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 Decem ber 16, 2010

Chair:

Doug Brookman Public Solutions Baltimore, MDExecutive Court Reporters (301) 565-0064 2

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 A merican Council for an E nergy-E fficient E conomy

Karim Amrane A ir

- 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 EnergyExecutive Court Reporters (301) 565-0064 3 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 Lab oratory:

Eric Andersen

Michelle Britt

Alan Cooke

Sarah Widder

Participants from Public Solutions:

Doug BrookmanExecutive Court Reporters (301) 565-0064 4 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. SACH S 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 160Executive Court Reporters (301) 565-0064 5 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

M R. LLENZA 203Executive Court Reporters (301) 565-0064 6

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

9: 07 a.m. 2

MR. BROOKMAN: Good morning. Welcome 3

everyone. This is the Department of Energy Public 4

Meeting on the Energy Conservation Standards 5

Framework Document for Automatic Commercial Ice 6

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

ab out 20 degrees, 15 degrees outside in Washington, 8

D.C. It’s a cold morning. 9

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

welcoming remarks here at the outset from John 11

Cymbalsky. 12

WELCOMING REMARKS FROM DEPARTMENT 13

MR. CYMBALSKY: Thank you Doug. Welcome 14

everybody to the Commercial Ice Maker Public 15

Meeting. It’s a very appropr iate day to pick 16

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

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

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

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

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

So you might want to stick to the train and not 22Executive Court Reporters (301) 565-0064 7 drive if it gets a little ugly out there. 1

For those of you that are new to this 2

process I would just like to put a special welcome 3

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

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

views and information on the product that we kind of 6

regulate here. 7

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

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

information that you can provide from the industry, 10

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

rulemaking, we appreciate. We appreciate comments 12

as early in the process as possible. 13

Just to reinforce how much we like the 14

stakeholders getting together. I just would like 15

for you to know that five of our next seven 16

rulemakings that we have on the schedule have 17

elements in it that were consensus-driven by 18

industry and efficiency advocates. Now if you come 19

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

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

looked at the levels in our analysis and so we 22

appreciate any sort of work on that side that you 23

all do. 24

But again, I have to run back to work, 25Executive Court Reporters (301) 565-0064 8 unfortunately, but have a good meeting, hopefully 1

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

big a deal. 3

INTRODUCTIONS 4

MR. BROOKMAN: Thank you. It’s our 5

tradition to start off by doing introductions. 6

Please say your name and organizational affiliation. 7

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

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

start over here, please. 10

MR. ERBS: Daryl Erbs, Manitowoc Ice. 11

MR. BROADBENT: John Broadbent, Scotsman 12

Industries. 13

MR. BIEL: Jeff Biel, Scotsman Ice 14

Systems. 15

MS. WALTNER: Meg Waltner, Natural 16

R esources Defense C ouncil

. 17

MR. ROY: Robin Roy, Natural Resources 18

Defense Council. 19

MS. MAUER: Joanna Mauer, Appliance 20

Standards Awareness Project. 21

MR. SACH S: Harvey Sach s, ACEEE. 22

MR. AMRANE: Karim Amrane, Air23

Conditioning, Heating, and Refrigeration Institute. 24

MR. LLENZA: Charlie Llenza, Department of 25Executive Court Reporters (301) 565-0064 9 Energy, the Project Manager for this rulemaking. 1

MR. BROOKMAN: Please stand up, Detlef. 2

MR. WESTPHALEN: Detlef Westphalen, I’m 3

with Navigant Consulting, supporting the DOE in this 4

rulemaking. 5

MS. BRITT: I’m Michelle Britt with 6

Pacific Northwest National Laboratory, also 7

supporting DOE. 8

MR. COOKE: Alan Cooke, Pacific Northwest 9

National Laboratory, also supporting DOE. My friend 10

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

PNNL supporting DOE. 12

MR. BALLO: Tim Ballo with Earthjustice. 13

MR. GOMEZ: Tommaso Gomez, 14

also with Navigant Consulting, also supporting DOE. 15

MR. BROOKMAN: Please say your name. 16

MS. WIDDER : Sarah Widder, Pacific 17

Northwest National Laboratory. 18

MR. BROOKMAN: Perfect timing. You’re 19

next. 20

MR. MA URITZ: I’m Donald Mauritz with the 21

Lawrence Berkeley National Laboratory, supporting 22

the Federal Energy Program. 23

AGENDA REVIEW 24

MR. BROOKMAN: Excellent. I’m going to do 25Executive Court Reporters (301) 565-0064 10 a very brief agenda review . I think all of you 1

received a packet of information as you c ame in th e 2

door, both the Federal Register notice and the 3

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

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

proceedings, will be the focal point for 6

presentation a nd discussion. And the Department, as 7

you look through the se slides, you’ll notice that 8

they have comment boxes, request for comments are 9

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

Immediately following this agenda review, 11

there’s a n opportunity for anybody who wishes to do 12

so to make an opening remark. Brief statements 13

surrounding key issues and key concerns that you 14

might wish to raise here at the outset. 15

Following that, we’re going to hear about 16

the regulatory history and rulemaking scope. And 17

then , rulemaking overview. Following that 18

immediately, we’ll go into the detailed substantive 19

content of this proceeding, market and technology 20

assessment, screening and engineering analysis. 21

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

take a coffee break. 23

Following that break or wherever it fits, 24

we’re going to have the test procedure background 25Executive Court Reporters (301) 565-0064 11 and scheduled changes, a discussion of markups, 1

energy use characterization, life cycle cost, and 2

payback period analysis, shipments analysis , 3

national impact analysis, and life cycle cost 4

subgroup analysis, utility impact analysis, 5

employment impact analysis , environmental assessment 6

and regulatory impact analysis. All of those 7

analyses there. 8

And there’s yet another opportunity as you 9

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

today we -- the agenda reflects that they expect 11

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

that general time frame, yet another opportunity for 13

people to raise issues that haven’t been raised 14

sufficiently to comment, additional opportunity to 15

comment then. So the Department really wants to 16

hear from you. 17

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

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

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

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

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

Comments on those? 23

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

listed up here what have emerged as norms for these 25Executive Court Reporters (301) 565-0064 12 meetings. Please speak one at a time. Please say 1

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

transcript of this meeting available, and it will be 3

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

now? Regulations.gov, yes. 5

I’m going to be cueing individuals to 6

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

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

need to say your organizational affiliation, all of 9

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

Department knows who is here, and the Department 11

would make a Xerox copy of everybody’s busi ness 12

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

If we keep the focus here, turn your cell 14

phones on silent mode , limit your sidebar 15

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

speak, you need to turn these microphones on

. 17

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

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

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

Questions, comments before we proceed? 21

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

proceeding is being made available via the web. We 23

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

have joined us via web -- do we have any yet? 25Executive Court Reporters (301) 565-0064 13 MR. JONES: Yes, we have two. 1

MR. BROOKMAN: For those of you who have 2

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

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

all remote. 5

As I understand it, there is the capacity 6

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

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

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

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

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

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

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

Let me see, Harvey Sachs. 14

MR. SACH S: Would it be appropriate to ask 15

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

introduced as well. 17

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

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

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

names, Eric, yes. 21

MR. JONES: All right. We have Jennifer 22

Williamson, John Lemmond, Mark Menzer, Michael 23

Maertens, Stephen Schaeffer, Hung Pham, Elizabeth 24

Albern, David Winiarski, Brian Bunisek (ph), and 25Executive Court Reporters (301) 565-0064 14 Bi jit Kundu. 1

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

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

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

I’m about to proceed here. Additional 5

questions here at the outset before we -- 6

PARTICIPANT: Is this the point for the 7

opening remarks? 8

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

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

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

remarks to highlight key issues and concerns that 12

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

Joanna. 14

STAKEHOLDER OPENING STATEMENTS 15

MS. MAUER: Joanna Mauer. First we just 16

want to acknowledge that DOE is initiating this 17

rulemaking early, relative to the statutory deadline 18

for publication of the final rule, and we appreciate 19

that DOE has recognized this rulemaking as a 20

potential opportunity for realizing savings sooner 21

than what might otherwise have happened. We also 22

strongly support DOE’s proposal to expand the scope 23

of this rulemaking beyond cube machines, to include 24

both continuous type ice- makers and ice

- makers with 25Executive Court Reporters (301) 565-0064 15 larger capacities. 1

We look forward to the discussion during 2

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

questions that we have to get some clarification on 4

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

few issues that we hope will be addressed. 6

First, it seems like there are multiple 7

ways of classifying automatic ice- maker s and we’d 8

like to better understand the scope of coverage of 9

the current test procedure and the proposed scope of 10

coverage for this rulemaking, to insure that all 11

types of ice- maker s are covered, including 12

combination soda ice machines, and ice- maker s that 13

produce chipped or crushed ice. 14

Secondly, we support DOE’s proposal to 15

include a water efficiency metric for potable water 16

consumption, and while we recognize the substantial 17

improvement in water efficiency that the industry 18

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

significant opportunities for water savings. We 20

also want to insure that any water efficiency 21

standard actually translates to water savings in the 22

field. We’ve heard anecdotal ly that installers 23

often install cube- type ice-maker s with a purge 24

setting in the highest water use position, which may 25Executive Court Reporters (301) 565-0064 16 result in substantially different water consumption 1

in the field compared to tested water consumption. 2

We also encourage DOE to explore technical 3

solutions that might include automatic adaptive 4

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

whether DOE is proposing to capture any energy use 6

associated with ice storage, and whether that energy 7

use is captured in the current test procedure. 8

Thank you and we appreciate the 9

opportunity to participate in this public meeting. 10

MR. BROOKMAN: Thank you. Additional 11

comments, opening remarks here. Yes, Daryl. 12

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

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

standards to basically define the efficiency and 15

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

in A H RI in the development of their standards and 17

also with the ASHRAE test methods. 18

In terms of this rulemaking, we certainly 19

appreciate that DOE is following the prescribed 20

procedure where every five years they need to take a 21

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

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

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

standards for a little under a year now, so it’s 25Executive Court Reporters (301) 565-0064 17 kind of new for us. You know, unlike air 1

conditioning and some other product segments, we’re 2

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

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

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

changing something that we’re really still trying to 6

put in place as an operating mechanism, but we 7

appreciate that, you know, this proceeding needs to 8

go forward. 9

In terms of cube, batch-type cube 10

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

been relatively little change in the technology 12

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

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

future, but I want to make sure that everyone 15

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

components that are really key in terms of energy 17

efficiency are somewhat constrained and somewhat 18

unique. So something as simple as a compressor for 19

an ice

- maker has some special requirements due to 20

the periodic nature of the batch ice making cycle. 21

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

ice machine. It has to have certain design 23

requirements. 24

Our volume in total for the industry is 25Executive Court Reporters (301) 565-0064 18 small. It’s maybe 200,000 in a really good year, 1

and so when you look at what a compressor 2

manuf acturer going to do when they’re designing new 3

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

something that represents that kind of volume. So 5

compared to air conditioning and some other 6

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

you don’t con sider the refrigeration system in an 8

ice machine as being no different from that in an 9

air conditioner and therefore able to take advantage 10

of all of the technologies that have been introduced 11

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

critical point. 13

And then the whole water side of it, which 14

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

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

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

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

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

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

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

going to be very concerned about changes that are 22

just focused on water use or energy use because at 23

the end of the day if we improve the energy 24

efficiency by a little bit, but give customers an 25Executive Court Reporters (301) 565-0064 19 output from our products that they see degraded from 1

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

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

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

encouraged to embrace this type of change. 5

So I guess just a little bit of caution 6

from my perspective, and we’ll have additional 7

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

MR. BROOKMAN: Additional comments here at 9

the outset. Yes, please, John. 10

MR. BROADBENT: John Broadbent at Scotsman 11

Industries. I just want to let you know that 12

Scotsman also takes this regulation rulemaking very 13

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

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

whatever and be a resource as needed. 16

One thing I can point out is I was 17

personally involved, as well as another person from 18

Scotsman Ice Group, involved in the California 19

Energy Commission rulemaking that today’s 20

regul ations came from, and so I understand how we 21

got there and am familiar with how all those 22

equations were arrived at. 23

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

MR. SACH S: Harvey Sachs. First, thank 25Executive Court Reporters (301) 565-0064 20 you to DOE, and secondly, just a bit of a follow up 1

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

actually much warmer here in Washington than it is 3

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

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

enormous amounts of hot air generated here. House 6

and Senate are in session. 7

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

meteorological prediction there. 9

MR. SACHS : I was. 10

MR. BROOKMAN: Okay. 11

MR. SACHS : With that kind of certainty. 12

I also want to just mention very quickly some 13

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

need to draw, for self

- contained units, the clear 15

distinction between water-cooled condensers and air16

cooled condensers, and it’s going to require some 17

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

created equal. Ther e’s a very strong difference 19

between the consumptive use of a once-through or 20

open loop system, versus a water looped system, 21

which in an area like a convenience store, or 22

potentially, a full service restaurant or a hotel, 23

has beneficial uses for the rejected heat, and we 24

want to make sure that the standards are very clear 25Executive Court Reporters (301) 565-0064 21 about this, and not differentiating -- not 1

discriminating against the potential benefits for 2

water looped systems. 3

The second thing that I’ve chatted with a 4

number of people in some hearings about, and 5

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

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

role of standards in jobs, competitiveness, and 8

innovation. And to me it is extremely important 9

that the Department base its analysis of maximum 10

technology on an international baseline, and not 11

just common practice in the United States. If our 12

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

remain competitive, to protect jobs and investment, 14

we must understand what the state-of

- the

- art is 15

in ternationally. We have seen that this can be a 16

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

if we treat our country as an isolated island in 18

terms of this analysis. 19

Finally, the issue that I struggle with 20

personally and look to be informed on by the 21

manufacturers, is the interplay between standards 22

and the ability to market innovative features that 23

have consumer value, that have energy saving value, 24

but may or may not be appropriate for standards, per 25Executive Court Reporters (301) 565-0064 22 se. And this relates to features like adaptive 1

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

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

applications, would be amenable to grid control to 4

avoid use during particularly intensive peak load 5

periods. 6

So that’s the framework for the kinds of 7

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

greater or lesser stringency, but things that lead 9

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

MR. BROOKMAN: Thank you. Some comments 11

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

regulatory history and rulemaking scope, to Charles 13

Llenza. 14

REGULATORY HISTORY AND RULEMAKING SCOPE 15

M R. LLENZA: All right. I’m going to 16

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

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

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

present a procedure on the analytical approach to -- 20

for our rulemaking here, to provide the forum for 21

public discussion, and to encourage the interested 22

parties and the stakeholders to provide us comments 23

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

is to inform the interested parties of all the 25Executive Court Reporters (301) 565-0064 23

resources -- web resources -- that the Department 1

has available in terms of the rulemaking for 2

comments and process and sharing information. 3

Once again, I just want to emphasize the 4

boxes here highlight the request for comments the 5

Department has made . So let me start now with 6

regulatory history. 7

EPCA established energy conservation 8

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

in EPACT 2005, it prescribes standards for ice cube 10

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

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

prescribed requirements as of January 1, 2010. It 13

also authorized the Department to issue standards 14

for these type of automatic commercial ice- maker 15

machines that are covered under 42 USC 63 13 16

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

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

determine whether to amend applicable standards or 19

to issue new standards as necessary. 20

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

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

Somebody mentioned the timeframe was a little bit 23

earlier, and yes, the Department has started this 24

rulemaking probably a full year ahead of schedule, 25Executive Court Reporters (301) 565-0064 24 based on the legislation, and in addition to this, 1

we’re on a two

- year, compressed rulemaking schedule. 2

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

standards almost two years ahead of the determined 4

schedule of 2015. Go ahead. 5

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

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

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

started this rulemaking earlier than usual? 9

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

general the Department has taken -- has the 11

authority to start rulemakings earlier, but has 12

never really had the opportunity to do so because 13

we’ve been behind the 8

- ball on most of these 14

rulemakings, because we are under the consent 15

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

under the consent decree are being executed on time, 17

so the Department has decided to accelerate 18

rulemakings to pursue other areas for rulemakings. 19

And if anybody’s b een following the activities of 20

the Department, the Department is accelerating the 21

length of time to complete this rulemaking. Usually 22

these rulemakings are three years in the 23

undertaking, and this particular rulemaking, after 24

we’ve done a scoping of the work and what is 25Executive Court Reporters (301) 565-0064 25 involved in terms of the test procedure, we found 1

that the test procedures were pretty much -- fairly 2

in good shape to be adopted in a fairly accelerated 3

manner as a DOE test procedure with some 4

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

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

there is some clarity in terms of the actual 7

equipment. 8

So I guess this is one of the first 9

rulemakings that will go through an accelerated 10

process, and in addition, based on the available 11

resour ces to the Department, the Department has 12

decided at this point in time to start the 13

rulemaking a bit earlier than the schedule would 14

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

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

front office. 17

Okay, s o back to the regulatory history. 18

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

We’ll go through this as we go

-- I’ve laid out the 20

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

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

don’t necessar ily have the pressure of the deadline, 23

because the deadline is 2015, and according to our 24

schedule we will complete that ahead of time. So we 25Executive Court Reporters (301) 565-0064 26 will have a little bit more flexibility, but at the 1

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

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

three

- year schedule for this rulemaking. 4

Okay. So let me get back to the 5

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

masse” test procedure that the Department adopted, 7

the test procedure for this particular equipment 8

were adopted, and that was ARI Standard 810

- 2003, as 9

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

addition, this references ASHRAE Standard 29 -1988 11

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

there is an updated AHRI test procedure, which is 13

8 10

- 2007, and the ASHRAE standard also has been 14

updated to 29-2009. 15

So this is basically the basic scoping of 16

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

procedure for the Department to include the most 18

current test procedures for the two mentioned here 19

in this slide. 20

Okay. I’m going to go into the scope

-- 21

scoping area of the regulation. The regulatory 22

definition as per EPACT, states that the equipment 23

is factory-assembled, not necessarily shipped in one 24

package , 25Executive Court Reporters (301) 565-0064 27 A. Consists of condensing unit and ice making 1

section operating as an integrated unit, 2

which means for making and harvesting ice, 3

and 4

B. May include means of storing ice, 5

dispensing ice, and/or storing and 6

dispensing ice. 7

Next slide, w e’ve included a list of def initions 8

here. Now these are not statutory definitions. 9

These are definitions that we’re going to use 10

throughout the presentation, and we thought we’d 11

provide this slide for clarity in terms of what 12

we’re talking about as we go through the 13

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

the prescribed standards for January 1, 2010 that 15

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

applicable to cube machines only. 17

As you can see, new equipment produced as 18

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

meet these standards. 20

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

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

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

a new standard for continuous flake, and nuggets, 24

and t ube machines with capacities between 50 and 25Executive Court Reporters (301) 565-0064 28 4 , 000 pounds per 24 hour period. 1

Okay. You probably note here that there’s 2

a difference in terms of what the Department was 3

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

machines, but the test procedure and the Department 5

decided that we should look into the additional 6

1 , 500 pound increment because the test procedure 7

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

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

certainly within the prerogative of the Department 10

that we could go further than what we were mandated 11

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

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

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

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

4 , 000 pounds per 24-hour period. 16

Another issue will be the test procedures. 17

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

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

updates to that test procedure so we want to bring 20

that to be current under the current rulemaking. 21

And we also want to explore the part of 22

water use of the ice making equipment, and also 23

there are some concerns about the standby and off24

mode energy use. I also heard that somebody 25Executive Court Reporters (301) 565-0064 29 mentioned controls, automated controls, and probably 1

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

looking at to some level of detail as options. 3

So, here’s our first additional comment or 4

question box. A, DOE welcomes the identification of 5

any additional key scoping issues not identified 6

here or within the framework document. 7

MR. BROOKMAN: So quite a bit of content 8

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

it’s useful the Department supplied these 10

definitions although they said it’s not statutory, 11

and then other issues related to scope. 12

MR. LLENZA: One thing that I do have 13

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

had mentioned the issue of international standards. 15

The Department now has started a process of actually 16

talking to the European Union on international 17

standards. I won’t use the word ha rmonization, 18

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

we are starting to have conversations with the 20

appropriate project managers in Europe for this 21

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

cooler/freezer counterparts yesterday in a 23

t eleconference call, so we are starting to talk to 24

them about this. This is fairly new for the 25Executive Court Reporters (301) 565-0064 30 Department at this point in time. We surely don’t 1

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

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

what information we can share, and as a project 4

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

of the international issues might be beneficial to 6

the US industry also to understand. 7

So as part of this rulemaking, we will 8

probably be contacting European counterparts on some 9

of the technical issues and maybe some of the test 10

procedure issues as we develop them through this 11

rulemaking. 12

MR. BROOKMAN: Yes, Daryl. 13

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

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

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

cooled machine between an open loop and a closed 17

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

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

we’re going to take away some important 20

opportunities for energy savings by treating them 21

all as open loop. 22

MR. BROOKMAN: Is that addressed in the 23

test procedure? 24

MR. ERBS: I would say that the test 25Executive Court Reporters (301) 565-0064 31 procedure doesn’t care. The issue is one of , 1

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

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

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

MR. BROOKMAN: Karim. 5

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

following on the comment that Charles made about 7

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

well, because on the -- when exploring those 9

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

is not going to negatively impact the US industry. 11

And at the same time that you’re looking for

-- 12

you’re looking to international standards, or 13

European standards, the Europeans are not looking at 14

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

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

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

European standards, but Europeans are not looking at 18

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

when dealing with this kind of issue because it 20

might have some significant impact on the industry. 21

MR. BROOKMAN: Harvey Sachs. 22

MR. SACH S: Harvey Sachs. Thank you very 23

much, Charles, for the comments on the 24

international. I want to clarify that there are two 25Executive Court Reporters (301) 565-0064 32 aspects, one which is what we refer to in 1

parentheses as “harmonization” of standards that are 2

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

that could be potentially very important as a 4

competitive advantage or as Karim has suggested, a 5

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

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

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

important that the contractors be instructed to look 9

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

the leading edge of automatic ice making 11

technologies globally, whether or not the standards 12

wind up being globally harmonized. The standard of 13

design and manufacture is important to be revealed 14

as part of this process. Thank you. 15

MR. BROOKMAN: Thank you. 16

MR. LLENZA: And I want to make a 17

clarifying statement. This is Charles Llenza, 18

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

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

in terms of when we have these conversations with 21

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

have several contacts, not only in Europe but in 23

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

dialogue would be also to explore what available 25Executive Court Reporters (301) 565-0064 33 methods and test procedures, information that’s 1

available that the Department could benefit to 2

assist US industry in understanding not only the 3

international markets a little better, but also in 4

terms of improving our equipment here in the United 5

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

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

you have mentioned. 8

MR. BROOKMAN: Other issues that 9

individuals wish to raise? The Department has 10

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

RULEMAKING OVERVIEW 12

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

to the rulemaking overview and framework. The 14

Department uses as a guide the EPCA seven factors, 15

and basically the rulemaking will be following these 16

seven factors that we have them showed on this slide 17

-- economic impacts, consumers and manufacturers, 18

lifetime operating costs, savings compared to 19

increased cost of equipment, total project energy 20

savings, the impact on the utility performance, 21

impact on lessening up competition, need for 22

national energy conservation standards, and other 23

factors as the Secretary considers relevant. 24

Just a reminder that this is a guideline. 25Executive Court Reporters (301) 565-0064 34 We don’t necessarily have to pursue anything 1

