically remove the 

water than to dry it. 

 MS. REICH: Well, DOE right now is 

considering the clothes dryer test procedure. As it 

currently stands it is only addressing clothes dryers, 

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and therefore would only address the drying portion of 

the cycle. But again, the rulemaking is -- those 

topics are under consideration. 

 MR. BURT: Thank you. 

 MR. WITKOWSKI: And if you have any 

suggestions or comments on the test procedure, we 

encourage you to, in the written comments if not here, 

to propose those. We're always happy to look at 

comments and suggestions. 

 MR. BROOKMAN: Thank you, Stephen. 

 MS. REICH: You know, well perfect lead-in to 

the test procedure. This is a separate rulemaking 

that is currently underway for both clothes dryers and 

the room air conditioner test procedure is being 

evaluated as part of that same rulemaking. For the 

clothes dryer test procedure, under consideration are 

both active mode issues, and stand-by and off mode 

energy use. And the latter is being addressed as part 

of a requirement by the Energy Independence and 

Security Act, EISA, which requires that if it is 

technically feasible to incorporate such energy use 

into the efficiency metric, then the test procedure, if 

it doesn't already include that, needs to measure such 

energy use. 

 And as I mentioned before, the test procedure 

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does not currently have provisions in it that can 

accommodate ventless clothes dryers, and DOE believes 

that there are some simple clarifications that can be 

inserted into it that would allow the testing of the 

units, primarily the -- stating clearly that the use of 

the exhaust simulator would not be required. 

 DOE would like to receive comment on product 

classes for ventless clothes dryers, specifically the 

current DOE clothes dryer test procedure does not 

contain provisions for testing the ventless clothes 

dryers. DOE invites interested parties to submit 

inputs on potential clothes dryer test procedure 

amendments for such testing, as well as data and 

information on the energy efficiency performance of 

those units. 

 MR. BROOKMAN: Okay. So we've already heard 

one report, that's good. Debra. 

 MS. BRUNK: This is Debra Brunk. This isn't 

specifically on the ventless clothes dryers, but it is 

on the test procedure. Back last year we had the 

Notice of Proposed Rulemaking on the standby portion of 

the test procedure for these products, and I guess I'm 

just curious what DOE's plans are in terms of making -- 

are there any plans to, as we review the overall test 

procedure changes for RMC and all of those kinds of 

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things, to also look at the proposed changes for the 

standby power and active modes. That certainly is 

addressed a lot here in the technical support document, 

but there's a lot going on with the standby, and I 

guess we're just curious if there'll be another 

opportunity to at least maybe review where DOE plans to 

head in that direction? 

 MS. REICH: Yes. The test procedure 

rulemaking is addressing both active mode and standby 

mode issues, and it is expected that there will be a 

supplementary NOPR that's published for that 

rulemaking. 

 MR. BROOKMAN: Yes, please. 

 MR. POPE: Ted Pope, I just wanted to seek 

clarification -- too much? 

 MR. BROOKMAN: Lift it up. 

 MR. POPE: -- clarification on the type of 

comments you’re seeking on a test method. Lane 

mentioned earlier, and we have similar concerns about 

not more accurately assessing the end-of-cycle energy 

use, and the relevance of automatic shut-off. Can you 

confirm whether DOE's open to comments on those aspects 

that don't relate to the ventless clothes dryer 

question? Is it wide open on active mode? 

 MS. REICH: Yes, it is. There are going to 

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active mode, and DOE welcome any inputs on all active 

mode and standby mode issues. 

 MR. POPE: Great. Thank you. 

 MR. BROOKMAN: Okay. Other comments? 

 MS. REICH: In terms of the active mode, 

specifically, that is a topic that DOE is considering, 

the automatic cycle termination, because it's 

recognized right now there is a single fixed credit 

that is available for clothes dryers that incorporate 

some type of termination sensory, either moisture or 

temperature sensing. And it's recognized that some 

approaches may be better than others, so there -- it's 

-- provisions are being looked at that would actually 

measure the effectiveness of a type of system that 

provides automatic cycle termination so that it 

recognizes that it's avoiding overdrying the clothing. 

 Other issues that are being addressed are 

related, primarily, to the fact that consumer usage and 

capabilities of the machines have changed since the 

last test procedure rulemaking. Specifically, people 

are using potentially different number of cycles per 

year. Clothes washers are resulting in clothes loads 

that are being put in the dryer with a different 

remaining moisture content that would impact the 

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measurement of the energy efficiency in the dryer, and 

that consumer load sizes are likely to be different 

than they were over the years. So each of these issues 

are being looked at. 

 Again, DOE welcomes all of the -- all of 

these inputs. However, because of the concurrent 

rulemaking schedules, the active mode issues have not 

been addressed in the preliminary analysis. So you'll 

see we're focusing primarily on standby power for this 

rulemaking at this time. 

 MR. BROOKMAN: Elizabeth. 

 MS. JOYCE: Hi, Elizabeth Joyce. I just 

wanted to reconfirm that we think it's very important 

that DOE does consider adjustments to the credit for 

automatic cycle termination, given some of the new 

findings that NRDC drafted for it, and also considering 

that DOE's analysis shows that -- assumes that even 

baseline units have -- for dryers -- have some kind of 

automatic termination feature, that it's very important 

that DOE consider that. 

 MR. BROOKMAN: Yes. Alex. 

 MR. LEKOV: Alex Lekov. Just one thing, very 

briefly, to mention that the proposed change for the 

test procedure in terms of usage patterns and 

capabilities are not considered in the test procedure 

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considerations, however, they're implemented in the 

preliminary analysis as related to life cycle 

calculations. 

 MR. BURT: Just to clarify, that was on the 

assumptions for the consumer use side and the initial 

moisture content and -- 

 MR. BROOKMAN: Yes, Alex. Lane, thank you. 

Alex, please. 

 MR. LEKOV: The assumptions applied in the 

life cycle cost analysis are changing the number of 

clothes dryer cycles per year, changing the RMC, and 

the dryer test load size. 

 MR. BROOKMAN: Thanks for that specificity. 

Okay. Other clarifications before we move on? 

 MS. REICH: Standby and off mode energy use. 

 DOE is required to consider that in the test procedure 

by EISA, and so therefore DOE has already initiated a 

rulemaking that has looked at standby and off mode 

energy use and has published a test procedure Notice of 

Proposed Rulemaking back in December 2008. Now what 

happened was that EISA requires DOE to consider the 

most recent version of the International Standard for 

measuring standby power, which is IEC standard 62301. 

And it was recognized at the time of the NOPR for the 

test procedure, or for DOE's test procedure, that IEC 

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was in the process of updating this 62301 standard, and 

DOE decided that it would be most beneficial to 

continue the rulemaking to allow it to consider any 

potential revisions to IEC 62301, because these would 

represent the industry's best inputs into how to 

measure standby power. 

 At the time that that decision was made, it 

was expected that the second version of IEC's 62301 was 

going to be issued in July 2009, but that rulemaking 

has been delayed, at least until the end of this year, 

so DOE determined that it would be appropriate to move 

on with the rulemaking and consider the language that 

has been incorporated into the most recent draft 

version -- it's identified as Committee Draft for Vote 

2, of IEC 62301. 

 So those proposed amendments for standby 

power and off mode power are being incorporated into a 

single rulemaking that now is also addressing active 

mode issues. 

 MR. BROOKMAN: Lane. 

 MR. BURT: Lane Burt. One note on the 

standby power. I'm glad that the Department is looking 

at this. It can be significant for clothes dryers. 

Ecos found that dryers' electronic controls have 

standby between 1.4 and 3.1 watts, but only needed to 

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have standby power in the range of 0.03 to 0.05 watts, 

representing over 400 kilowatt hours over the lifetime 

of the product. 

 MR. BROOKMAN: Thank you. Debra Brunk. 

 MS. BRUNK: Debra Brunk. I just wanted to 

note AHAM's support for DOE evaluating the most recent 

draft of the IEC 62301, second edition, CDV-2. We do 

believe that's the most appropriate draft, and I think 

moving forward, it does put DOE in harmonization with 

the -- certainly where Canada will be, but also Europe 

and most of the rest of the world. 

 MS. REICH: Moving to room air conditioners. 

 Again, this is a fairly concentrated market. DOE 

identified fewer than ten key manufacturers who are 

selling room air conditioners into the U.S. And as of 

2007, 70 percent was attributed to just four 

manufacturers. 

 At this time, DOE has not identified any 

manufacturers -- domestic manufacturers of room air 

conditioners, because all production has been moved 

outside of the U.S., and most of that has gone to Asia, 

although some amount may still be occurring in Mexico. 

 Also, significantly different since 2007, is that two 

out of the four manufacturers have exited the market 

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are about nine and a half million units being shipped 

annually. 

 MR. BROOKMAN: Yes. Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock, yeah, I -- 

a couple quick questions. It says production moved out 

of the U.S. When did that occur, just out of 

curiosity? Was it like last five years or ten years 

ago? And the reason I'm asking is how will that impact 

the manufacturing impact analysis? 

 MR. BROOKMAN: Yes. Detlef. Say your name, 

Detlef. 

 MR. WESTPHALEN: Detlef Westphalen. So the 

question is, what is the history of, I guess, the 

flight of manufacturing of room air conditioners out of 

the U.S.? 

 MR. ROSENSTOCK: And particularly when? 

 MR. WESTPHALEN: When? Well, my 

understanding is that this was happening all through 

the 90s, and, you know, certainly not within the last 

five years, probably more than ten years ago most of 

the trend. 

 MR. BROOKMAN: Okay. Thank you. Does anyone 

else wish to comment on that? No. Okay. Steve, are 

you okay? 

 MR. ROSENSTOCK: Well, again, there's a 

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section in the analysis that talks about manufacturer 

impact analysis, and since all the manufacturers are 

overseas, you know, it's kind of an interesting point 

in terms of are we trying to determine the impact on -- 

I could have said competitors, but now all the 

manufacturers that are overseas, and there's no 

domestic manufacturing impact, so I'm just kind of 

curious, you know, what exactly -- I know there should 

be -- there probably should be analysis, but there is 

no domestic impact. 

 MR. BROOKMAN: Let's raise it then. Okay. 

 MS. REICH: I'm going to let Detlef answer 

that question also. 

 MR. WESTPHALEN: No comment. 

 MS. REICH: No? 

 MR. BROOKMAN: Mike Rivest. 

 MR. RIVEST: Steve, in doing the 

manufacturing impact, part of our job is to make the 

conclusions that you just made, so I think we identify 

the manufacturing, the location of manufacturing 

facilities, if that's available, and the number of 

employees in the industry, both domestically and 

internationally. And in terms of our modeling of the 

industry, it's become impossible to segregate companies 

that are U.S. owned with manufacturing in the U.S. and 

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Mexico, overseas, so we don't try to separate out the 

financial modeling. But all the impacts on 

manufacturing capacity and employment are treated 

separately, and that information is presented that way. 

 MR. ROSENSTOCK: And you're going to 

determine the impact on overseas employment? 

 MR. RIVEST: We've determined the -- yeah, 

the overall impact on employment of the industry, and 

then as a subgroup of that, local employment. 

 MR. BROOKMAN: That's down the road. Go 

ahead. 

 MR. BOWLEY: Yeah, this is Brice Bowley, 

General Electric. I'd like to at least state that even 

though most of the manufacturing or all of the 

manufacturing is now in Asia, that the revenue from 

that does help fund the research and manufacturing for 

domestic production of other appliances. So I wouldn't 

say -- the actual manufacturing jobs are in Asia, but 

it does help fund other research and work done in the 

U.S. 

 MR. ROSENSTOCK: Thank you very much for 

that. I appreciate that. But the DOE's analyses tend 

to segregate out just solely the impact on that 

industry, so that's why I was asking. They don't do 

any cross-over, spill-over effects when they do that 

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 MR. BOWLEY: I guess my point is there is 

some spill-over effect there, so. 

 MR. ROSENSTOCK: Okay. Thanks. 

 MR. BROOKMAN: Thank you. Okay. Let's move 

on. 

 MS. REICH: DOE is proposing to use the 

existing 16 product classes for room air conditioners, 

12 of these came about originally from NAECA, four more 

were added in '97 in the last rulemaking, and again 

these are categorized into groups based on whether it 

has reverse cycle or louvers, whether they're casement 

type products, and also by capacity. 

 On the test procedure side for room air 

conditioner, similarly to clothes dryers, EISA has a 

requirement that DOE shall examine standby and off mode 

energy use and incorporate it into the energy 

descriptor in the test procedure if it's technically 

feasible. So, along with the clothes dryers, they were 

-- clothes dryers and room air conditioners are bundled 

together. The test procedure purposes into a single 

rulemaking for which a Notice of Proposed Rulemaking 

was published back in December 2008 as well. 

 Again, similar to clothes dryers, DOE 

continued the room air conditioner test procedure 

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rulemaking so that these revisions to IEC 62301 could 

be considered, and now the room air conditioner test 

procedure amendments will be addressing the standby use 

and active mode issues. 

 On the active mode side, the issues DOE is 

considering are how many hours of use consumers are 

using the room air conditioners, and also the fact that 

the referenced external standards it uses for its 

methodology, an AHAM test standard and also one from 

ASHRAE, are both quite, I shall say, aged, and so DOE 

is considering the most recent versions of those, 

referencing the most recent versions, the AHAM RAC 1-

2003, and ASHRAE 16-1983, which was approved for update 

in 2009. 

 MR. BROOKMAN: Debra Brunk. 

 MS. BRUNK: This is Debra Brunk. I just want 

to note that the AHAM RAC-1 is now actually AHAM RAC-1-

2008. It's an ANSI AHAM standard. 

 MS. REICH: Okay. The preliminary analysis 

for room air conditioners consistent with EISA's 

requirement that, because of the expected final rule 

date for these energy conservation standards, DOE must 

consider standby mode and off mode energy use. This 

analysis has been conducted on the basis of an 

assumption of the 750 annual active mode hours, and 

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5115 standby mode hours. During -- when DOE published 

the framework document, there was some discussion about 

whether 750 hours is still a representative number for 

the active mode, and in fact, well, the discussion had 

been whether that number should be reduced. But as 

part of this -- these analyses, particularly the life 

cycle cost analysis, research there indicates that, in 

fact, those numbers may be on average, higher than 750. 

 Given this kind of uncertainty, DOE is 

proposing for the purpose of today's analysis, to base 

the integrated metric on still using the 750 active 

mode hours. 

 MR. BROOKMAN: Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock. On your 

second bullet point, the active mode hours can be 

higher than 750, is that for both residential and 

commercial types of applications, or just one of them? 

 And then I have a second question. 

 MS. REICH: Alex can correct me if I'm wrong, 

but I think that's for both. 

 MR. BROOKMAN: Alex Lekov. 

 MR. LEKOV: For residential applications 

which the Department has determined in the range of 90 

percent of the entire market, it is about very close to 

750. For commercial, it is significantly higher. 

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 MR. ROSENSTOCK: Thank you. Second question 

I had for the standby hours of 5115 hours, that's about 

equal to seven months of standby, and is that like a 

weighted average of those consumers or businesses that 

actually unplug the room air conditioners, that somehow 

you have a power strip to turn them off, versus some 

that leave them plugged in all year? Because if it was 

-- if they're plugged in all year, it would be 8010, 

basically, versus -- and if they were unplugged, it 

would be closer to like 2000. 

 MS. REICH: It does consider the portion -- 

 MR. ROSENSTOCK: Kind of a weighted average? 

 Thank you. 

 MS. REICH: In order to integrate standby 

power into the metric for room air conditioners, right 

now the efficiency metric is an energy efficiency 

ratio, defined as the cooling capacity divided by the 

input power. In order to roll in standby power, the 

integrated metric is defined on an annualized basis, 

where now the cooling capacity is multiplied by the 

number of active mode hours. The power consumption in 

an active mode is also multiplied by 750 hours, and 

then it's added to the standby energy use in this 

average 5115 hours. 

 MR. BROOKMAN: Brice. 

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 MR. BOWLEY: Brice Bowley. Just have a 

question. Looking at the calculation, what happens if 

you have an appliance that has both standby and off 

power. I understand that's not common in the market 

now, but going forward with standby becoming a more 

important, you know, factor to control, we see 

appliances potentially having an optional button to 

turn power off to the unit to reduce the power 

consumption in the non-active modes. So I guess my 

question is, is how do we address room air or other 

appliances that now actually have the possibility for 

both off and standby? 

 MS. REICH: In the test procedure rulemaking 

that was only looking at standby power, it was proposed 

that, as you say, that a unit would be either in the 

off or inactive mode. It was also proposed that if it 

had the capability for both, that those would be 

roughly half of the hours annually would be attributed 

to each mode. Not really having any information to 

come up with any sort of different weighting, but that 

-- that has been available for comment, so any data 

that we have and can receive would be certainly 

appreciated. 

 MR. BOWLEY: I guess the only concern I would 

have of weighting it fifty-fifty is that doesn't really 

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give manufacturers as much incentive to add an 

additional feature to have an off mode. Whereas if it 

was, if we have one or two watts in standby, and we 

have an off mode that's 0.05, attributing it all to the 

off mode actually makes it more likely to have that 

option to consumers. 

 MR. BROOKMAN: Thank you. 

 MR. WITKOWSKI: Stephen Witkowski, DOE, and 

again, if you have any data or specific examples, DOE 

welcomes that information, and we will certainly look 

at it. 

 MS. REICH: All right. For the technology 

assessment, again, DOE tries to gather as much 

information as possible about all possible technologies 

that can improve efficiency. The starting point is 

often the technical support document from previous 

rulemakings, but then DOE supplements that with more 

recent information from as many sources as possible, 

which can be a literature review. DOE observes 

technologies that have been implemented when it 

conducts its reverse engineering, and also, really 

solicits information from as many interested parties as 

it can. Comments that are submitted during 

rulemakings, as well as manufacturer interviews. 

 The technologies are narrowed down into 

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specific design options that are considered later, 

using screening criteria that are laid out by DOE. 

These consist of, first of all, technological 

feasibility, and this would be whether it has been 

demonstrated in a prototype or has already been 

commercialized and is available on the market. 

 Second, is that the technology must be 

practicable to manufacture, install, and service, on a 

scale that's necessary for the industry at the time 

that any upgraded standards become effective. 

 The third criterion is whether there are any 

impacts on utility or product availability. 

 And finally, of course, needs to consider 

health and safety issues. 

 When DOE applies these screening criteria, 

first of all for residential clothes dryers, out of the 

18 technologies that were identified, three were 

screened out. Microwave drying was eliminated on the 

basis of potential safety concerns that were never 

really solved back a number of years ago when certain 

prototypes were being developed, and it's never 

progressed to DOE's knowledge past that point. Water 

cooling for ventless units and indirect heating, in 

which some of the heat for drying is derived from a 

home's hydronic heating system were eliminated due to 

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the complexity of installation and servicing issues 

that would violate the criteria on whether this could 

be installed and serviced on a scale that's necessary. 

 So that left 15 design options for clothes dryers. 

 For room air conditioners, all of the 

technologies that were identified were found to have 

met the criteria, and therefore were carried through to 

the engineering analysis. 

 Even though the technologies mentioned before 

had met the screening criteria, in fact, there are also 

some of those technologies that could not be evaluated 

in the engineering analysis for a couple of reasons. 

For dryers, reverse tumbling was found to have 

negligible energy benefits. The -- as it turned out, 

the primary purpose of that is to prevent wrinkling in 

clothing, and so it provides some utility, but it does 

not save any energy. Then as we've discussed before, 

the improved cycle termination can't be measured right 

now according to the test procedure. So those were 

eliminated from consideration for clothes dryers. 

 For room air conditioners, there were some 

technologies, a number of them that the components were 

already believed to have been optimized for the 

application, and therefore there were no improved 

designs that aren't already being used, specifically, 

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the improved fin design, two design improvements to the 

indoor blower and the outdoor fan efficiency. 

 Other technologies, again, are implemented. 

These are, again, just standard practice: the 

hydrophilic film coating on the fins, and the spray 

condensate -- those, again, based on DOE's research and 

observations, they appear to be industry standard, so 

these are not opportunities to improve efficiency above 

what's already being done. 

