UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

PUBLIC MEETING 

ON

ENERGY CONSERVATION STANDARD 

FRAMEWORK DOCUMENT FOR 

AUTOMATIC COMMERCIAL ICE-MAKERS

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Room 8E-089

Thursday 

December 16, 2010

 

Chair:

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Daryl Erbs 

Manitowoc Ice 

John Broadbent 

Scotsman Industries 

Jeff Biel 

Scotsman Ice Systems 

Meg Waltner 

Natural Resources Defense Council 

Robin Roy 

Natural Resources Defense Council 

Joanna Mauer 

Appliance Standards Awareness Project 

Harvey Sachs

American Council for an Energy-Efficient Economy 

Karim Amrane 

Air-Conditioning, Heating, and Refrigeration Institute 

Tim Ballo 

Earthjustice 

Donald Mauritz 

Lawrence Berkeley National Laboratory 

Participants from DOE:

John Cymbalsky 

Department of Energy 

Ari Altman 

Department of Energy 
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General Counsel’s Office

Charlie Llenza 

Department of Energy 

Project Manager 

Participants from

From Energetics:

Eric Jones 

From Navigant Consulting:

Detlef Westphalen 

Tommaso Gomez 

Participants from Pacific Northwest National 

Laboratory:

Eric Andersen 

Michelle Britt

Alan Cooke 

Sarah Widder 

Participants from Public Solutions:

Doug Brookman 
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I N D E X

AGENDA ITEMS PAGE

Welcoming Remarks 6

 MR. CYMBALSKY

Introductions 8

 MR. BROOKMAN 

Agenda Review 9

 MR. BROOKMAN 

Stakeholder Opening Statements

 MS. MAUER 14

 MR. ERBS 16

 MR. BROADBENT 19

 MR. SACHS 19

Regulatory History and Rulemaking Scope 

MR. LLENZA 22

Rulemaking Overview 

 MR. LLENZA 33

Market Assessment 

 MS. BRITT 36

Technology Assessment

 MR. WESTPHALEN 76

Screening Analysis 

 MR. WESTPHALEN 97

 

Engineering Analysis 98

 MR. WESTPHALEN 

Test Procedure Background and Potential Changes 

 MS. WIDDER 136 

Markups and Equipment Price Determination 

 MR. COOKE 160 
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AGENDA (continued) 

Energy Use Characterization 

MS. BRITT 167 

 

Life Cycle Cost and Payback Period Analysis 

 MR. COOKE 178 

Shipments Analysis

 MR. COOKE 189 

National Impact Analysis 

 MR. COOKE 194 

Preliminary Manufacturer Impact Analysis

 MR. COOKE 196 

NOPR Analyses Overview

 MR. WESTPHALEN 199 

Other issues

 MR. BROOKMAN 202 

Conclusions and Closing Remarks 

 MR. LLENZA 203 

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

2 9:07 a.m.

3 MR. BROOKMAN: Good morning. Welcome 

4 everyone. This is the Department of Energy Public 

5 Meeting on the Energy Conservation Standards 

6 Framework Document for Automatic Commercial Ice 

7 Makers. Today is Thursday, December 2010. It’s 

8 about 20 degrees, 15 degrees outside in Washington, 

9 D.C. It’s a cold morning.

10 So glad you could join us. We’re going to have 

11 welcoming remarks here at the outset from John 

12 Cymbalsky. 

13 WELCOMING REMARKS FROM DEPARTMENT 

14 MR. CYMBALSKY: Thank you Doug. Welcome 

15 everybody to the Commercial Ice Maker Public 

16 Meeting. It’s a very appropriate day to pick 

17 commercial ice-makers. We’re finally going to get 

18 some snow later today. So for those of you from out 

19 of town, you’ll get to witness firsthand what D.C. 

20 is like with one to two inches of snow. So be 

21 prepared. I’m sure your flights won’t be cancelled. 

22 So you might want to stick to the train and not 
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1 drive if it gets a little ugly out there. 

2 For those of you that are new to this 

3 process I would just like to put a special welcome 

4 to you and just let you know that our process here 

5 is very open. We’re very interested in getting your 

6 views and information on the product that we kind of 

7 regulate here. 

8 We do not want to do anything that’s in a 

9 back room. We want everything out in the open. Any 

10 information that you can provide from the industry, 

11 data in particular, that will help us have a better 

12 rulemaking, we appreciate. We appreciate comments 

13 as early in the process as possible. 

14 Just to reinforce how much we like the 

15 stakeholders getting together. I just would like 

16 for you to know that five of our next seven 

17 rulemakings that we have on the schedule have 

18 elements in it that were consensus-driven by 

19 industry and efficiency advocates. Now if you come 

20 up with a consensus efficiency level, it doesn’t 

21 mean that’s the one we will choose, but we have 

22 looked at the levels in our analysis and so we 

23 appreciate any sort of work on that side that you 

24 all do. 

25 But again, I have to run back to work, 
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1 unfortunately, but have a good meeting, hopefully 

2 get home safe in the snow. I’m sure it won’t be too 

3 big a deal. 

4 INTRODUCTIONS 

5 MR. BROOKMAN: Thank you. It’s our 

6 tradition to start off by doing introductions. 

7 Please say your name and organizational affiliation. 

8 You can also get in the habit of turning on your 

9 microphone so that this is on the record. We’ll 

10 start over here, please.

11 MR. ERBS: Daryl Erbs, Manitowoc Ice. 

12 MR. BROADBENT: John Broadbent, Scotsman 

13 Industries. 

14 MR. BIEL: Jeff Biel, Scotsman Ice 

15 Systems. 

16 MS. WALTNER: Meg Waltner, Natural 

17 Resources Defense Council.

18 MR. ROY: Robin Roy, Natural Resources 

19 Defense Council. 

20 MS. MAUER: Joanna Mauer, Appliance 

21 Standards Awareness Project. 

22 MR. SACHS: Harvey Sachs, ACEEE.

23 MR. AMRANE: Karim Amrane, Air24 Conditioning, Heating, and Refrigeration Institute. 

25 MR. LLENZA: Charlie Llenza, Department of 
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1 Energy, the Project Manager for this rulemaking. 

2 MR. BROOKMAN: Please stand up, Detlef. 

3 MR. WESTPHALEN: Detlef Westphalen, I’m 

4 with Navigant Consulting, supporting the DOE in this 

5 rulemaking. 

6 MS. BRITT: I’m Michelle Britt with 

7 Pacific Northwest National Laboratory, also 

8 supporting DOE. 

9 MR. COOKE: Alan Cooke, Pacific Northwest 

10 National Laboratory, also supporting DOE. My friend 

11 who is heading this way, Sarah Widder, is also with 

12 PNNL supporting DOE. 

13 MR. BALLO: Tim Ballo with Earthjustice. 

14 MR. GOMEZ: Tommaso Gomez, 

15 also with Navigant Consulting, also supporting DOE. 

16 MR. BROOKMAN: Please say your name. 

17 MS. WIDDER: Sarah Widder, Pacific 

18 Northwest National Laboratory. 

19 MR. BROOKMAN: Perfect timing. You’re 

20 next.

21 MR. MAURITZ: I’m Donald Mauritz with the 

22 Lawrence Berkeley National Laboratory, supporting 

23 the Federal Energy Program. 

24 AGENDA REVIEW 

25 MR. BROOKMAN: Excellent. I’m going to do 
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1 a very brief agenda review. I think all of you 

2 received a packet of information as you came in the 

3 door, both the Federal Register notice and the 

4 agenda, and also the power point slides. The power 

5 point slides, for those of you that are new to these 

6 proceedings, will be the focal point for 

7 presentation and discussion. And the Department, as 

8 you look through these slides, you’ll notice that 

9 they have comment boxes, request for comments are 

10 pulled out for you so that you can’t miss them. 

11 Immediately following this agenda review, 

12 there’s an opportunity for anybody who wishes to do 

13 so to make an opening remark. Brief statements 

14 surrounding key issues and key concerns that you 

15 might wish to raise here at the outset. 

16 Following that, we’re going to hear about 

17 the regulatory history and rulemaking scope. And 

18 then, rulemaking overview. Following that 

19 immediately, we’ll go into the detailed substantive 

20 content of this proceeding, market and technology 

21 assessment, screening and engineering analysis. 

22 Somewhere, there, midmorning or so, we’ll 

23 take a coffee break. 

24 Following that break or wherever it fits, 

25 we’re going to have the test procedure background 
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1 and scheduled changes, a discussion of markups, 

2 energy use characterization, life cycle cost, and 

3 payback period analysis, shipments analysis, 

4 national impact analysis, and life cycle cost 

5 subgroup analysis, utility impact analysis, 

6 employment impact analysis, environmental assessment 

7 and regulatory impact analysis. All of those 

8 analyses there. 

9 And there’s yet another opportunity as you 

10 see in the agenda for - at the end of the day, which 

11 today we -- the agenda reflects that they expect 

12 we’ll be done round about one o’clock today. In 

13 that general time frame, yet another opportunity for 

14 people to raise issues that haven’t been raised 

15 sufficiently to comment, additional opportunity to 

16 comment then. So the Department really wants to 

17 hear from you. 

18 So if it goes according to plan, we may be 

19 ending early today. Maybe we’ll get out of here 

20 before the snow starts falling, we’ll see. But we 

21 don’t want to truncate anybody’s capacity to say 

22 what they came to say. Questions about the agenda? 

23 Comments on those? 

24 I’d ask for your consideration. I’ve 

25 listed up here what have emerged as norms for these 
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1 meetings. Please speak one at a time. Please say 

2 your name for the record. There will be a complete 

3 transcript of this meeting available, and it will be 

4 on the EERE website, or is that at regulations.gov 

5 now? Regulations.gov, yes. 

6 I’m going to be cueing individuals to 

7 speak by name. I also wish to encourage follow-on. 

8 Please say your name each time you speak. You don’t 

9 need to say your organizational affiliation, all of 

10 you registered as you came in the door, so the 

11 Department knows who is here, and the Department 

12 would make a Xerox copy of everybody’s business 

13 cards so all in attendance will know who’s here.

14 If we keep the focus here, turn your cell 

15 phones on silent mode, limit your sidebar 

16 conversations. And as I said, if you’re going to 

17 speak, you need to turn these microphones on. 

18 They’re pretty good. They’re orbital and they work 

19 pretty well. And you could be concise, share the 

20 air time, that’s what we’re hoping for today. 

21 Questions, comments before we proceed? 

22 One other thing, we -- this meeting, this regulatory 

23 proceeding is being made available via the web. We 

24 have therefore, have held a webinar. For those who 

25 have joined us via web -- do we have any yet? 
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1 MR. JONES: Yes, we have two. 

2 MR. BROOKMAN: For those of you who have 

3 joined us via the web, glad to have you with us. 

4 We’ll try to make this accessible to all present and 

5 all remote. 

6 As I understand it, there is the capacity 

7 during the meeting, for you to ask questions via the 

8 web, so you can type them in and Eric, who’s 

9 monitoring what’s going on, will try and forward 

10 your questions as best he can, as best they fit with 

11 the proceeding as it goes on here. So that’s an 

12 invitation to those of you on-line, don’t feel like 

13 you can’t ask a question if it’s important to you.

14 Let me see, Harvey Sachs.

15 MR. SACHS: Would it be appropriate to ask 

16 that those on the web -- on the remote broadcast be 

17 introduced as well. 

18 MR. BROOKMAN: Is there a way to do it? 

19 MR. JONES: I can read off their names. 

20 MR. BROOKMAN: Why don’t you read off the 

21 names, Eric, yes. 

22 MR. JONES: All right. We have Jennifer 

23 Williamson, John Lemmond, Mark Menzer, Michael 

24 Maertens, Stephen Schaeffer, Hung Pham, Elizabeth 

25 Albern, David Winiarski, Brian Bunisek (ph), and 
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1 Bijit Kundu. 

2 MR. BROOKMAN: Okay. Thank you. So those 

3 of you on the web, please feel free to send us a 

4 question, and we’ll do our best to address it.

5 I’m about to proceed here. Additional 

6 questions here at the outset before we -- 

7 PARTICIPANT: Is this the point for the 

8 opening remarks? 

9 MR. BROOKMAN: That is exactly where we’re 

10 going next, yes. So this is the opportunity for 

11 anybody that wishes to do so, to make brief opening 

12 remarks to highlight key issues and concerns that 

13 you might have here, as I say, at the outset. 

14 Joanna.

15 STAKEHOLDER OPENING STATEMENTS 

16 MS. MAUER: Joanna Mauer. First we just 

17 want to acknowledge that DOE is initiating this 

18 rulemaking early, relative to the statutory deadline 

19 for publication of the final rule, and we appreciate 

20 that DOE has recognized this rulemaking as a 

21 potential opportunity for realizing savings sooner 

22 than what might otherwise have happened. We also 

23 strongly support DOE’s proposal to expand the scope 

24 of this rulemaking beyond cube machines, to include 

25 both continuous type ice-makers and ice-makers with 
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1 larger capacities. 

2 We look forward to the discussion during 

3 today’s meeting and we just wanted to outline a few 

4 questions that we have to get some clarification on 

5 through the course of this meeting, as well as the 

6 few issues that we hope will be addressed. 

7 First, it seems like there are multiple 

8 ways of classifying automatic ice-makers and we’d 

9 like to better understand the scope of coverage of 

10 the current test procedure and the proposed scope of 

11 coverage for this rulemaking, to insure that all 

12 types of ice-makers are covered, including 

13 combination soda ice machines, and ice-makers that 

14 produce chipped or crushed ice. 

15 Secondly, we support DOE’s proposal to 

16 include a water efficiency metric for potable water 

17 consumption, and while we recognize the substantial 

18 improvement in water efficiency that the industry 

19 has made in recent years, we believe there is still 

20 significant opportunities for water savings. We 

21 also want to insure that any water efficiency 

22 standard actually translates to water savings in the 

23 field. We’ve heard anecdotally that installers 

24 often install cube-type ice-makers with a purge 

25 setting in the highest water use position, which may 
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1 result in substantially different water consumption 

2 in the field compared to tested water consumption. 

3 We also encourage DOE to explore technical 

4 solutions that might include automatic adaptive 

5 controls. And finally, we’d like to understand 

6 whether DOE is proposing to capture any energy use 

7 associated with ice storage, and whether that energy 

8 use is captured in the current test procedure. 

9 Thank you and we appreciate the 

10 opportunity to participate in this public meeting. 

11 MR. BROOKMAN: Thank you. Additional 

12 comments, opening remarks here. Yes, Daryl. 

13 MR. ERBS: Hi, Daryl Erbs, Manitowoc Ice. 

14 We also are very much in support of the use of 

15 standards to basically define the efficiency and 

16 help regulate our industry. We’ve been very active 

17 in AHRI in the development of their standards and 

18 also with the ASHRAE test methods. 

19 In terms of this rulemaking, we certainly 

20 appreciate that DOE is following the prescribed 

21 procedure where every five years they need to take a 

22 look at it. We hope they’ll have an open mind as to 

23 whether it’s actually necessary to make any changes. 

24 For us, we’ve been under the scope of these 

25 standards for a little under a year now, so it’s 
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1 kind of new for us. You know, unlike air 

2 conditioning and some other product segments, we’re 

3 still trying to sort out how well it’s working as it 

4 currently is, and so I guess, qualitatively, it 

5 feels like it’s kind of soon to be talking about 

6 changing something that we’re really still trying to 

7 put in place as an operating mechanism, but we 

8 appreciate that, you know, this proceeding needs to 

9 go forward. 

10 In terms of cube, batch-type cube 

11 machines, you know, from my perspective, there has 

12 been relatively little change in the technology 

13 available to us over the past few years. It doesn’t 

14 say that there couldn’t be other changes in the 

15 future, but I want to make sure that everyone 

16 appreciates that in a batch-type ice machine, the 

17 components that are really key in terms of energy 

18 efficiency are somewhat constrained and somewhat 

19 unique. So something as simple as a compressor for 

20 an ice-maker has some special requirements due to 

21 the periodic nature of the batch ice making cycle. 

22 And so we can’t use just any old compressor in an 

23 ice machine. It has to have certain design 

24 requirements. 

25 Our volume in total for the industry is 
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1 small. It’s maybe 200,000 in a really good year, 

2 and so when you look at what a compressor 

3 manufacturer going to do when they’re designing new 

4 products? T? They really don’t pay attention to 

5 something that represents that kind of volume. So 

6 compared to air conditioning and some other 

7 industries, I think you just have to make sure that 

8 you don’t consider the refrigeration system in an 

9 ice machine as being no different from that in an 

10 air conditioner and therefore able to take advantage 

11 of all of the technologies that have been introduced 

12 into those product classes. So I think that’s a 

13 critical point. 

14 And then the whole water side of it, which 

15 I know we’ll talk about, is complicated. There’s a 

16 lot of magic that goes on, a lot of black art, and a 

17 lot of things that we’re still trying to understand. 

18 I’m just being honest. I mean, we understand pieces 

19 of it, but, you know, the key output from an ice 

20 machine is to make clear, hard ice, and to do that 

21 repeatably and to do it reliably. And so we’re 

22 going to be very concerned about changes that are 

23 just focused on water use or energy use because at 

24 the end of the day if we improve the energy 

25 efficiency by a little bit, but give customers an 
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1 output from our products that they see degraded from 

2 what they had in the past, I don’t think we’re going 

3 to help anyone in the process. They’re not going to 

4 replace their ice machines. They’re not going to be 

5 encouraged to embrace this type of change. 

6 So I guess just a little bit of caution 

7 from my perspective, and we’ll have additional 

8 comments as we go on through the day. Thank you. 

9 MR. BROOKMAN: Additional comments here at 

10 the outset. Yes, please, John. 

11 MR. BROADBENT: John Broadbent at Scotsman 

12 Industries. I just want to let you know that 

13 Scotsman also takes this regulation rulemaking very 

14 seriously, and I’ve been appointed to be the contact 

15 for the effort, and I’m at your service to do 

16 whatever and be a resource as needed. 

17 One thing I can point out is I was 

18 personally involved, as well as another person from 

19 Scotsman Ice Group, involved in the California 

20 Energy Commission rulemaking that today’s 

21 regulations came from, and so I understand how we 

22 got there and am familiar with how all those 

23 equations were arrived at. 

24 MR. BROOKMAN: Okay. Yes, Harvey Sachs.

25 MR. SACHS: Harvey Sachs. First, thank 
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1 you to DOE, and secondly, just a bit of a follow up 

2 on Doug’s warning about weather conditions. It’s 

3 actually much warmer here in Washington than it is 

4 in outlying areas like Baltimore, which means we’ll 

5 be much closer to slush, and that’s because of the 

6 enormous amounts of hot air generated here. House 

7 and Senate are in session. 

8 MR. BROOKMAN: I’m not sure we’re making a 

9 meteorological prediction there. 

10 MR. SACHS: I was. 

11 MR. BROOKMAN: Okay. 

12 MR. SACHS: With that kind of certainty. 

13 I also want to just mention very quickly some 

14 concerns that we have at ACEEE. One of them is the 

15 need to draw, for self-contained units, the clear 

16 distinction between water-cooled condensers and air17 cooled condensers, and it’s going to require some 

18 work. But clearly not all water-cooled units are 

19 created equal. There’s a very strong difference 

20 between the consumptive use of a once-through or 

21 open loop system, versus a water looped system, 

22 which in an area like a convenience store, or 

23 potentially, a full service restaurant or a hotel, 

24 has beneficial uses for the rejected heat, and we 

25 want to make sure that the standards are very clear 
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1 about this, and not differentiating -- not 

2 discriminating against the potential benefits for 

3 water looped systems. 

4 The second thing that I’ve chatted with a 

5 number of people in some hearings about, and 

6 appreciate the chance to catch up with Mr. Erbs, 

7 with Daryl, on this morning is this sense of the 

8 role of standards in jobs, competitiveness, and 

9 innovation. And to me it is extremely important 

10 that the Department base its analysis of maximum 

11 technology on an international baseline, and not 

12 just common practice in the United States. If our 

13 industry is to be competitive, to be leaders, to 

14 remain competitive, to protect jobs and investment, 

15 we must understand what the state-of-the-art is 

16 internationally. We have seen that this can be a 

17 competitive edge for American industry, but it can’t 

18 if we treat our country as an isolated island in 

19 terms of this analysis. 

20 Finally, the issue that I struggle with 

21 personally and look to be informed on by the 

22 manufacturers, is the interplay between standards 

23 and the ability to market innovative features that 

24 have consumer value, that have energy saving value, 

25 but may or may not be appropriate for standards, per 
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1 se. And this relates to features like adaptive 

2 controls, and for that matter, the much-ballyhooed 

3 smart grid,ci, certain in ice-maker and and many 

4 applications, would be amenable to grid control to 

5 avoid use during particularly intensive peak load 

6 periods. 

7 So that’s the framework for the kinds of 

8 concerns we have. It’s not simply a matter of 

9 greater or lesser stringency, but things that lead 

10 us on the right path. Okay. Thank you. 

11 MR. BROOKMAN: Thank you. Some comments 

12 here? Okay. Then we’re going to go straight to the 

13 regulatory history and rulemaking scope, to Charles 

14 Llenza.

15 REGULATORY HISTORY AND RULEMAKING SCOPE

16 MR. LLENZA: All right. I’m going to 

17 start at a little faster pace. We have a few slides 

18 here under the introduction, and I’ll go through 

19 those. We all know the purpose of the meeting is to 

20 present a procedure on the analytical approach to -- 

21 for our rulemaking here, to provide the forum for 

22 public discussion, and to encourage the interested 

23 parties and the stakeholders to provide us comments 

24 in terms of the regulation. And in addition, this 

25 is to inform the interested parties of all the 
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1 resources -- web resources -- that the Department 

2 has available in terms of the rulemaking for 

3 comments and process and sharing information. 

4 Once again, I just want to emphasize the 

5 boxes here highlight the request for comments the 

6 Department has made. So let me start now with 

7 regulatory history. 

8 EPCA established energy conservation 

9 standards, and that was amended by EPACT 2005, and 

10 in EPACT 2005, it prescribes standards for ice cube 

11 makers with the capacity between 50 pounds and 2,500 

12 pounds per 24 hour period. And provided also -- 

13 prescribed requirements as of January 1, 2010. It 

14 also authorized the Department to issue standards 

15 for these type of automatic commercial ice-maker 

16 machines that are covered under 42 USC 6313

17 (d)(2)(a). In addition, EPCA directed DOE, no later 

18 than January 1, 2015, to issue new standards or to 

19 determine whether to amend applicable standards or 

20 to issue new standards as necessary. 

21 So basically, that’s where we’re at today. 

22 This is the process -- we’re starting the process. 

23 Somebody mentioned the timeframe was a little bit 

24 earlier, and yes, the Department has started this 

25 rulemaking probably a full year ahead of schedule, 
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1 based on the legislation, and in addition to this, 

2 we’re on a two-year, compressed rulemaking schedule. 

3 So we will end up with this, hopefully, with issuing 

4 standards almost two years ahead of the determined 

5 schedule of 2015. Go ahead. 

6 MR. BROOKMAN: We have a comment. Karim. 

7 MR. AMRANE: Karim Armane, AHRI. Charles, 

8 can you elaborate a little bit here as to why DOE 

9 started this rulemaking earlier than usual? 

10 MR. LLENZA: Well, in general -- in 

11 general the Department has taken -- has the 

12 authority to start rulemakings earlier, but has 

13 never really had the opportunity to do so because 

14 we’ve been behind the 8-ball on most of these 

15 rulemakings, because we are under the consent 

16 decree. As the consent decree has now -- the items 

17 under the consent decree are being executed on time, 

18 so the Department has decided to accelerate 

19 rulemakings to pursue other areas for rulemakings. 

20 And if anybody’s been following the activities of 

21 the Department, the Department is accelerating the 

22 length of time to complete this rulemaking. Usually 

23 these rulemakings are three years in the 

24 undertaking, and this particular rulemaking, after 

25 we’ve done a scoping of the work and what is 
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1 involved in terms of the test procedure, we found 

2 that the test procedures were pretty much -- fairly 

3 in good shape to be adopted in a fairly accelerated 

4 manner as a DOE test procedure with some 

5 modifications, of course, and we will go through a 

6 process of doing that. And, in addition, I think 

7 there is some clarity in terms of the actual 

8 equipment. 

9 So I guess this is one of the first 

10 rulemakings that will go through an accelerated 

11 process, and in addition, based on the available 

12 resources to the Department, the Department has 

13 decided at this point in time to start the 

14 rulemaking a bit earlier than the schedule would 

15 require to complete. So that’s all I have. I mean 

16 it’s a decision at the policy level from the the 

17 front office. 

18 Okay, so back to the regulatory history. 

19 Is there any other questions by the way? Okay. 

20 We’ll go through this as we go -- I’ve laid out the 

21 schedule. I’m pretty confident that we can meet the 

22 schedule. Since we’re ahead of schedule, also, we 

23 don’t necessarily have the pressure of the deadline, 

24 because the deadline is 2015, and according to our 

25 schedule we will complete that ahead of time. So we 
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1 will have a little bit more flexibility, but at the 

2 same time, we have a firm commitment to see if we 

3 can meet the two-year schedule as opposed to the 

4 three-year schedule for this rulemaking. 

5 Okay. So let me get back to the 

6 regulatory history on this. As part of the “en 

7 masse” test procedure that the Department adopted, 

8 the test procedure for this particular equipment 

9 were adopted, and that was ARI Standard 810-2003, as 

10 the test procedure to be used on this equipment. In 

11 addition, this references ASHRAE Standard 29-1988 

12 (RA 2005) as a method of test. We understand that 

13 there is an updated AHRI test procedure, which is 

14 810-2007, and the ASHRAE standard also has been 

15 updated to 29-2009. 

16 So this is basically the basic scoping of 

17 what we have to do, which is to update the test 

18 procedure for the Department to include the most 

19 current test procedures for the two mentioned here 

20 in this slide. 

21 Okay. I’m going to go into the scope --

22 scoping area of the regulation. The regulatory 

23 definition as per EPACT, states that the equipment 

24 is factory-assembled, not necessarily shipped in one 

25 package, 
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1 A. Consists of condensing unit and ice making 

2 section operating as an integrated unit, 

3 which means for making and harvesting ice, 

4 and

5 B. May include means of storing ice, 

6 dispensing ice, and/or storing and 

7 dispensing ice.

8 Next slide, we’ve included a list of definitions 

9 here. Now these are not statutory definitions. 

10 These are definitions that we’re going to use 

11 throughout the presentation, and we thought we’d 

12 provide this slide for clarity in terms of what 

13 we’re talking about as we go through the 

14 presentation. Next slide is in the scope, these are 

15 the prescribed standards for January 1, 2010 that 

16 EPACT provided that are now in force, and this is 

17 applicable to cube machines only. 

18 As you can see, new equipment produced as 

19 of the effective date of January 1, 2010 have to 

20 meet these standards. 

21 Key issues. I think we’re trying here to 

22 cover -- to decide on what ice products -- block, 

23 flake, nugget, cracked. DOE is considering to issue 

24 a new standard for continuous flake, and nuggets, 

25 and tube machines with capacities between 50 and 
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1 4,000 pounds per 24 hour period. 

2 Okay. You probably note here that there’s 

3 a difference in terms of what the Department was 

4 asked to do with the limit of the 2,500 pound 

5 machines, but the test procedure and the Department 

6 decided that we should look into the additional 

7 1,500 pound increment because the test procedure 

8 covers up to 4,000 pounds, so without much effort, 

9 we could include that type of equipment, and it’s 

10 certainly within the prerogative of the Department 

11 that we could go further than what we were mandated 

12 to do. So this is the area we’ll be exploring.

13 Also, in terms of coverage, we’re looking 

14 into size, defined by the 24-hour harvest rate. So, 

15 again, we’re looking at machines up to capacity of 

16 4,000 pounds per 24-hour period. 