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

through the rulemaking in the next two years. 3

The process as identified for these seven 4

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

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

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

The standard will then continue to a preliminary 8

analysis stage where the Department will present the 9

data information, the preliminary -- all the scoping 10

documents et cetera, and that will be available on 11

the web as things come on line. 12

From the preliminary analysis we’ll go 13

into a Notice of Proposed Rulemaking stage, and then 14

at some point, a final rule. 15

As you know, we published in the Federal 16

Register the framework document, November 19 th . And 17

today’s public meeting covers this framework. In 18

addition today’s framework provides the o verview for 19

the rulemaking and I just want to remind everybody 20

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

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

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

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

will become part of the public record. 25Executive Court Reporters (301) 565-0064 35 Here’s the website that we are using, 1

where all the material will be available. 2

I put together a timeline in terms of the 3

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

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

tw o year timeline to complete the standard. Within 6

the standard we are in the process of updating the 7

test procedures through a parallel and conjunctive 8

rulemaking for the test procedure. So today is the 9

framework document. You see the chevrons on this 10

ti meline. You’ll notice the little triangle and 11

today we’re talking framework that was published on 12

November 19 th

. 13

The boxes on the bottom will be, if you 14

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

Today’s meeting is the framework meeting for t he 16

public documents and other information that the 17

Department has provided. We will then have TP NOPR 18

public meeting sometime in the spring 2011. As we 19

develop the preliminary analysis and that becomes 20

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

t hen we will have standards NOPR public meeting 22

sometime in May 2012. These dates are somewhat 23

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

kind of our target timeframes. 25Executive Court Reporters (301) 565-0064 36 In addition, what you’ll see on the top is 1

the different documents that will be published over 2

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

to mention here -- the test procedure final rule 4

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

published on or before the standards NOPR timeframe. 6

So everything looks pretty good on this 7

schedule. We welcome comments to the schedule, of 8

course, since this is something new the Department 9

is doing in terms of compressed timelines for this 10

rulemaking. 11

And as you can see, the estimated final 12

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

think that’s completed my segment of the 14

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

my colleague will take over the presentation. 16

MARKET AND TECHNOLOGY ASSESSMENT 17

MARKET ASSESSMENT 18

19

MS. BRITT: Michelle Britt, Pacific 20

Northwest National La boratory. This morning I’m 21

going to be first of all talk about market and 22

technology assessment analysis. The purpose of 23

market and technology analysis is to thoroughly 24

characterize and understand both the market and the 25Executive Court Reporters (301) 565-0064 37 industry as a whole, not only the baseline but some 1

of, perhaps, the unique features of manufacturers or 2

their markets, and to also identify the potential 3

technological measures that could be applied to 4

increase energy and water efficiency. 5

There are four steps really involved here. 6

Fi rst of all, digging into the material and 7

identifying the potential classes as we understand 8

the manufacturers. And DOE has some of the same 9

questions, I believe it was Megan that brought up 10

the question with regard to how are these classes 11

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

a moment. But understanding the shipments and the 13

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

identifying both the regulatory and the non15

regulatory programs that might affect efficiency of 16

the equipment. 17

So DOE is seeking an-- urging for

-- 18

information specifically on annual shipments into 19

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

by efficiency types, and is there a correlation 21

between those two? Information on the proportion of 22

equipment that goes into a resale market, and input 23

and data on estimates of understanding the market 24

share, equipment features and efficiency trends in 25Executive Court Reporters (301) 565-0064 38 the market as a whole. I’ll stop here for just a 1

moment. 2

MR. BROOKMAN: Okay. So several important 3

questions there. Karim. 4

MR. AMRANE: K arim Amrane, AHRI. As far 5

as the shipment information, I think AHRI can help 6

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

to share this information with the government so we 8

will do that. 9

MR. BROOKMAN: What about the trends? 10

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

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

MR. BROOKMAN: Okay. Other comments. 13

Several questions here: resale, efficiency trends, 14

distribution channels? Daryl. 15

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

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

think the channels identified are correct, but in 18

the framework document the percentages that go 19

through the different channels is -- is pretty far 20

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

that’s somethin g that maybe again, through AHRI 22

might be the most appropriate way for us to provide 23

better estimates of how much product goes through 24

wholesale and then a dealer channel, versus other 25Executive Court Reporters (301) 565-0064 39 levels of steps. 1

MR. BROOKMAN: Okay. Thank you. 2

MR. LLENZA: Th is is Charles Llenza, 3

Department of Energy. The Department welcomes the 4

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

channels should be. 6

MR. BROOKMAN: Additional comments as you 7

see in these comment boxes here. Nothing on the 8

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

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

have them. 11

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

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

trade shows and spoken with manufacturers and 14

distributors. We’ve researched through catalogs and 15

the marketing materials. Researched analysis that’s 16

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

and have evaluated some of the past and current data 18

resources. We’ve also evaluated the international 19

standards that we could obtain -- Australia, New 20

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

So on this table here are some of the 22

potential classes for commercial ice- maker s as we 23

un derstand it through the manufacturers’ analysis 24

thus far. Going back to the adoption or the 25Executive Court Reporters (301) 565-0064 40 development and adoption of the California standard, 1

our understanding is that flake and nuggets have 2

been considered through the development of this 3

standard. The issue came up with the test procedure 4

adoption for the initial EPACT 2005 standard for 5

ice

- makers, specifically, some of the manufacturers 6

at that point pointed out that the standard could 7

and should be extended to the flake and nugget 8

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

next evaluation of the standard that they would 10

consider such. 11

There are questions about the harvest 12

rates. Here we have the harvest rates breakdowns as 13

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

standard was extended to include the continuous 15

flake and nugget machines, do those same harvest 16

rate breakdowns apply, or would there be different - 17

- appropriate different harvest rate breakdowns? 18

And in understanding some of the 19

manufacturers’ information, are the cl asses broken 20

down most appropriately by type of ice produced, or 21

by the technology of the equipment that produces 22

that ice? That particularly becomes a question when 23

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

the smaller capacities, and is the critical feature 25Executive Court Reporters (301) 565-0064 41 there the output of the ice or the technology? And 1

so we have questions with regard to tube machines, 2

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

be along with the cube in the batch equipment? 4

And then finally, a question that we have 5

on this table, is the equipment that is specifically 6

designed to be attached to a remote rack system, 7

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

little bit more with the test procedure issues, but 9

in terms of looking at these classes and assessing 10

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

at this point. 12

MR. BROOKMAN: John. 13

MR. BROADBENT: This is John Broadbent, 14

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

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

the harvest rates shown in the previous slide. 17

Those breakdowns are a function of -- so for 18

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

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

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

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

In other words, there was a plot of energy 23

efficiency versus capacity, and when you draw 24

straight lines through that data, you can’t do it 25Executive Court Reporters (301) 565-0064 42 with one straight line. So if you have two straight 1

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

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

three lines, and those two numbers where the three 4

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

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

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

that also only applied to data at that time. 8

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

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

number, and possibly you would not get three break 11

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

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

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

nugget would be also completely different. 15

MS. BRITT: Okay. 16

MR. BROADBENT: And then I wanted to talk 17

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

when they talked about flake and nugget machines. 19

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

or ARI at the time, that characterized the 21

efficiencies of flake and nugget machines, and so 22

they couldn’t really include it. But everyone 23

understood at that time that they were significantly 24

more efficient than cube type ice machines. 25Executive Court Reporters (301) 565-0064 43 You also mentioned tube type ice machines, 1

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

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

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

continuous mode, like flake and nugget machines. 5

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

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

be considered cube ice. 8

And then the final thing you mentioned 9

rack systems. The issue there is that the 10

manufacturers don’t know when they make the ice 11

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

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

And it’s an application question, not a 14

manufacturing question. 15

MS. BRITT: Great. 16

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

these machines, correct? 18

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

you can tell the Department how they would fix these 20

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

and the different harvest capacity rates, so for 22

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

probably go through the same process that was done 24

before where you plot the machines you want to 25Executive Court Reporters (301) 565-0064 44 regulate, capacities across the bottom, energy 1

efficiency on the vertical axis, and then I know 2

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

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

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

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

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

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

example. 9

There is a challenge in doing that, if you 10

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

exclude certain categories. So for example, if you 12

had flake and nugget machines, and cube ice machines 13

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

have flake and nugget machines all passing, and cube 15

machines all failing. 16

MR. BROOKMAN: Just to be more specific, 17

can you say how the Department should differentiate 18

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

to you next. 20

MR. BROADBENT: From Scotsman’s 21

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

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

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

that is actually a pretty good breakdown. I would 25Executive Court Reporters (301) 565-0064 45 warn against putting cube and batch-type ice 1

machines and continuous type ice machines, in other 2

words, flake and nugget machines, together in the 3

same category because what will happen is, as I 4

said, all the continuous machines will have a very 5

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

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

all fail. 8

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

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

however, as you look at these capacity rates that 11

are shown there -- 12

MR. BROADBENT: Yes. 13

MR. BROOKMAN: -- how would you recommend 14

that that be split? 15

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

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

see it. 18

MR. BROOKMAN: Please -- go ahead. 19

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

MR. BROOKMAN: Say your name. 21

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

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

very helpful to know how these harvest rate 24

breakdowns were created initially, and so thank you 25Executive Court Reporters (301) 565-0064 46 very much for that information. And I think that’s 1

something the Department definitely should do is try 2

to recreate these lines based on current technology 3

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

the Department is considering separating cube and at 5

least continuous-type ice

- makers into separate 6

product categories, and perhaps separating that 7

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

depending on feedback that we get from the 9

manufacturers. 10

But in setting those lines, setting the 11

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

Department to have any data that manufacturers have 13

for cube type or continuous type ice- maker s that we 14

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

difficult for us to draw those lines without data. 16

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

make sure I -- 18

MR. AMRANE: Actually we would support 19

separating, you know, continuous machine from ice 20

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

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

a vailable in the AHRI directory and then drawing 23

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

done, okay. We need to look at shipments as well, 25Executive Court Reporters (301) 565-0064 47 because it’s nothing to see there is one product 1

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

hundr ed thousand shipped. So I think what you’re 3

going to get from us is going to be probably 4

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

better idea of how to draw the lines. 6

MR. BROOKMAN: That’s helpful. 7

MS. WIDDER : Thank you very much. 8

MR. BROOKMAN: Yes, thank you. Harvey 9

Sachs

. 10

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

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

classification, the basic taxonomy to the extent 13

possible, should be based on the customer’s 14

perspective, and by metapho r, there’s only a limited 15

substitute-ability for customer looking for a side16

by

- side refrigerator versus a top freezer 17

refrigerator. So taking a customer perspective for 18

the taxonomy, the classification, would seem to be 19

the first point. 20

The second one, which bleeds into that, is 21

the batch versus continuous, which is a technology 22

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

particularly relevant to the extent that its 24

nonsubstitutability. If the continuous ice is 25Executive Court Reporters (301) 565-0064 48 inherent a cloudy ice that’s not going to be used 1

with single malt scotch, that’s an important 2

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

are used in some sort of quasi-industrial 4

application where there’s substitutability, then I 5

get very concerned about separating out a less 6

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

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

that the Department will be very, very sensitive to 9

how the customer looks at the product. 10

MR. BROOKMAN: Charles Llenza. 11

M R. LLENZA: I’m Charles Llenza, 12

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

important that the stakeholders at this point look 14

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

actually make strong comments as to what it should 16

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

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

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

beginning. 20

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

are continuing to focus in on these proposed classes 22

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

Daryl. 24

MR. ERBS: Hi, Daryl Erbs. So I’ll start 25Executive Court Reporters (301) 565-0064 49 with the response to Harvey’s question or point, 1

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

argue that continuous type ice and cube ice type are 3

not direct substitutes. They’r e alternates. They 4

have very different characteristics that leads to 5

very different underlying technology and processes 6

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

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

together. So I think from my perspective, clearly 9

they need to be separated. 10

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

agree that it really falls into the same general 12

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

caution lumping it together because the different 14

machines in the industry have really come out of 15

different applications and so if you look at tube 16

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

the same size ranges that we have for other batch 18

cube machines, it still largely came out of ice 19

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

physical size of the equipment, it typically is 21

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

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

larger capacity, the size of an ice making cap 24

really matters a lot. We have very limited space 25Executive Court Reporters (301) 565-0064 50 available in a restaurant, in a hotel, in a casino, 1

the places where we put ice machines. Typically, 2

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

efficiency and also the cost of a machine is going 4

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

much material you use. 6

So my argument would be that the standards 7

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

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

classification of different formats, my suggestion 10

would be that you would look at that one as 11

potentially another format that falls within batch, 12

but still gets treated separately because of the 13

range of sizes that that technology has been based 14

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

being somewhat different from some of the other 16

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

important point. 18

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

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

-- I 20

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

standards for display cases, and so there is a 22

precedent there, but I would be concerned about the 23

amount of effort it would take the industry to come 24

up with -- because we would need totally different 25Executive Court Reporters (301) 565-0064 51 rating and test procedure to handle that. 1

The ice making heads that get applied to 2

rack systems are typically a derivative of the ice 3

making heads that would go with some type of a 4

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

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

completely different design for a rack system. And 7

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

try to regulate that separately, given all the 9

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

to do the analysis on. 11

But I think if we regulate all these other 12

classes, you’ve effectively driven the technology to 13

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

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

making head. Most of the energy consumption is in 16

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

going to achieve a whole lot by bringing that new 18

class into the regulatory sphere. 19

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

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

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

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

clarify. You were talking about the difference 24

between cube and tube type ice machines, and the 25Executive Court Reporters (301) 565-0064 52 need to separate, and this is actually for all of 1

the stakeholders. I understand the difference in 2

application based on space and a number of things 3

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

quality or the type of ice produced from a consumer 5

perspective, or as Harvey mentioned, to put in 6

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

is there a difference there? 8

MR. ERBS: Well, I would -- 9

MS. WIDDER : I’m as king. 10

PARTICIPANT: Any port in a storm. 11

MR. ERBS: I personally would never put 12

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

type ice machines. We have certain corporate 14

standards that we’re

-- 15

MR. BROOKMAN: I just want to note that 16

this is why people are so attached to testing 17

procedures. Go ahead, I’m sorry. 18

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

really speak to the possibilities in terms of 20

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

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

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

that

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

anything, particularly in these proceedings that 25Executive Court Reporters (301) 565-0064 53 would say well, this is a different kind of ice 1

because -- it has some different characteristics 2

from a shape standpoint, because you make a long 3

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

it’s maybe a little different in terms of form

-- we 5

all make different shapes of cubes, and customers 6

have their own preferences, and we let customers 7

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

wouldn’t use that as a basis. 9

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

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

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

-- if 12

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

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

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

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

driven by the highest volume typical size 17

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

out of different needs. The designs have evolved to 19

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

a basis for differentiating them. 21

MS. WIDDER : Thank you very much. 22

MR. BROOKMAN: Harvey Sachs. 23

MR. SACHS : Harvey Sachs. Humorously, I 24

have to correct myself. I do not put any ice in 25Executive Court Reporters (301) 565-0064 54 scotch. Rum, yes, but scotch, no. 1

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

record. 3

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

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

decade, I believe it is inappropriate to have 6

technology-based standards, and this whine has been 7

particularly intensive in terms of different 8

efficiency levels for screw-type and centrifugal 9

chillers of the same capacity for that application. 10

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

object ed to different efficiency standards for 12

different output capacities, for different abilities 13

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

continuous classes. They seem to serve different 15

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

the difference between two batch processes, two 17

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

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

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

hard to demonstrate that they’re not both 21

predominantly used in health care and hospitality. 22

Is that clear? 23

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

this last discussion was very good, and I’m eager 25Executive Court Reporters (301) 565-0064 55 for us to move on, unless there was additional 1

things to be raised right here. Joanna. 2

MS. MAUER: Joanna Mauer. Just a couple 3

of questions. Are combination soda/ice machines 4

captured in these product classes at all? 5

MS. BRITT: They are captured in the 6

product classes, and it depends, though, sometimes 7

soda ice machines actually have the ice made 8

separately and then integrated, and then sometimes 9

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

separate chiller systems. So there’s separate 11

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

within that. 13

MS. MAUER: And so they would be 14

classified based on the type of ice they produce? 15

MS. BRITT: Yes. 16

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

crushed ice? 18

MS. BRITT: That goes back to are we 19

classifying by technology or are we classifying by 20

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

And if we are classifying by technology, then 22

crushed and cracked? You said cracked? 23

MS. MAUER: Chipped. 24

MS. BRITT: Chipped -- no, in talking to 25Executive Court Reporters (301) 565-0064 56 different manufacturers there seems to be different 1

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

ice and then dropping it by gravity and it shatters 3

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

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

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

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

marketing te rm, and I’m sure that I will be 8

corrected if we’ve got that wrong. 9

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

here

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

chipped is not a -- 12

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

definitions on page 12, you did not list chipped 14

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

MS. BRITT: May I follow up? 16

MR. BROOKMAN: Please do. 17

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

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

or 4,000 pound

-- two machines and they were both 20

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

Manitowoc’s traditional technology, then I believe, 22

if I understand correctly, Harvey Sachs is saying he 23

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

Erbs is saying no, they would be in separate 25Executive Court Reporters (301) 565-0064 57 categories -- or classes, excuse me. 1

MR. BROOKMAN: Daryl first. 2

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

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

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

found that as size changed, efficiency changed 6

because you moved into different technology bases, 7

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

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

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

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

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

to make that break. 13

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

understand the dynamics of the applications. You 15

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

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

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

scientific basis that there’s no good reason to 19

separate them because a batch machine is a batch 20

machine, and all technology should compete on an 21

equal basis. If they fundamentally change the size 22

of the machine or some other characteristic of the 23

machine, that may make it unattractive to a certain 24

class of end users, and so I’m concerned, without 25Executive Court Reporters (301) 565-0064 58 understanding it more clearly, that we may do harm 1

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

other rulemaking which may cause people to buy too 3

smaller devices instead of one larger device, 4

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

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

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

technology that would fit in their application, they 8

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

be less efficient. 10

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

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

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

understand how we might affect market dynamics by 14

forcing efficiency levels to different points. 15

MR. LLENZA: Charles Llenza, Department of 16

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

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

understand the technology is probably, in light of 19

your comment, would be understandable. 20

MR. BROOKMAN: Jeff, do you want to 21

comment here? 22

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

little bit on the chipped and crushed and nugget, 24

flaked. 25Executive Court Reporters (301) 565-0064 59 MR. BROOKMAN: Well , let’s let Harvey 1

follow on to Daryl’s comment. 2

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

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

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

say that my presumption is that capacity and 6

differentiation of the end product are good ways to 7

begin the process. I think its incumbent upon the 8

industry to establish that there are other things, 9

and what you’ve mentioned has sounded like space 10

constrained which came up in residential air 11

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

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

And it’s just conceptually trying to 14

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

personally, to see a different standard for a 200 16

ton screw than a 200 ton centrifugal. They are 17

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

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

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

their markets differ? How do their user needs 21

differ that will warrant separate classification in 22

the standards process? 23

MR. BROOKMAN: Okay, Jeff. 24

MR. BIEL: Yeah, just to clarify a little 25Executive Court Reporters (301) 565-0064 60 bit about chipped and flaked and nugget and 1

everything. Compressed ice is kind of the generic 2

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

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

Some manufacturers call it nugget, some call it 5

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

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

talking about some different devices than can be 8

used that are separate that are actually crushing a 9

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

different technologies out there to create these 11

different ice forms. So not everyone calls their 12

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

particular manufacturers. 14

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

Joanna. 16

MS. MAUER: Joanna Mauer. Thank you for 17

that clarification. I just encourage DOE, in coming 18

up with definitions for the product classes, to just 19

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

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

term is for the classification, just that the 22

definition is broad enough that regardless of how 23

manufacturers refer to these types of machines that 24

they’re covered. 25Executive Court Reporters (301) 565-0064 61 MR. BROOKMAN: Good. Thank you. Okay. 1

MS. BRITT: The final market assessment 2

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

the harvest rate capacities, and initially the test 4

procedure was only applicable for up to 2,500 5

pounds, but the new test procedure that is available 6

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

However, manufacturers are currently using that test 8

procedure on equipment with harvest rates greater 9

than 4,000 pounds. 10

So in assessing that market, we’ve been 11

trying to evaluate what is the natural, appropriate 12

threshold for the top of this energy conservation 13

standard, and where is that not only technology 14

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

look at different technologies with different 16

capacity thresholds in different markets. You have, 17

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

to 200 pound range harvest capacities. The ones, 19

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

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

very few manufacturers that are really in that four 22

to 7 ,000 pound h arvest rates. 23

So again, that’s what we’ll be 24

considering. Absolutely welcome input on what is 25Executive Court Reporters (301) 565-0064 62 seen as both a technological natural ceiling for the 1

harvest rate capacities. Sarah will be addressing 2

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

test procedure issues, but specifically if they’re 4

market and technology issues with that ceiling. 5

MR. LLENZA: This is Charles Llenza, 6

Department of Energy. I want to make a little 7

clarification because when we talk definitions, it 8

depends on what definiti on we’re talking about. 9

The regulatory definition is basically 10

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

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

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

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

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

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

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

that particular product, of the ice in question. 18

The equipment and shipments that’s out th ere, you 19

figure utility, and then the market utility of that 20

equipment. 21

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

at the definition very broad, the regulatory 23

definition on slide 11 is very broad. The trick 24

here is to make sure as has been said in the meeting 25Executive Court Reporters (301) 565-0064 63 here that we are not eliminating classes of 1

equipment because we lump them together, that we 2

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

driving the market to eliminate classes of equipment 4

just because we’ve classified them individually in 5

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

this is kind of important. 7

Again, the Department would appreciate any 8

further guidance on this that the industry can 9

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

this right because the definition itself is so broad 11

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

Now, of course, if you look at the 13

prescribed requirements, this is all we have, which 14

is the second category of guidance. And it just 15

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

t ime, as has been mentioned here. So that 17

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

information has changed now, based on the industry 19

and the industry’s moved into different directions, 20

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

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

practicality of using that kind of arrangement for 23

classifications of equipment, et cetera. So I just 24

wanted to clarify that. 25Executive Court Reporters (301) 565-0064 64 MR. BROOKMAN: So going back to this 1

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

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

issues have been addressed. Comment D, remote 4

compressor rack, maybe E, somewhat addressed harvest 5

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

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

all, right now. Harvey. 8

MR. SACHS : Harvey Sachs. Backing up to 9

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

be appropriate to ask AHRI for what their preferred 11

classification would look like, not with respect to 12

efficiency levels, but to the classes that reflect 13

the market for these products? 14

MR. BROOKMAN: I think you mean in the 15

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

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

that correct, Karim? Yes? 18

MR. AMRANE: Well, we will be collecting 19

data and based on that we’ll probably be able

-- 20

recommending classifications or to keep those 21

classifications or to change them. 22

MR. BROOKMAN: Thank you. That would 23

certainly be something that earlier would be more 24

helpful than later. Thank you. 25Executive Court Reporters (301) 565-0064 65 So I wish to call your attention to the 1

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

on this as possible. Yes, Karim. 3

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

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

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

commercial and industrial. When you get beyond 7

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

feel that is outside the scope of this rulemaking in 9

the first place. So we will support keeping the 10

scope up to 4,000 pounds. 11

MR. BROOKMAN: Okay. 12

MS. BRITT: Can I ask for clarification? 13

MR. BROOKMAN: Please do. 14

MS. BRITT: Can you expound a little bit 15

on your definition of industrial, from a marketing 16

perspective. 17

MR. AMRANE: I’ll let the manufacturer 18

explain that better. 19

MR. BROOKMAN: Daryl? 20

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

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

guess from a perspective, there are industrial uses 23

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

Pharmaceutical, plastics, bread making all use ice, 25Executive Court Reporters (301) 565-0064 66 believe it or not for temperature control purposes, 1

and they would typically be large factories that 2

would have on site production facilities and they 3

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

custom engineered factory a nd they’re putting some 5

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

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

and a capital investment standpoint. 8

Even an industrial plant for ice delivery 9

systems, again typically would have a very different 10

business model associated with it, and so how the 11

ice machine factors into the overall investment and 12

return on investment, I think, drives different 13

decision points around efficiency and first cost. 14

Commercial to me, you know, it’s 15

restaurants, it’s institutional, it’s

-- I mean it 16

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

more closely associated with some type of food 18

product, whether it be retailing food or service of 19

food, and maybe a few other related areas. 20

MR. BROOKMAN: Beverages and the like. 21

Jeff. 22

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

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

industrial is manufacturing or process-based usage 25Executive Court Reporters (301) 565-0064 67 where commercial ice, in the realms that we work, is 1