 And finally, due to the conditions of the 

room AC test procedure, which tests the units at fixed 

environmental conditions, certain technologies which 

are appropriate under changing conditions aren't 

captured -- the improvement, although it may be seen in 

the real world isn't captured by the test procedure, 

namely the variable speed compressors, the thermostatic 

electronic expansion valves and thermostatic cyclic 

controls. So those, too, were eliminated prior to the 

start of the engineering analysis. 

 MR. BROOKMAN: Lane Burt. 

 MR. BURT: Yes, I just wanted to reiterate 

that we feel very strongly that improved termination 

should be scrutinized to the highest level. Secondly, 

I think the Department's assumption in the test 

procedure of all synthetic mixed fabrics may be 

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underselling the efficiency value of a reverse tumble. 

 Cotton does tend to ball up when rotated in one 

continuous direction, as do other natural fabrics. So 

perhaps that test procedure assumption is causing you 

to underweigh those potential benefits. 

 MS. REICH: Okay. And certainly if you have 

any information on appropriate changes to the test 

cloth, that would be welcome. 

 MR. BURT: We would suggest a mix of 100 

percent cotton and 50:50 as an alternative to what the 

Department does right now, which is all 50:50. 

 MS. REICH: Okay. Just listing here, I won't 

go through these in detail, but these are the clothes 

dryer design options that are carried through. If 

anybody has questions on specific technologies, let me 

know. And similarly, the room air conditioner design 

options. DOE would welcome any comments and data 

regarding any additional design options or variants of 

the design options that are already being considered 

that can provide efficiency improvements for both 

clothes dryers and room air conditioners, including 

those that may not yet be on the market. 

 MR. BROOKMAN: So you can see a complete 

listing on those two slides, 26 and 27, comments on 

those? Okay. 

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 MS. REICH: Okay. As everybody is probably 

familiar -- 

 MR. BROOKMAN: We have one. Lane, please. 

 MR. BURT: I do have one quick question. I 

didn't have a chance to really scan it, but the impact 

of the intake air from the dryer and its impact on the 

air conditioning system, is that considered? So if the 

option is to draw outdoor air versus indoor air, 

depending on what is more ideal for actually drying the 

clothes. 

 MS. REICH: Right. In terms of -- is it in 

terms of infiltration of ambient air or -- 

 MR. BURT: No, the actual intake -- air 

intake into the dryer itself. Ecos suggested that 

there may be potential for savings by allowing that 

design option, just a duct on the dryer that could be 

activated or not activated, depending on when it's more 

useful. 

 MS. REICH: Okay. 

 MR. BROOKMAN: Ted. 

 MR. POPE: Ted Pope. Along the same lines, I 

noticed that the TSD mentioned that DOE didn't think 

there was energy penalty for increased infiltration, 

and I could understand that during the heating season, 

but I wasn't clear how DOE came to that conclusion for 

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 MS. REICH: Right, you know, I think it's an 

issue of a lack of data showing the effects, and that 

the issue is, on balance is there a net effect, and so 

it's not known what percentage of the time that's going 

to have a net positive impact versus a negative impact. 

 So in the absence of that kind of information, DOE 

believes that on average the net effect is probably 

about even. 

 MR. BROOKMAN: Ted. 

 MR. POPE: Sorry, Ted Pope. Can you explain 

what the benefit is? I don't see that. I just see 

half -- half the air being a penalty as opposed to -- 

 MR. BROOKMAN: Let me ask first. You have 

data as she might desire? 

 MR. WITKOWSKI: Yeah, Steve Witkowski, DOE. 

I'd like to emphasize that, you know, what we're here 

for is to receive input data and information. Again, 

our analyses are based on the best data we have. There 

are a lot of theoretical discussions that go on as to 

possible benefits, but until DOE has something solid to 

base it on, we really aren't here to get into 

discussions over what may or may not be benefit. And 

again, we strongly urge any input data or peer reviewed 

articles or whatever may help us change our analyses. 

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 MR. BROOKMAN: Lane. 

 MR. BURT: We will submit that table that 

Ecos developed that has dryer energy consumption, 

kilowatt hours per load for various weather and 

locations. 

 MR. BROOKMAN: We look forward to that. 

Thank you. 

 MS. REICH: Okay. So, again, probably 

everybody has seen this slide quite a bit. This is to 

show fundamentally what the purpose of the engineering 

analysis is, which is to define what the relationship 

is between incremental improvements in efficiency of 

the product and what the impact on the manufacturing 

cost will be. The curves that are generated from this 

are used in the downstream analysis that look at the 

life cycle cost and pay back period, national impacts 

on the manufacturer impact analysis. 

 DOE takes multiple approaches in developing 

the information for the engineering analysis. The 

primary source of information is initially data that is 

provided by AHAM, that is an aggregate of various 

manufacturers’ submissions, and in this particular 

case, AHAM was able to submit data for clothes dryers, 

but did not receive sufficient information from room 

air conditioner manufacturers that would allow it to 

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aggregate it and potentially not reveal any proprietary 

information. 

 So, then DOE also reviews the analysis that 

was done previously, in former rulemakings, and then 

conducts a reverse engineering analysis in which 

samples of products are tested and torn down, and a 

manufacturing cost model is developed. DOE also 

conducts manufacturer interviews with as many 

participants as are willing to provide information, and 

also in this particular case, for room air 

conditioners, to supplement the fact that we didn't 

have the AHAM data as a starting point, DOE interviewed 

a number of component vendors and developed an energy 

model. 

 For clothes dryers, DOE conducted the 

analysis on all the product classes. Due to the large 

number of room air conditioner classes, DOE selected 

some representative room air conditioner classes that 

had a high number of shipments in them, and then 

extrapolated the results to the other product classes. 

 Just run through this very quickly, how the 

cost models are developed. They consist of a per-unit 

cost, the full production cost, plus conversion costs 

that are experienced by the manufacturer. These 

material and component costs are developed during the 

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reverse engineering process, and the cost model that is 

built from that information includes not only the 

manufacturing costs, material costs, but labor and 

overhead as well. 

 Once these manufacturer costs are determined 

-- manufacturer costs are developed, these are 

supplemented with interviews that allow DOE to further 

refine the results. 

 In terms of the reverse engineering, this is 

where specific units are pulled apart and evaluated, 

and the key part of this process is in the selection of 

the units to tear down. DOE attempts to find 

representative models that span the range in efficiency 

from a baseline efficiency to max-tech, and tries to 

evaluate if there are different types of platforms 

available also. They're taken apart, a bill of 

materials is created, and also the different types of 

fabrication processes and assembly processes are 

estimated based on what's observed and the net result 

from a very large, complex Excel spreadsheet is the 

manufacturing cost. 

 Okay. For this rulemaking, DOE is 

considering integrated efficiency metrics, and is 

proposing new metrics that are based on the existing 

ones that now incorporate standby mode and off mode 

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energy use. And for clothes dryers, rather than the 

energy factor, it's now an integrated energy factor, 

and similarly for room air conditioners, it's an 

integrated energy efficiency ratio. 

 I've already mentioned the IEER, the 

rationale for that calculation. For IEF for clothes 

dryers, normally that's a -- it's a per cycle 

measurement. It's test load pounds per kilowatt hour 

of energy use. Now, in this metric, in order to obtain 

a per cycle standby power input or contribution, the 

standby power is taken -- is measured over the annual 

number of standby hours, and that then is segmented 

into -- by the number of cycles per year, segmented 

into the contribution of standby hours for that given 

cycle. 

 MR. BROOKMAN: Yes, Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock. Yeah, 

looking at this IEF for clothes dryers, with 8620 hours 

in standby, and the -- which leaves 140 hours for 

active, if the assumption is 416 hour annual dryer 

cycles, that's 20 minutes per dryer cycle. I don't 

know if that's really accurate or not, so you might 

want to review those numbers. Thank you. 

 MR. BROOKMAN: Lane. 

 MR. BURT: On the IEF, is the Department of 

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Energy considering larger changes to the efficiency 

metric. We would suggest that pounds of water removed 

per unit energy would be much more usable to the 

consumer in evaluating whether this dryer is more 

efficient than that, and also would be more reflective 

of the actual conditions where the dryer is put in, 

where you might need to take out a lot of water from a 

heavily saturated cotton load, versus a little bit of 

water from the same size load with a fabric that dries 

much quicker. 

 MR. BROOKMAN: Thank you. 

 MS. REICH: For clothes dryers, an efficiency 

level approach was taken in which a baseline unit is 

categorized, and then based then on efficiencies of 

products that are currently on the market, efficiency 

levels up until the maximum, the highest possible 

efficiency are defined. Then during the reverse 

engineering, the tear-down analysis looks at units in 

the test sample that were selected at each one of those 

efficiency levels, and determines what the typical 

manufacturing costs will be for that unit, and thus at 

that efficiency level. And from these, the cost 

efficiency curves are generated. 

 For the baseline vented clothes dryers, 

because existing -- or because federal standards 

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currently exist for these products, at least for the 

active mode, DOE used those standards as the baseline 

efficiency level. For ventless units, since these are 

not currently covered products in the standards, DOE 

estimated what the baseline efficiency in active mode 

would be based upon its own testing. Actually, I'm 

sorry, that was based on -- yeah, information from an 

independent lab that conducted the tests, and it's 

important to note that these were tested under 

conditions of the DOE test procedure, the only 

difference being the removal of that exhaust simulator. 

 For standby and off put energy use, DOE did 

do its own testing, and determined what an average 

energy use in those modes would be among the sample 

units, and then the baseline integrated energy factor 

was created from the combination of those values. 

 This chart shows the values that are used. 

The first column are for the vented dryers, those are 

the existing standards. The last two values in that 

column were the test values. And in DOE's tests it 

determined that an average of two watts of standby 

power were observed. So the net effect of that is to 

reduce the level of the integrated energy factor a 

little bit lower than the existing energy factor 

because of that extra energy use that had not been 

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previously accounted for. 

 Then to determine, for active mode efficiency 

levels above the baseline, a number of different 

sources are used to find efficiency data. There are a 

number of product databases that are available, various 

manufacturer information catalogs and journals, 

provide the information, and in some cases, 

particularly at the max-tech, if these are prototype 

technologies that discuss what a percentage efficiency 

improvement is available, that will be factored in. In 

addition, feedback is obtained from comments that were 

received at the framework stage and from interviews 

conducted with the manufacturers. 

 The only clothes dryer class for which this 

type of information was not available, were the vented 

electric compact 120 volt units, because such 

information on products is just not available. DOE is 

not aware of information on these units, and therefore, 

had to scale the efficiency levels above the baseline 

from that of -- by the same ratio as the baseline 

values for electric standard dryers. 

 For standby mode, DOE was able to identify 

possible reductions in standby power associated with 

some specific technologies, and the features that were 

observed for clothes dryers were improvements in the 

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power supply and the implementation of an automatic 

power shut down. For the units in DOE's test sample, 

no off mode capability was found -- was observed, and 

therefore in this analysis, only standby power is being 

addressed. 

 In order to move from active mode efficiency 

levels to an integrated efficiency level, DOE needed to 

figure out where to -- how to apply improvements in 

standby power, how they would relate to improvements in 

active mode energy efficiency. And the assumption DOE 

made would be that a baseline unit would remain at the 

baseline two watts even as active mode energy 

efficiency is improved for any efficiency level that 

did not strictly require electronic controls because, 

of course, in order to achieve standby power reduction, 

you'd have to have standby power with the electronic 

controls. So at the efficiency level at which a 

clothes dryer must have electronic controls, at that 

point DOE determined where it would be most cost 

effective in terms of how much would IEF be impacted by 

unit cost for either an active mode improvement or a 

standby mode improvement, and put that in at the point 

where it was most cost effective. 

 So it's a little confusing, but maybe I can 

explain it better by seeing where these -- how the 

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efficiency levels -- integrated efficiency levels wound 

up. So again, at the baseline level, DOE assumed that 

there would be two watts of standby power, and this is 

because DOE observed that baseline products could 

either have electromechanical controls or electronic 

controls, so it assumed that if there was standby 

power, that that would be two watts. 

 At the higher level -- at higher levels it 

required efficiency level three before a clothes dryer 

must have electronic controls to achieve that active 

mode efficiency, and therefore, starting at -- starting 

above level four, it was cost-effective now to start 

improving standby power. There were two levels that 

were defined, going from a two watt standby power at 

the baseline, to a one and a half watt, which was 

associated with the improvement in the power supply, 

and then an additional step to implement an automatic 

power shutdown resulted in efficiency level five. 

 Perhaps not unexpectedly, these were added in 

prior to the heat pump technology, which is the maxtech level, because the improvements in energy 

efficiency were more cost effective than the heat pump 

technology. 

 MR. BROOKMAN: Ted. 

 MR. POPE: Sorry, just a question. I 

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apologize for not understanding this, but what is 

causing a two watt standby for mechanically controlled 

units? 

 MS. REICH: It's not for electromechanical, 

but DOE recognizes that there are a fair number of 

units that have electronic controls even at the 

baseline efficiency, so it assumed that for those units 

there would be a two watt standby level. 

 MR. POPE: I'll think more about that. Thank 

you. 

 MR. BROOKMAN: Steve. 

 MR. ROSENSTOCK: Steve Rosenstock. Yeah, 

what percent of the marketplace has the, I'll say 

mechanical for lack of a better word, mechanical versus 

all electronic type of features where, you know, the 

more mechanical or older style has zero watt standby 

and the electronic have two watts. Is there -- do you 

have some figures because, again, I'm saying like if 

the market's like 50:50 then you might be overstating 

the national energy savings. 

 MS. REICH: Right. I don't have market 

information. I believe in our test sample, I believe 

it was weighted more to having the electronic controls 

at the lower efficiency. 

 MR. BROOKMAN: We'll give that time to dwell 

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 MS. REICH: Okay. These are the integrated 

efficiency levels for the ventless electric compact 

units. Again, for the baseline, it's assumed for all 

clothes dryers that the same standby power levels are 

appropriate, so that at the baseline all ventless units 

are presumed to have electronic controls, so the 

standby power levels would be layered in right above 

the baseline. 

 There are two additional gap-fill levels. 

These are based on -- let's see, there was a waiver 

that was granted to Miele for a condensing unit that 

said that Miele agreed that its condensing unit, when 

tested to the DOE test procedure without the simulator, 

would achieve 82.5 percent of the efficiency of an 

electric standard unit, so that was the source of one 

gap-fill active mode level. The second one was derived 

from NIST data, and finally the heat pump active load 

efficiency level was derived from test data that 

indicated what percentage improvement could be achieved 

by implementing that. 

 For all levels above where automatic power 

shutdown is first implemented, it's assumed that that 

would be maintained at higher efficiencies. 

 Similarly, there is a -- we have the 

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information for combination washers and dryers. At 

this point it did not become cost effective to layer in 

standby power until after the second efficiency level, 

and again, we have the heat pump technology as the maxtech. 

 Okay. Now I'm going to have a number of 

charts with a lot of cost information. I won't go 

through each number individually, but as a function of 

IEF, this presents the results for the integrated 

incremental manufacturing costs. And what you'll see 

that, of course, we start at a zero incremental cost at 

the baseline, and these are the results of DOE's cost 

analysis up to the max-tech. I just want to note again 

that this cost includes the material, labor and direct 

overhead that's used to manufacture the product. 

 These are the results for two of the vented 

product classes, the electric standard and the electric 

compact 120 volt. This chart shows the results for the 

remaining two vented product classes, the electric 

compact 240, and vented gas. 

 The third slide shows the cost information 

for the ventless product classes, the electric compact 

240 volt, and the combination washer and dryer. Any 

comments? 

 MR. BROOKMAN: Hang on. A lot of data. Tim. 

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 MR. BALLO: Tim Ballo, Earthjustice. If we 

could just back up for a second to the issue of the 

electromechanically controlled dryers, and the 

inclusion of a two watt standby for those models when 

calculating the IEF. I think, and this is just 

thinking out loud without -- I haven't really thought 

about it fully, but the Department might run into a 

problem with the anti-backsliding provision of EPCA if 

it does not adopt a standard, or if it adopts a 

standard that actually, because of the two watt standby 

into the IEF metric, would essentially lower the 

efficiency requirements for electromechanically 

controlled dryers. If the existing energy factor’s at 

some level, I think it's -- let's say it's at 3.01 for 

electric standard dryers, if DOE adopts a integrated 

energy factor that has the effect of allowing some 

additional cushioning for electromechanically 

controlled dryers, because of that two watt standby 

that they don't actually use, I think it might run 

afoul of the anti-backsliding provision. 

 MS. REICH: That's a very good point. It's 

certainly something that should be taken into 

consideration. 

 MR. BROOKMAN: Tom Eckman. 

 MR. ECKMAN: Tom Eckman, Northwest Power 

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Council. It seems to me we've got a bit of a conundrum 

here with respect to the two watt standby, because I 

think it's almost tautological. Since we're not 

dealing with early termination controls, which require, 

probably, electric circuit board or something with the 

control to determine moisture content, and 

automatically shutting down the unit, you're giving the 

two watt standby all the burden of just -- the cost 

burden on only changing standby losses, when, in fact, 

that electronic control could be used for early 

termination, or termination when the moisture content 

is adequate. So you're not seeing the benefits because 

the test procedure doesn't recognize that. So you're 

putting all the burden of the cost, basically, on the 

one watt or point five watt reduction for standby, and 

none of the benefit that you get by going from 

mechanical to electronic controls for moisture 

termination reasons. So I think that's -- you can't 

get there that way, because the test procedure doesn't 

allow it, so I think you've got to go back and have a 

different decision tree here, because it doesn't -- if 

you follow the test procedure that would take advantage 

of termination when moisture is low enough to be 

acceptable, then the benefits of reducing -- the cost 

of moving to electric -- electronic controls are shared 

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over more benefits. So they're in the wrong place in 

the stack. 

 MS. REICH: I don't disagree with your 

comments at all, and, you know, certainly the hope is 

that as the test procedure rulemaking proceeds, that 

the issues such as being able to more effectively 

measure the automatic cycle termination can be 

incorporated and evaluated in the efficiency levels. 

 MR. ECKMAN: Given the credit that's provided 

automatically now for termination with moisture 

controls instead of time, you automatically are 

excluding that as a benefit because everybody gets it, 

simply, and there's no cost shown for it. If you put 

that -- so I think it needs to be in at least the 

baseline cost analysis that if a product is receiving 

the 18 percent credit for that type of device, then the 

cost of that type of device needs to be there. Well, 

that's electronic controls. 

 MS. REICH: Right. And for those baseline 

units that have electronic controls that already is 

incorporated. 

 MR. ECKMAN: Well then the two watt standby 

isn't necessary for those baseline units. Because they 

can do better with electronic controls. 

 MR. BROOKMAN: Mr. -- say your name, please. 

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 MR. BATTAGLIA: James Battaglia. Well, for 

the automatic termination, electronic controls are not 

necessarily required, so the baseline assumption was 

that automatic termination was present, so that twelve 

percent credit is in the baseline. 

 MR. BROOKMAN: Who do you represent? 

 MR. BATTAGLIA: Navigant Consulting. 

 MR. BROOKMAN: Thank you. 

 MR. BATTAGLIA: Does that answer your 

question? 

 MR. ECKMAN: So that electronic -- you can 

terminate on the basis of moisture with mechanical 

control? 

 MR. BATTAGLIA: Well, you can terminate it on 

the basis of a temperature sensor, which also gets you 

that automatic termination credit, yeah, in the exhaust 

air. For moisture sensing, you can use a separate 

electronic control, but I don't believe we saw that 

that was consuming any standby power. 

 MR. ECKMAN: But a portion of the cost, I 

think, has to -- it's connected with the test procedure 

because you're not recognizing the differential control 

capabilities of mechanical versus electronic controls. 

 MR. BROOKMAN: Tom, maybe we could discuss 

this at the break. 

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 MR. ECKMAN: I think that's -- until those 

are linked together, we're going to miss this. 

 MR. BROOKMAN: Steve. 

 MR. WITKOWSKI: Yes, Steve Witkowski, DOE, 

again, we welcome comments, and there is a comment 

procedure and if you take issue with this, or if you 

want to bring this up in the other test procedure, it 

really helps if there's written documentation or 

written arguments submitted, particularly with data. 