17 Another issue will be the test procedures. 

18 So we’ve adopted, in the DOE test procedure, the en 

19 masse in 2008 -- I mean 2006 -- and there are 

20 updates to that test procedure so we want to bring 

21 that to be current under the current rulemaking. 

22 And we also want to explore the part of 

23 water use of the ice making equipment, and also 

24 there are some concerns about the standby and off25 mode energy use. I also heard that somebody 
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1 mentioned controls, automated controls, and probably 

2 that’s one of the areas that we’ll probably be 

3 looking at to some level of detail as options. 

4 So, here’s our first additional comment or 

5 question box. A, DOE welcomes the identification of 

6 any additional key scoping issues not identified 

7 here or within the framework document. 

8 MR. BROOKMAN: So quite a bit of content 

9 there in that segment. And I can clearly -- I think 

10 it’s useful the Department supplied these 

11 definitions although they said it’s not statutory, 

12 and then other issues related to scope. 

13 MR. LLENZA: One thing that I do have 

14 also, and I just made a note of that is that Harvey 

15 had mentioned the issue of international standards. 

16 The Department now has started a process of actually 

17 talking to the European Union on international 

18 standards. I won’t use the word harmonization, 

19 because that’s not necessarily what we’re doing, but 

20 we are starting to have conversations with the 

21 appropriate project managers in Europe for this 

22 equipment. I happen to have talked to the walk-in 

23 cooler/freezer counterparts yesterday in a 

24 teleconference call, so we are starting to talk to 

25 them about this. This is fairly new for the 
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1 Department at this point in time. We surely don’t 

2 want to delay our rulemakings based on this, but I 

3 think there is going to be a learning curve as to 

4 what information we can share, and as a project 

5 manager, I would see, as Harvey indicated, that some 

6 of the international issues might be beneficial to 

7 the US industry also to understand. 

8 So as part of this rulemaking, we will 

9 probably be contacting European counterparts on some 

10 of the technical issues and maybe some of the test 

11 procedure issues as we develop them through this 

12 rulemaking. 

13 MR. BROOKMAN: Yes, Daryl. 

14 MR. ERBS: I just want to echo a comment 

15 that Harvey made, which I think a key scoping issue 

16 that isn’t here is the differentiation for a water 

17 cooled machine between an open loop and a closed 

18 loop application. So I think we need to add that, 

19 and I’m not sure how we deal with it, but I think 

20 we’re going to take away some important 

21 opportunities for energy savings by treating them 

22 all as open loop. 

23 MR. BROOKMAN: Is that addressed in the 

24 test procedure? 

25 MR. ERBS: I would say that the test 
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1 procedure doesn’t care. The issue is one of, 

2 really, application, and again, that’s where I’m not 

3 quite sure how DOE would propose to handle that, but 

4 it’s real. I think we need to talk about it.

5 MR. BROOKMAN: Karim. 

6 MR. AMRANE: Karim Amrane, AHRI. I guess 

7 following on the comment that Charles made about 

8 international standards, I’d like to caution DOE as 

9 well, because on the -- when exploring those 

10 standards, make sure that -- making sure that this 

11 is not going to negatively impact the US industry. 

12 And at the same time that you’re looking for --

13 you’re looking to international standards, or 

14 European standards, the Europeans are not looking at 

15 the US standards. So if you are looking at them, we 

16 would like it to be reciprocal in a way, so it’s not 

17 just a one-way stream here, where we’re looking at 

18 European standards, but Europeans are not looking at 

19 the US standards. So I would like to caution DOE, 

20 when dealing with this kind of issue because it 

21 might have some significant impact on the industry. 

22 MR. BROOKMAN: Harvey Sachs.

23 MR. SACHS: Harvey Sachs. Thank you very 

24 much, Charles, for the comments on the 

25 international. I want to clarify that there are two 
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1 aspects, one which is what we refer to in 

2 parentheses as “harmonization” of standards that are 

3 readily transported. The issue that I raised -- and 

4 that could be potentially very important as a 

5 competitive advantage or as Karim has suggested, a 

6 threat --The issue I raised is slightly different, 

7 which is that in the scoping, in the examination of 

8 max-tech, maximum technology, it is to me, very 

9 important that the contractors be instructed to look 

10 internationally, not just Europe, but also Asian, at 

11 the leading edge of automatic ice making 

12 technologies globally, whether or not the standards 

13 wind up being globally harmonized. The standard of 

14 design and manufacture is important to be revealed 

15 as part of this process. Thank you. 

16 MR. BROOKMAN: Thank you. 

17 MR. LLENZA: And I want to make a 

18 clarifying statement. This is Charles Llenza, 

19 Department of Energy. We’re well aware that we 

20 don’t want to impact US industry in any negative way 

21 in terms of when we have these conversations with 

22 the Europeans. I think the benefit would be, is we 

23 have several contacts, not only in Europe but in 

24 Asia, that we have been talking to, and part of the 

25 dialogue would be also to explore what available 
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1 methods and test procedures, information that’s 

2 available that the Department could benefit to 

3 assist US industry in understanding not only the 

4 international markets a little better, but also in 

5 terms of improving our equipment here in the United 

6 States. So that’s part of what we’re looking at. 

7 And so, you know, we take the caution seriously that 

8 you have mentioned. 

9 MR. BROOKMAN: Other issues that 

10 individuals wish to raise? The Department has 

11 listed several key issues here on slide 14. Okay. 

12 RULEMAKING OVERVIEW

13 MR. LLENZA: So I’m going to move on now 

14 to the rulemaking overview and framework. The 

15 Department uses as a guide the EPCA seven factors, 

16 and basically the rulemaking will be following these 

17 seven factors that we have them showed on this slide 

18 -- economic impacts, consumers and manufacturers, 

19 lifetime operating costs, savings compared to 

20 increased cost of equipment, total project energy 

21 savings, the impact on the utility performance, 

22 impact on lessening up competition, need for 

23 national energy conservation standards, and other 

24 factors as the Secretary considers relevant. 

25 Just a reminder that this is a guideline. 
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1 We don’t necessarily have to pursue anything 

2 specific, but we will explore these areas as we go 

3 through the rulemaking in the next two years. 

4 The process as identified for these seven 

5 factors: we will have -- we have a framework 

6 document for the framework period, and that’s what 

7 we’re doing today, and that’s why we’re here today. 

8 The standard will then continue to a preliminary 

9 analysis stage where the Department will present the 

10 data information, the preliminary -- all the scoping 

11 documents et cetera, and that will be available on 

12 the web as things come on line. 

13 From the preliminary analysis we’ll go 

14 into a Notice of Proposed Rulemaking stage, and then 

15 at some point, a final rule. 

16 As you know, we published in the Federal 

Register the framework document, November 19th 17 . And 

18 today’s public meeting covers this framework. In 

19 addition today’s framework provides the overview for 

20 the rulemaking and I just want to remind everybody 

21 that we have a comment period open until January 18, 

22 2011. Anything that’s not said today, you will have 

23 plenty of time to make comment, written comment, or 

24 as e-mailing us comments and that -- those comments 

25 will become part of the public record. 
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1 Here’s the website that we are using, 

2 where all the material will be available. 

3 I put together a timeline in terms of the 

4 two year process that we’re going to go through. To 

5 explain this briefly, we will have a -- we have a 

6 two year timeline to complete the standard. Within 

7 the standard we are in the process of updating the 

8 test procedures through a parallel and conjunctive 

9 rulemaking for the test procedure. So today is the 

10 framework document. You see the chevrons on this 

11 timeline. You’ll notice the little triangle and 

12 today we’re talking framework that was published on 

November 19th 13 .

14 The boxes on the bottom will be, if you 

15 notice, we have four comment periods, four meetings. 

16 Today’s meeting is the framework meeting for the 

17 public documents and other information that the 

18 Department has provided. We will then have TP NOPR 

19 public meeting sometime in the spring 2011. As we 

20 develop the preliminary analysis and that becomes 

21 available, that’s planned for September 2011. And 

22 then we will have standards NOPR public meeting 

23 sometime in May 2012. These dates are somewhat 

24 flexible, but in order for us to plan, these are 

25 kind of our target timeframes. 
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1 In addition, what you’ll see on the top is 

2 the different documents that will be published over 

3 the time, and as you see, we estimate that -- just 

4 to mention here -- the test procedure final rule 

5 will be -- we’ve looked at trying to get that 

6 published on or before the standards NOPR timeframe. 

7 So everything looks pretty good on this 

8 schedule. We welcome comments to the schedule, of 

9 course, since this is something new the Department 

10 is doing in terms of compressed timelines for this 

11 rulemaking. 

12 And as you can see, the estimated final 

13 rule compliance date will be January 2015. Okay. I 

14 think that’s completed my segment of the 

15 presentation. If we’re good here, Michelle Britt, 

16 my colleague will take over the presentation. 

17 MARKET AND TECHNOLOGY ASSESSMENT 

18 MARKET ASSESSMENT 

19

20 MS. BRITT: Michelle Britt, Pacific 

21 Northwest National Laboratory. This morning I’m 

22 going to be first of all talk about market and 

23 technology assessment analysis. The purpose of 

24 market and technology analysis is to thoroughly 

25 characterize and understand both the market and the 
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1 industry as a whole, not only the baseline but some 

2 of, perhaps, the unique features of manufacturers or 

3 their markets, and to also identify the potential 

4 technological measures that could be applied to 

5 increase energy and water efficiency. 

6 There are four steps really involved here. 

7 First of all, digging into the material and 

8 identifying the potential classes as we understand 

9 the manufacturers. And DOE has some of the same 

10 questions, I believe it was Megan that brought up 

11 the question with regard to how are these classes 

12 broken down. We’ll get into that just a bit more in 

13 a moment. But understanding the shipments and the 

14 trends and how they’re distributed in the market; 

15 identifying both the regulatory and the non16 regulatory programs that might affect efficiency of 

17 the equipment. 

18 So DOE is seeking an-- urging for --

19 information specifically on annual shipments into 

20 the market by, not only by equipment class, but also 

21 by efficiency types, and is there a correlation 

22 between those two? Information on the proportion of 

23 equipment that goes into a resale market, and input 

24 and data on estimates of understanding the market 

25 share, equipment features and efficiency trends in 
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1 the market as a whole. I’ll stop here for just a 

2 moment.

3 MR. BROOKMAN: Okay. So several important 

4 questions there. Karim. 

5 MR. AMRANE: Karim Amrane, AHRI. As far 

6 as the shipment information, I think AHRI can help 

7 you and we will, you know, manufacturers have agreed 

8 to share this information with the government so we 

9 will do that. 

10 MR. BROOKMAN: What about the trends? 

11 MR. AMRANE: We don’t forecast, so at 

12 AHRI, we don’t do that. I don’t know that.

13 MR. BROOKMAN: Okay. Other comments. 

14 Several questions here: resale, efficiency trends, 

15 distribution channels? Daryl. 

16 MR. ERBS: Daryl Erbs. I’m not sure if 

17 we’re going to get into it further later on. I 

18 think the channels identified are correct, but in 

19 the framework document the percentages that go 

20 through the different channels is -- is pretty far 

21 off base, at least on our experience, so I think 

22 that’s something that maybe again, through AHRI 

23 might be the most appropriate way for us to provide 

24 better estimates of how much product goes through 

25 wholesale and then a dealer channel, versus other 
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1 levels of steps. 

2 MR. BROOKMAN: Okay. Thank you. 

3 MR. LLENZA: This is Charles Llenza, 

4 Department of Energy. The Department welcomes the 

5 industry’s input in terms of what they think those 

6 channels should be. 

7 MR. BROOKMAN: Additional comments as you 

8 see in these comment boxes here. Nothing on the 

9 web? For those of you who are joining us via the 

10 web, we will try to entertain your questions if you 

11 have them. 

12 MS. BRITT: Staff’s approach thus far into 

13 digging into some of these issues: we’ve attended 

14 trade shows and spoken with manufacturers and 

15 distributors. We’ve researched through catalogs and 

16 the marketing materials. Researched analysis that’s 

17 been conducted on ice-makers over the last 20 years, 

18 and have evaluated some of the past and current data 

19 resources. We’ve also evaluated the international 

20 standards that we could obtain -- Australia, New 

21 Zealand, and the Canadian standards, to be specific. 

22 So on this table here are some of the 

23 potential classes for commercial ice-makers as we 

24 understand it through the manufacturers’ analysis 

25 thus far. Going back to the adoption or the 
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1 development and adoption of the California standard, 

2 our understanding is that flake and nuggets have 

3 been considered through the development of this 

4 standard. The issue came up with the test procedure 

5 adoption for the initial EPACT 2005 standard for 

6 ice-makers, specifically, some of the manufacturers 

7 at that point pointed out that the standard could 

8 and should be extended to the flake and nugget 

9 machines, and at that point DOE said that in the 

10 next evaluation of the standard that they would 

11 consider such. 

12 There are questions about the harvest 

13 rates. Here we have the harvest rates breakdowns as 

14 they apply to the cube type batch machines. If the 

15 standard was extended to include the continuous 

16 flake and nugget machines, do those same harvest 

17 rate breakdowns apply, or would there be different -

18 - appropriate different harvest rate breakdowns? 

19 And in understanding some of the 

20 manufacturers’ information, are the classes broken 

21 down most appropriately by type of ice produced, or 

22 by the technology of the equipment that produces 

23 that ice? That particularly becomes a question when 

24 we’re looking at some of the tube machines, even in 

25 the smaller capacities, and is the critical feature 
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1 there the output of the ice or the technology? And 

2 so we have questions with regard to tube machines, 

3 and would they be in their own class, or would they 

4 be along with the cube in the batch equipment? 

5 And then finally, a question that we have 

6 on this table, is the equipment that is specifically 

7 designed to be attached to a remote rack system, 

8 should it be in a separate class. We’ll get to it a 

9 little bit more with the test procedure issues, but 

10 in terms of looking at these classes and assessing 

11 the market, that’s one of the questions that we have 

12 at this point. 

13 MR. BROOKMAN: John. 

14 MR. BROADBENT: This is John Broadbent, 

15 Scotsman Industries. I’d like to address some of 

16 the points you made. First of all, with respect to 

17 the harvest rates shown in the previous slide. 

18 Those breakdowns are a function of -- so for 

19 example, on that one that says ice making had water 

20 less than 500 one category, and then 500 to 1,436, 

21 and then above 1,436. Those numbers, so the 500 and 

22 the 1,436, result from trying to curve-fit the data. 

23 In other words, there was a plot of energy 

24 efficiency versus capacity, and when you draw 

25 straight lines through that data, you can’t do it 
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1 with one straight line. So if you have two straight 

2 lines, for example, where those lines cross would be 

3 one of those numbers. In the case of water, there’s 

4 three lines, and those two numbers where the three 

5 lines each cross each other. So it really doesn’t 

6 reflect the market, and it doesn’t apply to other 

7 types of machines. So you can use it for -- and 

8 that also only applied to data at that time. 

9 Doesn’t necessarily apply to data today. So, if you 

10 were to plot cubes today, you’d get a different 

11 number, and possibly you would not get three break 

12 points, you might get two, you might get five. 

13 Depends on how you want to do the math, if you want 

14 to do it that way. And then likewise, flake and 

15 nugget would be also completely different. 

16 MS. BRITT: Okay. 

17 MR. BROADBENT: And then I wanted to talk 

18 about -- you were correct with regard to the CEC 

19 when they talked about flake and nugget machines. 

20 At that point in time, there was not data from AHRI 

21 or ARI at the time, that characterized the 

22 efficiencies of flake and nugget machines, and so 

23 they couldn’t really include it. But everyone

24 understood at that time that they were significantly 

25 more efficient than cube type ice machines. 
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1 You also mentioned tube type ice machines, 

2 and those are essentially -- they’re very much like 

3 a cube ice-maker. They operate in a batch mode 

4 where you freeze and then harvest, as opposed to a 

5 continuous mode, like flake and nugget machines. 

6 And then with respect -- so my point there is that 

7 tubes really ought to be -- tube ice really ought to 

8 be considered cube ice. 

9 And then the final thing you mentioned 

10 rack systems. The issue there is that the 

11 manufacturers don’t know when they make the ice 

12 making part of it, what kind of rack it’s going to 

13 be attached to. And so we really can’t do the test. 

14 And it’s an application question, not a 

15 manufacturing question. 

16 MS. BRITT: Great. 

17 MR. BROOKMAN: So I think you’re new to 

18 these machines, correct? 

19 MR. BROADBENT: Yes. It’s very helpful if 

20 you can tell the Department how they would fix these 

21 things. For example, as you referred to the water 

22 and the different harvest capacity rates, so for 

23 example, on the harvest rate breakdown, we’ll 

24 probably go through the same process that was done 

25 before where you plot the machines you want to 
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1 regulate, capacities across the bottom, energy 

2 efficiency on the vertical axis, and then I know 

3 what the CEC did was draw a line such that at that 

4 point in time, they were looking to split it where 

5 only 20 percent of the machines would pass, and so 

6 you would draw a line, if that’s your criteria, you 

7 would draw a line so that 20 percent of the machines 

8 are below the line, 80 percent are above, for 

9 example. 

10 There is a challenge in doing that, if you 

11 lump everything together and draw the lines, you’ll 

12 exclude certain categories. So for example, if you 

13 had flake and nugget machines, and cube ice machines 

14 all in the same graph and you drew the line, you’d 

15 have flake and nugget machines all passing, and cube 

16 machines all failing. 

17 MR. BROOKMAN: Just to be more specific, 

18 can you say how the Department should differentiate 

19 or align these classes in this example? I’m coming 

20 to you next. 

21 MR. BROADBENT: From Scotsman’s

22 perspective, the way you have it broken down now, 

23 you know, with ice making heads, air or water 

24 cooled, remote condensing, the self-contained -- 

25 that is actually a pretty good breakdown. I would 
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1 warn against putting cube and batch-type ice 

2 machines and continuous type ice machines, in other 

3 words, flake and nugget machines, together in the 

4 same category because what will happen is, as I 

5 said, all the continuous machines will have a very 

6 good efficiency, and all the cube machines, which is 

7 the majority of the sales in the industry, they’ll 

8 all fail. 

9 MR. BROOKMAN: I don’t want to press you 

10 to be any more specific than you want to be, 

11 however, as you look at these capacity rates that 

12 are shown there -- 

13 MR. BROADBENT: Yes. 

14 MR. BROOKMAN: -- how would you recommend 

15 that that be split? 

16 MR. BROADBENT: That’s a result of doing 

17 the math, so there’s no way I could tell you until I 

18 see it.

19 MR. BROOKMAN: Please -- go ahead.

20 MS. WIDDER: Sorry, Doug. I think -- 

21 MR. BROOKMAN: Say your name. 

22 MS. WIDDER: I’m Sarah Widder from Pacific 

23 Northwest National Laboratory. To follow up, it’s 

24 very helpful to know how these harvest rate 

25 breakdowns were created initially, and so thank you 
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1 very much for that information. And I think that’s 

2 something the Department definitely should do is try 

3 to recreate these lines based on current technology 

4 for proposed classes which I’d just like to clarify, 

5 the Department is considering separating cube and at 

6 least continuous-type ice-makers into separate 

7 product categories, and perhaps separating that 

8 further, based on tube type or flake versus nugget, 

9 depending on feedback that we get from the 

10 manufacturers. 

11 But in setting those lines, setting the 

12 standards, it would be very, very helpful to the 

13 Department to have any data that manufacturers have 

14 for cube type or continuous type ice-makers that we 

15 could populate those lines. It’s going to be 

16 difficult for us to draw those lines without data. 

17 MR. BROOKMAN: Karim, please, I want to 

18 make sure I -- 

19 MR. AMRANE: Actually we would support 

20 separating, you know, continuous machine from ice 

21 cube machines. Regarding the data, the way it was 

22 done, it was on really looking purely at what’s 

23 available in the AHRI directory and then drawing 

24 those lines which shouldn’t be the way it should be 

25 done, okay. We need to look at shipments as well, 
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1 because it’s nothing to see there is one product 

2 here in the category, but only one shipment, not a 

3 hundred thousand shipped. So I think what you’re 

4 going to get from us is going to be probably 

5 shipping weight and data so at least you will have a 

6 better idea of how to draw the lines. 

7 MR. BROOKMAN: That’s helpful.

8 MS. WIDDER: Thank you very much. 

9 MR. BROOKMAN: Yes, thank you. Harvey 

10 Sachs.

11 MR. SACHS: Harvey Sachs. And I guess this 

12 is very, very interesting to me, but I think the 

13 classification, the basic taxonomy to the extent 

14 possible, should be based on the customer’s 

15 perspective, and by metaphor, there’s only a limited 

16 substitute-ability for customer looking for a side17 by-side refrigerator versus a top freezer 

18 refrigerator. So taking a customer perspective for 

19 the taxonomy, the classification, would seem to be 

20 the first point. 

21 The second one, which bleeds into that, is 

22 the batch versus continuous, which is a technology 

23 base, and that is highly relevant, but it’s 

24 particularly relevant to the extent that its 

25 nonsubstitutability. If the continuous ice is 
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1 inherent a cloudy ice that’s not going to be used 

2 with single malt scotch, that’s an important 

3 parameter to me. If on the other hand, both of them 

4 are used in some sort of quasi-industrial 

5 application where there’s substitutability, then I 

6 get very concerned about separating out a less 

7 efficient from a more efficient one. So I’m hoping 

8 -- and I guess this is addressed to you, Charles, 

9 that the Department will be very, very sensitive to 

10 how the customer looks at the product. 

11 MR. BROOKMAN: Charles Llenza. 

12 MR. LLENZA: I’m Charles Llenza, 

13 Department of Energy. That’s why it’s very 

14 important that the stakeholders at this point look 

15 at what we’ve assumed things to look like, and 

16 actually make strong comments as to what it should 

17 be, based on what Harvey has just mentioned. And 

18 because we’re starting now, it’s harder to change it 

19 down the line if we don’t get it right at the 

20 beginning. 

21 MR. BROOKMAN: And that’s why all of us 

22 are continuing to focus in on these proposed classes 

23 for those of you for whom this is very important. 

24 Daryl.

25 MR. ERBS: Hi, Daryl Erbs. So I’ll start 
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1 with the response to Harvey’s question or point, 

2 which is although you do see some crossover, I would 

3 argue that continuous type ice and cube ice type are 

4 not direct substitutes. They’re alternates. They 

5 have very different characteristics that leads to 

6 very different underlying technology and processes 

7 to produce it. And so I think it would be very 

8 difficult and I think hard to defend, to lump them 

9 together. So I think from my perspective, clearly 

10 they need to be separated. 

11 On tube ice, it’s batch ice, so I would 

12 agree that it really falls into the same general 

13 category as any other cube ice, but I do want to 

14 caution lumping it together because the different 

15 machines in the industry have really come out of 

16 different applications and so if you look at tube 

17 ice as a category, although it crosses over now into 

18 the same size ranges that we have for other batch 

19 cube machines, it still largely came out of ice 

20 plants, so very large end users. If you look at the 

21 physical size of the equipment, it typically is 

22 fairly large. For a lot of our applications, even 

23 in the larger capacity, in fact as you get into the 

24 larger capacity, the size of an ice making cap 

25 really matters a lot. We have very limited space 
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1 available in a restaurant, in a hotel, in a casino, 

2 the places where we put ice machines. Typically, 

3 there’s a very strong premium on space. And so the 

4 efficiency and also the cost of a machine is going 

5 to directly relate to how much space you occupy, how 

6 much material you use. 

7 So my argument would be that the standards 

8 we have can handle the testing of tube ice type ice 

9 machine, but just as we’ve broken out into different 

10 classification of different formats, my suggestion 

11 would be that you would look at that one as 

12 potentially another format that falls within batch, 

13 but still gets treated separately because of the 

14 range of sizes that that technology has been based 

15 on, and the size and really cost of those machines 

16 being somewhat different from some of the other 

17 batch type ice machines. So I think that’s an 

18 important point. 

19 And Harvey, I’m not done, but I’m sure 

20 they’ll give you some time. On the rack system -- I 

21 mean, this is a bit like what happened with the 

22 standards for display cases, and so there is a 

23 precedent there, but I would be concerned about the 

24 amount of effort it would take the industry to come 

25 up with -- because we would need totally different 
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1 rating and test procedure to handle that. 

2 The ice making heads that get applied to 

3 rack systems are typically a derivative of the ice 

4 making heads that would go with some type of a 

5 remote. The volume is not sufficient, that I’m 

6 aware of at least from my experience, to drive a 

7 completely different design for a rack system. And 

8 so I’m not sure that it would be worth the effort to 

9 try to regulate that separately, given all the 

10 effort it would take. That’s something you’ll have 

11 to do the analysis on. 

12 But I think if we regulate all these other 

13 classes, you’ve effectively driven the technology to 

14 a point that whatever is on a rack system is going 

15 to be at that same level of efficiency as an ice 

16 making head. Most of the energy consumption is in 

17 the condensing units, so really I don’t think we’re 

18 going to achieve a whole lot by bringing that new 

19 class into the regulatory sphere. 

20 MR. BROOKMAN: Okay. Sarah, you want -- 

21 MS. WIDDER: Sure. Thanks, Daryl, and 

22 I’ll ask you more questions about testing of remote 

23 rack systems later. But right now I just wanted to 

24 clarify. You were talking about the difference 

25 between cube and tube type ice machines, and the 
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1 need to separate, and this is actually for all of 

2 the stakeholders. I understand the difference in 

3 application based on space and a number of things 

4 you mentioned, but is there also a difference in ice 

5 quality or the type of ice produced from a consumer 

6 perspective, or as Harvey mentioned, to put in 

7 scotch. Would you put tube type ice in scotch, or 

8 is there a difference there? 

9 MR. ERBS: Well, I would -- 

10 MS. WIDDER: I’m asking.

11 PARTICIPANT: Any port in a storm. 

12 MR. ERBS: I personally would never put 

13 tube type ice in scotch because we don’t make tube 

14 type ice machines. We have certain corporate 

15 standards that we’re --

16 MR. BROOKMAN: I just want to note that 

17 this is why people are so attached to testing 

18 procedures. Go ahead, I’m sorry.

19 MR. ERBS: And I don’t feel qualified to 

20 really speak to the possibilities in terms of 

21 quality. Tube type -- they are batch machines. 

22 They do purge water, right, so they have a lot of 

23 the same operational mechanisms, so I don’t think 

24 that -- and I think we should be careful not to say 

25 anything, particularly in these proceedings that 
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1 would say well, this is a different kind of ice 

2 because -- it has some different characteristics 

3 from a shape standpoint, because you make a long 

4 tube of ice and then you break it up into chunks, so 

5 it’s maybe a little different in terms of form -- we 

6 all make different shapes of cubes, and customers 

7 have their own preferences, and we let customers 

8 decide which shape of cube they want to buy. So I 

9 wouldn’t use that as a basis. 

10 I think it’s more around the format of the 

11 machine which is based on the market segment it’s 

12 been applied to. So if you’re putting it into -- if 

13 it only goes into a back room, or into a big 

14 warehouse that you’re filling full of ice, you’re 

15 not concerned about size. If you’re trying to serve 

16 a lot of different markets, you’re going to be 

17 driven by the highest volume typical size 

18 requirement. So that’s why I’m saying they’ve come 

19 out of different needs. The designs have evolved to 

20 best suit those needs, and so I think that provides 

21 a basis for differentiating them. 

22 MS. WIDDER: Thank you very much. 

23 MR. BROOKMAN: Harvey Sachs.

24 MR. SACHS: Harvey Sachs. Humorously, I 

25 have to correct myself. I do not put any ice in 
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1 scotch. Rum, yes, but scotch, no. 

2 MR. BROOKMAN: I’m glad we got that on the 

3 record.