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

service, health care, lodging. 3

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

you want them to talk about capacity? 5

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

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

talking about the capacity machines that are over 8

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

for food service and lodging, maybe in a large 10

resort or a larger type facility. We understand the 11

clear industrial uses, thermal storage and things 12

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

still for beverages, still for human consumption, 14

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

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

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

clear break point? Yes. 18

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

that’s a pretty good break point. 20

MR. BROOKMAN: So some huge casino, they 21

don’t have industrial scale machines? 22

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

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

I mean there’s also an issue of logistics of getting 25Executive Court Reporters (301) 565-0064 68 ice from one side to another, so you’re going to 1

have multiple ice stations. 2

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

that. Yes, please. 4

5

MR. BROADBENT: John Broadbent. From a 6

technical standpoint, this is a natural break point. 7

There is an issue with testing very large ice 8

machines, and that is the test standard says you 9

have to supply 90 degree Fahrenheit air within a 10

very tight tolerance, and if you have a machine 11

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

-- and 12

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

at some point you have a really hard time finding 14

test facilities that are capable of providing that 15

amount of air at that temperature. And with this 16

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

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

problem finding some place to test it. 19

MR. BROOKMAN: Harvey. 20

MR. SACHS : Harvey Sachs. Think about it 21

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

seems to me that we’ve transitioned to the 23

industrial class when we get into very low 24

production volumes of products that are largely 25Executive Court Reporters (301) 565-0064 69 customized, rather than largely picked off an 1

auction list. And the situation seems to be, 2

Michelle, very much analogous to the rather 3

arbitrary, but useful, line between commercial and 4

indu strial boilers. 5

And from public policy perspective, even 6

though there are some of these machines out there, 7

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

also a sense that the customers buying them have 9

access to more insight into life cycle costing and 10

are more likely to be making intelligent decisions, 11

may not need the Department’s help. 12

MR. BROOKMAN: Okay. Did we cover all 13

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

MS. BRITT: I will very quickly touch on 15

regulatory and non-regulatory initiatives. DOE has 16

been exploring both of these and taken a look at 17

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

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

whether they’re incentivized, voluntary, or 20

mandatory, that may affect either the end user or 21

the manufacturer, that may affect market trends, et 22

cetera. 23

MR. LLENZA: This is Charles Llenza, 24

Department of Energy. For somehow we had put 25Executive Court Reporters (301) 565-0064 70 regulatory and non-regulatory, so this slide has a 1

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

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

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

other box it’s a breakdown of the non

- regulatory, 5

just for clarification. 6

MS. BRITT: My -- I’m sorry. 7

MR. BROOKMAN: Karim. 8

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

MS. BRITT: May I explain this slide, 10

Charles? 11

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

MS. BRITT: My objective in having the pie 13

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

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

application in any type of building. The same with 16

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

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

FEMP and compare them to the standards as though 19

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

focused on their members, focused on the commercial 21

kitchens, and the utility within the kitchen. 22

And my purpose in having the pie chart 23

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

have been very valuable, it doesn’t ap ply to the 25Executive Court Reporters (301) 565-0064 71 entire ice markets -- ice

- maker market. 1

MR. LLENZA: This is Charles Llenza, 2

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

members that we took those two points out because 4

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

MR. BROOKMAN: So then the shares in the 6

actual pie chart, what do they represent? 7

MS. BRITT: The shares represent the 8

approximated actual energy use by automatic ice9

maker s within different types of buildings. So you 10

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

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

would welcome input on these assumptions. Okay, 13

these are numbers originally based in 1993, updated 14

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

spread across the industry. 16

The point is, they’re n ot all used in 17

kitchens. So we a re looking for information and the 18

insight you have on both regulatory and non19

regulatory incentives that may impact your industry. 20

Two seconds and I’m on your point. 21

MR. BROOKMAN: And I know that several of 22

our members from industry are shaking their heads, 23

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

suggests that health care is 39 percent of the 25Executive Court Reporters (301) 565-0064 72 commercial ice-maker energy use? 1

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

ahead a few slides, and I’ve got

-- this is 3

s omething I was going to address more in energy use 4

this afternoon. 5

Here we go. Going back over the last 20 6

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

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

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

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

data that has been available on commercial ice-maker 11

use. 12

Originally we had estimates that had been 13

made by ADL back in 1990 of ice-maker

-- ice -makers 14

per building. And then based on -- of cours e we 15

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

numbers that were available, they extrapolated from 17

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

square feet of that type of building, across through 19

efficiencies and utilization factors, and arrived at 20

that pie chart. 21

And that pie chart has been living in the 22

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

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

energy use, is the need to update those assumptions, 25Executive Court Reporters (301) 565-0064 73 both utilization factor, and duty cycle, those have 1

changed from the early 1993 report where there’s 2

some variation across building types, to the latest 3

information that was confirmed by manufacturers in 4

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

So, we welcome up-to

- date inp ut on ice6

makers per building type. We can extrapolate then, 7

using CBEC’s data and update the pie chart 8

appropriately. 9

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

specific parameters here further down in the 11

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

want to receive comment on this pie chart now or 13

does that come later? 14

MS. BRITT: Could we do it later? 15

MR. BROOKMAN: Okay. That sounds good. 16

MS. BRITT: Or whatever works best for 17

you. 18

MR. BROOKMAN: Daryl Erbs, go ahead. 19

MR. ERBS: One comment. 20

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

for. Go ahead. 22

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

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

and I don’t know who’s going to manage this, but one 25Executive Court Reporters (301) 565-0064 74 of the concerns I do have is as we move forward that 1

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

break points aligned with what we do for the 3

efficiency standards. Because CEE, through their 4

utility member companies, provide rebates that are 5

important to us and do drive decisions that we make 6

o n design changes to our ice machines. 7

And so just as we would like a standard 8

approach for regulations with Energy Star and DOE 9

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

standards between what CEE is doing and the federal 11

regulations. 12

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

MR. ERBS: Well, they work. John 14

mentioned doing through California, actually it was 15

harmonized in that CEE. And the current standards 16

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

tiers, and DOE’s starting their rul emaking, so I 18

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

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

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

a really nice thing. 22

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

MR. LLENZA: This is Charles Llenza, 24

Department of Energy. Do you have any contacts 25Executive Court Reporters (301) 565-0064 75 directly in the CEE that we can actually force him 1

to make comments on this for us? 2

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

get you connected with the right person. 4

MR. LLENZA: That would probably be the 5

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

we would like, probably, them to provide direct 7

input to the Department on the framework process. 8

MR. BROOKMAN: Karim. 9

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

using the same classification because it started 11

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

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

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

MR. LLENZA: One last comment on this 15

also. Has the industry found that arrangement with 16

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

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

really means that we probably should continue that 19

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

benefited everybody. 21

MR. BROOKMAN: Yes, Harvey Sachs. 22

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

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

them, but I would observe but their time costing is 25Executive Court Reporters (301) 565-0064 76 substantially shorter than the Department’s. That 1

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

to be deeply analytical. So if DOE works through 3

the process with input from everyone, changes 4

classifications, sets efficiency standards, 5

whatever, that will have a lead time associated with 6

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

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

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

be in future years. 10

MR. BROOKMAN: Thank you. 11

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

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

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

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

over to my colleague, Detlef Westphalen. 16

MR. BROOKMAN: And for those of you that 17

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

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

doing okay? No quest ions, nothing’s come in? 20

TECHNOLOGY ASSESSMENT 21

MR. WESTPHALEN: Thank you, Michelle. 22

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

will be talking about the technology assessment, 24

then later the screening analysis and the 25Executive Court Reporters (301) 565-0064 77 engineering analysis, and I have like a little cameo 1

at the end for manufacturer impact analysis. 2

So moving on to technology assessment, the 3

potential technologies to include in the analysis, 4

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

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

some time here to characterize the technologies with 7

the particular types of equipment, by the type of 8

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

or by water. 10

One thing, getting back to the tube versus 11

cube discussion that we had earlier, that I should 12

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

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

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

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

what the intent is for the definition of equipment 17

class. 18

So, request for comment on the 19

technologies, what technologies or designs, if any, 20

should be added or removed from the list. If 21

certain technologies should be removed from the 22

list , what equipment classes are affected? And in 23

commenting on design options, please discuss any 24

potential impacts on safety, performance, and 25Executive Court Reporters (301) 565-0064 78 consumer utility. 1

MR. BROOKMAN: Harvey Sachs. 2

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

the technologies used, and only think in terms of 4

analogies, but one of those is the potential of 5

adaptive controls to take advantage of learned 6

periods of relatively low ice making capacity 7

requirements, and modulate the capacity to take 8

advantage of the relatively large heat exchanges 9

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

appropriate controls, or the modulating compressor, 11

should not be eliminated from the list of technology 12

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

Again, you’re trying to look at what 14

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

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

applicable to this equipment which is a relatively 17

low range of ambient conditions. Thank you. 18

MR. BROOKMAN: Thank you. Daryl. 19

MR. ERBS: A couple of comments. Our 20

recommendation would be that you not spend a lot of 21

time looking at insulation. Not that I could argue 22

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

there for other reasons, to prevent sweating, to 24

maintain some other characteristics of the machine. 25Executive Court Reporters (301) 565-0064 79 But that one, I mean, you can study it, but it would 1

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

into account in terms of your modeling, unless you 3

have a much more sophisticated model than we do. 4

There are a couple of design options that 5

talk about melting during harvest and thermal 6

cycling of the evaporator, and just my comment on 7

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

unless you understand the means, unless you identify 9

specific technology that somehow leads to that end, 10

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

analysis around it. 12

You could of course say, if we reduce the 13

amount of meltage from ten percent to three percent, 14

that would improve the energy efficiency. We 15

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

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

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

of a broad class of component that there are general 19

engineering principles around how you would improve 20

its efficiency as a component. 21

So that one, I guess, I would challenge 22

unless the Department or its contractor can really 23

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

uncomfortable having that included because it could 25Executive Court Reporters (301) 565-0064 80 drive some technology option decisions that we’re 1

not sure how to get there. 2

MR. LLENZA: T his is Charles Llenza, 3

Department of Energy. Does that have -- the 4

particular issue have anything to do with the 5

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

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

melting or the flake, whatever, if you have 8

in sulation, for example, does that help retain that 9

particular product that the machine is making, 10

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

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

necessarily make the equipment more efficient in 13

produci ng the cube, but in terms of the retention of 14

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

insulation might have some effect on that melting of 16

the ice, I guess. 17

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

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

-- 19

my perspective is we’re not talking about rulemaking 20

that relates to the efficiency of a storage bin. 21

MR. WESTPHALEN: Just in clarification -- 22

sorry, just in clarification, this list was not 23

intended to look at storage. Standby issues, of 24

which, you know, the thermal storage issues could be 25Executive Court Reporters (301) 565-0064 81 a part are under consideration, but this is focused 1

directly on the ice production. 2

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

keep going? 4

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

MR. BROOKMAN: Okay. John. 6

MR. BROADBENT: Certainly, Scotsman 7

Industries can help you with your list. I think 8

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

out a couple clarifications there. On drain water 10

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

actually should be a check. And likewise, less 12

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

checked. 14

MR. BROOKMAN: Okay. 15

MR. WESTPHALEN: Those are -- 16

MR. BROADBENT: They’re essentially the 17

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

and so the same technology things should apply. 19

MR. BROOKMAN: Okay. 20

MR. WESTPHALEN: I guess just some 21

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

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

same water use per 100 pounds as the flake or 24

nugget, they’re using all of it. 25Executive Court Reporters (301) 565-0064 82 MR. BROADBENT: Well, they sometimes use 1

upstream, like a reverse osmosis system so that they 2

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

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

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

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

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

it’s the same process. 8

MR. WESTPHALEN: Okay. 9

MR. BROOKMAN: As long as you understood 10

that, that’s wh at matters. 11

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

marching orders to find out more and to ask 13

questions. 14

MR. BROOKMAN: Joanna. 15

MS. MAUER: Joanna Mauer. So just 16

clarification questions. Is DOE proposing to 17

include any energy use associated with the actual 18

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

at energies? 20

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

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

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

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

technology at this point, and issues of the test 25Executive Court Reporters (301) 565-0064 83 procedure. I don’t know if we want to even wander 1

into this territory now, Charles. 2

MR. LLENZA: This is Charles Llenza, 3

Department of Energy. At this point, we would 4

strongly recommend the industry weigh in on what 5

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

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

this should be considered. So comments would be 8

appreciated. 9

MR. BROOKMAN: In terms of storage? 10

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

of this particular rulemaking. 12

MR. BROOKMAN: And detailed, written 13

comments, I presume. Karim. 14

MR. AMRANE: This is Karim Amrane. I 15

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

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

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

administration directed you to look at is really the 19

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

MR. BROOKMAN: Yes, I see some industry 21

members -- Jeff first. 22

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

i s being put into the making of the ice, after that 24

it’s kind of out of the manufacturer’s hands. 25Executive Court Reporters (301) 565-0064 84 There’s no more energy being put into the storage 1

bin. 2

MR. BROOKMAN: Okay. Daryl. 3

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

if there’s interest in creati ng regulation around 5

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

rulemaking. It would have a much wider set of 7

stakeholders, because you’ve got besides just the 8

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

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

range of ways that ice gets stored after it gets 11

produced. And so I think it would be overly 12

complicated to try to integrate that into this. It 13

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

handle that separately. 15

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

MR. ALTMAN: Yes, Ari Altman from 17

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

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

this framework and the rulemaking relates to our 20

authority under the statutes which specifically 21

references the regulation of the ice-maker 22

themselves. So the storage component, to the extent 23

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

do think that that may be a separate issue from this 25Executive Court Reporters (301) 565-0064 85 rulemaking that we’re involved in right now. 1

MR. BROOKMAN: Sarah. 2

MS. WIDDER : 3

Sarah Widder, Pacific Northwest National Lab. Just 4

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

discussions of including storage bins in some 6

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

that contain the storage bin as part of an 8

integrated unit, as per the statutory definition. 9

But we do welcome comments on whether that is within 10

the scope or should be treated separately. But that 11

would just be an application to self-contained 12

units, that it’s part of t he ice-maker itself. 13

MR. BROOKMAN: Daryl. 14

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

say a self-contained ice

- maker because of the 16

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

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

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

transfer through that storage section, which would 20

then somehow be accounted for in the standard, that 21

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

would be treating them differently than all of the 23

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

comes from them also melts. It’s just someone 25Executive Court Reporters (301) 565-0064 86 else’s piece of hardware, so you’d be creating a 1

double standard if you tried to do that. 2

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

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

perhaps the percentage of meltage, or what the scope 5

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

easier to understand the justification for treating 7

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

effect. So welcoming that data. 9

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

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

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

MR. WESTPHALEN: Okay. Condenser water. 13

As we talked about earlier, the current DOE standard 14

does regulate condenser water, use of water cooled 15

products or equipment, and in considering technology 16

options for condenser water, DOE grappled with some 17

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

previous discussion. 19

First of all, if we reduce condenser water 20

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

impacts and also the environmental impacts of 22

condenser water use reductions could vary, depending 23

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

dumped down the drain. You could be using pumped 25Executive Court Reporters (301) 565-0064 87 well water. You could be using cooling tower water. 1

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

implications are very different depending on which 3

of those sources provide the water. 4

And DOE has not, at this point, identified 5

any clear energy saving technologies that directly 6

save condensing water, but in some sense indirectly, 7

the energy saving technologies could save condenser 8

water because a condenser water reduction, then, 9

could be mitigated by energy efficiency improvements 10

elsewhere. 11

So DOE seeks comment, whether any 12

technology options not yet identified are available 13

to reduce condenser water use, and seeks data 14

sources on the prevalence of the different sources 15

for the cooling water. 16

MR. BROOKMAN: Harvey Sachs. 17

MR. SACHS : Harvey Sachs. Jus t very 18

briefly. To me it is absolutely critical to 19

differentiate consumptive water use in making ice 20

and a little bit of melt water from closed water 21

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

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

appl ication from a water loop that’s connected to 24

heat rejection elsewhere. 25Executive Court Reporters (301) 565-0064 88 MR. WESTPHALEN: I guess in taking in your 1

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

the DOE regulations have authority over the 3

equipment, but not necessarily over the 4

appli cations, and Ari might be able to chime in a 5

little bit. And so in order to address your 6

comment, we obviously have to get around them, 7

figure out how to deal with that. 8

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

where you’ll find that industry and the ad vocates 10

would be quite instinctively inclined toward helping 11

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

up to be fairly energy efficient, depending on the 13

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

than ambient. We can get a pretty good heat 15

exchanger. That could look like it has a strong 16

advantage over both an air cooled, particularly in a 17

self

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

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

that advantage given to once-through units for which 20

the energy consumption in processing that water is 21

externalized. This is an environmental issue. 22

MR. BROOKMAN: I notice that one or two 23

manufacturers are nodding their heads in agreement. 24

John. 25Executive Court Reporters (301) 565-0064 89 MR. BROADBENT: This is John Broadbent. I 1

would agree that -- first of all, manufacturer 2

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

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

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

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

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

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

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

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

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

control how it’s us ed. 12

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

understanding, John, is that it is conventional 14

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

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

ice making process from the -- 17

MR. BROADBENT: They all do. 18

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

a technical distinction between units designed to be 20

able to do pump and dump from -- 21

MR. BROADBENT: All water-cooled machines 22

have a separate system for the cooling water from 23

the potable water. 24

MR. SACHS : S o we have a basis that we can 25Executive Court Reporters (301) 565-0064 90 use, I think. 1

MR. WESTPHALEN: I guess I would ask the 2

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

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

not the other? 5

MR. BROOKMAN: John, on the record. 6

MR. BROADBENT: No. 7

MR. BROOKMAN: John says no. 8

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

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

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

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

inspector coming in and verifying whether a water13

cooled machine is hooked up to a recirculating 14

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

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

than just rulemaking. We would have to work at 17

other levels to make that happen. 18

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

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

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

be needed with -- 22

MR. BROADBENT: No, actually, pump and 23

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

side. 25Executive Court Reporters (301) 565-0064 91 MR. SACHS : They do not? 1

MR. BROADBENT: They do not. 2

MR. SACHS : So where this takes further 3

work and certainly code issues, labeling of 4

mechanisms -- what’s important to me at this point 5

is that, at minimum, that we not be penalizing the 6

use of a closed loop relative to an air source unit. 7

MR. BROOKMAN: We’re going to take one 8

more slide. 9

MR. WESTPHALEN: Next we talk a little bit 10

about potable water -- 11

MR. BROOKMAN: Two more slides. 12

MR. WESTPHALEN: Potable water currently 13

i s not regulated, and this was mentioned as one of 14

the key issues. DOE is considering the regulation 15

of potable water. Reducing potable water use is 16

expected to reduce energy use. DOE has not 17

identified any particular technologies that will 18

allow a redu ction of potable water use. You’ll 19

remember in the slide showing energy saving 20

technologies, reduction of potable water use was 21

listed, but no particular technologies for reducing 22

potable water use. 23

And so we have additional comments on 24

potable water -- requests for comments on potable 25Executive Court Reporters (301) 565-0064 92 water use, and these touch also, I believe, on 1

condenser water as well. First of all, DOE requests 2

feedback on potable water use as a metric, 3

specifically, should DOE be regulating potable water 4

use? 5

MR. BROOKMAN: Read all of them so they 6

can respond to all of them. 7

MR. WESTPHALEN: Okay. Item 3-12. DOE 8

requests comment on the relationship between potable 9

water use and energy efficiency. Specifically, to 10

what degree is potable water efficiency likely to 11

increase with increased stringency of energy 12

efficiency requirements for the ice-makers covered 13

under this rulemaking, without explicit potable 14

water efficiency requirements? 15

Item 3- 13 . DOE seeks feedback on 16

including total water use in the technological 17

assessm ent. 18

Item 3- 14. DOE seeks input on what 19

technologies or designs should be considered to 20

improve water efficiencies, both potable and 21

condenser water. 22

MR. BROOKMAN: Joanna. 23

MS. MAUER: Joanna Mauer. Just on the 24

first item, I just wanted to reiterate that we 25Executive Court Reporters (301) 565-0064 93 strongly support a potable water use metric, and as 1