 MR. ECKMAN: Yeah, I'm just -- 

 MR. WITKOWSKI: We encourage you to -- 

 MR. ECKMAN: -- falling to the -- with the 

perception that the two watts are being granted to a 

baseline unit that already has electronic controls in 

it, and then the cost is being added later for 

electronic controls somewhere down the stack, just 

doesn't seem logical. The baseline unit already has 

electronic controls. 

 MR. BROOKMAN: Okay. Okay. 

 MS. REICH: Okay. Just for comparison 

purposes, what's presented here is, on the left hand 

side are the cost increments that DOE determined on the 

basis of its reverse engineering, and on the right hand 

side are the values that were submitted by AHAM, that 

represent the aggregated industry numbers. 

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level is based on prototype technology, AHAM was unable 

to provide information there. 

 Also, for gas clothes dryers -- I'm sorry, 

the last set was for electric clothes dryers, these are 

for vented gas clothes dryers. DOE's numbers again on 

the left, AHAM's numbers on the right. 

 For room air conditioners, a different 

approach was taken. Rather than an efficiency level 

approach, a design option approach was used. 

 MR. WESTPHALEN: Now, the agenda calls for a 

break right now, but if we want to keep moving along. 

 MR. BROOKMAN: How long is your segment? 

 MR. WESTPHALEN: Twenty slides, roughly. 

 MR. WITKOWSKI: I would suggest a break. 

 MR. BROOKMAN: Let's take a break. Okay. 

It's now 10:40 by my watch. We'll break for 15 

minutes, which means we'll resume at 10:55 in this 

room. While you're in the Forrestal Building you must 

wear a badge visible, and if not, someone will escort 

you. 

 (Whereupon, a 16 minute recess off the record 

was taken.) 

 MR. BROOKMAN: Okay. Let's proceed. We're 

going to hear from Detlef. 

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 ENGINEERING ANALYSIS FOR ROOM AIR CONDITIONERS 

 MR. WESTPHALEN: Okay. I'll give everybody 

just one half a minute. Okay. I'm Detlef Westphalen. 

 I'm going to be presenting the section of the 

presentation on engineering analysis for room air 

conditioners. 

 Engineering analysis for room air 

conditioners was very similar to what is normally done, 

and very similar to what Judy described for the clothes 

dryers. Just top level, two key differences. In the 

data gathering effort that AHAM conducted, insufficient 

numbers of manufacturers provided data for AHAM to 

aggregate and provide that information to DOE. So that 

was a source of information typically provided that we 

did not have. And also, the transition in refrigerants 

from HCFC-22 to R-410A, I guess, prevented us from 

analyzing the products that will be regulated when the 

rule takes effect. And so some of the things that we 

did, were trying to deal with those differences. 

 Top level results, I think there are some -- 

one of the comments addresses the question of size 

impacts on the room air conditioners and I think that's 

one of the key issues that, you know, from our analysis 

it looks like cost effective efficiency improvements 

can be made, however, to some extent, in some cases a 

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greater extent than others, they're dependent on the 

ability to increase the size of the product. 

 The steps in the development, as mentioned, 

are very similar. Select representative products -- 

this started out by looking at what are the 

representative product classes, then selecting 

representative products of those classes that span a 

range of efficiency levels. Then developing 

definitions for the baseline and again, as you saw for 

clothes dryers, this was a little bit more complicated 

than it has been in the past, due to the standby and 

the integrated efficiency metrics that we need to 

consider. 

 Also involved in developing the baseline, we 

did energy modeling in order to define what is a 

baseline unit using R-410A refrigerant. 

 Then we also looked at the impact of 

different design options for increasing efficiency, and 

also for increasing costs. Tear down analysis was done 

for the reverse engineering aspect, and also to develop 

our manufacturing cost models, which we used to develop 

cost estimates for the baseline models and also the 

models with design changes. And ultimately, cost 

efficiency curves were generated as is done with these 

rulemakings and engineering analyses. 

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 Representative product classes. At the 

framework meeting, DOE proposed looking at three 

product classes, one, three, and five. These are the 

low capacity, mid-capacity, and high capacity for the 

window units, without reverse cycle. Window units are 

the ones with the louvered sides, and stakeholders 

suggested that DOE also look at product class eight, 

which is a product class covering the units that are 

built for through-the-wall installation. They don't 

have the louvered sides--because they're in the wall, 

air cannot be drawn into those units from the sides, it 

has to be drawn in from the back and then discharged to 

the back, so it's a very different product design. 

 DOE conducted the analysis in detail on these 

four product classes, and then extended the analysis 

numerically to the remaining twelve. This chart shows 

some of the information associated with prevalence of 

the different product classes. This is based on three 

databases from CEC, AHAM, and Energy Star. Ideally, we 

would have received data on shipments by product class, 

but as I recall, that information was not available, so 

we used this as a proxy to get an understanding of the 

importance of the different product classes. And as 

indicated, we selected one, three, five, and eight, 

which represent a large number of products that were 

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available in these databases. Those were selected for 

the analysis, the detailed analysis. 

 I mentioned the refrigerant change, R-410A. 

DOE conducted the analysis using energy modeling and 

constructed baseline designs with the models using R410A as the refrigerant. Now this work was based on 

tear-downs of units with HCFC-22 refrigerant. Energy 

modeling of the R-22 units and then with input we had 

received from vendors and discussions with 

manufacturers, modifications of those designs through 

the modeling to represent baseline R-410A models. And 

subsequently those models were further modified in 

order to look at different efficiency levels. 

 This chart just shows an example of some of 

the information that was input to the model, 

essentially, performance data for -- 

 MR. ROSENSTOCK: Steve Rosenstock, yeah, 

looking at this graph, it looks like there's a general 

lowering of efficiency using the R-410A compressors, 

kind of -- looks almost across the board. Is that what 

your testing found? It looks like it's in the five to 

ten percent range. Is that what the tests seem to 

indicate? 

 MR. WESTPHALEN: This is data obtained from 

compressor vendors. 

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 MR. ROSENSTOCK: Okay. 

 MR. WESTPHALEN: We did not do any 

calorimeter testing with compressors. And at the time 

we were doing this work, there really was only one 

product on the market that even had 410A refrigerant, 

that we were aware of. 

 This chart also shows -- and maybe I'm 

getting too much into detail in response to one of the 

comments from the framework phase, suggesting that we 

look at scroll compressors, and you can see the 

efficiency improvement shown by switching to scroll 

isn't really borne out by the data. 

 MR. GOUW: This is Sean Gouw from Southern 

California Edison. Just curious, what were the 

operating conditions for the test? 

 MR. WESTPHALEN: For these data? 

 MR. GOUW: Yes, for that data. 

 MR. WESTPHALEN: Those probably would have 

been the 45 degree evaporating condition, 130 

condensing condition, standard 20 degree superheat, 

leaving the evaporator, 15 degrees subcooling leaving 

the condenser. 

 MR. GOUW: Okay. Just wanted to point out, 

there is an interesting study done by NIST, where they 

compared R-22 and R-410A in a split system. They used 

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the same split system, and they found that condensing 

temperatures above 95 degrees is where you saw the drop 

in efficiency due to R-410A having the lower critical 

temperature. Just wanted to note that. 

 MR. WESTPHALEN: Okay. In response to that, 

I guess what you're suggesting is that this difference 

in efficiency may not be borne out at lower condensing 

temperatures, and in cases where use of a large 

condenser would have reduced condensing temperature, 

that effect would have been borne out in our energy 

analysis, because we used actual compressor performance 

data. 

 MR. GOUW: Okay. 

 MR. BROOKMAN: Thank you. 

 MR. WESTPHALEN: As with clothes dryers, we 

also were looking at standby power levels and 

incorporating them into the analysis at both baseline 

efficiency levels and higher efficiency levels. DOE 

measured standby power consumption of representative 

room air conditioners. The majority of the room air 

conditioners that were obtained for tear-down were 

electronic controlled. There were a few that were not, 

but the baseline assumption, the representative 

baseline product is assumed to have electronic control. 

 And two different standby power levels were 

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identified, based on different technologies used for 

the power supply for those units. 

 So the baseline efficiency levels were 

developed, including active mode efficiency, and the 

standby power level. And one thing I should mention 

here, for two of these product classes here, we 

conducted analysis on two different capacities of 

product, product class three and eight. We conducted 

analysis on both 8,000 and 12,000 BTU an hour units. 

 The baseline active mode efficiency level was 

selected based on the current standard, that's the EER, 

and then the baseline standby power energy use was 

selected as 1.4 watts, consistent with our 

measurements. And so the integrated energy efficiency 

ratios were calculated based on these numbers and the 

IEER equation that Judy showed previously. 

 Incremental efficiency levels were selected 

based on a review of available products. I mentioned 

the database, triple database, CEC, AHAM, and Energy 

Star. DOE combined all of this data and spent 

considerable amount of time looking at retailer and 

manufacturer websites to deselect products that 

obviously are no longer for sale, and so the list was 

then narrowed to a database that we felt was a credible 

list of actually on sale products for the time that we 

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were doing this assessment. 

 And so then DOE selected efficiency levels 

above the baseline, rounded to the nearest tenth, 

because we don't want to carry a standard to the 

hundredths, up to what was considered the suitable 

maximum levels. 

 MR. BROOKMAN: Elizabeth. 

 MS. JOYCE: Elizabeth Joyce, just a question. 

 If I read the TSD right, you did determine the maximum 

levels, again based on the Energy Star products, or the 

products that were available in the Energy Star 

database as of 2008? 

 MR. WESTPHALEN: That's correct. The maximum 

efficiency levels reported. 

 MS. JOYCE: Okay. Is it possible to consider 

more recent products that could have entered into the 

database since that time? Will DOE be able to consider 

that? 

 MR. WESTPHALEN: Yes, we have done some 

looking at available products recently, and for 

instance, the 12 at efficiency level five really hasn't 

been exceeded as far as we're aware. 

 MS. JOYCE: Okay. 

 MR. BROOKMAN: Brice. 

 MR. BOWLEY: Brice Bowley. Are any of the 

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models that are up there, like the max efficiency, are 

any of them 410A products? I know -- because there are 

a few products that were 410A at the time, so I 

wondered if any of those include the 410A. 

 MR. WESTPHALEN: Well, that's a good 

question. You look at, for instance, product class 

one, less than 6000 BTUs an hour. We stretched this 

product class to 12 because of the 6000 BTU an hour 

product, it's actually product class two, but there was 

no -- that was the 410A product. There was no reason 

to believe that -- 

 MR. BOWLEY: So I know what product that is, 

I guess. 

 MR. WESTPHALEN: Correct. Correct. 

 MR. BOWLEY: My only concern was -- 

 MR. WESTPHALEN: Well, if you do, yeah. 

 MR. BOWLEY: So what? 

 MR. WESTPHALEN: If you do know what product 

that is, yes. 

 MR. BOWLEY: Well, I suspect I know what 

product it is. The only question, I guess the concern 

is, there was an article in Consumer Reports about the 

deficiencies of some of the products meeting the high 

efficiency, specifically one labeled at 12 that was a 

410A product. 

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 MR. WESTPHALEN: Okay. We'll have to review 

that. 

 MR. BOWLEY: I can forward the article. 

 MR. BROOKMAN: Thank you. 

 MR. WESTPHALEN: We'd appreciate that. 

 MR. BROOKMAN: The Department would 

appreciate that. 

 MR. WESTPHALEN: So I think we've covered 

this slide. There's an additional slide showing the 

incremental efficiency levels for the other two product 

classes, and those efficiency levels were structured 

and developed in the same fashion as described for the 

previous two. 

 As mentioned, DOE conducted energy modeling 

in order to determine efficiency levels for these R410A products. The models were initially based on 

products that were received and reverse engineered, and 

then those models were matched with their reported 

performance and then adjusted, first, to develop an R410A baseline, and then subsequently modified to 

increase the efficiency levels. 

 The model that was used had been used in the 

previous room air conditioner rulemaking. As part of 

this rulemaking it was updated to include consideration 

of additional refrigerants, namely R-410A, and also it 

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was updated in the area of heat exchanger algorithms in 

order to allow assessment of microchannel heat 

exchangers and also incorporate more modern algorithms 

and correlations that have been developed for some of 

the other heat exchangers. It was also updated for 

Microsoft Windows operating system. 

 The model -- the energy model itself does not 

address air flow and energy use for fans, so off line 

analyses were done so that if we said, okay, well let's 

increase the air flow 20 percent, that we also 

considered the blower power that would be required in 

order to do that. 

 So here's a request for comment and it was 

initiated by the realization that at the framework 

phase DOE proposed the use of an efficiency level 

approach, however, because of the transition in 

refrigerant, there were no R-410A models to look at for 

reverse engineering and analyzing using the efficiency 

level approach, so the methodology was modified, so DOE 

requests comments initially on that. 

 MR. BROOKMAN: You can see the comment box. 

DOE adopted an approach relying more on design option 

analysis using both energy modeling and manufacturing 

cost modeling to determine the impacts of efficiency 

improvements for the products. Any comments on that? 

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No? 

 MR. WESTPHALEN: As mentioned at the start of 

my discussion, one of the issues that we came across 

was clearly if you let the size of the box grow, 

there's more room for larger heat exchangers, and it's 

much more cost effective to increase performance than 

if you restrict the growth of the box. And as part of 

the analysis, DOE considered growth in two steps for 

all of these product classes for which growth is 

possible, that is the window units. This step was not 

taken for through-the-wall units which are basically 

sold at a fixed size, and that has to do a lot with the 

fact that it's a heavily geared towards a replacement 

market, where you have existing sleeves, and if you 

made it larger, you couldn't sell that product any 

more. 

 But for the window air conditioners, DOE 

considered two steps in size growth for each of these 

product classes, and the details are shown a little bit 

better in the TSD. However, there's clearly a 

question, and this was brought up in framework meeting 

and comments, that there's a consumer utility impact of 

larger box size. And so at this point, during the 

preliminary analysis, DOE did not have good -- a good 

understanding of what is an acceptable growth in size. 

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 For instance, what are the window sizes, what's the 

distribution of window sizes in the markets where these 

products are sold? How big can the product class five 

get? What is the dependence on sales rates, on, for 

instance, impulse buy on a hot July afternoon, of how 

big the unit is or how heavy it is? And absent that, 

DOE conducted the analyses, but there's still the 

question out there of what kind of size limitations 

might there be that would strictly set the consumer 

utility at a certain level. 

 So DOE has a request for comment here. A 

methodology for determining appropriate maximum sizes 

has not been established, and DOE seeks input on this 

topic, including, if possible, consumer surveys or 

similar data. And I would expect this is something 

that perhaps there is not been time to look at what's 

available. 

 MR. BROOKMAN: So written comments would be 

especially helpful. Ted. 

 MR. POPE: Probably a dumb question, on the 

through-the-wall, is the further projection now 

possible, or is that already presumed to be 

constrained? 

 MR. WESTPHALEN: That would be presumed to be 

constrained. You know, there are all different sizes 

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of walls, but the sleeves are standard size. 

 MR. POPE: But going outside, so, you know, 

projecting out to the outdoor space more wouldn't 

affect the sleeve size, or -- 

 MR. WESTPHALEN: Well, the sleeves are -- and 

maybe some of the manufacturer representatives could 

speak to this more directly as to details. 

 MR. BROOKMAN: Brice. 

 MR. BOWLEY: Yeah, Brice Bowley. As far as 

extending the depth, I mean basically the building set 

up at a certain dimension width and height, so you're 

correct, you could extend it deeper, except the 

existing wall sleeves would not allow for deeper 

installation, so the through-the-wall units usually 

don't come with a wall sleeve, they're slid into an 

existing sleeve if it's a replacement. So the existing 

sleeves would have to be torn out and replaced with 

additional ones. 

 MR. POPE: Thank you. 

 MR. BROOKMAN: Thank you. No additional 

comments at this time? Okay. 

 MR. WESTPHALEN: So the next few slides show 

the results of the analyses and in tabular form for the 

four product classes directly analyzed. One thing you 

see here is that we have reported incremental 

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manufacturing production costs in one column, and 

shipping costs in another column separately. And the 

shipping costs are reflective of the size of the 

product, and the reason that we've reported these 

separately is that the shipping cost is generally paid 

by the retailer in this market, and so in order to 

properly account for the price at retail, that needs to 

be considered in the equation as well. 

 The manufacturer markup would apply to the 

incremental MPC, and then a shipping cost would be 

added, and depending on how the retailer markup works, 

the shipping costs would have to be considered in that 

equation. 

 MR. BROOKMAN: Yes, Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock, yeah. For 

the shipping costs, are those basically, I'll say, 

based on international rates, since the product is 

being shipped from overseas? 

 MR. WESTPHALEN: That's correct. A container 

from Asia. 

 MR. ROSENSTOCK: Okay. Thank you. 

 MR. WESTPHALEN: And I believe the assumption 

is getting to a U.S. port and that the distribution 

within the U.S. would be part of the retailer markup. 

Also you notice that the baseline incremental 

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manufacturing production cost is non-zero, and this 

reflects the cost conversion to R-410A refrigerant, 

which clearly is not part of the assessment of TSLs 

directly, but factors into the manufacturer impact 

analysis. 

 These are the results for product class 

three. As mentioned, DOE conducted analysis for 8000 

and 12000 BTU an hour products for this product class, 

and then averaged those two values to obtain these 

numbers. Product class five, these are the window 

units, large size with no reverse cycle. And then 

product class eight. Again, these results are 

consolidated for two different capacities. And again, 

you can see the shipping costs here, while they 

reported they don't change because the size doesn't 

change. 

 MR. BROOKMAN: Brice. 

 MR. BOWLEY: Brice Bowley. A question on the 

shipping cost, that's not intended to be incremental 

shipping cost, then, is that correct? That's the total 

product shipping cost? 

 MR. WESTPHALEN: Right, as you can see for 

the baseline it's non-zero. 

 MR. BOWLEY: Okay. 

 MR. WESTPHALEN: And if you have comments, 

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obviously, on those costs, we'll welcome that and we'll 

consider it. 

 Just a few words on extrapolation of the 

results to other product classes. I don't want to get 

into this in too much depth. It's discussed in the 

TSD. For some of these product classes, we can 

interpolate between product classes with larger and 

smaller capacities. For many of them, extrapolation 

was required for a different product class, but this 

methodology discussed in the TSD was used for the rest 

of the louvered product classes, the through-the-wall 

product classes six, seven, nine, and ten; the reverse 

cycle product classes, which in many ways are similar 

to the window units and the through-the-wall units, 

except for inclusion of reverse cycle for heat pump 

heating; and then the casement and casement slider 

product classes, 15 and 16. 

 And again, we have a request for comment on 

the extrapolation and I expect that maybe this is 

something where there would be more information 

available for the written comments, but if anybody has 

any comments at this point on that approach? 

 MR. BROOKMAN: Tom Eckman. 

 MR. ECKMAN: On the reversing units, do you 

take into account the impact on the heating side 

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efficiency of an increase in heat exchanger area and 

things like that when you look at the performance, or 

just -- is that just looked at cooling only? 

 MR. WESTPHALEN: It's looked at cooling only 

at this point. The standard applies to the cooling 

only side of the operation, and -- 

 MR. ECKMAN: It has an impact, clearly, on 

the energy consumption on the heating side as well, if 

it affects that performance. 

 MR. WESTPHALEN: Yeah, I expect, and Alex can 

probably answer whether it was even considered in the 

LCC. I expect not. 

 MR. ECKMAN: Was it considered in the LCC, 

that the heating -- the impact on heating of any 

changes in the performance on the cooling side? 

 MR. LEKOV: Alex Lekov -- 

 MR. BROOKMAN: Alex, find a microphone. 

 MR. LEKOV: The effect of heating on the 

cooling side -- 

 MR. BROOKMAN: Find a microphone, Alex. 

 MR. LEKOV: In terms of room air 

conditioners, not at this time, the LCC analyses do not 

include this. 

 MR. ECKMAN: Okay. 

 MR. BROOKMAN: Thank you. Additional 

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comments? You see the request for comment in the box 

there. We're going to keep moving on. 