4 MR. SACHS: Yes. In a much more serious 

5 vein, as Karim has heard me whine for the last 

6 decade, I believe it is inappropriate to have 

7 technology-based standards, and this whine has been 

8 particularly intensive in terms of different 

9 efficiency levels for screw-type and centrifugal 

10 chillers of the same capacity for that application. 

11 In the same sense, though, I’ve never 

12 objected to different efficiency standards for 

13 different output capacities, for different abilities 

14 to do work. So, I’m comfortable with batch versus 

15 continuous classes. They seem to serve different 

16 functions in the market. I would be a skeptic about 

17 the difference between two batch processes, two 

18 batch machine types, tube versus cube, unless I’m 

19 shown that there is some difference, unless it’s 

20 capacity-based, because I think it’s going to be 

21 hard to demonstrate that they’re not both 

22 predominantly used in health care and hospitality. 

23 Is that clear? 

24 MR. BROOKMAN: Yes, thank you. So I think 

25 this last discussion was very good, and I’m eager 
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1 for us to move on, unless there was additional 

2 things to be raised right here. Joanna. 

3 MS. MAUER: Joanna Mauer. Just a couple 

4 of questions. Are combination soda/ice machines 

5 captured in these product classes at all? 

6 MS. BRITT: They are captured in the 

7 product classes, and it depends, though, sometimes 

8 soda ice machines actually have the ice made 

9 separately and then integrated, and then sometimes 

10 they are a unified machine, but it’s actually often 

11 separate chiller systems. So there’s separate 

12 equipment in one box, but yes, they are covered 

13 within that. 

14 MS. MAUER: And so they would be 

15 classified based on the type of ice they produce? 

16 MS. BRITT: Yes. 

17 MS. MAUER: And the same go for chipped or 

18 crushed ice? 

19 MS. BRITT: That goes back to are we 

20 classifying by technology or are we classifying by 

21 output of the type or shape of ice, if you will. 

22 And if we are classifying by technology, then 

23 crushed and cracked? You said cracked? 

24 MS. MAUER: Chipped. 

25 MS. BRITT: Chipped -- no, in talking to 
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1 different manufacturers there seems to be different 

2 ways to make chipped ice. Are we making a plate of 

3 ice and then dropping it by gravity and it shatters 

4 and we have small pieces of ice? I’ve heard chipped 

5 and cracked -- chipped as in chipped off of a block, 

6 chipped as a variation of crushed. So I don’t know 

7 if that’s as much of a technical term as it is a 

8 marketing term, and I’m sure that I will be 

9 corrected if we’ve got that wrong. 

10 MS. MAUER: So I’m not sure if I’m asking 

11 here -- I don’t know that chipped is a stan -- 

12 chipped is not a -- 

13 MR. BROOKMAN: And I would note that DOE’s 

14 definitions on page 12, you did not list chipped 

15 there. So maybe it’s open to some interpretation.

16 MS. BRITT: May I follow up? 

17 MR. BROOKMAN: Please do. 

18 MS. BRITT: Okay. I just want to clarify 

19 -- my understanding then is that if we had a 3,000 

20 or 4,000 pound -- two machines and they were both 

21 batch, and one used tube technology, and one used 

22 Manitowoc’s traditional technology, then I believe, 

23 if I understand correctly, Harvey Sachs is saying he 

24 sees them in the same category, and I understand Mr. 

25 Erbs is saying no, they would be in separate 
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1 categories -- or classes, excuse me. 

2 MR. BROOKMAN: Daryl first. 

3 MR. ERBS: Okay. So let me try again, 

4 because there’s some validity to that. Just as you 

5 see on those charts, when people did the plots they 

6 found that as size changed, efficiency changed 

7 because you moved into different technology bases, 

8 whether it be compression or other. If you look at 

9 tube machines, I think they go down to as small as 

10 2,000 pounds, you know, they go up to tens of 

11 thousands of pounds, and so you look at maybe if we 

12 do the plotting, then that’ll help us decide to how 

13 to make that break. 

14 But it’s also, I think, you have to 

15 understand the dynamics of the applications. You 

16 can choose to put them all in the same category, but 

17 that could be very harmful to the industry if you do 

18 that. So while you may have a valid argument from a 

19 scientific basis that there’s no good reason to 

20 separate them because a batch machine is a batch 

21 machine, and all technology should compete on an 

22 equal basis. If they fundamentally change the size 

23 of the machine or some other characteristic of the 

24 machine, that may make it unattractive to a certain 

25 class of end users, and so I’m concerned, without 
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1 understanding it more clearly, that we may do harm 

2 to the industry. I think there’s an example of some 

3 other rulemaking which may cause people to buy too 

4 smaller devices instead of one larger device, 

5 because of first cost. And we could do the same 

6 thing on ice machines, if we make it unattractive to 

7 buy a 3,000 pound machine with one type of 

8 technology that would fit in their application, they 

9 might go buy two 1,500 pound machines, which would 

10 be less efficient. 

11 And so I think, Harvey, in the end, we’d 

12 agree that what we want to do is drive the applied 

13 efficiency. And so let’s just make sure we 

14 understand how we might affect market dynamics by 

15 forcing efficiency levels to different points. 

16 MR. LLENZA: Charles Llenza, Department of 

17 Energy. That’s the water -- the water heating 

18 products, yeah. Well, it’s okay, but it’s to 

19 understand the technology is probably, in light of 

20 your comment, would be understandable. 

21 MR. BROOKMAN: Jeff, do you want to 

22 comment here? 

23 MR. BIEL: I was just going to comment a 

24 little bit on the chipped and crushed and nugget, 

25 flaked.
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1 MR. BROOKMAN: Well, let’s let Harvey 

2 follow on to Daryl’s comment.

3 MR. SACHS: Thank you. Harvey Sachs. As 

4 always, thank you, Daryl. I guess if I were to 

5 rewind the tape and then start over, I would try to 

6 say that my presumption is that capacity and 

7 differentiation of the end product are good ways to 

8 begin the process. I think its incumbent upon the 

9 industry to establish that there are other things, 

10 and what you’ve mentioned has sounded like space 

11 constrained which came up in residential air 

12 conditioners. And I think all of us are very much 

13 open to that. We’re not trying to do harm. 

14 And it’s just conceptually trying to 

15 express where I start from that it just bugs me, 

16 personally, to see a different standard for a 200 

17 ton screw than a 200 ton centrifugal. They are 

18 serving the same need, so I think it would be 

19 helpful to all of us if a tube and a cube of 400 

20 pounds a day are doing the same job, but how do 

21 their markets differ? How do their user needs 

22 differ that will warrant separate classification in 

23 the standards process?

24 MR. BROOKMAN: Okay, Jeff. 

25 MR. BIEL: Yeah, just to clarify a little 
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1 bit about chipped and flaked and nugget and 

2 everything. Compressed ice is kind of the generic 

3 term for the ice that we’re talking about, the 

4 small, little pieces of ice that you can chew on. 

5 Some manufacturers call it nugget, some call it 

6 chewblet, chunklet, cubelet, but kind of the basic 

7 process. When you get into chipped, then you’re 

8 talking about some different devices than can be 

9 used that are separate that are actually crushing a 

10 cube that’s already produced, so there’s some 

11 different technologies out there to create these 

12 different ice forms. So not everyone calls their 

13 compressed ice, nugget ice, some is very specific to 

14 particular manufacturers. 

15 MR. BROOKMAN: Okay. Other -- Yes, 

16 Joanna.

17 MS. MAUER: Joanna Mauer. Thank you for 

18 that clarification. I just encourage DOE, in coming 

19 up with definitions for the product classes, to just 

20 make sure that all of these types of ice-makers are 

21 covered somehow, regardless of how you -- what the 

22 term is for the classification, just that the 

23 definition is broad enough that regardless of how 

24 manufacturers refer to these types of machines that 

25 they’re covered.
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1 MR. BROOKMAN: Good. Thank you. Okay. 

2 MS. BRITT: The final market assessment 

3 issue that we’ve been looking at is taking a look at 

4 the harvest rate capacities, and initially the test 

5 procedure was only applicable for up to 2,500 

6 pounds, but the new test procedure that is available 

7 for DOE to take a look at goes up to 4,000 pounds. 

8 However, manufacturers are currently using that test 

9 procedure on equipment with harvest rates greater 

10 than 4,000 pounds. 

11 So in assessing that market, we’ve been 

12 trying to evaluate what is the natural, appropriate 

13 threshold for the top of this energy conservation 

14 standard, and where is that not only technology 

15 threshold, but market threshold. And again, here we 

16 look at different technologies with different 

17 capacity thresholds in different markets. You have, 

18 of course, the ones that are focused more in the 100 

19 to 200 pound range harvest capacities. The ones, 

20 more of the market is at 1,000 to 2,000. And then 

21 you have the 2,500 to 5,000 pounds, and you have 

22 very few manufacturers that are really in that four 

23 to 7,000 pound harvest rates. 

24 So again, that’s what we’ll be 

25 considering. Absolutely welcome input on what is 
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1 seen as both a technological natural ceiling for the 

2 harvest rate capacities. Sarah will be addressing 

3 it more in test procedures later, but if there are 

4 test procedure issues, but specifically if they’re 

5 market and technology issues with that ceiling. 

6 MR. LLENZA: This is Charles Llenza, 

7 Department of Energy. I want to make a little 

8 clarification because when we talk definitions, it 

9 depends on what definition we’re talking about.

10 The regulatory definition is basically 

11 what describes ice. And if we go back to slide 11, 

12 you see they don’t get into the complexities of if 

13 it’s tube, flake, nugget, chipped, crushed, whatever 

14 you want to call it. So once it’s in that 

15 definition A or B, it’s ice, and then we’re going to 

16 regulate it. The question is, how do we describe it 

17 in such a way that it has described the utility of 

18 that particular product, of the ice in question. 

19 The equipment and shipments that’s out there, you 

20 figure utility, and then the market utility of that 

21 equipment. 

22 So we have a little, you know, if you look 

23 at the definition very broad, the regulatory 

24 definition on slide 11 is very broad. The trick 

25 here is to make sure as has been said in the meeting 
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1 here that we are not eliminating classes of 

2 equipment because we lump them together, that we 

3 lump them together in the wrong way, that we end up 

4 driving the market to eliminate classes of equipment 

5 just because we’ve classified them individually in

6 the wrong categories based on utility, I think. So 

7 this is kind of important. 

8 Again, the Department would appreciate any 

9 further guidance on this that the industry can 

10 provide. I think it’s really important that we get 

11 this right because the definition itself is so broad 

12 it doesn’t really tell us how to organize this.

13 Now, of course, if you look at the 

14 prescribed requirements, this is all we have, which 

15 is the second category of guidance. And it just 

16 happens to be the way they broke it down at the 

17 time, as has been mentioned here. So that 

18 particular -- this is slide 13, if that particular 

19 information has changed now, based on the industry 

20 and the industry’s moved into different directions, 

21 better efficiency, et cetera, then also we need to 

22 get some better input on slide 13 in terms of the 

23 practicality of using that kind of arrangement for 

24 classifications of equipment, et cetera. So I just 

25 wanted to clarify that. 
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1 MR. BROOKMAN: So going back to this 

2 comment box that we have here in front of us on 25, 

3 I’m scanning down through, and I think some of these 

4 issues have been addressed. Comment D, remote 

5 compressor rack, maybe E, somewhat addressed harvest 

6 rate, but I just want to make sure that we address 

7 these as completely as possible at this point, if at 

8 all, right now. Harvey. 

9 MR. SACHS: Harvey Sachs. Backing up to 

10 slide 24, or actually, really to slide 23, would it 

11 be appropriate to ask AHRI for what their preferred 

12 classification would look like, not with respect to 

13 efficiency levels, but to the classes that reflect 

14 the market for these products? 

15 MR. BROOKMAN: I think you mean in the 

16 future? I thought that we heard that they haven’t 

17 crunched the numbers yet, or gathered them yet. Is 

18 that correct, Karim? Yes? 

19 MR. AMRANE: Well, we will be collecting 

20 data and based on that we’ll probably be able --

21 recommending classifications or to keep those 

22 classifications or to change them. 

23 MR. BROOKMAN: Thank you. That would 

24 certainly be something that earlier would be more 

25 helpful than later. Thank you. 
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1 So I wish to call your attention to the 

2 comment box here on 25, to get as complete coverage 

3 on this as possible. Yes, Karim. 

4 MR. AMRANE: Karim Amrane, AHRI. As far 

5 as the capacity, the 4,000 pounds and above, I think 

6 we believe 4,000 pounds is really the limit between 

7 commercial and industrial. When you get beyond 

8 4,000, you get to industrial application, which we 

9 feel that is outside the scope of this rulemaking in 

10 the first place. So we will support keeping the 

11 scope up to 4,000 pounds.

12 MR. BROOKMAN: Okay. 

13 MS. BRITT: Can I ask for clarification? 

14 MR. BROOKMAN: Please do. 

15 MS. BRITT: Can you expound a little bit 

16 on your definition of industrial, from a marketing 

17 perspective. 

18 MR. AMRANE: I’ll let the manufacturer 

19 explain that better.

20 MR. BROOKMAN: Daryl? 

21 MR. ERBS: Daryl Erbs. I’ll take my shot 

22 at it. I haven’t given it tremendous thought, but I 

23 guess from a perspective, there are industrial uses 

24 of ice, so some of them are very easy to identify. 

25 Pharmaceutical, plastics, bread making all use ice, 
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1 believe it or not for temperature control purposes, 

2 and they would typically be large factories that 

3 would have on site production facilities and they 

4 just use it as a feeding stock item. So it’s a 

5 custom engineered factory and they’re putting some 

6 ice making in, and it’s just a very different world 

7 in terms of how you look at it from an efficiency 

8 and a capital investment standpoint. 

9 Even an industrial plant for ice delivery 

10 systems, again typically would have a very different 

11 business model associated with it, and so how the 

12 ice machine factors into the overall investment and 

13 return on investment, I think, drives different 

14 decision points around efficiency and first cost. 

15 Commercial to me, you know, it’s 

16 restaurants, it’s institutional, it’s -- I mean it 

17 still covers a lot of different segments, but it’s 

18 more closely associated with some type of food 

19 product, whether it be retailing food or service of 

20 food, and maybe a few other related areas. 

21 MR. BROOKMAN: Beverages and the like. 

22 Jeff.

23 MR. BIEL: Jeff Biel. I would pretty much 

24 agree with Daryl’s assessment. It’s really -- 

25 industrial is manufacturing or process-based usage 
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1 where commercial ice, in the realms that we work, is 

2 more geared for the end user, whether it’s food 

3 service, health care, lodging. 

4 MR. BROOKMAN: Michelle, I’m curious. Did 

5 you want them to talk about capacity? 

6 MS. BRITT: Well, that’s where we’ve run 

7 into some of our clarifying issues, where we’re 

8 talking about the capacity machines that are over 

9 2,500 or over 4,000 pounds that are still designated 

10 for food service and lodging, maybe in a large 

11 resort or a larger type facility. We understand the 

12 clear industrial uses, thermal storage and things 

13 like that, but when it’s still for an end user, 

14 still for beverages, still for human consumption, 

15 but it’s a larger machine, then are we looking at 

16 commercial or industrial? That’s been our -- 

17 MR. BROOKMAN: Yeah. Is 4,000 a pretty 

18 clear break point? Yes. 

19 MR. BIEL: Jeff Biel. Yes, I would say 

20 that’s a pretty good break point.

21 MR. BROOKMAN: So some huge casino, they 

22 don’t have industrial scale machines?

23 MR. BIEL: They’ll have large machines, 

24 but you’re going to have them in different areas, so 

25 I mean there’s also an issue of logistics of getting 
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1 ice from one side to another, so you’re going to 

2 have multiple ice stations. 

3 MR. BROOKMAN: Oh, okay. I think I’ve got 

4 that. Yes, please. 

5

6 MR. BROADBENT: John Broadbent. From a 

7 technical standpoint, this is a natural break point. 

8 There is an issue with testing very large ice 

9 machines, and that is the test standard says you 

10 have to supply 90 degree Fahrenheit air within a 

11 very tight tolerance, and if you have a machine 

12 that’s 4,000 pounds or larger, it’s a very -- and 

13 I’m actually not sure where the trouble begins, but 

14 at some point you have a really hard time finding 

15 test facilities that are capable of providing that 

16 amount of air at that temperature. And with this 

17 standard there’s only one way to do it, and so if 

18 you have a really large machine, you may have a real 

19 problem finding some place to test it. 

20 MR. BROOKMAN: Harvey. 

21 MR. SACHS: Harvey Sachs. Think about it 

22 from a public policy perspective, or trying to, it 

23 seems to me that we’ve transitioned to the 

24 industrial class when we get into very low 

25 production volumes of products that are largely 
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1 customized, rather than largely picked off an 

2 auction list. And the situation seems to be, 

3 Michelle, very much analogous to the rather 

4 arbitrary, but useful, line between commercial and 

5 industrial boilers. 

6 And from public policy perspective, even 

7 though there are some of these machines out there, 

8 and those machines will use a lot of energy, there’s 

9 also a sense that the customers buying them have 

10 access to more insight into life cycle costing and 

11 are more likely to be making intelligent decisions, 

12 may not need the Department’s help.

13 MR. BROOKMAN: Okay. Did we cover all 

14 these? Because we’re about to move on.

15 MS. BRITT: I will very quickly touch on 

16 regulatory and non-regulatory initiatives. DOE has 

17 been exploring both of these and taken a look at 

18 Energy Star, FEMP, and the CEE and we’re interested 

19 in any input that you may have on other initiatives, 

20 whether they’re incentivized, voluntary, or 

21 mandatory, that may affect either the end user or 

22 the manufacturer, that may affect market trends, et 

23 cetera.

24 MR. LLENZA: This is Charles Llenza, 

25 Department of Energy. For somehow we had put 
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1 regulatory and non-regulatory, so this slide has a 

2 little mistake, I guess, if you want to call it. So 

3 on the left hand side of the slide is the regulatory 

4 market, which is Energy Star, FEMP, CEE and in the 

5 other box it’s a breakdown of the non-regulatory, 

6 just for clarification. 

7 MS. BRITT: My -- I’m sorry.

8 MR. BROOKMAN: Karim. 

9 MR. AMRANE: No, no. You confused me. 

10 MS. BRITT: May I explain this slide, 

11 Charles? 

12 MR. LLENZA: Sure, go ahead. Sorry. 

13 MS. BRITT: My objective in having the pie 

14 chart here, in my understanding, Energy Star, their 

15 standards apply to ice-makers used in any type of 

16 application in any type of building. The same with 

17 FEMP, although federal. However, CEE, in speaking 

18 with them, we often think of CEE and Energy Star and 

19 FEMP and compare them to the standards as though 

20 they all have the same applications, but CEE is very 

21 focused on their members, focused on the commercial 

22 kitchens, and the utility within the kitchen. 

23 And my purpose in having the pie chart 

24 there, is while the CEE standards and their tiering, 

25 have been very valuable, it doesn’t apply to the 
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1 entire ice markets -- ice-maker market.

2 MR. LLENZA: This is Charles Llenza, 

3 again. I’ve just been told by one of my team 

4 members that we took those two points out because 

5 they were confusing. So now, I’m sorry, I misspoke.

6 MR. BROOKMAN: So then the shares in the 

7 actual pie chart, what do they represent? 

8 MS. BRITT: The shares represent the 

9 approximated actual energy use by automatic ice10 makers within different types of buildings. So you 

11 can see that health care has a very large share; 

12 lodging -- I won’t get into these assumptions, and I 

13 would welcome input on these assumptions. Okay, 

14 these are numbers originally based in 1993, updated 

15 in ’96. So it’s how the ice-maker energy use is 

16 spread across the industry. 

17 The point is, they’re not all used in 

18 kitchens. So we are looking for information and the 

19 insight you have on both regulatory and non20 regulatory incentives that may impact your industry. 

21 Two seconds and I’m on your point.

22 MR. BROOKMAN: And I know that several of 

23 our members from industry are shaking their heads, 

24 for the record. So in this pie chart your data 

25 suggests that health care is 39 percent of the 
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1 commercial ice-maker energy use? 

2 MS. BRITT: This was the -- may I flip 

3 ahead a few slides, and I’ve got -- this is 

4 something I was going to address more in energy use 

5 this afternoon. 

6 Here we go. Going back over the last 20 

7 years of analysis, and looking at ADL -- Arthur 

8 Daniel Little’s original report from 1993, and then 

9 their 1996 report, and of course NCI’s 2009 report, 

10 we’ve been looking through the back trends of the 

11 data that has been available on commercial ice-maker 

12 use. 

13 Originally we had estimates that had been 

14 made by ADL back in 1990 of ice-maker -- ice-makers 

15 per building. And then based on -- of course we 

16 didn’t have CBEC’s I guess in 1990, but based on the 

17 numbers that were available, they extrapolated from 

18 number of ice-makers per building type, per 1,000 

19 square feet of that type of building, across through 

20 efficiencies and utilization factors, and arrived at 

21 that pie chart. 

22 And that pie chart has been living in the 

23 analysis on ice-makers since 1990, and one of the 

24 questions that I was going to ask you when I got to 

25 energy use, is the need to update those assumptions, 
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1 both utilization factor, and duty cycle, those have 

2 changed from the early 1993 report where there’s 

3 some variation across building types, to the latest 

4 information that was confirmed by manufacturers in 

5 2008, or as point five across all building types. 

6 So, we welcome up-to-date input on ice7 makers per building type. We can extrapolate then, 

8 using CBEC’s data and update the pie chart 

9 appropriately. 

10 MR. BROOKMAN: We’re going to get to the 

11 specific parameters here further down in the 

12 presentation, but let’s go back to slide 26. Do you 

13 want to receive comment on this pie chart now or 

14 does that come later? 

15 MS. BRITT: Could we do it later? 

16 MR. BROOKMAN: Okay. That sounds good. 

17 MS. BRITT: Or whatever works best for 

18 you.

19 MR. BROOKMAN: Daryl Erbs, go ahead. 

20 MR. ERBS: One comment. 

21 MR. BROOKMAN: That’s what you’re here 

22 for. Go ahead. 

23 MR. ERBS: Okay. So I won’t comment on 

24 the pie chart until later. My only other comment, 

25 and I don’t know who’s going to manage this, but one 
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1 of the concerns I do have is as we move forward that 

2 we somehow find a way to keep the CEE tiers and 

3 break points aligned with what we do for the 

4 efficiency standards. Because CEE, through their 

5 utility member companies, provide rebates that are 

6 important to us and do drive decisions that we make 

7 on design changes to our ice machines. 

8 And so just as we would like a standard 

9 approach for regulations with Energy Star and DOE 

10 minimum standards, we also don’t want to have double 

11 standards between what CEE is doing and the federal 

12 regulations. 

13 MR. BROOKMAN: How’s it working now?

14 MR. ERBS: Well, they work. John 

15 mentioned doing through California, actually it was 

16 harmonized in that CEE. And the current standards 

17 are the same. Now CEE is proposing a new set of 

18 tiers, and DOE’s starting their rulemaking, so I 

19 don’t know how it’s going to end. I just wanted to 

20 note that the CEE program is important to us and if 

21 there’s some way to keep that aligned, that would be 

22 a really nice thing. 

23 MR. BROOKMAN: Yeah. We heard you there. 

24 MR. LLENZA: This is Charles Llenza, 

25 Department of Energy. Do you have any contacts 
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1 directly in the CEE that we can actually force him 

2 to make comments on this for us? 

3 MR. ERBS: Yeah, Kim Ericson. We could 

4 get you connected with the right person. 

5 MR. LLENZA: That would probably be the 

6 best interest, so we can contact him directly, and 

7 we would like, probably, them to provide direct 

8 input to the Department on the framework process. 

9 MR. BROOKMAN: Karim. 

10 MR. AMRANE: Karim Amrane. Again, they’re 

11 using the same classification because it started 

12 that way. Whether it was right or wrong is a 

13 different issue, but now it’s there, and so -- 

14 MR. BROOKMAN: Yeah, got you. Okay. 

15 MR. LLENZA: One last comment on this 

16 also. Has the industry found that arrangement with 

17 CEE convenient, or obviously this is what I’m 

18 hearing, so I guess the nodding of the heads yes, 

19 really means that we probably should continue that 

20 kind of arrangement in the future, because it’s 

21 benefited everybody. 

22 MR. BROOKMAN: Yes, Harvey Sachs.

23 MR. SACHS: Harvey Sachs. I’ve worked 

24 with CEE since it’s beginning. I will not speak for 

25 them, but I would observe but their time costing is 
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1 substantially shorter than the Department’s. That 

2 they’re set up to be adaptive. They’re not set up 

3 to be deeply analytical. So if DOE works through 

4 the process with input from everyone, changes 

5 classifications, sets efficiency standards, 

6 whatever, that will have a lead time associated with 

7 it. And in my experience, again, not speaking for 

8 them, that lead time has been adequate for them to 

9 use this to use it in keying what their tiers will 

10 be in future years. 

11 MR. BROOKMAN: Thank you. 

12 MR. SACHS: The CEE is the tail, the DOE 

13 is the dog. In the sense of which wags which. 

14 MR. BROOKMAN: Okay. So then, moving on. 

15 MS. BRITT: Yes, I’d like to turn this 

16 over to my colleague, Detlef Westphalen. 

17 MR. BROOKMAN: And for those of you that 

18 are curious, in not too many minutes, ten, fifteen 

19 minutes or so, we’re going to take a break. Are we 

20 doing okay? No questions, nothing’s come in?

21 TECHNOLOGY ASSESSMENT

22 MR. WESTPHALEN: Thank you, Michelle. 

23 Detlef Westphalen, I’m with Navigant Consulting. I 

24 will be talking about the technology assessment, 

25 then later the screening analysis and the 
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1 engineering analysis, and I have like a little cameo 

2 at the end for manufacturer impact analysis. 

3 So moving on to technology assessment, the 

4 potential technologies to include in the analysis, 

5 and you’ll note that the list is longer than it was 

6 in the document. You’ll also note that we’ve taken 

7 some time here to characterize the technologies with 

8 the particular types of equipment, by the type of 

9 ice and also by whether the product is cooled by air 

10 or by water. 

11 One thing, getting back to the tube versus 

12 cube discussion that we had earlier, that I should 

13 note, is that if those two equipment types are in 

14 the same class, then if I look at the data, then I 

15 should add to this list, within the 2,000 to 4,000 

16 pound per day range, tube technology, because that’s 

17 what the intent is for the definition of equipment 

18 class.

19 So, request for comment on the 

20 technologies, what technologies or designs, if any, 

21 should be added or removed from the list. If 

22 certain technologies should be removed from the 

23 list, what equipment classes are affected? And in 

24 commenting on design options, please discuss any 

25 potential impacts on safety, performance, and 
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1 consumer utility. 

2 MR. BROOKMAN: Harvey Sachs.

3 MR. SACHS: Harvey Sachs. I’m naïve about 

4 the technologies used, and only think in terms of 

5 analogies, but one of those is the potential of 

6 adaptive controls to take advantage of learned 

7 periods of relatively low ice making capacity 

8 requirements, and modulate the capacity to take 

9 advantage of the relatively large heat exchanges 

10 that would result. So the two-stage compressor with 

11 appropriate controls, or the modulating compressor, 

12 should not be eliminated from the list of technology 

13 options, even if we’re not seeing it now. 

14 Again, you’re trying to look at what 

15 maxtech is, and actually, I don’t know if it’s there 

16 or not. I don’t know if it’s specifically 

17 applicable to this equipment which is a relatively 

18 low range of ambient conditions. Thank you. 

19 MR. BROOKMAN: Thank you. Daryl. 

20 MR. ERBS: A couple of comments. Our 

21 recommendation would be that you not spend a lot of 

22 time looking at insulation. Not that I could argue 

23 it has absolutely no effect, but I think it’s really 

24 there for other reasons, to prevent sweating, to 

25 maintain some other characteristics of the machine. 
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1 But that one, I mean, you can study it, but it would 

2 be interesting to see how you’re going to take that 

3 into account in terms of your modeling, unless you 

4 have a much more sophisticated model than we do. 