I mentioned, we’ve definitely seen significant 2

improvements in the industry in lowering water 3

consumption. But I think we still do see a pretty 4

big range among machines and water use. I think 5

there’s still room for improvement. 6

MR. BROOKMAN: Do we have confirmation 7

over here, John? 8

MR. BROADBENT: From a technology 9

standpoint, if you lower the potable water use, you 10

will improve energy efficiency because that extra 11

water is 32 degree water that you’re throwing down 12

the drain, so you definitely get some benefit. 13

There’s no limitation in the industry, and if you 14

try to go too low, you start having difficulties in 15

terms of the ice will become cloudy and soft, which 16

is undesirable. And also what happens is the 17

impurities in the water tend to precipitate out and 18

coat all the different parts in your ice machine and 19

requires either more frequent cleaning, or you’re 20

going to have a breakdown of some sort in your 21

machine. So it’s a reliability iss ue for the end 22

user if the water use is too low. 23

MR. BROOKMAN: Daryl? 24

MR. ERBS : Just to add to that comment. I 25Executive Court Reporters (301) 565-0064 94 would agree that just efficiency would tend to drive 1

our use down for batch machines. It’s

-- so this 2

really is all about batch ice machines, because 3

continuous type is pretty much we all can figure out 4

how much water they use, based on how much ice they 5

produce. 6

I think there’s actually kind of a minimum 7

-- there’s an optimum point where if you drive to 8

drive potable water use too low, not only do you 9

create the reliability issues that John spoke to, 10

but as you start to try and use less and less water, 11

and increase the amount of scale that is deposited 12

on the evaporator of the ice machine, it actually 13

hurts efficiency, not only because of the heat 14

transfer resistance, but in a lot of evaporator 15

constructions, the scale will slow down the 16

harvesting part of the cycle, so you’ll get more 17

melting. You’ll have higher temperatures. 18

And as manufacturers, again, we have to 19

deal with a wide range of water quality issues 20

throughout the country, and so if we put out a 21

machine that has to be basically set to handle maybe 22

all but the very worst quality water, then that 23

places that limit on how far we can go. Now, if we 24

had some way to get adaptive controls in, that might 25Executive Court Reporters (301) 565-0064 95 open up some new possibilities, but with the current 1

situation, I think we’re getting very close to the 2

optimum point. 3

And again, I would caution you, just in 4

terms of in your analysis, making sure you 5

understand those effects and how to treat them 6

properly, because it’s not just the thermal part of 7

the equation, there’s the TDS of the water and the 8

minerals coming out of solution that drive a lot of 9

our decisions on design. 10

MR. BROOKMAN: Okay. Harvey Sachs. 11

MR. SACHS : T his has been very helpful to 12

me and I appreciate it. I would echo, the potential 13

of adaptive controls, but also the necessity for 14

some potential necessity for additional elements in 15

the rating methods in terms of specification of 16

water hardness, or total dissolved solids or 17

carbonate ion or whatever it is, that if -- 18

otherwise, all manufacturers will be driven to test 19

with distilled water, which would not be a good way 20

to run them on the long term in Ohio with hard 21

water. So I think that’s what you’re dri ving at, 22

Daryl and John. 23

MR. BROOKMAN: Okay. Thank you. I’m 24

going to ask you to scan through these four 25Executive Court Reporters (301) 565-0064 96 questions in this comment box and make sure you’ve 1

referenced them, answered them -- yes. Daryl. 2

MR. ERBS: One other comment. Item 3-13. 3

Tota l water use. Then I assume you’re talking about 4

combining potable and the condenser water use for 5

water cooled machines? Would that be total? 6

MR. WESTPHALEN: Yeah, this gets ahead 7

into the test procedure discussion a little. 8

MR. ERBS: And there I would say I would 9

be

-- I would not be in favor of that just because 10

the amount of water used by the condenser compared 11

to that used by the potable -- I mean, the ratios 12

are ten to one, well, maybe not quite, but -- so it 13

would tend to dwarf any changes you made on the 14

potable water side if you just lumped it all 15

together. So I would be in favor of keeping those 16

separate. 17

MR. BROOKMAN: Okay. Thank you. Calling 18

your attention to this comment box, take any 19

additional comments now, before we go to break. 20

Okay. So let’s take a break. It’s by my watch, 21

seven after, let’s take a 15 minute break. Let’s 22

resume at 11:20. Whi le you’re here in the Forrestal 23

Building, you must wear this visitor’s badge in a 24

place that’s visible. 25Executive Court Reporters (301) 565-0064 97 (Whereupon, the hearing was off the record for 1

an 18

- minute recess.) 2

MR. BROOKMAN: Let’s please take your 3

seats. We’re going to resume. We are ret urning to 4

Detlef and taking up screening analysis. 5

SCREENING ANALYSIS 6

MR. WESTPHALEN: The screen is stuck here, 7

if I could get some IT help. Thank you. Moving on 8

to screening analysis. We talked about some 9

technologies. In the screening analysis, we try to 10

screen out the technologies that are not appropriate 11

to consider and the engineering and downstream 12

analyses. 13

The approach for screening is to evaluate 14

each technology based on these four screening 15

criteria. The first one is technological 16

feasib ility. What that translates into is the 17

technology either is used in current products that 18

are for sale, or it has been demonstrated in a 19

prototype. 20

The other three criteria are fairly self21

explanatory: practicability to manufacturer to 22

install and service; impacts on equipment utility or 23

availability to consumers; and impact on health and 24

safety. 25Executive Court Reporters (301) 565-0064 98 So item 4

- 1 . DOE welcomes comments on 1

these four screening criteria. 2

MR. BROOKMAN: I think that most of you 3

are familiar with these. Comments? 4

MR. WESTPHALEN: Okay. We’ll move on. 5

Next

-- oops. 6

MR. BROOKMAN: Harvey Sachs. 7

MR. SACHS : Harvey Sachs, sounding like a 8

broken record. But technological feasibility would 9

be demonstrated if this -- if a particular 10

technology option is in use anywhere in the world in 11

a mass production environment. Not just in the US 12

as we have seen in one or two proceedings in the 13

past. 14

MR. WESTPHALEN: Okay. Point well taken. 15

MR. BROOKMAN: Okay. Any others? 16

ENGINEERING ANALYSIS 17

MR. WESTPHALEN: Moving on to the 18

engineering analysis. The point of the engineering 19

analysis is to develop the relationship between the 20

efficiency improvements and the additional cost that 21

would be incurred, additional equipment cost 22

associated with improving that efficiency, and 23

generally it is a cost efficiency curve, like shown 24

in the graph on the bottom left there. Usually low 25Executive Court Reporters (301) 565-0064 99 slope, small efficiency improvement levels, and as 1

this slope gets steeper it gets harder and harder to 2

squeeze more out of the apple, as you take more and 3

more out. 4

And the results of the engineering 5

analysis are then used in all the downstream 6

analyses to provide the basis for the economic 7

analyses. 8

There are different approaches used in 9

different rulemakings for the engineering analyses, 10

and some of these have been categorized, such as the 11

design option approach, the efficiency level 12

approach, and the reverse engineering approach. 13

For the design option approach, briefly, 14

DOE looks at how much does this design option cost, 15

and how much energy use will it reduce? The 16

efficiency level approach is based on set efficiency 17

levels and attempts to gather information, for 18

instance, from the industry, of the costs associated 19

with attaining those efficiency levels. The reverse 20

engineering approach, you have different pieces of 21

equipment. You know their efficiency level based on 22

rating tests, and you do reverse engineering to 23

develop a manufacturing cost model to determine what 24

the costs are for those different levels. 25Executive Court Reporters (301) 565-0064 100 For this rulemaking, DOE intends to use a 1

combination of these approaches, using multiple 2

available data sources, and -- which will then feed 3

into the cost efficiency relationships. 4

Item 5- 6. DOE requests feedback on the 5

use of a combined analysis approach, that uses 6

multiple information sources to determine the 7

relationship between manufacturer selling price and 8

energy consumption for automatic commercial ice9

makers. Any comments? 10

MR. BROOKMAN: No comments? Okay. 11

MR. WESTPHALEN: Getting back to the 12

energy use condenser water use trade- offs. You saw 13

the cost efficiency curve prototype that we showed 14

earlier, in a product where you could have 15

efficiency improvements and also water use 16

improvements. You could envision a three17

dimensional mapping of product cost versus 18

efficiency on both these axes. Obviously, that 19

could get quite complicated. We’re not aware that 20

this has ever been done in any other rulemaking. 21

But because there’s a trade off here, 22

there’s a potential place where, you know, it would 23

be the optimum for consumers based on life cycle 24

costs and national impacts. 25Executive Court Reporters (301) 565-0064 101 So DOE seeks comments from stakeholders 1

providing insights regarding such trade offs, and 2

I’ll just read item 5

- 4 here, as well. 3

DOE seeks comments on simplifying 4

assumptions that may be made to reduce potential 5

complexity of maximizing benefits associated with 6

both the water and energy use reductions. 7

MR. SACHS : Harvey Sachs, addressing DOE 8

applies and OGC. There have been some questions in 9

the past with conflicting interpretations on DOE’s 10

authority to combine a prescriptive with a 11

performance standard. And I’d certainly like to get 12

clarification of that in terms of the potential -- 13

one way to address both the water and the energy 14

issues. 15

MR. WESTPHALEN: It sounds like a legal 16

question? 17

MR. SACHS : Well, that’s why I suggested 18

OGC as well. And as a particular example of what 19

I’m thinking about, an energy performance standard 20

in terms of kilowatt hours per pound of -- or watt 21

hours per pound of ice made, or however we want to 22

do that, might effectively be coupled with an 23

adaptive water use standard that respects the fact 24

that water use must vary, depending on hardness of 25Executive Court Reporters (301) 565-0064 102 the water. 1

I don’t know if this makes sense, but I 2

think it would be helpful to the process to have DOE 3

starting to think about this if it turns out to be 4

something everybody wants or is willing to accept in 5

exchange for other things. Thank you. 6

MR. BROOKMAN: Thank you. Ari. 7

MR. ALTMAN: Yes, Ari Altman from OGC. I 8

think kind of -- we’re in an initial stage, I’d say, 9

in terms of how we’re going to regulate water use 10

beyond the condenser water use. So what you’re 11

referring to is really kind of a -- well, we have 12

the energy use already as kilowatt hours per pound 13

of ice or hundred pounds of ice. In terms of what 14

you’re referring to as an adaptive standard, I think 15

we’d have to consider whether or not we have the 16

authority to do that. It is different than the way 17

Congress laid it out. 18

So we’ll definitely take it under 19

advisement, but I don’t think I could commen t right 20

now. If we would, you know, tend to extend our 21

authority to that. 22

MR. SACHS : As the reference point -- 23

Harvey Sachs -- just a reference point for this Ari, 24

I appreciate your caution. But the residential 25Executive Court Reporters (301) 565-0064 103 boiler standard now has a performance requirement in 1

terms of AFUE and has an additional prescriptive 2

requirement for a particular class of controls that 3

increase the end use efficiency, but could not be 4

addressed by the standard. This was first 5

negotiated, and then eventually accepted by DOE. 6

So the question is whether the Department 7

would use that precedent, or others like it, to 8

consider this range of options. And we can go on, 9

but I wanted to make sure that we flag that as a 10

question. 11

MR. ALTMAN: Sure, and we can definitely 12

take a look at the boiler standard as an example. 13

Just to clarify, though, our authority for 14

this rulemaking is separate from the boiler 15

rulemaking in that the authority comes under a 16

separate section of the statute. So I’m not 17

personally familiar with that negotiation that went 18

on with the boiler standard. I think we would have 19

to take a look at how the language was interpreted, 20

and t hat section of the statute, versus what the 21

ACIM language is as provided by Congress. 22

MR. BROOKMAN: Yes, Daryl. 23

MR. ERBS: Well, I guess my comments would 24

be other than -- you know, I think you understand 25Executive Court Reporters (301) 565-0064 104 the obvious, which, there’s an inverse relatio nship 1

on a water cooled condenser between flow rate and 2

its energy efficiency, so that would lead one to 3

say, does DOE have the ability, then, to even 4

considering relaxing the current limitation on 5

condenser water flow rate if it showed enough 6

potential benefit from an energy use standpoint? I 7

don’t know how you weight the two in terms of this 8

combined regulation. What’s more important, energy 9

or water? Probably depends on where you live. 10

But I would say we’d be open to looking at 11

that, but then there will still be some limits from 12

a practical standpoint, in terms of water flow rate, 13

whether it be what the heat exchanger is capable of 14

from a reliable lifetime operation standpoint and 15

other things. 16

Then on the simplifying assumptions, I 17

just wanted to, I guess, reiterate some of my 18

earlier comments. I don’t think there are any 19

because I think there’s a lot of complexities and 20

compounding effects that go on between how you 21

manage water use and how the machine operates. So I 22

know you’re looking for a nice, simple model. I 23

can’t offer you much hope of one. 24

MR. BROOKMAN: However, if others have 25Executive Court Reporters (301) 565-0064 105 that ability to offer any, that would be great. 1

MR. LLENZA: Yeah, and this is Charles 2

Llenza, Department of Energy. I would encourage 3

strongly that the stakeholders think about this a 4

little bit over Christmas and submit written 5

statements in regards to the trade offs. In 6

addition to what they believe should be the scope of 7

the Department’s concerns with the water issues 8

here. I think that would assist the Department in 9

framing this particular rulemaking, not only to the 10

needs of the policy that the Department’s creating, 11

but also to the need of the stakeholders here 12

present and on the webinar. 13

MR. BROOKMAN: Karim. 14

MR. AMRANE: Karim Amrane. I guess this 15

is a question for legal counsel here. But could DOE 16

relax the water consumption usage if it’s already in 17

the standard? 18

MR. ALTMAN: Ari Altman from OGC. It’s 19

certainly not something that we’ve considered, I 20

believe, yet at this point in the rulemaking, but it 21

really breaks under two separate categories. First, 22

the standards prescribed by Congress for cube type 23

ice

- makers. The Secretary does have authority under 24

the statute to revisit those standards, and that’s 25Executive Court Reporters (301) 565-0064 106 part of this rulemaking. Specifically, that looks 1

at

-- simply gives us authority to amend the 2

standard. So it does not specifically require DOE 3

to increase the standard, although in looking at 4

technological feasibility and economic 5

justification, the assumption is that the standard 6

would be increasing if it can be justified. 7

For the other types of ice-makers, which 8

this is a new rulemaking, under new authority, 9

certainly we’re starting from scratch, so the answer 10

to that is we can set it wherever it seems 11

appropriate. 12

MR. LLENZA: Thi s is Charlie Llenza, and I 13

don’t want to speak for the Department, per se 14

specifically, but we do have anti-backsliding 15

regulation for energy use, so if -- the way that 16

works, if there is a level that has been set by 17

Congress in the regulation, at least for energy use, 18

we’re not allowed to backslide. Now, I don’t know 19

if that applies to the water usage, because I’m not 20

so familiar with water usage throughout the regs, 21

and how that impacts what the Department has 22

authority or is allowed to do or not do. So I think 23

that this is one of the areas where we will have to 24

explore further in terms of to see what the 25Executive Court Reporters (301) 565-0064 107 regulations allow us to do in terms of the water 1

usage. 2

MR. ALTMAN: This is Ari again from OGC. 3

I think, you know, ice-makers are a bit unique in 4

t hat we’re regulating both water and energy at the 5

same time. There are very few appliances in which 6

we do that. So this issue of anti-backsliding, 7

which usually relates directly to energy use, I 8

don’t know off hand whether or not it would be 9

implicated if we say relaxed a water standard while 10

increasing the energy standard, for an overall 11

benefit in terms of energy consumption. We’ll have 12

to look at that, but it’s an interesting question. 13

MR. BROOKMAN: Good data. You all need 14

good data. 15

MR. WESTPHALEN: Okay. Moving on. 16

Industry data collection. As you’re aware in many 17

rulemakings, DOE asks trade organizations such as 18

AHRI, to collect data from the industry and 19

aggregate it to inform the rulemaking. And in some 20

cases, by the time of the framework, we have a 21

template showing exactly what we want. We don’t at 22

this point. 23

Instead, we’re asking for feedback on what 24

that template might look like. We will be working 25Executive Court Reporters (301) 565-0064 108 on developing that kind of a template, and certainly 1

we want to have some back and forth on how that 2

would be structured. And this would also encompass 3

some of the issues addressed earlier by Michelle, 4

such as shipments, shipment data, things like that. 5

So item 5- 2, DOE requests comments on the 6

best way to collect such information from the 7

industry. DOE anticipates that such data might be 8

collected and aggregated by AHRI for submittal to 9

DOE. 10

Item 5- 3, DOE requests input on 11

appropriate categories and questions to be included 12

in such requests for data. 13

And item 5- 4 A , DOE seeks comments and 14

recommendations regarding the potential data 15

collection efforts that might be made by industry 16

participants to support this rulemaking and the 17

proper structure of data request forms that could be 18

used to assist such efforts. 19

MR. BROOKMAN: Karim. 20

MR. AMRANE: Karim Amrane, AHRI. We have, 21

in the past, done that, collected and aggregated 22

data, cost efficiency data for DOE. But it was 23

challenged by many as being done through a black 24

box, nobody knew what was in there. So we moved 25Executive Court Reporters (301) 565-0064 109 away from that, and again, I mean I -- we don’t want 1

to go through this kind of analysis if at the end of 2

the day it’s not going to be used by DOE. It’s a 3

lot of effort, but I’m not even sure the 4

manufacturers would be willing to share this 5

information. But assumi ng that they will, it’s a 6

lot of effort which at the end, at least in some 7

cases, has been challenged. 8

So I don’t know, I mean, DOE seems to have 9

moved away from just getting data from AHRI, cost 10

efficiency data from AHRI on other rulemakings, so 11

again , I mean, unless there is a commitment or an 12

agreement that yes, the data will be used, AHRI is 13

not going to try to get this information. 14

MR. BROOKMAN: Harvey Sachs. 15

MR. SACHS : Harvey Sachs, ACEEE. Somehow 16

I felt Karim was speaking to me when he pointed at 17

me, and I think my instinct is to first of all say 18

that we count on AHRI as a very important source of 19

data in the market segmentation, market classes. I 20

think that’s a very valuable function. For this 21

product class, as opposed to others, I certainly 22

will take this to my colleagues as a very specific 23

issue and I will say, guys, can you trust AHRI? And 24

I think the answer is likely to be that we would 25Executive Court Reporters (301) 565-0064 110 hope AHRI is doing some of its own analysis, because 1

we like it when we have independent estimates from 2

AHRI and DOE, and I think you’ll certainly give us 3

credit for beating up DOE on its analyses at least 4

as much as AHRI. Is that fair enough? 5

MR. BROOKMAN: Okay. Thank you. And let 6

me respond to a question that has come in via the 7

web. Several people have asked if the webinar 8

participants can be electronically sent the same 9

materials as in person attendees, and two approaches 10

to that. One would be that all of the materials 11

that are being presented in the webinar are going to 12

be posted on the web site next week. That’s one. 13

But if you need to have it, anybody who’s listening 14

in via the web, if you need to have it quicker, than 15

you can request it via e- mail, and I’m about to give 16

you that e-mail address. The technical lead, the 17

program lead, Charles Llenza, if you send Charles 18

Llenza an e- mail, then today or very soon he’ll send 19

you these materials back via e-mail, and that 20

address is as follows: it’s 21

Charles.llenza@ee.doe.gov . I’m going to spell th at, 22

C

- H

- A

- R -L- E

- S, dot, Llenza, L-L

- E

- N

- Z

- A at EE dot 23

DOE dot GOV. 24

So, keep going. 25Executive Court Reporters (301) 565-0064 111 MR. WESTPHALEN: Good. 1

MR. BROOKMAN: Oh, question here. Yes, 2

please, Jeff. 3

MR. BIEL: Jeff Biel. To your point, 4

Karim, AHRI is a tremendous resource for us and so 5

we definitely encourage the use of AHRI for shipment 6

data. One point also, we were talking about tube 7

ice and flake ice, you know, there are, when we 8

start talking about those ice forms, they are not 9

part of industry associations, some manufacturers of 10

t hose products. So there would probably need to be 11

some additional data gathering done for some of 12

those categories. 13

MR. BROOKMAN: Okay. 14

MR. WESTPHALEN: Moving on to some eye 15

charts here, and we’re putting some of this 16

information on the table here . We don’t necessarily 17

expect fully considered responses at the moment, but 18

certainly if we could get comments in the written 19

comments that might help us to adjust our plans for 20

some of this analysis. 21

This first chart is a list of cube 22

machines that DOE is planning to purchase for tear 23

down and testing with an attempt to cover a broad 24

spectrum of product types. I haven’t listed 25Executive Court Reporters (301) 565-0064 112 manufacturers, but also covering a broad spectrum of 1

manufacturers. 2

And we also have a list of continuous type 3

flake and nugget machines here, and, you know, that 4

manufacturer that makes that number 17 with a zero 5

width, that’s just amazing

-- this should be 21 inch 6

width here. I apologize for that. 7

Additional comment H. DOE requests 8

comments on its plans for tear downs and testing, 9

and in particular, what types, capacities or sizes 10

of equipment are not sufficiently well represented 11

and as I say, certainly we welcome comments in the 12

written comments if you haven’t had time to really 13

digest this at the moment. 14

MR. BROOKMAN: Do you know now how many 15

you’re going to try and purchase and tear down? 16

MR. WESTPHALEN: All of the -- basically 17

what you see here. This is in the plans, it’s 18

already in the works. 19

MR. BROOKMAN: Okay. Yes, Joanna. 20

MS. MAUER: Joanna Mauer. Just a question 21

on the plans for tear downs for the cube type 22

machines. Are the products -- the number of 23

products of each equipment type, are those intended 24

to reflect shipments in some way? 25Executive Court Reporters (301) 565-0064 113 MR. WESTPHALEN: Well, we don’t have very 1

good shipmen t data, or we didn’t when we developed 2

this initial list, so certainly any comments that 3

reflect representation by shipments would be 4

welcome. 5

MR. BROOKMAN: Karim. 6

MR. AMRANE: Karim Amrane, AHRI. That’s 7

my next question. I mean, when are you planning to 8

do the tear down? I mean is it going to come the 9

next month, or is it going to come -- 10

MR. WESTPHALEN: Yeah, it’s coming an , 11

a ccelerated, rulemaking schedule -- certainly we’re 12

prepared to add to this list in order to get a 13

better representation. 14

MR. BROOKMAN: A moment ago I asked you 15

what you’re going to tear down, and it appears that 16

you were referring to slide 40 or to slide 39? 17

MR. WESTPHALEN: Both. All of these -- 18

MR. BROOKMAN: That’s what I wasn’t clear 19

about. 20

MR. AMRANE: Becau se I’m asking the 21

question because we don’t have yet this shipment 22

weighted data which hopefully we will have, will 23

give us a better idea of what is the right capacity 24

you need to. 25Executive Court Reporters (301) 565-0064 114 MR. LLENZA: Charles Llenza, Department of 1

Energy. I think we’re talking about purchasing this 2

next month, as soon as possible, and the equipment 3

should be torn down in early spring, if not 4

completely done by then. So this is part of the 5

problem of an accelerated test procedure in terms of 6

the timeframe. We have to make decisions at a 7

faster rate because we have to actually look at the 8

equipment, if we have to look at the equipment. 9

This particular rulemaking has never seen 10

ice making machines so this is kind of critical at 11

this point. I hate to put pressure on AHRI, but 12

t hey’re going to have to do some homework over 13

Christmas if we want to be able to get this right. 14

But this is at least the initial stage, so 15

I think we could get a good perspective. If this is 16

good enough for right now and then as we get the 17

firmer data, that takes a little more time, we could 18

add to this list additional equipment to tear down 19

to look at. So what we’re hoping is to capture, 20

let’s say 90 percent of the equipment here, and 21

maybe one or two other pieces of equipment that we 22

specifically d idn’t address, we can then purchase 23

and tear down later. Because obviously, we cannot 24

do everything at once. 25Executive Court Reporters (301) 565-0064 115 So this is going into a queue and maybe if 1

we can -- if you have the specific queue, maybe we 2

can provide that queue in terms of -- so that we 3

know when the decision points have to be made. But 4

I think this is our minimum list, right, is that the 5

way we’re addressing this? 6

MR. WESTPHALEN: Well, this has been 7

submitted already for going through the process, 8

because of our contractual arrangem ents, I don’t 9

want to get into the details, but this is already in 10

the works. We don’t know when these products will 11

start to arrive. You know, there are lead time 12

implications as well, and test lab availability 13

questions. 14

MR. AMRANE: Karim Amrane, AHRI. I see 15

the list. I see nothing much about 2,500, is that 16

on purpose. There is one unit, I believe, 2800? 17

MR. WESTPHALEN: There’s a 2300. 18

MR. AMRANE: And now you’re talking about 19

expanding the scope to 4,000 , so you’re not testing 20

anything at the higher end? 21

MR. WESTPHALEN: The only machines that 22

are, you know, there are very few machines, really, 23

that are between 2,500 and 4,000, and most of those 24

are the tube machines. We don’t have tube machines 25Executive Court Reporters (301) 565-0064 116 represented, that’s something that we are 1

co nsidering as well. 2

MR. AMRANE: If that’s the case, then why 3

did you -- why is DOE thinking of expanding the 4

scope to 4,000 if there are really few machines 5

there. I mean what are going to be the energy 6

savings there then? I mean -- again, it’s a 7

quest ion that as a matter of fact, there has been no 8

justification from DOE’s part as to why DOE is 9

thinking -- why DOE wants to expand the scope to 10

4,000 , except the test procedure that wasn’t 11

mandatory goes to 4,000, which is fine. But I guess 12

now you’re tel ling that there are few machines at 13

that capacity, so why is DOE spending the resources, 14

time, to look at that. 15

MR. LLENZA: And this is Charles Llenza, 16

Department of Energy. I think part of what we’re 17

doing is -- you know, this is our proposal and we 18

w ould appreciate the comments. The other thing is I 19

could see where, if we didn’t at least make an 20

effort to go to the 4,000 level, that many of the 21

machines that are at the borderline of the 2,500 22

level could end up migrating to the 4,000 level and 23

they w ould be beyond their scope of coverage. So it 24

could be, I would say, a preemptive strike from the 25Executive Court Reporters (301) 565-0064 117 Department to cover up to 4,000 to make sure that we 1

don’t have any migration of technology going to the 2

4,000 level, where the industry would be comfortable 3

making those machines, but then they would escape 4

our standard setting. 5

MR. AMRANE: This is Karim again. I don’t 6

want it to appear that I am opposed to DOE to 4,000, 7

it’s just that it seems to me there are very few 8

justifications for doing that. 9

MR. BROOKMAN: So one question that occurs 10

to me as I look at these 19 different types of 11

equipment that now have been ordered, and you’ll see 12

how they roll in. Is that what happens? 13

MR. WESTPHALEN: Yeah. We’re keeping tabs 14

on when they come in. 15

MR. BROOKMAN: So one question is, are 16

there significant gaps here? Is there significant 17

overlap? Is there an efficiency that could be 18

applied to this list that’s not implicit here? 19

MR. BIEL: Actually, I have one -- Jeff 20

Biel

-- one question for clarification. Category 21

number 19 for flake or nugget, SCU-A, I assume 22

that’s a self

- contained unit, so it’s an ice -maker 23

and storage. Would that also include nugget 24

machines that are ice-maker, storage, and dispensing 25Executive Court Reporters (301) 565-0064 118 as well? 1