 MR. WESTPHALEN: Okay. The next section 

addresses manufacturer selling prices, and manufacturer 

markup. Manufacturer selling prices account for the 

non-production costs and profit. DOE determined the 

appropriate markup factors for review of U.S. 

Securities and Exchange Commission 10K reports, and the 

production costs are multiplied by this factor to 

determine the manufacturer's selling prices. And the 

manufacturer selling prices are then an input to the 

LCC analysis, along with the shipping costs that we 

talked about before. 

 This manufacturer markup is 1.26. This 

number might be familiar to some of you. And at this 

point, I think we open the floor to comments and 

recommendations on any other aspects of market and 

technology assessment, screening analysis, and 

engineering analysis. 

 MR. BROOKMAN: Any additional comments? 

Since we took a break that lasted until 11, I think 

we'll go at least until noon, maybe 12:15, before we 

break for lunch. Alex Lekov. 

ENERGY USE ANALYSIS, MARKUPS FOR EQUIPMENT PRICE 

DETERMINATION AND LIFE-CYCLE COST ANALYSIS 

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 MR. LEKOV: I'll continue with the next group 

of analyses related to the determination of the markups 

to determine the product prices, energy use 

characterization, and life cycle cost analysis. 

 Markup for product price determination, the 

purpose of this analysis is to characterize the 

channels for how products are distributed from the 

manufacturer to the consumer, and so as to determine 

the prices paid by the consumer based on manufacturer 

selling price, both for baseline and higher efficiency 

products. 

 The purpose of energy use characterization is 

to develop the energy consumption savings estimate for 

selected product efficiency levels. And the overall 

life cycle costs and payback analysis develop the 

consumer life cycle cost savings and payback periods 

for the higher efficiency products considered in the 

rule. 

 This is the overall flow chart of the LCC 

analysis. The upper part of the chart shows the 

parameters associated with the development of total 

installed costs. The bottom part represents the 

operating costs development, and on the right side are 

the final results. The yellow boxes are the inputs, 

the green boxes identify intermediate results, and the 

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blue boxes are the final outcome of the LCC analysis. 

 During this presentation I'll be talking 

almost for every single box you see here and associated 

assumptions and results. 

 Briefly, the overall method. Life cycle 

costs equals total installed costs, plus the sum of 

operating costs, discounted to a particular base here. 

 The economic evaluation is performed from the consumer 

perspective. Analysis models the uncertainty and 

variability of the inputs and apply Monte Carlo 

simulation approach and many of the parameters are 

presented as probability distribution. 

 The platform for the analysis is in Microsoft 

Excel spreadsheet, combined with Crystal Ball which 

allows to use input in the format of probability 

distributions. The flow chart at the bottom summarizes 

the above. 

 As mentioned at the beginning, we'll be 

talking markups, energy characterization, and LCC. So 

the next several slides, the focus will be on the 

markups. So the purpose is to the consumer -- to 

determine the consumer product prices based on the 

manufacturer costs, as well as to characterize product 

distribution channels and market segments. 

 The inputs are coming from engineering 

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analysis for the manufacturer markup and the retailer 

markups are determined by investigating data from U.S. 

Census Bureau financial data for household appliance. 

The output comes in the shape of markups which are 

defined as baseline and incremental. 

 Before describing the details about these two 

types of markups, I will mention that this type of 

approach is not new to the Department. It has been 

applied to many rulemakings over the last eight, nine, 

years. With that overall the markup relates the 

consumer price to the cost of goods sold, which is 

essentially the cost that the distributor pays for the 

equipment and for handling the equipment. The baseline 

markup itself represents the price to cost prior to a 

change in efficiency. So it could include the consumer 

price that covers all of retailer or distributer 

expenses, plus profit, and in addition to this, 

includes the direct labor costs as listed here. 

 Once you have a change in the efficiency of 

the product, there is an incremental markup, and this 

incremental markup relates to the incremental change in 

the cost of goods sold. The premise of the whole 

concept is that some costs remain constant, would 

suggest and some are changing. So the incremental 

markups cover only expenses that vary with the consumer 

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-- with the cost of goods sold, in this case, expenses 

that increase due to an increased product efficiency. 

However, this concept and based on the Census data, 

gives us the fact that the direct labor costs are not 

accounting -- are not much accounted in the incremental 

markup. 

 The second component of the markup analysis 

is to define the distribution channels. At this time, 

this is pretty straightforward. Manufacturer has a 

consumer distribution channel, and the overall average 

markups by product costs, the outcome is shown here. 

 MR. BROOKMAN: Yes, Debra. 

 MS. BRUNK: Debra Brunk from AHAM. I just 

have a question, and it was not clear to me from 

reviewing the preliminary TSD. Was a separate analysis 

done on clothes dryers and room air conditioners, or 

were they analyzed together? 

 MR. LEKOV: Separate analysis. 

 MS. BRUNK: It was a separate analysis? 

 MR. LEKOV: Yes. 

 MS. BRUNK: Okay. Thank you. 

 MR. LEKOV: So, once we have the markups, we 

are getting it to the derivation of the consumer price, 

which essentially has the inputs that are coming from 

the engineering analysis, the baseline manufacturer's 

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selling price, and the markups as just explained. In 

addition, we're accounting for the sales tax. So this 

is how the consumer price is derived. 

 Total installed cost of the equipment. 

Installation cost is an important component of it. So, 

basically it represents the labor and materials 

necessary to install the appliance. For this product 

here, the example on this screen, relates to the room 

air conditioner, DOE found no evidence that the 

installation costs would be impacted with the increased 

efficiency levels. 

 The source for the data is RS Means. We used 

the 2008 version here. What you see is, on this screen 

is a typical approach how this type of costs are 

calculated within the RS Means method. So for the 

three room air conditioner product classes, you have 

the labor hours, and they include their cost and 

overhead and profit, pretty standard, and those are 

here, the outcome in terms of average price. 

 Similarly, for clothes dryers method, 

everything is the same. Here, the table shows how the 

Department developed the installation costs. What's 

important is that for some of the product cost 

estimates were made basically separately for retrofit, 

while in the case of clothes dryers, new owner, new 

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construction. So there are slight differences in terms 

of labor hours. In addition to this, new construction 

item includes material costs for the piping piece. 

 MR. BROOKMAN: Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock, yeah. In 

terms of -- for the clothes dryers, in terms of the 

max-tech, if you're using, say, an electric heat pump 

clothes dryer, I am familiar with the heat pump water 

heaters on the market, they typically need clearance 

space for the heat pump aspect to operate properly, so 

it does surprise me that even in that case there 

doesn't -- I would guess there would be an increase in 

labor hours because there might be some retrofits 

needed, you know, if the clothes washer is located in a 

closet or a tight space. For proper operation of the -

- I'll say the heat pump component, I would guess that 

there would be a significant increase in labor possible 

in those situations, and significant increase in labor 

hours. 

 MR. LEKOV: The heat pump clothes dryers are 

not a common product for the United States markets. 

Basically, there is not much experience with it. The 

cost mentioned basically will depend on the location of 

the unit and particularly in the interior air 

conditioned space, the aspect of closeness and so on. 

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At this time, the Department essentially based on the 

fact that this product probably does not exist in the 

United States with the exception of the prototypes. 

There is no experience. The Department would 

appreciate any data and we'll consider including those 

expenses in the NOPR phase of the rule. 

 MR. ROSENSTOCK: Well okay, Steve Rosenstock, 

then again, the Department might want to look at some 

of the experiences with heat pump water heaters, 

because there might be very similar issues in terms of 

space issues and installation issues. Thank you. 

 MR. BROOKMAN: Thank you. Yes, Jennifer. 

 MS. AMANN: Hi, Jennifer Amann. I was just 

going to say I think you may be better off getting data 

from Europe where you have some countries exceeding ten 

percent saturation of heat pump clothes dryers at this 

time, so it might be better to look at the experience 

with actual heat pump dryer installations. 

 MR. BROOKMAN: Thank you. 

 MR. LEKOV: Thank you. The Department will 

consider this. 

 MR. BROOKMAN: Debra Brunk. 

 MS. BRUNK: Debra Brunk. I think just along 

the same lines here, I'm not that familiar with the RS 

Means. Does that provide labor information, just in 

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terms of hours? Is there some sort of labor versus 

weight of product, or labor versus size, or that kind 

of information available? Again, we're talking about 

potentially looking at increased sizes or weights for 

room air conditioners, and also as you move to a heat 

pump dryer, there's a significant weight difference 

there. So I'm just -- if you could help me understand 

a little bit in terms of what RS Means provides in 

terms of that kind of information on labor. 

 MR. LEKOV: This is exactly correct. Both 

the labor hours, as well as the cost is provided in 

some details. I will start first the costs, and this 

is what's included in the analysis. Essentially, we 

are accounting for variable labor rates, basically RS 

Means are a way of calculating rates for a range of 

states, so you could see a variability, let's say, from 

60 percent to 150 percent, depending on where the labor 

force is located. 

 In terms of the size of the product, yes, RS 

Means provides differences in the labor hours 

associated with the size of the equipment, however, for 

this product, I don't believe we had knowledge of 

different labor hours for different capacity units. 

However, if there is any data or reference to this, the 

Department will consider it. 

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 With that, the next slides we will focus on 

the energy use characterization, essentially I'm going 

into the determination of the operating costs 

associated with these equipment pieces. So, in the 

case of room air conditioners, the Department looked 

both in the installations in the residential market 

segment and in commercial. For the residential 

buildings, the basic tool is the availability of the 

EIA's RECS database. The Department applied a set of 

assumptions to determine what part of RECS is 

applicable for this product, and once this is 

determined, it looked at the cooling area associated to 

the room ACs for each household, in conjunction with 

the Energy Star sizing guidelines, to determine the 

capacity of the unit in each household. 

 So that's shown on this slide, and there are 

details in Chapter 7 and Appendix 7A. In the case of 

the installation in commercial buildings, the 

Department started with the CBECS, which is the 

Commercial Buildings Energy Consumption Survey. And in 

this particular case, again, applied a set of 

assumptions, looked at the cooling -- or the cooled 

area for each specific building, and applied criteria 

to derive the ... so basically for, depending on the 

square footage, the Department used each sample to 

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derive the energy use for the three capacities, three 

capacity ranges. 

 MR. ROSENSTOCK: Quick question? Steve 

Rosenstock, yeah, I -- in CBECS they actually ask for -

- if the buildings have room air conditioners, they 

actually ask for the size of the offices that they're 

serving? 

 MR. LEKOV: Exactly. CBECS provide 

information, whether there are room air conditioners, 

as well as provide the square footage of the building 

cooled by the room air conditioners. 

 MR. BROOKMAN: Debra Brunk. 

 MS. BRUNK: Debra Brunk. It asks for square 

footage of the building or square footage of the room? 

 MR. LEKOV: Square footage of the cooled 

area. 

 MS. BRUNK: Okay. 

 MR. LEKOV: For household -- for the clothes 

dryer, the Department also used the RECS example, 

applied criteria whether there is a clothes dryer in 

the household, and after that, separated it into two 

samples, depending on the fuel type. In addition, for 

electric clothes dryers, the Department applied 

different criteria for the compact unit, so it applied 

those to manufactured homes, multifamily homes, and for 

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single family with less than 1000 square foot. 

 MR. BROOKMAN: Steve. 

 MR. ROSENSTOCK: Steve Rosenstock. Actually 

going back to the room air conditioner, sorry. In your 

research what percentage of room air conditioners are 

being used in commercial buildings? Were you able to 

get any sort of rough estimate in terms of the 

percentage saturation? 

 MR. LEKOV: In the NIA analysis, the 

Department arrived at the 12 percent value. 

 MR. ROSENSTOCK: So 12 percent room air 

conditioners are being used in commercial buildings? 

Thank you. 

 MS. BRUNK: Doug? 

 MR. BROOKMAN: Yes, Debra. 

 MS. BRUNK: Debra Brunk, I just have a 

question on the clothes dryer. Let me understand this. 

 For the electric vented clothes dryer, are you saying 

that if in RECS they came up as a manufactured home, a 

multifamily home, or a single family home less than 

1000 square feet, it was assumed to have an electric 

unit clothes dryer? Is that how I would read this? 

 MR. LEKOV: That's the second step. First 

it's necessary to determine -- basically RECS report 

whether there is a clothes dryer or not, so that is the 

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basic thing. Once it is determined there is a clothes 

dryer, the next set of considerations is applied, and 

essentially, you first segregate the fuel types and for 

electric the purpose of what I'm saying is basically 

for the equipment, that if the area of the compact 

units, those are -- the example is -- those are applied 

to this type of houses only, because those are small 

units that are more appropriate -- the assumption that 

those are more appropriate for these housing types. 

 MS. BRUNK: Okay. Thank you. 

 MR. LEKOV: The next important and the base 

component of the analysis is to make an assignment of 

the products in the base case, in terms of efficiency. 

 So this particular slide is focused on the room air 

conditioners, and the importance of this is to make 

sure that the considerations, such as not all consumers 

purchase products at the current minimum standard, as 

well as the fact that the consumers purchase products 

at efficiency greater than or equal to the prospective 

standard level. So not to have this double counting, 

that's the kind of common prospect. 

 So, the DOE used the AHAM shipment databases 

by efficiency level as available, as well as the Energy 

Star fractions by state to identify the fraction of 

equipment in each product class that are above the 

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baseline level. And here are the numbers for the room 

air conditioners, the next one are the numbers for 

clothes dryers. 

 MR. BROOKMAN: Yes, Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock, yeah, this 

leads to the following slide about issues, base case 

efficiency distributions. In it you write here that 

the recent data -- the data on recent trends of 

products are inconclusive. But I'm just -- 

 MR. LEKOV: Right. Yes. 

 MR. ROSENSTOCK: But I'm just kind of 

curious. Are you talking about the recent years, 2008, 

2009, recession years? And what about the trends 

through, I'll say, 2007, what were the -- for example, 

you know, some of the products -- I'll say Energy Star 

levels were 40 to 60 percent looking at the Energy Star 

level on room air conditioners from, say, 2000 to 2007, 

the increase from 10 to 44 percent, and the recession 

kind of killed that trend, or -- 

 MR. LEKOV: Essentially, we looked even more 

than the last several years. So basically the trends 

are all over the place. I believe that the charts are 

in the technical support document. 

 MR. ROSENSTOCK: Okay. 

 MR. LEKOV: So, at this time, the Department 

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basically assumed that the 2007 trend is applicable for 

the effective date of 2014, as well as after that. 

Again, the constant assumption was adopted. Of course, 

any data or references to anything that could help the 

Department to refine this is welcome. 

 MR. BROOKMAN: Let's return to the comment 

box. You see a request for comment. If there's 

anything else to be said on this subject before we move 

on? Yes, Tim. 

 MR. BALLO: Tim Ballo with Earthjustice. If 

we could just back up quickly to slide 81. I just have 

a question about that. I take it that the houses 

meeting the assumptions listed at the bottom of this 

slide are assumed, for purposes of the life cycle cost 

analysis, to install an electric vented dryer. And I'm 

just wondering, we have some data that was presented at 

the beginning of the analysis that showed those dryers 

were a very small percentage of the market, and I'm 

just wondering if -- if the assumptions used in the 

life cycle cost analysis reflect a similar distribution 

that was shown in the sales data? 

 MR. LEKOV: I would try to disconnect this 

from the fraction of sales. This is more -- basically 

this set of criteria is more to identify more 

appropriate sample size associated to this specific 

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type of equipment. 

 MR. BROOKMAN: Let's return to the comment 

box. So Alex stated this. DOE assumed that the market 

shares of efficiency levels in 2014 would be roughly 

the same as shares in 2007, and you can see the rest of 

the comment there. Any additional comments, questions, 

on that there? Debra Brunk. 

 MS. BRUNK: Debra Brunk. Actually again 

going back to what Tim just noticed or mentioned on 

slide 81, I guess I still have a question, and again 

this deals with the whole analysis. Should that middle 

box be electric vented or electric ventless? 

 MR. LEKOV: That's true. Yes, that should be 

ventless. 

 MS. BRUNK: So that should be ventless? 

 MR. LEKOV: Correct. 

 MS. BRUNK: So then I guess I have another 

question which would be, why -- what assumptions or 

what goes into making the assumptions that any of those 

three particular homes would have a ventless versus a 

vented product? 

 MR. LEKOV: First, the overall example for 

the standard includes every single household. This is 

just a subsample to identify this compact, vented 

compact, as well as ventless unit to associate them 

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with more appropriate size housing that could be 

matched in terms of deriving the energy use. So that's 

just -- the only purpose of this is not to associate 

the compact unit, for example, with a huge house. 

 MS. BRUNK: Debra Brunk. So -- still just so 

I'm clear. Should this read electric vented and 

ventless clothes dryer, that middle box? 

 MR. LEKOV: This box -- vented compact -- 

 MS. BRUNK: I'm sorry, it's compact vented. 

 MR. LEKOV: -- 120 and 240 volts, as well as 

the vented. So those are all derived from this 

example. 

 MS. BRUNK: It's all compact units, and that 

would also potentially include your washer-dryer 

combos? 

 MR. LEKOV: Yes. 

 MS. BRUNK: Okay. 

 MR. LEKOV: Correct. 

 MS. BRUNK: Okay. 

 MR. BROOKMAN: Phil. 

 MR. MANTHEI: I was just confused like 

everybody else. 

 MR. BROOKMAN: Any additional questions or 

comments here? Okay. 

 MR. LEKOV: So with that, this slide focuses 

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on the -- essentially the energy -- deriving the annual 

energy use for the room air conditioner, and the three 

-- make it a little bit clearer, these three boxes are 

the key for what has happened. So, basically, we have 

the operating hours for room air conditioners derived 

from the RECS energy use, EER annual distributions from 

AHAM, so those two values essentially are shown here, 

the two parameters for developing the unit consumption 

basically comes from the report of energy use and the 

number of RECS units which I explained under the 

example chart. 

 The capacity was derived from the cooling 

area criteria, again, explained on the previous chart. 

 This allows to derive the three basic parameters 

needed for the operating hours, which are the existing 

EER, the energy consumption, and the capacity. Once we 

have the operating hours, the number of units, and EER, 

now we are determining the annual energy use. 

 Once this happens there is a next step. 

We're converting the annual energy use to monthly 

energy use, and the purpose of this approach is 

essentially to more accurately to reflect the energy 

use of the room air conditioners, which is seasonal, 

and the fact that the Department actually has monthly 

energy prices, which allow to do the calculations month 

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by month. 

 So how this happens essentially for each 

household, the Department extracts the cooling degree 

days and scales this use in the 12 monthly energy use, 

using the cooling degree days for each month. This 

allows to arrive at the monthly energy use. 

 MR. BROOKMAN: Debra Brunk. 

 MS. BRUNK: Debra Brunk with AHAM. I just 

have a couple of questions here, and I noticed this 

from reviewing the preliminary technical support 

document. It looks like DOE is relying heavily on the 

RECS data for this analysis, and I guess I'm just 

curious why that is when there is data available from 

the technical analysis that was completed, in terms of 

using the test procedure. We have roughly the number 

of units that are on the market, the distribution of 

those units in terms of their capacity, and EER, or the 

proposed IEER with the energy efficiency change. And 

then we also do have an accepted number of operating 

hours, at least with the test procedure. 

 So I guess I'd like to better understand the 

rationale for using RECS data to estimate the monthly 

energy use, as opposed to the test procedure. 

 MR. LEKOV: The basic presumption is that the 

engineering analysis, the Department fully utilizes the 

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assumptions according to the existing test procedure, 

while in the life cycle cost analysis, and this is in 

the definition of this analysis, the Department always 

tried to adjust to any information available about the 

field operation and consumption of the equipment. So, 

the RECS, which is the periodical base by EIA, has good 

reputation as a source of this type of field data. So 

in this case the Department choose this approach. 

 MR. BROOKMAN: Debra. 

 MS. BRUNK: Debra Brunk. I guess I just -- 

certainly the RECS data is appropriate, I think, for a 

lot of analyses, and is well-recognized, as you 

mentioned. I guess what I'm trying to understand, 

first of all is, has DOE done any kind of validation in 

terms of what they are receiving in terms of the RECS 

data and those estimates versus what you would obtain 

on the test procedure? Has there been any validation 

that the RECS data is actually representative of what 

consumers are indeed using, as opposed to what they are 

saying they are using? 