5 There are a couple of design options that 

6 talk about melting during harvest and thermal 

7 cycling of the evaporator, and just my comment on 

8 those is that they seem to be kind of an end, and 

9 unless you understand the means, unless you identify 

10 specific technology that somehow leads to that end, 

11 I’m not sure how you actually do the engineering 

12 analysis around it. 

13 You could of course say, if we reduce the 

14 amount of meltage from ten percent to three percent, 

15 that would improve the energy efficiency. We 

16 understand that. We don’t know how to do it, or at 

17 least we -- I don’t think it’s like in the case of a 

18 condenser or a fan or something, where there’s sort 

19 of a broad class of component that there are general 

20 engineering principles around how you would improve 

21 its efficiency as a component. 

22 So that one, I guess, I would challenge 

23 unless the Department or its contractor can really 

24 identify the specific technology behind it, I’d be 

25 uncomfortable having that included because it could 
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1 drive some technology option decisions that we’re 

2 not sure how to get there. 

3 MR. LLENZA: This is Charles Llenza, 

4 Department of Energy. Does that have -- the 

5 particular issue have anything to do with the 

6 utility of water in any way? In other words, if 

7 water is melting at a faster rate, the cube is 

8 melting or the flake, whatever, if you have 

9 insulation, for example, does that help retain that 

10 particular product that the machine is making, 

11 longer, in the receptacle or the container? I don’t 

12 see -- I could see your point that that would not 

13 necessarily make the equipment more efficient in 

14 producing the cube, but in terms of the retention of 

15 the product in a container, in a vessel, the 

16 insulation might have some effect on that melting of 

17 the ice, I guess. 

18 MR. ERBS: So if we’re talking about 

19 melting of the ice after it’s harvested, I think --

20 my perspective is we’re not talking about rulemaking 

21 that relates to the efficiency of a storage bin. 

22 MR. WESTPHALEN: Just in clarification -- 

23 sorry, just in clarification, this list was not 

24 intended to look at storage. Standby issues, of 

25 which, you know, the thermal storage issues could be 
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1 a part are under consideration, but this is focused 

2 directly on the ice production. 

3 MR. BROOKMAN: Back to Daryl. You want to 

4 keep going? 

5 MR. ERBS: No, I think I was done. 

6 MR. BROOKMAN: Okay. John. 

7 MR. BROADBENT: Certainly, Scotsman 

8 Industries can help you with your list. I think 

9 you’ve got most of them there. I did want to point 

10 out a couple clarifications there. On drain water 

11 thermal exchange, you have tube as “NA”, and it 

12 actually should be a check. And likewise, less 

13 potable water flow, tube is “NA”, and it should be 

14 checked. 

15 MR. BROOKMAN: Okay. 

16 MR. WESTPHALEN: Those are -- 

17 MR. BROADBENT: They’re essentially the 

18 same as a cube ice machine. They work the same way, 

19 and so the same technology things should apply. 

20 MR. BROOKMAN: Okay. 

21 MR. WESTPHALEN: I guess just some 

22 clarification on that. When I’ve looked at some of 

23 the data for the two machines, they seem to have the 

24 same water use per 100 pounds as the flake or 

25 nugget, they’re using all of it.
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1 MR. BROADBENT: Well, they sometimes use 

2 upstream, like a reverse osmosis system so that they 

3 can use 100 percent of the water, but if you use tap 

4 water and make ice with it, and you use 100 percent 

5 of it, your ice will begin to get cloudy, and you’ll 

6 have other issues as well. So, I mean -- and if 

7 they’re at zero, that’s great, but fundamentally, 

8 it’s the same process. 

9 MR. WESTPHALEN: Okay. 

10 MR. BROOKMAN: As long as you understood 

11 that, that’s what matters.

12 MR. WESTPHALEN: Well, I see it as the 

13 marching orders to find out more and to ask 

14 questions. 

15 MR. BROOKMAN: Joanna. 

16 MS. MAUER: Joanna Mauer. So just 

17 clarification questions. Is DOE proposing to 

18 include any energy use associated with the actual 

19 ice storage as part of the scope in terms of looking 

20 at energies? 

21 MR. WESTPHALEN: Well, I wouldn’t use so 

22 strong a word as proposed at this point. I think 

23 it’s under consideration. And, you know, this gets 

24 into issues of coverage. I’m just talking about 

25 technology at this point, and issues of the test 
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1 procedure. I don’t know if we want to even wander 

2 into this territory now, Charles. 

3 MR. LLENZA: This is Charles Llenza, 

4 Department of Energy. At this point, we would 

5 strongly recommend the industry weigh in on what 

6 they think about the energy for the storage -- you 

7 know, these particular -- the ice making part of 

8 this should be considered. So comments would be 

9 appreciated. 

10 MR. BROOKMAN: In terms of storage? 

11 MR. LLENZA: Yeah, in terms of the scope 

12 of this particular rulemaking. 

13 MR. BROOKMAN: And detailed, written 

14 comments, I presume. Karim. 

15 MR. AMRANE: This is Karim Amrane. I 

16 guess as far as -- it seems to me outside of the 

17 scope, I mean, you know, the energy is used to make 

18 the ice, you know, and that’s what the energy 

19 administration directed you to look at is really the 

20 ice machine. After that, I think it’s outside.

21 MR. BROOKMAN: Yes, I see some industry 

22 members -- Jeff first.

23 MR. BIEL: Yeah, once -- I mean the energy 

24 is being put into the making of the ice, after that 

25 it’s kind of out of the manufacturer’s hands. 
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1 There’s no more energy being put into the storage 

2 bin.

3 MR. BROOKMAN: Okay. Daryl. 

4 MR. ERBS: Yes, I guess I would say that 

5 if there’s interest in creating regulation around 

6 storage efficiency, that, to me, would be a separate 

7 rulemaking. It would have a much wider set of 

8 stakeholders, because you’ve got besides just the 

9 bins that the ice machines sit on, you have beverage 

10 dispensers, you have carts, totes, you know, a whole 

11 range of ways that ice gets stored after it gets 

12 produced. And so I think it would be overly 

13 complicated to try to integrate that into this. It 

14 would really, I think, my recommendation would be to 

15 handle that separately. 

16 MR. BROOKMAN: Okay. Yes, please. Ari. 

17 MR. ALTMAN: Yes, Ari Altman from 

18 Department of Energy, General Counsel’s office. I 

19 just want to clarify on this point, that in general 

20 this framework and the rulemaking relates to our 

21 authority under the statutes which specifically 

22 references the regulation of the ice-maker 

23 themselves. So the storage component, to the extent 

24 that that storage is separate from the ice-maker, I 

25 do think that that may be a separate issue from this 
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1 rulemaking that we’re involved in right now.

2 MR. BROOKMAN: Sarah. 

3 MS. WIDDER: 

4 Sarah Widder, Pacific Northwest National Lab. Just 

5 one thing to add to that. I think in our 

6 discussions of including storage bins in some 

7 capacity, it would be only self-contained ice-makers 

8 that contain the storage bin as part of an 

9 integrated unit, as per the statutory definition. 

10 But we do welcome comments on whether that is within 

11 the scope or should be treated separately. But that 

12 would just be an application to self-contained 

13 units, that it’s part of the ice-maker itself. 

14 MR. BROOKMAN: Daryl. 

15 MR. ERBS: So, I could see why you would 

16 say a self-contained ice-maker because of the 

17 storage is part of the ice-maker, so that’s now part 

18 of the machine. But then if you were to try to take 

19 into account in any way, the loss of ice due to heat 

20 transfer through that storage section, which would 

21 then somehow be accounted for in the standard, that 

22 would put those ice-makers in a different -- you 

23 would be treating them differently than all of the 

24 other classes, which, by the way, the ice that also 

25 comes from them also melts. It’s just someone 
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1 else’s piece of hardware, so you’d be creating a 

2 double standard if you tried to do that. 

3 MS. WIDDER: I think one thing to just to 

4 follow up on that. The DOE would welcome comment on 

5 perhaps the percentage of meltage, or what the scope 

6 of energy use we’re talking about here. It might be 

7 easier to understand the justification for treating 

8 it or ignoring it if we knew the magnitude of the 

9 effect. So welcoming that data. 

10 MR. BROOKMAN: Thank you, Sarah. Okay. 

11 We’re going to get through a few more slides and 

12 then we’re going to get a break. Detlef.

13 MR. WESTPHALEN: Okay. Condenser water. 

14 As we talked about earlier, the current DOE standard 

15 does regulate condenser water, use of water cooled 

16 products or equipment, and in considering technology 

17 options for condenser water, DOE grappled with some 

18 issues, and some of this has been touched on in the 

19 previous discussion. 

20 First of all, if we reduce condenser water 

21 use, the energy use could increase. Then the cost 

22 impacts and also the environmental impacts of 

23 condenser water use reductions could vary, depending 

24 on the source. You could be using tap water that’s 

25 dumped down the drain. You could be using pumped 
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1 well water. You could be using cooling tower water. 

2 We’ve also heard of chilled water, and obviously the 

3 implications are very different depending on which 

4 of those sources provide the water. 

5 And DOE has not, at this point, identified 

6 any clear energy saving technologies that directly 

7 save condensing water, but in some sense indirectly, 

8 the energy saving technologies could save condenser 

9 water because a condenser water reduction, then, 

10 could be mitigated by energy efficiency improvements 

11 elsewhere. 

12 So DOE seeks comment, whether any 

13 technology options not yet identified are available 

14 to reduce condenser water use, and seeks data 

15 sources on the prevalence of the different sources 

16 for the cooling water. 

17 MR. BROOKMAN: Harvey Sachs.

18 MR. SACHS: Harvey Sachs. Just very 

19 briefly. To me it is absolutely critical to 

20 differentiate consumptive water use in making ice 

21 and a little bit of melt water from closed water 

22 loop situations. Once through, “pump and dump” they 

23 call it, the ground source, is a very different 

24 application from a water loop that’s connected to 

25 heat rejection elsewhere. 
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1 MR. WESTPHALEN: I guess in taking in your 

2 comment, one of the things that I wrestle with is 

3 the DOE regulations have authority over the 

4 equipment, but not necessarily over the 

5 applications, and Ari might be able to chime in a 

6 little bit. And so in order to address your 

7 comment, we obviously have to get around them, 

8 figure out how to deal with that. 

9 MR. SACHS: I suspect there’s a scenario 

10 where you’ll find that industry and the advocates 

11 would be quite instinctively inclined toward helping 

12 together with that, that a once-through can be set 

13 up to be fairly energy efficient, depending on the 

14 temperature we choose, but it’s likely to be cooler 

15 than ambient. We can get a pretty good heat 

16 exchanger. That could look like it has a strong 

17 advantage over both an air cooled, particularly in a 

18 self-contained, or a water loop that might run in a 

19 slightly higher ambient, and we do not want to see 

20 that advantage given to once-through units for which 

21 the energy consumption in processing that water is 

22 externalized. This is an environmental issue. 

23 MR. BROOKMAN: I notice that one or two 

24 manufacturers are nodding their heads in agreement. 

25 John.
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1 MR. BROADBENT: This is John Broadbent. I 

2 would agree that -- first of all, manufacturer 

3 doesn’t control the end use of the machine. All 

4 right. So, we make water-cooled machines. We don’t 

5 know if it’s going in a closed loop system, or a 

6 pump and dump. Right. And further, the closed loop 

7 system can be a really efficient, good system. You 

8 don’t have filters that you have to clean. It’s 

9 really a great system, and very efficient. But if 

10 it’s on a pump and dump, you’re wasting a lot of 

11 water. So -- but as a manufacturer, we can’t 

12 control how it’s used.

13 MR. SACHS: But -- Harvey Sachs. My 

14 understanding, John, is that it is conventional 

15 practice for, let’s say at least the closed loop 

16 systems, to have a separate water inlet to feed the 

17 ice making process from the -- 

18 MR. BROADBENT: They all do. 

19 MR. SACHS: They all do. So that we have 

20 a technical distinction between units designed to be 

21 able to do pump and dump from -- 

22 MR. BROADBENT: All water-cooled machines 

23 have a separate system for the cooling water from 

24 the potable water. 

25 MR. SACHS: So we have a basis that we can 
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1 use, I think. 

2 MR. WESTPHALEN: I guess I would ask the 

3 question, is there any other way to design a system 

4 so that it can be used with the one application and 

5 not the other? 

6 MR. BROOKMAN: John, on the record. 

7 MR. BROADBENT: No. 

8 MR. BROOKMAN: John says no. 

9 MR. ERBS: Yeah, I have to echo what John 

10 said. Quite honestly, I think the only way to get 

11 around this is through some type of codes. I mean, 

12 it really has to be down at a level of a building 

13 inspector coming in and verifying whether a water14 cooled machine is hooked up to a recirculating 

15 closed loop system or not. Now that can be done, 

16 and there are -- you know, but it would require more 

17 than just rulemaking. We would have to work at 

18 other levels to make that happen. 

19 MR. SACHS: I don’t want to belabor it, 

20 but it appears to me that it would be imprudent to 

21 do a pump and dump without a filter. It would not 

22 be needed with -- 

23 MR. BROADBENT: No, actually, pump and 

24 dumps don’t have a filter on the condensing water 

25 side.
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1 MR. SACHS: They do not? 

2 MR. BROADBENT: They do not. 

3 MR. SACHS: So where this takes further 

4 work and certainly code issues, labeling of 

5 mechanisms -- what’s important to me at this point 

6 is that, at minimum, that we not be penalizing the 

7 use of a closed loop relative to an air source unit. 

8 MR. BROOKMAN: We’re going to take one 

9 more slide. 

10 MR. WESTPHALEN: Next we talk a little bit 

11 about potable water -- 

12 MR. BROOKMAN: Two more slides. 

13 MR. WESTPHALEN: Potable water currently 

14 is not regulated, and this was mentioned as one of 

15 the key issues. DOE is considering the regulation 

16 of potable water. Reducing potable water use is 

17 expected to reduce energy use. DOE has not 

18 identified any particular technologies that will 

19 allow a reduction of potable water use. You’ll 

20 remember in the slide showing energy saving 

21 technologies, reduction of potable water use was 

22 listed, but no particular technologies for reducing 

23 potable water use. 

24 And so we have additional comments on 

25 potable water -- requests for comments on potable 
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1 water use, and these touch also, I believe, on 

2 condenser water as well. First of all, DOE requests 

3 feedback on potable water use as a metric, 

4 specifically, should DOE be regulating potable water 

5 use?

6 MR. BROOKMAN: Read all of them so they 

7 can respond to all of them. 

8 MR. WESTPHALEN: Okay. Item 3-12. DOE 

9 requests comment on the relationship between potable 

10 water use and energy efficiency. Specifically, to 

11 what degree is potable water efficiency likely to 

12 increase with increased stringency of energy 

13 efficiency requirements for the ice-makers covered 

14 under this rulemaking, without explicit potable 

15 water efficiency requirements? 

16 Item 3-13. DOE seeks feedback on 

17 including total water use in the technological 

18 assessment. 

19 Item 3-14. DOE seeks input on what 

20 technologies or designs should be considered to 

21 improve water efficiencies, both potable and 

22 condenser water. 

23 MR. BROOKMAN: Joanna. 

24 MS. MAUER: Joanna Mauer. Just on the 

25 first item, I just wanted to reiterate that we 
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1 strongly support a potable water use metric, and as 

2 I mentioned, we’ve definitely seen significant 

3 improvements in the industry in lowering water 

4 consumption. But I think we still do see a pretty 

5 big range among machines and water use. I think 

6 there’s still room for improvement.

7 MR. BROOKMAN: Do we have confirmation 

8 over here, John? 

9 MR. BROADBENT: From a technology 

10 standpoint, if you lower the potable water use, you 

11 will improve energy efficiency because that extra 

12 water is 32 degree water that you’re throwing down 

13 the drain, so you definitely get some benefit. 

14 There’s no limitation in the industry, and if you 

15 try to go too low, you start having difficulties in 

16 terms of the ice will become cloudy and soft, which 

17 is undesirable. And also what happens is the 

18 impurities in the water tend to precipitate out and 

19 coat all the different parts in your ice machine and 

20 requires either more frequent cleaning, or you’re 

21 going to have a breakdown of some sort in your 

22 machine. So it’s a reliability issue for the end 

23 user if the water use is too low. 

24 MR. BROOKMAN: Daryl? 

25 MR. ERBS: Just to add to that comment. I 
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1 would agree that just efficiency would tend to drive 

2 our use down for batch machines. It’s -- so this 

3 really is all about batch ice machines, because 

4 continuous type is pretty much we all can figure out 

5 how much water they use, based on how much ice they 

6 produce. 

7 I think there’s actually kind of a minimum 

8 -- there’s an optimum point where if you drive to 

9 drive potable water use too low, not only do you 

10 create the reliability issues that John spoke to, 

11 but as you start to try and use less and less water, 

12 and increase the amount of scale that is deposited 

13 on the evaporator of the ice machine, it actually 

14 hurts efficiency, not only because of the heat 

15 transfer resistance, but in a lot of evaporator 

16 constructions, the scale will slow down the 

17 harvesting part of the cycle, so you’ll get more 

18 melting. You’ll have higher temperatures. 

19 And as manufacturers, again, we have to 

20 deal with a wide range of water quality issues 

21 throughout the country, and so if we put out a 

22 machine that has to be basically set to handle maybe 

23 all but the very worst quality water, then that 

24 places that limit on how far we can go. Now, if we 

25 had some way to get adaptive controls in, that might 
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1 open up some new possibilities, but with the current 

2 situation, I think we’re getting very close to the 

3 optimum point. 

4 And again, I would caution you, just in 

5 terms of in your analysis, making sure you 

6 understand those effects and how to treat them 

7 properly, because it’s not just the thermal part of 

8 the equation, there’s the TDS of the water and the 

9 minerals coming out of solution that drive a lot of 

10 our decisions on design. 

11 MR. BROOKMAN: Okay. Harvey Sachs. 

12 MR. SACHS: This has been very helpful to 

13 me and I appreciate it. I would echo, the potential 

14 of adaptive controls, but also the necessity for 

15 some potential necessity for additional elements in 

16 the rating methods in terms of specification of 

17 water hardness, or total dissolved solids or 

18 carbonate ion or whatever it is, that if -- 

19 otherwise, all manufacturers will be driven to test 

20 with distilled water, which would not be a good way 

21 to run them on the long term in Ohio with hard 

22 water. So I think that’s what you’re driving at, 

23 Daryl and John. 

24 MR. BROOKMAN: Okay. Thank you. I’m 

25 going to ask you to scan through these four 
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1 questions in this comment box and make sure you’ve 

2 referenced them, answered them -- yes. Daryl. 

3 MR. ERBS: One other comment. Item 3-13. 

4 Total water use. Then I assume you’re talking about 

5 combining potable and the condenser water use for 

6 water cooled machines? Would that be total? 

7 MR. WESTPHALEN: Yeah, this gets ahead 

8 into the test procedure discussion a little. 

9 MR. ERBS: And there I would say I would 

10 be -- I would not be in favor of that just because 

11 the amount of water used by the condenser compared 

12 to that used by the potable -- I mean, the ratios 

13 are ten to one, well, maybe not quite, but -- so it 

14 would tend to dwarf any changes you made on the 

15 potable water side if you just lumped it all 

16 together. So I would be in favor of keeping those 

17 separate. 

18 MR. BROOKMAN: Okay. Thank you. Calling 

19 your attention to this comment box, take any 

20 additional comments now, before we go to break. 

21 Okay. So let’s take a break. It’s by my watch, 

22 seven after, let’s take a 15 minute break. Let’s 

23 resume at 11:20. While you’re here in the Forrestal 

24 Building, you must wear this visitor’s badge in a 

25 place that’s visible.
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1 (Whereupon, the hearing was off the record for 

2 an 18-minute recess.) 

3 MR. BROOKMAN: Let’s please take your 

4 seats. We’re going to resume. We are returning to 

5 Detlef and taking up screening analysis. 

6 SCREENING ANALYSIS

7 MR. WESTPHALEN: The screen is stuck here, 

8 if I could get some IT help. Thank you. Moving on 

9 to screening analysis. We talked about some 

10 technologies. In the screening analysis, we try to 

11 screen out the technologies that are not appropriate 

12 to consider and the engineering and downstream 

13 analyses. 

14 The approach for screening is to evaluate 

15 each technology based on these four screening 

16 criteria. The first one is technological 

17 feasibility. What that translates into is the 

18 technology either is used in current products that 

19 are for sale, or it has been demonstrated in a 

20 prototype. 

21 The other three criteria are fairly self22 explanatory: practicability to manufacturer to 

23 install and service; impacts on equipment utility or 

24 availability to consumers; and impact on health and 

25 safety.
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1 So item 4-1. DOE welcomes comments on 

2 these four screening criteria. 

3 MR. BROOKMAN: I think that most of you 

4 are familiar with these. Comments? 

5 MR. WESTPHALEN: Okay. We’ll move on. 

6 Next -- oops. 

7 MR. BROOKMAN: Harvey Sachs.

8 MR. SACHS: Harvey Sachs, sounding like a 

9 broken record. But technological feasibility would 

10 be demonstrated if this -- if a particular 

11 technology option is in use anywhere in the world in 

12 a mass production environment. Not just in the US 

13 as we have seen in one or two proceedings in the 

14 past.

15 MR. WESTPHALEN: Okay. Point well taken. 

16 MR. BROOKMAN: Okay. Any others? 

17 ENGINEERING ANALYSIS 

18 MR. WESTPHALEN: Moving on to the 

19 engineering analysis. The point of the engineering 

20 analysis is to develop the relationship between the 

21 efficiency improvements and the additional cost that 

22 would be incurred, additional equipment cost 

23 associated with improving that efficiency, and 

24 generally it is a cost efficiency curve, like shown 

25 in the graph on the bottom left there. Usually low 
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1 slope, small efficiency improvement levels, and as 

2 this slope gets steeper it gets harder and harder to 

3 squeeze more out of the apple, as you take more and 

4 more out. 

5 And the results of the engineering 

6 analysis are then used in all the downstream 

7 analyses to provide the basis for the economic 

8 analyses. 

9 There are different approaches used in 

10 different rulemakings for the engineering analyses, 

11 and some of these have been categorized, such as the 

12 design option approach, the efficiency level 

13 approach, and the reverse engineering approach. 

14 For the design option approach, briefly, 

15 DOE looks at how much does this design option cost, 

16 and how much energy use will it reduce? The 

17 efficiency level approach is based on set efficiency 

18 levels and attempts to gather information, for 

19 instance, from the industry, of the costs associated 

20 with attaining those efficiency levels. The reverse 

21 engineering approach, you have different pieces of 

22 equipment. You know their efficiency level based on 

23 rating tests, and you do reverse engineering to 

24 develop a manufacturing cost model to determine what 

25 the costs are for those different levels. 
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1 For this rulemaking, DOE intends to use a 

2 combination of these approaches, using multiple 

3 available data sources, and -- which will then feed 

4 into the cost efficiency relationships. 

5 Item 5-6. DOE requests feedback on the 

6 use of a combined analysis approach, that uses 

7 multiple information sources to determine the 

8 relationship between manufacturer selling price and 

9 energy consumption for automatic commercial ice10 makers. Any comments? 

11 MR. BROOKMAN: No comments? Okay. 

12 MR. WESTPHALEN: Getting back to the 

13 energy use condenser water use trade-offs. You saw 

14 the cost efficiency curve prototype that we showed 

15 earlier, in a product where you could have 

16 efficiency improvements and also water use 

17 improvements. You could envision a three18 dimensional mapping of product cost versus 

19 efficiency on both these axes. Obviously, that 

20 could get quite complicated. We’re not aware that 

21 this has ever been done in any other rulemaking. 

22 But because there’s a trade off here, 

23 there’s a potential place where, you know, it would 

24 be the optimum for consumers based on life cycle 

25 costs and national impacts. 
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1 So DOE seeks comments from stakeholders 

2 providing insights regarding such trade offs, and 

3 I’ll just read item 5-4 here, as well. 

4 DOE seeks comments on simplifying 

5 assumptions that may be made to reduce potential 

6 complexity of maximizing benefits associated with 

7 both the water and energy use reductions. 

8 MR. SACHS: Harvey Sachs, addressing DOE 

9 applies and OGC. There have been some questions in 

10 the past with conflicting interpretations on DOE’s 

11 authority to combine a prescriptive with a 

12 performance standard. And I’d certainly like to get 

13 clarification of that in terms of the potential -- 

14 one way to address both the water and the energy 

15 issues.

16 MR. WESTPHALEN: It sounds like a legal 

17 question? 

18 MR. SACHS: Well, that’s why I suggested 

19 OGC as well. And as a particular example of what 

20 I’m thinking about, an energy performance standard 

21 in terms of kilowatt hours per pound of -- or watt 

22 hours per pound of ice made, or however we want to 

23 do that, might effectively be coupled with an 

24 adaptive water use standard that respects the fact 

25 that water use must vary, depending on hardness of 
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1 the water. 

2 I don’t know if this makes sense, but I 

3 think it would be helpful to the process to have DOE 

4 starting to think about this if it turns out to be 

5 something everybody wants or is willing to accept in 

6 exchange for other things. Thank you. 

7 MR. BROOKMAN: Thank you. Ari. 

8 MR. ALTMAN: Yes, Ari Altman from OGC. I 

9 think kind of -- we’re in an initial stage, I’d say, 

10 in terms of how we’re going to regulate water use 

11 beyond the condenser water use. So what you’re 

12 referring to is really kind of a -- well, we have 

13 the energy use already as kilowatt hours per pound 

14 of ice or hundred pounds of ice. In terms of what 

15 you’re referring to as an adaptive standard, I think 

16 we’d have to consider whether or not we have the 

17 authority to do that. It is different than the way 

18 Congress laid it out. 

19 So we’ll definitely take it under 

20 advisement, but I don’t think I could comment right 

21 now. If we would, you know, tend to extend our 

22 authority to that. 

23 MR. SACHS: As the reference point -- 

24 Harvey Sachs -- just a reference point for this Ari, 

25 I appreciate your caution. But the residential 
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1 boiler standard now has a performance requirement in 

2 terms of AFUE and has an additional prescriptive 

3 requirement for a particular class of controls that 

4 increase the end use efficiency, but could not be 

5 addressed by the standard. This was first 

6 negotiated, and then eventually accepted by DOE. 

7 So the question is whether the Department 

8 would use that precedent, or others like it, to 

9 consider this range of options. And we can go on, 

10 but I wanted to make sure that we flag that as a 

11 question. 

12 MR. ALTMAN: Sure, and we can definitely 

13 take a look at the boiler standard as an example. 

14 Just to clarify, though, our authority for 

15 this rulemaking is separate from the boiler 

16 rulemaking in that the authority comes under a 

17 separate section of the statute. So I’m not 

18 personally familiar with that negotiation that went 

19 on with the boiler standard. I think we would have 

20 to take a look at how the language was interpreted, 

21 and that section of the statute, versus what the 

22 ACIM language is as provided by Congress. 

23 MR. BROOKMAN: Yes, Daryl. 

24 MR. ERBS: Well, I guess my comments would 

25 be other than -- you know, I think you understand 
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1 the obvious, which, there’s an inverse relationship 

2 on a water cooled condenser between flow rate and 

3 its energy efficiency, so that would lead one to 

4 say, does DOE have the ability, then, to even 

5 considering relaxing the current limitation on 

6 condenser water flow rate if it showed enough 

7 potential benefit from an energy use standpoint? I 

8 don’t know how you weight the two in terms of this 

9 combined regulation. What’s more important, energy 

10 or water? Probably depends on where you live. 