MR. WESTPHALEN: Well, that’s a p articular 2

product, that’s just an ice

- maker and storage self3

contained unit. 4

MR. BIEL: But is the scope of the program 5

to cover self contained units that also have 6

dispensing capabilities? And how would they be 7

classified? 8

MR. BROOKMAN: And we already talked about 9

storage, but go ahead, can you answer his question? 10

MR. WESTPHALEN: Well, in terms of 11

coverage, my understanding is that there is 12

coverage, and so if your point is that we should 13

include in our tear downs a product that does 14

include disp ensing, then we’ll take that under 15

consideration. 16

MR. BROOKMAN: So your written comments on 17

all of this, of course. Joanna. 18

MS. MAUER: Joanna Mauer. Just another 19

question on the energy and water use values, are 20

those from the AHRI directory, or where do those 21

come from? 22

MR. WESTPHALEN: We took a number of 23

databases, consolidated them, looked at 24

manufacturers websites, weed out ones that don’t 25Executive Court Reporters (301) 565-0064 119 exist any more, and so basically we have developed a 1

database. 2

MS. MAUER: From multiple data sources? 3

MR. WESTPHALEN: Yes, that’s partially 4

AHRI. 5

MR. LLENZA: This is Charles Llenza, 6

Department of Energy too. I wanted to make one 7

point also, just to add a point to Karim’s question. 8

The Department, I mean, at least from project 9

manager’s point of vie w, I felt that extending to 10

4,000 would take very little effort on the part of 11

the Department to go the extra mile to increase, 12

because the test procedure work is already pretty 13

much done. So we are adjusting pretty much the 14

scope of work to the test procedure level, with very 15

little extra added cost to the actual rulemaking. 16

So, strategically speaking, there’s some 17

reasons why not, if there’s no major objections to 18

cover everything up to 4,000 pounds. After that 19

breaking point has been expressed in this meeting, 20

the equipment changes and it becomes industrial as 21

opposed to commercial. I think that’s the feeling 22

of this group, therefore at that point, then, that 23

becomes an issue as should the Department really 24

spend the money, and is that beyond the intent and 25Executive Court Reporters (301) 565-0064 120 the scope that the legislation provided. 1

MR. BROOKMAN: So -- go ahead Harvey. 2

MR. SACHS : Harvey Sachs. I just want the 3

record to reflect that Karim’s objecting to the 4

Department’s effort to harmonize with his standard. 5

MR. AMRANE: And I’m not. This is Karim 6

with AHRI. As I said, we are not opposed at DOE 7

looking at 4,000, but again, it seems to me that 8

there are very few justification for doing it, 9

that’s all. 10

MR. BROOKMAN: So look at the list and 11

tell the Department if they can improve this list, 12

if there’s redundancy, if there’s gaps. Any 13

comments on these 19 products. Yes. Or 14

recommendations, yes. 15

MR. ERBS: I actually don’t have a 16

comment, but a question, just a clarifying question. 17

I heard the comment about doing homework over 18

Christmas, and I would prefer to comment on this 19

list in the written comments, which I believe we 20

have until January something. 21

MR. AMRANE: Eighteen. 22

MR. ERBS: Yes, so is January 18 soon 23

enough to be able to have a meaningful effect on 24

this list, or have you already gone out and 25Executive Court Reporters (301) 565-0064 121 purchased them? 1

MR. LLENZA: Well, the orders are in, so 2

Santa’s bringing the toys. I don’t know how fast

-- 3

the logistics of this is a lot more complicated than 4

it seems. The problem is getting this equipment 5

into the testing facilities and getting them tested. 6

So

-- and then putting in the orders and everything 7

else. I would just think that if we stick to the 8

comment period we’ll be fine. We’ll make the 9

adjustments necessary at our end. We’re pr epared in 10

terms of the expense of additional equipment if we 11

need to purchase additional equipment. 12

I think there would be enough time to 13

execute a certain level of priority on the equipment 14

also with -- so we’re not so concerned about this. 15

We just -- I guess the initial concern is is this a 16

good enough first shot at the mix of equipment so 17

that we at least have one piece of equipment for 18

every kind of machine that’s out there? 19

And then, the concern is, for example, we 20

don’t have anything that’s at t he 4,000 level, so, 21

you know, whatever input you provide us, we can feed 22

that into our testing plan and go out and purchase 23

additional equipment, if the industry feels that we 24

need to purchase certain other equipment also, then 25Executive Court Reporters (301) 565-0064 122 that could be considered also to be put into our 1

plan also. 2

MR. BROOKMAN: So any additional comments 3

now? 4

MR. ERBS: So I would just say what I 5

would likely do is recommend a few additional models 6

so if you’ve got some ability to add a few more in, 7

then that would probably satisfy my concerns. 8

MR. LLENZA: Yeah, we have flexibility and 9

we knew this was going to happen so we built 10

flexibility in our testing requests to the office 11

here so that we could add things to the plan as we 12

see fit down the line here. 13

MR. BROOKMAN: We have a question from 14

somebody participating on the webinar. Stephen 15

Schaeffer asks what is the purpose for tear down and 16

testing of units? Who will be testing the units? 17

Which of you would like to -- Detlef. 18

MR. WESTPHALEN: The purpose of the tear 19

do wn is reverse engineering that feeds directly into 20

the engineering analysis, and that includes both 21

technically, how do these things work? Is it a PSC 22

motor? What efficiency? How many watts does it 23

draw? What is the control sequence? 24

But it also has to do with the 25Executive Court Reporters (301) 565-0064 1 23 manufacturing, what manufacturing processes are 1

used, and feeds into the development of 2

manufacturing cost model that is used in the 3

engineering analysis to help with coming up with 4

cost efficiency -- 5

MR. BROOKMAN: Who will be doing the 6

testing? 7

MR. WESTPHALEN: At this point we have 8

requested Intertech to do the testing. 9

MR. BROOKMAN: Okay. Thank you for that. 10

Any additional comments on this eye chart? Let’s 11

move on. 12

MR. WESTPHALEN: Equipment test data. DOE 13

realizes we don’t have the resources to test it all. 14

This is kind of a very general question. I’ll read 15

it and then make some comments. 16

DOE is also interested in receiving 17

equipment test data, test procedure use, rating 18

conditions, harvest rate, voltage, integrated 19

aver age product temperature, daily energy 20

consumption, et cetera. Test data representative of 21

the baseline model in each equipment class is 22

particularly important. 23

Granted, this is a very general request. 24

I think as we move forward we might get more 25Executive Court Reporters (301) 565-0064 124 specif ic and contact appropriate parties to find out 1

if we can obtain some data that answers specific 2

questions. But we’re willing to take comment on 3

this. 4

MR. BROOKMAN: Yes, Karim. 5

MR. AMRANE: Karim Amrane, AHRI. What do 6

you mean by integrated average temperature? It 7

probably was taken out of the ... refrigeration room. 8

There’s no such a thing as integrated average 9

temperature for ice-makers. 10

MR. WESTPHALEN: Well, that doesn’t make 11

sense then. Strike that. You know, I -- I like to 12

talk and instead of listing out all the data, I like 13

to say give me the raw data, you know. 14

MR. BROOKMAN: Okay. Thank you for that 15

clarification. Additional comments on equipment 16

test data? 17

MR. WESTPHALEN: The next few slides deal 18

with efficiency levels that are being considered. 19

The first slide addresses baseline efficiency 20

levels. These are the levels against which 21

improvements in efficiency will be compared for all 22

of the analyses. For the cubers, the natural 23

baseline is the current DOE standard for both the 24

co ndenser water and the energy use. For flake and 25Executive Court Reporters (301) 565-0064 125 nugget machines, two options are under 1

consideration, one is a standard for Canada. Option 2

two, two-part curves or three-part curves based on a 3

fit with existing data and this is similar to the 4

approach that Harvey mentioned earlier. 5

Potable water use for cubers and this 6

would also, presumably apply to tubers, similar 7

approach, such as the curve fits. 8

And DOE seeks feedback on the proposed 9

baselines. Granted, some of these options -- option 10

two has not been quantified for you, but listed as a 11

potential approach. 12

MR. BROOKMAN: Comments on the proposed 13

baselines? Any comments regarding the option one 14

versus the option two? 15

MR. AMRANE: Karim Amrane, AHRI. I mean 16

are you planning to ask industry for data on this? 17

I mean, because, you know, I’m not sure we have 18

published our director with flakers and nuggets yet. 19

No, we don’t have that yet, but maybe it’s something 20

we can collect for you and you can look at? I don’t 21

know on that? 22

MR. WESTPHALE N: Well, maybe we’ll be in 23

touch and maybe it makes sense to -- you know, as I 24

mentioned, we have put together a database. We have 25Executive Court Reporters (301) 565-0064 126 data for flakers and nugget machines, and it may be 1

worth trying to get some feedback on the specifics 2

of that database. 3

Moving on to incremental efficiency 4

levels. Here for the -- 5

MR. LLENZA: This is Charles Llenza, 6

Department of Energy. I just wanted to bring out a 7

point because this is an interesting question. We 8

have, for the purpose of the presentation, covered 9

th e majority of the questions that were provided at 10

the framework -- in the framework document, except 11

there’s a series of questions that were not covered 12

in the public meeting slides here today. But I 13

would suggest that if you pick up -- and we’re going 14

to publish a piece of information that tells you 15

which were covered at the meeting and which 16

questions were not covered at the meeting, because I 17

feel that it would be beneficial to all the 18

stakeholders to have that list for those questions 19

that were not covered today at this meeting, that 20

they can then specifically submit their replies 21

under separate correspondence by the comment period. 22

And in this particular case, there was a 23

question, item 3-8, that said, DOE requests feedback 24

on the proposed experiment classes for automatic 25Executive Court Reporters (301) 565-0064 127 commercial ice-makers covered in this rulemaking and 1

criterias for creating these classes. So yes, we’re 2

asking for feedback because we didn’t cover all the 3

questions here. 4

So -- and I think it was not a mistake, 5

but we were short- sighted in not putting the 6

additional questions in the presentation. But I 7

just want to make sure everybody understands there’s 8

some additional questions in the actual framework 9

document. 10

Yes, this list will be published on the 11

web as part of the material from the meeting. 12

MR. BROOKMAN: Thank you. That will be 13

helpful. 14

MR. WESTPHALEN: We’re on incremental 15

efficiency levels. First looking at levels for 16

cubers. And on this chart we’ve listed all the 17

existing product classes with the baseline as DOE 18

standard, and also listed the max available that 19

we’ve identified, based on our research for each of 20

those classes. 21

And you’ll note that the suggested 22

efficiency levels are consistent across the capacity 23

range for a product type. That’s so the individual 24

lines don’t then become discontinuous. For 25Executive Court Reporters (301) 565-0064 128 instance, if we looked at an efficiency level of 20 1

percent for the small, and 22 percent for the 2

medium, if the standard were set at that level, 3

obviously you’d have discontinuity in the standard, 4

and everybody would push just to get over the line. 5

Some of these are based on the CEE and E6

STAR which addresses one of the comments made 7

previously, to try and maintain some consistency. 8

So these are the cubers, the flake and nugget 9

machines. There was less information to go on. But 10

here I’m also showing the minimum available based on 11

NRCan standard, and the max available, and some 12

suggested efficiency levels for these products. 13

You see here for the remote condensing 14

unit with a rack, the 60 percent to 91 percent. 15

Obviously, that reflects the fact that you’re not 16

including the compressor and condenser, and it also 17

brings up the question again that although you would 18

-- some of the discussion suggested we don’t 19

separate those, you have to add in the compressor 20

and condenser somehow in order for this comparison 21

to make sense. And I think Sarah will talk about 22

some of this a little bit more in the test procedure 23

part of the discussion. 24

MR. BROOKMAN: Joanna. 25Executive Court Reporters (301) 565-0064 129 MS. MAUER: Joanna Mauer. Can you just 1

ex plain, Detlef, the minimum available columns, so 2

the first number, for example, 28 percent. What 3

does that refer to exactly? 4

MR. WESTPHALEN: Well, it’s like a maxtech 5

available, but it’s the mintech available. So that 6

the worst or the most energy using of that first row 7

is 20 percent below the NRCan standard. 8

MR. BROOKMAN: 20 percent below. 9

MS. MAUER: So a negative number would be 10

above? 11

MR. WESTPHALEN: Above. Exactly. 12

MS. MAUER: And then the efficiency levels 13

are relative to the NRCan standard. 14

MR. WESTPHALEN: NRCan standard, yes. 15

MS. MAUER: Okay. Thank you. 16

MR. BROOKMAN: Any other questions about 17

what’s been presented? Are you expecting them to 18

comment on this real time? 19

MR. WESTPHALEN: If they can, but 20

certainly written comments after more careful 21

consideration are welcome as well. 22

MR. BROOKMAN: This is fairly complicated 23

here. 24

MR. AMRANE: Karim Amrane. Just a general 25Executive Court Reporters (301) 565-0064 130 statement about the NRCan standards. The way by 1

which an NRCan establish a standard is very 2

different than the DOE process. And I have to say 3

not all the standards are -- they don’t go through 4

the same rigor and economic analysis that DOE does. 5

So again, consider, this is the baseline. I would 6

like to caution you about that. I mean it’s not 7

necessarily done the same way. 8

MR. WESTPHALEN: Okay. 9

MR. BROOKMAN: And nor would you make a 10

global statement about the outcome at this point? 11

MR. AMRANE: No. 12

MR. BROOKMAN: Okay. Thank you. I just 13

thought I’d try. 14

MR. WESTPHALEN: And request for comment. 15

Obviously, DOE seeks input from stakeholders about 16

the proposed efficiency levels. DOE also seeks 17

input from stakeholders on appropriate maximum 18

technologically feasible efficiency levels. And 19

there again, I don ’t expect all that information to 20

come right here and now. 21

MR. LLENZA: This is Charles Llenza of the 22

Department. Your comments are always welcome until 23

the close of the comment period. After that, the 24

Department has a discretion in terms of doing what 25Executive Court Reporters (301) 565-0064 131 they need to do with the comments. And so don’t 1

feel compelled that you have to answer all the 2

questions here today. If you need more time to 3

think about it, we would appreciate it by the 18 th

, 4

as opposed to the drop dead date. 5

MR. BROOKMAN: Okay. Then proprietary 6

designs. 7

MR. WESTPHALEN: Okay. Proprietary 8

designs. DOE will evaluate all design options that 9

are commercially available or present in working 10

prototypes, including proprietary designs. However, 11

consideration of proprietary designs will be limited 12

if they represent a unique path to achieving a 13

particular efficiency level. Obviously, the 14

confidentiality of manufacturers will be maintained 15

if we find out something about a great new 16

technology that one of you gentlemen has developed 17

that cuts the energy use in half, then obviously, if 18

you own that, we can’t really be divulging it. Also 19

we wouldn’t be able to base the standard on that. 20

So the request for comment here is item 5- 21

8, are there proprietary designs that DOE should 22

consider in the analyses for any of the equipment 23

under consideration? If so, how should DOE acquire 24

the cost data necessary? Conversely, are there 25Executive Court Reporters (301) 565-0064 132 proprietary designs that DOE -- that should not be 1

considered? Which products use these designs? 2

MR. BROOKMAN: Karim. 3

MR. AMRANE: Karim Amrane, AHRI. We don’t 4

believe that proprietary designs should be 5

considered in this analysis, for the simple reason 6

that if it is proprietary, it’s not going to be 7

something that others are going to be able to use, 8

so how can you use proprietary design to establish a 9

standard, and ask others to meet a standard? So 10

again, I don’t think it’s something that DOE should 11

look at when establishing minimum federal standards. 12

MR. BROOKMAN: Other comments on -- 13

related to proprietary designs? John. 14

MR. BROADBENT: Yeah, I would agree -- 15

John Broadbent -- I would agree with Harvey. 16

MR. AMRANE: I’m not Harvey. 17

MR. BROADBENT: I’m sorry, you’re over 18

there. 19

MR. BROOKMAN: John, I do that at least 20

once a meeting, so that made me feel a lot better. 21

Go ahead. 22

MR. BROADBENT: So what is the distinction 23

between proprietary and unique? You said that the 24

proprietary designs would only be considered if 25Executive Court Reporters (301) 565-0064 133 they’re not a unique path. And I’m uncertain what 1

the difference between the two. 2

MR. WESTPHALEN: Well, I think if a design 3

is patented and other manufacturers can’t use it

-- 4

MR. BROADBENT: That’s proprietary or 5

unique? 6

MR. WESTPHALEN: That could be both. A 7

design that is unique is something new and novel -- 8

and in some of these cases, it might be a component 9

vendor that has a proprietary design that that 10

component vendor has that design, but all the 11

manufacturers can use it, there is still questions 12

about the suitability of using that kind of a design 13

because of the obvious financial implications. 14

MR. LLENZA: This is Charles Llenza, 15

Department of Energy. I think we’re not necessarily 16

interested in the proprietary design because that 17

would be difficult to set a standard to that level. 18

I think what we’re more interested in is in the 19

design options. If the proprietary design has 20

certain design options that we did not consider, 21

where the design options themselves are not 22

proprietary, then the Department may look at those 23

design options and add them to the list of 24

components that you could use in creating TSL levels 25Executive Court Reporters (301) 565-0064 134 at some point for different classes of equipment. 1

So I’m not sure -- not that I’m not sure

- 2

- I don’t think it’s from the design of the 3

equipment itself in terms of how this particular 4

equipment is designed this way, whatever, but it’s 5

actually in the design options. And I guess the 6

interest from the Department’s point of view would 7

be if we missed something that’s out there, that’s 8

put together in a different way, then it becomes 9

proprietary, but then we can use the component parts 10

of it to improve on the technology side of the 11

house. That’s the only angle I would see. 12

MR. BROOKMAN: Yes, Daryl. 13

MR. ERBS: So I guess my comment would be, 14

I think what we could do is help answer questions -- 15

if you’re unsure w hether a particular design feature 16

is proprietary, in other words, is there IP around 17

it, we, as manufacturers, tend to keep track of who 18

has patents on what, and maybe that would be helpful 19

to you to say, this particular feature that you see 20

in one of the units you purchased and you tear down 21

is something that’s only available to one 22

manufacturer, and maybe that would lead to some 23

broader discussion around, well, are there alternate 24

technologies or approaches that would get you the 25Executive Court Reporters (301) 565-0064 135 same end result or same net impact. In some cases 1

the answer is yes, in other cases, it may be no, so 2

all I can offer is that we would work with you as 3

you go through the analysis to help identify those. 4

MR. BROOKMAN: Sarah. 5

MS. WIDDER : Daryl kind of covered it. I 6

just wa nted to flip the discussion a little bit, and 7

talk about -- I think that the Department does 8

sometimes consider or think about proprietary 9

designs if, as Daryl said, there’s alternate paths 10

to reach the same net result. Because often we set 11

these efficien cy levels and don’t specify a 12

particular design path to reach those levels. So 13

manufacturers can use proprietary designs to reach 14

them. 15

I think that second bullet that we’re 16

discussing right now is just saying the Department 17

wants to insure that there’s not an efficiency level 18

that’s set where the only way to reach that level is 19

a specific proprietary design. There could be three 20

separate proprietary designs that reach that level, 21

as long as everyone can get there. 22

MR. BROOKMAN: Okay. That’s good. Final 23

comments on this? 24

MR. WESTPHALEN: Okay. I think that 25Executive Court Reporters (301) 565-0064 136 covers engineering analysis and now Sarah Widder 1

will move on to test procedures. 2

TEST PROCEDURES: BACKGROUND AND POTENTIAL CHANGES 3

MS. WIDDER : Thanks, Detlef. Good 4

afternoon everyone. So we’ve brought up a couple 5

issues relative to the test procedures so far, and 6

I’m just going to try and consolidate them all here. 7

First, the current DOE test procedure, as 8

many of you know, is AHRI 810-2003 that was 9

incorporated in the 2006 en masse test procedure 10

rulemaking. That test procedure also references the 11

ASHRAE Standard 29, 1988 version, which was 12

reaffirmed in 2005, as the method of test. 13

And additionally, in that rulemaking DOE 14

adopted a revised method for calculating the energy 15

consumption, and they did that because they believed 16

that there was some room for misinterpretation of 17

how to normalize the energy consumption to 100 18

pounds of ice, and there was some belief that some 19

of the ice could be discarded in a different test 20

and you would reach a higher than representative 21

energy consumption value. And so that revised 22

calculation is something we’re also going to be 23

examining in revising the test procedure, whether 24

that’s still necessary. 25Executive Court Reporters (301) 565-0064 137 And that will probably be discussion for 1

the test procedure NOPR public meeting, but I just 2

wanted to bring it up now. 3

As was mentioned already, AHRI and ASHRAE 4

have updated their test procedures, AHRI to 810- 5

2007 , ASHRAE has subsequently updated to Standard 6

29

- 2009 , and both those te st procedures reflect the 7

same changes and are in agreement. 8

And then this last bullet, I wanted to 9

present that we’re not considering treating standby 10

and off mode in the DOE test procedures at this 11

time. There’s been some discussion about how that 12

c ould be incorporated, but right now that’s not 13

being proposed. 14

Just a little bit more on updating to the 15

current industry test procedures. Our authority 16

comes from EPCA which states that if AHRI standard 17

810

- 2003 is amended, the Secretary shall amend the 18

DOE test procedure to be consistent unless to do so 19

would not meet the EPCA requirements of the test 20

procedure. DOE believes that AHRI - that updated 21

AHRI test procedure -- meets those requirements and 22

is considering adopting it. 23

The specific changes to AHRI 810- 2007 24

expand the test procedure to apply to cube type as 25Executive Court Reporters (301) 565-0064 138 well as continuous type ice-makers up to a capacity 1

of 4 , 000 pounds per day, which expands from the 2

previous test procedure which ranged from 50 to 3

2 , 500 pounds per day, as has already been said. The 4

ASHRAE standard 29- 2009 reflects the same changes. 5

DOE is requesting comment on updating to 6

the revised versions of the industry test 7

procedures. 8

MR. BROOKMAN: Karim. 9

MR. AMRANE: Sure. Karim from AHRI. We 10

support that. 11

MS. WIDDER : Thank you, Karim. 12

MR. BROOKMAN: Good thing. We have it on 13

the record. Joanna. 14

MS. MAUER: Joanna Mauer. I was just 15

wondering if you could describe a little bit about 16

standby and off mode, what that would mean for ice17

makers. In other words, kind of, what is an ice18

maker doing when it would be in standby or in off 19

mode as you see it? 20

MS. WIDDER : Sure. What we’ve looked at

- 21

- I will let Daryl comment after what I’ve -- my 22

interpretation. What we’ve looked at in terms of 23

standby and off mode for ice-makers, they are 24

typically plugged in all the time, and so there’s 25Executive Court Reporters (301) 565-0064 139 not really an off period, as there is for some more 1

seasonal equipment, but there is sort of a standby 2

mode where the ice-maker is not actively producing 3

ice, and is just storing the ice for dispensing or - 4

- and then there’s a bin level or some sort of 5

mechanism that measures when more ice needs to be 6

made. And while it’s not making ice, we’ve termed 7

that sort of -- we don’t want to use standby, 8

because it’s not

-- that’s a very legi slative word, 9

so more off cycle or non-ice-making energy 10

consumption. 11

And we’ve thought about that being 12

quantified in the storage bin effectiveness test, if 13

that were to be considered. And we’ll discuss a 14

little bit more how we’re going to use that i n the 15

energy use analysis later in the presentation. But 16

as far as the test procedure, what we identified as 17

a possible means to address it would be the storage 18

bin effectiveness. 19

MR. BROOKMAN: Daryl, you want to add 20

anything? 21

MR. ERBS: Yeah. Just in terms of what 22

standby mode would actually represent, I mean I just 23

did some very simple back of the envelope 24

calculations. I mean, the worst case is an ice 25Executive Court Reporters (301) 565-0064 140 machine that’s got an electronic control because 1