 And I guess that's just -- the other concern 

is my understanding of the RECS data is that in terms 

of overall energy consumption, it may pull out a 

certain product, but most products, and I believe room 

air conditioners and clothes dryers fall into this 

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category -- these are lumped into sort of a general 

energy consumption number. And so I'm trying to 

understand the different assumptions that may be used 

and built upon to actually reach this monthly energy 

use. 

 MR. LEKOV: In terms of room air 

conditioners, RECS utilizes an approach called the 

conditional demand analysis to extract the room air 

conditioner-specific data for their reporting, in terms 

of energy use. The approach applied here also realize, 

in terms of determining the energy -- the operating 

hours themselves, also relies very heavily on the 

information of efficiency that's available, and in 

terms of annual service chart data. Essentially there 

is data for the room air conditioner as a whole for the 

period since 1972, as well as there is an AHAM data 

available, I believe, for the last three years. As for 

the specific product cost, it's by product cost, as 

well as the Department has a few other data points, 

like the EER's 1992 and 2000, where the standard 

changed. So this allowed a pretty good mapping of the 

efficiency data. 

 In addition to this, the capacity, I 

explained the other parameter that's in the formula, 

the way it was determined, using the Energy Star 

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guideline in terms of area. So the -- to a certain 

extent it correlates overall -- balances the three 

parameters used in this calculation to get to the 

operating hours. 

 MR. BROOKMAN: Do you have any -- 

 MR. LEKOV: Having said this, I would like to 

emphasize that still this is one approach that the 

Department choose to use. However, the Department is 

open for proposals and data that could justify another 

calculation approach. 

 MR. BROOKMAN: John Cymbalsky. 

 MR. CYMBALSKY: John Cymbalsky, DOE. Having 

worked for EIA for 20 years, I'm familiar with the RECS 

survey, so RECS is a sample that is statistically 

valid, that's the first point. Second point is that 

the energy use is based on monthly billing data that 

they actually collect from the sample, so it is 

controlled for that, and like Alex said, the 

conditional demand analysis, what it will do, based on 

the monthly electricity use, it's fairly 

straightforward to tease out the cooling numbers. 

Dryers might be a little more problematic. 

 MR. BROOKMAN: Thank you. Do you have any 

additional comments before we move on. We're going to 

move toward lunch as quickly as possible. I want to 

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see how much more content we can cover, say, in the 

next five or ten minutes. You okay? 

 MR. LEKOV: Yes. 

 MR. BROOKMAN: Let's move on. 

 MR. LEKOV: The clothes dryers. This 

morning, Navigant Consulting presented well the 

background, the active mode and standby power. So the 

LCC analysis calculate those separately, and the main 

point which I'll emphasize here is that for certain 

parameters, like the load weight distribution, the 

remaining moisture content, and dryer cycles, the 

Department did evaluations and determined distributions 

of value, some of which are considered for adoption in 

the ongoing test procedure. 

 Particularly in terms of these three 

parameters, I will try also to come with some numerical 

values. So based on the tub size as well as the 

associated pounds of clothing, the Department, for 

example, came with a different average value for the 

load weight, which is higher than seven. I believe 

from the distribution, which is like from three to ten, 

the average is about 8.1 pounds. So this is what's 

used in the calculation. 

 The remaining moisture content is the most 

important parameter. Essentially, based on information 

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in the CEC directory, basically the Department came 

with a much lower range of remaining moisture content, 

within the 30 to 61 percent range, compared to the test 

procedure of 72 percent, which is essentially a 

reduction by more than one-third. 

 And in addition to this, based on information 

provided in RECS, the Department came with a similar 

lower -- oh, what I did? 

 MR. BROOKMAN: Just hit F5. 

 MR. LEKOV: F5 brought me to -- very -- okay, 

I apologize. So, basically, the number of annual 

cycles is 285, which is for the standard electric, and 

somewhat lower for gas than what's happened. This is -

- as a result of this, field energy consumption for 

clothes dryers is much lower than the one you get -- 

somebody will get using the test procedure. 

 MR. BROOKMAN: Let's pause there. I didn't 

get your name. 

 MS. WALTNER: Meg Waltner. I can wait. 

 MR. BROOKMAN: Okay. 

 MR. LEKOV: Just to briefly mention here, the 

Department also calculated the standby power using the 

assumptions mentioned this morning, and it included the 

value -- the value is included in the overall 

electricity use. 

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 MR. BROOKMAN: Meg. 

 MS. WALTNER: Meg Waltner. The Ecos study 

mentioned earlier found that there's a 20 minute 

variation in cycle time, based on whether the sensors 

work accurately or not, did you take that into 

consideration as well? 

 MR. BROOKMAN: Do you know when that Ecos 

study will be available? 

 MS. WALTNER: I think we can provide you a 

draft copy after this hearing. 

 MR. BROOKMAN: I think the Department always 

likes data to be early and complete, so the sooner the 

better from their perspective, I'm certain. 

 MS. WALTNER: Okay. 

 MR. BROOKMAN: Okay. Steve Rosenstock. 

 MR. ROSENSTOCK: Steve Rosenstock, yeah, in 

terms of cycle time, doesn't the -- isn't there 

information from the DOE test procedures or some sort 

of testing that -- 

 MR. LEKOV: The length of a single cycle? 

 MR. ROSENSTOCK: Yes. 

 MR. LEKOV: Sixty minutes, this is the basic 

assumption. 

 MR. ROSENSTOCK: But I'm saying, isn't there 

some data out there that describes, either for 

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parties, that kind of gives a better, you know, another 

idea of just typical cycle time, just because there's 

such a variation? He said it's an assumption, that's 

why I'm asking. 

 MR. LEKOV: The clothes dryer team, NCI and 

us look at this issues, I believe at this time, this is 

the value we're using. If other data exists or 

references that could identify a range, it would be 

applied. 

 MR. ROSENSTOCK: Thank you. 

 MR. BROOKMAN: So then, yes. Yes, Debra. 

 MS. BRUNK: Debra Brunk. I guess I would 

just be interested in understanding if DOE had any 

suggestions or ideas on why the number of cycles per 

year decreased from what it is currently, which is 416, 

to 329, which is what was proposed in the framework 

document, to now 285 cycles per year. Do you have any 

sense of what might be happening in the market to cause 

that decrease? 

 MR. LEKOV: I believe a few things happened. 

 One of them, basically, this derivation comes from the 

parameters reported in RECS. One item is the increase 

of -- the coupling of clothes washers with clothes 

dryers, the frequency before was 0.84, now it is 0.94. 

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 That -- so the coincidence of the two values, and this 

data actually coincides with another data point from 

Procter and Gamble. 

 Other items that bring it in this direction 

is maybe some factors such as maybe people are doing 

larger loads less frequently. Maybe also was fewer 

considerations -- I'm also looking to the NCI folks, 

those who have considered also the test procedures, so 

if there is any good -- 

 MR. BROOKMAN: Let me pause, Alex, do you 

have any comment on the shift from 329 to 295? Nothing 

additional? Steve? 

 MR. ROSENSTOCK: Well, again, I was going to 

say, you know, wouldn't the combination of larger 

clothes washers and clothes dryers in terms of 

capacity, plus demographics, if families are getting 

smaller, wouldn't that also tend to make the number of 

cycles go down? 

 MR. LEKOV: Yeah, the demographics is 

definitely another factor. 

 MR. BROOKMAN: So once again, the Department 

loves to see data on these, rather than speculation. 

Phil, did you have a comment or question? 

 MR. MANTHEI: Only that obviously as our 

moisture content goes down to the neighborhood that 

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you're talking about here, 46 percent, the clothes 

loads are going to dry in a lot less time than 60 

minutes. 

 MR. LEKOV: That's correct. The main thing 

is that this is what you see in the reported data, and 

these days the clothes washers are much more efficient 

in terms of providing clothing with less moisture 

content. 

 MR. BROOKMAN: Does AHAM have that data, or 

do the individual manufacturers can they supply that 

data? Would it be for distribution of clothes washers, 

different age of clothes washers that would supply the 

moisture to the clothes to the dryer? 

 MR. MANTHEI: You're asking about AHAM data? 

 MR. BROOKMAN: Or data that perhaps you might 

have, Phil. 

 MR. MANTHEI: Well, certainly we could 

provide data on what it takes to dry a seven pound load 

with the existing test procedure at a different 

moisture retention content -- 

 MR. BROOKMAN: Okay. 

 MR. MANTHEI: -- going into the dryer. 

 MR. BROOKMAN: That would be very helpful. 

Debra, I don't know about you, can AHAM supply that 

data? 

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 MS. BRUNK: We can -- Debra Brunk, we can try 

to collect it, we do not currently have that just in 

hand. 

 MR. BROOKMAN: Okay. If you were to 

speculate, if it's not 60 minutes, what would it be, 

Phil? 

 MR. MANTHEI: It's going to be a little bit 

less. Well, at least in the calculations of EF, and 

certainly IEF, the test procedure just terminates at 

five percent, but again, we're connecting the dots 

between the new test procedure and potentially a new 

test procedure that has moisture sensing determination, 

and in the life cycle cost analysis, I'm reading ahead 

a little bit, you're not looking at anything that 

started with a remaining moisture content below 70 

percent. But clearly from the data that's presented in 

the TSD, you've got from AHAM's data, the average 

remaining moisture content, something like 47 percent 

across the stock, different between top loaders and 

front loaders. Seems to me in the life cycle cost 

analysis you need to reflect the fact that that 60 

minute cycle isn't appropriate for, and is different 

from a top loader load delivered at 38 percent 

remaining moisture content, and a front loader that's 

delivered at a different remaining -- excuse me, 47 

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percent and 50 percent. 

 So the remaining moisture content ought to 

drive cycle time, particularly if, in the baseline, 

you're assuming you've got a sensor that turns off the 

unit when it's dry. If that's not the case, then let's 

not price that into the baseline, but I think that's 

what I just heard earlier today, that the baseline 

assumes it's got a sensor in it that takes advantage of 

termination on the basis of how dry the clothes are. 

Well, we can't have a 60 minute cycle time if that 

sensor is there, it ought to be determined based on 

remaining moisture content. 

 MR. BROOKMAN: Okay. Thank you. 

 MR. MANTHEI: It seems like that's 

inconsistent. 

 MR. BROOKMAN: Thank you. Final comments on 

this subject. I'm going to -- if you look forward to 

the next page in your slides, we have four -- I think 

significant comment boxes. I'm thinking maybe we 

should go to lunch. These are important issues for the 

Department. They want you to comment on them to the 

best of your ability. So let's -- is that -- 

 MR. LEKOV: Yes, they're essentially, all 

those four topics relate to what we have been 

discussing the last ten minutes. 

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lot to be said on load sizes, remaining moisture 

content, number of annual cycles, and annual operating 

hours? A lot additional or have we covered it pretty 

much? Steve Rosenstock. 

 MR. ROSENSTOCK: I guess the only thing in 

terms of load size -- Steve Rosenstock -- in terms of 

load sizes for clothes dryers, if the trend has been 

again for larger clothes dryers, should the -- has the 

average load size increased? That'd be my only 

question. 

 MR. BROOKMAN: So then let's just try -- 

additional thoughts on load sizes? You see the comment 

box there. I think everybody -- they just need lunch, 

I think. It's 12:20. Let's return to this when we 

resume in this room at 1:20. Please wear your badges 

in the building. 

 (Whereupon, at 12:20 p.m., the hearing was 

recessed, to reconvene at 1:20 p.m., this same day, 

Tuesday, March 15, 2010.) 

 

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 A F T E R N O O N S E S S I O N 

 1:20 p.m. 

MR. BROOKMAN: Okay. Let’s resume. Thanks 

to all of you for being back on time. We are going to 

pick up where we left off. I believe is not this 

slide. 

PARTICIPANT: The next slide. 

MR. BROOKMAN: The next slide, yes. 

Welcome back, by the way. I hope your lunch 

was nice. We had just progressed beyond that slide and 

now we’re on 87, load sizes for clothes dryers. And I 

know all these issues matter a lot to the Department. 

So, let’s hear from you about that one first and then 

we’ll move on to moisture content, number of annual 

cycles, and annual operating hours. 

MR. LEKOV: I wonder whether it will be 

helpful for each of them with one sentence to summarize 

what’s the source of the calculation so -- 

MR. BROOKMAN: If it’s brief. 

MR. LEKOV: Yeah, and really brief. 

So, for the load size, as mentioned here, 

it’s essentially the calculation -- basically the 

derivation of the distribution as it relates or comes 

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from the models clothes washers, models in the CEC 

directory with the correlation between tub size and 

average pounds from the clothes washer test procedure. 

So, the tub size and average pounds are from 

the clothes washer test procedure and the tub sizes are 

for clothes dryers from CEC directory. 

MR. BROOKMAN: That was good. That was 

brief. Now, so comments then on load sizes. 

 Yes, Debra. 

MS. BRUNK: Debra Brunk. So you’re using the 

load table in the DOE test procedure? 

MR. LEKOV: For clothes washers. 

MS. BRUNK: For clothes washers. What 

happens if the drum volume on the CEC database is 

higher than the load table? Do you extrapolate? 

MR. LEKOV: My recollection is that there is 

sufficient range of large tub sizes. So, I think that 

basically covers, I believe, for a relatively large ten 

or 11, if I am not wrong. But definitely that was the 

approach. 

MR. BROOKMAN: Additional comments on load 

sizes? 

Debra, are you okay? Okay. 

And, of course, you don’t need to cover it 

all now. If you have additional thoughts that follow 

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on from this, the Department wants them and soon, in 

your written comments. 

So, please, they would invite that, I’m 

certain. Do you want to provide an overview on clothes 

dryer remaining moisture content, how that’s derived? 

MR. LEKOV: Yeah. Basically the remaining 

moisture content comes from the clothes washers 

reported value in the CEC directory. 

MR. BROOKMAN: Comments on remaining moisture 

content? 

 (No response.) 

MR. BROOKMAN: We covered some of these a 

little bit already. 

MR. LEKOV: So the range is 30 to 61 percent, 

you’re right. 

MR. BROOKMAN: Yes, please, Ted. 

MR. POPE: I may have misunderstood. I 

thought somebody said the LCC did presume the lower 

RMC, and so forth? 

MR. LEKOV: Correct. 

MR. POPE: That is correct. 

MR. LEKOV: That’s exactly what I said the 

test procedure is at 70 percent. DOE’s estimate is a 

range from 30 to 61 percent with a mean value of 46. 

MR. BROOKMAN: So then we’re going to move on 

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to annual cycles for clothes dryers. 

MR. LEKOV: This one comes from RECS data 

which reports two things; reports for clothes washers 

by bins, the number of cycles and in addition to this 

the frequency of using a clothes dryers. So these two 

values came to derive the clothes dryer cycle. And 

after that it was multiplied by the availability of 

clothes dryer household. 

MR. BROOKMAN: So any additional comments on 

this? 

 (No response.) 

MR. BROOKMAN: So from the silence I won’t 

over interpret. 

 [Laughter.] 

MR. BROOKMAN: Nor will that Department. 

They will wait for your comments. 

MR. LEKOV: We can move on. 

MR. BROOKMAN: Yes. Annual operating hours 

for room air conditioners. 

MR. LEKOV: This one is pretty complex. I 

think quite a few details are available in the TSD. 

Just I know if needed, feel comfortable to call or email any time. We will provide the deep details of 

this derivation. 

MR. BROOKMAN: Additional comments on that 

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one? Annual operating hours for room air conditioners. 

(No response.) 

MR. BROOKMAN: Okay. So then we’re going to 

proceed. 

MR. LEKOV: Okay. 

MR. BROOKMAN: Okay. 

MR. LEKOV: With this, those are the results 

for both products, the baseline average annual energy 

use for all product classes for both products. 

MR. BROOKMAN: Yes, Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. So 

these are using -- um, these are including this standby 

energy values as well? 

MR. LEKOV: That’s correct. And the 

electricity includes the standby. 

MR. ROSENSTOCK: Okay. I had a quick 

question. Because when I looked at the formulas before 

for the room air conditioners, there was about 10 

kilowatt hours and for the clothes dryers, again, about 

-- I just used it like 2 watts as a standby, about 16 

kilowatt hours for clothes dryers, you’re showing a 71 

kilowatt hours per year for the vented gas clothes 

dryer? 

MR. LEKOV: Uh-huh. 

MR. ROSENSTOCK: Is there -- is that for the 

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motor -- is that for the -- is there an electric motor? 

 Again, electric motor -- 

MR. LEKOV: Yes. 

MR. ROSENSTOCK: -- that’s for the motor plus 

standby? 

MR. LEKOV: Selected -- plus 

MR. ROSENSTOCK: Thank you. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk. I guess this just 

goes back to kind of the difference between the test 

procedure and the energy use. I mean, the baseline 

efficiency level is baseline energy efficiency used 

from the test procedure. I mean, if you were to 

actually calculate this out, the energy use, the two do 

not correlate. So I’m just curious how you plan to -- 

how the DOE plans to kind of to deal with that 

inconsistency? 

So, for example, if you were to take a 

baseline efficiency level of 2.96 on a vented electric 

standard clothes dryer, you would expect your energy 

use to be quite different from the 519 kilowatt hours 

per year that’s reported there. 

So I guess I’m just trying to understand how 

you would, you know, rationalize those differences? 

MR. LEKOV: Basically the number of cycles 

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drives the calculation to a large extent. 

MS. BRUNK: Yes. 

MR. LEKOV: What else in looking at basically 

energy use, that those are the main barometers. And 

essentially the only way to change this will be to 

change the number of cycles if we have any data or 

inputs on this. The other item, of course, is the 

remaining moisture content. There was one comment when 

they took a look at -- and the load size. 

If anybody provides data in this area, the 

DOE will include it or consider it. 

MR. BROOKMAN: Additional comments? 

 Tom Eckman. 

MR. ECKMAN: This is a question for the 

manufacturers. I’m aware of in some of the equipment 

you’ve -- for maintenance purposes you have little data 

loggers going on in there. Is there runtime meter data 

being collected? I know there sometimes are on 

dishwashers, but is that true with dryers? Do 

manufacturers keep that data for maintenance purposes? 

 Because they’re pretty low maintenance items. So I 

suspect that investment is probably deminimus. 

MR. BROOKMAN: Debra Brunk. 

MS. BRUNK: This is Debra Brunk. I would 

have to get back to our members to determine if that’s 

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the case. I know for some products those are available 

and they may not be available for all product classes 

as well. 

MR. ECKMAN: It may be -- the RECS datas 

user-reported numbers of cycles a year. It’s not 

metered. So if we went around the room and asked how 

many cycles of dryer use I have a year, I bet we would 

get a random variable with a high level of 

disconfidence. 

 [Laughter.] 

MR. LEKOV: The data is provided, of course, 

for quote, “washers” and it’s in six bins. So from to 

from to. So the LCC calculations work with 

distributions. 

MR. ECKMAN: Right. Even with the 

distribution the mean value is, you know, pretty big. 

Yeah, standard deviation on that mean might be fairly 

high. 

MR. BROOKMAN: Big tails. 

MR. ECKMAN: Big tails. 

And so getting some meter data on cycles per 

year or run times per lifetime or something like that 

might be useful to calibrate on. 

MR. BROOKMAN: Okay. Thank you. 

Okay. Alex, let’s go. 

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MR. LEKOV: So now let’s go in the parameters 

that are used for the calculation of the paybacks and 

LCC cycle itself. Energy prices are a big driver. 

This one shows the sources. I’ll go directly to the 

actual derivation. So basically for the LCC 

electricity prices are defined for each household. 

Important to note is that you use this in average price 

to define the LCC baseline, however, it uses marginal 

prices to define the LCC cost savings. 

So, there is a slight difference between the 

residential approach and the commercial approach. It’s 

not slightly, there is a difference between the two 

approaches. 

In the case of a residential they input data 

comes from the LBNL’s sample of 90 utilities which 

recently has been updated in 2008 as well as the 

monthly consumption data from RECS 2005. 