11 But I would say we’d be open to looking at 

12 that, but then there will still be some limits from 

13 a practical standpoint, in terms of water flow rate, 

14 whether it be what the heat exchanger is capable of 

15 from a reliable lifetime operation standpoint and 

16 other things. 

17 Then on the simplifying assumptions, I 

18 just wanted to, I guess, reiterate some of my 

19 earlier comments. I don’t think there are any 

20 because I think there’s a lot of complexities and 

21 compounding effects that go on between how you 

22 manage water use and how the machine operates. So I 

23 know you’re looking for a nice, simple model. I 

24 can’t offer you much hope of one.

25 MR. BROOKMAN: However, if others have 
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1 that ability to offer any, that would be great. 

2 MR. LLENZA: Yeah, and this is Charles 

3 Llenza, Department of Energy. I would encourage 

4 strongly that the stakeholders think about this a 

5 little bit over Christmas and submit written 

6 statements in regards to the trade offs. In 

7 addition to what they believe should be the scope of 

8 the Department’s concerns with the water issues 

9 here. I think that would assist the Department in 

10 framing this particular rulemaking, not only to the 

11 needs of the policy that the Department’s creating, 

12 but also to the need of the stakeholders here 

13 present and on the webinar. 

14 MR. BROOKMAN: Karim. 

15 MR. AMRANE: Karim Amrane. I guess this 

16 is a question for legal counsel here. But could DOE 

17 relax the water consumption usage if it’s already in 

18 the standard? 

19 MR. ALTMAN: Ari Altman from OGC. It’s 

20 certainly not something that we’ve considered, I 

21 believe, yet at this point in the rulemaking, but it 

22 really breaks under two separate categories. First, 

23 the standards prescribed by Congress for cube type 

24 ice-makers. The Secretary does have authority under 

25 the statute to revisit those standards, and that’s 
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1 part of this rulemaking. Specifically, that looks 

2 at -- simply gives us authority to amend the 

3 standard. So it does not specifically require DOE 

4 to increase the standard, although in looking at 

5 technological feasibility and economic 

6 justification, the assumption is that the standard 

7 would be increasing if it can be justified. 

8 For the other types of ice-makers, which 

9 this is a new rulemaking, under new authority, 

10 certainly we’re starting from scratch, so the answer 

11 to that is we can set it wherever it seems 

12 appropriate. 

13 MR. LLENZA: This is Charlie Llenza, and I 

14 don’t want to speak for the Department, per se 

15 specifically, but we do have anti-backsliding 

16 regulation for energy use, so if -- the way that 

17 works, if there is a level that has been set by 

18 Congress in the regulation, at least for energy use, 

19 we’re not allowed to backslide. Now, I don’t know 

20 if that applies to the water usage, because I’m not 

21 so familiar with water usage throughout the regs, 

22 and how that impacts what the Department has 

23 authority or is allowed to do or not do. So I think 

24 that this is one of the areas where we will have to 

25 explore further in terms of to see what the 
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1 regulations allow us to do in terms of the water 

2 usage.

3 MR. ALTMAN: This is Ari again from OGC. 

4 I think, you know, ice-makers are a bit unique in 

5 that we’re regulating both water and energy at the 

6 same time. There are very few appliances in which 

7 we do that. So this issue of anti-backsliding, 

8 which usually relates directly to energy use, I 

9 don’t know off hand whether or not it would be 

10 implicated if we say relaxed a water standard while 

11 increasing the energy standard, for an overall 

12 benefit in terms of energy consumption. We’ll have 

13 to look at that, but it’s an interesting question.

14 MR. BROOKMAN: Good data. You all need 

15 good data. 

16 MR. WESTPHALEN: Okay. Moving on. 

17 Industry data collection. As you’re aware in many 

18 rulemakings, DOE asks trade organizations such as 

19 AHRI, to collect data from the industry and 

20 aggregate it to inform the rulemaking. And in some 

21 cases, by the time of the framework, we have a 

22 template showing exactly what we want. We don’t at 

23 this point. 

24 Instead, we’re asking for feedback on what 

25 that template might look like. We will be working 
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1 on developing that kind of a template, and certainly 

2 we want to have some back and forth on how that 

3 would be structured. And this would also encompass 

4 some of the issues addressed earlier by Michelle, 

5 such as shipments, shipment data, things like that. 

6 So item 5-2, DOE requests comments on the 

7 best way to collect such information from the 

8 industry. DOE anticipates that such data might be 

9 collected and aggregated by AHRI for submittal to 

10 DOE.

11 Item 5-3, DOE requests input on 

12 appropriate categories and questions to be included 

13 in such requests for data. 

14 And item 5-4A, DOE seeks comments and 

15 recommendations regarding the potential data 

16 collection efforts that might be made by industry 

17 participants to support this rulemaking and the 

18 proper structure of data request forms that could be 

19 used to assist such efforts. 

20 MR. BROOKMAN: Karim. 

21 MR. AMRANE: Karim Amrane, AHRI. We have, 

22 in the past, done that, collected and aggregated 

23 data, cost efficiency data for DOE. But it was 

24 challenged by many as being done through a black 

25 box, nobody knew what was in there. So we moved 
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1 away from that, and again, I mean I -- we don’t want 

2 to go through this kind of analysis if at the end of 

3 the day it’s not going to be used by DOE. It’s a 

4 lot of effort, but I’m not even sure the 

5 manufacturers would be willing to share this 

6 information. But assuming that they will, it’s a 

7 lot of effort which at the end, at least in some 

8 cases, has been challenged. 

9 So I don’t know, I mean, DOE seems to have 

10 moved away from just getting data from AHRI, cost 

11 efficiency data from AHRI on other rulemakings, so 

12 again, I mean, unless there is a commitment or an 

13 agreement that yes, the data will be used, AHRI is 

14 not going to try to get this information. 

15 MR. BROOKMAN: Harvey Sachs.

16 MR. SACHS: Harvey Sachs, ACEEE. Somehow 

17 I felt Karim was speaking to me when he pointed at 

18 me, and I think my instinct is to first of all say 

19 that we count on AHRI as a very important source of 

20 data in the market segmentation, market classes. I 

21 think that’s a very valuable function. For this 

22 product class, as opposed to others, I certainly 

23 will take this to my colleagues as a very specific 

24 issue and I will say, guys, can you trust AHRI? And 

25 I think the answer is likely to be that we would 
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1 hope AHRI is doing some of its own analysis, because 

2 we like it when we have independent estimates from 

3 AHRI and DOE, and I think you’ll certainly give us 

4 credit for beating up DOE on its analyses at least 

5 as much as AHRI. Is that fair enough? 

6 MR. BROOKMAN: Okay. Thank you. And let 

7 me respond to a question that has come in via the 

8 web. Several people have asked if the webinar 

9 participants can be electronically sent the same 

10 materials as in person attendees, and two approaches 

11 to that. One would be that all of the materials 

12 that are being presented in the webinar are going to 

13 be posted on the website next week. That’s one. 

14 But if you need to have it, anybody who’s listening 

15 in via the web, if you need to have it quicker, than 

16 you can request it via e-mail, and I’m about to give 

17 you that e-mail address. The technical lead, the 

18 program lead, Charles Llenza, if you send Charles 

19 Llenza an e-mail, then today or very soon he’ll send 

20 you these materials back via e-mail, and that 

21 address is as follows: it’s 

22 Charles.llenza@ee.doe.gov. I’m going to spell that, 

23 C-H-A-R-L-E-S, dot, Llenza, L-L-E-N-Z-A at EE dot 

24 DOE dot GOV. 

25 So, keep going. 
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1 MR. WESTPHALEN: Good. 

2 MR. BROOKMAN: Oh, question here. Yes, 

3 please, Jeff. 

4 MR. BIEL: Jeff Biel. To your point, 

5 Karim, AHRI is a tremendous resource for us and so 

6 we definitely encourage the use of AHRI for shipment 

7 data. One point also, we were talking about tube 

8 ice and flake ice, you know, there are, when we 

9 start talking about those ice forms, they are not 

10 part of industry associations, some manufacturers of 

11 those products. So there would probably need to be 

12 some additional data gathering done for some of 

13 those categories. 

14 MR. BROOKMAN: Okay. 

15 MR. WESTPHALEN: Moving on to some eye 

16 charts here, and we’re putting some of this 

17 information on the table here. We don’t necessarily 

18 expect fully considered responses at the moment, but 

19 certainly if we could get comments in the written 

20 comments that might help us to adjust our plans for 

21 some of this analysis. 

22 This first chart is a list of cube 

23 machines that DOE is planning to purchase for tear 

24 down and testing with an attempt to cover a broad 

25 spectrum of product types. I haven’t listed 
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1 manufacturers, but also covering a broad spectrum of 

2 manufacturers. 

3 And we also have a list of continuous type 

4 flake and nugget machines here, and, you know, that 

5 manufacturer that makes that number 17 with a zero 

6 width, that’s just amazing -- this should be 21 inch 

7 width here. I apologize for that. 

8 Additional comment H. DOE requests 

9 comments on its plans for tear downs and testing, 

10 and in particular, what types, capacities or sizes 

11 of equipment are not sufficiently well represented 

12 and as I say, certainly we welcome comments in the 

13 written comments if you haven’t had time to really 

14 digest this at the moment. 

15 MR. BROOKMAN: Do you know now how many 

16 you’re going to try and purchase and tear down?

17 MR. WESTPHALEN: All of the -- basically 

18 what you see here. This is in the plans, it’s 

19 already in the works. 

20 MR. BROOKMAN: Okay. Yes, Joanna. 

21 MS. MAUER: Joanna Mauer. Just a question 

22 on the plans for tear downs for the cube type 

23 machines. Are the products -- the number of 

24 products of each equipment type, are those intended 

25 to reflect shipments in some way? 
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1 MR. WESTPHALEN: Well, we don’t have very 

2 good shipment data, or we didn’t when we developed 

3 this initial list, so certainly any comments that 

4 reflect representation by shipments would be 

5 welcome. 

6 MR. BROOKMAN: Karim. 

7 MR. AMRANE: Karim Amrane, AHRI. That’s 

8 my next question. I mean, when are you planning to 

9 do the tear down? I mean is it going to come the 

10 next month, or is it going to come -- 

11 MR. WESTPHALEN: Yeah, it’s coming an , 

12 accelerated, rulemaking schedule -- certainly we’re 

13 prepared to add to this list in order to get a 

14 better representation. 

15 MR. BROOKMAN: A moment ago I asked you 

16 what you’re going to tear down, and it appears that 

17 you were referring to slide 40 or to slide 39? 

18 MR. WESTPHALEN: Both. All of these -- 

19 MR. BROOKMAN: That’s what I wasn’t clear 

20 about.

21 MR. AMRANE: Because I’m asking the 

22 question because we don’t have yet this shipment 

23 weighted data which hopefully we will have, will 

24 give us a better idea of what is the right capacity 

25 you need to. 
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1 MR. LLENZA: Charles Llenza, Department of 

2 Energy. I think we’re talking about purchasing this 

3 next month, as soon as possible, and the equipment 

4 should be torn down in early spring, if not 

5 completely done by then. So this is part of the 

6 problem of an accelerated test procedure in terms of 

7 the timeframe. We have to make decisions at a 

8 faster rate because we have to actually look at the 

9 equipment, if we have to look at the equipment. 

10 This particular rulemaking has never seen 

11 ice making machines so this is kind of critical at 

12 this point. I hate to put pressure on AHRI, but 

13 they’re going to have to do some homework over 

14 Christmas if we want to be able to get this right. 

15 But this is at least the initial stage, so 

16 I think we could get a good perspective. If this is 

17 good enough for right now and then as we get the 

18 firmer data, that takes a little more time, we could 

19 add to this list additional equipment to tear down 

20 to look at. So what we’re hoping is to capture, 

21 let’s say 90 percent of the equipment here, and 

22 maybe one or two other pieces of equipment that we 

23 specifically didn’t address, we can then purchase 

24 and tear down later. Because obviously, we cannot 

25 do everything at once. 
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1 So this is going into a queue and maybe if 

2 we can -- if you have the specific queue, maybe we 

3 can provide that queue in terms of -- so that we 

4 know when the decision points have to be made. But 

5 I think this is our minimum list, right, is that the 

6 way we’re addressing this?

7 MR. WESTPHALEN: Well, this has been 

8 submitted already for going through the process, 

9 because of our contractual arrangements, I don’t 

10 want to get into the details, but this is already in 

11 the works. We don’t know when these products will 

12 start to arrive. You know, there are lead time 

13 implications as well, and test lab availability 

14 questions. 

15 MR. AMRANE: Karim Amrane, AHRI. I see 

16 the list. I see nothing much about 2,500, is that 

17 on purpose. There is one unit, I believe, 2800? 

18 MR. WESTPHALEN: There’s a 2300.

19 MR. AMRANE: And now you’re talking about 

20 expanding the scope to 4,000, so you’re not testing 

21 anything at the higher end? 

22 MR. WESTPHALEN: The only machines that 

23 are, you know, there are very few machines, really, 

24 that are between 2,500 and 4,000, and most of those 

25 are the tube machines. We don’t have tube machines 
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1 represented, that’s something that we are 

2 considering as well. 

3 MR. AMRANE: If that’s the case, then why 

4 did you -- why is DOE thinking of expanding the 

5 scope to 4,000 if there are really few machines 

6 there. I mean what are going to be the energy 

7 savings there then? I mean -- again, it’s a 

8 question that as a matter of fact, there has been no 

9 justification from DOE’s part as to why DOE is 

10 thinking -- why DOE wants to expand the scope to 

11 4,000, except the test procedure that wasn’t 

12 mandatory goes to 4,000, which is fine. But I guess 

13 now you’re telling that there are few machines at 

14 that capacity, so why is DOE spending the resources, 

15 time, to look at that. 

16 MR. LLENZA: And this is Charles Llenza, 

17 Department of Energy. I think part of what we’re 

18 doing is -- you know, this is our proposal and we 

19 would appreciate the comments. The other thing is I 

20 could see where, if we didn’t at least make an 

21 effort to go to the 4,000 level, that many of the 

22 machines that are at the borderline of the 2,500 

23 level could end up migrating to the 4,000 level and 

24 they would be beyond their scope of coverage. So it 

25 could be, I would say, a preemptive strike from the 
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1 Department to cover up to 4,000 to make sure that we 

2 don’t have any migration of technology going to the 

3 4,000 level, where the industry would be comfortable 

4 making those machines, but then they would escape 

5 our standard setting. 

6 MR. AMRANE: This is Karim again. I don’t 

7 want it to appear that I am opposed to DOE to 4,000, 

8 it’s just that it seems to me there are very few 

9 justifications for doing that. 

10 MR. BROOKMAN: So one question that occurs 

11 to me as I look at these 19 different types of 

12 equipment that now have been ordered, and you’ll see 

13 how they roll in. Is that what happens? 

14 MR. WESTPHALEN: Yeah. We’re keeping tabs 

15 on when they come in. 

16 MR. BROOKMAN: So one question is, are 

17 there significant gaps here? Is there significant 

18 overlap? Is there an efficiency that could be 

19 applied to this list that’s not implicit here?

20 MR. BIEL: Actually, I have one -- Jeff 

21 Biel -- one question for clarification. Category 

22 number 19 for flake or nugget, SCU-A, I assume 

23 that’s a self-contained unit, so it’s an ice-maker 

24 and storage. Would that also include nugget 

25 machines that are ice-maker, storage, and dispensing 
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1 as well? 

2 MR. WESTPHALEN: Well, that’s a particular 

3 product, that’s just an ice-maker and storage self4 contained unit. 

5 MR. BIEL: But is the scope of the program 

6 to cover self contained units that also have 

7 dispensing capabilities? And how would they be 

8 classified? 

9 MR. BROOKMAN: And we already talked about 

10 storage, but go ahead, can you answer his question? 

11 MR. WESTPHALEN: Well, in terms of 

12 coverage, my understanding is that there is 

13 coverage, and so if your point is that we should 

14 include in our tear downs a product that does 

15 include dispensing, then we’ll take that under 

16 consideration. 

17 MR. BROOKMAN: So your written comments on 

18 all of this, of course. Joanna. 

19 MS. MAUER: Joanna Mauer. Just another 

20 question on the energy and water use values, are 

21 those from the AHRI directory, or where do those 

22 come from? 

23 MR. WESTPHALEN: We took a number of 

24 databases, consolidated them, looked at 

25 manufacturers websites, weed out ones that don’t 
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1 exist any more, and so basically we have developed a 

2 database. 

3 MS. MAUER: From multiple data sources? 

4 MR. WESTPHALEN: Yes, that’s partially 

5 AHRI.

6 MR. LLENZA: This is Charles Llenza, 

7 Department of Energy too. I wanted to make one 

8 point also, just to add a point to Karim’s question. 

9 The Department, I mean, at least from project 

10 manager’s point of view, I felt that extending to 

11 4,000 would take very little effort on the part of 

12 the Department to go the extra mile to increase, 

13 because the test procedure work is already pretty 

14 much done. So we are adjusting pretty much the 

15 scope of work to the test procedure level, with very 

16 little extra added cost to the actual rulemaking. 

17 So, strategically speaking, there’s some 

18 reasons why not, if there’s no major objections to 

19 cover everything up to 4,000 pounds. After that 

20 breaking point has been expressed in this meeting, 

21 the equipment changes and it becomes industrial as 

22 opposed to commercial. I think that’s the feeling 

23 of this group, therefore at that point, then, that 

24 becomes an issue as should the Department really 

25 spend the money, and is that beyond the intent and 
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1 the scope that the legislation provided. 

2 MR. BROOKMAN: So -- go ahead Harvey. 

3 MR. SACHS: Harvey Sachs. I just want the 

4 record to reflect that Karim’s objecting to the 

5 Department’s effort to harmonize with his standard.

6 MR. AMRANE: And I’m not. This is Karim 

7 with AHRI. As I said, we are not opposed at DOE 

8 looking at 4,000, but again, it seems to me that 

9 there are very few justification for doing it, 

10 that’s all.

11 MR. BROOKMAN: So look at the list and 

12 tell the Department if they can improve this list, 

13 if there’s redundancy, if there’s gaps. Any 

14 comments on these 19 products. Yes. Or 

15 recommendations, yes. 

16 MR. ERBS: I actually don’t have a 

17 comment, but a question, just a clarifying question. 

18 I heard the comment about doing homework over 

19 Christmas, and I would prefer to comment on this 

20 list in the written comments, which I believe we 

21 have until January something. 

22 MR. AMRANE: Eighteen. 

23 MR. ERBS: Yes, so is January 18 soon 

24 enough to be able to have a meaningful effect on 

25 this list, or have you already gone out and 
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1 purchased them? 

2 MR. LLENZA: Well, the orders are in, so 

3 Santa’s bringing the toys. I don’t know how fast --

4 the logistics of this is a lot more complicated than 

5 it seems. The problem is getting this equipment 

6 into the testing facilities and getting them tested. 

7 So -- and then putting in the orders and everything 

8 else. I would just think that if we stick to the 

9 comment period we’ll be fine. We’ll make the 

10 adjustments necessary at our end. We’re prepared in 

11 terms of the expense of additional equipment if we 

12 need to purchase additional equipment. 

13 I think there would be enough time to 

14 execute a certain level of priority on the equipment 

15 also with -- so we’re not so concerned about this. 

16 We just -- I guess the initial concern is is this a 

17 good enough first shot at the mix of equipment so 

18 that we at least have one piece of equipment for 

19 every kind of machine that’s out there?

20 And then, the concern is, for example, we 

21 don’t have anything that’s at the 4,000 level, so, 

22 you know, whatever input you provide us, we can feed 

23 that into our testing plan and go out and purchase 

24 additional equipment, if the industry feels that we 

25 need to purchase certain other equipment also, then 
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1 that could be considered also to be put into our 

2 plan also. 

3 MR. BROOKMAN: So any additional comments 

4 now?

5 MR. ERBS: So I would just say what I 

6 would likely do is recommend a few additional models 

7 so if you’ve got some ability to add a few more in, 

8 then that would probably satisfy my concerns. 

9 MR. LLENZA: Yeah, we have flexibility and 

10 we knew this was going to happen so we built 

11 flexibility in our testing requests to the office 

12 here so that we could add things to the plan as we 

13 see fit down the line here. 

14 MR. BROOKMAN: We have a question from 

15 somebody participating on the webinar. Stephen 

16 Schaeffer asks what is the purpose for tear down and 

17 testing of units? Who will be testing the units? 

18 Which of you would like to -- Detlef.

19 MR. WESTPHALEN: The purpose of the tear 

20 down is reverse engineering that feeds directly into 

21 the engineering analysis, and that includes both 

22 technically, how do these things work? Is it a PSC 

23 motor? What efficiency? How many watts does it 

24 draw? What is the control sequence? 

25 But it also has to do with the 
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1 manufacturing, what manufacturing processes are 

2 used, and feeds into the development of 

3 manufacturing cost model that is used in the 

4 engineering analysis to help with coming up with 

5 cost efficiency -- 

6 MR. BROOKMAN: Who will be doing the 

7 testing? 

8 MR. WESTPHALEN: At this point we have 

9 requested Intertech to do the testing. 

10 MR. BROOKMAN: Okay. Thank you for that. 

11 Any additional comments on this eye chart? Let’s 

12 move on. 

13 MR. WESTPHALEN: Equipment test data. DOE 

14 realizes we don’t have the resources to test it all. 

15 This is kind of a very general question. I’ll read 

16 it and then make some comments. 

17 DOE is also interested in receiving 

18 equipment test data, test procedure use, rating 

19 conditions, harvest rate, voltage, integrated 

20 average product temperature, daily energy 

21 consumption, et cetera. Test data representative of 

22 the baseline model in each equipment class is 

23 particularly important. 

24 Granted, this is a very general request. 

25 I think as we move forward we might get more 
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1 specific and contact appropriate parties to find out 

2 if we can obtain some data that answers specific 

3 questions. But we’re willing to take comment on 

4 this.

5 MR. BROOKMAN: Yes, Karim. 

6 MR. AMRANE: Karim Amrane, AHRI. What do 

7 you mean by integrated average temperature? It 

8 probably was taken out of the ... refrigeration room. 

9 There’s no such a thing as integrated average 

10 temperature for ice-makers. 

11 MR. WESTPHALEN: Well, that doesn’t make 

12 sense then. Strike that. You know, I -- I like to 

13 talk and instead of listing out all the data, I like 

14 to say give me the raw data, you know. 

15 MR. BROOKMAN: Okay. Thank you for that 

16 clarification. Additional comments on equipment 

17 test data? 

18 MR. WESTPHALEN: The next few slides deal 

19 with efficiency levels that are being considered. 

20 The first slide addresses baseline efficiency 

21 levels. These are the levels against which 

22 improvements in efficiency will be compared for all 

23 of the analyses. For the cubers, the natural 

24 baseline is the current DOE standard for both the 

25 condenser water and the energy use. For flake and 
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1 nugget machines, two options are under 

2 consideration, one is a standard for Canada. Option 

3 two, two-part curves or three-part curves based on a 

4 fit with existing data and this is similar to the 

5 approach that Harvey mentioned earlier. 

6 Potable water use for cubers and this 

7 would also, presumably apply to tubers, similar 

8 approach, such as the curve fits. 

9 And DOE seeks feedback on the proposed 

10 baselines. Granted, some of these options -- option 

11 two has not been quantified for you, but listed as a 

12 potential approach. 

13 MR. BROOKMAN: Comments on the proposed 

14 baselines? Any comments regarding the option one 

15 versus the option two? 

16 MR. AMRANE: Karim Amrane, AHRI. I mean 

17 are you planning to ask industry for data on this? 

18 I mean, because, you know, I’m not sure we have 

19 published our director with flakers and nuggets yet. 

20 No, we don’t have that yet, but maybe it’s something 

21 we can collect for you and you can look at? I don’t 

22 know on that? 

23 MR. WESTPHALEN: Well, maybe we’ll be in 

24 touch and maybe it makes sense to -- you know, as I 

25 mentioned, we have put together a database. We have 
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1 data for flakers and nugget machines, and it may be 

2 worth trying to get some feedback on the specifics 

3 of that database. 

4 Moving on to incremental efficiency 

5 levels. Here for the -- 

6 MR. LLENZA: This is Charles Llenza, 

7 Department of Energy. I just wanted to bring out a 

8 point because this is an interesting question. We 

9 have, for the purpose of the presentation, covered 

10 the majority of the questions that were provided at 

11 the framework -- in the framework document, except 

12 there’s a series of questions that were not covered 

13 in the public meeting slides here today. But I 

14 would suggest that if you pick up -- and we’re going 

15 to publish a piece of information that tells you 

16 which were covered at the meeting and which 

17 questions were not covered at the meeting, because I 

18 feel that it would be beneficial to all the 

19 stakeholders to have that list for those questions 

20 that were not covered today at this meeting, that 

21 they can then specifically submit their replies 

22 under separate correspondence by the comment period. 

23 And in this particular case, there was a 

24 question, item 3-8, that said, DOE requests feedback 

25 on the proposed experiment classes for automatic 
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1 commercial ice-makers covered in this rulemaking and 

2 criterias for creating these classes. So yes, we’re 

3 asking for feedback because we didn’t cover all the 

4 questions here. 

5 So -- and I think it was not a mistake, 

6 but we were short-sighted in not putting the 

7 additional questions in the presentation. But I 

8 just want to make sure everybody understands there’s 

9 some additional questions in the actual framework 

10 document. 

11 Yes, this list will be published on the 

12 web as part of the material from the meeting. 

13 MR. BROOKMAN: Thank you. That will be 

14 helpful. 

15 MR. WESTPHALEN: We’re on incremental 

16 efficiency levels. First looking at levels for 

17 cubers. And on this chart we’ve listed all the 

18 existing product classes with the baseline as DOE 

19 standard, and also listed the max available that 

20 we’ve identified, based on our research for each of 

21 those classes. 

22 And you’ll note that the suggested 

23 efficiency levels are consistent across the capacity 

24 range for a product type. That’s so the individual 

25 lines don’t then become discontinuous. For 
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1 instance, if we looked at an efficiency level of 20 

2 percent for the small, and 22 percent for the 

3 medium, if the standard were set at that level, 

4 obviously you’d have discontinuity in the standard, 

5 and everybody would push just to get over the line. 

6 Some of these are based on the CEE and E7 STAR which addresses one of the comments made 

8 previously, to try and maintain some consistency. 

9 So these are the cubers, the flake and nugget 

10 machines. There was less information to go on. But 

11 here I’m also showing the minimum available based on 

12 NRCan standard, and the max available, and some 

13 suggested efficiency levels for these products. 

14 You see here for the remote condensing 

15 unit with a rack, the 60 percent to 91 percent. 

16 Obviously, that reflects the fact that you’re not 

17 including the compressor and condenser, and it also 

18 brings up the question again that although you would 

19 -- some of the discussion suggested we don’t 

20 separate those, you have to add in the compressor 

21 and condenser somehow in order for this comparison 

22 to make sense. And I think Sarah will talk about 

23 some of this a little bit more in the test procedure 

24 part of the discussion. 

25 MR. BROOKMAN: Joanna. 
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1 MS. MAUER: Joanna Mauer. Can you just 

2 explain, Detlef, the minimum available columns, so 

3 the first number, for example, 28 percent. What 

4 does that refer to exactly? 

5 MR. WESTPHALEN: Well, it’s like a maxtech 

6 available, but it’s the mintech available. So that 

7 the worst or the most energy using of that first row 

8 is 20 percent below the NRCan standard. 

9 MR. BROOKMAN: 20 percent below. 

10 MS. MAUER: So a negative number would be 

11 above?

12 MR. WESTPHALEN: Above. Exactly. 

13 MS. MAUER: And then the efficiency levels 

14 are relative to the NRCan standard. 