then there is a little bit of loss in the 2

trans former, whatever the power supply is for it. 3

Basically, when an ice machine isn't 4

making ice, everything’s turned off, so you would 5

only have that loss in the power supply. There are 6

some ice machines that are fairly mechanical, 7

they’re zero. So I wo uld not even put -- but if you 8

look at one where you would have electronic control, 9

I mean it’s down below half of a percent, if you 10

look at how much of the time an ice machine is 11

typically on, how much it’s off, and then what does 12

that off time energy represent relative to the 13

energy it uses when it’s on, to me that’s down at a 14

level that again, I don’t feel that it would justify 15

the additional test procedures to try to encourage 16

more efficient transformers so when it’s off it’s 17

using a little bit less electricity. 18

MS. MAUER: Thanks, Daryl. Maybe just a 19

follow up. Are the storage bins typically 20

refrigerated or -- 21

MR. ERBS: No, they’re not. Storage bins, 22

that’s a whole different topic. Storage bins

-- and 23

they range radically in terms of their efficiency 24

based on their size. It’s just simple physics, the 25Executive Court Reporters (301) 565-0064 141 bigger the bin, the more efficient it is because 1

you’ve got more volume to surface area. And so 2

there’s a range. And there are, you know, there

-- 3

it’s not insignificant the amount of ice that me lts, 4

but I mean that’s the way it is. But they don’t use 5

any electricity. It’s purely just loss of product 6

due to heat transfer. 7

MR. LLENZA: This is Charles Llenza, 8

Department of Energy. For the self-contained units, 9

that’s the same issue? 10

MR. ERBS: In terms of melting of the ice? 11

MR. LLENZA: In terms of the electricity 12

used. 13

MR. ERBS: Oh, yeah. 14

MR. LLENZA : They’re all non

- refrigerated? 15

MS. WIDDER : Yes. 16

MR. ERBS: Correct. 17

MR. LLENZA: Both classes? 18

MR. ERBS: Correct. 19

MR. LLENZA : Okay. 20

MR. BROOKMAN: Yes, please, your name for 21

the record? 22

MR. MAURITZ: Donald Mauritz, Berkeley 23

National Lab. Just getting back to the standby 24

issue for a second. You mentioned it was a very 25Executive Court Reporters (301) 565-0064 142 small percentage or fraction of a percentage. Can 1

you translate that into wattage? Is it a watt or 2

two, or are we talking ten watts? 3

MR. ERBS: It’s probably on the order of 4

ten watts. 5

MR. BROOKMAN: Okay. Thanks. 6

MS. WIDDER : All right. We’ll keep going 7

then. In addition to the changes that were 8

incorporated into the updated ASHRAE and AHRI test 9

procedures, there are a couple of other issues that 10

the Department is looking at from a test procedure 11

perspective, most of which have been mentioned here, 12

but have a little bit different take now that we’re 13

looking at how do we test these. 14

One would be the testing of larger 15

capacity equipment beyond the 4,000 pounds per day 16

capacity range. If we chose -- if the Department 17

chose to cover those equipment, would they be 18

applicable under the current test procedure? And 19

the DOE understands that these larger capacity 20

machines should not have a problem being tested 21

using the methods defined in AHRI 810-2007 and 22

ASHRAE, the current ASHRAE standard. 23

DOE requests comment on applying the AHRI 24

810

- 2007 te st procedure, if there’s any issues that 25Executive Court Reporters (301) 565-0064 143 we should be aware of with larger capacity or 1

perhaps more unique type machines, tube type 2

machines, that would have difficulty being tested 3

under this method. 4

MR. BROOKMAN: John. 5

MR. BROADBENT: John Broadbent. The only 6

issue -- you have Intertech doing the testing. I 7

don’t know how big their equipment goes, so that 8

would be the only potential limitation. 9

MS. WIDDER : Thank you. 10

MR. AMRANE: Karim Amrane, AHRI. I think 11

I made the comment before that we d on’t see the need 12

to go beyond 4, 000. We think it’s industrial and 13

outside the scope of this rulemaking. 14

MS. WIDDER : Yes. Another issue. This 15

has already been raised and we have already received 16

comments about the issue of either combining 17

condenser water use and potable water use used in 18

making ice into a singular total water use metric, 19

or keeping them separate. There are reasons that 20

you would do either, and I know there has been 21

comments that they should stay separate, and this is 22

only if the DOE chooses to regulate potable water 23

use or has the authority to regulate potable water 24

use. But we’ll take comments again at this time if 25Executive Court Reporters (301) 565-0064 144 you’d like to make them about the pros and cons, or 1

the reasons why you would keep condenser water use 2

and potable water use separate or combine them into 3

a singular metric. 4

MR. BROOKMAN: John. 5

MR. BROADBENT: If you combine them into a 6

single metric, and eliminate having them separate, 7

then installations where they’re using a closed loop 8

water system, where you’re n ot really

-- I mean 9

you’re using the water for condensing, but you’re 10

not throwing it away, that becomes almost 11

irrelevant, but now you’ve lost visibility to the 12

potable water use. So I don’t know that it makes 13

sense to combine them. I think it makes sense to 14

keep them separate. 15

MR. BROOKMAN: Thank you. 16

MS. WIDDER : All right. Another issue 17

that’s been brought up is the issue of testing 18

remote condensing units. DOE has recognized an 19

inconsistency in the way energy use of remote 20

condensing ice-make rs is reported. Some ice-makers 21

that are sold with a dedicated remote condensing 22

unit are reported with the energy use of the ice 23

making head, the compressor and the condenser. 24

Other ice-makers that are sold to specifically be 25Executive Court Reporters (301) 565-0064 145 hooked up to a remote rack system only the energy 1

use of the ice making head is reported. So that, as 2

has been mentioned, is much lower than the 3

compressor and condenser energy use. 4

And right now, those are not 5

differentiated, and so the DOE is recognizing the 6

need to perhaps specify further the way in which 7

these different types of remote condensing ice8

makers are tested. 9

And the DOE has developed three potential 10

approaches to address this issue. The first would 11

be a calculation method that applies a default 12

factor to the ice making head energy consumption, 13

that would be representative of the remote rack 14

condenser use, and that would be similar to the AHRI 15

1200 test procedure, which has developed a table of 16

EER s , energy efficiency ratios, that could be 17

applied to the heat load of the ice-maker and you 18

could come up with a representative factor based on 19

the heat load of the ice-maker. 20

The second would be a measurement method 21

whereby the ice making head is hooked up to a 22

dedicated remote compressor and condenser system of 23

su fficient capacity, and although that wouldn’t be 24

representative of how that ice making head would be 25Executive Court Reporters (301) 565-0064 146 used in the field, in conversations with 1

manufacturers, that seems that’s the way it’s tested 2

today, it is just hooked up to a dedicated remote 3

compressor. A nd that could be consistent across all 4

that class of equipment. 5

And then the third option would be to 6

continue to report only the ice making head energy 7

use of those remote condensing systems, and not 8

report the energy use of the remote rack or the 9

re mote condenser and compressor. And that would -- 10

any of these, actually, but specifically the third 11

option, would require a separate equipment class so 12

they would not be compared to a similar ice making 13

head that has a dedicated remote compressor and 14

cond enser when that energy use is reported. 15

And so the request for comment, DOE 16

requests comment on how the energy consumption of 17

ice

- makers that are designed to be connected to a 18

remote rack should be calculated in the DOE test 19

procedure. Specifically, the pros and cons of the 20

three methods proposed, or any additional methods 21

that manufacturers or stakeholders feel would be 22

more representative. And also perhaps whether or 23

not these methods would require a separate equipment 24

class, or should require a separate equipment class. 25Executive Court Reporters (301) 565-0064 147 MR. BROOKMAN: Joanna. 1

MS. MAUER: Joanna Mauer. Just a quick 2

clarification. These potential options are to 3

address ice-makers that are connected to rack 4

systems, specifically, not ice-maker that are 5

connected to dedicated remote condensers? 6

MS. WIDDER : Correct. Correct. 7

MS. MAUER: And maybe just a question for 8

the manufacturers. Are ice-makers with remote 9

condensing units always sold with the remote 10

condensing unit as a package? 11

MR. BROADBENT: This is John Broadbent. 12

Yes. 13

MS. MAUER: Thank you. 14

MR. BROOKMAN: So Daryl, please. 15

MR. ERBS: So, my comments would be for 16

this to really work, I think you’re going to have to 17

have a test method. So number one, which is purely 18

calculation, to me doesn’t make sense becaus e 19

different ice making heads could have different 20

efficiencies in terms of how they converted the 21

refrigerant supplied by the rack into ice. And if I 22

understand number one, you would just treat them all 23

the same. You would have the electrical use that 24

th ey consumed at the ice making head, but you 25Executive Court Reporters (301) 565-0064 148 wouldn’t differentiate based on how much refrigerant 1

they consumed to make the ice, because you’re not 2

doing any testing. 3

MS. WIDDER : No, I’m sorry. To clarify 4

point one. It would be similar to the third point, 5

where you’re testing the ice making head, and so 6

that is a measurement, and then applying -- and then 7

measuring the refrigerant flow and use that to -- 8

MR. ERBS: But I don’t think the 9

refrigerant flow is measured today I guess is my 10

point. 11

MS. WID DER : It’s not, that’s correct. 12

That would require more test methods. 13

MR. ERBS: So for this to work, I think it 14

would be a test method that requires measuring the 15

refrigerant flow to the ice making head, and then 16

you could combine that with some assumption around 17

the efficiency of the rack. Again, just -- that’s 18

the approach that was taken for the display case. 19

MS. WIDDER : Right. 20

MR. ERBS: That makes sense to me, but 21

it’s

-- like in my earlier comment, is -- is it 22

warranted based on the volume of these. But 23

technically, you can do it. 24

MR. BROOKMAN: Karim. 25Executive Court Reporters (301) 565-0064 149 MR. AMRANE: Karim Amrane, AHRI. A 1

question, I mean, what’s the incentive here? I mean 2

are we talking about a lot of units here? Are we 3

talking about just a few? Why do we want to go -- 4

is it really necessary to capture those? 5

MS. WIDDER : I think that’s a question 6

that I would feed back at you, Karim. We’ve 7

identified these as for sale in the market. As has 8

been mentioned previously, we don’t have very robust 9

shipments data right now, and it seems to be that 10

these types of remote rack systems are a more recent 11

product and developed more recently. Since the 12

flake and nugget machines have increased in 13

popularity and we’ve noticed it mostly with a flak e 14

and nugget ice making head, that then is connected 15

to a remote condensing rack for a grocery store 16

application, and to be completely honest with you, 17

I’m not sure of the shipments per year. I think 18

you’re correct in thinking that it might be lower 19

than a self-contained cuber unit, but I think we’d 20

welcome comments to that extent as well, as to 21

whether it’s justified to cover these. 22

MR. LLENZA: This is Charles Llenza, 23

Department of Energy. Like the beverage vending 24

machine equipment, we had the solid doors and the 25Executive Court Reporters (301) 565-0064 150 glass doors, but we knew that the industry was 1

telling us that the glass door shipments were going 2

to be increasing over time. Therefore, part of what 3

we’re going here is establishing what we have and 4

where we’re going. 5

So if we think that where we’re going is 6

that these -- that the number of shipments would be 7

increasing to a significant amount, then that would 8

be relative to the shipment data and the input from 9

the industry in terms of where the industry thinks 10

we’re going with this equipment, and that’s more 11

relative as opposed to the snapshot we have, which 12

is there are not too many units right now. 13

MR. BROOKMAN: So that’s what

-- 14

MR. BIEL: Jeff Biel. Yeah, absolute 15

numbers i t’s one of the smallest categories that 16

we’ve seen

. A s far as where it’s going, it’s to ugh 17

to say, but I would have a real tough time seeing 18

that it would exceed any of the other existing 19

categories that we’ve been talking about. 20

MR. BROOKMAN: John. 21

MR. BROADBENT: This is John Broadbent. 22

And I reflect Jeff’s comment that the sales are 23

really low and the rack systems are pretty much 24

predetermined, you know, because the ice maker is a 25Executive Court Reporters (301) 565-0064 151 small part of the overall system. So the rack 1

system would have already been selected, so we have 2

no control over that. There’s a lot of different 3

manufa cturers, and there’s a high custom component 4

to the rack system, so you never really know. 5

So like for item 2, it would be extremely 6

difficult to test a given ice-maker with all the 7

variety of potential rack systems, almost 8

impossible. 9

MS. WIDDER : I ’m sorry, I should clarify 10

that as well. That’s not what’s being proposed in 11

i t em two. I don’t think ice

- makers should be tested 12

with remote racks, and I’m not aware of many test 13

l ab s that have remote racks. This would be taking 14

an ice

- making head that is designed to be sold to a 15

remote condensing rack, specifically, but hooking it 16

up instead to a dedicated condenser and compressor 17

unit that a manufacturer produces which would not be 18

representive of its energy use in the field, but 19

would be a way to test it. That’s the second 20

option. 21

MR. BROOKMAN: What’s left

-- Daryl. Go 22

ahead Daryl. 23

MR. ERBS: So just from my perspective in 24

terms of -- is it like the remote condensing going 25Executive Court Reporters (301) 565-0064 152 to be the next big thing? No, I don’t think so. In 1

fact, my understanding is that on the retail side -- 2

I mean these go in the grocery stores almost 3

exclusively and the only other place would be in 4

some very large seafood processing, where they 5

actually need so much ice they would invest in that 6

kind of a unit. 7

Grocery stores, if anything, are moving 8

away from the use of flake ice. They still like to 9

use it for certain merchandise like fish where 10

there’s an aesthetic appeal. But a lot of the, like 11

the produce cases have gone to misting and 12

refrigerated rail systems, and so where they used to 13

use flaked ice, they don’t any more. It’s really 14

just a replacement business for those stores that 15

continue with their standard approach. 16

And as we all know, there’s not more 17

seafood coming out of the ocean, there’s less, and 18

so I w ould argue that it’s not a growth area, and so 19

wh a te v er the volumes are today, they probably not 20

goin g to grow significantly in the future. 21

MR. BROOKMAN: Joanna. 22

MS. MAUER: Joanne Mauer. I think the 23

other question I would have is whether there is a 24

significant number of applications or consumer 25Executive Court Reporters (301) 565-0064 153 choice of purchasing an ice-maker with a dedicated 1

remote condenser or if it has a rack system that it 2

could hook it up to, and in that case, whether there 3

weren’t standards for products that were connected 4

t o rack systems whether we might see some shift in 5

the market, even, if the current sales volumes are 6

low today. Just a question. 7

MR. BROOKMAN: Daryl, yes. 8

MR. ERBS: First, I’ll go back to an 9

earlier comment. At least the ones we sell, it’s 10

essentially the same ice making head that we would 11

use for either rack system or a dedicated remote 12

condensing unit with some minor variations, because 13

on the rack system they’ll put a pressure regulator 14

on the suction because the suction heads that run on 15

the rac ks don’t necessarily match exactly with the 16

ice making head. 17

But they’re going to get essentially the 18

same efficiency with the ice making head, whether 19

they buy it to go with a dedicated condensing unit, 20

or to attach to a rack system. The decision is 21

really driven by if it’s a new supermarket, they’ll 22

design it in because that’s a more cost

- effective, 23

and actually energy efficient

-- it’s more effective 24

to do it through the rack system. 25Executive Court Reporters (301) 565-0064 154 If they’re making flake ice in the central 1

location, but I mean one of the trends you’ll see in 2

supermarkets is for other uses of ice. They’re 3

putting in beverage bars. They’re putting in 4

bagging systems in the stores -- those aren’t really 5

amenable to hooking up to a rack, and so I think 6

there’s just a

-- it’s a system design and they’re 7

probably not making those decisions based on the 8

energy efficiency rating of the ice machine. It’s 9

driven by other design considerations for the store. 10

MR. BROOKMAN: Harvey. 11

MR. SACHS : Harvey Sachs. The gorilla in 12

the shadows of this room is the evolution of 13

refrigeration architectures as we go into the next 14

round of refrigerant replacements for environmental 15

concerns. And what I’m hearing for a lot of reasons 16

beyond Daryl’s comments, is that rack mounted 17

systems are not likely to be a growth industry 18

because of refrigerant loss concerns. 19

I would appreciate industry’s comments on 20

that so that we’re not putting a lot of resources, 21

both government and industry, into things which are 22

not helping us get ready for the next decade, 23

because the time costs on these things is pretty 24

long. 25Executive Court Reporters (301) 565-0064 155 MR. BROOKMAN: Comments on that? And also 1

I’d like to get final comments on these three 2

potential options if there’s anything else to be 3

said about them. Daryl. 4

MR. ERBS: The only, I guess, comment that 5

I would make on that is the rack systems of the 6

future will not be the rack systems of the past. I 7

mean the current trend is actually to go to multiple 8

refrigerant solutions. CO2 is continuing to grow in 9

the retail side, and I think that’s go ing to 10

continue to be driven by the regulations around 11

leakage and all of the reporting. And so I think 12

you’re right that it’s

-- but they’ll continue to 13

exist but it’ll also bring a complexity of -- if we 14

were to put in place these regulations and CO2 15

b ecomes the favorite refrigerant for the low side, 16

if

-- that just adds another layer of complexity to 17

a fairly small piece of the puzzle. 18

MR. BROOKMAN: So additional comments on 19

this slide, because we’re going to move on. 20

MS. WIDDER : All right. Moving on. This 21

is my last slide, but there is quite a bit of 22

content here. There’s also a number of issues that 23

the DOE has been looking into relating to accuracy 24

or repeatability of the test procedure. And these 25Executive Court Reporters (301) 565-0064 156 are just a list of several factors. I’ll g o through 1

each of them in more detail, that could affect the 2

accuracy or repeatability of the test procedures and 3

at the end we’ll look for comments on that. 4

The first has been brought up already, the 5

issue of water hardness or total dissolved solids, 6

mi nerals in the water affecting the energy use of 7

the ice

- maker, whether that’s a significant impact, 8

or something that needs to be standardized across 9

ice

- makers based on -- I think the manufacturers 10

mentioned they designed it for sort of worst case 11

scenari o, but will that change? Will your energy 12

use change significantly if you have cleaner water, 13

or is there a type of filter technology that’s being 14

put on to affect water hardness from the potable 15

water side? 16

Another issue is the ice quality, 17

specifically with flake and nugget machines. 18

There’s a range of percentage water versus 19

percentage ice that can be produced, and is there a 20

need to standardize around a certain percentage of 21

water for those equipment classes, or perhaps 32 22

degree ice in all cases with no water content, and 23

use some sort of calorimetry test that’s already 24

part of ASHRAE to standardize to that level for 25Executive Court Reporters (301) 565-0064 157 flake and nugget machines, just to make sure we’re 1

comparing apples to apples? For those types of 2

machines, if you had a machine that produced 30 3

percent water, that clearly would use lots less 4

energy than one that produced ten percent water with 5

ice for the same amount of -- same volume of water 6

in. 7

The ice temperature, also, if you produced 8

colder ice, that will use more energy than if you 9

produced just 32 degree ice, and is there a need to 10

standardize around ice temperature? That would sort 11

of go into ice quality as well, but is there a 12

significant market share or a need for colder ice? 13

Also, specified in the test procedure is a 14

25

- foot length of refrigeration line. Is there a 15

need to specify a specific diameter or insulation 16

level? Right now it’s as per manufacturer 17

specification. As those will both impact the energy 18

use of the machine, perhaps those are types of 19

design option s, and so they don’t need to be treated 20

specifically or explicitly standardized, but they’re 21

just factors that the DOE has recognized will affect 22

the results. 23

Also the condenser air inlet temperature 24

is specified, but typically, right now in the test 25Executive Court Reporters (301) 565-0064 158 pro cedure it’s a singular measurement and in other

- 1

- in other appliances that use condenser inlet air 2

temperature as a value for cooling, they have a grid 3

measurement that’s more accurate to make sure you’re 4

having the proper temperature of air inlet, having 5

it of the specified accuracy, and is that warranted 6

here for air cooled machines. 7

And then the last point also comes out of 8

other appliance rulemakings, where clearance around 9

the side of the appliance or above the appliance has 10

become an issue. There are some taller ice-makers 11

and right now there’s a test temperature sensor that 12

would test the ambient air temperature a foot above 13

the ice -maker. And is there issues if that test 14

temperature is then at the ceiling of the test room, 15

will that affect the accuracy of the results? Is 16

that an issue? Is that done today, and what’s done 17

to address these? 18

MR. BROOKMAN: So comments on these 19

potential sources of inaccuracies and potentially 20

others. I guess surrounding what the impact would 21

be. 22

MS. WIDDER : Yes. And I’ll just clarify, 23

now would be helpful but also in written comments if 24

that’s more appropriate. 25Executive Court Reporters (301) 565-0064 159 MR. BROOKMAN: John. 1

MR. BROADBENT: John Broadbent. I’ll 2

comment on some of these. Water hardness will have 3

minimal energy impact on the short term test, would 4

have effects long-term on how a machine gets dirty, 5

how often you have to clean it, things like that, 6

reliability. 7

Ice quality is a very tricky one. When 8

someone goes to get a glass of ice, the ice that has 9

the lowest energy content would actually be the most 10

efficient, because they’re just going to fill their 11

glass up, not looking for X amount of BTUs, they’re 12

looking to fill their glass up. So if they have the 13

lowest energy density ice in their cup, they’ll 14

actually use the least amount of ice. So that 15

argument, I would say, low quality is actually good. 16

So it’s very tricky to try and

-- and I don’t know 17

if there’s a right answer for that, but it’s a very 18

tricky one. And I can address that further in our 19

written comments. 20

Ice temperature, everybody pretty much is 21

at 32 degrees. I’m not aware of any ice that’s 22

severely subcooled. 23

And I don’t believe any of those other 24

criteria are going to have a significant impact. 25Executive Court Reporters (301) 565-0064 160 MS. WIDDER : Thank you. 1

MR. BROOKMAN: Other comments? Okay. 2

MS. WIDDER : Next we welcome Alan Cooke 3

from Pacific Northwest National Lab to talk about 4

Markups and Equipment P rice Determination. 5

MARKUPS AND EQUIPMENT PRICE DETERMINATION 6

MR. COOKE: Good afternoon. I’m going to 7

talk about markups. In the analyses that are going 8

to follow downstream, life cycle cost and payback 9

period, and also the national impact analysis, we 10

use the price that consumers pay for the equipment. 11

What Detlef talked about estimating earlier is the 12

actual production cost, and then in Detlef’s 13

analysis he’ll also add a markup for the 14

manufacturer to reach a manufacturer selling price. 15

But in this stage of the analysis, we will 16

look at the markup that is added by the distribution 17

chain. In a minute I’ll go to another slide that 18

will show the three channels, but I thought I would 19

describe them first. 20

We’ve defined three different distribution 21

chains, and we’ll give you an opportunity to comment 22

on them later, after I get done here, and also in 23

writing. 24

The first one is a direct manufacturer to 25Executive Court Reporters (301) 565-0064 161 the consumer chain. We’ve described that as the 1

national accounts chain. 2

MR. BROOKMAN: You want to advance the 3

slide? 4

MR. COOKE: I’ll advance it in just a 5

mome nt. The second one is a chain where it goes 6

from the manufacturer to a distributor or a 7

warehouse, or whatever you want to call them, 8

wholesaler, and then it goes to the consumer. 9

And then the third one is a chain where 10

some sort of a contractor actually initiates it, and 11

they buy it from the distributor who buys it from 12

the manufacturer. So you have a one step chain, a 13

two step chain, and a three step chain. 14

What we will do in our analysis is we will 15

obtain information from the distributor industry, 16

through their national trade associations or 17

wherever we can find the information to try to 18

define what the costs are for the distributors. And 19

that will become one input. 20

We’ll also go to the census bureau and 21

find information about what some of the various 22

contractors that are involved in this. It might be 23

the HVAC type of -- HVAC and refrigeration type of 24

contractors, whatever it might be. So we will 25Executive Court Reporters (301) 565-0064 162 define a couple or three cost elements. 1