The marginal prices are defined basically 

when you know the tariff you put a different energy use 

and calculate where the change occurred. For this 

particular analysis probably important to mention that 

a marginal price can be lower than the baseline. So 

that’s in terms of residential. 

For commercial the approach is complex, but 

the most important that in addition to the electricity 

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also it’s applied incremental in terms of demand 

charge. 

MR. BROOKMAN: Steve Rosenstock? 

MR. ROSENSTOCK: Steve Rosenstock, Edison 

Electric Institute. I think this approach is fine. I 

think my question was, as you’ll see in the next slide, 

that there was -- there has been a drop in the last 

couple of years in electric prices. And, again, it 

looks like you’re -- it says, prices are calculated 

based on previous analysis, CUAC is that a unitary -- a 

central unitary air conditioners? 

MR. LEKOV: That’s for the commercial one. 

That is in this approach, the details of how arrived 

essentially comes from the commercial AC. 

MR. ROSENSTOCK: And DT is distribution 

transformer? 

MR. LEKOV: Correct. 

MR. ROSENSTOCK: Okay. Again, those -- I 

know for transformers that analysis was completed in 

2007. Things have changed since then. 

The other question I had was, are you taking 

a similar approach with gas prices for the gas dryer 

analysis? 

MR. LEKOV: Yeah, I -- okay, the gas is 

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essentially comes from the so-called EAI natural 

navigator and there the Department is using average 

prices. However, they are percents as regions, so they 

are different for the household depending on the 

region. 

MR. ROSENSTOCK: So you are not using the 

actual utility tariffs for the gas prices? 

MR. LEKOV: Yeah, I don’t -- yes, no. The 

answer is no, we are not using the actual utilities for 

gas. 

MR. ROSENSTOCK: Again, it just seems that 

you’re taking a more detailed approach on the electric 

side than on the gas side. I don’t understand why. 

MR. LEKOV: Because the DOE had this tariff 

database which is a unique tool available for 

electricity. At this point no equivalent. 

MR. ROSENSTOCK: But the tariffs for on the 

gas side are publicly available as well. 

MR. LEKOV: That is true. 

Maybe Greg can tell you. 

MR. ROSENQUIST: Greg Rosenquist, LBNL. We 

use the prices in the tariffs because AC is more of a 

peaky end use. While, you know, clothes dryers are 

more flat. So that was the reason why. 

MR. ROSENSTOCK: Okay. I understand. 

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MR. BROOKMAN: Thanks, Greg. Okay. 

So additional comments on this slide before I 

move on? 

(No response.) 

MR. LEKOV: And this is just to show that for 

the forecast, DOE uses the official AEO reference case 

in lower and higher case of energy prices forecast to 

use the prices that we have for the basic to expand 

them for the future. 

So, the next item associated to the 

determination of operating costs is the repair and 

maintenance. And basically DOE directly goes here to 

ask for a comment since no evidence was found that 

there is change in the repair and maintenance as 

product efficiency increases. So any data that could 

help to refine this assumption would be appreciated. 

MR. BROOKMAN: Yes, Debra Brunk. 

MS. BRUNK: This is Debra Brunk. We can 

certainly look for data, but I would suggest that DOE 

actually has these data in the form of the design 

option analysis that they conducted on these products. 

 Typically if you have higher component costs that are 

incorporated into a product, you will also have higher 

repair maintenance costs if those components need to be 

replaced. 

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suggest that DOE does have those data. 

MR. BROOKMAN: That wouldn’t be validated by 

some field experience? 

MS. BRUNK: Perhaps. 

MR. BROOKMAN: That would be an extrapolation 

what you just described; wouldn’t it? 

MS. BRUNK: Yes. 

MR. BROOKMAN: Okay. So data, once again. 

Okay. Alex. 

MR. LEKOV: Going to other inputs, discount 

rates and a lifetime, so, the primary source for 

discount rates is a major source from Federal Reserve 

Board survey of consumer finances. And in order -- and 

actually it’s a pretty good source because it gives us 

data point from ’89 to 2007. It accounts for almost 

200,000 data points which allow to create distributions 

both for new construction and for replacements. 

So, the new constructions are primary-based 

when applicable on a mortgage associated with the 

household and the replacement account basically for 

both the cost of any debt SOL as for cost of any equity 

or potential cost of any equity. 

To calculate the discount rate is very 

different and also need to know that this is a real 

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discount rate. It does not account for the inflation. 

A lifetime. DOE took an approach to derive 

lifetime based on REC’s available equipment age data 

information of the stock from American housing survey 

and matched this with the shipping data to derive 

lifetime distribution using Weibull functions. Weibull 

functions arae considered as a very good way of 

expressing the lifetime of distribution of different 

equipment. 

So the main answers are here for room air 

conditioner, the lifetime is 10 and a half years and 

the clothes dryers is 16 years on average. 

MR. BROOKMAN: Debra Brunk. 

MS. BRUNK: This is Debra Brunk. Just a 

question on how you might -- I know you have your 

minimum and your maximum in terms of your -- your 

average lifetime, but I mean, typically I think what 

we’ve seen is there could be a pretty tremendous 

lifetime difference on room air conditioners with the 

product class. And does the analysis get into that 

level of detail or, um, based on the data from the AHS? 

MR. LEKOV: No, we’re are no distinguished by 

product costs. Essentially there is no such details 

for example in American Housing Survey or in RECs for 

that matter. 

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But those -- this type of data corresponds to 

quite a few literature studies, the data points that 

you could find in the literature. 

On the lifetime the Department basically asks 

for a comment basically both on the approach and actual 

values. 

MR. BROOKMAN: Additional comments on 

lifetime? 

 (No response.) 

MR. LEKOV: The next two slides are 

essentially examples of the LCC savings and results 

that details for all product classes are in the TSD. 

Here the room air conditioners I believe most of the 

participants today are familiar with this expression of 

life cycle costs which includes the savings, includes 

the impacted households, and provides the payback as 

calculated at the lifecycle costs. And I will toggle 

between this here and the clothes dryers for electric 

standards. 

MR. BROOKMAN: Yes, Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock. Again, I 

really like the way the data is presented and 

appreciate, especially for payback showing median and 

average. Especially on the room air conditioners there 

seems to be quite a scatter between median and average. 

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there’s such a huge difference? 

MR. LEKOV: Basically it’s obvious that what 

this means we have a huge tail. Which means that a 

relatively small number of households will have very 

high expenses. 

MR. BROOKMAN: Please, Brice, use the 

microphone. 

MR. BOWLEY: The average payback is high like 

at 10.4. Doesn’t that imply I have very low usage of 

the product? 

MR. LEKOV: The combination that’s exactly 

true. 

MR. BOWLEY: Okay. 

MR. LEKOV: Low usage and high costs or one 

of the two -- 

MR. BOWLEY: Okay. Wouldn’t that be low 

usage and low cost? 

MR. LEKOV: But one of -- 

MR. BOWLEY: Okay. 

MR. LEKOV: -- or both. 

MR. BROOKMAN: Ted. 

MR. POPE: Ted Pope. Quick question. The 

large market share for the higher tiers of the clothes 

dryer analysis, you know, I realize there are a number 

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of factors that are of value to consumers that don’t 

show up as an energy consideration. But I would 

imagine that one of the convincing sales points about 

the dryers are more expensive because they have 

moisture sensing and so forth would be the argument 

that there’s less wear and tear on clothing. Is it 

conceivable that DOE would consider including some nonenergy benefit value in terms of, you know, clothing 

life increases if data were available? Or would that 

just be outside the scope of the analysis? 

MR. LEKOV: If this could be quantified, if 

somebody provides data, it definitely would be 

considered. 

MR. POPE: Thank you. 

MR. LEKOV: Okay. With that, that’s the 

general requests for any comments here or further 

written comments on any aspects -- 

MR. BROOKMAN: Elizabeth? 

MS. JOYCE: Elizabeth Joyce. Two comments, 

kind of general in terms of lifecycle savings for both 

AC and dryers. For room AC, we notice looking at the 

TSD that in many cases for some of the standards 

levels, these levels with the highest life cycle 

savings kind of look to be at least the max technology 

levels for a number of the product classes. And so 

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consider -- or is willing to consider kind of even more 

aggressive standard levels of kind of really pushing 

the envelope in that case if it seems that -- even at 

the max-tech level there can be effective savings. 

MR. LEKOV: I think the policy people should 

answer that. 

MS. JOYCE: Or I guess I would just at least 

like to -- 

MR. WITKOWSKI: Well, I think we’re looking 

at that. And until we are provided with information or 

specifics, you know, it becomes just speculative. 

MS. JOYCE: Certainly. 

MR. WITKOWSKI: But we would certainly look 

at any examples if they’re available. 

MS. JOYCE: Okay. 

MR. LEKOV: And I just will mention that 

there are many criteria -- additional criteria in 

addition to the lifecycle cost. 

MS. JOYCE: Sure. Sure. 

MR. BROOKMAN: And you had a second one? 

MS. JOYCE: Sure. The second issue was for 

dryers. Actually more of a question. Looking at, 

again, kind of lifecycle analysis -- lifecycle cost 

analysis from any of the dryer levels, it seems that 

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kind of the opposite was true. That in many cases the 

levels with the lowest costs for savings were kind of 

the baseline or maybe standard level one. And this was 

especially confusing to me looking at the market shares 

for some of the dryers, I think particularly for, I 

think, product class two and four. It seemed like the 

market was almost evenly split 50/50 between baseline 

and standard level two products. Yet, for those 

analyses it seemed like the highest life cycle savings 

or the lowest costs were for the baseline level. And I 

guess I don’t really understand how the market could be 

-- could have so many products that are at a higher 

level yet they don’t seem to be cost effective 

according to this analysis. 

I don't know if these products might have 

extra features, et cetera, that might make them -- 

MR. LEKOV: Just if I may on certain general 

terms, those are analysis results. They could be 

checked and so on. But assuming that they are correct 

generally what’s happened for clothes dryers you have 

very small efficiency improvement, if you look from 

efficiency level to efficiency level, and the cost is 

not negligible. Also, yah, those are the main factors 

that drive the results. 

MS. JOYCE: Okay. I guess I was just 

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confused how it could be -- 

MR. LEKOV: Correct. You will see more in 

the NIA analysis where basically the roll-up scenario 

is applied in terms of shipments. So this high 

efficiency levels may help to explain when we get there 

in two or three slides I will return to your question 

to see whether we could get it a little bit clearer. 

MS. JOYCE: Okay. Thank you. 

MR. BROOKMAN: Yes, Brice. 

MR. BOWLEY: Brice Bowley. I had a question 

on the payback analysis again. Looking at the -- like 

if I take, for example, the efficiency level one -- 

MR. BROOKMAN: Are you on clothes dryers or -

- 

MR. BOWLEY: I’m looking at the air 

conditioner -- room air conditioners. I guess I’m a 

little confused on how the median is calculated. If I 

look at that, 14 percent of the households have an 

increase in costs and 49 percent have no impact. So, 

how is it that since only 37 percent of the population 

has a benefit, how is the median, 50th percentile at 

1.6 years? 

MR. LEKOV: Okay. So first let me step back. 

 So you realize that what’s happening, we have example 

of 10,000 households. Okay. So each provides -- this 

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is a statistical significance in order to address the 

variability. Now, essentially if you eliminate the 

impact of this so-called no-impact, you have 51 percent 

that are impacted. So just looking at this, you have 

more households that have net benefit compared to net 

costs, 14 versus 37. So you would expect to get a 

certain not very high payback. It’s case-by-case, but 

those are the basics and the details are, of course, in 

the actual simulation. 

MR. BROOKMAN: John, did you -- 

MR. CYMBALSKY: John Cymbalsky. Were you 

asking why people are buying things that are not 

economic? Was that essentially your question? 

MS. JOYCE: Yeah. Sorry. 

MR. CYMBALSKY: I don’t think I can answer 

that. But -- 

 [Laughter.] 

MR. CYMBALSKY: -- what people think about 

it. 

MR. BROOKMAN: Elizabeth, go ahead. 

MS. JOYCE: I’m Elizabeth Joyce. Yeah, just 

kind of confusion over how it could be -- for example, 

I think for the gas dryers 60 percent the market today 

was shown to be at a standard level two and yet the 

most -- or the level with the lowest costs and the most 

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cost effective savings was the baseline level. And, 

yeah, I was just a little confused about how that 

works. I’m no economist. 

MR. LEKOV: Nor do you want to be. 

 [Laughter.] 

MR. BROOKMAN: I see Constantin. 

MR. von Wentzel: Constantin von Wentzel, 

Navigant Consulting. I would always be very careful 

about confusing costs and the price that a consumer 

would actually pay in an establishment to buy 

something. So it could be the relative position of a 

manufacturer producing more premium appliances that has 

a high market share that would enter and skew the 

results in one direction or the other in terms of the 

market share of certain appliances and their 

efficiencies. 

MR. BROOKMAN: Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. To 

get back to the no impact to follow on. As I recall, 

for the no impact, what that really meant was the 

lifecycle costs were plus or minus 2 percent of the 

baseline average LCC; is that -- is that still -- 

MR. LEKOV: No, Steve, it’s not correct. 

This is -- you are referring to something that the 

Department attempted about eight years ago. 

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MR. ROSENSTOCK: Okay. 

MR. LEKOV: -- with the central AC. 

MR. ROSENSTOCK: Yeah. 

MR. LEKOV: That has not been the case since 

then. Exactly the calculation, whatever it is. 

MR. ROSENSTOCK: So when you -- for these 

numbers that are showing no impact on the lifecycle, 

there’s no impact in terms of lifecycle costs, is that 

saying that -- you know, because isn’t there a 

sensitivity range in there somewhere? 

MR. LEKOV: It means that it’s already -- the 

household owns something at this level or above. So 

it’s not impacted by the standard. The equipment is 

already at a sufficiently high level. Above you can 

see the level. 

So, for example, I would say for level one, 

where 49 percent of the -- this 49 percent all of them 

have EER above 10.3 already in their household -- at 

10.3 -- 

Okay. With that this concludes the LCC 

section. And if -- unless Doug has other -- 

MR. BROOKMAN: Nope. 

MR. LEKOV: Okay. 

MR. BROOKMAN: I think we got final comments 

on life-cycle cost analysis. If there are any others, 

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let’s have them now because we are going to keep moving 

on. 

SHIPMENTS ANALYSIS AND NATIONAL IMPACT ANALYSIS 

MR. LEKOV: So I will be presenting also the 

shipment analysis and national impact analysis for both 

products. There is no need to read here, basically 

shipment analysis are needed for the national Impact 

analysis. And here is the process chart basically 

shows you that we have some inputs that are coming from 

LCC. We have model shipments coming from the shipments 

model and we are calculating savings and after that the 

assigning quantitative value to the savings. 

This one here gets into the detail and this 

example of room air conditions. So looking at two 

market segments, replacement, and essentially 

households that had no air conditioner or are adding a 

new room air conditioner. This analysis does not 

consider room AC in new construction. 

So, once they are determined the total 

shipments are derived. So many of the data sources 

used in the shipments model are, again, by market 

segment for both new construction and replacement. 

Lifetime comes from LCC. In terms of just for new 

construction as relates to clothes dryers, two sources 

forecasts for new housing from EIA as well as new 

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housing saturation from RECS. 

Historical shipments for both products AHAM 

submitted data. The existing AHAM fact books -- the 

distributions by product costs for both products we 

have AHAM data submittal for certain years. And with 

that, here is the result for room air conditioners as 

applied in the analysis and this is just to remind 

everybody, this is the base case forecast in case of no 

new standards. So the three segments are clearly 

defined here, room AC replacement, the large portion at 

the bottom, commercial at the top and the middle are 

essentially the new purchases for, as I mentioned, 

household that are ailing, replacement, and so on. 

Those are essentially used to calibrate the 

missing data compared to the actual historical data, 

the line here. As you see here the Department does not 

forecast increase of the shipments in the future. 

 (Pause.) 

MR. LEKOV: Clothes dryers, again, we have 

three markets, replacement, new homes, and first-time 

owners. The historical data is shown there. The trend 

is pretty clear from the historical data. And this is 

where the department ends up in terms of forecast. 

MR. BROOKMAN: Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. For 

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this modeled shipment for new homes, it appears that 

like after 2012 you’re basically saying -- again, I 

can’t -- I don’t have that segment, it’s about over a 

million to a million and a half new homes every year in 

the forecast? 

MR. LEKOV: That’s basically what AEO is 

reporting. 

MR. ROSENSTOCK: Because that seems kind of 

high based on what’s been happening the last few years. 

 Anything over -- well, this year they’re projecting 

300,000 based on NHB numbers. So it just seems a 

little on the -- it might be on the high side. 

MR. BROOKMAN: The 300 is just single family 

you’re talking about? 

MR. ROSENSTOCK: Single family homes, yes. I 

know this is probably new family and multi and -- 

MR. BROOKMAN: Yeah, the housing recession 

you can see pretty clearly right in that midway. 

MR. ROSENSTOCK: But it looks like, again, 

like in 2005 there were about 1.7 million single family 

homes built in the U.S. and last year it was down to 

600,000. So, again, it looks like it’s bouncing back 

to at about a million and a half new homes. Again, 

that seems a little high to me. Just a personal -- 

MR. CYMBALSKY: So you don’t think the 

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housing market will ever recover, that’s your 

statement? 

MR. ROSENSTOCK: I don’t think it’s going to 

go back to the boom years of 2003, 2005, at least -- 

again, just a personal thought, personal observation. 

I don't know how -- 

MR. LEKOV: So, just the response is it’s 

just AEO data. It’s not DOE’s data. 

MR. BROOKMAN: Additional -- 

MR. CYMBALSKY: Which is based on the global 

insight macro economic model. 

MR. BROOKMAN: Where did you get that? 

MR. WITKOWSKI: I would like to point out 

though that if you look at the 2005 data you will see 

that the slope is very high. The slope from going 

forward after that is much less. So you really have to 

look at the slope among other things. 

MR. BROOKMAN: Thanks Steven and also John. 

Okay. So let’s proceed. 

MR. LEKOV: So at this point we have the 

shipments handled and here are all the inputs involved 

in the calculation of the national impact analysis. So 

I will just mostly it’s a list of those and the source 

and the matter so we are looking total installed costs 

from LCC, repair and maintenance from LCC, annual 

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energy is from LCC, base case efficiency at the LCC 

standard case forecast. It’s a roll-up scenario. I 

believe I will be illustrating it on the next slide. 

Energy prices are the average prices and forecasting 

trends from EIA. Electricity site to source conversion 

comes from national energy modeling system, NEMS, and 

we derive, we do the runs. Discount rates are constant 

at 7 and 3 percent, they are coming from OMB. They are 

fixed by OMB. We have a present year which is the year 

where DOE projects to issue the final rule. And for 

room air conditioners, DOE plans to apply the same 

approach. 

Here is an illustration of the forecasted 

efficiency in the future basically using a roll-up 

scenario. Most of you should be familiar with what DOE 

-- how DOE is doing essentially. The base case it 

comes from the AHAM submittal and incorporates original 

efficiency distribution based on the state by state 

Energy Star market share. And after that is the 

standard case efficiency essentially efficiency below 

the standard level roll-up to the considered standard 

level. 

Just an illustration of results for one of 

the room AC product classes. So, this is how the 

energy savings are coming in quads which is ten on the 

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power of 15. 

This is more interesting chart. Basically 

this is the calculation of the net present value. So 

in terms of operating costs you have here below zero 

the expenses which are essentially the equipment cost 

and the repair and maintenance, here are the operating 

costs and it’s given for both commercial and 

residential and this is in billions of dollars the 

savings, the annual savings. 

That’s pretty much what the Department is 

reporting at this phase of the rulemaking for this 

rule. There is one additional slide for the purposes 

of which kind of to give you a heads up of that with 

the so-called trial standard level DOE will calculate 

the impact of the energy savings on the natural gas and 

electricity prices. So, for this phase, since we don’t 

have trial standard levels, just pick up the lowest 

savings for each product class of room AC total 

savings. And after that did the same thing for maxtech, did NEMS runs and came with this is the type of 

impact on the natural gas prices, 0.2 cents for 

efficiency level one, 1.3 for the max-tech which result 

in national benefits of 0.22 billion or 3.25 billion. 