15 MR. WESTPHALEN: NRCan standard, yes. 

16 MS. MAUER: Okay. Thank you. 

17 MR. BROOKMAN: Any other questions about 

18 what’s been presented? Are you expecting them to 

19 comment on this real time? 

20 MR. WESTPHALEN: If they can, but 

21 certainly written comments after more careful 

22 consideration are welcome as well. 

23 MR. BROOKMAN: This is fairly complicated 

24 here.

25 MR. AMRANE: Karim Amrane. Just a general 
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1 statement about the NRCan standards. The way by 

2 which an NRCan establish a standard is very 

3 different than the DOE process. And I have to say 

4 not all the standards are -- they don’t go through 

5 the same rigor and economic analysis that DOE does. 

6 So again, consider, this is the baseline. I would 

7 like to caution you about that. I mean it’s not 

8 necessarily done the same way. 

9 MR. WESTPHALEN: Okay. 

10 MR. BROOKMAN: And nor would you make a 

11 global statement about the outcome at this point? 

12 MR. AMRANE: No. 

13 MR. BROOKMAN: Okay. Thank you. I just 

14 thought I’d try.

15 MR. WESTPHALEN: And request for comment. 

16 Obviously, DOE seeks input from stakeholders about 

17 the proposed efficiency levels. DOE also seeks 

18 input from stakeholders on appropriate maximum 

19 technologically feasible efficiency levels. And 

20 there again, I don’t expect all that information to 

21 come right here and now. 

22 MR. LLENZA: This is Charles Llenza of the 

23 Department. Your comments are always welcome until 

24 the close of the comment period. After that, the 

25 Department has a discretion in terms of doing what 
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1 they need to do with the comments. And so don’t 

2 feel compelled that you have to answer all the 

3 questions here today. If you need more time to 

think about it, we would appreciate it by the 18th 4 , 

5 as opposed to the drop dead date. 

6 MR. BROOKMAN: Okay. Then proprietary 

7 designs. 

8 MR. WESTPHALEN: Okay. Proprietary 

9 designs. DOE will evaluate all design options that 

10 are commercially available or present in working 

11 prototypes, including proprietary designs. However, 

12 consideration of proprietary designs will be limited 

13 if they represent a unique path to achieving a 

14 particular efficiency level. Obviously, the 

15 confidentiality of manufacturers will be maintained 

16 if we find out something about a great new 

17 technology that one of you gentlemen has developed 

18 that cuts the energy use in half, then obviously, if 

19 you own that, we can’t really be divulging it. Also 

20 we wouldn’t be able to base the standard on that.

21 So the request for comment here is item 5-

22 8, are there proprietary designs that DOE should 

23 consider in the analyses for any of the equipment 

24 under consideration? If so, how should DOE acquire 

25 the cost data necessary? Conversely, are there 
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1 proprietary designs that DOE -- that should not be 

2 considered? Which products use these designs? 

3 MR. BROOKMAN: Karim. 

4 MR. AMRANE: Karim Amrane, AHRI. We don’t 

5 believe that proprietary designs should be 

6 considered in this analysis, for the simple reason 

7 that if it is proprietary, it’s not going to be 

8 something that others are going to be able to use, 

9 so how can you use proprietary design to establish a 

10 standard, and ask others to meet a standard? So 

11 again, I don’t think it’s something that DOE should 

12 look at when establishing minimum federal standards. 

13 MR. BROOKMAN: Other comments on -- 

14 related to proprietary designs? John. 

15 MR. BROADBENT: Yeah, I would agree -- 

16 John Broadbent -- I would agree with Harvey. 

17 MR. AMRANE: I’m not Harvey.

18 MR. BROADBENT: I’m sorry, you’re over 

19 there.

20 MR. BROOKMAN: John, I do that at least 

21 once a meeting, so that made me feel a lot better. 

22 Go ahead. 

23 MR. BROADBENT: So what is the distinction 

24 between proprietary and unique? You said that the 

25 proprietary designs would only be considered if 
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1 they’re not a unique path. And I’m uncertain what 

2 the difference between the two. 

3 MR. WESTPHALEN: Well, I think if a design 

4 is patented and other manufacturers can’t use it --

5 MR. BROADBENT: That’s proprietary or 

6 unique?

7 MR. WESTPHALEN: That could be both. A 

8 design that is unique is something new and novel -- 

9 and in some of these cases, it might be a component 

10 vendor that has a proprietary design that that 

11 component vendor has that design, but all the 

12 manufacturers can use it, there is still questions 

13 about the suitability of using that kind of a design 

14 because of the obvious financial implications. 

15 MR. LLENZA: This is Charles Llenza, 

16 Department of Energy. I think we’re not necessarily 

17 interested in the proprietary design because that 

18 would be difficult to set a standard to that level. 

19 I think what we’re more interested in is in the 

20 design options. If the proprietary design has 

21 certain design options that we did not consider, 

22 where the design options themselves are not 

23 proprietary, then the Department may look at those 

24 design options and add them to the list of 

25 components that you could use in creating TSL levels 
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1 at some point for different classes of equipment. 

2 So I’m not sure -- not that I’m not sure -

3 - I don’t think it’s from the design of the 

4 equipment itself in terms of how this particular 

5 equipment is designed this way, whatever, but it’s 

6 actually in the design options. And I guess the 

7 interest from the Department’s point of view would 

8 be if we missed something that’s out there, that’s 

9 put together in a different way, then it becomes 

10 proprietary, but then we can use the component parts 

11 of it to improve on the technology side of the 

12 house. That’s the only angle I would see.

13 MR. BROOKMAN: Yes, Daryl. 

14 MR. ERBS: So I guess my comment would be, 

15 I think what we could do is help answer questions -- 

16 if you’re unsure whether a particular design feature 

17 is proprietary, in other words, is there IP around 

18 it, we, as manufacturers, tend to keep track of who 

19 has patents on what, and maybe that would be helpful 

20 to you to say, this particular feature that you see 

21 in one of the units you purchased and you tear down 

22 is something that’s only available to one 

23 manufacturer, and maybe that would lead to some 

24 broader discussion around, well, are there alternate 

25 technologies or approaches that would get you the 
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1 same end result or same net impact. In some cases 

2 the answer is yes, in other cases, it may be no, so 

3 all I can offer is that we would work with you as 

4 you go through the analysis to help identify those. 

5 MR. BROOKMAN: Sarah. 

6 MS. WIDDER: Daryl kind of covered it. I 

7 just wanted to flip the discussion a little bit, and 

8 talk about -- I think that the Department does 

9 sometimes consider or think about proprietary 

10 designs if, as Daryl said, there’s alternate paths 

11 to reach the same net result. Because often we set 

12 these efficiency levels and don’t specify a 

13 particular design path to reach those levels. So 

14 manufacturers can use proprietary designs to reach 

15 them.

16 I think that second bullet that we’re 

17 discussing right now is just saying the Department 

18 wants to insure that there’s not an efficiency level 

19 that’s set where the only way to reach that level is 

20 a specific proprietary design. There could be three 

21 separate proprietary designs that reach that level, 

22 as long as everyone can get there. 

23 MR. BROOKMAN: Okay. That’s good. Final 

24 comments on this? 

25 MR. WESTPHALEN: Okay. I think that 
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1 covers engineering analysis and now Sarah Widder 

2 will move on to test procedures. 

3 TEST PROCEDURES: BACKGROUND AND POTENTIAL CHANGES 

4 MS. WIDDER: Thanks, Detlef. Good 

5 afternoon everyone. So we’ve brought up a couple 

6 issues relative to the test procedures so far, and 

7 I’m just going to try and consolidate them all here.

8 First, the current DOE test procedure, as 

9 many of you know, is AHRI 810-2003 that was 

10 incorporated in the 2006 en masse test procedure 

11 rulemaking. That test procedure also references the 

12 ASHRAE Standard 29, 1988 version, which was 

13 reaffirmed in 2005, as the method of test. 

14 And additionally, in that rulemaking DOE 

15 adopted a revised method for calculating the energy 

16 consumption, and they did that because they believed 

17 that there was some room for misinterpretation of 

18 how to normalize the energy consumption to 100 

19 pounds of ice, and there was some belief that some 

20 of the ice could be discarded in a different test 

21 and you would reach a higher than representative 

22 energy consumption value. And so that revised 

23 calculation is something we’re also going to be 

24 examining in revising the test procedure, whether 

25 that’s still necessary.
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1 And that will probably be discussion for 

2 the test procedure NOPR public meeting, but I just 

3 wanted to bring it up now. 

4 As was mentioned already, AHRI and ASHRAE 

5 have updated their test procedures, AHRI to 810-

6 2007, ASHRAE has subsequently updated to Standard 

7 29-2009, and both those test procedures reflect the 

8 same changes and are in agreement. 

9 And then this last bullet, I wanted to 

10 present that we’re not considering treating standby 

11 and off mode in the DOE test procedures at this 

12 time. There’s been some discussion about how that 

13 could be incorporated, but right now that’s not 

14 being proposed. 

15 Just a little bit more on updating to the 

16 current industry test procedures. Our authority 

17 comes from EPCA which states that if AHRI standard 

18 810-2003 is amended, the Secretary shall amend the 

19 DOE test procedure to be consistent unless to do so 

20 would not meet the EPCA requirements of the test 

21 procedure. DOE believes that AHRI - that updated 

22 AHRI test procedure -- meets those requirements and 

23 is considering adopting it. 

24 The specific changes to AHRI 810-2007 

25 expand the test procedure to apply to cube type as 
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1 well as continuous type ice-makers up to a capacity 

2 of 4,000 pounds per day, which expands from the 

3 previous test procedure which ranged from 50 to 

4 2,500 pounds per day, as has already been said. The 

5 ASHRAE standard 29-2009 reflects the same changes. 

6 DOE is requesting comment on updating to 

7 the revised versions of the industry test 

8 procedures.

9 MR. BROOKMAN: Karim. 

10 MR. AMRANE: Sure. Karim from AHRI. We 

11 support that. 

12 MS. WIDDER: Thank you, Karim. 

13 MR. BROOKMAN: Good thing. We have it on 

14 the record. Joanna. 

15 MS. MAUER: Joanna Mauer. I was just 

16 wondering if you could describe a little bit about 

17 standby and off mode, what that would mean for ice18 makers. In other words, kind of, what is an ice19 maker doing when it would be in standby or in off 

20 mode as you see it? 

21 MS. WIDDER: Sure. What we’ve looked at -

22 - I will let Daryl comment after what I’ve -- my 

23 interpretation. What we’ve looked at in terms of 

24 standby and off mode for ice-makers, they are 

25 typically plugged in all the time, and so there’s 
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1 not really an off period, as there is for some more 

2 seasonal equipment, but there is sort of a standby 

3 mode where the ice-maker is not actively producing 

4 ice, and is just storing the ice for dispensing or -

5 - and then there’s a bin level or some sort of 

6 mechanism that measures when more ice needs to be 

7 made. And while it’s not making ice, we’ve termed 

8 that sort of -- we don’t want to use standby, 

9 because it’s not -- that’s a very legislative word, 

10 so more off cycle or non-ice-making energy 

11 consumption. 

12 And we’ve thought about that being 

13 quantified in the storage bin effectiveness test, if 

14 that were to be considered. And we’ll discuss a 

15 little bit more how we’re going to use that in the 

16 energy use analysis later in the presentation. But 

17 as far as the test procedure, what we identified as 

18 a possible means to address it would be the storage 

19 bin effectiveness. 

20 MR. BROOKMAN: Daryl, you want to add 

21 anything? 

22 MR. ERBS: Yeah. Just in terms of what 

23 standby mode would actually represent, I mean I just 

24 did some very simple back of the envelope 

25 calculations. I mean, the worst case is an ice 
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1 machine that’s got an electronic control because 

2 then there is a little bit of loss in the 

3 transformer, whatever the power supply is for it. 

4 Basically, when an ice machine isn't 

5 making ice, everything’s turned off, so you would 

6 only have that loss in the power supply. There are 

7 some ice machines that are fairly mechanical, 

8 they’re zero. So I would not even put -- but if you 

9 look at one where you would have electronic control, 

10 I mean it’s down below half of a percent, if you 

11 look at how much of the time an ice machine is 

12 typically on, how much it’s off, and then what does 

13 that off time energy represent relative to the 

14 energy it uses when it’s on, to me that’s down at a 

15 level that again, I don’t feel that it would justify 

16 the additional test procedures to try to encourage 

17 more efficient transformers so when it’s off it’s 

18 using a little bit less electricity. 

19 MS. MAUER: Thanks, Daryl. Maybe just a 

20 follow up. Are the storage bins typically 

21 refrigerated or -- 

22 MR. ERBS: No, they’re not. Storage bins, 

23 that’s a whole different topic. Storage bins -- and 

24 they range radically in terms of their efficiency 

25 based on their size. It’s just simple physics, the 
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1 bigger the bin, the more efficient it is because 

2 you’ve got more volume to surface area. And so 

3 there’s a range. And there are, you know, there --

4 it’s not insignificant the amount of ice that melts, 

5 but I mean that’s the way it is. But they don’t use 

6 any electricity. It’s purely just loss of product 

7 due to heat transfer. 

8 MR. LLENZA: This is Charles Llenza, 

9 Department of Energy. For the self-contained units, 

10 that’s the same issue?

11 MR. ERBS: In terms of melting of the ice? 

12 MR. LLENZA: In terms of the electricity 

13 used.

14 MR. ERBS: Oh, yeah. 

15 MR. LLENZA: They’re all non-refrigerated? 

16 MS. WIDDER: Yes. 

17 MR. ERBS: Correct. 

18 MR. LLENZA: Both classes? 

19 MR. ERBS: Correct. 

20 MR. LLENZA: Okay. 

21 MR. BROOKMAN: Yes, please, your name for 

22 the record? 

23 MR. MAURITZ: Donald Mauritz, Berkeley 

24 National Lab. Just getting back to the standby 

25 issue for a second. You mentioned it was a very 
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1 small percentage or fraction of a percentage. Can 

2 you translate that into wattage? Is it a watt or 

3 two, or are we talking ten watts? 

4 MR. ERBS: It’s probably on the order of 

5 ten watts. 

6 MR. BROOKMAN: Okay. Thanks. 

7 MS. WIDDER: All right. We’ll keep going 

8 then. In addition to the changes that were 

9 incorporated into the updated ASHRAE and AHRI test 

10 procedures, there are a couple of other issues that 

11 the Department is looking at from a test procedure 

12 perspective, most of which have been mentioned here, 

13 but have a little bit different take now that we’re 

14 looking at how do we test these. 

15 One would be the testing of larger 

16 capacity equipment beyond the 4,000 pounds per day 

17 capacity range. If we chose -- if the Department 

18 chose to cover those equipment, would they be 

19 applicable under the current test procedure? And 

20 the DOE understands that these larger capacity 

21 machines should not have a problem being tested 

22 using the methods defined in AHRI 810-2007 and 

23 ASHRAE, the current ASHRAE standard. 

24 DOE requests comment on applying the AHRI 

25 810-2007 test procedure, if there’s any issues that 
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1 we should be aware of with larger capacity or 

2 perhaps more unique type machines, tube type 

3 machines, that would have difficulty being tested 

4 under this method. 

5 MR. BROOKMAN: John. 

6 MR. BROADBENT: John Broadbent. The only 

7 issue -- you have Intertech doing the testing. I 

8 don’t know how big their equipment goes, so that 

9 would be the only potential limitation. 

10 MS. WIDDER: Thank you. 

11 MR. AMRANE: Karim Amrane, AHRI. I think 

12 I made the comment before that we don’t see the need 

13 to go beyond 4,000. We think it’s industrial and 

14 outside the scope of this rulemaking. 

15 MS. WIDDER: Yes. Another issue. This 

16 has already been raised and we have already received 

17 comments about the issue of either combining 

18 condenser water use and potable water use used in 

19 making ice into a singular total water use metric, 

20 or keeping them separate. There are reasons that 

21 you would do either, and I know there has been 

22 comments that they should stay separate, and this is 

23 only if the DOE chooses to regulate potable water 

24 use or has the authority to regulate potable water 

25 use. But we’ll take comments again at this time if 
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1 you’d like to make them about the pros and cons, or 

2 the reasons why you would keep condenser water use 

3 and potable water use separate or combine them into 

4 a singular metric. 

5 MR. BROOKMAN: John. 

6 MR. BROADBENT: If you combine them into a 

7 single metric, and eliminate having them separate, 

8 then installations where they’re using a closed loop 

9 water system, where you’re not really -- I mean 

10 you’re using the water for condensing, but you’re 

11 not throwing it away, that becomes almost 

12 irrelevant, but now you’ve lost visibility to the 

13 potable water use. So I don’t know that it makes 

14 sense to combine them. I think it makes sense to 

15 keep them separate. 

16 MR. BROOKMAN: Thank you. 

17 MS. WIDDER: All right. Another issue 

18 that’s been brought up is the issue of testing 

19 remote condensing units. DOE has recognized an 

20 inconsistency in the way energy use of remote 

21 condensing ice-makers is reported. Some ice-makers 

22 that are sold with a dedicated remote condensing 

23 unit are reported with the energy use of the ice 

24 making head, the compressor and the condenser. 

25 Other ice-makers that are sold to specifically be 
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1 hooked up to a remote rack system only the energy 

2 use of the ice making head is reported. So that, as 

3 has been mentioned, is much lower than the 

4 compressor and condenser energy use. 

5 And right now, those are not 

6 differentiated, and so the DOE is recognizing the 

7 need to perhaps specify further the way in which 

8 these different types of remote condensing ice9 makers are tested. 

10 And the DOE has developed three potential 

11 approaches to address this issue. The first would 

12 be a calculation method that applies a default 

13 factor to the ice making head energy consumption, 

14 that would be representative of the remote rack 

15 condenser use, and that would be similar to the AHRI 

16 1200 test procedure, which has developed a table of 

17 EERs, energy efficiency ratios, that could be 

18 applied to the heat load of the ice-maker and you 

19 could come up with a representative factor based on 

20 the heat load of the ice-maker. 

21 The second would be a measurement method 

22 whereby the ice making head is hooked up to a 

23 dedicated remote compressor and condenser system of 

24 sufficient capacity, and although that wouldn’t be 

25 representative of how that ice making head would be 
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1 used in the field, in conversations with 

2 manufacturers, that seems that’s the way it’s tested 

3 today, it is just hooked up to a dedicated remote 

4 compressor. And that could be consistent across all 

5 that class of equipment. 

6 And then the third option would be to 

7 continue to report only the ice making head energy 

8 use of those remote condensing systems, and not 

9 report the energy use of the remote rack or the 

10 remote condenser and compressor. And that would -- 

11 any of these, actually, but specifically the third 

12 option, would require a separate equipment class so 

13 they would not be compared to a similar ice making 

14 head that has a dedicated remote compressor and 

15 condenser when that energy use is reported. 

16 And so the request for comment, DOE 

17 requests comment on how the energy consumption of 

18 ice-makers that are designed to be connected to a 

19 remote rack should be calculated in the DOE test 

20 procedure. Specifically, the pros and cons of the 

21 three methods proposed, or any additional methods 

22 that manufacturers or stakeholders feel would be 

23 more representative. And also perhaps whether or 

24 not these methods would require a separate equipment 

25 class, or should require a separate equipment class. 
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1 MR. BROOKMAN: Joanna. 

2 MS. MAUER: Joanna Mauer. Just a quick 

3 clarification. These potential options are to 

4 address ice-makers that are connected to rack 

5 systems, specifically, not ice-maker that are 

6 connected to dedicated remote condensers?

7 MS. WIDDER: Correct. Correct. 

8 MS. MAUER: And maybe just a question for 

9 the manufacturers. Are ice-makers with remote 

10 condensing units always sold with the remote 

11 condensing unit as a package? 

12 MR. BROADBENT: This is John Broadbent. 

13 Yes.

14 MS. MAUER: Thank you. 

15 MR. BROOKMAN: So Daryl, please. 

16 MR. ERBS: So, my comments would be for 

17 this to really work, I think you’re going to have to 

18 have a test method. So number one, which is purely 

19 calculation, to me doesn’t make sense because 

20 different ice making heads could have different 

21 efficiencies in terms of how they converted the 

22 refrigerant supplied by the rack into ice. And if I 

23 understand number one, you would just treat them all 

24 the same. You would have the electrical use that 

25 they consumed at the ice making head, but you 
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1 wouldn’t differentiate based on how much refrigerant 

2 they consumed to make the ice, because you’re not 

3 doing any testing. 

4 MS. WIDDER: No, I’m sorry. To clarify 

5 point one. It would be similar to the third point, 

6 where you’re testing the ice making head, and so 

7 that is a measurement, and then applying -- and then 

8 measuring the refrigerant flow and use that to -- 

9 MR. ERBS: But I don’t think the 

10 refrigerant flow is measured today I guess is my 

11 point.

12 MS. WIDDER: It’s not, that’s correct. 

13 That would require more test methods. 

14 MR. ERBS: So for this to work, I think it 

15 would be a test method that requires measuring the 

16 refrigerant flow to the ice making head, and then 

17 you could combine that with some assumption around 

18 the efficiency of the rack. Again, just -- that’s 

19 the approach that was taken for the display case. 

20 MS. WIDDER: Right. 

21 MR. ERBS: That makes sense to me, but 

22 it’s -- like in my earlier comment, is -- is it 

23 warranted based on the volume of these. But 

24 technically, you can do it. 

25 MR. BROOKMAN: Karim. 
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1 MR. AMRANE: Karim Amrane, AHRI. A 

2 question, I mean, what’s the incentive here? I mean 

3 are we talking about a lot of units here? Are we 

4 talking about just a few? Why do we want to go -- 

5 is it really necessary to capture those? 

6 MS. WIDDER: I think that’s a question 

7 that I would feed back at you, Karim. We’ve 

8 identified these as for sale in the market. As has 

9 been mentioned previously, we don’t have very robust 

10 shipments data right now, and it seems to be that 

11 these types of remote rack systems are a more recent 

12 product and developed more recently. Since the 

13 flake and nugget machines have increased in 

14 popularity and we’ve noticed it mostly with a flake

15 and nugget ice making head, that then is connected 

16 to a remote condensing rack for a grocery store 

17 application, and to be completely honest with you, 

18 I’m not sure of the shipments per year. I think 

19 you’re correct in thinking that it might be lower 

20 than a self-contained cuber unit, but I think we’d 

21 welcome comments to that extent as well, as to 

22 whether it’s justified to cover these.

23 MR. LLENZA: This is Charles Llenza, 

24 Department of Energy. Like the beverage vending 

25 machine equipment, we had the solid doors and the 
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1 glass doors, but we knew that the industry was 

2 telling us that the glass door shipments were going 

3 to be increasing over time. Therefore, part of what 

4 we’re going here is establishing what we have and 

5 where we’re going. 

6 So if we think that where we’re going is 

7 that these -- that the number of shipments would be 

8 increasing to a significant amount, then that would 

9 be relative to the shipment data and the input from 

10 the industry in terms of where the industry thinks 

11 we’re going with this equipment, and that’s more 

12 relative as opposed to the snapshot we have, which 

13 is there are not too many units right now. 

14 MR. BROOKMAN: So that’s what --

15 MR. BIEL: Jeff Biel. Yeah, absolute 

16 numbers it’s one of the smallest categories that 

17 we’ve seen. As far as where it’s going, it’s tough 

18 to say, but I would have a real tough time seeing 

19 that it would exceed any of the other existing 

20 categories that we’ve been talking about.

21 MR. BROOKMAN: John. 

22 MR. BROADBENT: This is John Broadbent. 

23 And I reflect Jeff’s comment that the sales are

24 really low and the rack systems are pretty much 

25 predetermined, you know, because the ice maker is a 
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1 small part of the overall system. So the rack 

2 system would have already been selected, so we have 

3 no control over that. There’s a lot of different 

4 manufacturers, and there’s a high custom component 

5 to the rack system, so you never really know. 

6 So like for item 2, it would be extremely 

7 difficult to test a given ice-maker with all the 

8 variety of potential rack systems, almost 

9 impossible. 

10 MS. WIDDER: I’m sorry, I should clarify 

11 that as well. That’s not what’s being proposed in 

12 item two. I don’t think ice-makers should be tested 

13 with remote racks, and I’m not aware of many test 

14 labs that have remote racks. This would be taking 

15 an ice-making head that is designed to be sold to a 

16 remote condensing rack, specifically, but hooking it 

17 up instead to a dedicated condenser and compressor 

18 unit that a manufacturer produces which would not be 

19 representive of its energy use in the field, but 

20 would be a way to test it. That’s the second 

21 option.

22 MR. BROOKMAN: What’s left -- Daryl. Go 

23 ahead Daryl. 

24 MR. ERBS: So just from my perspective in 

25 terms of -- is it like the remote condensing going 
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1 to be the next big thing? No, I don’t think so. In 

2 fact, my understanding is that on the retail side -- 

3 I mean these go in the grocery stores almost 

4 exclusively and the only other place would be in 

5 some very large seafood processing, where they 

6 actually need so much ice they would invest in that 

7 kind of a unit. 

8 Grocery stores, if anything, are moving 

9 away from the use of flake ice. They still like to 

10 use it for certain merchandise like fish where 

11 there’s an aesthetic appeal. But a lot of the, like 

12 the produce cases have gone to misting and 

13 refrigerated rail systems, and so where they used to 

14 use flaked ice, they don’t any more. It’s really 

15 just a replacement business for those stores that 

16 continue with their standard approach. 

17 And as we all know, there’s not more 

18 seafood coming out of the ocean, there’s less, and 

19 so I would argue that it’s not a growth area, and so 

20 whatever the volumes are today, they probably not 

21 going to grow significantly in the future. 

22 MR. BROOKMAN: Joanna. 

23 MS. MAUER: Joanne Mauer. I think the 

24 other question I would have is whether there is a 

25 significant number of applications or consumer 
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1 choice of purchasing an ice-maker with a dedicated 

2 remote condenser or if it has a rack system that it 

3 could hook it up to, and in that case, whether there 

4 weren’t standards for products that were connected 

5 to rack systems whether we might see some shift in 

6 the market, even, if the current sales volumes are 

7 low today. Just a question. 

8 MR. BROOKMAN: Daryl, yes. 

9 MR. ERBS: First, I’ll go back to an 

10 earlier comment. At least the ones we sell, it’s 

11 essentially the same ice making head that we would 

12 use for either rack system or a dedicated remote 

13 condensing unit with some minor variations, because 

14 on the rack system they’ll put a pressure regulator 

15 on the suction because the suction heads that run on 

16 the racks don’t necessarily match exactly with the 

17 ice making head. 

18 But they’re going to get essentially the 

19 same efficiency with the ice making head, whether 

20 they buy it to go with a dedicated condensing unit, 

21 or to attach to a rack system. The decision is 

22 really driven by if it’s a new supermarket, they’ll 

23 design it in because that’s a more cost-effective, 

24 and actually energy efficient -- it’s more effective 

25 to do it through the rack system. 
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1 If they’re making flake ice in the central 

2 location, but I mean one of the trends you’ll see in 

3 supermarkets is for other uses of ice. They’re 

4 putting in beverage bars. They’re putting in 

5 bagging systems in the stores -- those aren’t really 

6 amenable to hooking up to a rack, and so I think 

7 there’s just a -- it’s a system design and they’re 

8 probably not making those decisions based on the 

9 energy efficiency rating of the ice machine. It’s 

10 driven by other design considerations for the store. 

11 MR. BROOKMAN: Harvey. 

12 MR. SACHS: Harvey Sachs. The gorilla in 

13 the shadows of this room is the evolution of 

14 refrigeration architectures as we go into the next 

15 round of refrigerant replacements for environmental 

16 concerns. And what I’m hearing for a lot of reasons 

17 beyond Daryl’s comments, is that rack mounted 

18 systems are not likely to be a growth industry 

19 because of refrigerant loss concerns. 