And then the question is, in order to 2

apply this to the actual manufacturer price to get a 3

consumer price, how do we weight those to create one 4

factor? So what I’ve shown you here is somewhat 5

analogous to what we’re doing in the commercial 6

refrigeration rulemaking right now, where we’ve 7

defined two different -- where there’s really two 8

different types of products, one of which is remote 9

condensing, and one of which is fully self10

contained. 11

Self- contained in the CRE market, you can 12

just bring it in and plug it in and you’re pretty 13

much done. So that’s a complet ely different kind of 14

a market than the remote condensing. And these are 15

the kinds of numbers that we’re looking at right now 16

for trying to match those up -- actually it’s not

-- 17

but this is what we proposed in a framework document 18

for weighting those up in that particular 19

rulemaking. 20

What I’m going to be looking for here 21

today, and also in the written comments is, what is 22

the appropriate way to slice this up? So I’m 23

building up my markup factor in a way that resembles 24

your market. Should it be -- shou ld I be building 25Executive Court Reporters (301) 565-0064 163 it up for each product class? Are there breakouts 1

like the differentiation between remote and self2

contained that would make sense? And what is the 3

percentage that goes to each of these chains? 4

We use two different types of markups in 5

this process. The first one we call the baseline 6

markup. It’s designed to recover all of the costs 7

of the distribution chain. So it will be applied to 8

the baseline unit. The second markup is called the 9

incremental markup, and it’s designed to capture 10

t hose cost components that vary with the price of 11

the equipment. What might go up as the equipment 12

gets more expensive? And there aren’t very many of 13

them, but we’ve pretty much assumed that most of the 14

distributor chain costs are being captured in this 15

b aseline markup. 16

So we do have some questions that we hope 17

to get some feedback on. First of all, are those 18

three distributor chains, the distributor, and then 19

the distributor-contractor, are those the 20

appropriate distribution channels for commercial ice 21

making equipment that’s covered under this 22

rulemaking? 23

Second, DOE requests information on 24

whether the distribution channels differ by the 25Executive Court Reporters (301) 565-0064 164 types of buildings that comprise the market for 1

automatic commercial ice-makers, mainly food sales, 2

food service, health care facilities, lodging 3

facilities and others, so do they differ by that or 4

is it all the same? 5

Number three, do you like the use of that 6

baseline versus the incremental markup? Is there a 7

different approach that you would like us to use? 8

The fourth item is DOE seeks comments on 9

the sources of the food service distribution chain 10

data that can actually be used to compile the 11

markups for this equipment. Right now the only good 12

source of data that I’m aware of comes from a group 13

called HARDY, which covers heating, air conditioning 14

and refrigeration equipment, so it’s not really 15

specific to this, but right now it’s the only source 16

that I have identified, so I’m hoping that you have 17

some ideas where I can find this data. 18

And the last one on this list, is DOE 19

seeks comments on appropriate transportation and 20

shipping costs to include in the analysis and 21

whether these costs are likely to vary for higher 22

efficiency equipment. I might also add we might be 23

welcoming your comments on where these costs are 24

actually included. Are they actually included in 25Executive Court Reporters (301) 565-0064 165 the cost that the manufacturer is charging to the 1

distributors? Or are they added on later on in the 2

distribution chain? 3

MR. BROOKMAN: Jeff. 4

MR. BIEL: Do we have another day to 5

discuss this one? I mean the way ice machines go to 6

market, it’s quite complicated, and I don’t see a 7

big issue with the national account distributor. 8

And when you say contractor , I’ll just throw the 9

term dealer in there as well. There’s a lot of 10

different terms. 11

As far as the percentages, I think that’ll 12

probably be better addressed through the written 13

comments, and I personally don’t see a need to split 14

self

- contained and remote condensing, because the 15

lines get very blurred between national account 16

distributor and senior contractors, so you can 17

probably simplify that. 18

And I’ll be happy to provide a lot of 19

other comments in regards to your other items. Item 20

7.5, there’s really no additional shipping cost that 21

should be included with energy efficient equipment, 22

so it w ould be the same, pretty much, whether it’s 23

high efficiency or not. 24

MR. BROOKMAN: Along the distribution 25Executive Court Reporters (301) 565-0064 166 chain, does it apply uniformly where? The shipping 1

costs, where they get tagged? It’s all over the 2

place? 3

MR. BIEL: It can vary, yeah. 4

MR. BROOKMAN: Okay. Thank you. Anybody 5

else on the manufacturing side wish to comment here? 6

Yes. 7

MR. BROADBENT: John Broadbent. One of 8

your distribution chains was it went from 9

manufacturer to distributor directly to the end 10

user. That’s very rare. Our distributors get in 11

trouble if they do that. So it typically goes from 12

the distributor to a dealer to the end user. 13

MR. BROOKMAN: Is that because the 14

installation is complicated? 15

MR. BROADBENT: The reason for the 16

distributor is to provide local service, local 17

inventory of product, because you never know what a 18

given end user’s site is going to want, you’ve got 19

to have it close, and a high percentage of sales are 20

replacement sales, and so they need something right 21

away, and so they can’t wait a we ek for it to be 22

shipped from the factory. It needs to be local. So 23

historically, there is a distributor and a dealer in 24

place in a territory. 25Executive Court Reporters (301) 565-0064 167 MR. BROOKMAN: I see. Okay. You can see 1

as you look at this comment box, several different 2

comment requests. I think we’ve begun to address 3

some of them. Take a quick peek, see if there’s 4

anything else to be said at this point. Okay. 5

MR. COOKE: Okay. Then we’re going to 6

have Michelle Britt back up here, Michelle Britt 7

from the Pacific Northwest National Laboratory. 8

ENERGY USE CHARACTERIZATIONS 9

MS. BRITT: To try to be brief, I’m going 10

to skip ahead some of the background information and 11

so if I leave something out for somebody who’s new 12

to the process, please ask, but if there are no 13

questions I’ll go ahead and skip ahead. Energy use 14

characterization focuses on characterizes the use of 15

the equipment, both in terms of energy efficiency 16

and water use, as it will be used installed, or in 17

the field, based on different efficiency levels. 18

So, as you can imagine, we have a 19

significant number of assumptions that need to be 20

determined to work into this analysis. We need 21

assumptions regarding distribution, both in the 22

number and type of ice-makers. Here we get back 23

into the building occupancy issue. We need to 24

understand the relationship, if there is one, 25Executive Court Reporters (301) 565-0064 168 between building occupancy type and utilization 1

factors. 2

And the energy use impacts of the 3

utilization factors that result in down-cycling. We 4

touched on that a little bit earlier. If there is, 5

for e xample, a 35 percent utility factor, that other 6

65 percent of the time what are we looking at in 7

terms of energy use. If it is ten watts, we’ll 8

assume ten watts, but to project the -- to project 9

out on energy use characterization, we need to know 10

what’s h appening during that down cycling time. 11

And finally, the impacts of the indoor 12

machines on heating and cooling loads. Is there 13

something that we -- that could be substantial 14

enough that we need to look at whole building 15

modeling? So we need to be able to make assumptions 16

with regards to the percent of machines that use 17

remote compressors, remote condensers. Are they in 18

different types of buildings? Is there a 19

relationship between efficiency levels, harvest 20

ranges, et cetera? What are those relationships so 21

that we can understand the magnitude of impacts, if 22

there is one, on the heating and cooling loads of 23

the building? 24

With regards to developing some of these 25Executive Court Reporters (301) 565-0064 169 assumptions, what we’ve looked at so far in the 1

literature review, we’ve looked at any ACE EE papers 2

that have been produced on this topic. We’ve gone 3

back and looked at manufacturers’ input to the CEC 4

when they originally developed the standard. And 5

we’ve looked at ADL, now NCI, reports that go back 6

to 1993, when they developed some initial 7

a ssumptions based on 1990 numbers. 8

So as you can imagine, if there’s an 9

opportunity, if we need to update these assumptions, 10

we’d like to get that data so that the analysis is 11

appropriate to today’s ice -maker trends. 12

MR. BROOKMAN: Why are these numbers so 13

uniform? 14

MS. BRITT: That -- two of the things that 15

we’ve seen change in the assumptions between 1993, 16

which was actually 1990, and today, we’ve seen the 17

distribution, the number of units per building 18

change from fractional use per building, to whole 19

numbers per building. In 1990, it was assumed one 20

ice

- maker per every ten buildings. By 2008, it was 21

assumed one ice-maker per building, with the 22

exception of health care that was at five. 23

We saw similar differences with 24

utilization factors. In the early 1990 assumptions, 25Executive Court Reporters (301) 565-0064 170 it was a point five utilization factor that was 1

assumed everywhere except for hotels, which are 2

lodging, which was at point three. And the most 3

recent studies, in 2008, NCI contacted manufacturers 4

to verify those numbers at that time, came up with a 5

constant of point five across all building types. 6

MS. MAUER: Joanna Mauer. Just so I 7

understand. The utilization factors are supposed to 8

represent the percentage of time the ice-maker is 9

actually making ice? 10

MS. BRITT: Yes, I apologize. So yes, if 11

it’s a 2 ,000 pound machine, it was actually only 12

needed to make 1,000 pounds per day. 13

MR. BROOKMAN: Okay. 14

MS. BRITT: I’ve summarized our data needs 15

to make correct assumptions, and I have questions 16

up. 17

MR. BROOKMAN: So you can see the comment 18

box. Let’s hear from folks on these. 19

MR. SACHS : Well, Doug is not looking 20

around. 21

MR. BROOKMAN: Sorry. 22

MR. SACHS : Harvey Sachs. The flip side 23

of the question of whether ice making machine 24

operation is a negligible impact on building space 25Executive Court Reporters (301) 565-0064 171 conditioning loads, is whether alternative 1

architectures have potential beneficial impacts. 2

And that will be quite specific to the architecture 3

and to the building use, for example. The impacts 4

of water loops might be quite different in a 5

c onvenience store, a fast food restaurant, a sit6

down restaurant, and a hotel. So I don’t think, 7

personally, it’s worth getting too deeply into the 8

simulation games, but it might be worth thinking 9

about the differences between uses that lead to 10

beneficial use of the waste energy versus those that 11

don’t for some specific end

- member type buildings. 12

MR. BROOKMAN: Thank you. Yes, Daryl. 13

MR. ERBS: I guess I can make a couple of 14

comments. The first one is I truly don’t believe 15

that all end use segments are at point five. I know 16

of some that are higher than that. I know of some 17

that are lower than that. I couldn’t give you a 18

number for all of them. I don’t know how you get 19

that number. So I’m not sure I have a very good 20

suggestion for how to alter that. 21

And I don’t know how sensitive your 22

analysis is to variations by segment in that number, 23

so it would -- I guess I’d want to know how much 24

does it really matter to the end result of this 25Executive Court Reporters (301) 565-0064 172 rulemaking, before I’d even be motivated to try to 1

dig up some more information for you. It’s not an 2

easy thing to do. 3

MR. BROOKMAN: Can you summarize why 4

you’re seeking this data? 5

MS. BRITT: Right. As the energy uses get 6

calculated, if we’re looking at

-- if we do go into 7

looking at it by building type, then we use the 8

CBEC’s numbers of square footage by building type to 9

extrapolate out the energy use by the building type. 10

And again, if there’s a relationship there between 11

whether they’re water cooled or air cooled, and 12

whether they use the remote equipment, that’s when 13

it becomes -- may well become significant. 14

MR. BROOKMAN: Okay. John. John? 15

MR. BROADBENT: Yeah. The duty cycle, 16

utilization is going to be a function of the 17

equipment that was purchased. So you can buy a 18

machine that’s way too big for your needs, and it’s 19

going to have a very low utilization factor. Or you 20

can buy one that’s too small, and you’ll have a very 21

high utilization factor. So it’s really a function 22

of what -- and the other factor is, did they buy it 23

so they wouldn’t run out of ice on July 4 th , because 24

that’s what people do, they want to have 100 percent 25Executive Court Reporters (301) 565-0064 173 utilization on July 4 th , and then every other day, 1

they’re going to have too much ice. That way they 2

know they’ll never run out. 3

It’s also a function of how good the sal es 4

person was to convince you to buy a machine that’s 5

too big for his needs. There’s a lot more to it 6

than just utilization factor, it’s really about 7

capacity. 8

MR. BROOKMAN: Okay. 9

MR. BROADBENT: And then a comment 10

regarding water cooled and remotes. There is a lot 11

of, you know, all that energy has to go somewhere. 12

And if you’ve got a water cooled or a remote cooled, 13

the energy’s going outside, the waste heat’s going 14

outside, so you can’t use it for heating, but you 15

don’t have to air condition it either. So there is 16

a factor. 17

What will happen is that consumers will 18

buy whatever is the most cost effective for them, 19

given their situation, they may cheap out and get an 20

air cooled when they really would have been better 21

off, from a total energy standpoint, buying the 22

remote. So that is a factor. 23

MR. SACHS : Harvey Sachs. John, just to 24

clarify, I’m trying to think about situations where 25Executive Court Reporters (301) 565-0064 174 BTU’s a BTU, and I can at least use that for 1

preheating in a water loop for my hot water -- 2

service hot water, clean up needs. 3

MR. BROADBENT: Well, you could actually, 4

if you have an air cooled machine, for example, it 5

does provide some heat in the winter. So it’s a 6

trade off. You’d have to consider all those 7

factors. 8

MR. SACHS : I think we’re sharing the 9

p erspective that making the appropriate theological 10

assumptions, we could carry this one to far more 11

detail than it’s worth. 12

MR. BROOKMAN: Daryl, please. 13

MR. ERBS: So I’ll make one comment on 14

item 6

- 2. I’m going to hypothesize it. Most of the 15

time, the ice making machine has a negligible 16

impact, not that it doesn’t add heat to the space, 17

but, you know, common scenarios are if someone puts 18

a self

- contained air cooled unit in the kitchen, 19

it’s typically one of the smaller loads compared to 20

all the other things dumping heat into the kitchen, 21

so there’s a big load there, but it’s a small 22

percentage of it. 23

Another favorite example is -- we’ve all 24

experienced this -- in hospitality, hotels, the ice 25Executive Court Reporters (301) 565-0064 175 machine dumps a bunch of heat, but they put it in a 1

part of the hotel where there’s no air conditioning, 2

so that’s why when you walk in there to get your 3

ice, it’s really hot in that little closed

- in room 4

that they stuff the ice machine into, and there’s no 5

air conditioner there. So that is a case where -- 6

And probably the one case I know of where 7

it probably has some measurable effect would be like 8

a convenience store, if they don’t use remote 9

condensing, where they can use a lot of ice in a day 10

and there aren’t that many other significant heat 11

loads, some, but it’s not as intense as a normal 12

kitchen. So there’s probably a case where it has 13

some impact. 14

We do publish heat rejection data, so I 15

mean there’s some information available to you that 16

you could use, if you were going to do any kind of a 17

building analysis to do that. 18

MS. BRITT: Thank you. 19

MR. BROOKMAN: Hey, Harvey, if you want 20

this on the record -- 21

MR. SACHS : No. 22

MR. BROOKMAN: Okay. Then -- let’s keep 23

moving on and respond to these questions. Let me 24

note that one of our webinar participants, Hashizaki 25Executive Court Reporters (301) 565-0064 176 (ph) agrees with Daryl, that point five is an 1

unrealistic number. It varies by application, so 2

there’s more to be said on this subject and 3

hopefully I will provide good detailed, written 4

comments. 5

Any more comments on this comment box? 6

Joanna. 7

MS. MAUER: Joanna Mauer. I think I’d 8

just say that I think it would be very helpful to us 9

if DOE can present some kind of limited amount of 10

data or modeling, just to get a sense for the 11

magnitude of what this impact really is, to know 12

whether it’s, as Harvey said, a convenience store, 13

what would the impact be there, so we can get a 14

sense of whether it’s important to

-- 15

MR. LLENZA: This is Charles Llenza, 16

Department of Energy. Did we post anything in the 17

TSD chapters -- we haven’t posted an ything yet, have 18

we? Okay. All right. I think we’ll take that 19

under advisement. 20

MR. BROOKMAN: Karim. 21

MR. AMRANE: Karim Amrane, AHRI. I mean 22

DOE has done this type of analysis for commercial 23

refrigeration and you found this impact to be 24

negligible , so I don’t think you would have any

-- 25Executive Court Reporters (301) 565-0064 177 it would be any different in this case. So I don’t 1

know if you want to spend the time doing it, but I 2

don’t think it’s needed. 3

MR. BROOKMAN: Okay. Let me -- we’re kind 4

of at this decision point regarding the day. I told 5

you earlier that I thought we’d be running through 6

lunch. It’s now ten minutes after one. We have 7

about ten more slides, I think, or so, that are 8

substantive in the preliminary analysis segment, and 9

then once we get to the NOPR analysis presentation 10

slides, those go pretty quickly because they’re 11

really quite perspective. So we zoom through those 12

pretty quick. So the question is, should we just 13

keep going now? I see a lot of heads nodding. I 14

suspect it’s a half an hour or so and then we’re 15

done, but I just want to make sure no one’s severely 16

discomforted. Do we need a five minute break, or 17

should we just keep going? Keep going, Okay. You 18

have your instructions. 19

I tried to warm up the room, by the way. 20

I think it’s a little warmer in h ere now. 21

MR. COOKE: And I asked them up there if 22

they could warm up the room. 23

MR. BROOKMAN: That’s what did it. 24

MR. COOKE: And he will be here by the 25Executive Court Reporters (301) 565-0064 178 time we finish, so -- 1

MR. BROOKMAN: A weather update. It’s 2

snowing pretty good out there now, so there’s an 3

incentive for us to keep going. 4

MR. COOKE: So we’ll hurry up and get out 5

there where it’s actually warmer. 6

LIFE CYCLE COST AND PAYBACK PERIOD ANALYSIS 7

MR. COOKE: This is Alan Cooke. Pacific 8

Northwest National Lab . I’m going to talk a bout 9

life cycle cost and payback analysis. Life cycle 10

cost analyzes the cost of owning and operating this 11

equipment over the life of the equipment. So we 12

take into account the first cost, the installation 13

cost of that equipment to get it actually installed 14

into the user’s premises, the operating costs, and 15

then we look at that over the life of the equipment. 16

There are a couple things that we do with 17

this information. First of all, we’ll look at a 18

baseline life cycle cost for that baseline equipment 19

tha t Detlef is going to be describing for us, and 20

then we’ll start comparing that to the life cycle 21

cost of the equipment with the efficiency 22

improvements added to them, and the difference will 23

either be life cycle cost savings, if the efficiency 24

improvements outweigh the up front cost, or maybe 25Executive Court Reporters (301) 565-0064 179 life cycle cost increases if we find some things 1

that are really expensive and don’t save a lot of 2

energy. 3

There’s another piece of the analysis that 4

we do, largely with the same data, and that’s the 5

payback period analysis. In the payback period we 6

usually look at the first year operating cost 7

savings and divide that into the upfront cost of the 8

equipment to determine how many years it takes to 9

pay back that equipment. Now, if there are some 10

maintenance and repair costs that occur maybe every 11

other year or every third year, we’ll annualize 12

those so they do show up in the first year cost. 13

But generally, it’s the first year cost. 14

Here’s the flow chart, and I’m not going 15

to describe a lot of the individual boxes here. The 16

yellow boxes are inputs, and if you look on the 17

upper -- I guess that would be the left side -- we 18

see the inputs that are coming out of the 19

engineering analysis and a markup analysis. The 20

only thing we haven’t mentioned at all on that side 21

is sal es tax, which unfortunately is a fact of life. 22

So we add sales tax to the cost of all of these 23

pieces of equipment to get the actual consumer 24

price. Installation cost is added to that, and I’m 25Executive Court Reporters (301) 565-0064 180 going to talk about that in just a minute. That 1

g ives you your total installed cost. 2

On the bottom we have the energy input 3

that comes from the engineering analysis and the 4

energy analysis that Michelle just talked about. We 5

also have, in this particular piece of equipment, we 6

have the water usage. So that makes it just a 7

little unique as we’ve said a few times today. 8

The energy usage and the water usage are 9

combined with electricity and water rates to get at 10

the annual energy expense. Repair costs and 11

maintenance costs are added in there -- I’m going to 12

tal k about them in just a minute to get you to an 13

annual operating expense. 14

This is looked at over the lifetime of the 15

equipment which is an important variable that we 16

haven’t actually talked about yet, so we’ll talk 17

about that in just a minute. We have sums 18

discounted back to the present with discount rates 19

that apply to each building type that we’re going to 20

be studying. And all these things are combined, and 21

that gets you your life cycle cost. 22

Water prices. Water is not typically 23

studied in these, so it’s kind of a new animal. 24

We’re going to be trying to develop state by state 25Executive Court Reporters (301) 565-0064 181 water prices to go with our state by state 1

electricity prices, and we’re going to be looking to 2

the American Water Works, AWWA’s biannual price 3

survey, and any other price surveys or price 4

information that we can find. 5

Electricity pricing: we have the advantage 6

that the Energy Information Agency collects a lot of 7

information for baseline prices and they do 8

forecasts of electricity prices in their annual 9

energy outlook proces s. I’m unaware of anything at 10

a national level, at that level of aggregation for 11

water, so we’re going to be developing that 12

ourselves from the AWWA’s information. 13

So there is a question box here, and I’ll 14

stop right here and ask if there’s any comment. 15

We’re looking for input on the proposed methodology 16

for developing water costs. 17

MR. BROOKMAN: Harvey Sachs. 18

MR. SACHS : Harvey Sachs . I’m not an 19

expert in this area, but the AWWA data will be a 20

substantially lagging indicator. The recent reviews 21

of water infrastructure needs suggest that by the 22

time this data takes effect, water costs, on 23

average, will be much higher. In addition, there 24

are extraordinarily regional variabilities, larger 25Executive Court Reporters (301) 565-0064 182 than those for electricity prices. So the first 1

question that must be asked is whether water costs 2

significantly impact payback. And if so, it’s going 3

to require -- to say a doubling of today’s national 4

average price, if the answer to that is yes, then 5

just looking at the AWWA survey data will not be an 6

adequate way to treat water prices. 7

MR. BROOKMAN: Any additional ideas? 8

MR. SACHS : Well, I think you’re going to 9

have to get a bunch of us in a room to box it out 10

about what does make for appropriate price for the 11

period of interest, for 2015 on. 12

MR. BROOKMAN: Is anybody doing 13

forecasting on pricing? 14

MR. SACHS : There’s an awful lot of work 15

being done by people like Pacific Institute and the 16

Alliance for Water Efficiency. All of these are the 17

usual suspects, and I don’t have an answer, except 18

to raise th e flag that if it’s a significant 19

element, I’m quite convinced that today’s average, 20

or two years ago’s average will not be an adequate 21

representation of what water costs will be. 22

MR. BROOKMAN: Charles Llenza. 23

MR. LLENZA: Charles Llenza, Department of 24

Energy. Do you know if the EPA is conducting any 25Executive Court Reporters (301) 565-0064 183 studies in this area? 1