So those are again preliminary results before 

getting to the trial standard levels which will be 

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presented for the next phase. 

And this is wrapping up this part. Oh, and 

there is comments on any aspect. 

MR. BROOKMAN: For this discussion box, any 

part of national impact analysis? Ted. 

MR. POPE: I apologize, Alex, I think you 

said this. What was the reason for doing just the 

roll-up and not a shift? Did you say that? 

MR. LEKOV: Okay. In the past the Department 

presented both scenarios. It seemed to me over the 

last several years the more conservative approach was 

the roll-up so the interested parties basically set up 

with the roll-up. So the calculations are done based 

on the roll-up scenario only. 

MR. BROOKMAN: Okay. Steve Rosenstock. 

MR. ROSENSTOCK: Thank you. Steve 

Rosenstock, EEI. With the calculation of the natural 

gas and electric price impacts and you’re showing the 

benefits, are those benefits separate from future 

projections in gas and electric prices based on AEO? 

For example, if you said, you know, the electric 

pricing would be 11 cents, but because of the reduction 

in demand it 10.9 cents. Is that shown in your LCC 

analysis or is this a separate calculation that you’re 

saying, okay, we’ve done the analysis based on what AEO 

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is projecting, but because of the standard in reduction 

and demand, the actual prices are going to be lower and 

this is a separate savings? 

MR. LEKOV: Okay. First, this is -- you’re 

right. This is a separate analysis which represent the 

annual service for the forecasted period until 2044. I 

believe that what you are saying, Steve, is whether 

there is a closed loop through the LCC and NIA. If 

this is what you mean, basically to come back with the 

calculated lower costs, if this is the direction of 

your question, no, it has not been implemented such 

approach. 

Just also want to point that this particular 

item, although DOE is calculated, how to characterize, 

probably the weight at this point is not very high on 

this item. My understanding is there are some issues 

which are still under development related to the 

transfer portion of it. So, the numbers are presented 

and I would end with this. 

MR. BROOKMAN: Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. I 

appreciate that, but, again, this is probably maybe a 

20,000 foot level. If you say that these standards are 

going to have an impact on the -- I’ll say the 

wholesale or retail prices, then shouldn’t that be 

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included in the LCC analysis? You know, if you’re -- 

again, wouldn’t you have to assume that those benefits 

would show up in the consumer bills if the prices are 

going to go -- if it’s going to reduce the cost of 

natural gas or electricity, wouldn’t that show up in 

the future lower -- in terms of lower energy costs? 

MR. BROOKMAN: Okay. Thank you. Debra is 

next in the queue, Debra Brunk. 

MS. BRUNK: Debra Brunk. And I guess forgive 

me for my ignorance or confusion here, but I am 

struggling a little bit with this natural gas price 

impacts. Are we talking about generation here? What 

are we -- because I’m looking at room air conditioners 

and clothes dryers. I can understand how clothes 

dryers would affect, but I’m not clear how, you know, 

room air conditioners would affect natural gas prices 

except at a generation level. 

MR. LEKOV: Let me try in a simplistic way. 

So basically we have a set of energy savings. We pass 

them to the NEM system which essentially represent the 

entire U.S. energy in common. So what’s happened is 

the output represents certain impacts on the energy 

prices for about six or seven sectors, like power 

sector, transportation, residential, it’s essentially 

distributed. Those are appropriately weighted and 

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we’re using an approach called “inversed elasticity” 

essentially as documented in some external literature 

on this topic. DOE is not the first to do this. And 

certainly there is a sample and the reason why it came 

into the analysis four years ago. So at that point 

it’s possible to get the actual type of reduction. So 

those are about the entire U.S. economy as a result of 

whatever impact comes from these two products. And 

after that we simply do the calculations to get the 

associated NPV value. 

MS. BRUNK: So you’re going back to 

distribution. 

MR. BROOKMAN: Okay. Tim. 

MR. BALLO: Tim Ballo, Earthjustice. Just a 

quick question. I’m sorry if this is in the TSD. The 

15 percent rebound effect for room air conditioners, is 

that based on a study that looked at room air 

conditioners specifically or what’s the source for 

that? 

MR. LEKOV: It’s central air conditioning, I 

believe. Maybe John could comment on this because he 

wrote the algorithms for this. 

MR. CYMBALSKY: Well, I don’t do that job 

anymore, but -- 

 [Laughter.] 

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MR. BROOKMAN: John Cymbalsky. 

MR. CYMBALSKY: Yes, so where they come from 

are meta studies of general rebound effects for service 

end use demand and residential and commercial 

buildings. So, generally it’s things like heating, 

cooling, and lighting. Things you have direct control 

over. So as the cost -- the marginal cost of you using 

that end use falls, you’ll use it more intensively. So 

that’s what that represents. 

MR. BROOKMAN: Yes, please, Meg. No, pardon 

me. Joanna Mahr. 

MS. MAHR: Joanna Mahr. Just a question on 

the rebound effect. In reading the TSD it sounded to 

me like the assumption was that any decrease in savings 

due to the rebound effect was kind of offset by 

increase in consumer utility. And it sounded to me 

like it almost -- the rebound effect didn't come into 

the analysis; is that -- 

MR. LEKOV: Essentially what John said is 

correct for the life cycle cost analysis where you 

analyze household-by-household. However, for the 

national economy it’s -- the energy savings are fully 

reduced by 15 percent as this -- 

MR. BROOKMAN: Okay. Addition comments on 

this set of issues? 

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MR. BROOKMAN: And final comments on national 

impact analysis before we move on? 

(No response.) 

MR. BROOKMAN: Okay. Thank you, Constantin. 

 I mean, Alex. 

MR. LEKOV: Thank you. 

MR. BROOKMAN: And now we are going to hear 

from Constantin. 

TRIAL STANDARD LEVELS AND PRELIMINARY MANUFACTURER 

IMPACT ANALYSIS 

MR. von Wentzel: Okay. Ladies and 

gentlemen, my name is Constantin von Wentzel, I work 

for Navigant Consulting and I’m here to tell you about 

the preliminary impact analysis. 

Specifically we conducted interviews with 

manufacturers of room air conditioners and dryers 

either on site or telephone interviews on several 

topics. One was a rather comprehensive engineering 

analysis of options that manufacturers had to improve 

energy efficiencies and the costs thereof and the 

impacts on the manufacturers thereof. And in addition 

to that we discussed key issues as defined by the 

manufacturer, current market conditions, manufacturer 

and consumer subgroup analysis, product utility 

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innovation, potential impacts of amended conservation 

standards and the cumulative regulatory burdens. 

And for the residential clothes dryers we 

were able to get interviews with approximately 90 

percent of manufacturers in terms of market share. 

In terms of the residential clothes dryer key 

issues, cumulative regulatory burden, number one on the 

agenda was the UL safety requirement in terms of 

clothes dryers being able to contain fires inside the 

drums. Manufacturers were quite cognizant of the cost 

increases that could result in the products and the 

difficulty of implementing that. 

Current and new energy conservation standards 

for other, but related products, such as clothes dryers 

-- clothes washers was another key concern because it 

basically means that a manufacturer has to update 

multiple platforms at the same time as opposed to being 

able to time out or space out plant conversions. 

Last, but not least, in terms of cumulative 

regulatory burden was the potential reduction of 

hazardous substances requirements. This is not 

something that’s a key concern or a key issue yet in 

the United States in terms of it having been 

implemented already, but there appear to be enough 

signs on the horizon that manufacturers have started to 

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worry about it since some markets like California may 

in fact adopt those requirements. 

Impact on product mix, according to 

manufacturers amended energy conservation standards 

could result in longer drying times. This is because 

there is some benefit to simply blowing air through the 

clothes as opposed to heating that air. And the 

question is, is whether consumers would accept longer 

drying times in return for lower energy bills. And 

multiple manufacturers stated that their feeling was 

that if a clothes load took more than one hour to dry 

that most U.S. consumers at this point would reject 

such an appliance. 

In terms of the Energy Star program, multiple 

manufacturers mentioned that the existence of an Energy 

Star standard for clothes dryers could very well push 

forward innovation and higher efficiency in clothes 

dryers because it would justify the research. They 

also mentioned that consumers are becoming more 

educated on clothes dryers and would like to see a 

similar increase in energy efficiency for clothes 

dryers as they’ve observed for clothes washers. And 

the Energy Star label could hence be a very good 

differentiator between baseline equipment and higherefficiency company in the marketplace. 

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Manufacturers were quite concerned about 

current manufacturing conditions which is to say that 

their plants are running at very low capacities due to 

the current economic conditions. They mentioned that 

consumers are basically not consuming nearly as many 

clothes washers and clothes dryers as they have in the 

past. 

So, for example, instead of buying pairs of 

clothes washers and dryers consumers may elect to just 

replace one failed appliance as opposed to both. 

They’ve also seen impacts in terms of what 

kinds of clothes dryers and clothes washers 

manufacturers -- excuse me -- that consumers purchase. 

 Which is to say that they will go for a lower-end 

clothes dryer instead of the high-end because they 

simply don’t have the disposable income anymore to 

afford the higher-cost appliance. 

In addition, in response to the current 

economic conditions, many manufacturers have 

significantly pared back their engineering resources 

which puts an even greater strain on them in terms of 

being able to comply with amended energy efficiency 

standards across all the product platforms that these 

engineering staff are assigned to. 

And because the demand currently is so low, 

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it’s also extremely difficult to justify any kind of 

capital expenditure to change plants around or change 

product platforms at all. 

One of the other key concerns is that if you 

have a higher-volume production it’s easier to justify 

the capital expenditures to, for instance, come up with 

a solution in-house that’s cost effective. However, if 

there is very little capital available you may have to 

resort to buying a third party solution to increase 

your energy efficiency in your appliances. That in 

turn has a significant impact on the profitability of a 

manufacturer. 

So for some manufacturer, especially those 

with low market share, stringent standards could reduce 

their profit margin to a point where the U.S. market is 

no longer attractive. 

Several manufacturers also mentioned that if 

they were forced to redesign products due to amended 

standards costs would increase and they would reduce 

the scope of their products or even cut entire product 

platforms to remain profitable. And this is, again, 

the whole question of capital expenditure. If you’ve 

got multiple product platforms that you have to update, 

you may not have the capital available at all to make 

those changes. So as a result, you might decide to cut 

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the low-volume platforms that don’t, you know, 

represent the bread and butter of your production 

lines. 

And these product conversion costs have a 

significant impact, especially on lower-volume 

manufacturers because they have fewer units across 

which they can depreciate these capital expenditures. 

So, as I mentioned earlier, they may have to 

resort to buying higher-efficiency add-ons or add-ons 

that lead to higher efficiency from third parties which 

would, on the one hand, reduce the capital 

expenditures, but on the other hand result in a higher 

product cost which in turn could make their product 

completely uncompetitive relative to the other products 

in the market. And this is a very competitive market 

segment. 

So, multiple lower-volume manufacturers 

stated that amended energy standards at efficiency 

level 2 and up would most likely force them to exit the 

residential market due to investment requirements and 

the resultant market outlook. And multiple 

manufacturers also expressed concern over how the 

implementation of new design changes for clothes dryers 

would affect their standardization of common parts. 

So what this is referring to is, for 

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instance, your ability as a manufacturer to only stock, 

let’s say, to pull a number out of the thin air, five 

motors instead of 15 motors. Because you might be able 

to use five motors across all of your product platforms 

if they don’t have to be absolutely optimized for each 

platform. Whereas, if you had to optimize each 

platform individually, you might end up with 15 

different motors. That in turn leads to lower buying 

power with motor manufacturers and higher per-motor 

costs. And, of course, also higher storage costs and 

higher inventory costs and so on and so forth. 

Another dryer key issue is product 

innovation. This is a common theme that we’ve heard 

from manufacturers in the past which is to say there is 

a finite amount of resources that each manufacturer has 

that can be dedicated to product development and energy 

efficiency standards basically force manufacturers to 

allocate or prioritize allocations first and foremost 

to reach energy efficiency standards. And secondarily 

to product innovation which may in fact be more 

profitable, but unattainable unless you actually 

achieve that baseline energy efficiency standard set by 

an amended energy standard. 

All manufacturers are concerned that new or 

amended standards would take away from investments and 

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possible innovations that would take place without 

standards. So, just to finish that. 

So requests for comment in terms of 

residential clothes dryer manufacturer subgroups DOE 

research suggested there are no residential clothes 

dryer manufacturers in the United States that are 

designated as small businesses by the U.S. Small 

Business Administration. DOE invites comment from 

whether a manufacturer subgroup analysis is appropriate 

for the NOPR stage. 

MR. BROOKMAN: No comments. Okay. 

MR. von Wentzel: Shall we move on, Doug? 

MR. BROOKMAN: Okay. 

MR. von Wentzel: The next question is, 

residential clothes dryer manufacturers must also 

comply with the underwriter laboratory UL fire 

containment regulation for clothes dryers. DOE seeks 

information from interested parties to further evaluate 

that is issue in the NOPR analysis. 

MR. BROOKMAN: Debra, does AHAM do this kind 

of analysis or do you leave it up to your member 

companies to do it for themselves? 

MS. BRUNK: I’m sorry. Debra Brunk. What 

kind of analysis? 

MR. BROOKMAN: Do you see the box there? 

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MS. BRUNK: Right. 

MR. BROOKMAN: Information from interested 

parties to further evaluate the issue outlined of the 

cost of fire containment regulations? 

MS. BRUNK: I think what we would need to 

look into and understand is how this UL standard would 

affect the cost similar to the change from R-22 to R410A for room air conditioners. And I’m not clear that 

in the initial cost evaluation that we do that this was 

included. So we would need to go back to our 

manufacturers talk about this and try to decide if it 

would be prudent for us to try to provide that 

information as an aggregate. 

MR. BROOKMAN: Are there any manufacturers in 

the room? Do you have any comment at this point? 

 Phil? 

MR. MANTHEI: I think every manufacturer is 

going to have different things to look at. You know, 

we’re all concerned about, you know, if there’s 

plastic, you know, in the clothes dryers in the 

cylinder area and what that implies and, you know, 

meaning passing the test. Will the door pop open, you 

know, can’t pop open; what’s going to happen. 

MR. BROOKMAN: Okay. 

MR. MANTHEI: What are we going to have to 

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do, you know, to make sure that the cheese cloth that’s 

draped over the product, you know, certainly, you know, 

doesn’t catch fire during the tests. So we’ve all -- 

almost all the manufacturers have run their own tests. 

 I think we all have our own issues depending on our 

own design. And each manufacturer is probably going to 

have to make their own comments. 

MR. BROOKMAN: That would be great if you 

could supply that data. 

MR. von Wentzel: Moving then on to the room 

air conditioner preliminary MIA. In this case we are 

able to secure interviews with manufacturers 

representing approximately 30 percent of the market 

share. 

In terms of cumulative regulatory burdens, 

all manufacturers reported challenges regarding the 

2010 EPA phaseout of the use of HCFC-22 refrigerants. 

Issues included reliability and performance of R-410A 

based compressors and size constraints of room air 

conditioners while maintaining the current efficiency 

levels. 

So, for instance, manufacturers reported that 

compressor manufacturers had not yet introduced 

complete lines of compressors at various voltages and 

capacities. So this was a big concern. And then there 

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was also the reliability question because these 

compressors are fairly recent on the market in these 

sizes. 

Potential changes to the electrical codes for 

fire safety could add further costs and manufacturing 

complexity. I believe this refers to the need for AFCI 

plugs on room air conditioners. 

Multiple manufacturers also mentioned 

possible carbon penalties associated with future 

greenhouse gas regulations, RoHS requirements and 

Canadian product safety registration payments. That 

basically refers to a CSA pool. 

Environment Protection Agency banned 

production import of HCFC-22 for newly manufactured 

equipment in the U.S. starting on January 1st, 2010. 

This includes also equipment filled with HCFC-22. So 

it’s not just the gas itself or the refrigerant, it’s 

also equipment containing that. 

Manufacturers reported many challenges with 

addressing this regulation such as higher manufacturing 

costs, the reliability of R-410A based compressors and 

maintaining size constraint while meeting existing 

efficiency levels. And that refers back to the chart 

that we showed earlier which is to say that on average 

there appears to be a 10 percent penalty in terms of 

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the EER of R-410A compressors versus R-22 compressors. 

 Whether you can make that up in the heat exchanger 

design and so on is a question we can leave aside for 

now. 

R-410A compressors do not extend over the 

full range of capacity in EERs of HCFC-22 compressors, 

especially for high capacity room air conditioner 

compressors, i.e., above one and a half tons. 

R-410A operates at higher system pressures 

and thus requires thicker tubing, heat exchangers and 

so on and so forth and better sealing of the sealed 

system. 

In terms of the product mix impacts in the 

Energy Star program manufacturers reported lower 

efficiencies with R-410A based refrigerant units versus 

HCFC-22 units for a given cabinet size. Required 

changes may result in a decrease in total shipments due 

to constraints in the efficiency levels that can be 

reached within the current chassis sizes. Which is to 

say, some capacities may even disappear from the market 

because manufacturers will simply not be able to 

squeeze that much capacity or an adequate amount of 

capacity out of that unit while attaining current 

energy efficiency standards. 

Size limitations are especially relevant in 

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and through the wall market. This is what Detlef 

addressed earlier which is to say that your wall 

cutouts are set, your sleeve sizes may be set, and the 

addition cost of implementing units that are deeper or 

whatnot may be in fact very, very significant and may 

make the consumer make different choices. 

Increases in product size could have a 

significant impact in consumer utility which is to say 

people would perhaps not be able to lift these units 

into their windows anymore and so on and so forth. 

Industry consolidation. Multiple 

manufacturers stated that the number of factories 

currently supplying the U.S. market has shrunk from 20 

to 30 factories to less than 10 even as production 

volumes have increased. Amended standards could 

accelerate this consolidation and no major 

manufacturing facilities remained in the U.S. The bulk 

of manufacturing is now done in Asia with a tiny 

proportion or comparatively tiny proportion being 

produced in Mexico. 

The impact on profitability has been severe 

because the ability of manufacturers to charge a slight 

-- a slightly higher amount for Energy Star compliant 

room air conditioners might be wiped out if they can’t 

in fact produce room air conditioners anymore that 

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reach Energy Star levels because the cabinet may be too 

constrained or what have you. 

And manufacturers also noted that the types 

of consumers that buy room air conditioners tend to be 

very, very price sensitive and/or room air conditioners 

might be discretionary purchases that people make on a 

whim rather than, you know, with long-term planning. 

Industry profit margins have continually 

decreased and could continue to decrease with amended 

energy conservation standards. And what I was just 

speaking about in terms of Energy Star differentiation 

no longer being available is part of that. 

Product conversion costs. Manufacturers 

commented that the availability of technology options 

for energy efficiency improvement and the cost of 

bringing them to market is a key concern. Which is to 

say, if compressor manufacturers, for instance, don’t 

manage to increase the efficiency of R-410A compressors 

as they have, for instance, for HCFC-22 compressors in 

the past, then, you know, that path towards higher 

energy efficiency is blocked. 

Low margins of the room air conditioner 

business make it difficult to recoup any product 

development costs and obviously also capital conversion 

costs and what have you. Amended energy conservation 

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standards could exacerbate some manufacturers’ 

disadvantages of not controlling component development. 

What that’s referring to is, for instance, 

some manufacturers manufacturing their own compressors 

and other key components that go into air conditioners. 

 That kind of vertical integration due to scale and 

what have you then leads to an economic advantage over 

those manufacturers that have to source their 

compressors from somebody else. 

Some manufacturers believe that product 

innovation would be stymied which is to say, you know, 

the primary focus would be on meeting energy efficiency 

standards -- amended energy efficiency standards. A 

secondary focus would be on product innovation. 

Resources would be focused on redesigning for energy 

efficiency improvement rather than on development of 

new products. 

However, some manufacturers believe that 

product innovation would benefit from amended energy 

standards as a potential for compressor and motor 

technology evaluation would increase. So, it’s not 

universal. 