20 I would appreciate industry’s comments on 

21 that so that we’re not putting a lot of resources, 

22 both government and industry, into things which are 

23 not helping us get ready for the next decade, 

24 because the time costs on these things is pretty 

25 long.
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1 MR. BROOKMAN: Comments on that? And also 

2 I’d like to get final comments on these three 

3 potential options if there’s anything else to be 

4 said about them. Daryl. 

5 MR. ERBS: The only, I guess, comment that 

6 I would make on that is the rack systems of the 

7 future will not be the rack systems of the past. I 

8 mean the current trend is actually to go to multiple 

9 refrigerant solutions. CO2 is continuing to grow in 

10 the retail side, and I think that’s going to 

11 continue to be driven by the regulations around 

12 leakage and all of the reporting. And so I think 

13 you’re right that it’s -- but they’ll continue to 

14 exist but it’ll also bring a complexity of -- if we 

15 were to put in place these regulations and CO2 

16 becomes the favorite refrigerant for the low side, 

17 if -- that just adds another layer of complexity to 

18 a fairly small piece of the puzzle. 

19 MR. BROOKMAN: So additional comments on 

20 this slide, because we’re going to move on.

21 MS. WIDDER: All right. Moving on. This 

22 is my last slide, but there is quite a bit of 

23 content here. There’s also a number of issues that 

24 the DOE has been looking into relating to accuracy 

25 or repeatability of the test procedure. And these 
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1 are just a list of several factors. I’ll go through 

2 each of them in more detail, that could affect the 

3 accuracy or repeatability of the test procedures and 

4 at the end we’ll look for comments on that.

5 The first has been brought up already, the 

6 issue of water hardness or total dissolved solids, 

7 minerals in the water affecting the energy use of 

8 the ice-maker, whether that’s a significant impact, 

9 or something that needs to be standardized across 

10 ice-makers based on -- I think the manufacturers 

11 mentioned they designed it for sort of worst case 

12 scenario, but will that change? Will your energy 

13 use change significantly if you have cleaner water, 

14 or is there a type of filter technology that’s being 

15 put on to affect water hardness from the potable 

16 water side? 

17 Another issue is the ice quality, 

18 specifically with flake and nugget machines. 

19 There’s a range of percentage water versus 

20 percentage ice that can be produced, and is there a 

21 need to standardize around a certain percentage of 

22 water for those equipment classes, or perhaps 32 

23 degree ice in all cases with no water content, and 

24 use some sort of calorimetry test that’s already 

25 part of ASHRAE to standardize to that level for 
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1 flake and nugget machines, just to make sure we’re 

2 comparing apples to apples? For those types of 

3 machines, if you had a machine that produced 30 

4 percent water, that clearly would use lots less 

5 energy than one that produced ten percent water with 

6 ice for the same amount of -- same volume of water 

7 in.

8 The ice temperature, also, if you produced 

9 colder ice, that will use more energy than if you 

10 produced just 32 degree ice, and is there a need to 

11 standardize around ice temperature? That would sort 

12 of go into ice quality as well, but is there a 

13 significant market share or a need for colder ice? 

14 Also, specified in the test procedure is a 

15 25-foot length of refrigeration line. Is there a 

16 need to specify a specific diameter or insulation 

17 level? Right now it’s as per manufacturer 

18 specification. As those will both impact the energy 

19 use of the machine, perhaps those are types of 

20 design options, and so they don’t need to be treated 

21 specifically or explicitly standardized, but they’re 

22 just factors that the DOE has recognized will affect 

23 the results. 

24 Also the condenser air inlet temperature 

25 is specified, but typically, right now in the test 
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1 procedure it’s a singular measurement and in other -

2 - in other appliances that use condenser inlet air 

3 temperature as a value for cooling, they have a grid 

4 measurement that’s more accurate to make sure you’re 

5 having the proper temperature of air inlet, having 

6 it of the specified accuracy, and is that warranted 

7 here for air cooled machines. 

8 And then the last point also comes out of 

9 other appliance rulemakings, where clearance around 

10 the side of the appliance or above the appliance has 

11 become an issue. There are some taller ice-makers 

12 and right now there’s a test temperature sensor that 

13 would test the ambient air temperature a foot above 

14 the ice-maker. And is there issues if that test 

15 temperature is then at the ceiling of the test room, 

16 will that affect the accuracy of the results? Is 

17 that an issue? Is that done today, and what’s done 

18 to address these? 

19 MR. BROOKMAN: So comments on these 

20 potential sources of inaccuracies and potentially 

21 others. I guess surrounding what the impact would 

22 be.

23 MS. WIDDER: Yes. And I’ll just clarify, 

24 now would be helpful but also in written comments if 

25 that’s more appropriate.
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1 MR. BROOKMAN: John. 

2 MR. BROADBENT: John Broadbent. I’ll 

3 comment on some of these. Water hardness will have 

4 minimal energy impact on the short term test, would 

5 have effects long-term on how a machine gets dirty, 

6 how often you have to clean it, things like that, 

7 reliability. 

8 Ice quality is a very tricky one. When 

9 someone goes to get a glass of ice, the ice that has 

10 the lowest energy content would actually be the most 

11 efficient, because they’re just going to fill their 

12 glass up, not looking for X amount of BTUs, they’re 

13 looking to fill their glass up. So if they have the 

14 lowest energy density ice in their cup, they’ll 

15 actually use the least amount of ice. So that 

16 argument, I would say, low quality is actually good. 

17 So it’s very tricky to try and -- and I don’t know 

18 if there’s a right answer for that, but it’s a very 

19 tricky one. And I can address that further in our 

20 written comments. 

21 Ice temperature, everybody pretty much is 

22 at 32 degrees. I’m not aware of any ice that’s 

23 severely subcooled. 

24 And I don’t believe any of those other 

25 criteria are going to have a significant impact. 
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1 MS. WIDDER: Thank you. 

2 MR. BROOKMAN: Other comments? Okay. 

3 MS. WIDDER: Next we welcome Alan Cooke 

4 from Pacific Northwest National Lab to talk about 

5 Markups and Equipment Price Determination.

6 MARKUPS AND EQUIPMENT PRICE DETERMINATION 

7 MR. COOKE: Good afternoon. I’m going to 

8 talk about markups. In the analyses that are going 

9 to follow downstream, life cycle cost and payback 

10 period, and also the national impact analysis, we 

11 use the price that consumers pay for the equipment. 

12 What Detlef talked about estimating earlier is the 

13 actual production cost, and then in Detlef’s 

14 analysis he’ll also add a markup for the 

15 manufacturer to reach a manufacturer selling price. 

16 But in this stage of the analysis, we will 

17 look at the markup that is added by the distribution 

18 chain. In a minute I’ll go to another slide that 

19 will show the three channels, but I thought I would 

20 describe them first. 

21 We’ve defined three different distribution 

22 chains, and we’ll give you an opportunity to comment 

23 on them later, after I get done here, and also in 

24 writing. 

25 The first one is a direct manufacturer to 
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1 the consumer chain. We’ve described that as the 

2 national accounts chain. 

3 MR. BROOKMAN: You want to advance the 

4 slide?

5 MR. COOKE: I’ll advance it in just a 

6 moment. The second one is a chain where it goes 

7 from the manufacturer to a distributor or a 

8 warehouse, or whatever you want to call them, 

9 wholesaler, and then it goes to the consumer. 

10 And then the third one is a chain where 

11 some sort of a contractor actually initiates it, and 

12 they buy it from the distributor who buys it from 

13 the manufacturer. So you have a one step chain, a 

14 two step chain, and a three step chain. 

15 What we will do in our analysis is we will 

16 obtain information from the distributor industry, 

17 through their national trade associations or 

18 wherever we can find the information to try to 

19 define what the costs are for the distributors. And 

20 that will become one input. 

21 We’ll also go to the census bureau and 

22 find information about what some of the various 

23 contractors that are involved in this. It might be 

24 the HVAC type of -- HVAC and refrigeration type of 

25 contractors, whatever it might be. So we will 
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1 define a couple or three cost elements. 

2 And then the question is, in order to 

3 apply this to the actual manufacturer price to get a 

4 consumer price, how do we weight those to create one 

5 factor? So what I’ve shown you here is somewhat 

6 analogous to what we’re doing in the commercial 

7 refrigeration rulemaking right now, where we’ve 

8 defined two different -- where there’s really two 

9 different types of products, one of which is remote 

10 condensing, and one of which is fully self11 contained. 

12 Self-contained in the CRE market, you can 

13 just bring it in and plug it in and you’re pretty 

14 much done. So that’s a completely different kind of 

15 a market than the remote condensing. And these are 

16 the kinds of numbers that we’re looking at right now 

17 for trying to match those up -- actually it’s not --

18 but this is what we proposed in a framework document 

19 for weighting those up in that particular 

20 rulemaking. 

21 What I’m going to be looking for here 

22 today, and also in the written comments is, what is 

23 the appropriate way to slice this up? So I’m 

24 building up my markup factor in a way that resembles 

25 your market. Should it be -- should I be building 
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1 it up for each product class? Are there breakouts 

2 like the differentiation between remote and self3 contained that would make sense? And what is the 

4 percentage that goes to each of these chains? 

5 We use two different types of markups in 

6 this process. The first one we call the baseline 

7 markup. It’s designed to recover all of the costs 

8 of the distribution chain. So it will be applied to 

9 the baseline unit. The second markup is called the 

10 incremental markup, and it’s designed to capture 

11 those cost components that vary with the price of 

12 the equipment. What might go up as the equipment 

13 gets more expensive? And there aren’t very many of 

14 them, but we’ve pretty much assumed that most of the 

15 distributor chain costs are being captured in this 

16 baseline markup. 

17 So we do have some questions that we hope 

18 to get some feedback on. First of all, are those 

19 three distributor chains, the distributor, and then 

20 the distributor-contractor, are those the 

21 appropriate distribution channels for commercial ice 

22 making equipment that’s covered under this 

23 rulemaking? 

24 Second, DOE requests information on 

25 whether the distribution channels differ by the 
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1 types of buildings that comprise the market for 

2 automatic commercial ice-makers, mainly food sales, 

3 food service, health care facilities, lodging 

4 facilities and others, so do they differ by that or 

5 is it all the same? 

6 Number three, do you like the use of that 

7 baseline versus the incremental markup? Is there a 

8 different approach that you would like us to use? 

9 The fourth item is DOE seeks comments on 

10 the sources of the food service distribution chain 

11 data that can actually be used to compile the 

12 markups for this equipment. Right now the only good 

13 source of data that I’m aware of comes from a group 

14 called HARDY, which covers heating, air conditioning 

15 and refrigeration equipment, so it’s not really 

16 specific to this, but right now it’s the only source 

17 that I have identified, so I’m hoping that you have 

18 some ideas where I can find this data. 

19 And the last one on this list, is DOE 

20 seeks comments on appropriate transportation and 

21 shipping costs to include in the analysis and 

22 whether these costs are likely to vary for higher 

23 efficiency equipment. I might also add we might be 

24 welcoming your comments on where these costs are 

25 actually included. Are they actually included in 
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1 the cost that the manufacturer is charging to the 

2 distributors? Or are they added on later on in the 

3 distribution chain? 

4 MR. BROOKMAN: Jeff. 

5 MR. BIEL: Do we have another day to 

6 discuss this one? I mean the way ice machines go to 

7 market, it’s quite complicated, and I don’t see a 

8 big issue with the national account distributor. 

9 And when you say contractor, I’ll just throw the 

10 term dealer in there as well. There’s a lot of 

11 different terms. 

12 As far as the percentages, I think that’ll 

13 probably be better addressed through the written 

14 comments, and I personally don’t see a need to split 

15 self-contained and remote condensing, because the 

16 lines get very blurred between national account 

17 distributor and senior contractors, so you can 

18 probably simplify that. 

19 And I’ll be happy to provide a lot of 

20 other comments in regards to your other items. Item 

21 7.5, there’s really no additional shipping cost that 

22 should be included with energy efficient equipment, 

23 so it would be the same, pretty much, whether it’s 

24 high efficiency or not. 

25 MR. BROOKMAN: Along the distribution 
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1 chain, does it apply uniformly where? The shipping 

2 costs, where they get tagged? It’s all over the 

3 place?

4 MR. BIEL: It can vary, yeah. 

5 MR. BROOKMAN: Okay. Thank you. Anybody 

6 else on the manufacturing side wish to comment here? 

7 Yes.

8 MR. BROADBENT: John Broadbent. One of 

9 your distribution chains was it went from 

10 manufacturer to distributor directly to the end 

11 user. That’s very rare. Our distributors get in 

12 trouble if they do that. So it typically goes from 

13 the distributor to a dealer to the end user. 

14 MR. BROOKMAN: Is that because the 

15 installation is complicated? 

16 MR. BROADBENT: The reason for the 

17 distributor is to provide local service, local 

18 inventory of product, because you never know what a 

19 given end user’s site is going to want, you’ve got 

20 to have it close, and a high percentage of sales are 

21 replacement sales, and so they need something right 

22 away, and so they can’t wait a week for it to be 

23 shipped from the factory. It needs to be local. So 

24 historically, there is a distributor and a dealer in 

25 place in a territory. 
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1 MR. BROOKMAN: I see. Okay. You can see 

2 as you look at this comment box, several different 

3 comment requests. I think we’ve begun to address 

4 some of them. Take a quick peek, see if there’s 

5 anything else to be said at this point. Okay. 

6 MR. COOKE: Okay. Then we’re going to 

7 have Michelle Britt back up here, Michelle Britt 

8 from the Pacific Northwest National Laboratory. 

9 ENERGY USE CHARACTERIZATIONS 

10 MS. BRITT: To try to be brief, I’m going 

11 to skip ahead some of the background information and 

12 so if I leave something out for somebody who’s new 

13 to the process, please ask, but if there are no 

14 questions I’ll go ahead and skip ahead. Energy use 

15 characterization focuses on characterizes the use of 

16 the equipment, both in terms of energy efficiency 

17 and water use, as it will be used installed, or in 

18 the field, based on different efficiency levels. 

19 So, as you can imagine, we have a 

20 significant number of assumptions that need to be 

21 determined to work into this analysis. We need 

22 assumptions regarding distribution, both in the 

23 number and type of ice-makers. Here we get back 

24 into the building occupancy issue. We need to 

25 understand the relationship, if there is one, 
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1 between building occupancy type and utilization 

2 factors. 

3 And the energy use impacts of the 

4 utilization factors that result in down-cycling. We 

5 touched on that a little bit earlier. If there is, 

6 for example, a 35 percent utility factor, that other 

7 65 percent of the time what are we looking at in 

8 terms of energy use. If it is ten watts, we’ll 

9 assume ten watts, but to project the -- to project 

10 out on energy use characterization, we need to know 

11 what’s happening during that down cycling time. 

12 And finally, the impacts of the indoor 

13 machines on heating and cooling loads. Is there 

14 something that we -- that could be substantial 

15 enough that we need to look at whole building 

16 modeling? So we need to be able to make assumptions 

17 with regards to the percent of machines that use 

18 remote compressors, remote condensers. Are they in 

19 different types of buildings? Is there a 

20 relationship between efficiency levels, harvest 

21 ranges, et cetera? What are those relationships so 

22 that we can understand the magnitude of impacts, if 

23 there is one, on the heating and cooling loads of 

24 the building? 

25 With regards to developing some of these 
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1 assumptions, what we’ve looked at so far in the 

2 literature review, we’ve looked at any ACEEE papers 

3 that have been produced on this topic. We’ve gone 

4 back and looked at manufacturers’ input to the CEC 

5 when they originally developed the standard. And 

6 we’ve looked at ADL, now NCI, reports that go back 

7 to 1993, when they developed some initial 

8 assumptions based on 1990 numbers. 

9 So as you can imagine, if there’s an 

10 opportunity, if we need to update these assumptions, 

11 we’d like to get that data so that the analysis is 

12 appropriate to today’s ice-maker trends. 

13 MR. BROOKMAN: Why are these numbers so 

14 uniform? 

15 MS. BRITT: That -- two of the things that 

16 we’ve seen change in the assumptions between 1993, 

17 which was actually 1990, and today, we’ve seen the 

18 distribution, the number of units per building 

19 change from fractional use per building, to whole 

20 numbers per building. In 1990, it was assumed one 

21 ice-maker per every ten buildings. By 2008, it was 

22 assumed one ice-maker per building, with the 

23 exception of health care that was at five. 

24 We saw similar differences with 

25 utilization factors. In the early 1990 assumptions, 
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1 it was a point five utilization factor that was 

2 assumed everywhere except for hotels, which are 

3 lodging, which was at point three. And the most 

4 recent studies, in 2008, NCI contacted manufacturers 

5 to verify those numbers at that time, came up with a 

6 constant of point five across all building types. 

7 MS. MAUER: Joanna Mauer. Just so I 

8 understand. The utilization factors are supposed to 

9 represent the percentage of time the ice-maker is 

10 actually making ice? 

11 MS. BRITT: Yes, I apologize. So yes, if 

12 it’s a 2,000 pound machine, it was actually only 

13 needed to make 1,000 pounds per day. 

14 MR. BROOKMAN: Okay. 

15 MS. BRITT: I’ve summarized our data needs 

16 to make correct assumptions, and I have questions 

17 up.

18 MR. BROOKMAN: So you can see the comment 

19 box. Let’s hear from folks on these.

20 MR. SACHS: Well, Doug is not looking 

21 around.

22 MR. BROOKMAN: Sorry. 

23 MR. SACHS: Harvey Sachs. The flip side 

24 of the question of whether ice making machine 

25 operation is a negligible impact on building space 
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1 conditioning loads, is whether alternative 

2 architectures have potential beneficial impacts. 

3 And that will be quite specific to the architecture 

4 and to the building use, for example. The impacts 

5 of water loops might be quite different in a 

6 convenience store, a fast food restaurant, a sit7 down restaurant, and a hotel. So I don’t think, 

8 personally, it’s worth getting too deeply into the 

9 simulation games, but it might be worth thinking 

10 about the differences between uses that lead to 

11 beneficial use of the waste energy versus those that 

12 don’t for some specific end-member type buildings. 

13 MR. BROOKMAN: Thank you. Yes, Daryl. 

14 MR. ERBS: I guess I can make a couple of 

15 comments. The first one is I truly don’t believe 

16 that all end use segments are at point five. I know 

17 of some that are higher than that. I know of some 

18 that are lower than that. I couldn’t give you a 

19 number for all of them. I don’t know how you get 

20 that number. So I’m not sure I have a very good 

21 suggestion for how to alter that. 

22 And I don’t know how sensitive your 

23 analysis is to variations by segment in that number, 

24 so it would -- I guess I’d want to know how much 

25 does it really matter to the end result of this 
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1 rulemaking, before I’d even be motivated to try to 

2 dig up some more information for you. It’s not an 

3 easy thing to do. 

4 MR. BROOKMAN: Can you summarize why 

5 you’re seeking this data?

6 MS. BRITT: Right. As the energy uses get 

7 calculated, if we’re looking at -- if we do go into 

8 looking at it by building type, then we use the 

9 CBEC’s numbers of square footage by building type to 

10 extrapolate out the energy use by the building type. 

11 And again, if there’s a relationship there between 

12 whether they’re water cooled or air cooled, and 

13 whether they use the remote equipment, that’s when 

14 it becomes -- may well become significant. 

15 MR. BROOKMAN: Okay. John. John? 

16 MR. BROADBENT: Yeah. The duty cycle, 

17 utilization is going to be a function of the 

18 equipment that was purchased. So you can buy a 

19 machine that’s way too big for your needs, and it’s 

20 going to have a very low utilization factor. Or you 

21 can buy one that’s too small, and you’ll have a very 

22 high utilization factor. So it’s really a function 

23 of what -- and the other factor is, did they buy it 

so they wouldn’t run out of ice on July 4th 24 , because 

25 that’s what people do, they want to have 100 percent 
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utilization on July 4th 1 , and then every other day, 

2 they’re going to have too much ice. That way they 

3 know they’ll never run out. 

4 It’s also a function of how good the sales 

5 person was to convince you to buy a machine that’s 

6 too big for his needs. There’s a lot more to it 

7 than just utilization factor, it’s really about 

8 capacity. 

9 MR. BROOKMAN: Okay. 

10 MR. BROADBENT: And then a comment 

11 regarding water cooled and remotes. There is a lot 

12 of, you know, all that energy has to go somewhere. 

13 And if you’ve got a water cooled or a remote cooled, 

14 the energy’s going outside, the waste heat’s going 

15 outside, so you can’t use it for heating, but you 

16 don’t have to air condition it either. So there is 

17 a factor. 

18 What will happen is that consumers will 

19 buy whatever is the most cost effective for them, 

20 given their situation, they may cheap out and get an 

21 air cooled when they really would have been better 

22 off, from a total energy standpoint, buying the 

23 remote. So that is a factor. 

24 MR. SACHS: Harvey Sachs. John, just to 

25 clarify, I’m trying to think about situations where 
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1 BTU’s a BTU, and I can at least use that for 

2 preheating in a water loop for my hot water -- 

3 service hot water, clean up needs. 

4 MR. BROADBENT: Well, you could actually, 

5 if you have an air cooled machine, for example, it 

6 does provide some heat in the winter. So it’s a 

7 trade off. You’d have to consider all those 

8 factors. 

9 MR. SACHS: I think we’re sharing the 

10 perspective that making the appropriate theological 

11 assumptions, we could carry this one to far more 

12 detail than it’s worth.

13 MR. BROOKMAN: Daryl, please. 

14 MR. ERBS: So I’ll make one comment on 

15 item 6-2. I’m going to hypothesize it. Most of the 

16 time, the ice making machine has a negligible 

17 impact, not that it doesn’t add heat to the space, 

18 but, you know, common scenarios are if someone puts 

19 a self-contained air cooled unit in the kitchen, 

20 it’s typically one of the smaller loads compared to 

21 all the other things dumping heat into the kitchen, 

22 so there’s a big load there, but it’s a small 

23 percentage of it. 

24 Another favorite example is -- we’ve all 

25 experienced this -- in hospitality, hotels, the ice 
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1 machine dumps a bunch of heat, but they put it in a 

2 part of the hotel where there’s no air conditioning, 

3 so that’s why when you walk in there to get your 

4 ice, it’s really hot in that little closed-in room 

5 that they stuff the ice machine into, and there’s no 

6 air conditioner there. So that is a case where -- 

7 And probably the one case I know of where 

8 it probably has some measurable effect would be like 

9 a convenience store, if they don’t use remote 

10 condensing, where they can use a lot of ice in a day 

11 and there aren’t that many other significant heat 

12 loads, some, but it’s not as intense as a normal 

13 kitchen. So there’s probably a case where it has 

14 some impact. 

15 We do publish heat rejection data, so I 

16 mean there’s some information available to you that 

17 you could use, if you were going to do any kind of a 

18 building analysis to do that. 

19 MS. BRITT: Thank you. 

20 MR. BROOKMAN: Hey, Harvey, if you want 

21 this on the record -- 

22 MR. SACHS: No.

23 MR. BROOKMAN: Okay. Then -- let’s keep 

24 moving on and respond to these questions. Let me 

25 note that one of our webinar participants, Hashizaki 
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1 (ph) agrees with Daryl, that point five is an 

2 unrealistic number. It varies by application, so 

3 there’s more to be said on this subject and 

4 hopefully I will provide good detailed, written 

5 comments. 

6 Any more comments on this comment box? 

7 Joanna.

8 MS. MAUER: Joanna Mauer. I think I’d 

9 just say that I think it would be very helpful to us 

10 if DOE can present some kind of limited amount of 

11 data or modeling, just to get a sense for the 

12 magnitude of what this impact really is, to know 

13 whether it’s, as Harvey said, a convenience store, 

14 what would the impact be there, so we can get a 

15 sense of whether it’s important to --

16 MR. LLENZA: This is Charles Llenza, 

17 Department of Energy. Did we post anything in the 

18 TSD chapters -- we haven’t posted anything yet, have 

19 we? Okay. All right. I think we’ll take that 

20 under advisement. 

21 MR. BROOKMAN: Karim. 

22 MR. AMRANE: Karim Amrane, AHRI. I mean 

23 DOE has done this type of analysis for commercial 

24 refrigeration and you found this impact to be 

25 negligible, so I don’t think you would have any --
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1 it would be any different in this case. So I don’t 

2 know if you want to spend the time doing it, but I 

3 don’t think it’s needed.

4 MR. BROOKMAN: Okay. Let me -- we’re kind 

5 of at this decision point regarding the day. I told 

6 you earlier that I thought we’d be running through 

7 lunch. It’s now ten minutes after one. We have 

8 about ten more slides, I think, or so, that are 

9 substantive in the preliminary analysis segment, and 

10 then once we get to the NOPR analysis presentation 

11 slides, those go pretty quickly because they’re 

12 really quite perspective. So we zoom through those 

13 pretty quick. So the question is, should we just 

14 keep going now? I see a lot of heads nodding. I 

15 suspect it’s a half an hour or so and then we’re

16 done, but I just want to make sure no one’s severely 

17 discomforted. Do we need a five minute break, or 

18 should we just keep going? Keep going, Okay. You 

19 have your instructions. 

20 I tried to warm up the room, by the way. 

21 I think it’s a little warmer in here now.

22 MR. COOKE: And I asked them up there if 

23 they could warm up the room. 

24 MR. BROOKMAN: That’s what did it.

25 MR. COOKE: And he will be here by the 
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1 time we finish, so -- 

2 MR. BROOKMAN: A weather update. It’s 

3 snowing pretty good out there now, so there’s an 

4 incentive for us to keep going. 

5 MR. COOKE: So we’ll hurry up and get out 

6 there where it’s actually warmer.

7 LIFE CYCLE COST AND PAYBACK PERIOD ANALYSIS 

8 MR. COOKE: This is Alan Cooke. Pacific 

9 Northwest National Lab. I’m going to talk about 

10 life cycle cost and payback analysis. Life cycle 

11 cost analyzes the cost of owning and operating this 

12 equipment over the life of the equipment. So we 

13 take into account the first cost, the installation 

14 cost of that equipment to get it actually installed 

15 into the user’s premises, the operating costs, and 

16 then we look at that over the life of the equipment. 

17 There are a couple things that we do with 

18 this information. First of all, we’ll look at a 

19 baseline life cycle cost for that baseline equipment 

20 that Detlef is going to be describing for us, and 

21 then we’ll start comparing that to the life cycle 

22 cost of the equipment with the efficiency 

23 improvements added to them, and the difference will 

24 either be life cycle cost savings, if the efficiency 

25 improvements outweigh the up front cost, or maybe 
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1 life cycle cost increases if we find some things 

2 that are really expensive and don’t save a lot of 

3 energy.

4 There’s another piece of the analysis that 

5 we do, largely with the same data, and that’s the 

6 payback period analysis. In the payback period we 

7 usually look at the first year operating cost 

8 savings and divide that into the upfront cost of the 

9 equipment to determine how many years it takes to 

10 pay back that equipment. Now, if there are some 

11 maintenance and repair costs that occur maybe every 

12 other year or every third year, we’ll annualize 

13 those so they do show up in the first year cost. 

14 But generally, it’s the first year cost.

15 Here’s the flow chart, and I’m not going 

16 to describe a lot of the individual boxes here. The 

17 yellow boxes are inputs, and if you look on the 

18 upper -- I guess that would be the left side -- we 

19 see the inputs that are coming out of the 

20 engineering analysis and a markup analysis. The 

21 only thing we haven’t mentioned at all on that side 

22 is sales tax, which unfortunately is a fact of life. 

23 So we add sales tax to the cost of all of these 

24 pieces of equipment to get the actual consumer 

25 price. Installation cost is added to that, and I’m 
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1 going to talk about that in just a minute. That 

2 gives you your total installed cost. 