MR. SACHS : Harvey Sachs . I don’t know if 2

EPA is, but we’re happy to introduce you to this 3

whole water efficiency community. Apparently, it’s 4

a very active area. And I’ve only b een to one 5

meeting, so I’m naïve. 6

MR. BROOKMAN: Okay. Thank you. Comments 7

over here? No, nothing to add? Okay, you can keep 8

going on. I want to see if you can summarize, 9

David. 10

MR. COOKE: Okay. 11

MR. BROOKMAN: Oh, it’s Alan. Pardon me. 12

It’s Alan, the bearded man is Alan. 13

MR. COOKE: I really didn’t know how to 14

respond to that. Okay, there are three cost 15

components here that are really key that we haven’t 16

really talked about. 17

Repair costs, we’re going to look at the 18

annualized cost of replacing key components, so 19

it’s going to really be based on what do we 20

think those components cost and how often do 21

they need to be replaced. 22

Maintenance costs are going to be based on what 23

we think, by equipment type, the annual 24Executive Court Reporters (301) 565-0064 184 maintenance profile looks like and what it 1

costs to do that. 2

And finally, the upfront installation costs. 3

There are probably a number of different ways 4

we could estimate that. I’m hoping we can get 5

some input from you. 6

At this point in time, one of the things I 7

threw up here as an assumption is that I’m not 8

expecting that the efficiency improvements are going 9

to increase the installation cost unless they do 10

something to that basic equipment like make it 11

bigger, make it heavier, or unless we start seeing a 12

lot of complicated controls added to it that require 13

a lot of tweaking when you install that equipment. 14

So, requests for comments. We have a 15

number of things, and I think I’m not going to read 16

them, Doug? 17

MR. BROOKMAN: You can read them yourself. 18

Related to typical installation, maintenance and 19

repair cost, typical time period between sale of new 20

product and first maintenance and repairs, typical 21

cycles, and whether and how routine maintenance and 22

repair installation costs will change the products, 23

and if it’s appropriate to assume changes made to 24

repair/installation costs will be negligible for 25Executive Court Reporters (301) 565-0064 185 more efficient products. Comments along those 1

lines? Daryl. 2

MR. ERBS: I’ll start with the last one. 3

I would a gree that there shouldn’t be any 4

significant effect on the maintenance, repair, 5

installation cost. I mean the things I see getting 6

done shouldn’t really have a big effect. I mean 7

there is some routine maintenance for cleaning and 8

sanitizing that occurs o n ice machines, but that’s 9

really just based on environmental factors in terms 10

of how often you have to do that, and really 11

shouldn’t be influenced by the technology. 12

And then the first two items, I guess I -- 13

we’ll have to think about what we can provid e in the 14

way of information to you on that. 15

MR. BROOKMAN: Okay. Thank you. John. 16

MR. BROADBENT: Hi. I agree with Daryl 17

that as far as a more energy efficient machine, I 18

wouldn’t expect it to require any more maintenance 19

than one today. However, as I talked about before, 20

if you reduce the total water consumption rate a 21

lot, you could affect the maintenance frequency. 22

You could easily double it. 23

MR. BROOKMAN: Interesting. Jeff. 24

MR. BIEL: Jeff Biel. Again, the 25Executive Court Reporters (301) 565-0064 186 maintenance can vary greatly, depending on the 1

environmental conditions, water quality, location of 2

ice machine. Typical response would be at least 3

every six months there would be a routine 4

maintenance, but again, that could be every two 5

months, depending on what kind of an area you’re in. 6

So there’s some variability, but I believe six 7

months would be a recommendation. 8

MR. BROOKMAN: I’m scanning back to the 9

list one more time. Do you have any response to the 10

first item, item 3? 8-3? 11

MR. ERBS: My only comment on that is 12

it’ll depend on the type of machine, so whether it’s 13

self contained air, or remote condenser, they have 14

very different installation costs. 15

MR. BROOKMAN: Okay. Okay. 16

MR. ERBS: And so I think, I don’t know, 17

we can try and think about how we can provide some 18

general guidance. And it’s also very segment

-- 19

what kind of building is it going into? 20

MR. BROOKMAN: Let’s move on. 21

MS. MAUER: Doug, can I please ask a -- 22

MR. BROOKMAN: Please, Joanna. 23

MS. MAUER: Just following up on your 24

comment, John, about reducing potable water use 25Executive Court Reporters (301) 565-0064 1 87 significantly and how that could impact maintenance, 1

potentially. I just wondering whether you see today 2

in the field -- I think there’s a relatively large 3

range in water consumption rates for the cube type 4

machines, and whether you see within that range in 5

the market today whether there’s significant 6

variations in maintenance. 7

MR. BROADBENT: John Broadbent. My sense 8

is that all the manufacturers have set their potable 9

water use at a level that keeps them out of trouble, 10

an d so -- because I know that there have been 11

efforts in the past to go below, a lot below where 12

they are today, and that’s where people get into 13

trouble, and they backed off to where they are today 14

at the low end. 15

MS. MAUER: And just to follow up, is -- 16

do you think there’s a significant difference in the 17

water use in the field compared to how they’re 18

tested and rated? 19

MR. BROADBENT: I don’t actually. I think 20

that the tests that we do are pretty representative. 21

As far as water use, they’re pretty rep resentative. 22

MR. BROOKMAN: Thank you. 23

MR. COOKE: Equipment lifetimes. In the 24

press or in the literature, and I’ve listed some of 25Executive Court Reporters (301) 565-0064 188 the sources here, you see a fairly wide range, seven 1

to ten years estimated average life, with kind of a 2

median, mid point of 8.5 years. And this is for a 3

life cycle cost analysis, anyway, a pretty key 4

input . So item 8.7, DOE seeks comments on the 5

appropriate equipment lifetimes for the classes of 6

equipment that we’re covering here. 7

MR. BROOKMAN: So maybe potentially a lot 8

of variation among the classes, or can you comment 9

generally on the lifetimes? Daryl? 10

MR. ERBS : I think that’s a pretty good 11

range and why is there a range? Well, some of it is 12

there’s this variation in duty cycle, so an ice 13

machine that runs a higher percent of the time is 14

going to wear out sooner. I mean it’s just based on 15

that cycling of all those components. There are 16

mechanical parts in there, so -- I don’t think you 17

can really narrow it down much more than that. 18

So it may be that if you make some 19

assumptions around duty cycle, then you’d set the 20

lower life with the higher duty cycle. But based on 21

the information I have, I think that’s fairly 22

accurate. 23

MR. BROOKMAN: Okay. Thank you. Other 24

comments? Agreed? Yeah? John. 25Executive Court Reporters (301) 565-0064 189 MR. BROADBENT: This is John Broadbent. I 1

think seven to ten is what we’ve always said. I’ve 2

seen as low as five and as long as 20. And five may 3

happen if a chain is doing a remodel and they have 4

to make a call, keep it or get rid of it, and 5

they’ll replace it at that point. But it ’s really, 6

kind of for other reasons. And the 20 years, 7

somebody who really doesn’t care how it looks and 8

keeps going with it. 9

MR. BROOKMAN: Okay. 10

SHIPMENTS ANALYSIS 11

MR. COOKE: Shipment analysis. In order 12

to do the national impact analysis, I need to know 13

how many units are we talking about here. We’re 14

talking about total water usage, total energy usage, 15

and the present value. So in this step we’re 16

estimating the number of products that are being 17

shipped in a base case, and in a potential new or 18

amended energy efficiency standards case. 19

So I’ve listed some of the sources of data 20

that we’ve uncovered to date for shipments 21

information. In the base case, we’re asking the 22

question of what would the shipments be without new 23

stan dards? If the market was just left alone, what 24

would they be? And then we have to ask the question 25Executive Court Reporters (301) 565-0064 190 of what, if any, change would occur to shipments if 1

we do impose a standard? 2

So we have some questions here. We’ve 3

already asked for information under item one, but 4

this is critical to this analysis, so I’m going to 5

ask again. DOE’s seeks information on the 6

historical shipments for the ice making equipment 7

for each class, as well as industry trends regarding 8

the relative growth in each class. 9

And then item number two, DOE seeks 10

information on representative saturation rates. 11

One of the things that I really need to be 12

able to know in order to do some of these analyses 13

is, when we’re looking out there in the field at the 14

number of buildings or the amount of commercial 15

floor space, how many ice-makers are out there? How 16

big is this market of machines that currently exists 17

in the market place? 18

MR. LLENZA: This is Charles Llenza. I 19

just want to make -- that’s called the stock, right? 20

MR. COOKE: Yeah, it could be a stock. 21

What’s the saturation out there, the stock that’s 22

out there? 23

And 9.3, we’re looking for information on 24

the potential impacts of these standards on 25Executive Court Reporters (301) 565-0064 191 shipments. 1

MR. BROOKMAN: We’ve already heard from 2

AHRI that they’re going to be working on this. 3

MR. AMRANE: Right. I have an AHRI -- 4

this is Karim Amrane, AHRI. We will provide you the 5

historical shipment data, however we don’t forecast, 6

so just the historical shipment data. 7

MR. BROOKMAN: Can you talk about the 8

stock that’s o ut there? 9

MR. AMRANE: We don’t collect that kind of 10

information, so unless manufacturers have a pretty 11

good idea what it is, maybe we can try through them, 12

but we don’t have that data. 13

MR. BROOKMAN: Okay. Jeff. 14

MR. BIEL: Yes, as far as existing base 15

ice machines, I mean it’s something that we can try 16

to get. Because of our channels -- complicated 17

channels of distribution, it could be a challenge, 18

but I mean it’s something we can make an effort to 19

do. 20

MR. BROOKMAN: Okay. Because of course 21

the stock would rate, have big implications for 22

replacements. So that’s good for them to have it. 23

Okay. Daryl. 24

MR. ERBS: My only comment was going to be 25Executive Court Reporters (301) 565-0064 192 that it is pretty well saturated, there’s not a lot 1

of new construction, especially last couple of 2

yea rs, and maybe things will get a little bit 3

better, but -- so if you just use your average life 4

time and the data from AHRI, that’s going to get you 5

80 percent confidence on what the stock is, because 6

I believe we typically estimate that 70 percent of 7

our s ales are just replacements for units that were 8

already there, and then the rest is a mix of new 9

construction and some new categories. But I think 10

that’s going to be the easiest way to do it. 11

MR. BROOKMAN: Thank you. And Harvey. 12

MR. SACHS : Harvey Sachs. In my 13

experience, Daryl, that last sentence is the 14

critical thing, because that’s shipments with the 15

modifiers, so that you can get the standing stock. 16

So that I think would be very helpful. The 70 17

percent being replacements is what I need with the 18

shipments to get an estimate of stock. Shipments 19

and lifetime. And there are probably some other 20

data sources. 21

I don’t know how often the people like NRA 22

would share, but there are some other industry 23

associations that would tell you how many new 24

restaurant starts there are. 25Executive Court Reporters (301) 565-0064 193 MR. ERBS: Yeah. And there’s some other 1

data sources that you could use to help refine that 2

a bit more. 3

MR. LLENZA: And the Department would 4

appreciate as specific as leads as possible that you 5

can provide the Department in terms of resources, 6

points of contacts, and associations, et cetera. 7

MR. BROOKMAN: Okay. Other comments on 8

this? Yes. 9

MR. BROADBENT: Yes. John Broadbent. A 10

couple of comments. You asked about would we sell 11

more equipment if the efficiency standards are more 12

stringent, and my gut feel is that people won’t buy 13

new ice machines to get a higher efficiency level 14

because typically, the differences are not going to 15

be that great and the equipment might be more 16

expensive. And if it’s mor e expensive, that will 17

also discourage -- and really when you get down to 18

it, sales. Daryl’s point -- sales are driven by 19

replacements, so until their current machine breaks, 20

they’re not really shopping. 21

MR. BROOKMAN: Okay. 22

MR. COOKE: If I can follow up, do you 23

think the standards will change the market? It’s 24

not going to increase it, but will it do anything 25Executive Court Reporters (301) 565-0064 194 else to the market, or is that speculative? 1

MR. BROADBENT: The impact of the 2

California requirements was that basically everybody 3

upped their game to meet the standard. So you could 4

probably expect a similar effect. But I don’t know 5

that it had any effect on sales. 6

MR. BROOKMAN: All the manufacturers 7

increased the efficiency of their product to meet 8

that emerging California standard, right? 9

MR. BROADBENT: Right. 10

MR. BROOKMAN: I see. 11

MR. COOKE: All right. Thank you. One 12

more slide here -- actually we have a couple slides. 13

NATIONAL IMPACT ANALYSIS 14

MR. COOKE: National impact analysis. 15

I’ve actually already talked about this fi rst 16

bullet, which is the NIA seeks to quantify the 17

national energy savings, the national water savings, 18

and net present value. Well, net present value, 19

we’re going to take the number of units that we’re 20

talking about over a 30 year period, starting with 21

t he first year of the standards, and look at the 22

total cost of the efficiency improvements on the up 23

front side, and also the savings, the efficiency 24

savings over time, and bring that back to a present 25Executive Court Reporters (301) 565-0064 195 value and analyze what the net present value of that 1

is

. 2

One key assumption here is -- has to do 3

with rebound effect. If you’ve n ever heard that 4

term, rebound has to do with when you make something 5

more efficient, you’re in essence making it look 6

like it’s less expensive to use it

. S o people, for 7

example, might insulate their house and then realize 8

they don’t have to freeze in the winter and they 9

turn up their thermostat. 10

Because these things are plugged in pretty 11

much all the time, and they run basically when the 12

ice is needed, and because the usage of the ice 13

really isn’t a function of how much it costs to make 14

the ice, it’s really just a function of how much ice 15

do you need, we don’t think rebound effect is a 16

factor here. 17

The NES work will be done in a 18

spreadsheet, as will the life cycle cost work, and 19

that will all be available to you on the DOE 20

website. 21

I think the big thing here is just that 22

the national impact analysis is done at a national 23

level. It’s not really done at a consumer level, so 24

we’ll be using national discount rates that are 25Executive Court Reporters (301) 565-0064 196 prescri bed to us by OMB and we’ll also be adding to 1

the actual end use energy savings, an adjustment to 2

take those savings up to the generation level. So 3

it’s more like how many BTUs are we saving at the 4

upper end of the stream as opposed to at the 5

consumer end. 6

And we have some questions here. Do you 7

think that the rebound effect exists, or is it NA? 8

And then we welcome any comments that you have on 9

the national impact analysis. 10

MR. BROOKMAN: No comments on these? 11

Joanna. 12

MS. MAUER: Joanna Mauer. I think I would 13

agree with your assessment of the rebound effect. I 14

think it would be unlikely that we would see 15

something. 16

MR. BROOKMAN: Okay. So then -- 17

MR. COOKE: Detlef is next to talk about 18

preliminary manufacturer impact analysis. 19

PRELIMINARY MANUFACTURER IMPACT ANALYSIS 20

MR. WESTPHALEN: Everybody asked me what 21

is this chevron doing here that doesn’t connect to 22

anything else. Well, this connects to the NOPR 23

analysis in which there is a manufacturer impact 24

analysis. And the whole point of the manufacturer 25Executive Court Reporters (301) 565-0064 197 impact analysis is to assess the impact of the 1

standards on the manufacturers. And there’s a 2

financial model developed that’s called the GRIM, 3

government regulatory impact model, and uses inputs, 4

a lot of which we’ll collect through the discu ssions 5

with the manufacturers during the interviews in the 6

NOPR phase. 7

However, in the preliminary phase, we have 8

preliminary discussions where we start to try to get 9

some of an understanding, perhaps more qualitative 10

than quantitative of the potential manufacturer 11

impacts. So that’s the last piece of the puzzle 12

here on the preliminary analysis part of the 13

discussion. 14

So here we have questions. DOE seeks 15

comments on the establishment of manufacturers 16

subgroups for automatic commercial ice making 17

equipment, particularly small businesses and niche 18

manufacturers. This is one of the issues that is 19

generally considered as part of the manufacturer 20

impact analysis, whether there should be separate 21

analyses for manufacturer subgroups. 22

And also, what regulations or pending 23

regulations should DOE consider in the analysis of 24

cumulative regulatory burden? This also is one of 25Executive Court Reporters (301) 565-0064 198 the issues investigated in the manufacturer impact 1

analysis. 2

MR. BROOKMAN: Karim. 3

MR. AMRANE: Karim Amrane, AHRI. I guess 4

I’m just

-- second question. Yes, there are pending 5

regulations, for example, commercial refrigeration, 6

you’re going to be starting a new rule and it’s 7

going to impact some manufacturers who are making 8

both products. And there are also, not pending 9

regulations, but there are things looming in the 10

horizon about refrigerant issues and -- that might 11

impact some manufacturers. And some things, we’ve 12

asked DOE in the rulemakings to look at as well, 13

because as there is pressure to get rid of some of 14

the refrigerants that we are using today, they are 15

going to be costs with the new refrigerants that 16

probably need to be factored in in this rulemaking. 17

So something to keep in mind. 18

MR. BROOKMAN: Thank you. Other comments 19

on these two comment boxes? 20

MR. BIEL: Jeff Biel. Not necessarily 21

regulations, but I think the point that was made 22

before with regards to Energy Star and CEE, those 23

become more important in the market place to the 24

consumer and so we just want to make sure that those 25Executive Court Reporters (301) 565-0064 199 are kind of congruent with the actions of DOE. 1

NOPR ANALYSES OVERVIEW 2

MR. WESTPHALEN: Okay. Now I’ve kind of 3

led into the discussion of the NOPR analyses, and we 4

were just at this point, giving an overview of the 5

overall NOPR process here. 6

MR. BROOKMAN: Can you just reference the 7

timeframes for this? 8

MR. WESTPHALEN: The timeframes for the 9

NOPR, if I remember the schedule correctly, the 10

preliminary analysis meeting was September of this 11

year. 12

MR. BROOKMAN: Yeah, it’s on the s lide. 13

I’m sorry. 14

MR. WESTPHALEN: Yeah, slide ... and the 15

NOPR analysis starts -- we’re in the preliminary 16

analysis to the actual publication. So if you look 17

at the timeline on page 18 -- there you go -- on 18, 18

so you’re looking at the preliminary analys is, and 19

that’s planned for July 2011. Then the

-- it goes 20

for almost a year, to the spring or a little bit 21

less, about eight months, to the spring of 2012. 22

So the first thing done as part of the 23

NOPR analysis is to revise the preliminary analyses 24

based on the comments received during the 25Executive Court Reporters (301) 565-0064 200 preliminary analysis public meeting and comment 1

period. And then there are additional NOPR phase 2

analyses that address other issues, life cycle cost, 3

subgroup analysis -- this is looking at perhaps 4

small chain restaurants or something like that that 5

might be affected differentially as compared with 6

other end users. Manufacturer impact analysis, we 7

talked about that. Utility impact analysis, 8

employment impact analysis. Environmental 9

assessment and regulatory impact analyses. 10

And most of these NOPR phase analyses will 11

be conducted by Pacific Northwest National Labs, so 12

if there are particular questions, they might be in 13

a better position to answer them. 14

We have a series of requests for comments 15

that address some of these analyses. I don’t know 16

how deeply we want to go into each of the requests 17

for comment here. They touch on the broad range of 18

the NOPR phase analyses. 19

MR. BROOKMAN: Let’s let them scan 20

through. Please take, just take a moment to scan 21

through this comment box, and see if there’s 22

anything right now that you would like to address. 23

MR. WESTPHALEN: Or need for clarification 24

from the Department at this time. 25Executive Court Reporters (301) 565-0064 201 MR. BROOKMAN: Thank you. (Pause.) A few 1

of you are new to these proceedings, most everyone 2

else here is very familiar with these analytics. 3

There’s a lot of great detail and a little more work 4

that goes in here. 5

MR. LLENZA: This is Charles Llenza, 6

Department of Energy again. I think what’s 7

important too, at t his point in time in the 8

proceedings, which are the framework, is this is 9

kind of the overall plan the Department has and what 10

we’re providing is the scope of what analyses and 11

how we plan to use it, in sort of a very top down 12

approach. 13

So, at this time you don’t have the actual 14

information available, so we’re not expecting 15

comments on that, but we’re expecting comments on 16

the approach. So if there’s anything that we sort 17

of missed overall, that’s what the Department would 18

appreciate comments on. If the re’s something else 19

that we should be looking at in terms of doing our 20

analysis and downstream updating of that analysis. 21

MR. BROOKMAN: Any other co mments on it, 22

in addition to these requests for comments in the 23

box? 24

MR. WESTPHALEN: So now I think I’ m 25Executive Court Reporters (301) 565-0064 202 turning it back over to Charlie to close remarks. 1

OTHER ISSUES 2

MR. BROOKMAN: Let’s provide an 3

opportunity as we said we would, for final closing 4

remarks. Anything additional at this point that any 5

individual wishes to raise? Joanna. 6

MS. MAUER: Joanna Mauer. I just wanted 7

to make a brief comment going back to the test 8

procedures, on the issue of measuring potable water 9

use. And I’m not familiar at this point with the 10

current test procedure, but my understanding is that 11

products are tested with a purged setting in 12

whatever the default setting is, or how the products 13

are shipped by the manufacturer. 14

And then we’ve heard anecdotally that 15

oftentimes installers, I guess to avoid maintenance 16

calls, may install the product with the maximum 17

purge settin g. And so I don’t have any specific 18

recommendations at this point except to just urge 19

DOE to look into this issue and to evaluate whether 20

it might make sense to include, for example, 21

multiple purge settings somehow in the test 22

procedure, just to make sure that the measured water 23

use is actually adequately representing field 24

consumption. 25Executive Court Reporters (301) 565-0064 203 MR. BROOKMAN: Other issues that people 1

need to raise here at the close of this meeting? We 2

covered it sufficiently for now. Okay. 3

Okay. Then, to Charles Llenza. I’m 4

handing out the evaluation forms. Please take a few 5

minutes to fill them out. 6

CLOSING REMARKS 7

MR. LLENZA: Just quickly to go through 8

the last slides here. Slide number 81 is -- here’s 9

how you submit the comments to the Department. The 10

most important part of this to make sure you clearly 11

identified that this is part of the automatic 12

commercial ice making -- ice-maker rulemaking, and 13

then to put the docket number. The room number’s 14

not that important, but the docket number would be 15

critical. 16

Also to remember to provide your comments 17

by January 18, 2011. The Department will surely 18

appreciate if we get all the comments in by then. 19

In addition, the last slide here, I’m 20

providing the points of contacts and the web pages 21

the Department uses. So everything that has been 22

discussed at this proceedings, any corrections to 23

those slides, and any additional information or 24

request for information will be provided by posting 25Executive Court Reporters (301) 565-0064 204 it on the website. 1

And in addition to the people that are 2

attending the webinar, those parties that have sent 3

me an e -mail, I will provide them with the material 4

in advance. But we should be able to find 5

everything at the website within the next week or 6

so. 7

In addition, there is my e-mail and my 8

phone number. I prefer things via e-mail because I 9

like to keep records, especially since these are 10

deliberations over time. I can’t reme mber all the 11

phone calls I get. In addition too, there’s 12

additional point of contact, my supervisor, although 13

he’ll probably defer to me anyhow on this p articular 14

item. 15

I want to thank everybody for attending 16

these proceedings. I also want to provide you that 17

the Department of Energy of itself is having its 18

Christmas party today. The Secretary is sick, but 19

the party is still going -- will be going on and 20

starting at three o’clock in the main cafeteria, and 21

since you missed lunch, if you guys want to hang 22

around for another hour, you could end up just 23

mingling into the party and grabbing some free food 24

and some beverages. 25Executive Court Reporters (301) 565-0064 205 In addition to the fact that it is snowing 1

outside, so we don’t know if we’re going to be 2

trapped here for a few days, whatever. 3

The cafeteria, I think, was closing 4

relatively early today in order to get it prepped up 5

for the party so there is food downstairs for those 6

people that are just starving and need to have 7

something. There’s a Subway stop, and Dunkin 8

Donuts. 9

But if not, if you have other business in 10

the building, want to talk to several people, but 11

feel free to mingle through at three o’clock, you’re 12

all invited, courtesy of the Department, and thank 13

you again for attending today’s meeting. 14

(Whereupon, at 1:48 p.m., the hearing 15

in the above captioned matter was adjourned.) 16

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25Executive Court Reporters (301) 565-0064 206 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