In terms of consumer subgroups affected by 

room air conditioner amended energy efficiency 

standards, multiple manufacturers expressed concern 

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regarding the impacts on low-income and elderly 

subgroups, i.e., those who have lived -- who have to 

live off of fixed incomes. Higher cost necessitated 

from amended energy conservation standards may cause 

these individuals to choose not to buy such units or 

repair, if they can. This would put these consumers at 

risk of heat stroke and other heat-related medical 

issues. Which manufacturers brought up the example of, 

I think it was Chicago in 2003 where unfortunately a 

whole lot of people died due to heat-related issues. 

So, here is another comment regarding 

manufacturer subgroups. DOE research suggests that 

there is at least one room air conditioner manufacturer 

that is a small business. DOE invites comments on 

whether a manufacturer subgroup analysis is appropriate 

for the NOPR stage. 

MR. BROOKMAN: Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. For 

this comment, where is this small business located? 

MR. von Wentzel: I’m not sure I can disclose 

that. All I can say is that they have less than 500 

employees. 

MR. ROSENSTOCK: Is it domestic or overseas? 

MR. von Wentzel: It’s a domestically 

headquartered company. 

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MR. ROSENSTOCK: Is the manufacturer located 

domestically or overseas? 

MR. von Wentzel: I’m not sure I can answer 

that. I will have to get back to you. I’m sorry. 

MR. ROSENSTOCK: That will have an impact on 

my answer then because I would say if it was over -- 

the actual manufacturer was overseas, then I would -- 

my recommendation would be no. 

MR. BROOKMAN: Okay. Thank you. 

Additional thoughts on this before we move 

on? 

 Ted? 

MR. POPE: Ted Pope. Can you clarify -- I 

think most of the data slides you just showed were 

manufacturers’ response to the survey. 

MR. von Wentzel: Uh-huh. 

MR. POPE: You mentioned the R-410A of 10 

percent reduction in efficiency is what’s being said. 

But I feel like at the beginning of the morning session 

it was acknowledged that those efficiency decrements 

were measured on the very first units available with 

410A. I wanted to clarify whether you think that’s the 

case. Is that 10 percent reflective of state-of-theart 410A compressors, or was that from the very first, 

you know, products coming into the market say, two, 

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three years ago? 

MR. von Wentzel: I’m going to have to defer 

to Detlef because he’s our resident HVAC guru. 

MR. WESTPHALEN: Well, I think -- Detlef 

Westphalen. I think what Constantin mentioned in 

regard to the component vendors not being quite up to 

speed when the manufacturers were in the process of 

redesigning their products really comes into play here. 

 You know, we contacted all of the compressor vendors 

to attempt to obtain data to get an understanding of 

what the offerings were. And what we found was that 

there was limited -- you know, there were limited 

options available. We will certainly make another 

attempt and we are already in the process of doing that 

to find out, you know, have they extended their 

offerings? Are there better efficiencies available 

now? So that’s a developing situation and we’ll have 

to see where it goes. 

MR. POPE: Thank you. 

MR. BROOKMAN: Thank you. Let’s got to the 

next comment box. 

MR. von Wentzel: Yep. Other issues. DOE 

welcomes comments and recommendations from interested 

parties on any aspect related to the preliminary 

manufacturer impact analysis. 

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MR. BROOKMAN: Yes, please. 

MR. GOUW: Hi, this is Sean Gouw, Southern 

California Edison. I was just curious, I know 410 is 

the generally accepted replacement for R-22, but have 

any other refrigerants been explored at all? I know 

there are a bunch of papers that explore all of the 

different replacement -- I think there are some blends 

that offer similar thermodynamic properties. Although 

you do get the downside of when you develop leaks you 

have to evacuate and recharge the whole system since 

the ratios become kind of screwed up. But I was just 

wondering if DOE had acknowledged any other 

refrigerants besides R-410A? 

MR. von Wentzel: I’ll take the first stab at 

it and then Detlef can add on. We can simply report 

what manufacturers told us. And every unit that we’ve 

observed in the marketplace, to my knowledge, has been 

R-410A based. Whether you could implement different 

blends that offer properties closer to R-22, there is 

certainly a market for that. I mean, you go to any 

major show and you’ll see people offering these kinds 

of blends. But as far as I know, no OEM has adopted 

such blends. And what the exact reasons are, I’m 

afraid manufacturers would be the only ones to know. 

Or perhaps Detlef, if you have additional 

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comments. 

MR. WESTPHALEN: Well, I’m sure the 

manufacturers could comment as well. But 

standardization is a very important thing in this 

market. Not just from the manufacturing perspective, 

but also for the service and, you know, to be dealing 

with multiple types of refrigerants out in the market, 

you know, it’s already been kind of a mess. And you 

talk to some of the service personnel out there that, 

you know, well, I don't know -- you know, clearly 

there’s an importance for labeling. But there’s also, 

you know, the importance to, limit the number of 

options. 

And this also goes to the compressor 

manufacturers. They don’t want to be dealing with 

multiple refrigerants either. And so, you know, they 

kind of moved towards 410A and everybody got on board 

because of standardization. And there are a lot of 

benefits to that. 

MR. GOUW: I guess I was just curious if 

anyone knew of any studies, if anyone looked into any 

other refrigerants. I know the EPA website lists -- I 

want to say upwards of 20 different acceptable 

refrigerant replacements for R-22. 

MR. WESTPHALEN: It may be that, you know, 

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theoretically they could be developed. But if the 

compressor vendors aren’t going to stand behind the 

compressor using those substances, then the 

manufacturer can’t really consider using them. 

MR. BROOKMAN: Brice. 

MR. BOWLEY: Brice Bowley. I have to agree 

with Detlef. It’s certainly basically standardizing to 

one refrigerant is important because right now from a 

service standpoint we’re working with refrigerators 

which are 134A, old air conditioners which are R-22, 

and then R-410A and basically the compressors are -- 

you know, most of the compressor suppliers went to 410A 

and they qualified reliability which the reliability of 

the compressors long-term is a very costly process to 

actually qualify on multiple products. So that tends 

to be very costly. 

So service and qualification both are big 

cost drivers and standardizing to one, you know, 

refrigerant was really important for us. 

MR. BROOKMAN: Thank you. 

Let’s keep -- Steve, go ahead. 

MR. ROSENSTOCK: Just a final thought on the 

manufacturer impact analysis is for this -- for the 

NOPR stage is DOE going to be able to break out impact 

in terms of domestic versus international in terms of 

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all the manufacturing impact whether it’s production, 

economic, job losses or job gains? 

MR. von Wentzel: I think that’s a very tough 

nut to crack and we are going to have to think very 

hard about how to do exactly that. 

MR. ROSENSTOCK: Thank you. 

MR. von Wentzel: So we invite any 

suggestions from you regarding how you would best 

consider doing that. 

MR. BROOKMAN: Okay. 

MR. von Wentzel: Or any other interested 

party for that matter. 

MR. BROOKMAN: So let’s move on to the first 

aspect of the NOPR, the Trial Standard Levels. And 

then maybe after this we’ll take a short break. Yes. 

Back to Alex Lekov. 

Trial Standard Levels and Preliminary 

Manufacturer Impact Analysis 

MR. LEKOV: So from that point on there will 

be one or two slides type of presentations to outline 

the activity that are going to happen during the next 

phase. 

So just to remind everybody that the next 

phase of the rulemaking when the group meets in six or 

eight months, instead of efficiency levels you will see 

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trial standard levels. So here is to give heads up to 

everybody and to know that the trial standard levels 

are developed at the least of potential standard -- 

which impacts are weighted and the proposed standard 

level is selected. 

There are criteria on how to organize those. 

 Here is the list of the criteria and essentially today 

the Department would like to invite you potentially to 

comment on what’s the best way of putting together 

those trial standard levels. And there are some 

examples that show how the Department dealt with this 

in the past. 

For example, the one criteria was the most 

efficient level, essentially the max-tech, the levels 

with lower lifecycle costs, levels with payback within 

three years or less. Efficiency levels with a specific 

technology and also some efficiency level that may come 

under other criteria or just as characterized here 

filled in large gaps. 

So, that’s about it. 

MR. BROOKMAN: Do you want to move ahead to 

the next slide? 

MR. LEKOV: I don’t think there is another 

slide for this topic. 

MR. BROOKMAN: Okay. 

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MR. LEKOV: Basically this is the comment. 

Here is the request for the comment. It’s a 

consideration of the criteria for the selection of 

trial standard level. So, any feedback. 

MR. BROOKMAN: Fortunately it’s on the same 

page on your slides on your -- on the copy that you 

have. So any comments on trial standard levels? And 

you can refer back? Yes? 

 (No response.) 

MR. BROOKMAN: No. Okay. No comments. 

Yes, please, Joanna. 

MS. MAHR: Joanna Mahr. We would just like 

to encourage DOE in addition to evaluating the level 

that represents the lowest life-cycle cost also 

evaluate a level that represents the maximum savings 

while still being cost effective for the consumer. 

MR. BROOKMAN: Okay. Thank you. 

We’ve been going over an hour and a half 

since lunch. So let’s take a short break. Can we do 

this in ten minutes? Ten minutes which means just 

about 3:00. 

(Brief recess taken at 2:50 p.m.) 

MR. BROOKMAN: We’ll start back up. Jeff 

Kingman, manufacturer impact analysis. 

MANUFACTURE IMPACT ANALYSIS 

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MR. KINGMAN: I’m Jeff Kingman from Navigant 

Consulting. I’m working with the Department of Energy 

for the NOPR phase of the rulemaking. I’m particularly 

working on the manufacturer impact analysis. 

The important part about this slide is the 

manufacturer impact analysis is one of the downstream 

analyses. But the main purpose is to assess the impact 

of amended energy conservation standards on the 

manufacturers. The main output is the result of a cash 

flow model called a “government regulatory impact 

model.” And that is the measure of the industry -- the 

net present value of the industry after standards. 

Another important part of the manufacturer 

impact analysis is to look at the impact of subgroups 

of manufacturers that could be differentially harmed by 

standards. 

This slide just shows that the MIA is 

conducted in three phases and the next few slides just 

kind of go through those in a little bit more detail. 

Like I said before, this slide just again 

highlights that all the other of the analyses that were 

gone over in more detail today are inputs to the 

manufacturer impact analysis, in particular the 

shipments from the national impact analysis and the 

product costs from the engineering analysis. 

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The first phase is the industry profile. A 

lot of this stuff is presented in the TSD, but it is 

the public -- the information about the industry that’s 

available publicly. Some of the inputs or some of the 

things that DOE looks at are listed on this slide too. 

The second phase, DOE uses this publicly 

available information to do a preliminary run of the 

government regulatory impact model. And, again, the 

key output for that is the industry net present value. 

Another key part of phase two is the 

development of the interview guides. Similar to how 

the engineering analysis was conducted for the 

preliminary phase and the NOPR phase for the 

manufacturer impact analysis we go back to 

manufacturers with a new set of questions. Those 

interviews will take place following the comment period 

-- the close of the comment period, rather. And it’s 

just important to note that we do or Navigant 

Consulting does have confidentiality agreements in 

place with the manufacturers. And so information that 

is disclosed is kept private. At a minimum, it’s 

aggregated. 

This slide just some of the typical topics 

that the interviews include. 

In the third phase the actual analysis 

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conducted including the interviews and the inputs for 

the financial model are finalized. 

And, again, as I mentioned and as Constantin 

mentioned earlier too, the subgroup analyses are just a 

more focused version of the industry wide highlighting 

any groups that can be differentially impacted. One of 

the obligations or statutory obligations is to look at 

the impact on small businesses and that’s why we 

included those comments before or the request for 

comments before. 

Additionally we went over some of this 

before, but if anyone has any additional comments on 

the cumulative regulatory burden, those would also be 

appreciated. 

And this slide just highlights that, that 

this is in particular some of the regulations that are 

highlighted for dryer manufacturers, in particular, and 

if anyone has anything to add to that. 

And this is something that we’ll also be 

going over in interviews more in depth too. 

MR. BROOKMAN: Just pause there just very 

briefly. This comment box, additional things you don’t 

see here that the Department should consider with 

respect to cumulative regulatory burden. 

(No response.) 

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MR. BROOKMAN: Okay. 

MR. KINGMAN: And this is a similar slide for 

the room AC. 

Okay. And finally, as we -- we did go over 

this earlier today too, but we or DOE is interested in 

identifying any potential small business manufacturer 

for the NOPR phase. So if there are indications that 

there are others that we were missing, we would 

appreciate that. 

And finally, I’ll be around after the meeting 

too. I know we went through these kind of quickly, but 

if anyone has any specific question about how we 

conduct the NOPR analysis, definitely feel free to come 

over and talk to me. 

MR. BROOKMAN: Okay. Final comments on this 

stream before we go on to Utility Impact Analysis and 

the others? 

(No response.) 

MR. BROOKMAN: Okay. Alex Lekov. 

UTILITY IMPACT ANALYSIS, EMPLOYMENT IMPACT 

ANALYSIS, ENVIRONMENTAL ASSESSMENT, REGULATORY 

IMPACT ANALYSIS 

MR. LEKOV: So now I will address four 

analysis flows, utility impacts, indirect employment 

impacts, environmental assessment, and regulatory 

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impact analysis. Details on those -- those are pretty 

detailed analyses with relatively significant 

background that are going to be presented to you during 

the NOPR phase of the rulemaking. Starting the utility 

impact analysis, the purpose is to investigate the 

impact on utilities from reduced energy use and peak 

load demand due to potential standards. 

So, DOE uses the national energy savings 

results from NIA. And as a tool, DOE uses the NEMS 

program. The output of this are several variables. 

But the one that is emphasized and reported in the 

Federal Register documents is the change in new 

capacity construction. So, the reductions of power 

plant that may result from the standard. 

So, this is the introduction to the utility 

impact analysis. Any comments? 

(No response.) 

MR. LEKOV: The Department also addresses the 

indirect impact -- the indirect employment impact and 

just to highlight that this differs from what Jeff 

explained, the direct employment impacts which are 

associated to a specific industry. This is here we are 

talking about a national employment impact over 

multiple sectors of the economy. 

So, again, there is a standard tool called 

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IMSET which is a model of the U.S. economy. It looks 

at a number of sectors that may be impacted by the 

prediction in the energy use by those two products. 

The changes in products as well as other related energy 

expenditures are coming from the national impact 

analysis. And the outcome is essentially here is 

stated as change in employment sectors as a consequence 

of new standards essentially produces by itself a 

change of employment and change in the national 

employment, everything outside of the manufacturers. 

MR. BROOKMAN: So we will just take comments 

on that should there be any at this time. 

Employment impact analysis. Yes, your name, 

please. 

MR. LISS: Dave Liss, NEEP. I just wanted to 

actually jump back to the utility impact analysis. 

Sorry. 

MR. BROOKMAN: Okay. 

MR. LISS: I didn't get this in. 

On the change in the new capacity 

construction there are ways to quantify the economic 

benefits of reduction in capacity construction, at 

least in the northeast. And I know there are in other 

regions. Do you -- do you plan to include those 

quantifications in any kind of way in the NOPR? 

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MR. LEKOV: DOE’s standard approach is to 

report just the change in capacity generation. 

MR. LISS: Okay. 

MR. LEKOV: The economic benefits of this are 

not included at this point. 

MR. LISS: Okay. We’ll be -- I’m happy to 

submit some information from studies from the 

northeast. Thanks. 

MR. BROOKMAN: Thank you. That would be 

helpful. Okay. 

MR. LEKOV: So on environmental assessment, 

so the -- it’s a mandatory government requirement in a 

pretty significant way. Essentially the purpose is to 

report environmental impacts as a consequence of new 

energy conservation standards including changes in 

power plant emissions, and emissions at the household 

level. 

So, again, the analysis starts with energy 

savings from NIA. The main tools is NEMS which 

provides the component related to power plant 

emissions. In the case of fossil fuel fired plants is 

there are so-called “in building conditions”. Those 

are determined separately. Basically the Department 

develops a spreadsheet using emission factors based on 

specific guidelines from EPA. 

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MR. BROOKMAN: Yes, Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. Are 

you going to estimate the CO2 emissions from the fossil 

fueled appliance along with the SO2, NOx? 

MR. LEKOV: DOE plans to do this. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. It 

wasn’t shown on your slide, so that’s why I was asking. 

Thank you. 

MR. LEKOV: Okay. 

MR. BROOKMAN: Thank you. 

MR. LEKOV: Okay. The other important 

component here is which basically started to be 

standard in the recent rulemakings is the calculation 

of the economic benefits resulting from emission 

reductions based on a range of monetary values. 

Therefore, DOE before reported the emission savings in 

terms of carbon and in million tons -- now DOE also 

applies this interagency approach to provide also 

dollar values associated with those emission savings. 

And basically the output is the different 

emission reductions. Some of them are kept through 

regulations or they may not show up in the outcome. 

And this is about it for this particular analysis. 

MR. BROOKMAN: Comments on the environment 

assessment? 

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MR. BROOKMAN: Okay. 

MR. LEKOV: The Department is also obliged to 

provide regulatory impact analysis and does basically, 

although those are called regulatory impact analyses, 

they investigate the national impact due to nonregulatory alternative actions. So, there is a pretty 

detailed analysis which assess the impacts of early 

replacement, prescriptive standards, voluntary 

efficiency targets such as Energy Star, et cetera. 

So, the tool is a modified NES spreadsheet 

which has certain assumptions that are well documented 

in the Federal Register document or in the TSD. And 

essentially those scenarios increase the overall 

appliance efficiency and are modeling to represent the 

impact of these programs. 

Usually the outcome is certain impacts 

similar to the impacts from the standards. However, 

the changes are always different from the standard. 

And the end totals presented exactly the same 

way as the NIA in terms of national energy savings and 

net present values. 

MR. BROOKMAN: So comments on the regulatory 

impact analysis. 

(No response.) 

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MR. BROOKMAN: That’s it. 

MR. LEKOV: Okay. 

MR. BROOKMAN: Thank you, Alex. 

So as we said this morning, now is an 

opportunity for anybody to make additional comments, 

issues you wish to raise, think that have not been 

covered sufficiently, et cetera. 

 (Pause.) 

MR. BROOKMAN: Joanna, go ahead. 

MS. MAHR: Joanna Mahr. Just that we would 

request, I think there’s a small error in the national 

impact analysis spreadsheet for the group four of room 

air conditioners. It shows the operating cost savings 

to be negative. So I think it’s just a spreadsheet 

error. I would just request that change. 

MR. BROOKMAN: Okay. Thank you for noting 

that. 

Other comments before we turn it back to the 

DOE folks for closing remarks? 

(No response.) 

MR. BROOKMAN: Okay. That’s it for my part. 

 Thank you. Back to Stephen Witkowski. 

And I’m going to hand out this evaluation 

sheet. Please take the minute that it takes to fill it 

out. The Department reads them. They are always 

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looking for ways to improve these meetings. 

NEXT STEPS AND CLOSING REMARKS 

MR. WITKOWSKI: Well, first of all I would 

like to thank all of you for attending and 

participating. And I would strongly urge you to submit 

comments -- written comments by the comment period 

closing date which is April 26. And all of that 

information is on the last sheet here. It’s also in 

the Federal Register notice. 

In the past a number of you have also cc’d me 

requesting receipt of comments. I have no problem with 

that. My e-mail address is in the Federal Register 

Notice. But please make sure that the primary 

recipient is the e-mail address given here and in the 

Federal Register. We look forward to your comments. 

Also, once the transcripts are available and 

reviewed, we will try to get them posted. But, 

unfortunately, I can’t make any promises on the time 

frame. But we will do our best to get that up there. 

And, again, thank you very much for coming. 

We really appreciate your participation and we look 

forward to your input. 

MR. BROOKMAN: Safe travels. 

(Whereupon, at 3:20 p.m., the meeting was 

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adjourned.) 

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REPORTER'S CERTIFICATE

 This is to certify that the attached proceedings 

before: 

U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

ENERGY CONSERVATION STANDARDS FOR 

 RESIDENTIAL CLOTHES DRYER AND ROOM AIR CONDITIONERS 

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law Judge 

or the Agency. 

 Further, I am neither counsel for or related to any 

party to the above proceedings. 

 

Wendy Greene 

 Official Reporter 

Dated: March 17, 2010 

EERE-2007-BT-STD-0010 COMMENT 21.4