3 On the bottom we have the energy input 

4 that comes from the engineering analysis and the 

5 energy analysis that Michelle just talked about. We 

6 also have, in this particular piece of equipment, we 

7 have the water usage. So that makes it just a 

8 little unique as we’ve said a few times today.

9 The energy usage and the water usage are 

10 combined with electricity and water rates to get at 

11 the annual energy expense. Repair costs and 

12 maintenance costs are added in there -- I’m going to 

13 talk about them in just a minute to get you to an 

14 annual operating expense. 

15 This is looked at over the lifetime of the 

16 equipment which is an important variable that we 

17 haven’t actually talked about yet, so we’ll talk 

18 about that in just a minute. We have sums 

19 discounted back to the present with discount rates 

20 that apply to each building type that we’re going to 

21 be studying. And all these things are combined, and 

22 that gets you your life cycle cost. 

23 Water prices. Water is not typically 

24 studied in these, so it’s kind of a new animal. 

25 We’re going to be trying to develop state by state 
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1 water prices to go with our state by state 

2 electricity prices, and we’re going to be looking to 

3 the American Water Works, AWWA’s biannual price 

4 survey, and any other price surveys or price 

5 information that we can find. 

6 Electricity pricing: we have the advantage 

7 that the Energy Information Agency collects a lot of 

8 information for baseline prices and they do 

9 forecasts of electricity prices in their annual 

10 energy outlook process. I’m unaware of anything at 

11 a national level, at that level of aggregation for 

12 water, so we’re going to be developing that 

13 ourselves from the AWWA’s information.

14 So there is a question box here, and I’ll 

15 stop right here and ask if there’s any comment. 

16 We’re looking for input on the proposed methodology 

17 for developing water costs. 

18 MR. BROOKMAN: Harvey Sachs.

19 MR. SACHS: Harvey Sachs. I’m not an 

20 expert in this area, but the AWWA data will be a 

21 substantially lagging indicator. The recent reviews 

22 of water infrastructure needs suggest that by the 

23 time this data takes effect, water costs, on 

24 average, will be much higher. In addition, there 

25 are extraordinarily regional variabilities, larger 
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1 than those for electricity prices. So the first 

2 question that must be asked is whether water costs 

3 significantly impact payback. And if so, it’s going 

4 to require -- to say a doubling of today’s national 

5 average price, if the answer to that is yes, then 

6 just looking at the AWWA survey data will not be an 

7 adequate way to treat water prices. 

8 MR. BROOKMAN: Any additional ideas? 

9 MR. SACHS: Well, I think you’re going to 

10 have to get a bunch of us in a room to box it out 

11 about what does make for appropriate price for the 

12 period of interest, for 2015 on. 

13 MR. BROOKMAN: Is anybody doing 

14 forecasting on pricing? 

15 MR. SACHS: There’s an awful lot of work 

16 being done by people like Pacific Institute and the 

17 Alliance for Water Efficiency. All of these are the 

18 usual suspects, and I don’t have an answer, except 

19 to raise the flag that if it’s a significant 

20 element, I’m quite convinced that today’s average, 

21 or two years ago’s average will not be an adequate 

22 representation of what water costs will be. 

23 MR. BROOKMAN: Charles Llenza. 

24 MR. LLENZA: Charles Llenza, Department of 

25 Energy. Do you know if the EPA is conducting any 
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1 studies in this area? 

2 MR. SACHS: Harvey Sachs. I don’t know if 

3 EPA is, but we’re happy to introduce you to this 

4 whole water efficiency community. Apparently, it’s 

5 a very active area. And I’ve only been to one 

6 meeting, so I’m naïve.

7 MR. BROOKMAN: Okay. Thank you. Comments 

8 over here? No, nothing to add? Okay, you can keep 

9 going on. I want to see if you can summarize, 

10 David.

11 MR. COOKE: Okay. 

12 MR. BROOKMAN: Oh, it’s Alan. Pardon me. 

13 It’s Alan, the bearded man is Alan. 

14 MR. COOKE: I really didn’t know how to 

15 respond to that. Okay, there are three cost 

16 components here that are really key that we haven’t 

17 really talked about. 

18 Repair costs, we’re going to look at the 

19 annualized cost of replacing key components, so 

20 it’s going to really be based on what do we 

21 think those components cost and how often do 

22 they need to be replaced. 

23 Maintenance costs are going to be based on what 

24 we think, by equipment type, the annual 
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1 maintenance profile looks like and what it 

2 costs to do that. 

3 And finally, the upfront installation costs. 

4 There are probably a number of different ways 

5 we could estimate that. I’m hoping we can get 

6 some input from you. 

7 At this point in time, one of the things I 

8 threw up here as an assumption is that I’m not 

9 expecting that the efficiency improvements are going 

10 to increase the installation cost unless they do 

11 something to that basic equipment like make it 

12 bigger, make it heavier, or unless we start seeing a 

13 lot of complicated controls added to it that require 

14 a lot of tweaking when you install that equipment. 

15 So, requests for comments. We have a 

16 number of things, and I think I’m not going to read 

17 them, Doug? 

18 MR. BROOKMAN: You can read them yourself. 

19 Related to typical installation, maintenance and 

20 repair cost, typical time period between sale of new 

21 product and first maintenance and repairs, typical 

22 cycles, and whether and how routine maintenance and 

23 repair installation costs will change the products, 

24 and if it’s appropriate to assume changes made to 

25 repair/installation costs will be negligible for 
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1 more efficient products. Comments along those 

2 lines? Daryl. 

3 MR. ERBS: I’ll start with the last one. 

4 I would agree that there shouldn’t be any 

5 significant effect on the maintenance, repair, 

6 installation cost. I mean the things I see getting 

7 done shouldn’t really have a big effect. I mean 

8 there is some routine maintenance for cleaning and 

9 sanitizing that occurs on ice machines, but that’s 

10 really just based on environmental factors in terms 

11 of how often you have to do that, and really 

12 shouldn’t be influenced by the technology.

13 And then the first two items, I guess I -- 

14 we’ll have to think about what we can provide in the 

15 way of information to you on that. 

16 MR. BROOKMAN: Okay. Thank you. John. 

17 MR. BROADBENT: Hi. I agree with Daryl 

18 that as far as a more energy efficient machine, I 

19 wouldn’t expect it to require any more maintenance 

20 than one today. However, as I talked about before, 

21 if you reduce the total water consumption rate a 

22 lot, you could affect the maintenance frequency. 

23 You could easily double it. 

24 MR. BROOKMAN: Interesting. Jeff. 

25 MR. BIEL: Jeff Biel. Again, the 
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1 maintenance can vary greatly, depending on the 

2 environmental conditions, water quality, location of 

3 ice machine. Typical response would be at least 

4 every six months there would be a routine 

5 maintenance, but again, that could be every two 

6 months, depending on what kind of an area you’re in. 

7 So there’s some variability, but I believe six 

8 months would be a recommendation. 

9 MR. BROOKMAN: I’m scanning back to the 

10 list one more time. Do you have any response to the 

11 first item, item 3? 8-3?

12 MR. ERBS: My only comment on that is 

13 it’ll depend on the type of machine, so whether it’s 

14 self contained air, or remote condenser, they have 

15 very different installation costs. 

16 MR. BROOKMAN: Okay. Okay. 

17 MR. ERBS: And so I think, I don’t know, 

18 we can try and think about how we can provide some 

19 general guidance. And it’s also very segment --

20 what kind of building is it going into? 

21 MR. BROOKMAN: Let’s move on.

22 MS. MAUER: Doug, can I please ask a -- 

23 MR. BROOKMAN: Please, Joanna. 

24 MS. MAUER: Just following up on your 

25 comment, John, about reducing potable water use 
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1 significantly and how that could impact maintenance, 

2 potentially. I just wondering whether you see today 

3 in the field -- I think there’s a relatively large 

4 range in water consumption rates for the cube type 

5 machines, and whether you see within that range in 

6 the market today whether there’s significant 

7 variations in maintenance. 

8 MR. BROADBENT: John Broadbent. My sense 

9 is that all the manufacturers have set their potable 

10 water use at a level that keeps them out of trouble, 

11 and so -- because I know that there have been 

12 efforts in the past to go below, a lot below where 

13 they are today, and that’s where people get into 

14 trouble, and they backed off to where they are today 

15 at the low end. 

16 MS. MAUER: And just to follow up, is -- 

17 do you think there’s a significant difference in the 

18 water use in the field compared to how they’re 

19 tested and rated? 

20 MR. BROADBENT: I don’t actually. I think 

21 that the tests that we do are pretty representative. 

22 As far as water use, they’re pretty representative. 

23 MR. BROOKMAN: Thank you. 

24 MR. COOKE: Equipment lifetimes. In the 

25 press or in the literature, and I’ve listed some of 
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1 the sources here, you see a fairly wide range, seven 

2 to ten years estimated average life, with kind of a 

3 median, mid point of 8.5 years. And this is for a 

4 life cycle cost analysis, anyway, a pretty key 

5 input. So item 8.7, DOE seeks comments on the 

6 appropriate equipment lifetimes for the classes of 

7 equipment that we’re covering here.

8 MR. BROOKMAN: So maybe potentially a lot 

9 of variation among the classes, or can you comment 

10 generally on the lifetimes? Daryl? 

11 MR. ERBS: I think that’s a pretty good 

12 range and why is there a range? Well, some of it is 

13 there’s this variation in duty cycle, so an ice 

14 machine that runs a higher percent of the time is 

15 going to wear out sooner. I mean it’s just based on 

16 that cycling of all those components. There are 

17 mechanical parts in there, so -- I don’t think you 

18 can really narrow it down much more than that. 

19 So it may be that if you make some 

20 assumptions around duty cycle, then you’d set the 

21 lower life with the higher duty cycle. But based on 

22 the information I have, I think that’s fairly 

23 accurate. 

24 MR. BROOKMAN: Okay. Thank you. Other 

25 comments? Agreed? Yeah? John. 
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1 MR. BROADBENT: This is John Broadbent. I 

2 think seven to ten is what we’ve always said. I’ve 

3 seen as low as five and as long as 20. And five may 

4 happen if a chain is doing a remodel and they have 

5 to make a call, keep it or get rid of it, and 

6 they’ll replace it at that point. But it’s really, 

7 kind of for other reasons. And the 20 years, 

8 somebody who really doesn’t care how it looks and 

9 keeps going with it. 

10 MR. BROOKMAN: Okay. 

11 SHIPMENTS ANALYSIS 

12 MR. COOKE: Shipment analysis. In order 

13 to do the national impact analysis, I need to know 

14 how many units are we talking about here. We’re 

15 talking about total water usage, total energy usage, 

16 and the present value. So in this step we’re 

17 estimating the number of products that are being 

18 shipped in a base case, and in a potential new or 

19 amended energy efficiency standards case. 

20 So I’ve listed some of the sources of data 

21 that we’ve uncovered to date for shipments 

22 information. In the base case, we’re asking the 

23 question of what would the shipments be without new 

24 standards? If the market was just left alone, what 

25 would they be? And then we have to ask the question 
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1 of what, if any, change would occur to shipments if 

2 we do impose a standard? 

3 So we have some questions here. We’ve 

4 already asked for information under item one, but 

5 this is critical to this analysis, so I’m going to 

6 ask again. DOE’s seeks information on the 

7 historical shipments for the ice making equipment 

8 for each class, as well as industry trends regarding 

9 the relative growth in each class. 

10 And then item number two, DOE seeks 

11 information on representative saturation rates. 

12 One of the things that I really need to be 

13 able to know in order to do some of these analyses 

14 is, when we’re looking out there in the field at the 

15 number of buildings or the amount of commercial 

16 floor space, how many ice-makers are out there? How 

17 big is this market of machines that currently exists 

18 in the market place? 

19 MR. LLENZA: This is Charles Llenza. I 

20 just want to make -- that’s called the stock, right?

21 MR. COOKE: Yeah, it could be a stock. 

22 What’s the saturation out there, the stock that’s 

23 out there? 

24 And 9.3, we’re looking for information on 

25 the potential impacts of these standards on 
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1 shipments. 

2 MR. BROOKMAN: We’ve already heard from 

3 AHRI that they’re going to be working on this. 

4 MR. AMRANE: Right. I have an AHRI -- 

5 this is Karim Amrane, AHRI. We will provide you the 

6 historical shipment data, however we don’t forecast, 

7 so just the historical shipment data. 

8 MR. BROOKMAN: Can you talk about the 

9 stock that’s out there?

10 MR. AMRANE: We don’t collect that kind of 

11 information, so unless manufacturers have a pretty 

12 good idea what it is, maybe we can try through them, 

13 but we don’t have that data.

14 MR. BROOKMAN: Okay. Jeff. 

15 MR. BIEL: Yes, as far as existing base 

16 ice machines, I mean it’s something that we can try 

17 to get. Because of our channels -- complicated 

18 channels of distribution, it could be a challenge, 

19 but I mean it’s something we can make an effort to 

20 do.

21 MR. BROOKMAN: Okay. Because of course 

22 the stock would rate, have big implications for 

23 replacements. So that’s good for them to have it. 

24 Okay. Daryl. 

25 MR. ERBS: My only comment was going to be 
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1 that it is pretty well saturated, there’s not a lot 

2 of new construction, especially last couple of 

3 years, and maybe things will get a little bit 

4 better, but -- so if you just use your average life 

5 time and the data from AHRI, that’s going to get you 

6 80 percent confidence on what the stock is, because 

7 I believe we typically estimate that 70 percent of 

8 our sales are just replacements for units that were 

9 already there, and then the rest is a mix of new 

10 construction and some new categories. But I think 

11 that’s going to be the easiest way to do it.

12 MR. BROOKMAN: Thank you. And Harvey. 

13 MR. SACHS: Harvey Sachs. In my 

14 experience, Daryl, that last sentence is the 

15 critical thing, because that’s shipments with the 

16 modifiers, so that you can get the standing stock. 

17 So that I think would be very helpful. The 70 

18 percent being replacements is what I need with the 

19 shipments to get an estimate of stock. Shipments 

20 and lifetime. And there are probably some other 

21 data sources. 

22 I don’t know how often the people like NRA 

23 would share, but there are some other industry 

24 associations that would tell you how many new 

25 restaurant starts there are. 
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1 MR. ERBS: Yeah. And there’s some other 

2 data sources that you could use to help refine that 

3 a bit more. 

4 MR. LLENZA: And the Department would 

5 appreciate as specific as leads as possible that you 

6 can provide the Department in terms of resources, 

7 points of contacts, and associations, et cetera. 

8 MR. BROOKMAN: Okay. Other comments on 

9 this? Yes. 

10 MR. BROADBENT: Yes. John Broadbent. A 

11 couple of comments. You asked about would we sell 

12 more equipment if the efficiency standards are more 

13 stringent, and my gut feel is that people won’t buy 

14 new ice machines to get a higher efficiency level 

15 because typically, the differences are not going to 

16 be that great and the equipment might be more 

17 expensive. And if it’s more expensive, that will 

18 also discourage -- and really when you get down to 

19 it, sales. Daryl’s point -- sales are driven by 

20 replacements, so until their current machine breaks, 

21 they’re not really shopping.

22 MR. BROOKMAN: Okay. 

23 MR. COOKE: If I can follow up, do you 

24 think the standards will change the market? It’s 

25 not going to increase it, but will it do anything 
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1 else to the market, or is that speculative? 

2 MR. BROADBENT: The impact of the 

3 California requirements was that basically everybody 

4 upped their game to meet the standard. So you could 

5 probably expect a similar effect. But I don’t know 

6 that it had any effect on sales. 

7 MR. BROOKMAN: All the manufacturers 

8 increased the efficiency of their product to meet 

9 that emerging California standard, right? 

10 MR. BROADBENT: Right. 

11 MR. BROOKMAN: I see. 

12 MR. COOKE: All right. Thank you. One 

13 more slide here -- actually we have a couple slides. 

14 NATIONAL IMPACT ANALYSIS 

15 MR. COOKE: National impact analysis. 

16 I’ve actually already talked about this first 

17 bullet, which is the NIA seeks to quantify the 

18 national energy savings, the national water savings, 

19 and net present value. Well, net present value, 

20 we’re going to take the number of units that we’re 

21 talking about over a 30 year period, starting with 

22 the first year of the standards, and look at the 

23 total cost of the efficiency improvements on the up 

24 front side, and also the savings, the efficiency 

25 savings over time, and bring that back to a present 
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1 value and analyze what the net present value of that 

2 is.

3 One key assumption here is -- has to do 

4 with rebound effect. If you’ve never heard that 

5 term, rebound has to do with when you make something 

6 more efficient, you’re in essence making it look 

7 like it’s less expensive to use it. So people, for 

8 example, might insulate their house and then realize 

9 they don’t have to freeze in the winter and they 

10 turn up their thermostat. 

11 Because these things are plugged in pretty 

12 much all the time, and they run basically when the 

13 ice is needed, and because the usage of the ice 

14 really isn’t a function of how much it costs to make 

15 the ice, it’s really just a function of how much ice 

16 do you need, we don’t think rebound effect is a 

17 factor here. 

18 The NES work will be done in a 

19 spreadsheet, as will the life cycle cost work, and 

20 that will all be available to you on the DOE 

21 website. 

22 I think the big thing here is just that 

23 the national impact analysis is done at a national 

24 level. It’s not really done at a consumer level, so 

25 we’ll be using national discount rates that are 
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1 prescribed to us by OMB and we’ll also be adding to 

2 the actual end use energy savings, an adjustment to 

3 take those savings up to the generation level. So 

4 it’s more like how many BTUs are we saving at the 

5 upper end of the stream as opposed to at the 

6 consumer end. 

7 And we have some questions here. Do you 

8 think that the rebound effect exists, or is it NA? 

9 And then we welcome any comments that you have on 

10 the national impact analysis. 

11 MR. BROOKMAN: No comments on these? 

12 Joanna.

13 MS. MAUER: Joanna Mauer. I think I would 

14 agree with your assessment of the rebound effect. I 

15 think it would be unlikely that we would see 

16 something. 

17 MR. BROOKMAN: Okay. So then -- 

18 MR. COOKE: Detlef is next to talk about 

19 preliminary manufacturer impact analysis. 

20 PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

21 MR. WESTPHALEN: Everybody asked me what 

22 is this chevron doing here that doesn’t connect to 

23 anything else. Well, this connects to the NOPR 

24 analysis in which there is a manufacturer impact 

25 analysis. And the whole point of the manufacturer 
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1 impact analysis is to assess the impact of the 

2 standards on the manufacturers. And there’s a 

3 financial model developed that’s called the GRIM, 

4 government regulatory impact model, and uses inputs, 

5 a lot of which we’ll collect through the discussions 

6 with the manufacturers during the interviews in the 

7 NOPR phase. 

8 However, in the preliminary phase, we have 

9 preliminary discussions where we start to try to get 

10 some of an understanding, perhaps more qualitative 

11 than quantitative of the potential manufacturer 

12 impacts. So that’s the last piece of the puzzle 

13 here on the preliminary analysis part of the 

14 discussion. 

15 So here we have questions. DOE seeks 

16 comments on the establishment of manufacturers 

17 subgroups for automatic commercial ice making 

18 equipment, particularly small businesses and niche 

19 manufacturers. This is one of the issues that is 

20 generally considered as part of the manufacturer 

21 impact analysis, whether there should be separate 

22 analyses for manufacturer subgroups. 

23 And also, what regulations or pending 

24 regulations should DOE consider in the analysis of 

25 cumulative regulatory burden? This also is one of 
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1 the issues investigated in the manufacturer impact 

2 analysis. 

3 MR. BROOKMAN: Karim. 

4 MR. AMRANE: Karim Amrane, AHRI. I guess 

5 I’m just -- second question. Yes, there are pending 

6 regulations, for example, commercial refrigeration, 

7 you’re going to be starting a new rule and it’s 

8 going to impact some manufacturers who are making 

9 both products. And there are also, not pending 

10 regulations, but there are things looming in the 

11 horizon about refrigerant issues and -- that might 

12 impact some manufacturers. And some things, we’ve 

13 asked DOE in the rulemakings to look at as well, 

14 because as there is pressure to get rid of some of 

15 the refrigerants that we are using today, they are 

16 going to be costs with the new refrigerants that 

17 probably need to be factored in in this rulemaking. 

18 So something to keep in mind. 

19 MR. BROOKMAN: Thank you. Other comments 

20 on these two comment boxes? 

21 MR. BIEL: Jeff Biel. Not necessarily 

22 regulations, but I think the point that was made 

23 before with regards to Energy Star and CEE, those 

24 become more important in the market place to the 

25 consumer and so we just want to make sure that those 
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1 are kind of congruent with the actions of DOE. 

2 NOPR ANALYSES OVERVIEW 

3 MR. WESTPHALEN: Okay. Now I’ve kind of 

4 led into the discussion of the NOPR analyses, and we 

5 were just at this point, giving an overview of the 

6 overall NOPR process here. 

7 MR. BROOKMAN: Can you just reference the 

8 timeframes for this? 

9 MR. WESTPHALEN: The timeframes for the 

10 NOPR, if I remember the schedule correctly, the 

11 preliminary analysis meeting was September of this 

12 year.

13 MR. BROOKMAN: Yeah, it’s on the slide. 

14 I’m sorry.

15 MR. WESTPHALEN: Yeah, slide ... and the 

16 NOPR analysis starts -- we’re in the preliminary 

17 analysis to the actual publication. So if you look 

18 at the timeline on page 18 -- there you go -- on 18, 

19 so you’re looking at the preliminary analysis, and 

20 that’s planned for July 2011. Then the -- it goes 

21 for almost a year, to the spring or a little bit 

22 less, about eight months, to the spring of 2012. 

23 So the first thing done as part of the 

24 NOPR analysis is to revise the preliminary analyses 

25 based on the comments received during the 
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1 preliminary analysis public meeting and comment 

2 period. And then there are additional NOPR phase 

3 analyses that address other issues, life cycle cost, 

4 subgroup analysis -- this is looking at perhaps 

5 small chain restaurants or something like that that 

6 might be affected differentially as compared with 

7 other end users. Manufacturer impact analysis, we 

8 talked about that. Utility impact analysis, 

9 employment impact analysis. Environmental 

10 assessment and regulatory impact analyses. 

11 And most of these NOPR phase analyses will 

12 be conducted by Pacific Northwest National Labs, so 

13 if there are particular questions, they might be in 

14 a better position to answer them. 

15 We have a series of requests for comments 

16 that address some of these analyses. I don’t know 

17 how deeply we want to go into each of the requests 

18 for comment here. They touch on the broad range of 

19 the NOPR phase analyses. 

20 MR. BROOKMAN: Let’s let them scan 

21 through. Please take, just take a moment to scan 

22 through this comment box, and see if there’s 

23 anything right now that you would like to address. 

24 MR. WESTPHALEN: Or need for clarification 

25 from the Department at this time. 
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1 MR. BROOKMAN: Thank you. (Pause.) A few 

2 of you are new to these proceedings, most everyone 

3 else here is very familiar with these analytics. 

4 There’s a lot of great detail and a little more work 

5 that goes in here. 

6 MR. LLENZA: This is Charles Llenza, 

7 Department of Energy again. I think what’s 

8 important too, at this point in time in the 

9 proceedings, which are the framework, is this is 

10 kind of the overall plan the Department has and what 

11 we’re providing is the scope of what analyses and 

12 how we plan to use it, in sort of a very top down 

13 approach. 

14 So, at this time you don’t have the actual 

15 information available, so we’re not expecting 

16 comments on that, but we’re expecting comments on 

17 the approach. So if there’s anything that we sort 

18 of missed overall, that’s what the Department would 

19 appreciate comments on. If there’s something else 

20 that we should be looking at in terms of doing our 

21 analysis and downstream updating of that analysis. 

22 MR. BROOKMAN: Any other comments on it, 

23 in addition to these requests for comments in the 

24 box?

25 MR. WESTPHALEN: So now I think I’m 
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1 turning it back over to Charlie to close remarks. 

2 OTHER ISSUES 

3 MR. BROOKMAN: Let’s provide an 

4 opportunity as we said we would, for final closing 

5 remarks. Anything additional at this point that any 

6 individual wishes to raise? Joanna. 

7 MS. MAUER: Joanna Mauer. I just wanted 

8 to make a brief comment going back to the test 

9 procedures, on the issue of measuring potable water 

10 use. And I’m not familiar at this point with the 

11 current test procedure, but my understanding is that 

12 products are tested with a purged setting in 

13 whatever the default setting is, or how the products 

14 are shipped by the manufacturer. 

15 And then we’ve heard anecdotally that 

16 oftentimes installers, I guess to avoid maintenance 

17 calls, may install the product with the maximum 

18 purge setting. And so I don’t have any specific 

19 recommendations at this point except to just urge 

20 DOE to look into this issue and to evaluate whether 

21 it might make sense to include, for example, 

22 multiple purge settings somehow in the test 

23 procedure, just to make sure that the measured water 

24 use is actually adequately representing field 

25 consumption. 
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1 MR. BROOKMAN: Other issues that people 

2 need to raise here at the close of this meeting? We 

3 covered it sufficiently for now. Okay. 

4 Okay. Then, to Charles Llenza. I’m 

5 handing out the evaluation forms. Please take a few 

6 minutes to fill them out. 

7 CLOSING REMARKS 

8 MR. LLENZA: Just quickly to go through 

9 the last slides here. Slide number 81 is -- here’s 

10 how you submit the comments to the Department. The 

11 most important part of this to make sure you clearly 

12 identified that this is part of the automatic 

13 commercial ice making -- ice-maker rulemaking, and 

14 then to put the docket number. The room number’s 

15 not that important, but the docket number would be 

16 critical. 

17 Also to remember to provide your comments 

18 by January 18, 2011. The Department will surely 

19 appreciate if we get all the comments in by then. 

20 In addition, the last slide here, I’m 

21 providing the points of contacts and the web pages 

22 the Department uses. So everything that has been 

23 discussed at this proceedings, any corrections to 

24 those slides, and any additional information or 

25 request for information will be provided by posting 
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1 it on the website. 

2 And in addition to the people that are 

3 attending the webinar, those parties that have sent 

4 me an e-mail, I will provide them with the material 

5 in advance. But we should be able to find 

6 everything at the website within the next week or 

7 so.

8 In addition, there is my e-mail and my 

9 phone number. I prefer things via e-mail because I 

10 like to keep records, especially since these are 

11 deliberations over time. I can’t remember all the 

12 phone calls I get. In addition too, there’s 

13 additional point of contact, my supervisor, although 

14 he’ll probably defer to me anyhow on this particular 

15 item.

16 I want to thank everybody for attending 

17 these proceedings. I also want to provide you that 

18 the Department of Energy of itself is having its 

19 Christmas party today. The Secretary is sick, but 

20 the party is still going -- will be going on and 

21 starting at three o’clock in the main cafeteria, and 

22 since you missed lunch, if you guys want to hang 

23 around for another hour, you could end up just 

24 mingling into the party and grabbing some free food 

25 and some beverages. 
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1 In addition to the fact that it is snowing 

2 outside, so we don’t know if we’re going to be 

3 trapped here for a few days, whatever. 

4 The cafeteria, I think, was closing 

5 relatively early today in order to get it prepped up 

6 for the party so there is food downstairs for those 

7 people that are just starving and need to have 

8 something. There’s a Subway stop, and Dunkin 

9 Donuts. 

10 But if not, if you have other business in 

11 the building, want to talk to several people, but 

12 feel free to mingle through at three o’clock, you’re 

13 all invited, courtesy of the Department, and thank 

14 you again for attending today’s meeting.

15 (Whereupon, at 1:48 p.m., the hearing 

16 in the above captioned matter was 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 STANDARD 

FRAMEWORK DOCUMENT FOR 

AUTOMATIC COMMERCIAL ICE-MAKERS

 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. 

 

 

Wend Greene 

 Official Reporter 

Dated: January 6, 2011